`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`
`
`
`
`
`MICROSOFT CORPORATION AND MICROSOFT MOBILE INC.,
`
`Petitioner,
`
`v.
`
`KONINKLIJKE PHILIPS N.V.,
`
`Patent Owner.
`
`
`
`
`
`
`
`Case IPR2017-01766
`Patent No. RE44,913
`
`
`
`
`
`
`
`
`
`
`
`
`
`PETITIONER'S MOTION FOR PRO HAC VICE ADMISSION
`UNDER 37 C.F.R. § 42.10(c)
`
`
`
`
`
`
`
`
`
`
`PTAB Case No. IPR2017-01766, Patent No. RE44,913
`Petitioner's Motion for Pro Hac Vice Admission
`
`
`
`
`Petitioners Microsoft Corporation and Microsoft Mobile Inc. (collectively
`
`“Petitioner”) respectfully request that the Board admit Chad S. Campbell as
`
`backup counsel pro hac vice in this proceeding. Mr. Campbell is an experienced
`
`litigation attorney and has substantial knowledge in the substantive issues of the
`
`invalidity of the challenged claims of the Patent in this proceeding. Therefore, Mr.
`
`Campbell meets the requirements of “an experienced litigating attorney and has an
`
`established familiarity with the subject matter at issue in the proceeding” under 37
`
`C.F.R. §42.10(c).
`
`1. Time For Filing
`
`
`
`This Motion for Pro Hac Vice Admission has been authorized by the Notice
`
`of Filing Date Accorded to Petition and Time for Filing Patent Owner Preliminary
`
`Response that was mailed on July 21, 2017 (Paper 4). This Motion is filed no
`
`sooner than twenty one (21) days after service of the petition.
`
`2.
`
`Statement of Facts
`
`
`
`In this proceeding, lead counsel for Petitioner is Christina McCullough, a
`
`registered practitioner. The following statement of facts shows that there is good
`
`cause for the Board to admit Mr. Campbell pro hac vice.
`
`
`
`Mr. Campbell is a patent litigation attorney with more than 23 years of
`
`experience representing clients in cases involving semiconductor technology,
`
`1
`
`
`
`PTAB Case No. IPR2017-01766, Patent No. RE44,913
`Petitioner's Motion for Pro Hac Vice Admission
`computer design and software. (Affidavit of Chad S. Campbell (“Campbell
`
`Affidavit”), ¶ 8 in attached Exhibit 1029.)
`
`
`
`Mr. Campbell regularly litigates patent cases in various forums including
`
`the United States Court of Appeals for the Federal Circuit and various federal
`
`district courts. (Id.) He has experience representing clients in many phases of
`
`litigation including discovery, Markman hearings, jury trials, and appeals. (Id.)
`
`
`
`Mr. Campbell has an established familiarity with the subject matter at issue
`
`in this proceeding, having represented Petitioner in a court proceeding against
`
`Patent Owner involving the same technology (Koninklijke Philips N.V. et al. v.
`
`Acer Inc. et al., Case No. 1:15-cv-01170-GMS (D. Del.); Koninklijke Philips N.V.
`
`et al. v. Asustek Computer Inc. et al., Case No. 1:15-cv-01125-GMS (D. Del.);
`
`Koninklijke Philips N.V. et al. v. Double Power Technology, Inc. et al., Case No.
`
`1:15-cv-01130-GMS (D. Del.); Koninklijke Philips N.V. et al. v. Visual Land, Inc.,
`
`Case No. 1:15-cv-01127-gms (D. Del.); Koninklijke Philips N.V. et al. v. Yifang
`
`USA, Inc., Case No. 1:15-cv-01131-GMS (D. Del.)).
`
`
`
`Mr. Campbell is familiar with the technologies and issued claims in the
`
`6,522,695, 7,529,806 and RE44,913 Patents. Mr. Campbell is also familiar with
`
`the prior art references cited in PTAB Case Nos. IPR2017-00890, IPR2017-01754
`
`and IPR2017-01766 and the associated invalidity grounds before the PTAB.
`
`
`
`2
`
`
`
`PTAB Case No. IPR2017-01766, Patent No. RE44,913
`Petitioner's Motion for Pro Hac Vice Admission
`3. Affidavit or Declaration of Individual Seeking to Appear
`
`
`
`This Motion for Pro Hac Vice Admission is accompanied by an Affidavit of
`
`Mr. Campbell (Exhibit 1029), which attests to the requirements for pro hac vice
`
`admission set forth in IPR2013-00639, Paper 7, dated Oct. 15, 2013.
`
`4. Conclusion
`
`
`
`Accordingly, Petitioners submit that there is good cause under 37 C.F.R.
`
`§ 42.10(c) for the Board to admit Chad S. Campbell as counsel pro hac vice and to
`
`authorize Mr. Campbell to represent Petitioner as back-up counsel in this
`
`proceeding.
`
`
`
`
`
`Dated: September 7, 2017
`
`
`
`
`
`
`Perkins Coie LLP
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101-3099
`(206) 359-8000
`
`
`
`
`
`
`Respectfully submitted,
`
` /Christina McCullough/
`Lead Counsel
`Christina J. McCullough, Reg. No. 58,720
`
`Back-Up Counsel
`Chad S. Campbell, Pro Hac Vice
`
`Attorneys for Microsoft Corporation and
`Microsoft Mobile Inc.
`
`3
`
`
`
`
`
`
`
`PTAB Case No. IPR2017-01766, Patent No. RE44,913
`Petitioner's Motion for Pro Hac Vice Admission
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true copy of the foregoing
`
`PETITIONER'S MOTION FOR PRO HAC VICE ADMISSION UNDER 37
`
`C.F.R. § 42.10(c) and Exhibit 1029 were served in its entirety this 7th day of
`
`September, 2017 by electronic mail on the Patent Owner via its attorneys of
`
`record:
`
`Justin J. Oliver, Reg. No. 44,986
`Jason Dorsky, Reg. No. 64,710
`PhilipsIPR@fchs.com
`
`
`
`Dated: September 7, 2017
`
`
`
`
`
`
`Perkins Coie LLP
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101-3099
`(206) 359-8000
`
`
`
`
`Respectfully submitted,
`
` /Christina McCullough/
`Lead Counsel
`Christina J. McCullough, Reg. No. 58,720
`
`Back-Up Counsel
`Chad S. Campbell, Pro Hac Vice
`
`Attorneys for Microsoft Corporation and
`Microsoft Mobile Inc.
`
`1
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
