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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MICROSOFT CORPORATION AND MICROSOFT MOBILE INC.,
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`Petitioner,
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`v.
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`KONINKLIJKE PHILIPS N.V.,
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`Patent Owner.
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`Case IPR2017-01766
`Patent No. RE44,913
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`PETITIONER'S MOTION FOR PRO HAC VICE ADMISSION
`UNDER 37 C.F.R. § 42.10(c)
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`PTAB Case No. IPR2017-01766, Patent No. RE44,913
`Petitioner's Motion for Pro Hac Vice Admission
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`Petitioners Microsoft Corporation and Microsoft Mobile Inc. (collectively
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`“Petitioner”) respectfully request that the Board admit Chad S. Campbell as
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`backup counsel pro hac vice in this proceeding. Mr. Campbell is an experienced
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`litigation attorney and has substantial knowledge in the substantive issues of the
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`invalidity of the challenged claims of the Patent in this proceeding. Therefore, Mr.
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`Campbell meets the requirements of “an experienced litigating attorney and has an
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`established familiarity with the subject matter at issue in the proceeding” under 37
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`C.F.R. §42.10(c).
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`1. Time For Filing
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`This Motion for Pro Hac Vice Admission has been authorized by the Notice
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`of Filing Date Accorded to Petition and Time for Filing Patent Owner Preliminary
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`Response that was mailed on July 21, 2017 (Paper 4). This Motion is filed no
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`sooner than twenty one (21) days after service of the petition.
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`2.
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`Statement of Facts
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`In this proceeding, lead counsel for Petitioner is Christina McCullough, a
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`registered practitioner. The following statement of facts shows that there is good
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`cause for the Board to admit Mr. Campbell pro hac vice.
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`Mr. Campbell is a patent litigation attorney with more than 23 years of
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`experience representing clients in cases involving semiconductor technology,
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`1
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`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
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`Affidavit”), ¶ 8 in attached Exhibit 1029.)
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`Mr. Campbell regularly litigates patent cases in various forums including
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`the United States Court of Appeals for the Federal Circuit and various federal
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`district courts. (Id.) He has experience representing clients in many phases of
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`litigation including discovery, Markman hearings, jury trials, and appeals. (Id.)
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`Mr. Campbell has an established familiarity with the subject matter at issue
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`in this proceeding, having represented Petitioner in a court proceeding against
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`Patent Owner involving the same technology (Koninklijke Philips N.V. et al. v.
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`Acer Inc. et al., Case No. 1:15-cv-01170-GMS (D. Del.); Koninklijke Philips N.V.
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`et al. v. Asustek Computer Inc. et al., Case No. 1:15-cv-01125-GMS (D. Del.);
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`Koninklijke Philips N.V. et al. v. Double Power Technology, Inc. et al., Case No.
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`1:15-cv-01130-GMS (D. Del.); Koninklijke Philips N.V. et al. v. Visual Land, Inc.,
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`Case No. 1:15-cv-01127-gms (D. Del.); Koninklijke Philips N.V. et al. v. Yifang
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`USA, Inc., Case No. 1:15-cv-01131-GMS (D. Del.)).
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`Mr. Campbell is familiar with the technologies and issued claims in the
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`6,522,695, 7,529,806 and RE44,913 Patents. Mr. Campbell is also familiar with
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`the prior art references cited in PTAB Case Nos. IPR2017-00890, IPR2017-01754
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`and IPR2017-01766 and the associated invalidity grounds before the PTAB.
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`2
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`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
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`This Motion for Pro Hac Vice Admission is accompanied by an Affidavit of
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`Mr. Campbell (Exhibit 1029), which attests to the requirements for pro hac vice
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`admission set forth in IPR2013-00639, Paper 7, dated Oct. 15, 2013.
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`4. Conclusion
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`Accordingly, Petitioners submit that there is good cause under 37 C.F.R.
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`§ 42.10(c) for the Board to admit Chad S. Campbell as counsel pro hac vice and to
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`authorize Mr. Campbell to represent Petitioner as back-up counsel in this
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`proceeding.
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`Dated: September 7, 2017
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`Perkins Coie LLP
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101-3099
`(206) 359-8000
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`Respectfully submitted,
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` /Christina McCullough/
`Lead Counsel
`Christina J. McCullough, Reg. No. 58,720
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`Back-Up Counsel
`Chad S. Campbell, Pro Hac Vice
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`Attorneys for Microsoft Corporation and
`Microsoft Mobile Inc.
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`3
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`PTAB Case No. IPR2017-01766, Patent No. RE44,913
`Petitioner's Motion for Pro Hac Vice Admission
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true copy of the foregoing
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`PETITIONER'S MOTION FOR PRO HAC VICE ADMISSION UNDER 37
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`C.F.R. § 42.10(c) and Exhibit 1029 were served in its entirety this 7th day of
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`September, 2017 by electronic mail on the Patent Owner via its attorneys of
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`record:
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`Justin J. Oliver, Reg. No. 44,986
`Jason Dorsky, Reg. No. 64,710
`PhilipsIPR@fchs.com
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`Dated: September 7, 2017
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`Perkins Coie LLP
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101-3099
`(206) 359-8000
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`Respectfully submitted,
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` /Christina McCullough/
`Lead Counsel
`Christina J. McCullough, Reg. No. 58,720
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`Back-Up Counsel
`Chad S. Campbell, Pro Hac Vice
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`Attorneys for Microsoft Corporation and
`Microsoft Mobile Inc.
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