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`Paper No. __
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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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`TAIWAN SEMICONDUCTOR MANUFACTURING CO., LTD,
`Petitioner,
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`v.
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`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`_____________
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`Case No. IPR2017-018431
`Patent No. 7,893,501
`_____________
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`PATENT OWNER’S MOTION TO WITHDRAW
`COUNSEL
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`1 Case IPR2017-01844 has been consolidated with this proceeding.
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`6827476.1
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`I.
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`STATEMENT OF RELIEF REQUESTED
`Pursuant to 37 C.F.R. § 42.10(e) and the Board’s December 13, 2018 email
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`authorizing this motion, Godo Kaisha IP Bridge 1 (“Patent Owner”) respectfully
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`requests that the Patent Trial and Appeal Board (“the Board”) authorize the
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`withdrawal of Joshua J. Miller as Backup Counsel in this matter.
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`II.
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`STATEMENT OF FACTS SHOWING GOOD CAUSE FOR THE
`BOARD TO AUTHORIZE WITHDRAWAL OF COUNSEL
`In December 2018, Joshua J. Miller will leave the law firm of Wolf
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`Greenfield & Sacks, P.C. Patent Owner therefore requests that Mr. Miller be
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`permitted to withdraw from the current proceeding.
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`No changes to the schedule would be required based on the change in
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`counsel. Further, Patent Owner will continue to be represented by a lead counsel
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`and at least one back up counsel who can conduct business on behalf of the lead
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`counsel in compliance with 37 C.F.R. § 42.10(a). Updated Mandatory Notices
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`under 37 C.F.R. §42.8(a)(3) are being filed concurrently with this motion.
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`III. REASONS FOR RELIEF REQUESTED
`“Counsel may not withdraw from a proceeding before the Board unless the
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`Board authorizes such withdrawal.” 37 C.F.R. § 42.10(e). Given Mr. Miller’s
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`upcoming departure from Wolf Greenfield & Sacks, P.C., it is appropriate to allow
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`Mr. Miller to withdraw from the proceeding.
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`1
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`Petitioner has been consulted and has indicated it does not object to Mr.
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`Miller’s withdrawal. Thus, Patent Owner believes that granting this motion will not
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`hinder the economy, the integrity of the patent system, the efficient administration
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`of the Office, or the ability of the Office to timely complete this proceeding. See 35
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`U.S.C. § 316(b).
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`IV. CONCLUSION
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`Patent Owner respectfully requests that the Board grant their motion to
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`authorize the withdrawal of Mr. Miller as Backup Counsel for Patent Owner in
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`IPR2017-01843.
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`Dated: December 18, 2018
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`Respectfully submitted,
`Godo Kaisha IP Bridge 1
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`By /Gerald B. Hrycyszyn/
`Gerald B. Hrycyszyn, Reg No. 50,474
`Edmund J. Walsh, Reg No. 32,950
`Richard F. Giunta, Reg No. 36,149
`WOLF GREENFIELD & SACKS, P.C.
`600 Atlantic Ave. Boston, MA 02210
`Tel: 617-646-8000/Fax: 617-646-8646
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`2
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
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`I certify that on December 18, 2018, I will cause a copy of the foregoing
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`document, including any exhibits or appendices referred to therein, to be served via
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`electronic mail, as previously consented to by Petitioner, upon the following
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`counsel of record:
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`David L. Cavanaugh
`Dominic E. Massa
`Michael H. Smith
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`Date: December 18, 2018
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`David.Cavanaugh@wilmerhale.com
`Dominic.Massa@wilmerhale.com
`MichaelH.Smith@wilmerhale.com
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`/Faye E. Miller/
`Faye E. Miller
`Paralegal
`WOLF GREENFIELD & SACKS, P.C.
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