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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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`SAMSUNG ELECTRONICS CO, LTD.,
`Petitioner
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`v.
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`JAMES B. GOODMAN,
`Patent Owner.
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`__________________________
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`Case IPR2017-02021
`U.S. Patent No. 6,243,315
`__________________________
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`PETITIONER’S MOTION FOR PRO HAC VICE ADMISSION
`PURSUANT TO 37 C.F.R. § 42.10(C)
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`I.
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`INTRODUCTION
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`Petitioner’s Motion for Pro Hac Vice Admission
`Proceeding No.: IPR2017-02021
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`Pursuant to 37 C.F.R. § 42.10(c), Petitioner Samsung Electronics America,
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`Inc. (“Petitioner” or “SEA”) respectfully requests that the Board recognize
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`Anthony G. Beasley as counsel pro hac vice in this proceeding. Petitioner’s lead
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`counsel in this proceeding is a registered practitioner and, as illustrated below, Mr.
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`Beasley is an experienced litigator with an established familiarity with this
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`proceeding’s subject matter. Thus, there is good cause for the Board to recognize
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`Mr. Beasley pro hac vice in this proceeding. 37 C.F.R. § 42.10(c).
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`II. TIME FOR FILING
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`This Motion for Pro Hac Vice Admission is being filed no sooner than
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`twenty one (21) days after service of the petition (Unified Patents, Inc. v. Parallel
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`Iron, LLC, Case IPR 2013-00639, Paper No. 7 (PTAB Oct. 15, 2013).)
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`III. STATEMENT OF FACTS
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`This Motion is authorized by the Notice of Filing Date Accorded to Petition
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`and Time for Filing Patent Owner Preliminary Response that was mailed on
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`September 13, 2017 (Paper No. 3). Petitioner’s lead and back-up counsel are
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`registered petitioners.
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`Where lead counsel is a registered practitioner, the Board may permit a non-
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`registered practitioner to appear pro hac vice “upon a showing that counsel is an
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`experienced litigating attorney and has established familiarity with the subject
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`matter at issue in the proceeding.” 37 C.F.R. §42.10(c); Unified Patents, Case
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`Petitioner’s Motion for Pro Hac Vice Admission
`Proceeding No.: IPR2017-02021
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`IPR2013-00639 (Paper 7) (setting forth requirements for pro hac vice admission).
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`As set forth in his Declaration submitted herewith (Ex. Samsung 1013), Mr.
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`Beasley is an experienced litigator. He is a Counsel with O’Melveny & Myers
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`LLP with over nine years’ experience representing clients in patent and technology
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`related litigation including matters involving similar technology to that at issue in
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`this proceeding. Mr. Beasley has argued complex claim construction and
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`invalidity issues at the district court level.
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`Mr. Beasley is also familiar with the subject matter of this proceeding. He is
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`lead counsel for Petitioner in the underlying district court litigation on the patent at
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`issue in this Inter Partes Review proceeding, U.S. Patent No. 6,243,315 (“’315
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`Patent”). As such, he has reviewed and analyzed the ’315 Patent, its file history,
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`previous proceedings involving the same patent, filings from other district court
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`litigations involving the same patent, and the prior art being asserted in this
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`proceeding. He has also advised Petitioner regarding claim construction positions
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`for both the district court litigation and this proceeding. Mr. Beasley has also been
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`involved in preparing the petition for Inter Partes Review submitted in this
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`proceeding, including working with Dr. Wolfe, the petitioner’s expert declarant.
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`Based on his work in the underlying litigation, involvement with the petition
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`in this proceeding, and the other facts detailed in his declaration, Mr. Beasley has
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`significant familiarity with the subject matter in this proceeding. Petitioner wishes
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`Petitioner’s Motion for Pro Hac Vice Admission
`Proceeding No.: IPR2017-02021
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`to apply Mr. Beasley’s knowledge of the patent and litigation experience by
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`employing him as counsel in this proceeding. Admission of Mr. Beasley pro hac
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`vice will enable Petitioner to avoid unnecessary expense and duplication of work in
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`this proceeding and between it and the co-pending litigation. Because Mr. Beasley
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`is an experienced practitioner with an established familiarity with the subject
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`matter of this proceeding, Petitioner respectfully submits that there is good cause
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`under 37 C.F.R. § 42.10(c) to recognize Mr. Beasley as counsel pro hac vice
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`during this proceeding.
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`IV. DECLARATION OF INDIVIDUAL SEEKING TO APPEAR
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`This Motion for pro hac vice admission is supported by the accompanying
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`Declaration of Anthony G. Beasley (Ex. Samsung 1013), as required by Unified
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`Patents, Case IPR2013-00639, Paper 7.
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`Date: September 21, 2017
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`Respectfully submitted,
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`
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`/s/ Xin-Yi Zhou
`Xin-Yi Zhou (Reg. No. 63,366)
`O’Melveny & Myers LLP
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`
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`Petitioner’s Motion for Pro Hac Vice Admission
`Proceeding No.: IPR2017-02021
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`PETITIONER’S UPDATED LIST OF EXHIBITS
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`Samsung 1006
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`Description
`Exhibit No.
`Samsung 1001 U.S. Patent No. 6,243,315 (“the ’315 Patent”)
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`Samsung 1002 Declaration of Dr. Andrew Wolfe in Support of Samsung
`Electronics America, Inc.’s Petition for Inter Partes Review of
`U.S. Patent No. 6,243,315
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`Samsung 1003 Curriculum Vitae of Dr. Andrew Wolfe
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`Samsung 1004 U.S. Patent No. 6,327,664 (“Dell”)
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`Samsung 1005 U.S. Patent No. 5,590,082 (“Abe”)
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`JESD21-C: JEDEC Configurations for Solid State Memories,
`Release 7 (“JESD21-C”)
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`Samsung 1007 Declaration of John R. Kelly Regarding Records of JEDEC
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`Samsung 1008 U.S. Patent No. 6,172,928 (“Ooishi”)
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`Samsung 1009 U.S. Patent No. 6,144,219 (“Palaniswami”)
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`Samsung 1010 Micron MT48LC4M4R1(S) Functional Specification
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`Samsung 1011 Micron MT48LC4M4A1/A2 S Datasheet
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`Samsung 1012 U.S. Patent No. 4,005,394 (“Fosler”)
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`Samsung 1013 Declaration of Anthony G. Beasley in Support of Petitioner’s
`Motion for Pro Hac Vice Admission
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`Petitioner’s Motion for Pro Hac Vice Admission
`Proceeding No.: IPR2017-02021
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`CERTIFICATE OF SERVICE
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`I hereby certify that on September 21, 2017, I caused a true and correct copy
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`of the foregoing materials:
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`• Petitioner’s Motion for Pro Hac Vice Admission Pursuant to 37 C.F.R. §
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`42.10(c) and
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`• Exhibit Samsung 1013, Declaration of Anthony G. Beasley in Support of
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`Petitioner’s Motion for Pro Hac Vice Admission
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`to be served via Express Mail or an equivalent service on the Patent Owner at the
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`following correspondence address of record:
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`David Fink
`7519 Apache Plume Drive
`Houston, TX 77071
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`/s/ Xin-Yi Zhou
`Xin-Yi Zhou (Reg. No. 63,366)
`O’Melveny & Myers LLP
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