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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`___________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
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`
`ZTE (USA) INC.,
`SAMSUNG ELECTRONICS CO., LTD.
` AND SAMSUNG ELECTRONICS AMERICA, INC.,
`Petitioners,
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`
`v.
`
`
`FUNDAMENTAL INNOVATION SYSTEMS INTERNATIONAL LLC,
`Patent Owner.
`
`___________________
`
`IPR2018-00111
`Patent No. 8,624,550
`___________________
`
`
`
` FUNDAMENTAL INNOVATION SYSTEMS INTERNATIONAL LLC'S
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF
`JASON S. SHEASBY UNDER 37 C.F.R. § 42.10(C)
`
`
`
`Mail Stop "PATENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`10456690
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`Case IPR2018-00111
`Patent 8,624,550
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`
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`I.
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`RELIEF REQUESTED
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`Pursuant to 37 C.F.R. § 42.10(c) and the Board's "Order Authorizing Motion
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`for Pro Hac Vice Admission – 37 C.F.R. § 42.10(c)," in Case IPR2013-00639,
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`Paper 7, entered October 15, 2013, incorporated by Paper 8 in the present case,
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`Patent Owner Fundamental Innovation Systems International LLC, ("Fundamental
`
`Innovation"), by and through its attorneys, respectfully requests that the Board admit
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`Jason G. Sheasby pro hac vice in this proceeding.
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`II.
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`GOVERNING LAW, RULES, AND PRECEDENT
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`Section 42.10(c) states as follows:
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`The Board may recognize counsel pro hac vice during a
`proceeding upon a showing of good cause, subject to the
`condition that lead counsel be a registered practitioner and
`to any other conditions as the Board may impose. For
`example, where the lead counsel is a registered
`practitioner, a motion to appear pro hac vice by counsel
`who is not a registered practitioner may be granted upon
`showing that counsel is an experienced litigating attorney
`and has an established familiarity with the subject matter
`at issue in the proceeding.
`
`III.
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`STATEMENT OF FACTS
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`Based on the following statement of facts, and supported by the Declaration
`
`of Jason G. Sheasby submitted herewith, Fundamental Innovation submits that a
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`Case IPR2018-00111
`Patent 8,624,550
`showing of good cause has been made and respectfully requests the pro hac vice
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`
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`
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`admission of Jason G. Sheasby in this proceeding:
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`1.
`
`Patent Owner’s lead counsel, Hong Zhong, is a registered practitioner
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`(Reg. No. 66,530). First back-up counsel, Michael R. Fleming, is also
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`a registered practitioner (Reg. No. 67,933).
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`2. Mr. Sheasby is a Partner at the law firm of Irell & Manella LLP.
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`3. Mr. Sheasby is an experienced litigating attorney and has been
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`litigating cases relating to patents for over 17 years.
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`4. Mr. Sheasby is a member in good standing of the California State Bar.
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`5. Mr. Sheasby has never been suspended or disbarred from practice
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`before any court or administrative body.
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`6.
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`No application filed by Mr. Sheasby for admission to practice before
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`any court or administrative body has ever been denied.
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`7.
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`No sanctions or contempt citations have been imposed against Mr.
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`Sheasby by any court or administrative body.
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`8. Mr. Sheasby has read and agrees to comply with the Office Patent Trial
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`Practice Guide and the Board’s Rules of Practice for Trials set forth in
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`part 42 of the C.F.R.
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`Case IPR2018-00111
`Patent 8,624,550
`9. Mr. Sheasby understands that he will be subject to the USPTO Rules of
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`Professional Conduct 37 C.F.R. §§ 11.101 et seq. and disciplinary
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`jurisdiction under 37 C.F.R. § 11.19(a).
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`10. Mr. Sheasby has appeared and been granted pro hac vice admission in
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`three inter partes reviews (IPR2012-00033, IPR2013-00242, and
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`IPR2014-001567) before the United States Patent and Trademark
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`Office.
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`11. Mr. Sheasby has an established familiarity with the subject matter at
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`issue in this proceeding. Mr. Sheasby has acquired substantial
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`understanding of the underlying legal and technological issues at stake
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`in related proceedings. Patent Owner has expended significant time and
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`resources with Mr. Sheasby and wishes to continue using Mr. Sheasby
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`as counsel in this proceeding as appropriate.
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`
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`IV.
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`GOOD CAUSE EXISTS FOR PRO HAC VICE ADMISSION OF
`JASON G. SHEASBY
`
`The facts outlined above in the Statement of Facts, and contained in the
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`Declaration of Jason G. Sheasby (Ex. 2007), establish that there is good cause to
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`admit Mr. Sheasby pro hac vice in this proceeding under 37 C.F.R. § 42.10. Patent
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`Owner's lead counsel and first back-up counsel are registered practitioners. Mr.
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`Case IPR2018-00111
`Patent 8,624,550
`Sheasby is an experienced litigating attorney and has an established familiarity with
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`the subject matter at issue.
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`V.
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`NO OPPOSITION TO THEIR MOTION
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`Patent Owner has conferred with Petitioner with regard to its Motion, and
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`Petitioner confirmed that it would not oppose the motion.
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`
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`VI.
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`CONCLUSION
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`In light of the foregoing, Patent Owner respectfully requests that the Board
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`admit Jason G. Sheasby pro hac vice in their proceeding.
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`
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`Dated: February 27, 2018
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`Respectfully submitted,
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`/s/ Hong Zhong
`
`
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`
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`IRELL & MANELLA LLP
`Hong Zhong, Reg. No. 66,530
`1800 Avenue of the Stars, Ste. 900
`Los Angeles CA 90067
`Tel: (310) 203-7183
`Fax: (310) 556-5385
`
`Attorneys for Patent Owner,
`Fundamental Innovation Systems International LLC
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`Case IPR2018-00111
`Patent 8,624,550
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6, the undersigned certifies that on February 27,
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`
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`2018, a copy of the foregoing document "FUNDAMENTAL INNOVATION
`
`SYSTEMS INTERNATIONAL LLC'S AMENDED UNOPPOSED MOTION
`
`FOR PRO HAC VICE ADMISSION OF JASON G. SHEASBY UNDER 37
`
`C.F.R. § 42.10(C)" was served by electronic mail, as agreed to by the parties, upon
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`the following:
`
`
`Charles M. McMahon
`Hersh H. Mehta
`Gregory S. Arovas
`Robert A. Appleby
`Todd M. Friedman
`Eugene Goryunov
`Alan Rabinowitz
`cmcmahon@mwe.com
`hmehta@mwe.cm
`greg.arovas@kirkland.com
`robert.appleby@kirkland.com
`todd.friedman@kirkland.com
`eugene.gorvunov@kirkland.com
`alan.rabinowitz@kirkland.com
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`/s/Susan M. Langworthy/
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