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`Filed: January 9, 2018
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`Filed on behalf of: KVK-Tech, Inc.
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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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`____________________
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`KVK-Tech, Inc.
`Petitioner
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`v.
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`Shire PLC
`Patent Owner
`
`____________________
`
`Case IPR2017-00293
`U.S. Patent No. 9,173,857
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`____________________
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`PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE OF
`THOMAS HEDEMANN
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`I.
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`Statement of Precise Relief Requested
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`Pursuant to 37 C.F.R. § 42.l0(c), Petitioner KVK-Tech, Inc. requests that the
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`Patent Trial and Appeal Board (the “Board”) admit Thomas Hedemann pro hac
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`vice in this proceeding, IPR2017-00293.
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`II.
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`Statement of Facts Showing Good Cause for the Board to Recognize
`Counsel Pro Hac Vice During this Proceeding
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`In accordance with 37 C.F.R. § 42.l0(c), the Board may recognize counsel
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`pro hac vice during a proceeding upon a showing of good cause, subject to the
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`condition that lead counsel be a registered practitioner and to any other conditions
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`the Board may impose. Section 42.10(c) indicates that, “where lead counsel is a
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`registered practitioner, a motion to appear pro hac vice by counsel who is not a
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`registered practitioner may be granted upon a showing that counsel is an
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`experienced litigating attorney and has an established familiarity with the subject
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`matter at issue in the proceeding.” The facts here establish good cause for the Board
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`to recognize Mr. Hedemann pro hac vice in this proceeding.
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`1. Lead counsel, Jonathan A. Harris, is a registered practitioner. Back-up counsel,
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`James T. Evans is also a registered practitioner.
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`2. Mr. Hedemann is an experienced litigator who has an established familiarity
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`with the subject matter at issue in the proceeding. Accompanying this motion as
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`Exhibit 1042 is the Declaration of Thomas Hedemann in Support of Motion for
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`Admission Pro Hac Vice (“Hedemann Decl.”). In his declaration, Mr. Hedemann
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`asserts:
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`I am a member in good standing in the Connecticut Bar and am admitted to
`practice before the U.S. District Court of Connecticut. I am also admitted to
`practice before the U.S. Court of Appeals for the Federal Circuit and the U.S.
`Supreme Court.
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`Hedemann Decl. ¶ 3 (Ex. 42). Mr. Hedemann also demonstrates that he has a detailed
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`working knowledge of the relevant subject matter through his participation in prior
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`proceedings involving amphetamine salts and Adderall® formulations as a result of
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`participation as counsel in prior amphetamine salt-related patent cases. Id. ¶ 10.
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`3. In his declaration, Mr. Hedemann also attests to each of the listed items
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`required by the Order – Authorizing Motion for Pro Hac Vice Admission – 37 C.F.R.
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`§ 42.10 in IPR2013-00639. See Hedemann Decl. ¶¶ 1-10 (Ex. 42). Mr. Hedemann
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`attests that he has read and will comply with the Office Patent Trial Practice Guide
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`and the Board's Rules of Practice for Trials set forth in 35 C.F.R. § 42. Id. ¶ 7. Mr.
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`Hedemann further attests that he agrees to be subject to the United States Patent and
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`Trademark Office's Rules of Professional Conduct as set forth in 37 C.F.R. §§ 11.101
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`et seq. and disciplinary jurisdiction under 37 C.F.R. § 1 l.19(a). Id. ¶ 8.
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`III. Conclusion
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`For the foregoing reasons, Petitioner respectfully requests that the Board
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`admit Mr. Hedemann pro hac vice in this proceeding.
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`Date: January 9, 2018
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`Respectfully submitted,
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`By: /s/ Jonathan A. Harris
` Jonathan A. Harris
` James T. Evans
` Axinn, Veltrop & Harkrider LLP
` Counsel for Petitioner,
` KVK-Tech, Inc.
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`
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`Case No. IPR2018-00293
`Petitioner’s Motion for Admission Pro Hac Vice of Thomas Hedemann
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.6(e)(4) and 42.105, the undersigned certifies
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`that a true and correct copy ot this document (Petitioner's Motion for
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`Admission Pro Hac Vice of Thomas Hedemann), and every Exhibit filed with
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`this document, were served electronically via email on January 9, 2018, in its
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`entirety on the following:
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`Joseph R. Robinson
`Troutman Sanders LLP
`875 Third Avenue
`New York, NY 10022
`joseph.robinson@troutmansanders.com
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`Dustin B. Weeks
`Troutman Sanders LLP
`Bank of America Plaza
`600 Peachtree Street NE, Suite 5200
`Atlanta, GA 30308-2231
`dustin.weeks@troutmansanders.com
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`Robert Schaffer
`Troutman Sanders LLP
`875 Third Avenue
`New York, NY 10022
`robert.schaffer@troutmansanders.com
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`Patent Owner has consented to electronic service.
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`/s/ James T. Evans
` James T. Evans
` Reg. No. 64,377
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