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`Trials@uspto.gov
`571-282-7822
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`Paper No.
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GARMIN INTERNATIONAL, INC. AND GARMIN USA,
`INC.,
`Petitioner
`
`v.
`
`LOGANTREE, LP,
`Patent Owner
`
`Case IPR2018-00565
`
`Patent 6,059,576
`
`Before Lawrence J. Banks, Trial Paralegal
`
`PATENT OWNER’S MOTION FOR
`ADMISSION PRO HAC VICE OF ARNOLD
`SHOKOUHI PURSUANT TO 37 C.F.R. §42.10
`
`
`
`I.
`
`
`RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. §42.10 and the Board’s “Order Authorizing Motion for Pro Hac Vice
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`Admission – 37 C.F.R. §42.10,” entered December 5, 2012, Patent Owner LoganTree, LP, requests
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`that the Board admit Arnold Shokouhi pro hac vice in this proceeding.
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`II.
`
`STATEMENT OF FACTS
`
`Pursuant to 37 C.F.R. §42.10(c), the Board
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`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.
`
`37 C.F.R. §42.10(c). The facts, supported by the attached Declaration of Arnold Shokouhi in Support
`
`of Motion for Admission Pro Hac Vice (“Shokouhi Decl.”), establish good cause to admit Mr.
`
`Shokouhi pro hac vice in this proceeding.
`
`1.
`
`Lead counsel Christopher M. Barkley is a registered practitioner and is
`
`experienced in proceedings before the Board.
`
`2.
`
`Arnold Shokouhi is an experienced litigating attorney who serves
`
`McCathern, PLLC, as its firm-wide Managing Partner. (Shokouhi Decl. ¶ 1.) Mr. Shokouhi has
`
`been a litigating attorney for more than 11 years and has been litigating patent cases for at least 7
`
`years. (Id. ¶ 2-3.) Mr. Shokouhi is a member in good standing of the Texas State Bar and the
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`California State Bar, with no suspensions or disbarments from practice, nor any application for
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`admission to practice denied, and is admitted to practice in each of the United States District Courts
`
`for the states of Texas and California. (Id. ¶ 4-5.)
`
`
`
`2
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`
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`3.
`
`Mr. Shokouhi has familiarity with the subject matter at issue in this proceeding
`
`based on his work as counsel in the pending district court case LoganTree LP, vs. Garmin
`
`International, Inc., and Garmin USA, Inc., Case No. 6:17-cv-01217 (D. Kan.), as well as LoganTree
`
`LP v. Fitbit Inc., Case No. 2:15-CV-1575-JRG (E.D. Tex.), both of which involve the same patent at
`
`issue in this proceeding. (Id. ¶ 6.) Mr. Shokouhi has been actively involved in all aspects of these
`
`district court cases, including the issue of validity of the patent-in-suit. (Id. ¶ 7.)
`
`4.
`
`Mr. Shokouhi has read and will comply with the Office Patent Trial Practice
`
`Guide and the Board’s Rules for Practice for Trials set forth in part 42 of the C.F.R., and he agrees
`
`to be subject to the USPTO Code of Professional Responsibility set forth in 37 C.F.R. §§10.20 et
`
`seq., and to disciplinary jurisdiction under 37 C.F.R. §11.19(a). (Id. ¶ 8-9.) Mr. Shokouhi has not
`
`applied to appear pro hac vice in any other proceedings before the Office in the last three (3) years.
`
`(Id. ¶ 10.)
`
`III. ANALYSIS
`
`The facts contained in the Statement of Facts above, and contained in the Shokouhi
`
`Declaration, establish that there is a good cause to admit Mr. Shokouhi pro hac vice in this
`
`proceeding under 37 C.F.R. §42.10. Lead counsel is a registered practitioner, Mr. Shokouhi is an
`
`experienced litigating attorney, and Mr. Shokouhi has an established familiarity with the subject
`
`matter at issue in the proceeding.
`
`IV. CONCLUSION
`
`For the foregoing reasons, Patent Owner LoganTree, LP, respectfully request that the
`
`Board admit Arnold Shokouhi pro hac vice in this proceeding.
`
`
`
`
`
`
`
`3
`
`
`
`Dated: March 14, 2018
`
`Respectfully submitted,
`
`
`/Christopher M. Barkley/
`
`Christopher M. Barkley (Reg. No. 64,329)
`Barkley IP
`100 Oceangate 12th Floor - #1009
`Long Beach, CA 90802
`Telephone: 562- 548-0393
`Facsimile: 562-683-0358
`Email:chris@barkleyip.com
`
`and
`
`Arnold Shokouhi (pro hac vice)
`James E. Sherry (pro hac vice)
`McCathern, PLLC
`3710 Rawlins Street, Suite 1600
`Dallas, TX 75219
`Telephone: 214-443-4478
`Facsimile: 214-741-4717
`Email: arnolds@mccathernlaw.com
`Email: jsherry@mccathernlaw.com
`
`
`
`Counsel for Patent Owner
`
`
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`4
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` Trials@uspto.gov
`571-282-7822
`
`
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`Paper No.
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GARMIN INTERNATIONAL, INC. AND GARMIN USA,
`INC.,
`Petitioner
`
`v.
`
`LOGANTREE, LP,
`Patent Owner
`
`Case IPR2018-00565
`
`Patent 6,059,576
`
`Before Lawrence J. Banks, Trial Paralegal
`
`DECLARATION OF ARNOLD SHOKOUHI IN
`SUPPORT OF PATENT OWNER’S MOTION FOR
`ADMISSION PRO HAC VICE OF ARNOLD
`SHOKOUHI PURSUANT TO 37 C.F.R. §42.10
`
`5
`
`
`
`I, Arnold Shokouhi, declare as follows:
`
`
`1.
`
`2.
`
`experience.
`
`3.
`
`4.
`
`I am the firm-wide Managing Partner for McCathern, PLLC.
`
`I am an experienced litigating attorney with more than eleven (11) years of
`
`I have been litigating patent cases for at least seven (7) years.
`
`I am a member in good standing of the Texas State Bar and the California Bar and
`
`am admitted to practice in each of the United States District Courts for the states of Texas and
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`California. I have never been suspended or disbarred from practice before any court or
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`administrative body.
`
`5.
`
`I have never had an application for admission to practice before any court or
`
`administrative body denied.
`
`6.
`
`I am familiar with the subject matter at issue in this proceeding, including the
`
`patent-at-issue. I am counsel in the pending district court case LoganTree LP, vs. Garmin
`
`International, Inc., and Garmin USA, Inc., Case No. 6:17-cv-01217 (D. Kan.), as well as LoganTree
`
`LP v. Fitbit Inc., Case No. 2:15-CV-1575-JRG (E.D. Tex.), both of which involve the same patent at
`
`issue in this proceeding.
`
`7.
`
`I am actively involved in all aspects of the pending district court case, including
`
`the issue of validity of the patent-in-suit and at issue in this proceeding.
`
`8.
`
`I have read and will comply with the Office Patent Trial Practice Guide and the
`
`Board’s Rules of Practice for Trials set forth in part 42 of the C.F.R.
`
`9.
`
`I agree to be subject to the USPTO Code of Professional Responsibility set forth
`
`in 37 C.F.R. §§10.20 et seq., and to disciplinary jurisdiction under 37 C.F.R. §11.19(a).
`
`
`
`6
`
`
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`10.
`
`I have not applied to appear pro hac vice in any proceeding before the Office in
`
`the last three (3) years.
`
`11.
`
`I hereby declare that all statements made herein of my own knowledge are true
`
`and that all statements made on information and belief are believed to be true; and further that
`
`these statements are made with the knowledge that willful false statements and the like so made
`
`are punishable by fine or imprisonment, or both, under Section 1001 of Title 18 of the United
`
`States Code and that such willful false statements may jeopardize the validity of U.S. Patent No.
`
`6,059,576.
`
`
`Dated: March 14, 2018 By: /Arnold Shokouhi/
`Arnold Shokouhi
`
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`7
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GARMIN INTERNATIONAL, INC. AND GARMIN USA,
`INC.,
`Petitioner
`
`v.
`
`LOGANTREE, LP,
`Patent Owner
`
`Case IPR2018-00565
`
`Patent 6,059,576
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that PATENT OWNER’S MOTION FOR ADMISSION PRO HAC
`
`VICE OF ARNOLD SHOKOUHI PURSUANT TO 37 C.F.R. § 42.10 and attached
`
`DECLARATION OF ARNOLD SHOKOUHI IN SUPPORT OF PATENT
`
`OWNER’S MOTION FOR ADMISSION PRO HAC VICE OF ARNOLD
`
`SHOKOUHI PURSUANT TO 37 C.F.R. § 42.10 in connection with Inter Partes
`
`Review Case IPR2018-00565 was served on this 14th day of March 2018 by
`
`Express Mail on Petitioner's counsel Adam P. Seitz, Megan J. Redmond, and
`8
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`
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`Clifford T. Brazil, Erise IP, P.A., 7015 College Blvd., Suite 700, Overland Park,
`
`Kansas 66211, as outlined by Petitioner's Service Information in the February 21,
`
`2018 Petition submission.
`
`
`
`Dated: March 14, 2018 By: /Melinda Lloyd/
`Melinda Lloyd
`Legal Assistance and Compliance Paralegal
`
`
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`
`9
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`
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