`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________
`
`GARMIN INTERNATIONAL, INC. AND GARMIN USA, INC.
`Petitioners
`
`v.
`
`LOGANTREE, LP
`Patent Owner
`
`____________
`
`Case No. IPR2018-00565
`Patent No. 6,059,576
` ____________
`
`
`
`PETITIONERS’ MOTION FOR ADMISSION
`PRO HAC VICE UNDER 37 C.F.R. § 42.10(C)
`
`
`
`IPR2018-00565
`U.S. Patent No. 6,059,576
`
`I.
`
`INTRODUCTION
`
`Petitioners Garmin International, Inc. and Garmin USA, Inc. (“Petitioners”)
`
`respectfully request that the Board recognize Megan Redmond as counsel pro hac
`
`vice during the above captioned proceeding. Petitioners file this Motion for
`
`Admission Pro Hac Vice in accordance with the Board’s March 1, 2018 Notice of
`
`Filing Date (Paper 3) and 37 C.F.R. §§ 42.10(c). Patent Owner does not oppose
`
`this motion.
`
`II. THE CONDITIONS FOR PRO HAC VICE ADMISSION ARE MET
`
`The conditions outlined in 37 C.F.R. § 42.10(c) and the Order – Authorizing
`
`Motion for Pro Hac Vice Admission in case IPR2013-00639, Paper 7 are met.
`
`Petitioners are filing this motion more than 21 days after February 21, 2018, the
`
`date of service of the Petition.
`
`Lead Counsel for Petitioners (Adam P. Seitz, Reg. No. 52,206) is registered
`
`to practice before the Board. 37 C.F.R. § 42.10(c).
`
`Second, good cause exists to permit Ms. Redmond to be admitted pro hac
`
`vice for this proceeding. Ms. Redmond has established familiarity with the subject
`
`matter at issue in this proceeding, including extensive knowledge of U.S. Patent
`
`No. 6,059,576 (“the ’576 patent”) and the printed prior art submitted in the instant
`
`Petition. Exhibit 1020, Declaration of Megan J. Redmond at ¶ 8. Ms. Redmond is
`
`a highly experienced patent litigation attorney and has been involved in numerous
`
`
`
`1
`
`
`
`IPR2018-00565
`U.S. Patent No. 6,059,576
`
`patent litigations before the federal courts. Id. at ¶ 9. She has particular
`
`experience litigating patents relating to activity monitoring. Id. For example, Ms.
`
`Redmond is currently representing Petitioners in co-pending district court litigation
`
`involving the ’576 patent. Id. As part of her representation of Petitioners in this
`
`and other matters, she has discussed the relevant technologies in depth with expert
`
`witnesses and engineers. Id. at ¶ 10. She also participated in the drafting and
`
`revision of the Petition filed in this proceeding. Id. at ¶ 11. Therefore, Ms.
`
`Redmond’s knowledge would be of substantial benefit to Petitioners in this
`
`proceeding.
`
`Patent Owner does not oppose Ms. Redmond appearing pro hac vice during
`
`this proceeding.
`
`III. AFFIDAVIT OR DECLARATION OF INDIVIDUAL SEEKING TO
`APPEAR
`
`A Declaration of Ms. Redmond as Exhibit 1020 accompanies Petitioners’
`
`Motion for Pro Hac Vice Admission.
`
`IV. CONCLUSION
`
`Petitioners respectfully request that the Board recognize Ms. Redmond as
`
`counsel pro hac vice during this proceeding.
`
`
`
`
`
`
`
`2
`
`
`
`IPR2018-00565
`U.S. Patent No. 6,059,576
`
`Dated: June 1, 2018
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`BY:
`
`
`ERISE IP, P.A.
`
`
`
`
`
` /s/ Adam P. Seitz
`
`Adam P. Seitz, Reg. No. 52,206
`
`
`
`
`
`
`
`COUNSEL FOR PETITIONERS
`
`
`
`3
`
`
`
`IPR2018-00565
`U.S. Patent No. 6,059,576
`
`CERTIFICATE OF SERVICE ON PATENT OWNER
`UNDER 37 C.F.R. § 42.6
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on June 1, 2018 the
`foregoing Petitioners’ Motion for Admission Pro Hac Vice Under 37 C.F.R. §
`42.10(c) was served via electronic filing with the Board on the following counsel
`of record for Patent Owner:
`
`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
`
`Arnold Shokouhi, 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
`
`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: jsherry@mccathernlaw.com
`
`Dated: June 1, 2018
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`BY: /s/ Adam P. Seitz
`
`
`
`Adam P. Seitz, Reg. No. 52,206
`
`
`
`
`
`COUNSEL FOR PETITIONERS
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`1
`
`