`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SONOS, INC.
`Petitioner
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`v.
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`IMPLICIT, LLC
`Patent Owner
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`IPR2018-00767 (Patent 8,942,252 B2)
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`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF
`WILLIAM ELLSWORTH DAVIS, III
`Pursuant to Rule 42.10(c), Patent Owner Implicit, LLC (“Implicit”)
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`respectfully requests pro hac vice admission of William E. Davis, III as counsel in
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`this proceeding.
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`I. Time for Filing
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`This Motion is timely because it is being filed no sooner than twenty one (21)
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`days after service of the Petition in this proceeding, which occurred on March 9,
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`2018.
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`II. Statement of Facts
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`The following statement of facts demonstrates that there is good cause for the
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`Board to recognize William E. Davis, III as counsel pro hac vice in this proceeding.
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`1
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`Mr. Davis is an experienced litigation attorney and has an established
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`familiarity with the subject matter at issue in this proceeding. Mr. Davis has been
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`practicing law since 2004 and has extensive experience litigating patent
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`infringement cases in many different District Courts across the country. Among his
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`experience in patent litigation matters, Mr. Davis has been lead counsel in multiple
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`trials, Markman hearings, patent summary judgment proceedings, and other patent-
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`related hearings and pleadings concerning, inter alia, patent validity and
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`infringement issues.
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`Mr. Davis is familiar with U.S. Patent Nos. 7,391,791 B2 (“the ’791 Patent”)
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`and 8,942,252 B2 (“the ’252 Patent”). Mr. Davis has been representing Patent
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`Owner Implicit in pending District Court litigation against Petitioner asserting the
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`’791 and ’252 Patents. Among other things, Mr. Davis has been involved in the
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`infringement, claim construction, and validity issues with regard to the ’791 and ’252
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`Patents.
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`III. Declaration of William E. Davis, III
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`As directed by the Board, this Motion is also accompanied by the Declaration
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`of William E. Davis III in Support of Motion for Pro Hac Vice Admission attesting
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`to the requirements laid out in the Board’s Order Authorizing Motion for Pro Hac
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`Vice Admission in Case IPR2013-00639 (Paper 7).
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`2
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`For the foregoing reasons as well as the reasons contained in the attached
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`declaration, Implicit respectfully requests admission of William E. Davis III as
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`counsel pro hac vice.
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`Respectfully submitted,
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`THE DAVIS FIRM, P.C.
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`By: /Christian Hurt Reg. No. 63,659/
`Christian Hurt
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`THE DAVIS FIRM, PC
`213 N. Fredonia Street, Suite 230
`Longview, Texas 75601
`903-230-9090
`churt@bdavisfirm.com
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`3
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`DECLARATION OF WILLIAM ELLSWORTH DAVIS, III IN SUPPORT OF
`MOTION FOR PRO HAC VICE ADMISSION
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`I, William E. Davis, III, being duly sworn and upon oath, hereby attest to the
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`following:
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`1.
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`2.
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`I am a member in good standing of the Bar of Texas.
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`I have never been suspended or disbarred from practice before any court
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`or administrative body.
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`3.
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`I have never been denied an application for admission to practice before
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`any court or administrative body.
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`4.
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`No sanction or contempt citation has ever been imposed against me by
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`any court or administrative body.
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`5.
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`I have 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 37 C.F.R. Part 42.
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`6.
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`I will be subject to the USPTO Rules of Professional Conduct set forth
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`in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R. §
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`11.19(a).
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`7.
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`I have not appeared pro hac vice before the Patent Trial and Appeal
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`Board.
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`8.
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`I am an experienced litigation attorney and have an established
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`familiarity with the subject matter at issue in this proceeding. I have been practicing
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`law since 2004 and have extensive experience litigating patent infringement cases in
`
`
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`4
`
`
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`many different District Courts across the country. Among my experience in patent
`
`litigation matters, I have been lead counsel and counsel in multiple trials, Markman
`
`hearings, patent summary judgment proceedings, and other patent-related hearings
`
`and pleadings concerning, inter alia, patent validity and infringement issues.
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`9.
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`I am familiar with U.S. Patent Nos. 7,391,791 B2 (“the ’791 Patent”)
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`and 8,942,252 B2 (“the ’252 Patent”). I have been representing Patent Owner
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`Implicit in pending District Court litigation against Petitioner asserting the ’791 and
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`’252 Patents. Among other things, I have been involved in the infringement, claim
`
`construction, and validity issues with regard to the ’791 and ’252 Patents.
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` declare under penalty of perjury that the foregoing is true and correct.
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` I
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`Executed this 18th day of February, 2019, in Longview, Texas.
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`/s/ William E. Davis, III
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`William E. Davis, III
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`5
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