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