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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`UNIFIED PATENTS INC.,
`Petitioner,
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`v.
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`REALTIME ADAPTIVE STREAMING LLC,
`Patent Owner.
`____________________
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`Case IPR2018-00883
` Patent No. 8,934,535
`____________________
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`UNOPPOSED MOTION FOR ADMISSION PRO HAC VICE OF
`THOMAS C. CHEN
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`IPR2018-00883
`MOTION FOR ADMISSION PRO HAC VICE OF THOMAS C. CHEN
`RELIEF REQUESTED
`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner Realtime Adaptive
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`I.
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`Streaming LLC (“Realtime”) respectfully requests that the Patent Trial and
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`Appeal Board admit Thomas C. Chen pro hac vice in this proceeding. Patent
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`Owner has conferred with counsel for Petitioner Unified Patents Inc., and
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`Petitioner does not oppose Realtime’s motion to allow Mr. Chen to appear
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`pro hac vice in this matter.
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`II. GOVERNING LAW, RULES, AND PRECEDENT
`Section 42.10(c) provides that “where lead counsel is a registered
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`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 established familiarity with the
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`subject matter at issue in the proceeding.”
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`III. STATEMENT OF FACTS
`The facts here satisfy § 42.10(c) and demonstrate good cause for the
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`Board to recognize Mr. Chen pro hac vice in this proceeding.
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`Lead counsel, William Rothwell, is a registered practitioner. Counsel,
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`Thomas C. Chen, is an experienced patent litigator in good standing with the
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`California State Bar and the District of Columbia Bar, admitted to practice
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`before the Federal Circuit and the United States District Courts for the
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`IPR2018-00883
`MOTION FOR ADMISSION PRO HAC VICE OF THOMAS C. CHEN
`Northern, Central, and Southern Districts of California, and has never been
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`suspended, disbarred, sanctioned, cited for contempt of court, or had a court
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`or administrative body deny his application for admission to practice. Ex.
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`2002 ¶¶ 1-5. Mr. Chen’s declaration includes a list of the proceedings before
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`the Office in which he has applied to appear pro hac vice in the last three
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`years. Id. at ¶ 6. Mr. Chen has read and will comply with the Office Patent
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`Trial Practice Guide and the Board’s Rules of Practice for Trials set forth in
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`part 42 of title 37 of the Code of Federal Regulations. Id. at ¶ 7. Mr. Chen
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`understands and accepts that he will be subject to the USPTO Rules of
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`Professional Conduct set forth in 37 C.F.R. §§ 11.101 et. seq. and
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`disciplinary jurisdiction under 37 C.F.R. § 11.19(a). Id. at ¶ 8. Mr. Chen is
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`familiar with the subject matter at issue in this proceeding through his
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`review of the record in this proceeding. Id. at ¶ 9.
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`IV. CONCLUSION
`For the foregoing reasons, Patent Owner respectfully requests that the
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`Board admit Thomas C. Chen pro hac vice in this proceeding.
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`IPR2018-00883
`MOTION FOR ADMISSION PRO HAC VICE OF THOMAS C. CHEN
`Respectfully submitted,
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`/s/ William Rothwell
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`William P. Rothwell, Reg. No. 72,522
`NOROOZI PC
`2245 Texas Drive, Suite 300
`Sugar Land, TX 77479
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`Counsel for Patent Owner
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`Date: August 14, 2018
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`IPR2018-00883
`MOTION FOR ADMISSION PRO HAC VICE OF THOMAS C. CHEN
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`CERTIFICATION OF SERVICE
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`The undersigned hereby certifies that the foregoing UNOPPOSED
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`MOTION FOR ADMISSION PRO HAC VICE OF THOMAS C.
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`CHEN was served electronically via e-mail on August 14, 2018, in its
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`entirety on the following counsel of record for Petitioner:
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`Lionel Lavenue (Lead Counsel)
`Ashraf Fawzy (Back-up Counsel)
`Jonathan Stroud (Back-up Counsel)
`C. Brandon Rash (Back-up Counsel)
`James Stein (Back-up Counsel)
`Service Email
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`lionel.lavenue@finnegan.com
`afawzy@unifiedpatents.com
`jonathan@unifiedpatents.com
`brandon.rash@finnegan.com
`james.stein@finnegan.com
`UnifiedPatents-IPR2018-
`00883@finnegan.com
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`Respectfully submitted,
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`/s/ William Rothwell
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`William P. Rothwell, Reg. No. 72,522
`NOROOZI PC
`2245 Texas Drive, Suite 300
`Sugar Land, TX 77479
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`Counsel for Patent Owner
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`Date: August 14, 2018
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