Case No. IPR2018-01240
`Petitioner’s Motion for Admission Pro Hac Vice of Louis Tompros
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`DOCKET NO.: 0107131-00564US4
`Filed on behalf of Intel Corporation
`By: David L. Cavanaugh, Reg. No. 36,476
`Richard Goldenberg, Reg. No. 38,895
`Wilmer Cutler Pickering Hale and Dorr LLP
`60 State Street
`Boston, Massachusetts 02109
`Email: david.cavanaugh@wilmerhale.com
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` richard.goldenberg@wilmerhale.com
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`
`Intel Corporation
`Petitioner
`
`v.
`
`Qualcomm Incorporated
`Patent Owner
`
`Case IPR2018-01240
`U.S. Patent No. 8,698,558
`
`PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE OF
`LOUIS TOMPROS
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`Petitioner’s Motion for Admission Pro Hac Vice of Louis Tompros
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`DOCKET NO.: 0107131-00564US4
`Filed on behalf of Intel Corporation
`By: David L. Cavanaugh, Reg. No. 36,476
`Richard Goldenberg, Reg. No. 38,895
`Wilmer Cutler Pickering Hale and Dorr LLP
`60 State Street
`Boston, Massachusetts 02109
`Email: david.cavanaugh@wilmerhale.com
`
` richard.goldenberg@wilmerhale.com
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`
`Intel Corporation
`Petitioner
`
`v.
`
`Qualcomm Incorporated
`Patent Owner
`
`Case IPR2018-01240
`U.S. Patent No. 8,698,558
`
`PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE OF
`LOUIS TOMPROS
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`Case No. IPR2018-01240
`Petitioner’s Motion for Admission Pro Hac Vice of Louis Tompros
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`Statement of Precise Relief Requested
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`I.
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`Pursuant to 37 C.F.R. § 42.10(c) and Paper No. 7 authorizing the parties to
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`file motions for pro hac vice admissions under 37 C.F.R. § 42.10(c), Petitioner
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`Intel Corp. (“Petitioner”) requests that the Patent Trial and Appeal Board (the
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`“Board”) admit Louis Tompros pro hac vice in this proceeding, IPR2018-01240.
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`II.
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`
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`Statement of Facts Showing Good Cause for the Board to Recognize
`Counsel Pro Hac Vice During the Proceeding
`In accordance with 37 C.F.R. § 42.10(c), the Board may recognize counsel
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`pro hac vice during a proceeding upon a showing of good cause, subject to the
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`condition that lead counsel be a registered practitioner and to any other conditions
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`as the Board may impose. Section 42.10(c) indicates that “where lead counsel is a
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`registered 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 an established familiarity with the subject
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`matter at issue in the proceeding.” The facts here establish good cause for the
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`Board to recognize Louis Tompros pro hac vice in this proceeding.
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`1.
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`Lead counsel, David L. Cavanaugh, is a registered practitioner.
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`Backup counsel, Richard Goldenberg, is also a registered practitioner.
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`2.
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`Counsel, Louis Tompros, is an experienced litigator and has
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`established familiarity with the subject matter at issue in the proceeding.
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`Case No. IPR2018-01240
`Petitioner’s Motion for Admission Pro Hac Vice of Louis Tompros
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`Accompanying this motion as Exhibit 1327 is the February 15, 2019, Declaration
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`of Louis Tompros in Support of this Motion for Admission Pro Hac Vice
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`(“Tompros Decl.”). In his declaration, Mr. Tompros asserts:
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`I am a member in good standing of the Bar of the Commonwealth of
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`Massachusetts, and am admitted to practice before the United States
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`Supreme Court, the Massachusetts Supreme Judicial Court, the United
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`States Courts of Appeal for the First, Seventh, Ninth, and Federal
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`Circuits, and the United States District Courts for the District of
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`Massachusetts and the Eastern District of Michigan.
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`Tompros Decl. ¶ 3 (Ex. 1327). Mr. Tompros also asserts:
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`I am familiar with the subject matter at issue in this proceeding. I
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`participated in the drafting of the Petition filed in this proceeding, and
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`I have reviewed the papers filed in this proceeding. I am representing
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`and have represented Apple Inc. (“Apple”), which Petitioner Intel has
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`identified as a real party-in-interest, in Certain Mobile Electronic
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`Devices and Radio Frequency and Processing Components Thereof,
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`Investigation No. 337-ITC-1065 (the “Apple ITC litigation”, which is
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`a related matter to this proceeding) and in Qualcomm Inc. v. Apple Inc.,
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`No. 3:17-cv-1375 (S.D. Cal.) (the “Apple litigation”, which is a related
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`matter to this proceeding). In addition, I am representing and have
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`Case No. IPR2018-01240
`Petitioner’s Motion for Admission Pro Hac Vice of Louis Tompros
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`represented Petitioner Intel Corporation in multiple patent-related
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`matters, including the following United States District Court cases:
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`VLSI Tech. LLC v. Intel Corp., No. 5:17-cv-05671 (N.D. Cal.); VLSI
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`Tech. LLC v. Intel Corp., No. 1:18-cv-00966 (D. Del.); DSS
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`Technology Management, Inc. v. Intel Corp., Nos. 6:15-cv-00130 and
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`6:14-cv-00197 (E.D. Tex.); and Power Management Solutions v. Intel
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`Corp., No. 1:11-cv-00743 (D. Del.).
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`Tompros Decl. ¶¶ 14-15 (Ex. 1327).
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`3.
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`In his declaration, Mr. Tompros also attests to each of the listed items
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`required by the “Order – Authorizing Motion for Pro Hac Vice Admission” in
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`Case IPR2013-00639, Paper 7. See Tompros Decl. ¶¶ 1-15 (Ex. 1327).
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`III. Conclusion
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`For the foregoing reasons, Petitioner respectfully requests that the Board
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`admit Louis Tompros pro hac vice in this proceeding.
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`Respectfully Submitted,
`
`/Theodoros Konstantakopoulos/.
`
`Theodoros Konstantakopoulos
`Reg. No. 74,155
`Wilmer Cutler Pickering Hale & Dorr LLP
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`Dated: February 15, 2019
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`Case No. IPR2018-01240
`Petitioner’s Motion for Admission Pro Hac Vice of Louis Tompros
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`Table of Exhibits for U.S. Patent 8,698,558 Petition for Inter Partes Review
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`Exhibit
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`Description
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`1301
`1302
`1303
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`1304
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`1305
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`1306
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`1307
`1308
`1309
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`1310
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`1311
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`1312
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`1313
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`U.S. Patent No. 8,698,558
`File History for U.S. Patent No. 8,698,558
`Declaration of Dr. Alyssa B. Apsel
`Chu, W.Y. et al., “A 10 MHz Bandwidth, 2 mV Ripple PA
`Regulator for CDMA Transmitters,” IEEE Journal of Solid-State
`Circuits 2809-2819 (2008) (“Chu”)
`Declaration of IEEE regarding Chu, Kwak, Kim, and Blanken
`(“IEEE Chu Decl.”)
`Choi, J. et al., “Envelope Tracking Power Amplifier Robust to
`Battery Depletion,” Microwave Symposium Digest (MTT), 2010
`IEEE MTT-S International 1332-36 (2010) (“Choi 2010”)
`Declaration of IEEE regarding Choi 2010 (“IEEE Choi Decl.”)
`Declaration of Debabani Choudhury (“Choudhury Decl.”)
`Declaration of Jinsung Choi (“Choi Decl.”)
`Blanken, P.G. et al., “A 50MHz Bandwidth Multi-Mode PA Supply
`Modulator for GSM, EDGE and UMTS Application,” 2008 Radio
`Frequency Integrated Circuits Symposium (IEEE) 401-04 (2008)
`(“Blanken”)
`Kwak, T.W. et al., “A 2 W CMOS Hybrid Switching Amplitude
`Modulator for EDGE Polar Transmitters,” IEEE Journal of Solid-
`State Circuits 2666-76 (2007) (“Kwak”)
`U.S. Patent No. 5,929,702, “Method and Apparatus for High
`Efficiency High Dynamic Range Power Amplification,” to Myers
`et al. (“Myers”)
`Kim, D. et al., “High Efficiency and Wideband Envelope Tracking
`Power Amplifier with Sweet Spot Tracking,” Radio Frequency
`Integrated Circuits Symposium (RFIC): 255-258 (2010) (“Kim”)
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`Case No. IPR2018-01240
`Petitioner’s Motion for Admission Pro Hac Vice of Louis Tompros
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`U.S. Patent No. 6,300,826, “Apparatus and Method for Efficiently
`Amplifying Wideband Envelope Signals” (filed May 5, 2000)
`(“Mathe ’826”)
`Maxim Integrated Products, Inc., MAX9738 –16VP-P Class G
`Amplifier with Inverting Boost Converter, Datasheet 19-3700,
`Rev. 0 (March 2008) (“Maxim”)
`Ertl, H. et al., “Basic Considerations and Topologies of Switched-
`Mode Assisted Linear Power Amplifiers,” IEEE Transactions on
`industrial electronics 44.1 (1997): 116-123 (“Ertl”)
`Kang, D. et al., “A Multimode/Multiband Power Amplifier With a
`Boosted Supply Modulator,” IEEE Transactions on Microwave
`Theory and Techniques 58.10 (2010): 2598-2608 (“Kang”)
`U.S. Patent No. 5,834,977, “Amplifying Circuit with Power
`Supply Switching Circuit” (filed October 30, 1996 and issued
`November 10, 1998) (“Maehara”)
`U.S. Patent No. 5,870,340, “Multiplexer” (filed July 8, 1997 and
`issued February 9, 1999) (“Ohsawa”)
`U.S. Patent No. 6,566,935, “Power Supply Circuit With a Voltage
`Selector” (filed August 28, 2000 and issued May 20, 2003)
`(“Renous”)
`Certificate of Correction for U.S. Patent No. 8,698,558 (“558
`COC”)
`Qualcomm Incorporated’s Initial Claim Construction Brief,
`Certain Mobile Electronic Devices and Radio Frequency and
`Processing Components Thereof, Investigation No. 337-TA-1065
`(“Qualcomm CC Brief”)
`Order No. 28: Construing Terms of the Asserted Patents, Certain
`Mobile Electronic Devices and Radio Frequency and Processing
`Components Thereof, Investigation No. 337-TA-1065 (“Markman
`Order”)
`Excerpts from Erickson et al., Fundamentals of Power Electronics,
`Second Edition (Kluwer Academic Publisher) (2001) (“Erickson”)
`Hanington, Gary. et al., “High-Efficiency Power Amplifier Using
`Dynamic Power-Supply Voltage for CDMA Applications,” IEEE
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`1314
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`1315
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`1316
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`1317
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`1318
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`1319
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`1320
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`1321
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`1322
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`1323
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`1324
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`1325
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`Case No. IPR2018-01240
`Petitioner’s Motion for Admission Pro Hac Vice of Louis Tompros
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`Transactions on Microwave Theory and Techniques 47:8 (1999)
`(“Hanington”)
`Declaration of James M. Dowd in Support of Motion for
`Admission Pro Hac Vice
`Declaration of Louis Tompros in Support of Motion for
`Admission Pro Hac Vice
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`1326
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`1327
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`Case No. IPR2018-01240
`Petitioner’s Motion for Admission Pro Hac Vice of Louis Tompros
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`CERTIFICATE OF SERVICE
`I hereby certify that on February 15, 2019, I caused a true and correct copy
`of the foregoing materials:
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`• Petitioner’s Motion for Admission Pro Hac Vice of Louis Tompros
`• Exhibit 1327
`• List of Exhibits (Ex. 1301 - 1327)
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`to be served via electronic mail on the following lead and backup counsel:
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`Joseph M. Sauer (jmsauer@jonesday.com)
`David B. Cochran (dcochran@jonesday.com)
`Richard A. Graham (ragraham@jonesday.com)
`David M. Maiorana (dmaiorana@jonesday.com)
`Joshua R. Nightingale (jrnightingale@jonesday.com)
`Matthew W. Johnson (mwjohsnon@jonesday.com)
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`/Theodoros Konstantakopoulos/.
`Theodoros Konstantakopoulos
`Reg. No. 74,155
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