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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`GOOGLE LLC,
`Petitioner
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`v.
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`CYWEE GROUP LTD.
`Patent Owner
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`____________________
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`Case IPR2018-01257
`Patent No. 8,552,978
`____________________
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`PATENT OWNER’S MOTION FOR
`PRO HAC VICE ADMISION OF CECIL E. KEY
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`IPR2018-01257
`U.S. Patent No. 8,552,978
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`Patent Owner CyWee Group Ltd. (“CyWee” or “Patent Owner”)
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`respectfully requests that the Board recognize and admit Cecil E. Key as counsel
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`pro hac vice to represent CyWee during the above-captioned proceeding. The
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`bases and support for CyWee’s requests are as follows.
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` 1. Timing of CyWee’s Request
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`CyWee’s motion is being filed no sooner than twenty-one (21) days after the
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`service of the petition.
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` 2. Good Cause Bases for CyWee’s Request
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`The Board may recognize counsel pro hac vice during a proceeding upon a
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`showing of good cause, subject to the condition that lead counsel is a registered
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`practitioner and a declaration of the party seeking admission is included with the
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`Request. 37 C.F.R. § 42.10(c). Good cause has been shown where, for example,
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`the attorney for which pro hac vice admission is sought is an experienced patent
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`litigator and has a familiarity with the subject matter at issue in the proceeding, and
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`the admission of the party’s counsel will facilitate the party’s ability to effectively
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`participate in the proceeding. CyWee respectfully submits that all of these
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`conditions have been met here.
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`CyWee’s lead counsel, Jay P. Kesan, is a registered practitioner. As
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`demonstrated by his declaration, Mr. Key is an experienced litigator who has
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`litigated patent infringement cases for various parties in federal district courts
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`IPR2018-01257
`U.S. Patent No. 8,552,978
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`throughout the United States and before the Court of Appeals for the Federal
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`Circuit. Id. at ¶¶ 3-7. Mr. Key’s legal career spans over twenty (20) years. See Id.
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`at ¶ 2. Mr. Key has extensive experience in litigating patent infringement cases,
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`and has served as lead counsel in such cases. Id. at ¶ 6. Mr. Key has been
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`previously admitted to practice pro hac vice before the Board, and participated in
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`trials before the Board. Id. at ¶ 11.
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`Mr. Key has read and is familiar with the patent at issue in this proceeding
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`and its file history, as well as the prior art and other arguments that have been
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`asserted by Petitioner.
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`CyWee submits that Mr. Key’s participation will assist it and its lead
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`counsel in effectively participating in this proceeding, and will facilitate timely
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`completion of the trial proceeding.
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`Mr. Key has never been suspended, disbarred, sanctioned or cited for
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`contempt by any court or administrative body, and has never had an application for
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`admission to practice before a court or agency denied. Id. at ¶¶ 7-8. Mr. Key is a
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`member in good standing of the Bars of Virginia and the District of Columbia. Id.
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`at ¶ 2. Mr. Key agrees to be subject to the Office Patent Trial Practice Guide, the
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`Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R, and the
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`USPTO’s Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et. seq.,
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`and submit to disciplinary jurisdiction under 37 C.F.R. § 11.19(a). Id. at ¶¶ 9-10.
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`3
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`3. Conclusion
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`IPR2018-01257
`U.S. Patent No. 8,552,978
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`For the foregoing reasons, CyWee respectfully requests that the PTAB
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`recognize Cecil E. Key as its counsel, pro hac vice, in this proceeding.
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`Dated: April 5, 2019
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`Respectfully submitted,
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`/Jay P. Kesan/
`Jay P. Kesan
`Reg. No. 37,488
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`Counsel for Patent Owner
`CyWee Group Ltd.
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`4
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`IPR2018-01257
`U.S. Patent No. 8,552,978
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on the date
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`indicated below, a complete and entire copy of this submission, including the
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`exhibits hereto, was provided by email to Petitioner’s counsel via email, as agreed
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`to by Petitioner’s Service Information in the Petition submission, by serving the
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`email address of record as follows:
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`Matthew A. Smith
`SMITH BALUCH LLP
`110 Alma St., Ste 109
`Menlo Park, CA
`(202) 669-6207
`smith@smithbaluch.com
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`Andrew S. Baluch
`SMITH BALUCH LLP
`110 Alma St., Ste 109
`Menlo Park, CA
`(847) 863-1645
`baluch@smithbaluch.com
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`Christopher M. Colice
`SMITH BALUCH LLP
`110 Alma St., Ste 109
`Menlo Park, CA
`(617) 947.7280
`colice@smithbaluch.com
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`Dated: April 5, 2019
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`5
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`/Jay P. Kesan/
`Jay P. Kesan
`Reg. No. 37488
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`Counsel for Patent Owner
`Cywee Group Ltd.
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