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`____________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________________
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`MYLAN PHARMACEUTICALS INC.
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`Petitioner
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`v.
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`BIOGEN MA, INC.,
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`Patent Owner
`____________________________
`
`Case No. IPR2018-01403
`U.S. Patent No. 8,399,514
`____________________________
`
`MOTION FOR PRO HAC VICE ADMISSION
`OF SHANNON M. BLOODWORTH
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`
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`I.
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`Statement of Precise Relief Requested
`Mylan Pharmaceuticals Inc. (“Mylan”) hereby respectfully requests that the
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`Patent Trial and Appeal Board (the “Board”) admit Shannon M. Bloodworth, pro
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`hac vice in this proceeding under 37 C.F.R. § 42.10(c).
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`Patent Owner has stated it will not oppose this motion.
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`II.
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`Statement of Facts Showing Good Cause for the Board to Recognize
`Counsel Pro Hac Vice During the Proceeding
`Under 37 C.F.R. § 42.10(c), the Board may admit counsel pro hac vice for
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`good cause, so long as lead counsel is a registered practitioner and subject to any
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`other conditions the Board requires. Under Section 42.10(c), good cause includes
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`when “counsel is an experienced litigating attorney and has an established
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`familiarity with the subject matter at issue in the proceeding.” This motion
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`satisfies the requirements of Section 42.10(c):
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`1.
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`Lead counsel, Brandon M. White, is a registered practitioner.
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`2. Ms. Bloodworth is an experienced patent litigator and has an
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`established familiarity with the subject matter at issue here, as shown in her
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`accompanying July 11, 2019 Declaration (“Bloodworth Decl.”), filed currently
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`with this motion. That declaration shows that Ms. Bloodworth has been a litigator
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`for more than 18 years. She is a member in good standing of the District of
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`Columbia, Maryland, Virginia, Wisconsin, and is also admitted in several federal
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`courts. Ms. Bloodworth is also familiar with the subject matter of this case,
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`including U.S. Patent No. 8,399,514 and its prosecution history, the underlying
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`technology, and the prior art cited by the petitioner in this matter. Bloodworth
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`Decl. ¶¶ 8-9.
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`3.
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`In her declaration, Ms. Bloodworth also attests to each of the listed
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`items required by the Order – Authorizing Motion for Pro Hac Vice Admission –
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`37 C.F.R. § 42.10 in IPR2013-00639. See Bloodworth Decl. ¶¶ 2-13.
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`III. Conclusion
`For the foregoing reasons, Mylan respectfully requests that the Board admit
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`Shannon M. Bloodworth, pro hac vice in this proceeding.
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`
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`Respectfully submitted,
`PERKINS COIE LLP
`/s/ Emily J. Greb
`Emily J. Greb
`Reg. No. 68,244
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`
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`Dated: July 15, 2019
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`
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`By:
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`- 2 -
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`2.
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the foregoing:
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`1. MOTION FOR PRO HAC VICE ADMISSION OF SHANNON M.
`BLOODWORTH, and
`DECLARATION OF SHANNON M. BLOODWORTH IN SUPPORT OF
`MOTION FOR PRO HAC VICE ADMISSION OF SHANNON M.
`BLOODWORTH
`was served electronically via email as follows:
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`Patent Owner:
`Barbara C. McCurdy
`Mark J. Feldstein
`Erin M. Sommers
`Pier D. DeRoo
`Cora R. Holt
`Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
`901 New York Avenue, NW
`Washington, DC 20001
`(202) 408-4047
`barbara.mccurdy@finnegan.com
`mark.feldstein@finnegan.com
`erin.sommers@finnegan.com
`pier.deroo@finnegan
`cora.holt@finnegan.com
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`Dated: July 15, 2019
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`
`
`/s/ Emily J. Greb
`Emily J. Greb
`Registration No. 68,244
`Perkins Coie LLP
`33 East Main Street, Suite 201
`Madison, WI 53703
`Telephone: (608) 663-7494
`E-mail: egreb@perkinscoie.com
`
`