`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________
`
`Canon Inc., Canon U.S.A., Inc., and Axis Communications AB,
`
`Petitioner,
`v.
`Avigilon Fortress Corporation,
`
`Patent Owner.
`______________________________
`Case No. IPR2019-00314
`Patent No. 7,932,923
`______________________________
`
`PATENT OWNER’S MOTION TO WITHDRAW COUNSEL
`
`
`
`
`
`
`
`
`
`
`
`Patent Owner’s Motion to Withdraw Counsel
`IPR2019-00314
`
`RELIEF REQUESTED
`Pursuant to 37 C.F.R. § 42.10(e), and as authorized by the Board in an email
`
`
`I.
`
`
`dated October 24, 2019, Patent Owner Avigilon Fortress Corporation (“Avigilon”)
`
`respectfully requests that current lead counsel, Eugene Goryunov, be allowed to
`
`withdraw as lead counsel.
`
` Avigilon has conferred with Petitioner’s counsel, who does not opposes this
`
`motion.
`
`II.
`
`STATEMENT OF FACT SUPPORTING WITHDRAWAL
`On October 22, 2019, counsel for Avigilon requested authorization from the
`
`board to file this motion The Board provided Avigilon with authorization to file
`
`this motion on October 24, 2019.
`
`Eugene Goryunov has terminates his employment with counsel for Avigilon,
`
`Kirkland & Ellis, it is appropriate to allow him to withdraw as lead counsel.
`
`The new lead counsel Reza Dokhanchy and back-up counsel Adam R.
`
`Alper, Akshay S. Deoras and Michael De Vries authorized to conduct business on
`
`behalf of Avigilon will remain in this proceeding. Accordingly, the withdrawal of
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`Mr. Goryunov will not interfere or delay this proceeding.
`
`III. CONCLUSION
`Avigilon respectfully requests that the Board grant this motion, and allow
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`Eugene Goryunov to withdraw as lead counsel.
`
`
`
`1
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`
`
`Date: January 8, 2020
`
`Patent Owner’s Motion to Withdraw Counsel
`IPR2019-00314
`
`Respectfully submitted,
`
` /s/ Reza Dokhanchy
`Reza Dokhanchy (Reg. No. 62,795)
`Adam R. Alper (pro hac vice)
`Akshay S. Deoras (pro hac vice)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, California 94104
`Telephone: (415) 439-1400
`Facsimile: (415) 439-1500
`reza.dokhanchy@kirkland.com
`aalper@kirkland.com
`adeoras@kirkland.com
`
`Michael De Vries (pro hac vice)
`KIRKLAND & ELLIS LLP
`333 South Hope Street
`Los Angeles, California 90071
`Telephone: (213) 680-8400
`Facsimile: (213) 680-8500
`michael.devries@kirkland.com
`
`Counsel for Patent Owner Avigilon
`Patent Holding 1 Corporation
`
`2
`
`
`
`Patent Owner’s Motion to Withdraw Counsel
`IPR2019-00314
`
`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a copy of the foregoing Patent
`
`Owner’s Motion to Withdraw Counsel was served on January 8, 2020
`
`via electronic service on lead and back up counsel:
`
`Axis Communications AB
`Lead Counsel
`
`Axis Communications AB
`Backup Counsel
`
`C. Gregory Gramenopoulos (Reg. No.
`36,532)
`Finnegan, Henderson, Farabow,
`Garrett & Dunner LLP
`901 New York Avenue, NW
`Washington, DC 20001-4413
`Telephone: 202-408-4263
`Facsimile: 202-408-4400
`gramenoc@finnegan.com
`
`Kelly S. Horn (Reg. No. 70,657)
`Guang-Yu Zhu (Reg. No. 66,250)
`Finnegan, Henderson, Farabow,
`Garrett & Dunner LLP
`901 New York Avenue, NW
`Washington, DC 20001-4413
`Telephone: 202-408-4313
`Facsimile: 202-408-4400
`kelly.horn@finnegan.com
`guang-yu.zhu@finnegan.com
`
`Canon Inc. and Canon U.S.A., Inc.
`Lead Counsel
`
`Canon Inc. and Canon U.S.A., Inc.
`Back-Up Counsel
`
`Joseph A. Calvaruso (Reg. No. 28,287)
`Orrick, Herrington, & Sutcliffe LLP
`2050 Main Street, Suite 1110
`Irvine, CA 92614-8255
`Telephone: 212-506-5140
`Facsimile: 949-567-6710
`ipprosecution@orrick.com
`jcalvaruso@orrick.com
`
`Richard F. Martinelli (Reg. No. 52,003)
`Orrick, Herrington, & Sutcliffe LLP
`2050 Main Street, Suite 1110
`Irvine, CA 92614-8255
`Telephone: 212-506-5140
`Facsimile: 949-567-6710
`ipprosecution@orrick.com
`rmartinelli@orrick.com
`
`Dated: January 8, 2020
`
` /s/ Reza Dokhanchy
`Reza Dokhanchy (Reg. No. 62,795)
`555 California Street
`San Francisco, California 94104
`Telephone: (415) 439-1400
`
`3
`
`
`
`Patent Owner’s Motion to Withdraw Counsel
`IPR2019-00314
`
`Facsimile: (415) 439-1500
`reza.dokhanchy@kirkland.com
`
`4
`
`
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