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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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`DR. REDDY’S LABORATORIES S.A. AND
`DR. REDDY’S LABORATORIES, INC.
`Petitioners
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`v.
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`INDIVIOR UK LIMITED.
`Patent Owner
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`________________________
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`U.S. PATENT NO. 9,687,454
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`SUBLINGUAL AND BUCCAL FILM COMPOSITIONS
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`Case No. IPR2019-00329
`________________________
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`PETITIONERS’ RENEWED UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF ROBERT FREDERICKSON III UNDER 37 C.F.R.
`§ 42.10(c)
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`TITLE:
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`Pursuant to 37 C.F.R. § 42.10(c), Dr. Reddy’s Laboratories S.A., and Dr.
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`Reddy’s Laboratories, Inc. (“Petitioners”) respectfully request pro hac vice
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`admission of Robert Frederickson III in this proceeding, IPR2019-00329,
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`regarding U.S. Patent No. 9,687,454 (“the ’454 patent”).
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`I.
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`THE REQUEST IS TIMELY
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`Pursuant to the Board’s “Notice of Filing Date Accorded to Petition and
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`Time for Filing Patent Owner Preliminary Response,” dated December 7, 2018
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`(Paper No. 6), authorizing the parties to file motions for pro hac vice admission
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`under 37 C.F.R. § 42.10(c) and in accordance with the guidance specified in the
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`“Order Authorizing Motion for Pro Hac Vice Admission,” entered in Case IPR2013-
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`00639 (Paper No. 7), (“PHV Admission Order”), Petitioners Dr. Reddy’s
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`Laboratories S.A. and Dr. Reddy’s Laboratories, Inc. respectfully request that
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`the Board allow Robert Frederickson III to appear pro hac vice on their behalf in
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`this proceeding. According to the PHV Admission Order, pro hac vice motions
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`can be filed no sooner than (21) days after service of the Petition. This pro hac
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`vice motion is filed more than 21 days after the service of the Petition and is
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`therefore timely. Patent Owner does not oppose this motion.
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`II. REASONS THE REQUESTED RELIEF SHOULD BE GRANTED
`As set forth in the Statement of Material Facts below, and as required by 37
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`C.F.R. § 42.10(c), Petitioners have demonstrated good cause to admit Mr.
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`2
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`Frederickson pro hac vice in this proceeding. In particular, Petitioners’ lead
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`counsel is a registered practitioner, and Mr. Frederickson is an experienced
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`litigating attorney having an established familiarity with the subject matter at
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`issue in this proceeding.
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`Furthermore, this motion is being filed more than twenty-one days after
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`service of the petition; includes a statement of facts showing good cause for the
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`Board to recognize Mr. Frederickson pro hac vice; and is being filed
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`concurrently with Exhibit 1027, the Corrected Declaration of Robert
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`Frederickson III in Support of Renewed Motion For Pro Hac Vice Admission
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`(“Corrected Frederickson Decl.”), all in accordance with the PHV Admission
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`Order.
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`III. STATEMENT OF MATERIAL FACTS
`1.
`37 C.F.R. § 42.10(c) provides that “[t]he Board may recognize
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`counsel pro hac vice during a proceeding upon a showing of good cause, subject
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`to the condition that lead counsel be a registered practitioner and to any other
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`conditions as the Board may impose. For example, where the 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 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.”
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`3
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`2.
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`Ira J. Levy, lead counsel for Petitioners Dr. Reddy’s
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`Laboratories S.A. and Dr. Reddy’s Laboratories, Inc. in this proceeding,
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`is a registered practitioner holding Registration No. 35,587.
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`3.
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`As set forth in the Corrected Frederickson Decl., Mr. Frederickson
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`is an experienced litigating attorney. Specifically, Mr. Frederickson has been
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`practicing law since 2007 and focuses his practice in the area of patent
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`litigation. (Corrected Frederickson Decl., ¶ 4).
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`4. Mr. Frederickson also has an established familiarity with the precise
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`subject matter at issue in this proceeding. In the course of this representation,
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`he has developed a strong familiarity with the ’454 patent, its prosecution history,
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`the general subject matter to which the ’454 patent is directed, and the prior art
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`references relied upon by Petitioners. (Corrected Frederickson Decl., ¶ 5).
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`Additionally, Mr. Frederickson has reviewed the Petition and accompanying
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`Exhibits filed in this matter and all other papers associated with this proceeding.
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`(Id.).
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`5. Mr. Frederickson has attested to the each of the requirements set
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`forth in paragraph 2(b)(i)-(viii) of the “Order Authorizing Motion for Pro Hac
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`Vice Admission” in Case IPR2013-00639, Paper 7 at 3. (Corrected
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`Frederickson Decl., ¶¶ 5-11).
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`IV. CONCLUSION
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`4
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`In view of the foregoing, Petitioners respectfully submit that the
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`requirements of 37 C.F.R. § 42.10(c) have been satisfied, and request an Order
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`permitting Robert Frederickson III to appear pro hac vice on their behalf in this
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`proceeding.
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`5
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`Dated: April 17, 2019
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`Respectfully submitted,
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`By: /Ira J. Levy/
`Ira J. Levy
`(Reg. No. 35,587)
`Goodwin Procter LLP
`The New York Times Building
`620 Eighth Avenue
`New York, NY 10018-1405
`Tel: 212-813-8800
`Fax: 212-355-3333
`ilevy@goodwinprocter.com
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`Counsel for Petitioners Dr. Reddy‘s
`Laboratories, S.A. and Dr. Reddy’s
`Laboratories, Inc.
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`6
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`CERTIFICATION OF SERVICE
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`The undersigned hereby certifies that “PETITIONERS’ RENEWED
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`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF ROBERT
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`FREDERICKSON III UNDER 37C.F.R. § 42.10(c),” and “EXHIBIT 1027 –
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`CORRECTED DECLARATION OF ROBERT FREDERICKSON III IN SUPPORT
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`OF RENEWED MOTION FOR PRO HAC VICE ADMISSION” were served
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`electronically via e-mail on April 17, 2019 on the following:
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`dgarr@cov.com
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`pchen@cov.com
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`IndiviorSBX@cov.com
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`Dated: April 17, 2019
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`/Ira J. Levy/
`Ira J. Levy
`(Reg. No. 35,587)
`Goodwin Procter LLP
`The New York Times Building
`620 Eighth Avenue
`New York, NY 10018-1405
`Tel: 212-813-8800
`Fax: 212-355-3333
`ilevy@goodwinprocter.com
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`7
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