UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`
`DR. REDDY’S LABORATORIES S.A. AND
`DR. REDDY’S LABORATORIES, INC.
`Petitioners
`
`
`v.
`
`
`INDIVIOR UK LIMITED.
`Patent Owner
`
`________________________
`
`
`U.S. PATENT NO. 9,687,454
`
`TITLE:
`
`SUBLINGUAL AND BUCCAL FILM COMPOSITIONS
`
`
`
`
`
`Case No. IPR2019-00329
`________________________
`
`PETITIONERS’ UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF ALEXANDRA D. VALENTI UNDER 37 C.F.R. § 42.10(c)
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`
`DR. REDDY’S LABORATORIES S.A. AND
`DR. REDDY’S LABORATORIES, INC.
`Petitioners
`
`
`v.
`
`
`INDIVIOR UK LIMITED.
`Patent Owner
`
`________________________
`
`
`U.S. PATENT NO. 9,687,454
`
`TITLE:
`
`SUBLINGUAL AND BUCCAL FILM COMPOSITIONS
`
`
`
`
`
`Case No. IPR2019-00329
`________________________
`
`PETITIONERS’ UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF ALEXANDRA D. VALENTI UNDER 37 C.F.R. § 42.10(c)
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.10(c), Dr. Reddy’s Laboratories S.A., and Dr. Reddy’s
`
`Laboratories, Inc. (“Petitioners”) respectfully request pro hac vice admission of
`
`Alexandra D. Valenti in this proceeding, IPR2019-00329, regarding U.S. Patent No.
`
`9,687,454 (“the ’454 patent”).
`
`I.
`
`THE REQUEST IS TIMELY
`
`Pursuant to the Board’s “Notice of Filing Date Accorded to Petition and Time
`
`for Filing Patent Owner Preliminary Response,” dated December 7, 2018 (Paper No.
`
`6), authorizing the parties to file motions for pro hac vice admission under 37 C.F.R.
`
`§ 42.10(c) and in accordance with the guidance specified in the “Order Authorizing
`
`Motion for Pro Hac Vice Admission,” entered in Case IPR2013-00639 (Paper No.
`
`7), (“PHV Admission Order”), Petitioners Dr. Reddy’s Laboratories S.A. and Dr.
`
`Reddy’s Laboratories, Inc. respectfully request that the Board allow Alexandra D.
`
`Valenti to appear pro hac vice on their behalf in this proceeding. According to the
`
`PHV Admission Order, pro hac vice motions can be filed no sooner than (21) days
`
`after service of the Petition. This pro hac vice motion is filed more than 21 days
`
`after the service of the Petition and is therefore timely. Patent Owner does not
`
`oppose this motion.
`
`
`
`
`2
`
`
`
`II. REASONS THE REQUESTED RELIEF SHOULD BE GRANTED
`
`As set forth in the Statement of Material Facts below, and as required by 37
`
`C.F.R. § 42.10(c), Petitioners have demonstrated good cause to admit Ms. Valenti
`
`pro hac vice in this proceeding. In particular, Petitioners’ lead counsel is a
`
`registered practitioner, and Ms. Valenti is an experienced litigating attorney having
`
`an established familiarity with the subject matter at issue in this proceeding.
`
`Furthermore, this motion is being filed more than twenty-one days after
`
`service of the petition; includes a statement of facts showing good cause for the
`
`Board to recognize Ms. Valenti pro hac vice; and is being filed concurrently with
`
`Exhibit 1029, the Declaration of Alexandra D. Valenti in Support of Motion For
`
`Pro Hac Vice Admission (“Valenti Decl.”), all in accordance with the PHV
`
`Admission Order.
`
`III. STATEMENT OF MATERIAL FACTS
`
`1.
`
`37 C.F.R. § 42.10(c) provides that “[t]he Board may recognize counsel
`
`pro hac vice during a proceeding upon a showing of good cause, subject to the
`
`condition that lead counsel be a registered practitioner and to any other conditions as
`
`the Board may impose. For example, where the lead counsel is a registered
`
`practitioner, a motion to appear pro hac vice by counsel who is not a registered
`
`practitioner may be granted upon showing that counsel is an experienced litigating
`
`
`
`
`3
`
`
`
`attorney and has an established familiarity with the subject matter at issue in the
`
`proceeding.”
`
`2.
`
`Ira J. Levy, lead counsel for Petitioners Dr. Reddy’s Laboratories S.A.
`
`and Dr. Reddy’s Laboratories, Inc. in this proceeding, is a registered practitioner
`
`holding Registration No. 35,587.
`
`3.
`
`As set forth in the Valenti Declaration, Ms. Valenti is an experienced
`
`litigating attorney. Specifically, Ms. Valenti has been practicing law since 2012
`
`and focuses her practice in the area of patent litigation. (Valenti Decl. ¶ 4.)
`
`4.
`
`Ms. Valenti also has an established familiarity with the precise subject
`
`matter at issue in this proceeding by representing Petitioner in a related district court
`
`litigation. In the course of this representation, she has developed a strong
`
`familiarity with the ’454 patent, its prosecution history, the general subject matter to
`
`which the ’454 patent is directed, and the prior art references relied upon by
`
`Petitioners. (Valenti Decl. ¶ 5.) Additionally, Ms. Valenti has reviewed the Petition
`
`and accompanying Exhibits filed in this matter and all other papers associated with
`
`this proceeding. (Id.)
`
`5.
`
`Ms. Valenti has attested to the each of the requirements set forth in
`
`paragraph 2(b)(i)-(viii) of the “Order Authorizing Motion for Pro Hac Vice
`
`Admission” in Case IPR2013-00639, Paper 7 at 3. (Valenti Decl. ¶¶ 5–12.)
`
`
`
`
`4
`
`
`
`IV. CONCLUSION
`
`In view of the foregoing, Petitioners respectfully submit that the requirements
`
`of 37 C.F.R. § 42.10(c) have been satisfied, and request an Order permitting
`
`Alexandra D. Valenti to appear pro hac vice on their behalf in this proceeding.
`
`
`Dated: November 12, 2019
`
`
`
`
`
`
`
`Respectfully submitted,
`
`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@goodwinlaw.com
`
`Counsel for Petitioners Dr. Reddy‘s
`Laboratories, S.A. and Dr. Reddy’s
`Laboratories, Inc.
`
`5
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that Petitioners’ Unopposed Motion for Pro
`
`Hac Vice Admission of Alexandra D. Valenti Under 37 C.F.R. § 42.10(c) and Exhibit
`
`1029 – Declaration of Alexandra D. Valenti in Support of Motion for Pro Hac
`
`Vice Admission were served electronically via e-mail on November 12, 2019 on the
`
`following:
`
`dgarr@cov.com
`pchen@cov.com
`IndiviorSBX@cov.com
`
`Dated: November 12, 2019
`
`
`
`
`
`
`
`
`
`
`
`/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@goodwinlaw.com
`
`6
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
