`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`GOOGLE LLC,
`Petitioner,
`
`v.
`
`REALTIME ADAPTIVE STREAMING LLC
`Patent Owner.
`
`
`
`
`
` Case IPR2019-01035
`Patent 9,769,477
`
`
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`
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`PATENT OWNER’S MOTION
`FOR PRO HAC VICE ADMISSION
`
`Patent Owner, Realtime Adaptive Streaming LLC hereby requests the Board
`
`recognize James S. Tsuei as counsel pro hac vice for this proceeding under 37 C.F.R.
`
`§ 42.10(c). Petitioner does not oppose this motion.
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`I. STATEMENT OF FACTS
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`As required by § 42.10(c), the following statement of facts demonstrates that
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`there is good cause for the Board to recognize Mr. Tsuei pro hac vice.
`
`
`
`Case IPR2019-01035
`Patent 9,769,477
`
`
`
`Mr. Tsuei is an experienced patent litigation attorney. Mr. Tsuei has practiced
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`patent litigation since 2012. Mr. Tsuei is an Associate at the firm of Russ August &
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`Kabat. Mr. Tsuei has experience litigating numerous patent infringement litigation
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`matter before U.S. district courts. U.S. Patent No. 9,769,477 was asserted by Patent
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`Owner in a co-pending litigation against Petitioner Google LLC, Realtime Adaptive
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`Streaming LLC, v. Google LLC, Case No. 2:18-cv-03629-GW-JC (C.D. Cal., Filed
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`April 30, 2018). Mr. Tsuei is an attorney responsible for the representation of Patent
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`Owner in that co-pending litigation. Through his role as an attorney in the co-
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`pending litigation, Mr. Tsuei has an established familiarity with the subject matter
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`at issue in this IPR proceeding. Mr. Tsuei has been heavily involved with issues
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`such as Patent Owner’s responses to Petitioner’s invalidity defenses in that litigation,
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`some of which overlap with the grounds presented in this IPR proceeding. Patent
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`Owner has expended significant resources in the co-pending litigation with Mr.
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`Tsuei, and it wishes to continue using him as counsel in this IPR proceeding.
`
`Patent Owner has executed a Power of Attorney authorizing Mr. Tsuei to
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`serve as backup counsel in this IPR proceeding. Counsel for Patent Owner has
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`conferred with counsel for Petitioner regarding this motion, and counsel for
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`Petitioner does not oppose this motion.
`
`
`
`2
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`
`
`Case IPR2019-01035
`Patent 9,769,477
`
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`II. DECLARATION OF INDIVIDUAL SEEKING TO APPEAR
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`This Motion for Pro Hac Vice admission is accompanied by the declaration
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`of Mr. Tsuei, attached hereto, attesting to the facts required by the Board in Unified
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`Patents, Inc. v. Parallel Iron, LLC, No. IPR2013-00639 (P.T.A.B. Oct. 15, 2013)
`
`Respectfully submitted,
`
` /s/ Philip X. Wang
`Philip X. Wang
`(Reg. No. 74,621)
`Russ August & Kabat
`12424 Wilshire Blvd., 12th Fl.
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`Fax: (310) 826-6991
`pwang@raklaw.com
`
`(Paper 10).
`
`
`
`Dated: February 3, 2020
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`
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`3
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`
`
`Case IPR2019-01035
`Patent 9,769,477
`
`
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`CERTIFICATE OF SERVICE (37 C.F.R. § 42.6(e)(1))
`
`
`The undersigned hereby certifies that the above document was served on
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`February 3, 2020, by filing this document through the Patent Trial and Appeal Board
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`End to End system as well as delivering a copy via electronic mail upon the following
`
`attorneys of record for the Petitioner:
`
`Naveen Modi (Reg. No. 46,224)
`naveenmodi@paulhastings.com
`PH-Google-Realtime-IPR@paulhastings.com
`Joseph E. Palys (Reg. No. 46,508)
`josephpalys@paulhastings.com
`Phillip Citreon (Reg No. 66,541)
`phillipcitroen@paulhastings.com
`Paul Hastings LLP
`
`
`
`
`
`Dated: February 3, 2020, 2020
`
`
`
`
`
`/s/ Philip X. Wang
`
`Philip X. Wang (Reg. No. 74,621)
`C. Jay Chung (Reg. No. 71,007)
`Reza Mirzaie (Reg. No. 69,138)
`Attorneys for Patent Owner
`Russ August & Kabat
`12424 Wilshire Blvd., 12th Fl.
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`Fax: (310) 826-6991
`pwang@raklaw.com
`jchung@raklaw.com
`rmirzaie@raklaw.com
`rak_realtimedata@raklaw.com
`
`
`
`4
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