`Patent No. 8,510,407
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`LENOVO HOLDING COMPANY, INC.,
`LENOVO (UNITED STATES) INC., and
`MOTOROLA MOBILITY LLC,
`Petitioners,
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`v.
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`DODOTS LICENSING SOLUTIONS LLC,
`Patent Owner.
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`CASE IPR2019-01279
`Patent No. 8,510,407
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`PATENT OWNER’S MOTION FOR PRO HAC VICE ADMISSION OF
`PERRY M. GOLDBERG UNDER 37 C.F.R. § 42.10(c)
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`1
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`Under 37 CFR § 42.10(c) and in response to the authorization provided by
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`the United States Patent and Trademark Office’s Patent Trial and Appeal Board
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`(“Board”) in the Notice of Filing Date Accorded to Petition (Paper Number 3,
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`entered July 11, 2019) (“Notice”) and by email dated March 10, 2020, Patent
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`Owner DoDots Licensing Solutions LLC (“DoDots”) respectfully moves for Perry
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`M. Goldberg to appear pro hac vice on its behalf, as back-up counsel, before the
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`Board in IPR2019-01279. This motion follows the guidelines set forth in
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`IPR2013-00639, Paper 7, entered October 15, 2013 (“Order”).
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`I.
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`Statement of Facts
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`Under the Order, the following statement of facts shows that good cause
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`exists for the Board to recognize Mr. Goldberg pro hac vice.
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`Lead counsel for this proceeding, Lewis E. Hudnell, III, is a registered
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`practitioner (Registration No. 51,185).
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`Mr. Goldberg is an experienced litigation attorney, and has been involved in
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`numerous patent infringement cases in federal District Courts across the country.
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`He has experience in various aspects of patent infringement matters including
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`trials, Markman hearings, and summary judgment hearings. Mr. Goldberg is a
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`member in good standing of the California Bar, and is admitted to practice before
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`the United States Court of Appeals for the Federal Circuit, and the United States
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`District Courts for the Northern and Central District of California. Mr. Goldberg
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`has not been suspended or disbarred from practice, never had any application for
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`admission to practice denied, nor had any sanctions or contempt citations imposed
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`against him.
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`Mr. Goldberg is lead counsel for DoDots in a co-pending litigation DoDots
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`Licensing Solutions LLC v. Lenovo Holding Company Inc., Case No. 1:18-cv-
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`00098-MN, pending in the United States District Court for the District of
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`Delaware. This litigation involves U.S. Patent No. 8,510,407 (“the ’407 Patent”),
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`the same patent at issue in this proceeding, as well as two other patents in the same
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`family as the ’407 Patent. In his role as lead litigation counsel in that case, Mr.
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`Goldberg has reviewed and is familiar with the ’407 Patent and the related patents,
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`and is familiar with the legal and factual issues in that case. He also has studied
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`the Petition and the prior art references relied upon by the Petitioners. As such,
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`Mr. Goldberg has established familiarity with the subject matter at issue in this
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`proceeding.
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`Mr. Goldberg has read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.,
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`and he agrees to be subject to the USPTO Rules of Professional Conduct set forth
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`in 37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R. §
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`11.19(a).
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`3
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`Mr. Goldberg is concurrently applying to appear pro hac vice in IPR2019-
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`00988 and IPR2019-01278. Mr. Goldberg has not applied to appear pro hac vice
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`before the Board in connection with any other proceedings.
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`DoDots has expended significant financial resources in the co-pending
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`litigation with Mr. Goldberg as counsel, and DoDots wishes to continue using Mr.
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`Goldberg in this proceeding.
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`As such, DoDots respectfully submits that there is good cause for the Board
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`to recognize Mr. Goldberg as counsel pro hac vice during this proceeding.
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`II. Affidavit or Declaration of Individual Seeking to Appear
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`This Motion for pro hac vice admission is accompanied by a Declaration of
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`Mr. Goldberg as required by the Order (Ex. 2001).
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`Respectfully submitted,
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`By: /s/ Lewis E. Hudnell, III
`Lewis E. Hudnell, III
`Reg. No. 51,185
`Hudnell Law Group P.C.
`800 W. El Camino Real
`Suite 180
`Mountain View, CA 94040
`T: 650-564-7720
`F: 347-772-3034
`lewis@hudnelllaw.com
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`4
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`CERTIFICATE OF SERVICE
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`I certify that the foregoing PATENT OWNER’S MOTION FOR PRO HAC
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`VICE ADMISSION OF PERRY M. GOLDBERG UNDER 37 C.F.R. § 42.10(c)
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`was served on March 10, 2020 on the Petitioners by filing this document through
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`the Patent Review Processing System as well as e-mailing a copy to
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`charanjit.brahma@troutman.com and dustin.weeks@troutman.com.
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`By: /s/ Lewis E. Hudnell, III
`Lewis E. Hudnell, III
`(Special Counsel to Progress LLP)
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`Reg. No. 51,185
`Hudnell Law Group P.C.
`800 W. El Camino Real
`Suite 180
`Mountain View, CA 94040
`T: 650-564-7720
`F: 347-772-3034
`lewis@hudnelllaw.com
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`5
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