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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
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`LENOVO HOLDING COMPANY, INC., LENOVO (UNITED STATES)
`INC., and MOTOROLA MOBILITY LLC,
`Petitioner,
`
`v.
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`DODOTS LICENSING SOLUTIONS LLC,
`Patent Owner.
`____________
`
`Case IPR2019-01279
`Patent No. 8,510,407
`__________________
`
`PETITIONERS’ MOTION FOR WITHDRAWAL AND SUBSTITUTION
`OF COUNSEL
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`Mail Stop Patent Board
`Patent Trial and Appeal Board
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`
`
`IPR2019-01279
`U.S. Patent No. 8,510,407
`
`I.
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`RELIEF REQUESTED
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`Pursuant to 37 C.F.R. § 42.10, Petitioners Lenovo Holding Company, Inc.,
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`Lenovo (United States) Inc., and Motorola Mobility LLC (“Petitioners”)
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`respectfully request that the Patent Trial and Appeal Board authorize withdrawal of
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`Charanjit Brahma and Dustin Weeks as its counsel and appoint John Alemanni as
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`lead counsel and Mathew Meyer as back-up counsel.
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`II.
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`STATEMENT SHOWING GOOD CAUSE FOR THE BOARD TO
`AUTHORIZE WITHDRAWAL AND SUBSTITUTION OF COUNSEL
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`For good cause, Petitioners request that the current designated counsel be
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`deemed withdrawn from the present proceeding, and new counsel, John Alemanni
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`and Mathew Meyer, be designated lead and back-up counsel, respectively, to
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`represent Petitioners in this proceeding.
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`Petitioners’ new counsel meet the requirements of 37 C.F.R. § 42.10(c) as
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`lead counsel and registered practitioners.
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`In idenfitying and designating new counsel who are ready and able to take
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`over the representation, reasonable steps have been taken to “avoid foreseeable
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`prejudice to the rights of the client, including giving due notice to his or her client
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`[and] allowing time for employment of another practitioner.” See 37 C.F.R. §
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`42.40(a). Further, Petitioners believe that granting this motion will not hinder the
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`economy, the integrity of the patnet system, the efficient administration of the
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`1
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`
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`IPR2019-01279
`U.S. Patent No. 8,510,407
`Office, or the ability of the Office to timely complete this proceeding. See 37
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`U.S.C. § 316(b).
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`Petitioner verifies that no further extensions of time will be sought by
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`Substitute Counsel.
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`III. PATENT OWNER DOES NOT OBJECT TO THE SUBSTITUION
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`Patent Owner has indicated it does not oppose the requested withdrawal and
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`substitution of counsel for Petitioners.
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`IV. CONCLUSION
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`For the foregoing reasons, Petitioners respectfully requests that the Board
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`authorize the withdrawal of current counsel and substitution of new counsel.
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`Dated: March 17, 2020
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`
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`Respectfully submitted,
`
`
`
`
`
`
`/Dustin Weeks/
`Dustin Weeks, Reg. No. 67,466
`Charanjit Brahma, Reg. No. 46,574
`Troutman Sanders LLP
`600 Peachtree Street, NE, Suite 3000
`Atlanta, GA 30308
`(404) 885-3000
`charanjit.brahma@troutman.com
`dustin.weeks@troutman.com
`
`Attorneys for Petitioners
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`2
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`
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`IPR2019-01279
`U.S. Patent No. 8,510,407
`
`
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`
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`CERTIFICATE OF SERVICE (37.C.F.R. § 42.6(e))
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`The undersigned hereby certifies that a true and correct copy of the forgoing
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`PETITIONERS’ MOTION FOR WITHDRAWAL AND SUBSTITUTION
`
`OF COUNSEL was served electronically via e-mail on March 17, 2020 in its
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`entirety on the following counsel of record for Patent Owner:
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`Lewis Hudnell
`akarkhanis@progressllp.com
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`Perry Goldberg
`goldberg@progressllp.com
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`Attorneys for Patent Owner
`
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`Dated: March 17, 2020
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`
`
`/Dustin B. Weeks/
`Dustin B. Weeks, Reg. No. 67,466
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`3
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