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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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`PROLLENIUM US INC.,
`Petitioner,
`v.
`ALLERGAN INDUSTRIE, SAS,
`Patent Owner.
`_____________
`IPR2019-01505, Patent 8,450,475 B2
`IPR2019-01506, Patent 8,357,795 B2
`IPR2019-01508, Patent 9,238,013 B2
`IPR2019-01509, Patent 9,358,322 B2
`IPR2019-01617, Patent 8,822,676 B2
`IPR2019-01632, Patent 8,357,795 B2
`IPR2020-00084, Patent 9,089,519 B2
`_____________
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`PATENT OWNER’S MOTION TO WITHDRAW BACK-UP COUNSEL1
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`1 Authorization for the use of a joint caption page was received on April 27, 2020.
`Neither party opposes the use of a joint caption page. An identical paper has been
`filed in each case recited in the consolidated caption.
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`
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`IPR2019-01505, Patent 8,450,475 B2; IPR2019-01506, Patent 8,357,795 B2;
`IPR2019-01508, Patent 9,238,013 B2; IPR2019-01509, Patent 9,358,322 B2;
`IPR2019-01617, Patent 8,822,676 B2; IPR2019-01632, Patent 8,357,795 B2;
`IPR2020-00084, Patent 9,089,519 B2
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`I.
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`Relief Requested
`Pursuant to 37 C.F.R. § 42.10(e), and as authorized by the Board via an
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`email dated July 17, 2020 (see 37 C.F.R. § 42.20(b)), counsel for Patent Owner,
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`Allergan Industrie, SAS, respectfully requests authorization for Dorothy P. Whelan
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`(Reg. No. 33,814), Michael Kane (Reg. No. 39,722), and Elizabeth Flanagan (pro
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`hac vice) to withdraw as counsel for Patent Owner in each inter partes review
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`(“IPR”) proceeding designated in the consolidated case caption.
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`II.
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`Statement of Reasons for Withdrawal of Back-Up Counsel
`As designated in Patent Owner’s recent Updated Mandatory Notice, filed
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`July 15, 2020 in each IPR proceeding designated in the consolidated case caption,
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`Patent Owner has designated Anthony M. Insogna (Reg. No. 35,203) as lead
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`counsel, Tamera M. Weisser (Reg. No. 47,856) as first back-up counsel, and S.
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`Christian Platt (Reg. No. 46,998), Sarah A. Geers (Reg. No. 69,123), and Jennifer
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`M. Hartjes (Reg. No. 77,687) as back-up counsel. Patent Owner desires those
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`designated attorneys to represent Patent Owner going forward in these
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`proceedings.
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`In addition, Patent Owner seeks the Board’s authorization to allow Dorothy
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`P. Whelan, Michael Kane, and Elizabeth Flanagan to withdraw as back-up counsel
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`for Patent Owner.
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`1
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`IPR2019-01505, Patent 8,450,475 B2; IPR2019-01506, Patent 8,357,795 B2;
`IPR2019-01508, Patent 9,238,013 B2; IPR2019-01509, Patent 9,358,322 B2;
`IPR2019-01617, Patent 8,822,676 B2; IPR2019-01632, Patent 8,357,795 B2;
`IPR2020-00084, Patent 9,089,519 B2
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`No extensions of time are sought with this Motion. It is believed that
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`granting this Motion will not hinder the economy, the integrity of the patent
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`system, the efficient administration of the Office, or the ability of the Office to
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`timely complete this proceeding. See 35 U.S.C. § 316(b); see also Motorola
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`Mobility LLC v. Arnouse, Case No. IPR2013-00010, Paper 30, Decision on
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`Renewed Motion to Withdraw at 5 (P.T.A.B. Apr. 19, 2013).
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`Counsel for Petitioner was contacted prior to filing this Motion. Petitioner
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`does not object to the withdrawal of counsel proposed in this Motion.
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`III. Conclusion
`For the foregoing reasons, Patent Owner respectfully requests that this
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`Motion to Withdraw Back-Up Counsel be granted.
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`Dated: July 20, 2020
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`Respectfully submitted,
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`/ Anthony M. Insogna /
`Anthony M. Insogna (Reg. No. 35,203)
`Jones Day
`4655 Executive Drive, Suite 1500
`San Diego, CA 92121-3134
`Tel.: (858) 314-1200
`Fax.: (844) 345-3178
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`Attorney for Patent Owner
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`2
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), I certify that I caused to be served on the
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`counsel for Petitioner a true and correct copy of Patent Owner’s Motion to
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`Withdraw Back-Up Counsel by electronic means at the following address of
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`record:
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`mcc.prollenium.ipr@mcciplaw.com
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`Dated: July 20, 2020
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`
`/ Anthony M. Insogna /
`Anthony M. Insogna (Reg. No. 35,203)
`Jones Day
`4655 Executive Drive, Suite 1500
`San Diego, CA 92121-3134
`Tel.: (858) 314-1200
`Fax.: (844) 345-3178
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`Attorney for Patent Owner
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