`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`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
`_____________
`
`PATENT OWNER’S MOTION TO WITHDRAW BACK-UP COUNSEL1
`
`
`
`
`
`
`
`
`
`
`
`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.
`
`
`
`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
`
`I.
`
`Relief Requested
`Pursuant to 37 C.F.R. § 42.10(e), and as authorized by the Board via an
`
`email dated July 17, 2020 (see 37 C.F.R. § 42.20(b)), counsel for Patent Owner,
`
`Allergan Industrie, SAS, respectfully requests authorization for Dorothy P. Whelan
`
`(Reg. No. 33,814), Michael Kane (Reg. No. 39,722), and Elizabeth Flanagan (pro
`
`hac vice) to withdraw as counsel for Patent Owner in each inter partes review
`
`(“IPR”) proceeding designated in the consolidated case caption.
`
`II.
`
`Statement of Reasons for Withdrawal of Back-Up Counsel
`As designated in Patent Owner’s recent Updated Mandatory Notice, filed
`
`July 15, 2020 in each IPR proceeding designated in the consolidated case caption,
`
`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
`
`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.
`
`
`
`1
`
`
`
`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
`
`No extensions of time are sought with this Motion. It is believed that
`
`granting this Motion will not hinder the economy, the integrity of the patent
`
`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).
`
`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.
`
`
`
`Dated: July 20, 2020
`
`
`
`
`
`
`Respectfully submitted,
`
`/ 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
`
`Attorney for Patent Owner
`
`2
`
`
`
`
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`CERTIFICATE OF SERVICE
`
`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
`
`
`/ 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
`
`Attorney for Patent Owner
`
`
`
`
`
`
`
`
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