`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`MEDTRONIC, INC., AND MEDTRONIC VASCULAR, INC.,
`Petitioner,
`
`v.
`
`TELEFLEX INNOVATIONS S.À.R.L.,
`Patent Owner.
`
`
`Case IPR2020-00129
`Patent RE 45,380
`
`
`
`PETITIONERS’ UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF WILLIAM E. MANSKE UNDER 37 C.F.R. § 42.10(C)
`
`
`
`
`
`IPR2020-00129
`Patent RE 45,380
`
`Pursuant to 37 C.F.R. § 42.10(c) and the Notice of Filing Date Accorded to
`
`Petition and Time for Filing Patent Owner Preliminary Response entered on
`
`December 9, 2019 (Paper 6) in this proceeding, Petitioners, Medtronic, Inc. and
`
`Medtronic Vascular, Inc., respectfully request pro hac vice admission of William
`
`E. Manske in this proceeding. Petitioners seek Mr. Manske’s assistance because of
`
`his familiarity with the substantive and technical issues involved in this
`
`proceeding. The parties have conferred, and Patent Owner does not oppose this
`
`Motion.
`
`1.
`
`Statement of Facts
`
`Mr. Manske is an experienced patent litigation attorney, with over nine
`
`years of experience in fact and expert discovery, Markman hearings, and oral
`
`arguments in patent infringement matters before both Federal district courts and
`
`the United States Court of Appeals for the Federal Circuit.
`
`Mr. Manske has established familiarity with the subject matter at issue in
`
`this proceeding. Robins Kaplan LLP represents Petitioners in this proceeding,
`
`and Mr. Manske is actively involved in all aspects of Petitioners’ submissions in
`
`this proceeding. Mr. Manske is familiar with the patents at issue and with
`
`Petitioners’ validity challenges. It is Petitioners’ wish to have Mr. Manske
`
`continue representing them in this matter before the Board. Petitioners have
`
`invested significant resources in their validity challenges. The scope of issues
`
`1
`
`
`
`
`
`IPR2020-00129
`Patent RE 45,380
`
`that Petitioners must address following Patent Owner’s numerous recent
`
`submissions necessitates Mr. Manske’s involvement. If this motion was denied,
`
`Petitioners would be prejudiced because they would have to undertake the
`
`burdensome and costly task of educating another attorney regarding the patent at
`
`issue in this proceeding, and the related evidence. Petitioners respectfully request
`
`that the Board avoid this prejudice and grant this Motion.
`
`Pursuant to the requirements of 37 C.F.R. § 42.10(c), Cyrus A. Morton, a
`
`registered practitioner, will remain as lead counsel in this matter. Mr. Morton—
`
`like Mr. Manske—is a partner at Robins Kaplan LLP. Mr. Manske has worked
`
`with Mr. Morton on other matters before the Board.
`
`2. Affidavit or Declaration of Individual Seeking to Appear
`
`This Motion for Pro Hac Vice Admission is accompanied by the required
`
`Declaration of Mr. Manske. In the Declaration of William E. Manske (Ex. 1297),
`
`Mr. Manske attests that he has read and will comply with the Patent Office Trial
`
`Practice Guide and the Board’s Rules of Practice set forth in 35 C.F.R. § 42. Mr.
`
`Manske further attests that he agrees to be subject to the USPTO’s Rules of
`
`Professional Conduct as set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary
`
`jurisdiction under 37 C.F.R. § 11.19(a).
`
`2
`
`
`
`IPR2020-00129
`Patent RE 45,380
`
`For the foregoing reasons, and in view of the Declaration submitted
`
`herewith, Petitioners submit that good cause exists for the pro hac vice admission
`
`of William E. Manske and respectfully requests that the Board grant this motion.
`
`Dated: October 13, 2020
`
`Respectfully submitted,
`
`/Cyrus A. Morton/
`Cyrus A. Morton
`Registration No. 44,954
`Robins Kaplan LLP
`2800 LaSalle Plaza
`800 LaSalle Avenue
`Minneapolis, MN 55402
`Tel: 612-349-8722
`Fax: 612-339-4181
`CMorton@RobinsKaplan.com
`Attorney for Petitioner
`
`3
`
`
`
`IPR2020-00129
`Patent RE 45,380
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this October 13, 2020, a copy of PETITIONERS’
`
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF WILLIAM
`
`E. MANSKE UNDER 37 C.F.R. § 42.10(C) and DECLARATION OF
`
`WILLIAM E. MANSKE IN SUPPORT OF MOTIONS FOR PRO HAC VICE
`
`ADMISSION was served in its entirety by electronic mail on Patent Owner’s
`
`counsel at the following addresses indicated in Patent Owner’s Mandatory Notices:
`
`J. Derek Vandenburgh, Reg. No. 32,179
`dvandenburgh@carlsoncaspers.com
`
`Dennis C. Bremer, Reg. No. 40,528
`dbremer@carlsoncaspers.com
`
`Joseph W. Winkels
`jwinkels@carlsoncaspers.com
`
`Peter M. Kohlhepp
`pkohlhepp@carlsoncaspers.com
`
`Dated: October 13, 2020
`
`Respectfully submitted,
`
`/Cyrus A. Morton/
`Cyrus A. Morton
`Registration No. 44,954
`Attorney for Petitioner
`
`4
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
