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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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`MEDTRONIC, INC., AND MEDTRONIC VASCULAR, INC.,
`Petitioner,
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`v.
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`TELEFLEX INNOVATIONS S.À.R.L.,
`Patent Owner.
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`Case IPR2020-00129
`Patent RE 45,380
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`PETITIONERS’ UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF WILLIAM E. MANSKE UNDER 37 C.F.R. § 42.10(C)
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`IPR2020-00129
`Patent RE 45,380
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`Pursuant to 37 C.F.R. § 42.10(c) and the Notice of Filing Date Accorded to
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`Petition and Time for Filing Patent Owner Preliminary Response entered on
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`December 9, 2019 (Paper 6) in this proceeding, Petitioners, Medtronic, Inc. and
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`Medtronic Vascular, Inc., respectfully request pro hac vice admission of William
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`E. Manske in this proceeding. Petitioners seek Mr. Manske’s assistance because of
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`his familiarity with the substantive and technical issues involved in this
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`proceeding. The parties have conferred, and Patent Owner does not oppose this
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`Motion.
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`1.
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`Statement of Facts
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`Mr. Manske is an experienced patent litigation attorney, with over nine
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`years of experience in fact and expert discovery, Markman hearings, and oral
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`arguments in patent infringement matters before both Federal district courts and
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`the United States Court of Appeals for the Federal Circuit.
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`Mr. Manske has established familiarity with the subject matter at issue in
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`this proceeding. Robins Kaplan LLP represents Petitioners in this proceeding,
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`and Mr. Manske is actively involved in all aspects of Petitioners’ submissions in
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`this proceeding. Mr. Manske is familiar with the patents at issue and with
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`Petitioners’ validity challenges. It is Petitioners’ wish to have Mr. Manske
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`continue representing them in this matter before the Board. Petitioners have
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`invested significant resources in their validity challenges. The scope of issues
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`IPR2020-00129
`Patent RE 45,380
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`that Petitioners must address following Patent Owner’s numerous recent
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`submissions necessitates Mr. Manske’s involvement. If this motion was denied,
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`Petitioners would be prejudiced because they would have to undertake the
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`burdensome and costly task of educating another attorney regarding the patent at
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`issue in this proceeding, and the related evidence. Petitioners respectfully request
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`that the Board avoid this prejudice and grant this Motion.
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`Pursuant to the requirements of 37 C.F.R. § 42.10(c), Cyrus A. Morton, a
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`registered practitioner, will remain as lead counsel in this matter. Mr. Morton—
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`like Mr. Manske—is a partner at Robins Kaplan LLP. Mr. Manske has worked
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`with Mr. Morton on other matters before the Board.
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`2. Affidavit or Declaration of Individual Seeking to Appear
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`This Motion for Pro Hac Vice Admission is accompanied by the required
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`Declaration of Mr. Manske. In the Declaration of William E. Manske (Ex. 1297),
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`Mr. Manske attests that he has read and will comply with the Patent Office Trial
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`Practice Guide and the Board’s Rules of Practice set forth in 35 C.F.R. § 42. Mr.
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`Manske further attests that he agrees to be subject to the USPTO’s Rules of
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`Professional Conduct as set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary
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`jurisdiction under 37 C.F.R. § 11.19(a).
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`IPR2020-00129
`Patent RE 45,380
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`For the foregoing reasons, and in view of the Declaration submitted
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`herewith, Petitioners submit that good cause exists for the pro hac vice admission
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`of William E. Manske and respectfully requests that the Board grant this motion.
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`Dated: October 13, 2020
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`Respectfully submitted,
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`/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
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`IPR2020-00129
`Patent RE 45,380
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`CERTIFICATE OF SERVICE
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`I hereby certify that on this October 13, 2020, a copy of PETITIONERS’
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`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF WILLIAM
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`E. MANSKE UNDER 37 C.F.R. § 42.10(C) and DECLARATION OF
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`WILLIAM E. MANSKE IN SUPPORT OF MOTIONS FOR PRO HAC VICE
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`ADMISSION was served in its entirety by electronic mail on Patent Owner’s
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`counsel at the following addresses indicated in Patent Owner’s Mandatory Notices:
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`J. Derek Vandenburgh, Reg. No. 32,179
`dvandenburgh@carlsoncaspers.com
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`Dennis C. Bremer, Reg. No. 40,528
`dbremer@carlsoncaspers.com
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`Joseph W. Winkels
`jwinkels@carlsoncaspers.com
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`Peter M. Kohlhepp
`pkohlhepp@carlsoncaspers.com
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`Dated: October 13, 2020
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`Respectfully submitted,
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`/Cyrus A. Morton/
`Cyrus A. Morton
`Registration No. 44,954
`Attorney for Petitioner
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