`
`
`
`
`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 EMILY J. TREMBLAY 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 Emily J.
`
`Tremblay in this proceeding. Petitioners seek Ms. Tremblay’s assistance because
`
`of her 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
`
`Petitioners’ lead counsel in this proceeding, Cyrus A. Morton, is a registered
`
`practitioner. Ms. Tremblay has been a practicing patent litigation attorney for more
`
`than three years. Before that, Ms. Tremblay spent four years clerking for federal
`
`judges, experiencing fact and expert discovery, dispositive motions, oral
`
`arguments, and trial in patent infringement matters.
`
`Ms. Tremblay has established familiarity with the subject matter at issue in
`
`this proceeding. She is supporting Petitioners’ ongoing work in opposition to the
`
`conception and reduction to practice briefing that Patent Owner filed on September
`
`24, 2020, and Petitioners’ reply in support of its Petition. 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
`
`
`
`1
`
`
`
`IPR2020-00129
`Patent RE 45,380
`
`issue in this proceeding, and the related evidence. Petitioners respectfully request
`
`that the Board avoid this prejudice and grant this Motion.
`
`2.
`
`Affidavit or Declaration of Individual Seeking to Appear
`
`This Motion for Pro Hac Vice Admission is accompanied by the required
`
`Declaration of Ms. Tremblay. In the Declaration of Emily J. Tremblay (Ex. 1298),
`
`Ms. Tremblay attests that she 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. Ms.
`
`Tremblay further attests that she 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).
`
`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 Emily J. Tremblay 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
`CMorton@RobinsKaplan.com
`Attorney for Petitioner
`
`2
`
`
`
`IPR2020-00129
`Patent RE 45,380
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on October 13, 2020, a copy of PETITIONERS’
`
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF EMILY J.
`
`TREMBLAY UNDER 37 C.F.R. § 42.10(C) and DECLARATION OF EMILY
`
`J. TREMBLAY IN SUPPORT OF MOTION FOR PRO HAC VICE
`
`ADMISSION have been served by electronic mail to the Patent Owners:
`
`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
`
`3
`
`