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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.
`Petitioners,
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`v.
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`TELEFLEX INNOVATIONS S.A.R.L.
`Patent Owner.
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`Case IPR2020-00132
`Patent RE45,760E
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`PATENT OWNER’S UNOPPOSED MOTION FOR
`PRO HAC VICE ADMISSION OF TARA C. NORGARD
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`Pursuant to the Notice in this case authorizing the parties to file motions for
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`pro hac vice admission under 37 C.F.R. § 42.10(c), Patent Owner Teleflex hereby
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`respectfully moves for the pro hac vice admission of Tara C. Norgard due to her
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`experience representing the Patent Owner in other patent-related matters
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`concerning the GuideLiner technology and her familiarity with the technical and
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`substantive issues involved in this proceeding. The parties have conferred, and the
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`Petitioner does not oppose this Motion.
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`In support of this motion, Patent Owner states as follows:
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`The Board may recognize counsel pro hac vice upon a showing of good
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`cause, subject to the condition that lead counsel be a registered practitioner and to
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`any other conditions the Board may impose. 37 C.F.R. § 42.10(c). A motion for
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`pro hac vice admission may be granted where a party shows that “counsel is an
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`experienced litigating attorney and has an established familiarity with the subject
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`matter at issue in the proceeding.” Id.
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`Good cause exists under 37 C.F.R. § 42.10(c) for the pro hac vice admission
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`of Tara C. Norgard as backup co-counsel in this matter. Ms. Norgard has
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`represented Teleflex in a related patent infringement action in the District of
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`Minnesota (Civil Action. No. 19-cv-1760 (PJS/TNL), filed July 2, 2019) involving
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`the same parties and the same patent at issue in this proceeding. Ms. Norgard has
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`also assisted the lead counsel representing the Patent Owner in this IPR, Derek
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`Vandenburgh.
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`As a result of these experiences, Ms. Norgard has developed a deep
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`familiarity with the patents at issue and the Petitioner’s validity challenges, and the
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`Patent Owner wishes to have Ms. Norgard continue representing it in this matter
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`before the Board.
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`The Patent Owner has invested significant financial resources in the related
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`proceedings described above, in which Ms. Norgard has served as counsel. If this
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`motion was denied, the Patent Owner would be prejudiced because it would have
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`to undertake the burdensome and costly task of educating another attorney
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`regarding the patent at issue in this proceeding, and the related evidence. The
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`Patent Owner respectfully requests that the Board avoid this prejudice and grant
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`this Motion.
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`Pursuant to the requirements of 37 C.F.R. § 42.10(c), Mr. Vandenburgh, a
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`registered practitioner, will remain as lead counsel in this matter. Mr. Vandenburgh
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`is a partner at Carlson Caspers, the same law firm that is representing the Patent
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`Owner in the related federal court action involving the patent at issue here, as well
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`as the patents at issue in the related instituted inter partes review proceedings. Ms.
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`Norgard has worked with Mr. Vandenburgh on other similar matters.
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`Pursuant to the order in this IPR authorizing motions for pro hac vice and
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`the requirements of the “Order -- Authorizing Motion for Pro Hac Vice
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`Admission” Case IPR2013-00639, Paper 7, this Motion is also supported by the
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`Declaration of Tara C. Norgard (Exhibit 2217), filed herewith.
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`In the Declaration of Tara C. Norgard (Ex. 2217), Ms. Norgard attests that
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`she has read and will comply with the Patent Office Trial Practice Guide and the
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`Board’s Rules of Practice set forth in 37 C.F.R. § 42. Ms. Norgard further attests
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`that she agrees to be subject to the USPTO’s Rules of Professional Conduct as set
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`forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R. §
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`11.19(a).
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`For the foregoing reasons, and in view of the Declaration submitted
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`herewith, Patent Owner submits that good cause exists for the pro hac vice
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`admission of Tara C. Norgard and respectfully requests that the Board grant this
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`motion.
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`Dated: October 30, 2020.
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`Respectfully submitted,
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`/ J. Derek Vandenburgh /
`J. Derek Vandenburgh (Lead Counsel)
`Registration No. 32,179
`Carlson, Caspers, Vandenburgh
` & Lindquist, P.A.
`225 South Sixth Street, Suite 4200
`Minneapolis, MN 55402
`Telephone: (612) 436-9600
`Facsimile: (612) 436-9650
`Email: DVandenburgh@carlsoncaspers.com
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`Lead Counsel for Patent Owner
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`CERTIFICATION OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e) and the agreement of the parties, the
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`undersigned certifies that on October 30, 2020, a true and correct copy of the
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`foregoing Patent Owner’s Unopposed Motion for Pro Hac Vice Admission of Tara
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`C. Norgard, along with the accompanying Exhibit 2217, was served via electronic
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`mail upon the following:
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`Cyrus A. Morton (Reg. No. 44,954)
`Sharon Roberg-Perez (Reg. No. 69,600)
`Christopher A. Pinahs (Reg. No. 76,375)
`William E. Manske (pro hac vice)
`Emily J. Tremblay (pro hac vice)
`Robins Kaplan LLP
`800 LaSalle Avenue, Suite 2800
`Minneapolis, MN 55401
`Phone: 349-8500
`Fax: 612-339-4181
`Email: Cmorton@robinskaplan.com
`Email: Sroberg-perez@robinskaplan.com
`Email: Cpinahs@robinskaplan.com
`Email: WManske@RobinsKaplan.com
`Email: ETremblay@RobinsKaplan.com
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` /
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` J. Derek Vandenburgh /
`J. Derek Vandenburgh (Lead Counsel)
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