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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG DISPLAY CO., LTD.,
`Petitioner,
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`v.
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`SOLAS OLED, LTD.,
`Patent Owner.
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`Case No. IPR2020-00320
`Patent No. 7,446,338
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`PETITIONER’S UNOPPOSED MOTION FOR ADMISSION
`PRO HAC VICE OF ROBERT T. HASLAM UNDER 37 C.F.R. § 42.10
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`I.
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`Relief Requested
`Pursuant to 37 C.F.R. § 42.10, and in accordance with the Board’s Order,
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`IPR2020-00320
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`Paper No. 7 in Case IPR2013-00639, and the Notice of Filing Date Accorded to
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`Petition (Paper No. 5), Petitioner requests that the Board admit Robert T. Haslam
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`pro hac vice in this proceeding. Counsel for Patent Owner has informed the
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`undersigned that Patent Owner does not oppose this motion.
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`II.
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`Statement of Facts
`37 C.F.R. § 42.10(c) states that the Board “may recognize counsel pro hac
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`vice during a proceeding upon a showing of good cause, subject to the condition that
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`lead counsel be a registered practitioner and to any other conditions as the Board
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`may impose. For example, where the lead counsel is a registered practitioner, a
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`motion to appear pro hac vice by counsel who is not a registered practitioner may
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`be granted upon showing that counsel is an experienced litigating attorney and has
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`an established familiarity with the subject matter at issue in the proceeding.” The
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`facts, supported by the attached Declaration of Robert T. Haslam in Support of
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`Petitioner’s Motion for Admission Pro Hac Vice (Ex. 1023, “Haslam Decl.”),
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`establish good cause to admit Mr. Haslam pro hac vice in this proceeding.
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`Lead counsel, David A. Garr, is a registered practitioner.
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`Counsel, Robert T. Haslam, is an experienced litigation attorney with forty
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`four years in private law practice and has substantial experience with patent
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`IPR2020-00320
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`litigation. Haslam Decl. at ¶ 9. Mr. Haslam has been counsel in over 50 patent
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`infringement matters, beginning in 1988, including cases pending in various district
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`courts. Id. Mr. Haslam, as a member of the American College of Trial Lawyers, has
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`experience with fact and expert discovery, trials, appeals, dispositive motions, and
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`Markman hearings. Id.
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`Mr. Haslam is a member in good standing of the Northern District of
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`California Bar. Id. at ¶ 2. He has no suspensions or disbarments from practice, nor
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`any application for admission to practice denied, nor any sanctions or contempt
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`citations. Id. at ¶¶ 3–5.
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`Mr. Haslam has familiarity with the subject matter and patent at issue in this
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`proceeding, U.S. Patent No. 7,446,338 (“the ’338 Patent”), including its prosecution
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`history and the scientific field to which the ’338 Patent is addressed. Haslam Decl.
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`at ¶ 10. In particular, Mr. Haslam has been advising the Petitioner throughout the
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`instant IPR proceeding, and has thereby developed a thorough understanding of the
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`’338 Patent, the relevant art, and scientific field. Id. Mr. Haslam is also familiar with
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`the U.S. Patents and subject matter at issue in related proceedings IPR2020-00140
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`and IPR2019-01668, id., and Petitioner is requesting that the Board admit Mr.
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`Haslam pro hac vice in those proceedings as well.
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`Mr. Haslam has read and will comply with the Office Patent Trial Guide and
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`the Board’s Rules of Practices for Trials set forth in Part 42 of Title 37, C.F.R., and
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`IPR2020-00320
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`he agrees to be subject to the USPTO Rules of Professional Conduct set forth in 37
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`C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a). Id.
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`at ¶¶ 6–7. Mr. Haslam has not applied to appear pro hac vice in any other proceeding
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`before the Office within the last three (3) years. Id. at ¶ 8.
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`III. Analysis
`The facts contained in the Statement of Facts above, and contained in the
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`Haslam Declaration, establish that there is good cause to admit Mr. Haslam pro hac
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`vice in this proceeding, under 37 C.F.R. § 42.10. Lead counsel is a registered
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`practitioner, Mr. Haslam is an experienced litigation attorney, and Mr. Haslam has
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`an established familiarity with the subject matter at issue in this proceeding.
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`IV. Conclusion
`For the foregoing reasons, Petitioner respectfully requests that the Board
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`admit Robert T. Haslam pro hac vice in this proceeding.
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`Date: August 20, 2020
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`Respectfully submitted,
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`By: /David A. Garr/
`David A. Garr
` Registration No. 74,932
`Peter P. Chen
` Registration No. 39,631
`Grant D. Johnson
`Registration No. 69,915
`COVINGTON & BURLING LLP
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`Attorneys for Petitioner
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`IPR2020-00320
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the above document was served on
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`August 20, 2020, by filing this document through the Patent Trial and Appeal Board
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`End to End System as well as delivering a copy via electronic mail upon the
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`following attorneys of record for the Patent Owner:
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`Neil Rubin
`Kent Shum
`Reza Mirzaie
`RUSS AUGUST & KABAT
`nrubin@raklaw.com
`kshum@raklaw.com
`rmirzaie@raklaw.com
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`Date: August 20, 2020
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`/David A. Garr/
`David A. Garr
`Registration No.: 74,932
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