`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`LKQ Corporation and Keystone Automotive Industries, Inc.,
`
`Petitioners,
`
`v.
`
`GM Global Technology Operations LLC,
`
`Patent Owner.
`
`_________________
`
`Case No.: IPR2020-00534
`U.S. Design Patent No. D797,625 S
`__________________________
`
`
`
`
`
`PETITIONER’S UNOPPOSED MOTION
`FOR ADMISSION PRO HAC VICE
`OF IFTEKHAR A. ZAIM UNDER 37 C.F.R. § 42.10
`
`
`
`IPR2020-00534
`U.S. Design Patent No. D797,625 S
`
`
`TABLE OF PETITIONER’S EXHIBITS
`
`Description
`
`Exhibit
`No.
`
`1001
`
`U.S. Patent No. D797,625 (“the ’625 Patent”).
`
`1002
`
`File History for U.S. Patent No. D797,625.
`
`1004
`
`Declaration of James M. Gandy, dated February 7, 2020.
`
`1004
`
`Declaration of Jason C. Hill, dated February 7, 2020.
`
`1005
`
`2018 Chevrolet Equinox Brochure, http://www.auto-
`brochures.com/makes/Chevrolet/Equinox/Chevrolet_US%20Equinox
`_2018.pdf.
`
`1006
`
`U.S. Design Patent No. D773,340 “Lian.”
`
`1007
`
`1008
`
`2010 Hyundai Tucson Brochure, http://www.auto-
`brochures.com/makes/Hyundai/Tucson/Hyundai_US%20Tucson_201
`0.pdf, archived on April 2, 2014 by Internet Archive organization’s
`“Wayback Machine” at
`https://web.archive.org/web/20140402003154/http://www.auto-
`brochures.com/makes/Hyundai/Tucson/Hyundai_US%20Tucson_201
`0.pdf.
`
`Exemplary images of the 2010 Hyundai Tucson Brochure,
`http://www.auto-
`brochures.com/makes/Hyundai/Tucson/Hyundai_US%20Tucson_201
`0.pdf, archived on April 2, 2014 by Internet Archive organization’s
`“Wayback Machine” at
`https://web.archive.org/web/20140402003154/http://www.auto-
`brochures.com/makes/Hyundai/Tucson/Hyundai_US%20Tucson_201
`0.pdf.
`
`1009
`
`File History of U.S. Patent No. D773,340 “Lian”
`
`1010
`
`File History of U.S. Pat. App. Ser. No. 29/516,319 (“the ’319
`Application”)
`
`i
`
`
`
`IPR2020-00534
`U.S. Design Patent No. D797,625 S
`
`
`Exhibit
`No.
`
`1011
`
`1012
`
`Description
`
`Source code of Auto-brochures.com, http://www.auto-
`brochures.com/, archived on March 13, 2014 by Internet Archive
`organization’s “Wayback Machine” at
`https://web.archive.org/web/20140313222453/http://www.auto-
`brochures.com/.
`
`Source code of Auto-brochures.com, http://www.auto-
`brochures.com/, archived on May 17, 2014 by Internet Archive
`organization’s “Wayback Machine” at
`https://web.archive.org/web/20140517005107/http://www.auto-
`brochures.com/.
`
`1013
`
`Declaration of Margaret Herrmann, dated February 6, 2020.
`
`1014
`
`Curriculum Vitae of James M. Gandy.
`
`1015
`
`Curriculum Vitae of Jason C. Hill
`
`1016
`
`Declaration of Iftekhar A. Zaim in support of Petitioner’s Unopposed
`Motion for Admission Pro Hac Vice under 37 C.F.R. § 42.10
`
`ii
`
`
`
`IPR2020-00534
`U.S. Design Patent No. D797,625 S
`
`
`Petitioner LKQ Corporation and Keystone Automotive Industries, Inc.
`
`(“Petitioner”) respectfully requests that the Board admit Iftekhar A. Zaim pro hac
`
`vice in this proceeding. Counsel for Patent Owner GM Global Technology
`
`Operations, LLC confirmed that it does not oppose this motion. This motion is
`
`authorized pursuant to the Notice of Filing Date Accorded to Petition and Time for
`
`Filing Patent Owner Preliminary Response entered in this proceeding. IPR2020-
`
`00534, Paper 3, at 2 (PTAB Feb. 13, 2019).
`
`I.
`
`LEGAL STANDARD
`
`“The Board may recognize counsel pro hac vice during a proceeding upon a
`
`showing of good cause, subject to the condition that lead counsel be a registered
`
`practitioner and to any other conditions as the Board may impose. For example,
`
`where the lead counsel is a registered practitioner, a motion to appear pro hac vice
`
`by counsel who is not a registered practitioner may be granted upon showing that
`
`counsel is an experienced litigating attorney and has an established familiarity with
`
`the subject matter at issue in the proceeding.” 37 C.F.R. §42.10(c); see also Unified
`
`Patents, Inc. v. Parallel Iron, LLC, IPR2013-00639 (PTAB Oct. 15, 2013) (Paper 7)
`
`(requirements for admission pro hac vice). The facts set forth below and in the
`
`accompanying Declaration of Iftekhar A. Zaim in Support of Petitioner’s Motion for
`
`Admission Pro Hac Vice (Ex. 1016, “Zaim Dec.”) establish good cause to recognize
`
`Mr. Zaim pro hac vice in this proceeding.
`
`1
`
`
`
`IPR2020-00534
`U.S. Design Patent No. D797,625 S
`
`II.
`
`STATEMENT OF FACTS
`
`Petitioner’s Lead Counsel in this proceeding, Barry F. Irwin, is a registered
`
`practitioner.
`
`Counsel Iftekhar A. Zaim is an experienced litigation attorney with nearly five
`
`years’ experience in private law practice as an intellectual property litigator,
`
`including substantial experience with patent litigation. Zaim Dec. at ¶ 9. Mr. Zaim
`
`has been substantially involved in more than eight patent cases and proceedings,
`
`including cases before various district courts and the United States International
`
`Trade Commission, as well as in a number of other non-patent cases before United
`
`States District Courts and the United States Court of International Trade. Id. Mr.
`
`Zaim has experience with dispositive motion practice as well as fact and expert
`
`discovery. Id. Mr. Zaim has also served as counsel pro hac vice in a previous inter
`
`partes review proceeding before the Board, IPR2018-00802, and served as first chair
`
`at oral argument in that proceeding. Id.
`
`Mr. Zaim is a member in good standing of the Illinois State Bar. Id. at ¶ 2.
`
`He has no suspensions or disbarments from practice, nor any application for
`
`admission to practice denied, nor any sanctions or contempt citations. Id. at ¶¶ 3–5.
`
`Mr. Zaim is familiar with the subject matter and patent at issue in this
`
`proceeding, U.S. Design Patent No. D797,625 S (“the ’625 Patent”), including its
`
`prosecution history and the technical field to which the ’625 Patent is addressed. Id.
`
`2
`
`
`
`IPR2020-00534
`U.S. Design Patent No. D797,625 S
`
`at ¶ 10. In particular, Mr. Zaim has been a member of the legal team advising the
`
`Petitioner in the instant IPR proceeding and related proceedings since September of
`
`2020 and worked with Petitioner’s expert consultants. Id. Mr. Zaim has thereby
`
`developed a thorough understanding of the ’625 Patent, the relevant art, and the
`
`technical field. Id.
`
`Mr. Zaim has read and will comply with the Office Patent Trial Guide and the
`
`Board’s Rules for Practice for Trials set forth in Part 42 of Title 37, C.F.R., and he
`
`agrees to be subject to the USPTO Rules of Professional Conduct set forth in 37
`
`C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`Id. at ¶¶ 6–7.
`
`III. ANALYSIS
`
`The facts contained in the Statement of Facts above, and contained in the
`
`accompanying Zaim Declaration, set forth good cause to recognize Mr. Zaim pro
`
`hac vice in this proceeding under 37 C.F.R. § 42.10(c). Lead counsel is a registered
`
`practitioner, Mr. Zaim is an experienced litigation attorney, and Mr. Zaim has an
`
`established familiarity with the subject matter at issue in this proceeding.
`
`3
`
`
`
`IPR2020-00534
`U.S. Design Patent No. D797,625 S
`
`IV. CONCLUSION
`
`For the foregoing reasons, Petitioner respectfully requests that the Board
`
`admit Mr. Zaim pro hac vice.
`
`
`Dated: October 16, 2020
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`/Barry F. Irwin, P.C./
`Barry F. Irwin, P.C.
`Registration No. 36,557
`Reid Huefner
`Registration No. 57,341
`Margaret A. Herrmann
`Registration No. 76,096
`Irwin IP LLC
`222 South Riverside Plaza, Suite 2350
`Chicago, IL 60606
`Phone: 312.667.6080
`birwin@irwinip.com
`rhuefner@irwinip.com
`mherrmann@irwinip.com
`
`4
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`
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`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies that a true
`
`copy of the Petitioner’s Unopposed Motion for Admission Pro Hac Vice of Iftekhar
`
`A. Zaim Under 37 C.F.R. 42.10 was served on this 16th day of October, 2020, by e-
`
`mail upon the following:
`
`
`
`
`
`LEAD COUNSEL
`Dorothy P. Whelan, Reg. No. 33,814
`3200 RBC Plaza
`
`
`
`
`60 South Sixth Street
`
`
`
`Minneapolis, MN 55402
`
`
`Tel: 612-335-5070/Fax 877-769-7945
`IPR45343-0018IP1@fr.com
`
`
`
`BACK-UP COUNSEL
`Craig A. Deutsch, Reg. No. 69,264
`Grace J. Kim, Reg. No. 71,977
`Jennifer J. Huang, Reg. No. 64,297
`Joseph A. Herriges, Pro Hac Vice
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Tel: 612-335-5070/Fax 877-769-7945
`PTABInbound@fr.com
`
`/Barry F. Irwin, P.C./
`Barry F. Irwin, P.C.
`Registration No. 36,557
`Irwin IP LLC
`222 South Riverside Plaza, Suite 2350
`Chicago, IL 60606
`Phone: 312.667.6081
`birwin@irwinip.com
`
`
`
`
`Additional electronic service to:
`whelan@fr.com;
`deutsch@fr.com;
`gkim@fr.com;
`jhuang@fr.com; and
`herriges@fr.com.
`
`Patent Owner has consented to service by electronic means.
`
`
`Dated: October 16, 2020
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