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Case No. IPR2020-01192
`U.S. Patent No. 8,421,618
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`LBT IP I, LLC,
`Patent Owner.
`____________
`
`Case IPR2020-01192
`U.S. Patent No. 8,421,618
`____________
`PATENT OWNER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION PURSUANT TO 37 C.F.R. § 42.10(C)
`
`
`INTRODUCTION
`
`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner LBT IP I LLC (“Patent
`
`I.
`
`Owner” or “LBT”) respectfully requests that the Board recognize Brian S. Seal as
`
`counsel pro hac vice in this proceeding. Patent Owner’s lead counsel in this
`
`proceeding is a registered practitioner and, as illustrated below, Mr. Seal is an
`
`experienced litigator with an established familiarity with this proceeding’s subject
`
`matter. Thus, there is good cause for the Board to recognize Mr. Seal pro hac vice
`
`in this proceeding. Counsel for Petitioner has indicated that it does not oppose this
`
`motion.
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`IWASHINGTON\000150560\0001\584770.v1-5/11/21
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`Case No. IPR2020-01192
`U.S. Patent No. 8,421,618
`
`II. TIME FOR FILING
`
`This Motion for Pro Hac Vice Admission is being filed no sooner than twenty-
`
`one (21) days after service of the petition. Unified Patents, Inc. v. Parallel Iron, LLC,
`
`Case IPR2013-00639, Paper No. 7 (P.T.A.B. Oct. 15, 2013).
`
`III. STATEMENT OF FACTS
`
`Patent Owner’s lead and back-up counsel are registered practitioners. Where
`
`lead counsel is a registered practitioner, the Board may permit a nonregistered
`
`practitioner to appear pro hac vice “upon a showing that counsel is an experienced
`
`litigating attorney and has established familiarity with the subject matter at issue in
`
`the proceeding.” 37 C.F.R. §42.10(c); Unified Patents, Case IPR2013-00639, Paper
`
`7 (setting forth requirements for pro hac vice admission). As set forth in his
`
`Declaration submitted herewith (Ex. 3003), Mr. Seal is an experienced litigator. He
`
`is a shareholder in the firm of Butzel Long PC with over 20 years of experience
`
`representing clients in patent and technology-related litigation, including matters
`
`involving similar technology to that at issue in this proceeding. Ex. 3003 at ¶ 9.
`
`Mr. Seal has litigated patent matters through trial and appeal and has argued
`
`complex claim construction and invalidity issues in numerous district court
`
`proceedings. Id. Mr. Seal is also familiar with the subject matter of this proceeding.
`
`Id. at ¶10. He is lead counsel counsel for Patent Owner in the related district court
`
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`Case No. IPR2020-01192
`U.S. Patent No. 8,421,618
`litigation on the patent at issue in this inter partes review, U.S. Patent No. 8,421,618
`
`(“’618 Patent”). Id. As such, he has reviewed and analyzed the ’618 Patent. Id.
`
`Based on his work in the district court litigation and the other facts detailed in
`
`his declaration, Mr. Seal has significant familiarity with the subject matter in this
`
`proceeding. Patent Owner wishes to apply Mr. Seal’s knowledge of the patent and
`
`litigation experience by employing him as counsel in this proceeding. Admission of
`
`Mr. Seal pro hac vice will enable Patent Owner to avoid unnecessary expense and
`
`duplication of work. Ex. 3003 at ¶11.
`
`Because Mr. Seal is an experienced practitioner with an established familiarity
`
`with the subject matter of this proceeding, Patent Owner respectfully submits that
`
`there is good cause under 37 C.F.R. § 42.10(c) to recognize him as counsel pro hac
`
`vice during this proceeding.
`
`
`
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`Case No. IPR2020-01192
`U.S. Patent No. 8,421,618
`IV. DECLARATION OF INDIVIDUAL SEEKING TO APPEAR
`
`This motion for Pro Hac Vice Admission is supported by the accompanying
`
`Declaration of Brian S. Seal (Ex. 3003), demonstrating that Mr. Seal meets the
`
`requirements specified in Unified Patents, IPR2013-00639, Paper 7. Id. at ¶¶2-11.
`
`Respectfully submitted,
`
`BUTZEL LONG, P.C.
`
`/Mitchell S. Zajac/
`Mitchell S. Zajac
`Registration No. 76,818
`Lead Counsel for Patent Owner
`
`
`Date: May 11, 2021
`
`150 W. Jefferson Avenue
`Suite 100
`Detroit, MI 48226
`Tel: 313-225-7000
`Fax: 313-225-7080
`
`
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`Case No. IPR2020-01192
`U.S. Patent No. 8,421,618
`CERTIFICATE OF SERVICE (37 C.F.R. § 42.6(e))
`
`The undersigned hereby certifies that the foregoing PATENT OWNER’S
`
`
`
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION PURSUANT TO 37
`
`C.F.R. § 42.10(C) is being served electronically via e-mail on May 11, 2021, in its
`
`entirety on the following counsel of record for Petitioners:
`
`Back-Up Counsel
`Adam P. Seitz (adam.seitz@eriseip.com)
`Robin Snader (robin.snader@eriseip.com)
`Kelly Hughes (Kelly.hughes@eriseip.com)
`Jocelyn Ram (jocelyn.ram@eriseip.com)
`
`
`
`Respectfully submitted,
`
`BUTZEL LONG, PC
`
`/Mitchell S. Zajac/
`Mitchell S. Zajac
`Registration No. 76,818
`Lead Counsel for Patent Owner
`
`Lead Counsel
`Jennifer C. Bailey (Reg. No. 52,583)
`Erise IP, P.A.
`7015 College Boulevard, Suite 700
`Overland Park, KS 66211
`Main: (913) 777-5600
`Fax: (913) 777-5601
`Email: Jennifer.bailey@eriseip.com
`
`
`
`
`
`
`Date: May 11, 2021
`
`150 W. Jefferson Avenue
`Suite 100
`Detroit, MI 48226
`Tel: 313-225-7000
`Fax: 313-225-7080
`
`
`
`IWASHINGTON\000150560\0001\584770.v1-5/11/21
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