`U.S. Patent No. 8,102,256
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.,
`Petitioner,
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`v.
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`LBT IP I, LLC,
`Patent Owner.
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`Case IPR2020-01191
`U.S. Patent No. 8,102,256
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`PATENT OWNER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION PURSUANT TO 37 C.F.R. § 42.10(C)
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`INTRODUCTION
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`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner LBT IP I LLC (“Patent
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`I.
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`Owner” or “LBT”) respectfully requests that the Board recognize Brian S. Seal as
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`counsel pro hac vice in this proceeding. Patent Owner’s lead counsel in this
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`proceeding is a registered practitioner and, as illustrated below, Mr. Seal is an
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`experienced litigator with an established familiarity with this proceeding’s subject
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`matter. Thus, there is good cause for the Board to recognize Mr. Seal pro hac vice
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`in this proceeding. Counsel for Petitioner has indicated that it does not oppose this
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`motion.
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`Case No. IPR2020-01191
`U.S. Patent No. 8,102,256
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`II. TIME FOR FILING
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`This Motion for Pro Hac Vice Admission is being filed no sooner than twenty-
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`one (21) days after service of the petition. Unified Patents, Inc. v. Parallel Iron, LLC,
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`Case IPR2013-00639, Paper No. 7 (P.T.A.B. Oct. 15, 2013).
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`III. STATEMENT OF FACTS
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`Patent Owner’s lead and back-up counsel are registered practitioners. Where
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`lead counsel is a registered practitioner, the Board may permit a nonregistered
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`practitioner to appear pro hac vice “upon a showing that counsel is an experienced
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`litigating attorney and has established familiarity with the subject matter at issue in
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`the proceeding.” 37 C.F.R. §42.10(c); Unified Patents, Case IPR2013-00639, Paper
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`7 (setting forth requirements for pro hac vice admission). As set forth in his
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`Declaration submitted herewith (Ex. 3003), Mr. Seal is an experienced litigator. He
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`is a shareholder in the firm of Butzel Long PC with over 20 years of experience
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`representing clients in patent and technology-related litigation, including matters
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`involving similar technology to that at issue in this proceeding. Ex. 3003 at ¶ 9.
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`Mr. Seal has litigated patent matters through trial and appeal and has argued
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`complex claim construction and invalidity issues in numerous district court
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`proceedings. Id. Mr. Seal is also familiar with the subject matter of this proceeding.
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`Id. at ¶10. He is lead counsel counsel for Patent Owner in the related district court
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`Case No. IPR2020-01191
`U.S. Patent No. 8,102,256
`litigation on the patent at issue in this inter partes review, U.S. Patent No. 8,102,256
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`(“’256 Patent”). Id. As such, he has reviewed and analyzed the ’256 Patent. Id.
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`Based on his work in the district court litigation and the other facts detailed in
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`his declaration, Mr. Seal has significant familiarity with the subject matter in this
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`proceeding. Patent Owner wishes to apply Mr. Seal’s knowledge of the patent and
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`litigation experience by employing him as counsel in this proceeding. Admission of
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`Mr. Seal pro hac vice will enable Patent Owner to avoid unnecessary expense and
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`duplication of work. Ex. 3003 at ¶11.
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`Because Mr. Seal is an experienced practitioner with an established familiarity
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`with the subject matter of this proceeding, Patent Owner respectfully submits that
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`there is good cause under 37 C.F.R. § 42.10(c) to recognize him as counsel pro hac
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`vice during this proceeding.
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`IV. DECLARATION OF INDIVIDUAL SEEKING TO APPEAR
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`This motion for Pro Hac Vice Admission is supported by the accompanying
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`Declaration of Brian S. Seal (Ex. 3003), demonstrating that Mr. Seal meets the
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`requirements specified in Unified Patents, IPR2013-00639, Paper 7. Id. at ¶¶2-11.
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`Respectfully submitted,
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`BUTZEL LONG, P.C.
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`/Mitchell S. Zajac/
`Mitchell S. Zajac
`Registration No. 76,818
`Lead Counsel for Patent Owner
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`Date: May 11, 2021
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`150 W. Jefferson Avenue
`Suite 100
`Detroit, MI 48226
`Tel: 313-225-7000
`Fax: 313-225-7080
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`CERTIFICATE OF SERVICE (37 C.F.R. § 42.6(e))
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`The undersigned hereby certifies that the foregoing PATENT OWNER’S
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`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION PURSUANT TO 37
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`C.F.R. § 42.10(C) is being served electronically via e-mail on May 11, 2021, in its
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`entirety on the following counsel of record for Petitioners:
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`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)
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`Respectfully submitted,
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`BUTZEL LONG, PC
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`/Mitchell S. Zajac/
`Mitchell S. Zajac
`Registration No. 76,818
`Lead Counsel for Patent Owner
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`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
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`Date: May 11, 2021
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`150 W. Jefferson Avenue
`Suite 100
`Detroit, MI 48226
`Tel: 313-225-7000
`Fax: 313-225-7080
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