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`Filed on behalf of Intel Corporation
`By: Grant K. Rowan, Reg. No. 41,278
`Wilmer Cutler Pickering Hale and Dorr LLP
`1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: grant.rowan@wilmerhale.com
`
` haixia.lin@wilmerhale.com
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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`Intel Corporation
`Petitioner
`
`v.
`
`ParkerVision, Inc.
`Patent Owner
`
`__________________________________________________
`
`Case No. IPR2020-01265
`U.S. Patent No. 7,110,444
`__________________________________________________
`
`
`PETITIONER’S MOTION FOR ADMISSION
`PRO HAC VICE OF MICHAEL J. SUMMERSGILL
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`Statement of Precise Relief Requested
`
`Case No. IPR2020-01265
`U.S. Patent No. 7,110,444
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`
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`Pursuant to 37 C.F.R. § 42.10(c) and Paper No. 4 in the above captioned
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`I.
`
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`proceeding authorizing the parties to file motions for pro hac vice admission,
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`Petitioner respectfully requests that the Patent Trial and Appeal Board (“Board”)
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`admit Michael J. Summersgill pro hac vice in this proceeding, Case No. IPR2020-
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`01265.
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`II.
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`
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`Statement of Facts Showing Good Cause for the Board to Recognize
`Counsel Pro Hac Vice During the Proceeding
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`In accordance with 37 C.F.R. § 42.10(c), the Board may recognize counsel
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`pro hac vice during a proceeding upon a showing of good cause, subject to the
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`condition that lead counsel be a registered practitioner and to any other conditions
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`as the Board may impose. Section 42.10(c) provides that “where the lead counsel
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`is a registered practitioner, a motion to appear pro hac vice by counsel who is not a
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`registered practitioner may be granted upon showing that counsel is an experienced
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`litigating attorney and has an established familiarity with the subject matter at issue
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`in the proceeding.” The facts here establish good cause for the Board to recognize
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`Michael J. Summersgill pro hac vice in this proceeding.
`
`1.
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`2.
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`Lead counsel, Grant K. Rowan, is a registered practitioner.
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`Counsel, Michael J. Summersgill, is an experienced litigator and has
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`an established familiarity with the subject matter at issue in the proceeding.
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`
`
`2
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`
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`Accompanying this motion as Exhibit 1020 is the April 30, 2021 Declaration of
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`Case No. IPR2020-01265
`U.S. Patent No. 7,110,444
`
`
`
`Michael J. Summersgill in Support of this Motion for Admission Pro Hac Vice
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`(“Summersgill Decl.”). In his declaration, Mr. Summersgill declares:
`
`I am a member in good standing of the Bar of the Commonwealth of
`Massachusetts (Bar No. 81682). I am also admitted to practice before
`the Massachusetts Supreme Judicial Court, the United States Court of
`Appeals for the Federal Circuit, the United States Court of Appeals
`for the First Circuit, the United States Court of Appeals for the
`Second Circuit, the United States Court of Appeals for the Ninth
`Circuit, the United States District Court for the District of
`Massachusetts, and the United States District Court for the Eastern
`District of Michigan.
`Summersgill Decl. ¶ 3 (Ex. 1020). Mr. Summersgill also asserts:
`I am familiar with the subject matter at issue in these proceedings. I
`have reviewed the papers and exhibits filed in these proceedings. I
`also participated in drafting the Petitions for Inter Partes Review in
`these proceedings and have reviewed Patent Owner’s Preliminary
`Responses filed in these proceedings.
`I am representing the Petitioners, Intel Corporation, in the following
`United States District Court case: ParkerVision, Inc. v. Intel Corp.,
`No. 6:20-cv-108-ADA (W.D. Tex.), which involves the patents at
`issue in these proceedings, as well as the prior art references at issue
`in these proceedings.
`Summersgill Decl. ¶¶ 11-12 (Ex. 1020).
`3.
`In his declaration, Mr. Summersgill also attests to each of the listed
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`items required by the “Order – Authorizing Motion for Pro Hac Vice Admission”
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`in Case IPR2013-00639, Paper 7. See Summersgill Decl. ¶¶ 1-13 (Ex. 1020).
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`3
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`III. Conclusion
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`Case No. IPR2020-01265
`U.S. Patent No. 7,110,444
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`
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`For the foregoing reasons, Petitioner respectfully requests that the Board
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`admit Michael J. Summersgill pro hac vice in this proceeding. The undersigned
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`authorizes the Office to charge $250 to Deposit Account No. 08-0219 for the fees
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`set forth in 37 C.F.R. § 42.15(e) for this pro hac vice motion. Please charge any
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`shortage of fees or credit any overpayments to the above Deposit Account.
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`Respectfully Submitted,
`
`/Brian J. Lambson/
`Brian J. Lambson, Reg. No. 72,570
`Wilmer Cutler Pickering
` Hale and Dorr LLP
`
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`Dated: May 11, 2021
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`4
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`
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`Table of Exhibits for U.S. Patent 7,110,444 Petition for Inter Partes Review
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`Case No. IPR2020-01265
`U.S. Patent No. 7,110,444
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`
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`Exhibit
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`Description
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`1001
`1002
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`1003
`1004
`1005
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`1006
`1007
`1008
`1009
`1010
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`1011
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`1012
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`1013
`1014
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`1015
`1016
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`1017
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`1018
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`1019
`1020
`1021
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`U.S. Patent No. 7,110,444 (“’444 patent”)
`Declaration of Dr. Vivek Subramanian Regarding U.S. Patent No. 7,110,444
`(“Subramanian Decl.”)
`’444 patent File History
`U.S. Patent No. 6,230,000 (“Tayloe”)
`SN74CBT3253D Dual 1-of-4 FET Multiplexer/Demultiplexer (rev. ed. May
`1998) (“TI Datasheet”)
`U.S. Patent No. 6,018,553 (“Sanielevici”)
`U.S. Patent No. 6,317,589 (“Nash”)
`U.S. Patent No. 4,985,647 (“Kawada”)
`U.S. Patent No. 5,764,693 (“Taylor”)
`“Modem,” IEEE Standard Dictionary of Electrical and Electronics Terms (4th
`ed. 1988)
`“Modem,” McGraw-Hill Dictionary of Scientific and Technical Terms, (5th
`ed. 1994)
`“Modem,” Websters New World Dictionary of American English (3rd ed.
`1988)
`U.S. Patent No. 5,742,641 (“Dingsor”)
`“Capacitor,” Microsoft Press Computer Dictionary (2d ed. 1994)
`
`“Capacitor,” IBM Dictionary of Computing (10th ed. 1994)
`ParkerVision v. Intel Corp., No. 6:20-cv-108-ADA, D.I. 24 (June 26, 2020)
`(“Trial Setting Order”)
`ParkerVision v. Intel Corp., No. 6:20-cv-108-ADA, D.I. 25 (June 26, 2020)
`(“Markman Setting Order”)
`Patent Owner’s Preliminary Infringement Contentions, ParkerVision v. Intel
`Corp., No. 6:20-cv-108-ADA (June 26, 2020)
`Declaration of Maureen M. Honeycutt (“Honeycutt Decl.”)
`Declaration of Michael Summersgill (“Summersgill Decl.”)
`Declaration of Todd Zubler (“Zubler Decl.”)
`
`5
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`
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`Case No. IPR2020-01265
`U.S. Patent No. 7,110,444
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`
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` CERTIFICATE OF SERVICE
`I hereby certify that on May 11, 2021, I caused a true and correct copy of the
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`materials:
`
`•
`
`•
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`Petitioner’s Motion for Admission Pro Hac Vice of Michael J.
`Summersgill
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`Declaration of Michael J. Summersgill in Support of Motion for
`Admission Pro Hac Vice (Exhibit 1020)
`
`•
`Petitioner’s Updated List of Exhibits
`To be served via electronic mail on the following counsel of record for Patent
`Owner:
`
`JCharkow@goldbergsegalla.com
`ciyer@goldbergsegalla.com
`smandir@goldbergsegalla.com
`
`Respectfully submitted,
`
`/Brian J. Lambson/
`Brian J. Lambson
`Registration No. 72,570
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`6
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