`Filed: September 1, 2020
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
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`INTEL CORPORATION,
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`Petitioner
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`v.
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`FG SRC LLC,
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`Patent Owner
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`_______________________
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`IPR2020-001449
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`Patent No. 7,149,867
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`________________________
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`PATENT OWNER’S MOTION FOR
`PRO HAC VICE ADMISION OF CECIL E. KEY
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`Patent Owner FG SRC LLC (“Patent Owner”) respectfully requests that the
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`Board recognize and admit Cecil E. Key as counsel pro hac vice to represent Patent
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`Owner during the above-captioned proceeding. The bases and support for Patent
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`Owner’s requests are as follows.
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` 1. Timing of Patent Owner’s Request
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`Patent Owner’s motion is being filed no sooner than twenty-one (21) days after
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`the service of the petition.
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` 2. Good Cause Bases for Patent Owner’s Request
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`The Board may recognize counsel pro hac vice during a proceeding upon a
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`showing of good cause, subject to the condition that lead counsel is a registered
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`practitioner and a declaration of the party seeking admission is included with the
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`Request. 37 C.F.R. § 42.10(c). Good cause has been shown where, for example, the
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`attorney for which pro hac vice admission is sought is an experienced patent litigator
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`and has a familiarity with the subject matter at issue in the proceeding, and the
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`admission of the party’s counsel will facilitate the party’s ability to effectively
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`participate in the proceeding. Patent Owner respectfully submits that all of these
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`conditions have been met here.
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`Patent Owner’s lead counsel, Jay P. Kesan, is a registered practitioner. As
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`demonstrated by his declaration, Mr. Key is an experienced litigator who has litigated
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`patent infringement cases for various parties in federal district courts throughout the
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`United States and before the Court of Appeals for the Federal Circuit. Id. at ¶¶ 3-7.
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`Mr. Key’s legal career spans over twenty (20) years. See Id. at ¶ 2. Mr. Key has
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`extensive experience in litigating patent infringement cases and has served as lead
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`counsel in such cases. Id. at ¶ 6. Mr. Key has been previously been admitted to practice
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`pro hac vice before the Board and participated in trials before the Board. Id. at ¶ 11.
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`Mr. Key has read and is familiar with the patent at issue in this proceeding
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`and its file history, as well as the prior art and other arguments that have been
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`asserted by Petitioner. Id. at ¶ 12.
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`Patent Owner submits that Mr. Key’s participation will assist it and its lead
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`counsel in effectively participating in this proceeding and will facilitate timely
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`completion of the trial proceeding.
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`Mr. Key has never been suspended, disbarred, sanctioned, or cited for contempt
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`by any court or administrative body, and has never had an application for admission to
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`practice before a court or agency denied. Id. at ¶¶ 7-8. Mr. Key is a member in good
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`standing of the Bars of Virginia and the District of Columbia. Id. at ¶ 2. Mr. Key
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`agrees to be subject to the Office Patent Trial Practice Guide, the Board’s Rules of
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`Practice for Trials set forth in part 42 of 37 C.F.R, and the USPTO’s Rules of
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`Professional Conduct set forth in 37 C.F.R. §§ 11.101 et. seq., and submit to
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`disciplinary jurisdiction under 37 C.F.R. § 11.19(a). Id. at ¶¶ 9-10.
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`3. Conclusion
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`For the foregoing reasons, Patent Owner respectfully requests that the PTAB
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`recognize Cecil E. Key as its counsel, pro hac vice, in this proceeding.
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`Date: September 1, 2020
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` Respectfully submitted,
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`/Jay P. Kesan /
`Jay P. Kesan, Reg. No. 37,488
`jkesan@dimuro.com
`DIMUROGINSBERG, PC
` DGKEYIP GROUP
`1750 Tyson’s Blvd., Suite 1500
`Tysons Corner, VA 22102
`Telephone: (703) 289-5118
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§42.6(3)(1), 42.6(e)(4), and 42.25(b), the undersigned
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`certifies that a complete copy of Patent Owner’s Motion for Pro Hac Vice Admission
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`of Cecil E Key was filed electronically through the Patent Trial and Appeal
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`Board’s PTAB E2E System and provided, via electronic service, to the Petitioner
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`by serving the correspondence address of record as follows:
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`Brian C. Nash
`PILLSBURY WINTHROP SHAW PITTMAN LLP
`401 Congress Avenue, Suite 1700
`Austin, TX 78701
`brian.nash@pillsburylaw.com
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`Dated: September 1, 2020
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`/Jay P. Kesan /
`Jay P. Kesan
`Reg. No. 38,488
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