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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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`KOSS CORPORATION,
`Patent Owner.
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`Case IPR2021-00255
`Patent 10,298,451
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`PETITIONER’S MOTION FOR PRO HAC VICE ADMISSION
`OF MICHAEL PIEJA
`UNDER 37 C.F.R. § 42.10(c)
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`Case IPR2021-00255
`Docket No. 50095-0020IP1
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`Pursuant to 37 C.F.R. § 42.10(c), the Petitioner, Apple Inc. (“Apple”)
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`respectfully requests that the Board recognize Michael Pieja as counsel pro hac
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`vice in this proceeding. Apple seeks the counsel of Michael Pieja due to his
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`experience in representing Apple Inc. in other patent-related matters and
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`particularly due to his familiarity with the substantive and technical issues
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`involved in this proceeding. This motion is authorized by the Notice of Filing
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`Date Accorded to Petition and Time for Filing Patent Owner Preliminary
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`Response that was mailed on December 8, 2020.
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`I.
`Statement of Facts
`Michael Pieja is a patent litigation attorney with more than 15 years of
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`experience representing clients in cases involving consumer electronics,
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`computer software, and semiconductors. Mr. Pieja regularly litigates patent
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`cases before various Federal District Courts, and the International Trade
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`Commission. Through his practice in such cases, Mr. Pieja has gained
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`substantial experience in trials, discovery, Markman hearings, and appeals. Mr.
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`Pieja is currently a partner at Goldman Ismail Tomaselli Brennan & Baum LLP,
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`focusing on litigation, including patent litigation. Apple provides Exhibit A, as
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`evidence, Mr. Pieja’s biography.
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`Case IPR2021-00255
`Docket No. 50095-0020IP1
`Michael Pieja also has particular experience and familiarity with the
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`substantive and technical issues involved in this inter partes review proceeding
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`and other inter partes review proceedings challenging other patents that have
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`been asserted against Apple in KOSS Corporation v. Apple Inc., 6:2020cv00665
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`(W.D.Tex.) (IPR2021-00305 and IPR2021-00381). For instance, Mr. Pieja
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`serves as trial counsel for Apple in the litigation referenced above that involves
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`these patents has, as a result, gained familiarity with the patents and prior art
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`references at issue. Apple has invested significant financial resources in each of
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`these proceedings, and Mr. Pieja will be taking a leading role with respect to the
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`patent that is the subject of the present proceeding. Moreover, through his
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`representation in the IPR proceedings, Apple has developed a particular
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`relationship with Mr. Pieja such that Apple desires to continue the relationship
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`with Mr. Pieja for the purpose of this proceeding.
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`II.
`Affidavit of Individual Seeking to Appear
`This Motion for Pro Hac Vice Admission is accompanied by an Affidavit
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`of Michael Pieja. Accordingly, Apple submits that there is good cause under 37
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`C.F.R. § 42.10(c) for the Board to recognize Michael Pieja as counsel pro hac
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`vice during this proceeding.
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`Date: 12/10/2021
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`Case IPR2021-00255
`Docket No. 50095-0020IP1
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`Respectfully submitted,
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`/Roberto Devoto/
`W. Karl Renner, Reg. No. 41,265
`Roberto Devoto, Reg. No. 55,108
`Ryan Chowdhury, Reg. No. 74,466
`Fish & Richardson P.C.
`3200 RBC Plaza, 60 South Sixth Street
`Minneapolis, MN 55402
`T: 202-783-5070
`F: 877-769-7945
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`Case IPR2021-00255
`Docket No. 50095-0020IP1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR § 42.6(e), the undersigned certifies that on December
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`10, 2021, a complete and entire copy of this Petitioner’s Motion for Pro Hac Vice
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`Admission of Michael Pieja, and its exhibit, were provided via email, to the Patent
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`Owner by serving the correspondence addresses of record as follows:
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`Mark G. Knedeisen
`Laurén Murray
`Brian P. Bozzo
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`K&L GATES LLP
`K&L Gates Center, 210 Sixth Avenue
`Pittsburgh, PA 15222
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`Email: mark.knedeisen@klgates.com
`Email: lauren.murray@klgates.com
`Email: brian.bozzo@klgates.com
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` /Crena Pacheco/
`Crena Pacheco
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(617) 956-5938
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