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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
`v.
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`TELEFONAKTIEBOLAGET LM ERICSSON,
`Patent Owner.
`____________
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`Case IPR2021-00539
`U.S. Patent 9,860,044
`____________
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`PATENT OWNER’S MOTION FOR WITHDRAWAL
`AND SUBSTITUTION OF COUNSEL
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`Patent Owner’s Motion for Withdrawal and Substitution of Counsel
`IPR2021-00539 / U.S. Patent 9,860,044
`37 C.F.R. §42.10 – STATEMENT OF RELIEF REQUESTED
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`I.
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`Pursuant to 37 C.F.R. § 42.10, Patent Owner Telefonaktiebolaget LM Ericsson
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`(“Ericsson”) respectfully requests that the Board withdraw J. Andrew Lowes and
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`Clint Wilkins of Haynes and Boone, LLP as its counsel and permit substitution of
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`new counsel.
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`II. STATEMENT SHOWING GOOD CAUSE FOR THE BOARD TO
`AUTHORIZE WITHDRAWAL AND SUBSTITUTION OF COUNSEL
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`Patent Owner requests that the current designated lead and back-up counsel,
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`J. Andrew Lowes and Clint Wilkins, Haynes and Boone, LLP, be deemed
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`withdrawn from the present proceeding. To the extent not already filed, an
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`Updated Mandatory Notice Under 37 C.F.R. § 42.8(a)(3) and Power of Attorney
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`will be filed promptly to reflect new counsel from Noroozi PC. All Haynes and
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`Boone, LLP counsel will be withdrawn from the present proceeding and counsel
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`from Noroozi PC will be substituted as counsel to represent Patent Owner.
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`Counsel meets the requirements of 37 C.F.R. § 42.10(c) and are registered
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`practitioners. Counsel has conferred with current counsel and reasonable steps
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`have been taken to “avoid foreseeable prejudice to the rights of the client,
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`including giving due notice to his or her client, [and] allowing time for
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`employment of another practitioner.” See 37 C.F.R. § 10.40(a). Further, Patent
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`Owner believes that granting this motion will not hinder the economy, the integrity
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`of the patent system, the efficient administration of the Office, or the ability of the
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`2
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`Patent Owner’s Motion for Withdrawal and Substitution of Counsel
`IPR2021-00539 / U.S. Patent 9,860,044
`Office to timely complete this proceeding. See 35 U.S.C. § 316(b). Patent Owner
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`verifies that no extensions of time will be sought based on substitution of counsel.
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`III. CONCLUSION
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`Patent Owner respectfully requests that the Board grant its motion for
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`withdrawal of counsel and permit substitution of new counsel.
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`Date: April 22, 2021
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`Respectfully submitted,
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`By: /J. Andrew Lowes/
`J. Andrew Lowes, Reg. No. 40,706
`Clint Wilkins, Reg. No. 62,448
`HAYNES AND BOONE, LLP
`2323 Victory Ave., Suite 700
`Dallas, TX 75219
`P: 972-680-7557
`F: 214-200-0853
`Counsel for Patent Owner
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`3
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`Patent Owner’s Motion for Withdrawal and Substitution of Counsel
`IPR2021-00539 / U.S. Patent 9,860,044
`CERTIFICATE OF SERVICE
`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e)(4), that
`service was made on counsel for Petitioner and counsel being substituted for Patent
`Owner as detailed below:
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`Date of Service
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`April 22, 2021
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`Manner of Service Electronic Service: todd.friedman@kirkland.com;
`james.marina@kirkland.com; jon.carter@kirkland.com;
`bao.nguyen@kirkland.com; kevin.bendix@kirkland.com;
`Samsung_Ericsson_IPR@kirkland.com
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`doug@noroozipc.com; kayvan@noroozipc.com;
`jason@noroozipc.com
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`Document Served Patent Owner’s Motion for Withdrawal and Substitution
`of Counsel
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`Todd M. Friedman, P.C.
`James E. Marina
`Jon R. Carter
`Bao Nguyen
`Kevin Bendix
`KIRKLAND & ELLIS LLP
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`Douglas L. Bridges
`Kayvan B. Noroozi
`Jason Wejnert
`NOROOZI PC
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`Persons served
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`Respectfully submitted,
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`/J. Andrew Lowes/
`J. Andrew Lowes, Reg. No. 40,706
`Clint Wilkins, Reg. No. 62,448
`Counsel for Patent Owner
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`4
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