`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
`
`v.
`
`TELEFONAKTIEBOLAGET LM ERICSSON.,
`Patent Owner.
`____________________
`
`Case IPR2021-00644
`Patent No. 10,484,915
`____________________
`
`UNOPPOSED MOTION FOR ADMISSION PRO HAC VICE OF
`KAYVAN B. NOROOZI
`
`
`
`IPR2021-00644
`MOTION FOR ADMISSION PRO HAC VICE OF KAYVAN B. NOROOZI
`
`I.
`
`RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner Telefonaktiebolaget
`
`LM Ericsson (“Ericsson”) respectfully requests that the Patent Trial and
`
`Appeal Board admit Kayvan B. Noroozi pro hac vice in this proceeding.
`
`Patent Owner has conferred with Petitioner, and Petitioner has stated that it
`
`does not oppose this motion.
`
`II. GOVERNING LAW, RULES, AND PRECEDENT
`
`Section 42.10(c) provides that “where lead counsel is a registered
`
`practitioner, a motion to appear pro hac vice by counsel who is not a
`
`registered practitioner may be granted upon a showing that counsel is an
`
`experienced litigating attorney and has established familiarity with the
`
`subject matter at issue in the proceeding.”
`
`III.
`
`STATEMENT OF FACTS
`
`The facts here satisfy § 42.10(c) and demonstrate good cause for the
`
`Board to recognize Mr. Noroozi pro hac vice in this proceeding.
`
`Lead counsel, Douglas L. Bridges, is a registered practitioner.
`
`Counsel, Kayvan B. Noroozi, is an experienced patent litigator in good
`
`standing with the California State Bar, admitted to practice before the United
`
`States District Courts for the Eastern District of Texas and Northern District
`
`of California, and has never been suspended, disbarred, sanctioned, cited for
`
`1
`
`
`
`IPR2021-00644
`MOTION FOR ADMISSION PRO HAC VICE OF KAYVAN B. NOROOZI
`
`contempt of court, or had a court or administrative body deny his application
`
`for admission to practice. Ex. 2012 ¶¶ 1-5. Mr. Noroozi’s declaration
`
`includes a list of the proceedings before the Office in which he has applied
`
`to appear pro hac vice in the last three years. Id. at ¶ 6. Mr. Noroozi has read
`
`and will comply with the Office Patent Trial Practice Guide and the Board’s
`
`Rules of Practice for Trials set forth in part 42 of title 37 of the Code of
`
`Federal Regulations. Id. at ¶ 7. Mr. Noroozi understands and accepts that he
`
`will be subject to the USPTO Rules of Professional Conduct set forth in 37
`
`C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R. §
`
`11.19(a). Id. at ¶ 8. Mr. Noroozi is familiar with the subject matter at issue in
`
`this proceeding through his review of the underlying patent, the record, and
`
`discussions with Patent Owner, and its counsel. Id. at ¶ 9.
`
`IV. CONCLUSION
`
`For the foregoing reasons, Patent Owner respectfully requests that the
`
`Board admit Kayvan B. Noroozi pro hac vice in this proceeding.
`
`2
`
`
`
`IPR2021-00644
`MOTION FOR ADMISSION PRO HAC VICE OF KAYVAN B. NOROOZI
`
`Respectfully submitted,
`
`/s/ Douglas L. Bridges
`
`Douglas L. Bridges, Reg. No. 54,730
`NOROOZI PC
`4204 Rochester Road
`Mobile, AL 36608
`
`Date: March 29, 2021
`
`Counsel for Patent Owner
`
`3
`
`
`
`IPR2021-00644
`MOTION FOR ADMISSION PRO HAC VICE OF KAYVAN B. NOROOZI
`
`CERTIFICATION OF SERVICE
`
`The undersigned hereby certifies that the foregoing MOTION FOR
`
`ADMISSION PRO HAC VICE OF KAYVAN B. NOROOZI was served
`
`electronically via e-mail on March 29, 2021, on the following counsel of
`
`record for Petitioner:
`
`W. Karl Renner
`Jeremy J. Monaldo
`Hyun Jin In
`Vivian Lu
`Service Emails
`
`Date: March 29, 2021
`
`IPR39843-0095IP1@fr.com
`jjm@fr.com
`in@fr.com
`val@fr.com
`PTABInbound@fr.com
`axf-ptab@fr.com
`
`Respectfully submitted,
`
`/s/ Douglas L. Bridges
`
`Douglas L. Bridges, Reg. No. 54,730
`NOROOZI PC
`4204 Rochester Road
`Mobile, AL 36608
`
`Counsel for Patent Owner
`
`4
`
`
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