From:
`To:
`Cc:
`
`Subject:
`Date:
`Attachments:
`
`Trials
`Greg Gulliver; Trials
`allison.lucier@hklaw.com; Andy Mu; benjamin.weed.ptab@klgates.com; bradford.cangro@pvuslaw.com;
`brian.bozzo@klgates.com; ckronenthal@bannerwitcoff.com; dkeese@perkinscoie.com; dlarkin@perkinscoie.com;
`erik.halverson@klgates.com; jacob.baron@hklaw.com; jeremy.peterson@pvuslaw.com;
`jhutchins@bannerwitcoff.com; merrill-ptab@perkinscoie.com; tessar-ptab@perkinscoie.com; Meredith Addy;
`robert@addyhart.com; td-ptab@devlinlawfirm.com
`RE: IPR2021-00906: Motion Filed - CRADLEPOINT, INC. v. 3G Licensing S.A.
`Wednesday, March 16, 2022 12:08:34 PM
`image001.png
`
`Counsel: Petitioner’s opposition to the motion for admission pro hac vice of Mr. Benchell is
`noted, as is Petitioner’s agreement to be bound by the outcome of the motions in IPR2021-
`00580 and -00584. The ruling on the motion in this case shall be held in abeyance pending
`the resolution of the motions in those other cases. No further briefing is required at this time.
`
`Thank you,
`
`Maria King
`Deputy Chief Clerk for Trials
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`703-756-1288
`
`
`
`From: Greg Gulliver <gbgulliver@addyhart.com>
`Sent: Tuesday, March 15, 2022 4:44 PM
`To: Trials <Trials@USPTO.GOV>
`Cc: allison.lucier@hklaw.com; Andy Mu <amu@bannerwitcoff.com>;
`benjamin.weed.ptab@klgates.com; bradford.cangro@pvuslaw.com; brian.bozzo@klgates.com;
`ckronenthal@bannerwitcoff.com; dkeese@perkinscoie.com; dlarkin@perkinscoie.com;
`erik.halverson@klgates.com; jacob.baron@hklaw.com; jeremy.peterson@pvuslaw.com;
`jhutchins@bannerwitcoff.com; merrill-ptab@perkinscoie.com; tessar-ptab@perkinscoie.com;
`Meredith Addy <meredith@addyhart.com>; robert@addyhart.com; td-ptab@devlinlawfirm.com
`Subject: RE: IPR2021-00906: Motion Filed - CRADLEPOINT, INC. v. 3G Licensing S.A.
`
`CAUTION: This email has originated from a source outside of USPTO. PLEASE CONSIDER THE SOURCE before
`responding, clicking on links, or opening attachments.
`
`Dear Board,
`
` I
`
` am backup counsel for Petitioner in the above-captioned matter. Patent Owner recently filed a
`motion for admission pro hac vice for Mr. Neil Benchell in this matter (below) and Petitioner has
`indicated its opposition. Petitioner is currently also opposing the admission of Mr. Benchell in
`IPR2021-00580, IPR2021-00584, and IPR2021-00640; the Parties are in the middle of the as-ordered
`briefing schedule in two proceedings IPR2021-00580 and IPR2021-00584, while the briefing in
`IPR2021-00640 has been paused pending the outcome of -00580 and -00584.
`
`

`

`
`Petitioner notes that the issues raised here are substantially similar identical to those previously
`briefed, and agrees to be bound by the outcome in those proceedings in this proceeding should the
`Board agree to hold in abeyance this motion for admission. However, Petitioner further notes that
`Mr. Benchell continues to submit false affidavits in this proceeding and others. For example, in
`IPR2020-01141, Exhibit 2009 states that Mr. Benchell has been admitted in IPR2021-00580 and
`IPR2021-00584, which is plainly false as Petitioner is opposing that admission and the Board has not
`ruled on any admission. Moreover, in Exhibit 2013 in this proceeding, Mr. Benchell attests that
`there is no evidence that Mr. Benchell was aware he was on the 2014 NJ list, but Petitioner
`submitted this in IPR2021-00580 at Paper 36 at 3 (citing Exhibit 1017). See IPR2021-00580, Exhibit
`1017 (noting the New Jersey Supreme court sent notice to each pro hac vice attorney).
`
`If the Board prefers briefing to be filed in parallel in this proceeding (as opposed to waiting for a
`determination as to those issues raised in IPR2021-00580, -00584), Petitioner respectfully requests a
`similar briefing schedule be entered in this proceeding outlining page limits and due dates for the
`opposition.
`
`Thank you,
`
`Gregory Gulliver
`
` GREGORY B GULLIVER
` +1 847 984 3020 direct
` gbgulliver@addyhart.com
`
` 401 N Michigan Ave
` Suite 1200-1
` Chicago, Illinois 60611
`
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`
`
`From: PTABE2E_System@uspto.gov <PTABE2E_System@uspto.gov>
`Sent: Wednesday, March 9, 2022 2:57 PM
`To: meredith@addyhart.com; robert@addyhart.com; td-ptab@devlinlawfirm.com
`Cc: allison.lucier@hklaw.com; amu@bannerwitcoff.com; benjamin.weed.ptab@klgates.com;
`bradford.cangro@pvuslaw.com; brian.bozzo@klgates.com; ckronenthal@bannerwitcoff.com;
`dkeese@perkinscoie.com; dlarkin@perkinscoie.com; erik.halverson@klgates.com;
`gbgulliver65@gmail.com; jacob.baron@hklaw.com; jeremy.peterson@pvuslaw.com;
`jhutchins@bannerwitcoff.com; merrill-ptab@perkinscoie.com; tessar-ptab@perkinscoie.com
`Subject: IPR2021-00906: Motion Filed - CRADLEPOINT, INC. v. 3G Licensing S.A.
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`PATENT TRIAL AND APPEAL BOARD
`
`Motion Filed Notice
`
`IPR2021-00906
`
`AIA Review No.:
`Petitioner:
`Patent Owner:
`Patent No.:
`7580388
`Motion Filing Party: Patent Owner
`Motion Type:
`
`CRADLEPOINT, INC. et al. of Boston, MA
`
`3G Licensing S.A.
`
`Motion to Appear Pro Hac Vice
`
`

`

`Motion Filing Date: 03/09/2022
`Submitted By:
`
`Timothy Devlin, td-ptab@devlinlawfirm.com
`
`The motion and related document(s), if any, have been filed.
`
`The following document(s) has/have been filed.
`
`Document(s) List
`
`No. Document
`No.
`
`Document
`Type
`
`Document Name
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`30
`
`31
`
`Motion
`
`Patent Owner's Motion for Pro Hac Vice
`Admission of Neil Benchell
`
`Motion
`
`Exhibit 2016 - Affidavit of Neil Benchell
`
`2012
`
`Exhibit
`
`Exhibit 2012
`
`2013
`
`Exhibit
`
`Exhibit 2013
`
`2014
`
`Exhibit
`
`Exhibit 2014
`
`2015
`
`Exhibit
`
`Exhibit 2015
`
`Filing
`Party
`
`Patent
`Owner
`
`Patent
`Owner
`
`Patent
`Owner
`
`Patent
`Owner
`
`Patent
`Owner
`
`Patent
`Owner
`
`Availability
`
`Available for
`everyone.
`
`Available for
`everyone.
`
`Available for
`everyone.
`
`Available for
`everyone.
`
`Available for
`everyone.
`
`Available for
`everyone.
`
`Questions regarding this receipt should be directed to the Patent Trial and Appeal Board at
`571-272-7822 or e-mail to Trials@uspto.gov.
`
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