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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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`APPLE, INC.,
`Petitioner
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`v.
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`ALIVECOR, INC.,
`Patent Owner
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`___________________
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`Case IPR2021-00972
`Patent No. 10,638,941
`___________________
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`MOTION FOR ADMISSION PRO HAC VICE
`OF SEAN PAK
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`I.
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`Relief Requested
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`Pursuant to 37 C.F.R. § 42.10, Patent Owner AliveCor, Inc. (“AliveCor”)
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`requests that the Board admit Sean Pak pro hac vice in this inter partes review
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`proceeding.
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`II.
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`Statement of Facts Showing Good Cause for the Board to Recognize
`Counsel Pro Hac Vice During the Proceeding
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`In accordance with 37 C.F.R. § 42.10(c), the Board may recognize counsel pro
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`hac vice during a proceeding, subject to the conditions set forth therein, and any
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`others that the Board may impose. Petitioner sets forth the following facts in support
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`of this Motion:
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`1.
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`Lead counsel for AliveCor in this proceeding, James M. Glass, is a
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`registered practitioner.
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`2.
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`Sean Pak is an experienced litigating attorney and has established
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`familiarity with the subject matter at issue in this proceeding.
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`Accompanying this Motion is the Declaration of Sean Pak in Support of
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`Motion for Admission Pro Hac Vice (“Pak Decl.”). In his declaration,
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`Mr. Pak attests, among other things, that he is a member in good
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`standing of the State Bar of California. (Pak Decl. ¶ 3.) Mr. Pak further
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`attests that he has been admitted to practice before the United States
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`Court for the Federal Circuit, as well as before several United States
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`District Courts. (Id.) Mr. Pak further attests that he has been in private
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`2
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`practice in the field of litigation since 2002, with the majority of that
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`time focused specifically on patent litigation. (Id. ¶ 2.) In addition, Mr.
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`Pak attests that his familiarity with the subject matter at issue in this
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`proceeding is demonstrated by his review of the patent-at-issue and the
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`cited prior art, as well as his representation of AliveCor in the District
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`Court action in which AliveCor has accused Apple of infringing the
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`patent-at-issue as well as the associated ITC action. (Id. ¶¶ 9-10.)
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`3.
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`In his declaration, Mr. Pak attests to each of the required items set forth
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`in 37 C.F.R. §42.10(c). (Id. ¶¶ 2-10.)
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`III. Conclusion
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`For the foregoing reasons, AliveCor respectfully requests that the Board admit
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`Sean Pak pro hac vice in this proceeding.
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`
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`Respectfully submitted,
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`Date: February 21, 2022
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`
`/s/ James M. Glass
`
`James M. Glass (Reg. No. 46,729)
`Quinn Emanuel Urquhart &
`Sullivan LLP
`51 Madison Ave, 22nd Floor
`New York, New York, 10010
`Tel: (212) 849-7142
`Fax: (212) 849-7100
`Email: qe-alivecor@quinnemanuel.co
`Counsel for Patent Owner AliveCor Inc.
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`3
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §42.6(e), the undersigned certifies that on February 21,
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`2022, a complete and entire copy of this Motion for Admission Pro Hac Vice of Sean
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`Pak was provided by email to the Patent Owner by serving correspondence address
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`of record as follows:
`
`W. Karl Renner
`Jeremy J. Monaldo
`IPR50095-0032IP1@fr.com
`PTABInbound@fr.com
`axf-ptab@fr.com
`monaldo@fr.com
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`Dated: February 21, 2022
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`/s/ James M. Glass
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`James M. Glass (Reg. No. 46,729)
`Quinn Emanuel Urquhart &
`Sullivan LLP
`51 Madison Ave, 22nd Floor
`New York, New York, 10010
`Tel: (212) 849-7142
`Fax: (212) 849-7100
`Email: qe-alivecor@quinnemanuel.co
`Counsel for Patent Owner AliveCor Inc.
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`4
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