Halverson, Erik J.
`Trials
`TD-PTAB; Neil Benchell; Andrew DeMarco; Stephanie Berger; Merrill, Kourtney Mueller (Perkins Coie);
`ptorchia@gibsondunn.com; ncurtis@gibsondunn.com; bburoker@gibsondunn.com; Dell-
`IPRService@gibsondunn.com; Tessar, Amanda (Perkins Coie); O"Dorisio, Roderick (Perkins Coie);
`PerkinsServiceSisvelIPR@perkinscoie.com; jacob.baron@hklaw.com; Allison.Lucier@hklaw.com; cradlepoint-
`IPRService@hklaw.com; Addy Martin, Meredith -EXTERNAL; robert@addyhart.com; gbgulliver@addyhart.com;
`litigation-dkt@addyhart.com; jeremy.peterson@pvuslaw.com; bradford.cangro@pvuslaw.com;
`TCLSisvelIPRService@pvuslaw.com; Benjamin Weed PTAB; Bozzo, Brian P.
`Cradlepoint, Inc. et al. v. Sisvel S.p.A. IPR2021-00580 and IPR2021-00584
`Tuesday, January 4, 2022 8:05:48 PM
`
`From:
`To:
`Cc:
`
`Subject:
`Date:
`
`Dear Board,
`
` I
`
` am backup counsel for Petitioner in the above referenced proceedings. I write to seek leave to file
`a motion to revoke, or otherwise oppose, the admission of Neil Benchell in these two proceedings:
`IPR2021-00580 and IPR2021-00584. Petitioner did not previously oppose Mr. Benchell’s admission,
`but recently became aware that Mr. Benchell signed a false declaration to secure his admission pro
`hac vice in these proceedings.
`
`In IPR2021-00580, Mr. Benchell’s application for admission is Paper 22 and the accompanying
`declaration was filed as Paper 23. The declaration was subsequently converted to Exhibit 2003 with
`Paper 28. In IPR2021-00584, his application for admission is Paper 24 and the accompanying
`declaration was filed as Paper 25. The declaration was subsequently converted to Exhibit 2003 with
`Paper 30. Both motions are currently pending and Petitioner seeks further guidance as to whether
`the motion should be structure as an opposition or a motion to revoke.
`
`Accordingly, Petitioner requests authorization to file a motion to revoke Mr. Benchell’s admission in
`IPR2021-00580 and IPR2021-00584 or an opposition to the pending motion for admission.
`
`The parties have conferred via email and, despite Petitioner’s three requests made on December 19,
`21, and January 3 for Patent Owner’s availability, Patent Owner has not provided its availability for
`the requested call. Petitioner can be available for a call with the Board on Thursday, January 6 from
`9 to 11am ET and any time after noon; as well as Tuesday January 11 from 9am until noon ET and
`any time after 2pm. Petitioner can provide additional availability if necessary.
`
`Thank you,
`
`Erik Halverson
`
`
`Erik Halverson
`
`4 Embarcadero Center Suite 1200, San Francisco, CA 94111
`70 W. Madison Suite 3300, Chicago, IL 60602
`San Francisco Office: 415-882-8238
`
`

`

`Palo Alto Office: 650-798-6765
`Chicago Office: 312-807-4240
`Cell: 847-347-5959
`erik.halverson@klgates.com
`www.klgates.com
`
`
`