IPR2021-01342
`U.S. Patent No. 6,968,248
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`
`APPLIED MATERIALS, INC.
`
`Petitioner,
`
`v.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Patent Owner.
`
`_____________________
`
`Case IPR: IPR2021-01342
`U.S. Patent No. 6,968,248
`_____________________
`PETITIONER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSIONS OF JEANNINE YOO SANO AND DON ZHE NAN WANG
`UNDER 37 C.F.R. § 42.10(c)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`i
`
`
`U.S. Patent No. 6,968,248
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`
`APPLIED MATERIALS, INC.
`
`Petitioner,
`
`v.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Patent Owner.
`
`_____________________
`
`Case IPR: IPR2021-01342
`U.S. Patent No. 6,968,248
`_____________________
`PETITIONER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSIONS OF JEANNINE YOO SANO AND DON ZHE NAN WANG
`UNDER 37 C.F.R. § 42.10(c)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`i
`
`
`
`IPR2021-01342
`U.S. Patent No. 6,968,248
`STATEMENT OF PRECISE RELIEF REQUESTED
`Pursuant to 37 C.F.R. § 42.10(c), and in accordance with the United States
`
`
`
`Patent and Trademark Office’s Patent Trial and Appeal Board’s (“Board”)
`
`“Order -- Authorizing Motion for Pro Hac Vice Admission” in Case IPR2013-
`
`00639, Paper 7 (“the Order”), and the Notice of Filing Date Accorded to Petition
`
`and Time For Filing Patent Owner Preliminary Response, Paper 3 (“the Notice”),
`
`which authorized the parties to file motions for pro hac vice admission, Petitioner
`
`Applied Materials, Inc. (“Applied”) requests that the Board admit Jeannine Yoo
`
`Sano and Don Zhe Nan Wang pro hac vice in this proceeding. Counsel for Patent
`
`Owner Ocean Semiconductor LLC (“Ocean”) has informed counsel for Petitioner
`
`that Patent Owner does not oppose this Motion.
`
` TIME FOR FILING
`Pursuant to the authorization provided in the Notice, this motion for pro hac
`
`vice admission is being filed no sooner than twenty-one days after service of the
`
`Petition.
`
` STATEMENT OF FACTS SHOWING GOOD CAUSE FOR THE
`BOARD TO RECOGNIZE COUNSEL PRO HAC VICE IN THE
`PROCEEDING
`Under 37 C.F.R. § 42.10(c), the Board “may recognize counsel pro hac vice
`
`during a proceeding upon a showing of good cause, subject to the condition that
`
`lead counsel be a registered practitioner and to any other conditions as the Board
`
`may impose. For example, where the lead counsel is a registered practitioner, a
`
`1
`
`
`
`IPR2021-01342
`U.S. Patent No. 6,968,248
`motion to appear pro hac vice by counsel who is not a registered practitioner may
`
`be granted upon showing that counsel is an experienced litigating attorney and has
`
`an established familiarity with the subject matter at issue in the proceeding.”
`
`The facts, supported by the attached Declarations of Jeannine Yoo Sano and
`
`Don Zhe Nan Wang (Exs. 1044-1045) establish good cause to admit Ms. Sano and
`
`Mr. Wang pro hac vice in this proceeding.
`
`Lead counsel for this proceeding, Eric Krause, is a registered practitioner
`
`(Reg. No. 62,329).
`
`Counsel for Petitioner contacted counsel for Patent Owner, who indicated
`
`that Petitioner did not oppose the admission pro hac vice of Ms. Sano and Mr.
`
`Wang.
`
`Counsel, Jeannine Yoo Sano, is an experienced litigating attorney with over
`
`twenty-five years in private practice and substantial experience with patent
`
`litigation. Ex. 1044 at ¶ 8. Ms. Sano has been lead counsel in patent infringement
`
`matters in numerous different district courts across the United States. Id. Ms.
`
`Sano is a member in good standing of the California State Bar, District of
`
`Columbia Bar, and the New York State Bar. Id. at ¶ 1. She is also admitted to
`
`practice in multiple federal district courts and courts of appeals, including the
`
`United States Supreme Court. Id. She has had no suspensions or disbarments
`
`from practice, no application for admission to practice denied, nor any sanctions or
`
`2
`
`
`
`IPR2021-01342
`U.S. Patent No. 6,968,248
`
`contempt citations. Id. at ¶¶ 2-4.
`
`Counsel, Don Zhe Nan Wang, has approximately six years of experience
`
`litigating complex patent validity, infringement, and enforceability issues. Ex.
`
`1045 at ¶ 8. Mr. Wang is a is a member in good standing of the California State
`
`Bar and he is admitted to practice in the U.S. District Court for the Northern
`
`District of California and U.S. Court of Appeals for the Ninth Circuit. Id. at ¶ 1.
`
`Mr. Wang has had no suspensions or disbarments from practice, no application for
`
`admission to practice denied, nor any sanctions or contempt citations. Id. at ¶¶ 2-4.
`
`Ms. Sano and Mr. Wang have familiarity with the subject matter, including
`
`the patent-at-issue in this proceeding, U.S. Patent No. 6,968,248 (“’402 patent”),
`
`its prosecution history and the technical field to which the ’402 patent is addressed.
`
`Ex. 1044 at ¶ 7; Ex. 1045 at ¶ 7. Ms. Sano and Mr. Wang have reviewed parties’
`
`written submissions, the prior art, and all other cited materials. Ex. 1044 at ¶ 7;
`
`Ex. 1045 at ¶ 7. Given their extensive patent litigation experience and their
`
`familiarity with the instant Petition, the cited materials, and the patented
`
`technology, both Ms. Sano and Mr. Wang have established familiarity with the
`
`subject matter at issue in this proceeding. Ex. 1044 at ¶¶ 7-8; Ex. 1045 at ¶¶ 7-8.
`
`Ms. Sano and Mr. Wang have read and will comply with the Office Patent Trial
`
`Guide and the Board’s Rules for Practices for Trials set forth in part 42 of title 37
`
`of the Code of Federal Regulations, and agree to be subject to the USPTO Rules of
`
`3
`
`
`
`IPR2021-01342
`U.S. Patent No. 6,968,248
`Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and to disciplinary
`
`jurisdiction under 37 C.F.R. § 11.19(a). Id. at ¶¶ 5-6. Given Ms. Sano’s and Mr.
`
`Wang’s familiarity with the subject matter at issue in this proceeding, Petitioner
`
`respectfully submits that it has shown good cause for the Board to recognize Ms.
`
`Sano and Mr. Wang as counsel pro hac vice during this proceeding.
`
` DECLARATION OF INDIVIDUAL SEEKING TO APPEAR
`This Motion is accompanied by the Declaration of Ms. Sano and the
`
`Declaration of Mr. Wang.
`
`
`
`Dated: June 9, 2022
`
`
`
`
`Respectfully submitted,
`
`/Eric A. Krause/
`Eric A. Krause (Reg. No. 62,329)
`Attorney for Petitioner
`
`Axinn, Veltrop & Harkrider LLP
`560 Mission Street
`San Francisco, CA 94105
`(415) 490-1491
`
`4
`
`
`
`IPR2021-01342
`U.S. Patent No. 6,968,248
`CERTIFICATION OF SERVICE (37 C.F.R. §§ 42.6(e))
`
`The undersigned hereby certifies that the above-captioned Petitioner’s
`
`Unopposed Motion for Pro Hac Vice Admission of Jeannine Yoo Sano and Don
`
`Zhe Nan Wang Under 37 C.F.R. §42.10(c) and its supporting declarations (Exs.
`
`1044-1045) were served in their entirety on June 9, 2022 upon the following
`
`Parties via email:
`
`
`Timothy Devlin (Lead Counsel)
`Alex Chan (Backup Counsel)
`Joel W. Glazer (Backup Counsel)
`Henrik Parker (Backup Counsel)
`DEVLIN LAW FIRM LLC
`1526 Gilpin Avenue
`Wilmington, DE 19806
`TD-PTAB@devlinlawfirm.com
`achan@devlinlawfirm.com
`jglazer@devlinlawfirm.com
`hparker@devlinlawfirm.com
`dlflitparas@devlinlawfirm.com
`oceansemi-dlf@devlinlawfirm.com
`
`
`
`Dated: June 9, 2022k
`
`
`
`
`
`
`
`
`/Eric A. Krause/
`Eric A. Krause (Reg. No. 62,329)
`Attorney for Petitioner
`
`Axinn, Veltrop & Harkrider LLP
`560 Mission Street
`San Francisco, CA 94105
`(415) 490-1491
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
