UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLIED MATERIALS, INC.,
`
`Petitioner
`
`v.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Patent Owner
`
`IPR2021-01342
`
`Patent No. 6,968,248
`
`PATENT OWNER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION UNDER 37 C.F.R. § 42.10(c)
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLIED MATERIALS, INC.,
`
`Petitioner
`
`v.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Patent Owner
`
`IPR2021-01342
`
`Patent No. 6,968,248
`
`PATENT OWNER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION UNDER 37 C.F.R. § 42.10(c)
`
`
`
`I.
`
`STATEMENT OF THE PRECISE RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. §§ 42.10(c) and 42.22, Patent Owner Ocean
`
`Semiconductor, LLC (“Ocean Semi”) respectfully requests that the Board recognize
`
`Peter A. Mazur of Devlin Law Firm LLC as backup counsel pro hac vice during
`
`this proceeding. The facts, supported by the attached Declaration of Peter A. Mazur
`
`in Support of Patent Owner’s Motion for Pro Hac Vice Admission (“Mazur Decl.”,
`
`Exhibit 2043), establish good cause to admit Mr. Mazur pro hac vice in this
`
`proceeding. Counsel for Patent Owner conferred with counsel for Petitioner, and
`
`Petitioner does not oppose this Motion.
`
`II.
`
`STATEMENT OF FACTS
`
`The following statement of facts shows that there is good cause for the Board
`
`to recognize Mr. Mazur pro hac vice. Mr. Mazur is a litigation attorney and has
`
`established familiarity with the subject matter at issue in this proceeding.
`
`Lead counsel for Patent Owner, Timothy Devlin, is a registered practitioner
`
`(Reg. No. 41,706) and experienced in inter partes proceedings in the USPTO.
`
`Peter A. Mazur joined Devlin Law Firm LLC as an Associate in 2019.
`
`(Mazur Decl. ¶ 1.) Mr. Mazur has primarily focused his practice on patent
`
`litigation. (Id. ¶ 1.) Mr. Mazur has gained experience conducting technical
`
`infringement and validity analysis, working with technical experts on infringement
`
`and validity issues, preparing for depositions of technical experts and fact witnesses,
`
`1
`
`
`
`briefing claim construction issues, preparing for Markman hearings, and
`
`representing clients in district court hearings. (Id. ¶ 1.)
`
`Mr. Mazur has been admitted to the Bar of the Commonwealth of
`
`Pennsylvania, the Bar of the State of New Jersey, and the Bar of the State of
`
`Delaware. Mr. Mazur has also been admitted to practice by the U.S. District Court
`
`for the District of Delaware. (Id. ¶ 2.)
`
`Mr. Mazur has never been suspended or disbarred from practice before any
`
`court or administrative body. (Id. ¶ 3.) He has never had an application for admission
`
`to practice before any court or administrated body denied. (Id. ¶ 3) Nor has any
`
`court or administrative body imposed sanctions or contempt citations against him.
`
`(Id. ¶ 3)
`
`Mr. Mazur has read and will comply with the Office Patent Trial Practice
`
`Guide and the Board’s Rules of Practice for Trials set forth in Title 37, Part 42 of
`
`the C.F.R. (Id. ¶ 4.) Mr. Mazur will be subject to the United States Patent and
`
`Trademark Office Code of Professional Responsibility set forth in 37 C.F.R. § §
`
`11.101 et seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a). (Id. ¶ 5.)
`
`Mr. Mazur is concurrently applying for pro hac vice admission in the
`
`following proceedings: IPR2021-001344. (Id. ¶ 8.)
`
`Mr. Mazur has established familiarity with the subject matter at issue in this
`
`proceeding. (Id. ¶ 6.) He is familiar with U.S. Patent No. 6,907,305 and all prior
`
`2
`
`
`
`art references and alleged grounds of invalidity relied upon by Petitioners in this
`
`proceeding. (Id. ¶ 7.) Moreover, Mr. Mazur will work under the guidance of
`
`Timothy Devlin, who is a registered practitioner and the lead counsel for Patent
`
`Owner in this proceeding, as well as Alex Chan and Henrik Parker, who are also
`
`registered practitioners and backup counsel in this proceeding. (Id. ¶ 7.) Therefore,
`
`Patent Owner respectfully submits that there is good cause for the Board to
`
`recognize Mr. Mazur as counsel pro hac vice during this proceeding.
`
`III. ANALYSIS
`
`The facts contained in the Statement of Facts above and Mr. Mazur’s
`
`Declaration establish that there is good cause to admit Mr. Mazur pro hac vice in
`
`this proceeding under 37 C.F.R. § 42.10 as backup counsel. Lead counsel Timothy
`
`Devlin is a registered practitioner and experienced in inter partes proceedings in the
`
`USPTO. Mr. Mazur has established familiarity with the subject matter at issue in
`
`this proceeding.
`
`IV. CONCLUSION
`
`For the foregoing reasons, Patent Owner respectfully requests that the Board
`
`admit Peter A. Mazur pro hac vice in this proceeding.
`
`3
`
`
`
`Dated: June 21, 2022
`
`DEVLIN LAW FIRM LLC
`
`/s/ Timothy Devlin
`Timothy Devlin
`Registration No. 41,706
`TD-PTAB@devlinlawfirm.com
`Alex Chan
`Registration No. 52,713
`achan@devlinlawfirm.com
`Henrik Parker
`Registration No. 31,863
`hparker@devlinlawfirm.com
`Joel W. Glazer
`Registration No. 76,493
`jglazer@devlinlawfirm.com
`1526 Gilpin Ave.
`Wilmington, DE 19806
`(302) 449-9010
`
`Attorneys for Patent Owner
`
`4
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that the foregoing document was served
`
`electronically via electronic mail on June 21, 2022, on the following counsel of
`
`record for Petitioners:
`
`COUNSEL FOR WESTERN DIGITAL TECHNOLOGIES, INC.
`LEAD COUNSEL
`BACKUP COUNSEL
`
`Eric A. Krause (Reg. No. 62,329)
`Axinn Veltrop & Harkrider LLP
`560 Mission Street
`San Francisco, California 94105
`Telephone: (415) 490-1491
`Facsimile: (415) 490-2001
`ekrause@axinn.com
`applied-ocean@axinn.com
`
`Pan C. Lee (Admitted Pro Hac Vice)
`Axinn, Veltrop & Harkrider LLP
`560 Mission Street
`San Francisco, CA 94105
`Phone: 415-490-1488
`Fax: 415-490-2001
`plee@axinn.com
`applied-ocean@axinn.com
`
`Jeannine Yoo Sano (Pro Hac Vice)
`Axinn, Veltrop & Harkrider LLP
`560 Mission Street
`San Francisco, CA 94105
`Phone: 415-490-1488
`Fax: 415-490-2001
`jsano@axinn.com
`applied-ocean@axinn.com
`
`Don Zhe Nan Wang (Pro Hac Vice)
`Axinn, Veltrop & Harkrider LLP
`560 Mission Street
`San Francisco, CA 94105
`Phone: 415-490-1488
`Fax: 415-490-2001
`dwang@axinn.com
`applied-ocean@axinn.com
`
`5
`
`
`
`/s/ Timothy Devlin
`
` Timothy Devlin
`
`6
`
`
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