IPR2021-01348
`U.S. Patent No. 6,836,691
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
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`APPLIED MATERIALS, INC.
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`Petitioner,
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`v.
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`OCEAN SEMICONDUCTOR LLC,
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`Patent Owner.
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`_____________________
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`Case IPR: IPR2021-01348
`U.S. Patent No. 6,836,691
`_____________________
`PETITIONER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF PAN LEE UNDER 37 C.F.R. § 42.10(c)
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`U.S. Patent No. 6,836,691
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
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`APPLIED MATERIALS, INC.
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`Petitioner,
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`v.
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`OCEAN SEMICONDUCTOR LLC,
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`Patent Owner.
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`_____________________
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`Case IPR: IPR2021-01348
`U.S. Patent No. 6,836,691
`_____________________
`PETITIONER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF PAN LEE UNDER 37 C.F.R. § 42.10(c)
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`IPR2021-01348
`U.S. Patent No. 6,836,691
`STATEMENT OF PRECISE RELIEF REQUESTED
`Pursuant to 37 C.F.R. § 42.10(c), and in accordance with the United States
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`Patent and Trademark Office’s Patent Trial and Appeal Board’s (“Board”) “Order -
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`- Authorizing Motion for Pro Hac Vice Admission” in Case IPR2013-00639, Paper
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`7 (“the Order”), and the Notice of Filing Date Accorded to Petition and Time For
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`Filing Patent Owner Preliminary Response, Paper 3 (“the Notice”), which
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`authorized the parties to file motions for pro hac vice admission, Petitioner
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`Applied Materials, Inc. (“Applied”) requests that the Board admit Pan Lee pro hac
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`vice in this proceeding. Counsel for Patent Owner Ocean Semiconductor LLC
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`(“Ocean”) has informed counsel for Petitioner that Patent Owner does not oppose
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`this Motion.
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` TIME FOR FILING
`Pursuant to the authorization provided in the Notice, this motion for pro hac
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`vice admission is being filed no sooner than twenty-one days after service of the
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`Petition.
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` 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
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`during a proceeding upon a showing of good cause, subject to the condition that
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`lead counsel be a registered practitioner and to any other conditions as the Board
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`may impose. For example, where the lead counsel is a registered practitioner, a
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`1
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`IPR2021-01348
`U.S. Patent No. 6,836,691
`motion to appear pro hac vice by counsel who is not a registered practitioner may
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`be granted upon showing that counsel is an experienced litigating attorney and has
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`an established familiarity with the subject matter at issue in the proceeding.”
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`The facts, supported by the attached Declaration of Pan Lee in Support of
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`Petitioner’s Motion for Admission Pro Hac Vice (Exhibit 1042), establish good
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`cause to admit Mr. Lee pro hac vice in this proceeding. Lead counsel for this
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`proceeding, Eric Krause, is a registered practitioner (Reg. No. 62,329). Counsel
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`for Petitioner contacted counsel for Patent Owner, who indicated that Petitioner did
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`not plan to oppose Mr. Lee’s admission pro hac vice. Counsel, Pan Lee, is an
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`experienced litigating attorney with over ten years in private practice and
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`substantial experience with patent litigation. Ex. 1042 at ¶ 8. Mr. Lee has been
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`counsel in several patent infringement matters before United States District Courts.
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`Id. Mr. Lee is a member in good standing of the State Bar of California. Id. at ¶ 1.
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`He is also admitted to practice in the U.S. District Court for the Northern District
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`of California, the Central District of California, and the Western District of Texas.
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`Id. He has had no suspensions or disbarments from practice, no application for
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`admission to practice denied, nor any sanctions or contempt citations. Id. at ¶¶ 2-4.
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`Mr. Lee has familiarity with the subject matter, including the ’691 patent, its
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`prosecution history and the technology field to which the ’691 patent is addressed.
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`Id. at ¶ 7. Moreover, Mr. Lee has reviewed parties’ written submissions, the prior
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`2
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`IPR2021-01348
`U.S. Patent No. 6,836,691
`art, and all other cited materials. Id. Given his extensive patent litigation
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`experience and his familiarity with the instant Petition, the cited materials, and the
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`patented technology, Mr. Lee has established familiarity with the subject matter at
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`issue in this proceeding. Id. at ¶¶ 7-8. Mr. Lee has extensive experience advising
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`clients on the validity and infringement of patents, working with experts, and
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`developing strategies related to the enforcement of patents. Id. at ¶ 8. Mr. Lee has
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`read and will comply with the Office Patent Trial Guide and the Board’s Rules for
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`Practices for Trials set forth in part 42 of title 37 of the Code of Federal
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`Regulations, and he agrees to be subject to the USPTO Rules of Professional
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`Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and to disciplinary jurisdiction
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`under 37 C.F.R. § 11.19(a). Id. at ¶¶ 5-6. Given Mr. Lee’s familiarity with the
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`subject matter at issue in this proceeding, Petitioner respectfully submits that it has
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`shown good cause for the Board to recognize Mr. Lee as counsel pro hac vice
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`during this proceeding.
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`3
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`Dated: February 2, 2022
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`IPR2021-01348
`U.S. Patent No. 6,836,691
`Respectfully submitted,
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`/Eric A. Krause/
`Eric A. Krause (Reg. No. 62,329)
`Attorney for Petitioner
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`Axinn, Veltrop & Harkrider LLP
`560 Mission Street
`San Francisco, CA 94105
`(415) 490-1491
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`4
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`IPR2021-01348
`U.S. Patent No. 6,836,691
`CERTIFICATION OF SERVICE (37 C.F.R. § 42.6(e))
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`The undersigned hereby certifies that the above-captioned Petitioner’s
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`Unopposed Motion for Pro Hac Vice Admission of Pan Lee Under 37 C.F.R. §
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`42.10(c) and its supporting declaration (Exhibit 1042) were served in their entirety
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`on February 2, 2022 upon the following Parties via email:
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`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
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`Dated: February 2, 2022k
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`/Eric A. Krause/
`Eric A. Krause (Reg. No. 62,329)
`Attorney for Petitioner
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`Axinn, Veltrop & Harkrider LLP
`560 Mission Street
`San Francisco, CA 94105
`(415) 490-1491
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