`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner.
`
`
`
`
`
`
`
`
`Case IPR2022-00120
`Patent 9,997,962
`
`
`
`
`
`
`
`
`
`PATENT OWNER’S MOTION FOR
`PRO HAC VICE ADMISSION OF JOHN PETRSORIC
`PURSUANT TO 37 C.F.R. §42.10(c)
`
`
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`I. RELIEF REQUESTED
`
`
`
`Case IPR2022-00120
`Patent No. 9,997,962
`
`
`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner Scramoge Technology Ltd.,
`
`respectfully requests that the Patent Trial and Appeal Board admit John Petrsoric
`
`pro hac vice in this proceeding. Patent Owner has conferred with Petitioner, and
`
`Petitioner has stated that it does not oppose this motion.
`
`II. GOVERNING LAW, RULES, AND PRECEDENT
`
`37 C.F.R. § 42.10(c) provides that “where lead counsel is a registered
`
`practitioner, a motion to appear pro hac vice by counsel who is not a registered
`
`practitioner may be granted upon a showing that counsel is an experienced litigation
`
`attorney and has stablished familiarity with the subject matter at issue in the
`
`proceeding.”
`
`III. STATETENT OF FACTS
`
`This Motion for pro hac vice admission should be granted because good cause
`
`exists to recognize Mr. Petrsoric pro hac vice, as set forth herein and in the
`
`accompanying Declaration of John Petrsoric in Support of Motion for Admission
`
`Pro Hac Vice (Ex. 2019). Lead Counsel, Brett Cooper, is a registered practitioner.
`
`Counsel, John Petrsoric is an experienced patent litigator in good standing with the
`
`New York State Bar, admitted to practice before the United States District Courts
`
`for the Easter District of Texas, Northern District of Illinois, Eastern District of New
`
`
`
`- 2 -
`
`
`
`
`
`Case IPR2022-00120
`Patent No. 9,997,962
`
`York and Southern District of New York with no disciplinary actions or denials of
`
`admission.
`
`Mr. Petrsoric has read and will comply with the Office Patent Trial Practice
`
`Guide and the Board’s Rules of Practice for Trials, and further understands that he
`
`will be subject to the USPTO Code of Professional Responsibility.
`
`Mr. Petrsoric is counsel in the related district court litigation and has extensive
`
`experience representing Patent Owner in patent litigations. Mr. Petrsoric is
`
`intimately familiar with the substantive and technical issues involved in this
`
`proceeding.
`
`IV. CONCLUSION
`
`For the foregoing reasons, Patent Owner respectfully requests that the Board
`
`admit John Petrsoric pro hac vice in this proceeding.
`
`
`
`Date: September 29, 2022
`
`
`
`Respectfully submitted,
`
`/Brett Cooper/
`Brett Cooper, Reg. No. 55,085
`Lead counsel for Patent Owner
`
`
`
`
`
`
`
`- 3 -
`
`
`
`
`
`Case IPR2022-00120
`Patent No. 9,997,962
`
`
`CERTIFICATE OF SERVICE (37 C.F,R. § 42.6(e))
`
`The undersigned hereby certifies that the above document was served on
`
`September 29, 2022, by filing this document through the Patent Trial and Appeal
`
`Board End to End System as well as delivering a copy via electronic mail upon the
`
`following attorneys of record for the Petitioner:
`
`Scott T. Jarratt (Reg No. 70,297)
`scott.jarratt.ipr@haynesboone.com
`Andrew S. Ehmke (Reg No. 50,271)
`andy.ehmke.ipr@haynesboone.com
`Calmann J. Clements (Reg No. 66,910)
`calmann.clements.ipr@haynesboone.com
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`Phone: (972) 739-8663
`Fax: (214) 200-0853
`
`
`
`
`Date: September 29, 2022
`
` /Brett Cooper/
`
`
`
`
`
`Brett Cooper
`Reg. No. 55,085
`Attorney for Patent Owner
`
`
`
`BC Law Group
`200 Madison Ave., 24th Fl.
`New York, NY 90025
`(212) 951-0100
`
`
`
`