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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
`v.
`MEMORYWEB, LLC
`Patent Owner
`
`Patent No. 10,423,658
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`Inter Partes Review No. IPR2022-00221
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`PATENT OWNER’S MOTION FOR PRO HAC VICE ADMISSION
`OF ANGELO J. CHRISTOPHER UNDER 37 C.F.R. § 42.10
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`IPR2022-00221
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`Pursuant to 37 C.F.R. § 42.10 and the authorization provided by the Board in
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`Paper 5 dated February 8, 2022 (“the Notice”), Patent Owner MemoryWeb, LLC
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`(“Patent Owner”) submits this unopposed motion for Angelo J. Christopher to
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`appear pro hac vice. Patent Owner respectfully requests for the Board to recognize
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`Mr. Christopher as counsel pro hac vice during this proceeding and demonstrates
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`good cause for doing so.
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`I.
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`Timing
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`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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`II.
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`Statement of Facts
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`Pursuant to the Notice, the following statement of facts shows that good cause
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`exists for the Board to recognize Mr. Christopher pro hac vice.
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`Patent Owner’s lead counsel for this proceeding, Jennifer Hayes, is a
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`registered practitioner (Reg. No. 50,845).
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`Mr. Christopher is an experienced litigation attorney with more than six (6)
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`years of patent litigation experience in district courts and the International Trade
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`Commission. Ex. 2029 at ¶ 8.
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`Mr. Christopher is counsel for Patent owner in the district court litigation
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`(MemoryWeb, LLC v. Samsung Electronics Co., Ltd. and Samsung Electronics
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`1
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`IPR2022-00221
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`America Inc., No. 3:22-cv-03665-VC (N.D. Cal.)) where the ‘658 patent is asserted
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`against Petitioner. Mr. Christopher has reviewed and is familiar with the ‘658 patent
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`and the issues raised in the Petition in this proceeding. Id. at ¶ 9.
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`Mr. Christopher is a member in good standing in the State Bar of Illinois, the
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`U.S. District Court for the Northern District of Illinois, and the U.S. Court of Appeals
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`for the Federal Circuit. Id. at ¶ 1.
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`Mr. Christopher has not been suspended or disbarred from practice, has
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`never had any application for admission to practice denied, and has never had any
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`sanctions or contempt citations imposed against him. Id. at ¶¶ 2-4.
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`Mr. Christopher has read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules of Practice for Trials set forth in Part 42 of Title 37 of
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`the C.F.R and agrees to be subject to the USPTO Code of Professional
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`Responsibility 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. Mr. Christopher has not appeared pro hac
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`vice before the Office in the last three years. Id. at ¶ 7.
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`Mr. Christopher recently passed the U.S. Patent and Trademark Office
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`Registration Examination and is awaiting final approval and his registration number
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`from the Office of Enrollment and Discipline. Id. at ¶ 10. Patent Owner seeks to have
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`Mr. Christopher participate in the deposition of Petitioner’s expert scheduled for
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`March 27, 2023, but does not anticipate Mr. Christopher receiving his registration
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`2
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`IPR2022-00221
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`number by that time. Id. Patent Owner will submit updated mandatory notices once
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`Mr. Christopher receives his registration number.
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`Therefore, Patent Owner submits that there is good cause for the Board to
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`recognize Mr. Christopher as counsel pro hac vice during this proceeding.
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`III. Statement of Facts
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`This Motion is accompanied by the Declaration of Mr. Christopher. Ex. 2029.
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`/Jennifer Hayes/
`Jennifer Hayes
`Reg. No. 50,845
`Nixon Peabody LLP
`300 South Grand Avenue,
`Suite 4100,
`Los Angeles, CA 90071-3151
`Tel. 213-629-6179
`Fax 866-781-9391
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`Respectfully submitted,
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`Dated: March 17, 2023
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`By:
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`3
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`IPR2022-00221
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing Patent Owner’s
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`Motion for Pro Hac Vice Admission of Angelo J. Christopher under 37 C.F.R. §
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`42.10 together with all exhibits filed therewith was served on March 17, 2023, upon
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`the following parties via electronic service:
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`IPR39843-0116IP1@fr.com
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`PTABInbound@fr.com
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`axf-ptab@fr.com
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`jjm@fr.com
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`in@fr.com
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`cgreen@fr.com
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`Counsel for Petitioner, Samsung Electronics Co., Ltd.
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`By:
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`/s/ Jennifer Hayes
`Lead Counsel for Patent Owner
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`4
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