`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` APPLE INC.,
` Petitioners,
`
` v.
`
` TELEFONAKTIEBOLAGET LM ERICSSON,
` Patent Owner.
` ____________________
`
` Case IPR2022-00455
` Patent 9,860,044
` ____________________
`
` MOTION FOR ADMISSION PRO HAC VICE OF
` KAYVAN B. NOROOZI
`
`
`
` Case No. IPR2022-00648
` U.S. Pat. 9,860,044
`
` EXHIBIT LIST
`
` ERICSSON 2001
`
` Declaration of Kayvan Noroozi in Support of Pro Hac
` Vice Admission
`
` 1
`
`
`
` Case No. IPR2022-00648
` U.S. Pat. 9,860,044
`
` I.
`
` RELIEF REQUESTED
` Pursuant to 37 C.F.R. § 42.10(c), Patent Owner Telefonaktiebolaget LM
`
` Ericsson, (“Ericsson”) respectfully requests that the Patent Trial and Appeal Board
`
` admit Kayvan B. Noroozi 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 CFR § 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
`
` litigating attorney and has established familiarity with the subject matter at issue in
`
` the proceeding.”
`
` STATEMENT OF FACTS
` III.
` The facts here satisfy § 42.10(c) and demonstrate good cause for the Board
`
` to recognize Mr. Noroozi pro hac vice in this proceeding.
`
` Lead counsel, Peter C. Knops, is a registered practitioner. Counsel, Kayvan
`
` B. Noroozi, is an experienced patent litigator in good standing with the California
`
` State Bar, admitted to practice before the United States District Courts for the
`
` 1
`
`
`
` Case No. IPR2022-00648
` U.S. Pat. 9,860,044
`
` Eastern District of Texas and Northern District of California, and has never been
`
` suspended, disbarred, sanctioned, cited for contempt of court, or had a court or
`
` administrative body deny his application for admission to practice. Ex. 2012 ¶¶
`
` 1-5. Mr. Noroozi’s declaration includes a list of the proceedings before the Office
`
` in which he has applied to appear pro hac vice in the last three years. Id. at ¶ 6. Mr.
`
` Noroozi has read and will comply with the Office Patent Trial Practice Guide and
`
` the Board’s Rules of Practice for Trials set forth in part 42 of title 37 of the Code of
`
` Federal Regulations. Id. at ¶ 7. Mr. Noroozi understands and accepts that he will be
`
` subject to the USPTO Rules of Professional Conduct set forth in 37 C.F.R.
`
` §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a). Id. at
`
` ¶ 8. Mr. Noroozi is familiar with the subject matter at issue in this proceeding
`
` through his involvement in a prior Inter Partes Review proceeding involving the
`
` underlying patent, a review of the underlying patent, the record, and discussions
`
` with Patent Owner and its counsel. Id. at ¶ 9.
`
` CONCLUSION
` IV.
` For the foregoing reasons, Patent Owner respectfully requests that the Board
`
` admit Kayvan B. Noroozi pro hac vice in this proceeding.
`
` 2
`
`
`
` Case No. IPR2022-00648
` U.S. Pat. 9,860,044
`
` Respectfully submitted,
`
` /Peter C Knops/
` Peter C Knops
` Reg. No. 37,659
`
` Date: April 12,2022
`
` Customer Number 146376
` Noroozi P.C.
` Telephone: 310-975-7074
` Facsimile: 844-975-7074
`
` 3
`
`
`
` Case No. IPR2022-00648
` U.S. Pat. 9,860,044
`
` CERTIFICATE OF SERVICE
`
` Pursuant to 37 CFR § 42.6(e), the undersigned certifies that on April 12,
`
` 2022, a complete and entire copy of this Patent Owner’s Motion for Pro Hac Vice ,
`
` and its exhibit, were provided via email, to the Petitioner by serving the
`
` correspondence addresses of record as follows:
`
` Paul R. Hart
` Paul.Hart@eriseip.com
` Erise IP, P.A.
` 5299 DTC Blvd., Ste. 1340
` Greenwood Village, CO 80111
`
` Adam P. Seitz
` Adam.Seitz@eriseip.com
` PTAB@eriseip.com
`
` Jennifer C. Bailey
` Jennifer.Bailey@eriseip.com
`
` Erise IP, P.A.
` 7015 College Blvd., Ste. 700
` Overland Park, Kansas 66211
`
` /Peter C Knops/
` Peter C. Knops, Reg. No. 37,659
` peter@noroozipc.com
` N OROOZI PC
` 11601 Wilshire Blvd., Suite 2170
` Los Angeles, CA 90025
` Tel.: 310-975-7074
`
` Counsel for Patent Owner
`
` Date: April 12, 2022
`
` 4
`
`
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