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, MICRON TECHNOLOGY, INC.,
`MICRON SEMICONDUCTOR PRODUCTS, INC., and
`MICRON TECHNOLOGY TEXAS LLC
`Petitioner,
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`v.
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`NETLIST, INC.,
`Patent Owner.
`___________________
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`Case No. IPR2022-00996
`Patent No. 11,016,918
`___________________
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`PATENT OWNER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF JASON G. SHEASBY UNDER 37 C.F.R. § 42.10(C)
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`___________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
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`SAMSUNG ELECTRONICS CO., LTD, MICRON TECHNOLOGY, INC.,
`MICRON SEMICONDUCTOR PRODUCTS, INC., and
`MICRON TECHNOLOGY TEXAS LLC
`Petitioner,
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`v.
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`NETLIST, INC.,
`Patent Owner.
`___________________
`
`Case No. IPR2022-00996
`Patent No. 11,016,918
`___________________
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`PATENT OWNER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF JASON G. SHEASBY UNDER 37 C.F.R. § 42.10(C)
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`IPR2022-00996
`Patent No. 11,016,918
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`I. RELIEF REQUESTED
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`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner Netlist, Inc. ("Netlist"), by
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`and through its attorneys, respectfully requests that the Board admit Jason G.
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`Sheasby pro hac vice in this proceeding. Petitioners do not oppose this motion.
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`II. GOVERNING LAW, RULES, AND PRECEDENT
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`Section 42.10(c) states as follows:
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`The Board may recognize counsel pro hac vice during a
`proceeding upon a showing of good cause, subject to the
`condition that lead counsel be a registered practitioner
`and to any other conditions as the Board may impose. For
`example, where the 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
`showing that counsel is an experienced litigating attorney
`and has an established familiarity with the subject matter
`at issue in the proceeding.
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`IPR2022-00996
`Patent No. 11,016,918
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`III. STATEMENT OF FACTS
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`Based on the following statement of facts, and supported by the Declaration
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`of Jason G. Sheasby submitted herewith (EX2060), Netlist submits that a showing
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`of good cause has been made and respectfully requests the pro hac vice admission
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`of Jason G. Sheasby in this proceeding:
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`1.
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`Patent Owner’s Lead Counsel, Hong Annita Zhong, is a registered
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`practitioner (Reg. No. 66,530) and a partner at the law firm of Irell &
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`Manella LLP.
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`2. Mr. Sheasby is a partner at the law firm of Irell & Manella LLP, the
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`same law firm as Lead and Back-up Counsel. Id. ¶ 3.
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`3. Mr. Sheasby is an experienced litigating attorney and has been
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`litigating cases relating to patents for over 20 years, and has amassed
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`substantial litigation experience during that time. Id. ¶ 4.
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`4. Mr. Sheasby is a member in good standing of the California State Bar.
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`Id. ¶ 5.
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`5. Mr. Sheasby has never been suspended or disbarred from practice
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`before any court or administrative body. Id. ¶ 5.
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`IPR2022-00996
`Patent No. 11,016,918
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`6.
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`No application filed by Mr. Sheasby for admission to practice before
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`any court or administrative body has ever been denied. Id. ¶ 6.
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`7.
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`No sanctions or contempt citations have been imposed against Mr.
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`Sheasby by any court or administrative body. Id. ¶ 7.
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`8. Mr. Sheasby has read and agrees to comply with the Office Patent
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`Trial Practice Guide and the Board’s Rules of Practice for Trials set
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`forth in part 42 of Title 37, Code of Federal Regulations. Id. ¶ 8.
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`9. Mr. Sheasby understands that he will be subject to the USPTO Rules
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`of Professional Conduct 37 C.F.R. §§ 11.101 et seq. and disciplinary
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`jurisdiction under 37 C.F.R. § 11.19(a). Id. ¶ 9.
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`10. Mr. Sheasby has also appeared and been granted pro hac vice
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`admission before the United States Patent and Trademark Office in
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`IPR2012-00033, IPR2013-00242, IPR2014-01567, IPR2015-00370,
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`IPR2015-00371, IPR2015-00372, IPR2015-00374, IPR2015-00375,
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`IPR2015-00377, IPR2015-00378, IPR2018-00111, IPR2018-00215,
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`IPR2018-00425, IPR2018-00472, IPR2018-00487, IPR2019-01081,
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`IPR2019-01082, IPR2019-01083, CBM2019-00002, CBM2019-
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`00003, CBM2019-00004, CBM2019-00005, IPR2019-01331,
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`IPR2019-01332, IPR2019-01333, IPR2020-00090, IPR2020-00091,
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`IPR2022-00996
`Patent No. 11,016,918
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`IPR2020-00092, IPR2020-00095, IPR2020-00096, IPR2020-00097,
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`IPR2020-00882, IPR2020-00975, IPR2020-00976, IPR2020-01101,
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`IPR2021-00067, IPR2021-00071, IPR2021-01070, IPR2021-01073,
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`IPR2021-01077, IPR2021-01163, IPR2021-01248, IPR2021-00966,
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`IPR2021-00967, IPR2022-00615, IPR2022-00639, IPR2022-00076
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`and IPR2022-00075. He has also applied for pro hac vice admission
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`in IPR2018-00465, but the proceeding was denied before the motion
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`was approved. Mr. Sheasby is also concurrently applying for pro hac
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`vice admission in IPR2022-00999. Id. ¶ 10.
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`11. Mr. Sheasby has an established familiarity with the subject matter at
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`issue in this proceeding. Mr. Sheasby has acquired substantial
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`understanding of the underlying legal and technological issues at stake
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`in this and related proceedings. In particular, Mr. Sheasby was
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`substantively involved in the preparation of the POPR submitted in
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`this case. Id. ¶ 11.
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`12. Patent Owner has expended significant time and resources with Mr.
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`Sheasby and wishes to rely on Mr. Sheasby as counsel in this
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`proceeding as appropriate, including in additional capacities, such as
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`Patent No. 11,016,918
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`for oral argument, and thereby benefit from Mr. Sheasby’s specific
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`knowledge and extensive litigation experience. Id. ¶ 11.
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`IV. GOOD CAUSE EXISTS FOR PRO HAC VICE ADMISSION OF JASON G.
`SHEASBY DESPITE PETITONER’S OPPOSITION
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`The facts outlined above in the Statement of Facts, and contained in the
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`Declaration of Jason G. Sheasby (EX2060), establish that there is good cause to
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`admit Mr. Sheasby pro hac vice in this proceeding under 37 C.F.R. § 42.10. Patent
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`Owner’s Lead is a registered practitioner. Mr. Sheasby is an experienced litigating
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`attorney and has an established familiarity with the subject matter at issue.
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`V. CONCLUSION
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`In light of the foregoing, Patent Owner respectfully requests that the Board
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`admit Jason G. Sheasby pro hac vice in this proceeding.
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`Dated: August 28, 2023
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` /Hong Zhong/
`H. Annita Zhong (Reg. No. 65,530)
`Jason Sheasby (pro hac vice to be requested)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067
`Tel: (310) 277-1010
`Fax: (310) 203-7199
`Email: HZhong@irell.com
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`IPR2022-00996
`Patent No. 11,016,918
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`CERTIFICATE OF SERVICE
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`I hereby certify, pursuant to 37 C.F.R. § 42.6, that on August 28, 2023, a
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`complete copy of the foregoing document and EX2060 were served upon the
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`following, by ELECTRONIC MAIL:
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`BAKER BOTTS L.L.P.
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`Eliot D. Williams, Reg. No. 50,822
`Theodore W. Chandler, Reg. No. 50,319
`Ferenc Pazmandi, Reg. No. 66,216
`Brianna L. Potter, Reg. No. 76,748
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`DLSamsungNetlistIPRs@BakerBotts.com
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`/Susan M. Langworthy/
` Susan M. Langworthy
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