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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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`ASSA ABLOY AB, ASSA ABLOY Inc.,
`HID Global Corporation, ASSA ABLOY Global Solutions, Inc.,
`and Master Lock Company, LLC
`Petitioners,
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`v.
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`CPC Patent Technologies PTY LTD.,
`Patent Owner
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`Case IPR2022-01006
`Patent No. 9,665,705
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`PETITIONERS’ MOTION TO SUBSTITUTE
`AND WITHDRAW COUNSEL
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`I.
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`STATEMENT OF RELIEF REQUESTED
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`Case IPR2022-01006
`Patent No. 9,665,705
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`Pursuant to 37 C.F.R. § 42.10(e) and the Board’s authorization in an email
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`dated April 22, 2024, Petitioners ASSA ABLOY AB, ASSA ABLOY Inc., HID
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`Global Corporation, ASSA ABLOY Global Solutions, Inc., and Master Lock
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`Company, LLC respectfully request that the Board authorize the withdrawal of all
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`counsel from Morgan, Lewis & Bockius LLP, including lead counsel Dion M.
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`Bregman (Reg. No. 45,645), and the substitution of Lionel M. Lavenue (Reg. No.
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`46,859) as new lead counsel.
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`II.
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`STATEMENT OF FACTS
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`Petitioners designated lead counsel Dion M. Bregman and backup counsel
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`Andrew V. Devkar and James J. Kritsas, all from Morgan, Lewis & Bockius LLP,
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`in its mandatory notices filed May 31, 2022. (Paper 2). These attorneys and their law
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`firm are no longer representing Petitioners in this IPR.
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`Petitioners filed new powers of attorney and updated mandatory notices on
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`April 18, 2024, (Papers 56, 57, and 58) designating new backup counsel Lionel M.
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`Lavenue, Kara A. Specht, Benjamin A. Saidman, Sydney R. Kestle, and Safiya
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`Aguilar, all from Finnegan, Henderson, Farabow, Garrett & Dunner, LLP. Mr.
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`Lavenue is familiar with the patent-at-issue, the prior art, and the briefing, and
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`Petitioners do not seek any delay in the proceedings in connection with this motion.
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`Patent Owner does not oppose this motion.
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`1
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`III. CONCLUSION
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`Case IPR2022-01006
`Patent No. 9,665,705
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`Petitioners respectfully request that Dion M. Bregman, Andrew V. Devkar,
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`and James J. Kritsas be deemed withdrawn from the present proceeding, and that
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`Petitioners be authorized to file updated mandatory notices designating Mr. Lavenue
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`as lead counsel.
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`Dated: April 22, 2024
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`Respectfully submitted,
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`By: /Lionel M. Lavenue/
` Lionel M. Lavenue
` Reg. No. 46,859
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`2
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`CERTIFICATE OF SERVICE
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`Case IPR2022-01006
`Patent No. 9,665,705
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`The undersigned hereby certifies that a copy of the foregoing
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`PETITIONERS’ MOTION TO SUBSTITUTE AND WITHDRAW
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`COUNSEL was served electronically on April 22, 2024 on counsel of record for
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`the Patent Owner as follows:
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`Michael J. Rye
`mrye@cantorcolburn.com
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`Steven M. Coyle
`scoyle@cantorcolburn.com
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`Nicholas A. Geiger
`ngeiger@cantorcolburn.com
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`
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`By: /Lisa C. Hines/
`Lisa C. Hines
`Case Manager
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
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`Dated: April 22, 2024
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