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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., ASSA ABLOY RESIDENTIAL
`GROUP, INC., AUGUST HOME, INC., HID GLOBAL CORPORATION,
`ASSA ABLOY GLOBAL SOLUTIONS, INC.,
`Petitioner,
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`v.
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`CPC PATENT TECHNOLOGIES PTY LTD.,
`Patent Owner.
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`Case IPR2022-01006
`Patent 9,665,705
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`PATENT OWNER’S MOTION FOR PRO HAC VICE ADMISSION OF
`NICHOLAS A. GEIGER PURSUANT TO 37 C.F.R. § 42.10(c)
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`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner CPC Patent Technologies
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`Pty Ltd., (“CPC”) hereby submits this motion for Nicholas A. Geiger to appear pro
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`hac vice. Patent Owner respectfully requests the Board to recognize Mr. Geiger as
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`counsel pro hac vice during this proceeding and demonstrates good cause for doing
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`so as shown below.
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`I.
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`AUTHORIZATION FOR THIS MOTION
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`This motion is authorized by the Notice of Filing Date Accorded to Petition
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`(“Notice”) (Paper 3) in the IPRs and is made no sooner than twenty-one (21) days
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`after service of the Petition.
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`II. GOOD CAUSE EXISTS
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`Pursuant to the Notice, the following statement of facts shows that good
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`cause exists for the Board to recognize Mr. Geiger pro hac vice.
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`Lead counsel for this proceeding, Andrew C. Ryan, is a registered
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`practitioner (Registration No. 43,070).
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`Mr. Geiger is an experienced litigation attorney with over fifteen (15) years
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`of litigation experience. Ex. 2002 ¶ 8. He has been involved in dozens of patent
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`infringement cases in federal district courts across the United States. Ex. 2002 ¶ 8.
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`He has experience in various aspects of patent infringement matters, including all
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`aspects of litigation leading up to and including jury trials and bench trials. Ex.
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`2002 ¶ 8.
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`2
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`Mr. Geiger is a member in good standing of the Bars of the State of
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`Connecticut, the District of Columbia, and the Commonwealth of Virginia and is
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`admitted to practice before the U.S. Court of Appeals for the Federal Circuit and
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`the U.S. District Court for the District of Connecticut. Ex. 2002 ¶ 2.
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`Mr. Geiger has not been suspended or disbarred from practice, has never had
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`any application for admission to practice denied, and has never had any sanctions
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`or contempt citations imposed against him. Ex. 2002 ¶¶ 3-5.
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`Mr. Geiger has obtained substantial familiarity with the involved patent, the
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`prior art, and the various issues raised in this proceeding and is serving as counsel
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`in the co-pending district court litigation, ASSA ABLOY AB et al. v. CPC Patent
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`Technologies Pty. Ltd., and Charter Pacific Corporation Ltd., Case No. 3:22-cv-
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`694-MPS (D. Conn.). Ex. 2002 ¶ 9. Moreover, Mr. Geiger has reviewed the
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`involved patent, the Petition, the prior art, and all other cited materials. Ex. 2002 ¶
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`9. Given his extensive patent litigation experience and familiarity with the Petition,
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`the cited materials, and the patented technology, Mr. Geiger has established
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`familiarity with the subject matter at issue in this proceeding. Ex. 2002 ¶ 9.
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`Mr. Geiger has read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules for Practice for Trials set forth in Part 42 of Title 37
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`of the Code of Federal Regulations, and he agrees to be subject to the USPTO’s
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`3
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`Code of Professional Conduct as set forth in 37 C.F.R. §§ 11.101 et seq., and to
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`disciplinary jurisdiction under 37 C.F.R. §§ 11.19(a). Ex. 2002 ¶¶ 6-7.
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`Mr. Geiger will also apply to appear pro hac vice in related Case Nos.
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`IPR2022-01045, IPR2022-01089, IPR2022-01093, and IPR2022-01094.
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`Given Mr. Geiger’s familiarity with the subject matter at issue in this
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`proceeding, Patent Owner respectfully submits that it has shown good cause for the
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`Board to recognize Mr. Geiger as counsel pro hac vice during this proceeding.
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`III. DECLARATION OF INDIVIDUAL SEEKING TO APPEAR
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`This Motion is accompanied by the Declaration of Steven M. Coyle.
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`Respectfully submitted,
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`By: /Andrew C. Ryan/
`Andrew C. Ryan
`USPTO Reg. No. 43,070
`CANTOR COLBURN LLP
`20 Church Street, 22nd Floor
`Hartford, CT 06103
`Tel.: (860) 286-2929
`Fax.: (860) 286-0115
`ryan@cantorcolburn.com
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`Attorneys for Patent Owner
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`Dated: September 6, 2022
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`4
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on this 6th day
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`of September, 2022, service of the foregoing document was made on the counsel of
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`record for the Petitioner by filing this document through the PTAB’s E2E System
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`as well as delivering a copy via electronic mail to the following address:
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`Dion Bregman
`Andrew Devkar
`James J. Kritsas
`Morgan, Lewis & Bockius LLP
`1400 Page Mill Road
`Palo Alto, CA 94304
`HID-IPRs@morganlewis.com
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`Dated: September 6, 2022
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`By: /Andrew C. Ryan/
`Andrew C. Ryan
`USPTO Reg. No. 43,070
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`5
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