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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`META PLATFORMS, INC.
`Petitioner
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`v.
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`THALES VISIONIX, INC.
`Patent Owner
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`U.S. PATENT NO. 6,922,632
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`IPR2022-01304
`_________________________________________________
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`REAL PARTY-IN-INTEREST GENTEX CORPORATION’S
`UNOPPOSED MOTION FOR ADMISSION PRO HAC VICE OF
`MELISSA B. COLLINS
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`April 21, 2023
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`
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`Case IPR2022-01304
`U.S. Patent No. 6,922,632
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`I.
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`Relief Requested
`Pursuant to 37 C.F.R. § 42.10, Real Party-in-Interest Gentex Corporation
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`(“Gentex”) requests that the Board admit Melissa B. Collins pro hac vice in this
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`proceeding to serve as backup counsel.
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`II. Governing Rules and Precedent
`The Board is authorized to recognize counsel pro hac vice pursuant to 37
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`C.F.R. § 42.10(c), which provides that:
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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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`Motion for pro hac vice admission must be filed in accordance with Unified
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`Patents v. Parallel Iron, IPR 2013-00639, Paper No. 7 (P.T.A.B. Oct. 15, 2013)
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`(the “Unified Patents Order”). The Unified Patents Order requires that a pro hac
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`vice motion “[c]ontain a statement of facts showing there is good cause for the
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`Board to recognize counsel pro hac vice during the proceeding.” Unified Patents
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`Order at 3. A motion for pro hac vice admission should also be accompanied by
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`Case IPR2022-01304
`U.S. Patent No. 6,922,632
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`an affidavit or declaration of the individual seeking to appear attesting to the
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`following:
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`i. Membership in good standing of the Bar of at least one State or the
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`District of Columbia;
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`ii. No suspensions or disbarments from practice before any court or
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`administrative body;
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`iii. No application for admission to practice before any court or
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`administrative body ever denied;
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`iv. No sanctions or contempt citations imposed by any court or
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`administrative body;
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`v.
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`The individual seeking to appear has read and will comply with the
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`Office Patent Trial Practice Guide and the Board’s Rules of
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`Practice for Trials set forth in part 42 of 37 C.F.R.;
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`vi.
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`The individual will be subject to the USPTO Rules of Professional
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`Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary
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`jurisdiction under 37 C.F.R. § 11.19(a);
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`vii. All other proceedings before the Office for which the individual
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`has applied to appear pro hac vice in the last three (3) years; and
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`viii.
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`Familiarity with the subject matter at issue in the proceeding.
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`Unified Patents Order at 3–4.
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`U.S. Patent No. 6,922,632
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`III.
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`Statement of Facts
`Based on the following facts, and supported by the Declaration of Ms.
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`Collins (Ex. 2006) submitted herewith, Petitioner requests the pro hac vice
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`admission of Melissa B. Collins in this proceeding:
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`1.
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`Gentex’s counsel, Arthur J. Argall III and D. Shayon Ghosh, are
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`registered practitioners (Argall, Reg. No. 73,005); (Ghosh, Reg. No.
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`75,865).
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`2.
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`Ms. Collins is a partner at Williams & Connolly LLP and an experienced
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`litigation attorney. Ms. Collins has more than ten (10) years of litigation
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`experience. (Ex. 2006 ¶ 2.)
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`3.
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`Ms. Collins has established familiarity with the subject matter at issue in
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`this proceeding. Ms. Collins is Gentex’s counsel in the co-pending
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`district court litigation, Gentex Corp. et al. v. Meta Platforms, Inc. et al.,
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`No. 22-cv-03892-YGR (N.D. Cal.), and, having been counsel in the
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`district court litigation for over a year, has engaged in extensive strategic
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`discussions with Patent Owner’s lead and backup counsel and Gentex’s
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`counsel regarding the matters at issue in this proceeding. (Ex. 2006
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`¶ 10.)
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`4.
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`Ms. Collins is a member in good standing of the bars of New York and
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`the District of Columbia. (Ex. 2006 ¶ 3.)
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`5.
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`6.
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`7.
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`8.
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`Ms. Collins has never been suspended or disbarred from practice before
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`any court or administrative body. (Ex. 2006 ¶ 4.)
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`No court or administrative body has ever denied Ms. Collins’s
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`application for admission to practice before it. (Ex. 2006 ¶ 5.)
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`No court or administrative body has ever imposed sanctions or contempt
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`citations on Ms. Collins. (Ex. 2006 ¶ 6.)
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`Ms. Collins has read and will comply with the Office of Patent Trial
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`Practice Guide and the Board’s Rules of Practice for Trials set forth in
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`part 42 of 37 C.F.R. (Ex. 2006 ¶ 7.)
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`9.
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`Ms. Collins understands that she will be subject to the USPTO Code of
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`Professional Responsibility set forth in 37 C.F.R. §§ 11.101 et seq. and
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`will be subject to disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`(Ex. 2006 ¶ 8.)
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`10. Ms. Collins has not been admitted to appear pro hac vice before the
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`Board in the last three years. (Ex. 2006 ¶ 9.)
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`IV. Good Cause Exists for the Pro Hac Vice Admission of Ms. Collins In
`This Proceeding
`The Board may recognize counsel pro hac vice during a proceeding upon a
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`showing of good cause, subject to the condition that lead counsel be a registered
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`practitioner and to any other conditions as the Board may impose. 37 C.F.R.
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`§ 42.10(c). Patent Owner’s lead counsel, Meredith Martin Addy, and additional
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`backup counsel for Gentex, Arthur J. Argall III and D. Shayon Ghosh, are all
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`registered practitioners before the Board. Based on the facts contained herein, as
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`supported by Ms. Collins’s declaration, good cause exists to admit Ms. Collins pro
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`hac vice in this proceeding.
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`As set forth in her declaration, Ms. Collins has established familiarity with
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`the subject matter at issue in the proceeding. As counsel for Gentex in the co-
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`pending district court litigation for over a year, Ms. Collins is familiar with the
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`issues now pending before the Board. Ms. Collins has also engaged in strategic
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`discussions with Patent Owner and Gentex’s counsel throughout her time as
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`counsel for Gentex in the district court litigation. Ms. Collins’s admission pro hac
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`vice will permit her to participate in depositions in this matter. For these reasons,
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`Gentex has a substantial need for Ms. Collins’s pro hac vice admission and her
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`involvement in the prosecution of this proceeding.
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`V.
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`Conclusion
`For the foregoing reasons, Petitioner respectfully request that Ms. Collins be
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`admitted pro hac vice in this proceeding. The Board is hereby authorized to charge
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`any fees associated with this filing to Customer No. 129657.
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`April 21, 2023
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`Case IPR2022-01304
`U.S. Patent No. 6,922,632
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`/Arthur J. Argall III/
`Arthur J. Argall III (Reg. No. 73,005)
`Additional Backup Counsel for Real-
`Party-in-Interest and Licensee
`Gentex Corp.
`Williams & Connolly LLP
`680 Maine Avenue SW
`Washington, DC 20024
`202-434-5000 (Telephone)
`202-434-5029 (Facsimile)
`Gentex-IPR@wc.com
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`Case IPR2022-01304
`U.S. Patent No. 6,922,632
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`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies that a true
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`and correct copy of the foregoing was served on April 21, 2023, by delivering a
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`copy via electronic mail on the following counsel of record for the Petitioner:
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`Meta-Thales-IPR@kirkland.com
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`April 21, 2023
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`/Arthur J. Argall III/
`Arthur J. Argall III (Reg. No. 73,005)
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