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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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`META PLATFORMS, INC.,
`Petitioner
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`v.
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`THALES VISONIX, INC.
`Patent Owner
`
`Case No. IPR2022-01305
`
`Patent No. 6,922,632
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`PETITIONER’S UNOPPOSED MOTION FOR THE PRO HAC VICE
`ADMISSION OF AKSHAY S. DEORAS
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`IPR2022-01305
`Petitioner’s Motion for Pro Hac Vice Admission
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`I.
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`RELIEF REQUESTED
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`Pursuant to 37 C.F.R. § 42.10(c), Petitioner Meta Platforms, Inc. (“Meta” or
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`“Petitioner”) respectfully moves the Patent Trial & Appeal Board (“Board”) for the
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`pro hac vice admission of Akshay S. Deoras in this proceeding.
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`II. GOVERNING LAW, RULES, AND PRECEDENT
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`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
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`upon a showing of good cause, subject to the condition that lead counsel
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`be a registered practitioner and to any other conditions as the Board may
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`impose. For example, where the lead counsel is a registered practitioner,
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`a motion to appear pro hac vice by counsel who is not a registered
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`practitioner may be granted upon showing that counsel is an
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`experienced litigating attorney and has an established familiarity with
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`the subject matter at issue in the proceeding.
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`The Board has stated that a motion for admission pro hac vice should include
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`a “statement of facts showing there is good cause for the Board to recognize counsel
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`pro hac vice during the proceeding” and “[b]e accompanied by an affidavit or
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`declaration of the individual seeking to appear attesting to the 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; ii. No suspensions or disbarments from practice
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`before any court or administrative body; iii. No application for
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`1
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`IPR2022-01305
`Petitioner’s Motion for Pro Hac Vice Admission
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`admission to practice before any court or administrative body ever
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`denied; iv. No sanctions or contempt citations imposed by any court or
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`administrative body; v. The individual seeking to appear has read and
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`will comply with the Office Patent Trial Practice Guide and the Board’s
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`Rules of Practice for Trials set forth in part 42 of 37 C.F.R.; vi. The
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`individual will be subject to the USPTO Rules of Professional Conduct
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`set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction
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`under 37 C.F.R. § 11.19(a); vii. All other proceedings before the Office
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`for which the individual has applied to appear pro hac vice in the last
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`three (3) years; and viii. Familiarity with the subject matter at issue in
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`the proceeding.”
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`Unified Patents, Inc. v. Parallel Iron, LLC, IPR 2013-00639 (MPT) (Paper 7 at 3-
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`4).
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`III. STATEMENT OF FACTS
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`Based on the following facts, supported by the attached declaration, Meta
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`requests that Mr. Deoras, be admitted pro hac vice in this proceeding. As an initial
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`matter, Meta’s lead counsel in this matter, W. Todd Baker (Reg. No. 45,265), is a
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`registered practitioner. Counsel for Petitioner has contacted Patent Owner’s and the
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`Real Party in Interests’ counsel by email to inquire whether they object to the relief
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`requested in this Motion, and their counsel confirmed that they have no objections.
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`Mr. Deoras is concurrently applying to appear pro hac vice in IPR2022-01294,
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`2
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`IPR2022-01305
`Petitioner’s Motion for Pro Hac Vice Admission
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`IPR2022-01298, IPR2022-01301, IPR2022-01302, IPR2022-01303, IPR2022-
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`01304, and IPR2022-01308.
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`A. Mr. Deoras Meets The Requirements For Admission Pro Hac Vice
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`1. Mr. Deoras has more than 14 years of experience as a litigation attorney
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`specializing in patent litigation, representing clients in patent litigation matters in
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`various United States District Courts, the Court of Appeals for the Federal Circuit,
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`and before the International Trade Commission.
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`2. Mr. Deoras is very familiar with U.S. Patent No. 6,922,632, and with the legal
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`subject matter, technical subject matter, and prior art discussed in Petitioner’s
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`Request for Inter Partes Review of U.S. Patent No. 6,922,632, which forms the basis
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`for this proceeding. He is counsel for Meta in the co-pending district court action
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`related to this patent (Gentex Corporation et al. v Meta Platforms, Inc. et al., Case
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`No. 4:22-cv-03892-YGR (N.D. Cal.), and is involved with factual and technical
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`developments in that matter.
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`3. Mr. Deoras is a member in good standing of the Bar of the State of California
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`and the State of New York. He is admitted to practice before the U.S. District Court
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`for the Northern District of California and the U.S. Court of Appeals for the Federal
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`Circuit.
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`4. Mr. Deoras has never been suspended or disbarred from practice before any
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`court or administrative body.
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`3
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`IPR2022-01305
`Petitioner’s Motion for Pro Hac Vice Admission
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`5. Mr. Deoras has never had a court or administrative body deny an application
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`for admission to practice.
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`6. Mr. Deoras has never been sanctioned or cited for contempt by any court or
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`administrative body.
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`7. Mr. Deoras has read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
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`8. Mr. Deoras agrees to be subject to the United States Patent and Trademark
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`Office Code of Professional Responsibility set forth in 37 C.F.R. §§ 11.101 et seq.
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`and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`9.
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`In the past three years, Mr. Deoras was admitted pro hac vice as counsel
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`before the PTAB in the following actions:
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` Inter Partes Review IPR2020-01579, IPR2020-01583, and IPR2020-01585
`as counsel for Apcon, Inc.
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` Inter Partes Review IPR2020-001517, IPR2020-001518, IPR2020-001612,
`IPR2020-001613, and IPR2021-00187 as counsel for Omnitracs, LLC
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` Inter Partes Review IPR2021-00323, IPR2021-00324, and IPR2021-00325
`as counsel for XRS Corporation
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`IV. GOOD CAUSE EXISTS FOR THE PRO HAC VICE ADMISSION OF
`MR. DEORAS IN THIS PROCEEDING
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`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 any other conditions the Board may impose. 37 C.F.R. § 42.10(c).
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`4
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`IPR2022-01305
`Petitioner’s Motion for Pro Hac Vice Admission
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`Meta’s lead counsel in this matter, W. Todd Baker (Reg. No. 45,265), is a registered
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`practitioner. Based on the facts contained herein, good cause exists to admit Mr.
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`Deoras pro hac vice.
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`Mr. Deoras is an experienced litigator with more than 14 years of patent
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`litigation experience. Mr. Deoras has represented clients in matters related to
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`computer systems and networked communications technologies, among others, and
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`has significant experience in patent litigation matters. Mr. Deoras is counsel for
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`Meta in the co-pending litigation on this same patent between the same parties and
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`is actively involved with the strategy and fact development in the matter. In view of
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`Mr. Deoras’ extensive knowledge of the subject matter of this proceeding, Meta has
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`a substantial need for Mr. Deoras’ pro hac vice admission and his involvement in
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`the continued defense of this proceeding.
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`V. CONCLUSION
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`For the foregoing reasons, Meta respectfully requests that Akshay S. Deoras
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`be admitted pro hac vice.
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`
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`Date: April 11, 2023
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`Respectfully submitted,
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` /W. Todd Baker/
`W. Todd Baker (No. 45,265)
`todd.baker@kirkland.com
`KIRKLAND & ELLIS LLP
`1301 Pennsylvania Ave., N.W.
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`5
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`IPR2022-01305
`Petitioner’s Motion for Pro Hac Vice Admission
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`Washington, D.C. 20004
`Telephone: (202) 389-5000
`Facsimile: (202) 389-5200
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`Ellisen Shelton Turner (No. 54,503)
`ellisen.turner@kirkland.com
`KIRKLAND & ELLIS LLP
`2049 Century Park East,
`Los Angeles, CA 90067
`Telephone: (310) 552-4200
`Facsimile: (310) 552-5900
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`Akshay S. Deoras, (pro hac vice pending)
`akshay.deoras@kirkland.com
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: (415) 439-1400
`Facsimile: (415) 439-1500
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`Yimeng Dou (No. 69,770)
`yimeng.dou@kirkland.com
`KIRKLAND & ELLIS LLP
`555 South Flower Street, Suite 3700
`Los Angeles, CA 90071
`Telephone: (213) 680-8400
`Facsimile: (213) 680-8500
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`Attorneys for Petitioner Meta Platforms,
`Inc.
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`IPR2022-01305
`Petitioner’s Motion for Pro Hac Vice Admission
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`PETITIONER’S EXHIBIT LIST
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`
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`Exhibit
`No.
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`Description
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`Previously
`Filed
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`1001 U.S. Patent No. 6,922,632
`
`1002
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`File History of U.S. Patent No. 6,922,632
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`1003 U.S. Patent No. 7,725,253
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`1004
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`File History of U.S. Patent No. 7,725,253
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`1005 Declaration of Dr. Ulrich Neumann in Support of Inter
`Partes Review of U.S. Patent No. 6,922,632
`
`1006 Curriculum Vitae of Dr. Ulrich Neumann
`
`1007 Welch, G. et al., “High-Performance Wide-Area
`Optical Tracking” (2001)
`
`1008 Welch, G. et al., “SCAAT: Incremental Tracking with
`Incomplete Information” (1997)
`
`1009 Welch G. “SCAAT: Incremental Tracking with
`Incomplete Information” PhD Thesis, University of
`North Carolina (1996)
`
`1010 U.S. Patent No. 5,615,132
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`1011 U.S. Patent No. 5,307,289
`
`1012 Gentex’s Amended Preliminary Infringement
`Contentions and corresponding Exhibits 4 and 5 (’632
`and ’253 infringement charts)
`
`1013 Azuma, R. “Predictive Tracking for Augmented
`Reality” PhD Thesis, University of North Carolina
`(1995)
`
`
`X
`
`X
`
`X
`
`X
`
`X
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`X
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`X
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`X
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`X
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`X
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`X
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`X
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`X
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`7
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`
`Exhibit
`No.
`
`IPR2022-01305
`Petitioner’s Motion for Pro Hac Vice Admission
`
`Description
`
`Previously
`Filed
`
`1014 You, S. and Neumann, U. “Orientation Tracking for
`Outdoor Augmented Reality Registration.” (1999)
`
`1015 Carlson, Neal A. and Berarducci, Michael P.
`“Federated Kalman Filter Simulation Results.”
`Navigation. Vol. 41, Issue 3 at 297-322. (Fall 1994)
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`1016 Reitmayr, Gerhard and Schmalstieg. “An Open
`Software Architecture for Virtual Reality Interaction”
`VRST ’01 (November 2001)
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`1017 Barfield, W. “Fundamentals of Wearable Computers
`and Augmented Reality” (2001)
`
`1018 Declaration of Rachel J. Watters regarding Welch, G.
`et al., “High-Performance Wide-Area Optical
`Tracking” (2001)
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`1019 Declaration of Scott Delman regarding Welch, G. et al.,
`“SCAAT: Incremental Tracking with Incomplete
`Information” (1997)
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`1020 Declaration of Dr. James L. Mullins regarding Welch
`G. “SCAAT: Incremental Tracking with Incomplete
`Information” PhD Thesis, University of North Carolina
`(1996)
`
`1021 Declaration of Scott Delman regarding Reitmayr,
`Gerhard and Schmalstieg. “An Open Software
`Architecture for Virtual Reality Interaction” VRST ’01
`(November 2001)
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`1022 U.S. Patent No. 5,807,284
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`1023 U.S. Patent No. 5,991,085
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`X
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`X
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`X
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`X
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`X
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`X
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`X
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`X
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`X
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`X
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`
`8
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`
`
`Exhibit
`No.
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`IPR2022-01305
`Petitioner’s Motion for Pro Hac Vice Admission
`
`Description
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`Previously
`Filed
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`1026
`
`1024 Chen, Steven C. and Lee, Kang. “A mixed-mode smart
`transducer interface for sensors and actuators”, Sound
`& Vibration, 32(4), 24-27 (April 1998)
`
`1025 Hoff, William and Vincent, Tyrone. “Analysis of Head
`Pose Accuracy in Augmented Reality”, IEEE
`Transactions on Visualization and Computer Graphics,
`Vol. 6, Issue 4, October – December 2000.
`
`Zetu, Dan et al., “Extended-Range Hybrid Tracker and
`Applications
`to Motion and Camera Tracking in Manufacturing
`Systems,” IEEE Transactions on Robotics and
`Automation, Vol. 16, Issue 3, June 2000
`
`1027 Declaration of Rachel J. Watters regarding Chen,
`Steven C. and Lee, Kang. “A mixed-mode smart
`transducer interface for sensors and actuators.” Sound
`& Vibration, 32(4), 24-27 (April 1998)
`
`1028 Declaration of Gordon MacPherson regarding Hoff,
`William and Vincent, Tyrone. “Analysis of Head Pose
`Accuracy in Augmented Reality”, IEEE Transactions
`on Visualization and Computer Graphics, Vol. 6, Issue
`4, October – December 2000.
`
`1029 Declaration of Gordon MacPherson regarding Zetu,
`Dan et al., “Extended-Range Hybrid Tracker and
`Applications
`to Motion and Camera Tracking in Manufacturing
`Systems,” IEEE Transactions on Robotics and
`Automation, Vol. 16, Issue 3, June 2000
`
`1030 U.S. Patent No. 5,592,401
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`X
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`X
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`X
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`X
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`X
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`X
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`X
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`
`
`9
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`
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`Exhibit
`No.
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`IPR2022-01305
`Petitioner’s Motion for Pro Hac Vice Admission
`
`Description
`
`Previously
`Filed
`
`1031 Case Management and Pretrial Order, Dkt. 116, Gentex
`Corporation et al. v Meta Platforms, Inc. et al.
`(October 18, 2022)
`1032 Declaration of Akshay S. Deoras in Support of
`Unopposed Motion to Appear Pro Hac Vice on Behalf
`of Petitioner
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`X
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`
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`10
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`IPR2022-01305
`Petitioner’s Motion for Pro Hac Vice Admission
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing document was
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`served on April 11, 2023 via electronic mail directed to counsel of record for the
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`Patent Owner at the following:
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`Thales-Meta-IPRs@addyhart.com
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`Gentex-IPR@wc.com
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`
` /W. Todd Baker/
`W. Todd Baker (No. 45,265)
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`11
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