`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`Google LLC,
`Petitioner
`
`v.
`
`WAG Acquisition, L.L.C.
`Patent Owner
`
`
`
`
`IPR2022-01413
`U.S. Patent No. 9,762,636 B2
`
`
`
`
`PETITIONER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF NAINA SONI UNDER 37 C.F.R. § 42.10(c)
`
`
`
`
`
`
`
`
`
`
`
`Petitioner’s Motion for Pro Hac Vice Admission
`U.S. Patent No. 9,762,636 B2
`
`
`Petitioner Google LLC respectfully requests that the Board recognize Naina
`
`Soni, Esq., as counsel pro hac vice during this proceeding. Patent Owner’s counsel
`
`do not oppose this Motion.
`
`BACKGROUND
`
`Petitioner’s Motion for Pro Hac Vice Admission is being filed in compliance
`
`with and pursuant to the Order—Authorizing Motion for Pro Hac Vice Admission
`
`in Case No. IPR2013-00639, Paper 7 (“the Order”) and pursuant to the Board’s
`
`advanced authorization expressed in the Board’s Notice of Filing Date Accorded to
`
`Petition and Time for Filing Patent Owner Preliminary Response dated September
`
`27, 2022 (Paper No. 5).
`
`STATEMENT OF FACTS
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`As required by the Order, the following statement of facts shows that there is
`
`good cause for the Board to recognize Ms. Naina Soni pro hac vice.
`
`Ms. Soni is a litigation attorney and has been involved in numerous complex
`
`litigations in state and federal courts. Ms. Soni’s biography is attached hereto as
`
`Exhibit 1116 to this Motion.
`
`Ms. Soni has reviewed U.S. Patent No. 9,762,636 and the Petition and all other
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`documents already filed in this proceeding. Further, Ms. Soni is counsel for Google
`
`LLC in the pending litigation between the parties involving U.S. Patent No.
`
`
`
`
`
`-1-
`
`
`
`
`
`Petitioner’s Motion for Pro Hac Vice Admission
`U.S. Patent No. 9,762,636 B2
`
`9,762,636 before the United States District Court for the Northern District of
`
`California entitled WAG Acquisition, L.L.C. v. Google LLC, Case No. 3:22-cv-
`
`05772-JD, and, as such, is familiar with the subject matter at issue in this proceeding.
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`Therefore, Petitioner respectfully submits that there is good cause for the
`
`Board to recognize Ms. Soni as counsel pro hac vice during this proceeding.
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`DECLARATION OF INDIVIDUAL SEEKING TO APPEAR
`
`Petitioner’s Motion for Pro Hac Vice Admission is accompanied by a
`
`Declaration of Naina Soni, Esq. attached hereto as Exhibit 1115 as required by the
`
`Order.
`
`
`
`
`
`Dated: November 14, 2023
`
`COOLEY LLP
`ATTN: Patent Docketing
`1299 Pennsylvania Avenue NW
`Suite 700
`Washington, D.C. 20004
`Tel: (858) 550-6086
`Fax: (720) 566-4099
`
`
`
`
`Respectfully submitted,
`
`By:
`
`
`
`
`/Eamonn Gardner/
`Eamonn Gardner
`Reg. No. 63,322
`Counsel for Petitioner
`
`
`
`
`
`-2-
`
`
`
`
`
`Petitioner’s Motion for Pro Hac Vice Admission
`U.S. Patent No. 9,762,636 B2
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§42.6(e)(4)(i) et seq., a complete copy of the attached
`PETITIONER’S UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION
`OF NAINA SONI UNDER 37 C.F.R. § 42.10(c), and related documents are being
`served via email on the 14th day of November 2023, upon Patent Owner’s attorneys
`of record:
`
`
`Ronald Abramson
`ron.abramson@listonabramson.com
`LISTON ABRAMSON LLP
`405 Lexington Ave, 46th Floor
`New York, NY 10174
`Tel: (212) 257-1630
`Fax: (914) 462-4175
`
`M. Michael Lewis
`Ari J. Jaffess
`Gina K. Kim
`michael.lewis@listonabramson.com
`ari.jaffess@listonabramson.com
`gina.kim@listonabramson.com
`LISTON ABRAMSON LLP
`405 Lexington Ave, 46th Floor
`New York, NY 10174
`Tel: (212) 257-1630
`Fax: (914) 462-4175
`
`
`Dated: November 14, 2023
`
`
`
`
`
`
`
`
`/Eamonn Gardner/
`Eamonn Gardner
`Reg. No. 63,322
`Counsel for Petitioner
`
`-3-
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`
`
`
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