`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` APPLE INC.,
` Petitioner,
`
` v.
`
` ZENTIAN LTD.,
` Patent Owner.
` ____________________
`
` Case IPR2023-00037
` Patent 10,971,140
` ____________________
`
` MOTION FOR ADMISSION PRO HAC VICE OF
` KAYVAN B. NOROOZI
`
`
`
` EXHIBIT LIST
`
` 2001
`
` Declaration of Kayvan Noroozi in Support of Pro Hac
` Vice Admission
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` Case No. IPR2023-00037
` U.S. Pat. 10,971,140
`
` I.
`
` RELIEF REQUESTED
` Pursuant to 37 C.F.R. § 42.10(c), Patent Owner Zentian Ltd. (“Zentian”)
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` respectfully requests that the Patent Trial and Appeal Board admit Kayvan B.
`
` Noroozi pro hac vice in this proceeding. Patent Owner has conferred with
`
` Petitioner, and Petitioner has stated that it does not oppose this motion.
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` II.
`
` GOVERNING LAW, RULES, AND PRECEDENT
` 37 CFR § 42.10(c) provides that “where lead counsel is a registered
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` practitioner, a motion to appear pro hac vice by counsel who is not a registered
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` practitioner may be granted upon a showing that counsel is an experienced
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` litigating attorney and has established familiarity with the subject matter at issue in
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` the proceeding.”
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` STATEMENT OF FACTS
` III.
` The facts here satisfy § 42.10(c) and demonstrate good cause for the Board
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` to recognize Mr. Noroozi pro hac vice in this proceeding.
`
` Lead counsel, Peter C. Knops, is a registered practitioner. Counsel, Kayvan
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` B. Noroozi, is an experienced patent litigator in good standing with the California
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` State Bar, admitted to practice before the United States District Courts for the
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` Eastern District of Texas and Northern District of California, and has never been
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` Case No. IPR2023-00037
` U.S. Pat. 10,971,140
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` suspended, disbarred, sanctioned, cited for contempt of court, or had a court or
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` administrative body deny his application for admission to practice. Ex. 2001 ¶¶
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` 1-5. Mr. Noroozi’s declaration includes a list of the proceedings before the Office
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` in which he has applied to appear pro hac vice in the last five years. Id. at ¶ 6. Mr.
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` Noroozi has read and will comply with the Office Patent Trial Practice Guide and
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` the Board’s Rules of Practice for Trials set forth in part 42 of title 37 of the Code of
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` Federal Regulations. Id. at ¶ 7. Mr. Noroozi understands and accepts that he will be
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` subject to the USPTO Rules of Professional Conduct set forth in 37 C.F.R.
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` §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a). Id. at
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` ¶ 8. Mr. Noroozi is familiar with the subject matter at issue in this proceeding
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` through his review of the underlying patent, the record, and discussions with Patent
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` Owner, and its counsel. Id. at ¶ 9.
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` Case No. IPR2023-00037
` U.S. Pat. 10,971,140
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` CONCLUSION
` IV.
` For the foregoing reasons, Patent Owner respectfully requests that the Board
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` admit Kayvan B. Noroozi pro hac vice in this proceeding.
`
` Respectfully submitted,
`
` /Peter C. Knops/
` Peter C Knops
` Reg. No. 37,659
`
` Date: April 5, 2023
`
` Customer Number 146376
` Noroozi P.C.
` Telephone: 310-975-7074
` Facsimile: 844-975-7074
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` Case No. IPR2023-00037
` U.S. Pat. 10,971,140
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` CERTIFICATE OF SERVICE
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` Pursuant to 37 CFR § 42.6(e), the undersigned certifies that on April 5,
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` 2023, a complete and entire copy of this Patent Owner’s Motion for Pro Hac Vice ,
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` and its exhibit, were provided via email, to the Petitioner by serving the
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` correspondence addresses of record as follows:
`
` Adam M. Sandwell
` Adam.Sandwell @eriseip.com
`
` Adam P. Seitz
` Adam.Seitz@eriseip.com
` PTAB@eriseip.com
`
` Jennifer C. Bailey
` Jennifer.Bailey@eriseip.com
`
` Erise IP, P.A.
` 7015 College Blvd., Ste. 700
` Overland Park, Kansas 66211
`
` /Peter C. Knops/
` Peter C. Knops, Reg. No. 37,659
` peter@noroozipc.com
` N OROOZI PC
` 11601 Wilshire Blvd., Suite 2170
` Los Angeles, CA 90025
` Tel.: 310-975-7074
`
` Counsel for Patent Owner
`
` Date: April 5, 2023
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