`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`APPLE INC.,
`Petitioner
`
`
`v.
`
`
`
`ZENTIAN LIMITED,
`Patent Owner
`___________
`
`Case No. IPR2023-00037
`U.S. Patent No. 10,971,140
`____________
`
`PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE UNDER 37 C.F.R.
`§ 42.10(C)
`
`
`
`
`
`1
`
`
`
`I.
`
`INTRODUCTION
`Petitioner Apple Inc. (“Petitioner”) respectfully requests the Board recognize
`
`Christina Canino, Esq., as counsel pro hac vice during the above captioned
`
`proceeding. Petitioner files this Motion for Admission Pro Hac Vice in accordance
`
`with the Board’s December 15, 2022, Notice of Filing Date (Paper 3) and 37 C.F.R.
`
`§§ 42.10(c) and 42.22. The Patent Owner does not oppose this motion.
`
`II. CONDITIONS FOR PRO HAC VICE ADMISSION ARE MET
`The conditions outlined in 37 C.F.R. § 42.10(c) and the Order – Authorizing
`
`Motion for Pro Hac Vice Admission in case IPR2013-00639, Paper 7 are met. Patent
`
`Owner is filing this motion more than 21 days after December 2, 2022, the date of
`
`service of the Petition.
`
`Lead Counsel for Petitioner (Jennifer C. Bailey, Reg. No. 52,583) is registered
`
`to practice before the Board and is actively participating in this IPR. 37 C.F.R.
`
`§ 42.10(c).
`
`Good cause exists to permit Christina Canino to be admitted pro hac vice for
`
`this proceeding. Christina Canino has established familiarity with the subject matter
`
`at issue in this proceeding, including knowledge of U.S. Patent No. 10,971,140
`
`(“the ’140 Patent”), the Petition, and the prior art submitted in the instant Petition.
`
`Exhibit 1034, Declaration of Christina Canino at ¶ 8. Christina Canino solely
`
`practices in patent litigation and IPRs and has been involved in several patent
`
`2
`
`
`
`litigations before the federal courts and assisted on many IPRs. Id. at ¶ 9. She has
`
`experience litigating patents and participating in IPRs where the patents related to
`
`both the electrical and mechanical fields. Id. She has argued before the relevant
`
`tribunals in patent litigation proceedings, assisted with depositions, and discussed
`
`these areas in-depth with expert witnesses and engineers. Id. Therefore, Christina
`
`Canino’s knowledge would be of substantial benefit to Petitioner in this proceeding.
`
`Counsel for Patent Owner does not oppose Christina Canino appearing pro
`
`hac vice during this proceeding.
`
`III. AFFIDAVIT OR DECLARATION OF INDIVIDUAL SEEKING TO
`APPEAR
`A Declaration of Christina Canino as Exhibit 1034 accompanies Petitioner’s Motion
`
`for Pro Hac Vice Admission.
`
`IV. FEES
`Petitioner approves the $250.00 fee in accordance with 42.15(e) for pro hac
`
`vice admission may be charged to deposit account 50-6159.
`
`V. CONCLUSION
`Petitioner respectfully requests that the Board recognize Christina Canino as counsel
`
`pro hac vice during this proceeding.
`
`
`
`
`
`3
`
`
`
`
`
`Date: August 23, 2023
`
`Respectfully submitted,
`
`
`
`ERISE IP, P.A.
`
`
`
`BY: /Jennifer C. Bailey/
`Jennifer C. Bailey, Reg. No. 52,583
`Adam P. Seitz, Reg. No. 52,206
`Adam M. Sandwell, Reg. No. 72,484
`
`COUNSEL FOR PETITIONER
`
`
`
`
`
`
`
`4
`
`
`
`CERTIFICATE OF SERVICE ON PATENT OWNER
`
`UNDER 37 C.F.R. § 42.105(a)
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on August 23,
`
`2023, the foregoing Petitioner’s Motion For Admission Pro Hac Vice Under 37
`
`C.F.R. § 42.10(C) was served via electronic filing with the Board and via Electronic
`
`Mail on the following practitioners of record for Patent Owner:
`
`Peter C. Knops (peter@noroozipc.com)
`Kayvan B. Noroozi (kayvan@noroozipc.com)
`Katherine Rhoades (katherine.rhoades@bartlitbeck.com)
`Nevin Gewertz (nevin.gewertz@bartlitbeck.com)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Jennifer C. Bailey
`Jennifer C. Bailey, Reg. No. 52,583
`ATTORNEY FOR PETITIONER
`
`
`
`
`
`
`
`
`
`
`
`5
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
