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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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`ANGEL TECHNOLOGIES GROUP LLC,
`Patent Owner
`_____________
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`Case: IPR2023-00057
`U.S. Patent No. 8,954,432
`_____________
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`PATENT OWNER’S MOTION FOR PRO HAC VICE ADMISSION OF
`KAYLEE E. HOFFNER UNDER 37 C.F.R. §42.10(c)
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313
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`IPR2023-00057
`U.S. Patent No. 8,954,432
`Pursuant to Rule 42.10(c), Patent Owner Angel Technologies Group LLC
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`requests that the Board recognize Kaylee E. Hoffner as counsel pro hac vice during
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`this proceeding.
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`I. TIME FOR FILING
`This Motion is timely because it is being filed no sooner than twenty-one (21)
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`days after service of the Petition in this proceeding, which occurred on October 26,
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`2022.
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`II. STATEMENT OF FACTS
`The following statement of facts show that there is good cause for the Board
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`to recognize Ms. Hoffner as counsel pro hac vice in this proceeding.
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`Ms. Hoffner is an experienced litigation attorney and has an established
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`familiarity with the subject matter at issue in this proceeding. Ms. Hoffner has been
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`involved in numerous complex litigations in federal courts. Ms. Hoffner’s biography
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`is attached hereto as Exhibit 2003.
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`Ms. Hoffner has reviewed U.S. Patent No. 8,954,432, and the petition already
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`filed in this proceeding.
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`III. DECLARATION OF KAYLEE E. HOFFNER
`Patent Owner’s Motion for Pro Hac Vice Admission is accompanied by the
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`Declaration of Ms. Hoffner, filed as Exhibit 2004, attesting to the requirements laid
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`out in the Board’s Order Authorizing Motion for Pro Hac Vice Admission in Case
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`IPR2013-00639 (Paper 7).
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`IPR2023-00057
`U.S. Patent No. 8,954,432
`For the foregoing reasons, as well as the reasons contained in the attached
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`declaration, Patent Owner respectfully requests admission of Kaylee E. Hoffner as
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`counsel pro hac vice during this proceeding.
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`Dated: November 18, 2022
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`Respectfully submitted,
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`s/ Ashley Moore
`Ashley N. Moore
`Reg. No. 51667
`amoore@mckoolsmith.com
`MCKOOL SMITH, P.C.
`300 Crescent Court, Suite 1500
`Dallas, TX 75201
`Telephone (214) 978-4000
`Facsimile: (214) 978-4044
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`Eliza Beeney (pro hac vice requested)
`ebeeney@mckoolsmith.com
`MCKOOL SMITH, P.C.
`One Manhattan West
`395 9th Avenue, 50th Floor
`New York, NY 10001
`Telephone (212) 402-9400
`Facsimile: (212) 402-9444
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`Kaylee Hoffner
`(pro hac vice requested)
`khoffner@mckoolsmith.com
`MCKOOL SMITH, P.C.
`600 Travis Street, Suite 7000
`Houston, TX 77002
`Telephone: (713) 485-7320
`Facsimile: (713) 485-7344
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`Counsel for Angel Technologies Group
`LLC
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`IPR2023-00057
`U.S. Patent No. 8,954,432
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`CERTIFICATION OF SERVICE
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`The undersigned hereby certifies that the foregoing PATENT OWNER’S
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`MOTION FOR PRO HAC VICE ADMISSION OF KAYLEE E. HOFFNER
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`UNDER 37 C.F.R. §42.10(c) has been served on Petitioner via email on the
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`following counsel of record for Petitioner:
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`Lisa K. Nguyen
`lisa.nguyen@allenovery.com
`David M. Tennant
`david.tennant@allenovery.com
`Alan M. Billharz
`alan.billharz@allenovery.com
`Chitrajit Chandrashekar
`chitrajit.chandrashekar@allenovery.com
`Eric E. Lancaster
`eric.lancaster@allenovery.com
`Sara L. Townsend
`sara.townsend@allenovery.com
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`Dated: November 18, 2022
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`By:
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`/s/ Ashley N. Moore
`Ashley N. Moore
`Reg. No. 51667
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