`U.S. Patent No. 6,157,589
`
`
`Filed on behalf of Polaris Innovations Limited
`
`By:
`
`Jing H. Cherng (gcherng@hopkinscarley.com)
`Robert K. Jain (rjain@hopkinscarley.com)
`Hopkins & Carley, a Law Corporation
`70 South First Street
`San Jose, CA 95113
`Tel: (408) 286-9800
`Fax: (408) 998-4790
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`XILINX, INC.,
`
`Petitioner,
`
`v.
`
`POLARIS INNOVATIONS LIMITED,
`
`Patent Owner.
`
`____________
`
`Case IPR2023-00516
`U.S. Patent No. 6,157,589
`____________
`
`PATENT OWNER’S MOTION FOR
`WITHDRAWAL AND SUBSTITUTION OF
`LEAD AND BACK-UP COUNSEL
`
`
`
`
`
`
`
`
`
`Case IPR2023-00516
`U.S. Patent No. 6,157,589
`
`
`I.
`
`37 C.F.R. § 42.10 – STATEMENT OF RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. § 42.10(e), and as authorized by the Board in its email dated
`
`May 8, 2023, Patent Owner respectfully requests that the Board authorize withdrawal of its
`
`counsel, Jing H. Cherng and Robert K. Jain of Hopkins & Carley, a Law Corporation.
`
`II.
`
`STATEMENT SHOWING GOOD CAUSE FOR THE BOARD TO
`AUTHORIZE WITHDRAWAL AND SUBSTITUTION OF COUNSEL
`
`Patent Owner requests that its counsel be deemed withdrawn from the present
`
`proceeding, and new counsel, David T. DeZern (Reg. No. 60,117) and Brent N. Bumgardner
`
`(Reg. No. 48,476), be designated lead and back-up counsel, respectively, to represent Polaris
`
`Innovations, Limited in this proceeding.
`
`New counsel have indicated that they are ready and able to take over the representation,
`
`and thus reasonable steps have been taken to avoid “material adverse effect on the interests of the
`
`client,” including giving due notice to the client, and allowing time for employment of another
`
`practitioner. See 37 C.F.R. § 11.116. Further, Patent Owner believes that granting this motion
`
`will not hinder the economy, the integrity of the patent system, the efficient administration of the
`
`Office, or the ability of the Office to timely complete this proceeding. See 35 U.S.C. § 316(b).
`
`New counsel have submitted Patent Owner’s Updated Power of Attorney. (Paper 6).
`
`III.
`
`PETITIONER DOES NOT OBJECT TO THIS SUBSTITUTION
`
`Petitioner has indicated that they do not oppose the requested withdrawal and substitution
`
`of counsel for Patent Owner.
`
`IV. CONCLUSION
`
`Patent Owner respectfully requests that the Board grant this motion. New counsel for
`
`Patent Owner has already filed Patent Owner’s Updated Mandatory Notices (Paper 7).
`
`
`
`
`
`
`- 2 -
`
`
`
`
`
`Case IPR2023-00516
`U.S. Patent No. 6,157,589
`
`
`Respectfully submitted,
`
`
`
`
`
`
`/s/ Jing H. Cherng
`
`Jing H. Cherng (Reg. No. 68,144)
`Robert K. Jain (Reg. No. 78,927)
`Hopkins & Carley
`A Law Corporation
`The Letitia Building
`70 South First Street
`San Jose, CA 95113-2406
`Telephone:
`(408) 286-9800
`Facsimile:
`(408) 998-4790
`gcherng@hopkinscarley.com
`rjain@hopkinscarley.com
`Attorneys for Patent Owner
`
`- 3 -
`
`
`
`
`
`
`
`
`
`
`Case IPR2023-00516
`U.S. Patent No. 6,157,589
`
`
`
`
`CERTIFICATE OF SERVICE
`It is certified that a copy of the foregoing has been served on Petitioner via
`
`electronic mail transmission addressed to the person(s) at the address(es) below:
`
`For Xilinx, Inc. (Petitioner)
`
`
`
`(Lead Counsel) Oaks, Brian <Boaks@mwe.com>
`
`
`
`
`
`(Back-up Counsel) DaMario, Thomas <Tdamario@mwe.com>;
`
`(Back-up Counsel) Kapadia, Aashish <Akapadia@mwe.com>;
`
`
`
`(Back-up Counsel) Kroll, Tessa <Tkroll@mwe.com>
`
`For Polaris Innovations Limited (Patent Owner)
`
`
`
`(Lead Counsel) David T. DeZern david@nelbum.com;
`
`
`
`(Back-up Counsel) Brent N. Bumgardner brent@nelbum.com
`
`
`
`Dated: May 8, 2023
`
`
`
`4870-2416-1121.2
`
`/s/ Jing H. Cherng
`
`Jing H. Cherng
`Reg. No. 68,144
`Counsel for Patent Owner
`
`
`
`
`
`
`
`
`
`
`
`