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Case IPR2023-00554
`U.S. Patent No. 10,652,111
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CISCO SYSTEMS, INC.,
`Petitioner
`
`v.
`
`ORCKIT CORPORATION,
`Patent Owner.
`
`Case IPR2023-00554
`Patent No. 10,652,111
`
`PATENT OWNER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION PURSUANT TO 37 C.F.R. §42.10(c)
`
`

`

`
`
`
`
`Case IPR2023-00554
`U.S. Patent No. 10,652,111
`
`Patent Owner Orckit Corporation respectfully requests that the Board
`
`recognize George Stamatopoulos as counsel pro hac vice during this proceeding.
`
`I.
`
`BACKGROUND
`
`Patent Owner’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 (MPT) [“the Order”]. In
`
`particular, this motion for pro hac vice Admission is being filed no sooner than
`
`twenty one (21) days after service of the petition.
`
`Further, this motion is authorized by the Notice of Filing Date Accorded To
`
`Petition and Time For Filing Patent Owner Preliminary Response (Paper 5).
`
`II. STATEMENT OF FACTS
`
`As required by the Order, the following statement of facts shows that there is
`
`good cause for the Board to recognize Mr. Stamatopoulos pro hac vice.
`
`Mr. Stamatopoulos is an experienced patent litigation attorney with more than
`
`ten years of experience. In that time, he has served as counsel in numerous patent
`
`infringement suits before the U.S. District Courts for the Eastern District of Virginia,
`
`Eastern District of Texas, and District of Delaware and is admitted to practice in the
`
`U.S. District Courts for the Eastern District of Texas, Eastern District of New York,
`
`and Southern District of New York.
`
`Mr. Stamatopoulos has reviewed and is very familiar with (i) U.S. Patent No.
`
`
`
`1
`
`

`

`Case IPR2023-00554
`U.S. Patent No. 10,652,111
`
`10,652,111 (the “’111 patent”), the patent-at-issue in this proceeding, (ii) the prior
`
`art relied upon in Petitioner’s Petition, (iii) the legal and factual arguments that have
`
`been addressed by Patent Owner, and (iv) the developments in this proceeding since
`
`the filing of the Petition. Mr. Stamatopoulos was counsel for Orckit Corporation in
`
`the related district court case, Orckit Corporation. v. Cisco Systems, Inc., No. 2:22-
`
`cv-00276-JRG-RSP (E.D. Tex.) (dismissed without prejudice on September 22,
`
`2023), in which Orckit Corporation had asserted the ’111 patent against Cisco
`
`Systems, Inc.
`
`Because Mr. Stamatopoulos is an experienced practitioner with an established
`
`familiarity with the subject matter of this proceeding, Patent Owner respectfully
`
`submits that there is good cause for the Board to recognize Mr. Stamatopoulos as
`
`counsel pro hac vice during this proceeding.
`
`III. DECLARATION OF INDIVIDUAL SEEKING TO APPEAR
`
`Patent Owner’s Motion for Pro Hac Vice Admission is accompanied by a
`
`Declaration of George Stamatopoulos (Exhibit 2022) as required by the Order.
`
`2
`
`

`

`Date: November 3, 2023
`
`Respectfully submitted,
`
`Case IPR2023-00554
`U.S. Patent No. 10,652,111
`
`_/Stephen P. McBride______
` Stephen P. McBride
` Reg. No. 78,396
`
` James T. Carmichael
` Reg. No. 45,306
`
` Carmichael IP, PLLC
`
` Counsel for Patent Owner
`
`3
`
`

`

`Case IPR2023-00554
`U.S. Patent No. 10,652,111
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the following documents were served
`
`by electronic service, by agreement between the parties, on the date below:
`
`PATENT OWNER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION PURSUANT TO 37 C.F.R. §42.10(c)
`EXHIBIT 2022
`
`The names and email addresses of the parties being served are as follows:
`
`Jeffrey D. Blake
`
`
`
`jblake@merchantgould.com
`
`Daniel W. McDonald
`
`dmcdonald@merchantgould.com
`
`OrckitIPR@merchantgould.com
`
`Respectfully submitted,
`
`Stephen P. McBride
`
`Date: Nov. 3, 2023
`
`

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