UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
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`v.
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`DODOTS LICENSING SOLUTIONS LLC,
`Patent Owner.
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`Case IPR2023-00701
`Patent 8,510,407
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`PETITIONER’S UNOPPOSED MOTION FOR PRO HAC VICE
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`ADMISSION OF MICHAEL BALLANCO UNDER 37 C.F.R. § 42.10(c)
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
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`v.
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`DODOTS LICENSING SOLUTIONS LLC,
`Patent Owner.
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`Case IPR2023-00701
`Patent 8,510,407
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`PETITIONER’S UNOPPOSED MOTION FOR PRO HAC VICE
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`ADMISSION OF MICHAEL BALLANCO UNDER 37 C.F.R. § 42.10(c)
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`Proceeding No.: IPR2023-00701
`Attorney Docket: 39843-0149IP1
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`SAMSUNG-1001 U.S. Patent No. 8,510,407 to Kembel, et al. (“the ’407 Patent”)
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`UPDATED EXHIBIT LIST
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`SAMSUNG-1002 Excerpts from the Prosecution History of the ’407 Patent (“the
`Prosecution History”)
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`SAMSUNG-1003 Declaration of Dr. Douglas C. Schmidt
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`SAMSUNG-1004 Curriculum Vitae of Dr. Douglas C. Schmidt
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`SAMSUNG-1005 U.S. Patent No. 6,278,448 B1 (“Brown”)
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`SAMSUNG-1006 U.S. Patent No. 6,449,638 B1 (“Wecker”)
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`SAMSUNG-1007 U.S. Patent No. 5,793,368 (“Beer”)
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`SAMSUNG-1008 U.S. Patent No. 6,789,263 B1 (“Shimada”)
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`SAMSUNG-1009 U.S. Patent No. 6,088,340 (“Buchholz”)
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`SAMSUNG-1010 U.S. Patent No. 6,819,345 B1 (“Jones”)
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`SAMSUNG-1011 HTML 4 Unleashed (“Darnell”)
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`SAMSUNG-1012 IPR2019-01279 Final Written Decision
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`SAMSUNG-1013 U.S. Patent No. 6,342,907 B1 (“Petty”)
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`SAMSUNG-1014 Lenovo Holding Company, Inc. v. DoDots Licensing Solutions
`LLC, No. 2021-1247, 2021 WL 5822248 (Dec. 8, 2021).
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`SAMSUNG-1015 U.S. Patent No. 6,311,058 B1 (“Wecker 2”)
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`SAMSUNG-1016 U.S. Patent No. 5,737,560 (“Yohanan”)
`SAMSUNG-1017 CNET News, “PointCast unveils free news service,”
`https://web.archive.org/web/20110616130215/http://news.cnet.co
`m/PointCast-unveils-free-news-service/2100-1023_3-
`204658.html, last accessed Feb. 16, 2023
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`Proceeding No.: IPR2023-00701
`Attorney Docket: 39843-0149IP1
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`SAMSUNG-1018 Declaration of June Ann Munford
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`SAMSUNG-1019 DoDots Licensing Solutions LLC v. Samsung Electronics Co., Ltd.
`et al., 6:22-cv-00535, W.D. Tex., filed May 24, 2022
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`SAMSUNG-1020 U.S. Patent No. 6,094,681 (“Shaffer”)
`SAMSUNG-1021 RESERVED
`SAMSUNG-1022 U.S. Patent No. 6,185,614 B1 (“Cuomo”)
`SAMSUNG-1023 RESERVED
`SAMSUNG-1024 Joint Claim Construction Statement, 6:22-cv-00535, W.D. Tex.,
`filed May 15, 2023
`SAMSUNG-1025 IPR2019-01279, Paper 40 (CAFC Decision)
`SAMSUNG-1026 Email from Board dated November 15, 2023 authorizing
`Petitioner to file a Motion to Submit Supplemental Information
`SAMSUNG-1027 Declaration of Michael Ballanco in Support of Pro Hac Vice
`Admission
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`ii
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`Proceeding No.: IPR2023-00701
`Attorney Docket: 39843-0149IP1
`Pursuant to 37 C.F.R. § 42.10(c), Petitioner respectfully requests that the
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`Board recognize Michael Ballanco as counsel pro hac vice in this proceeding.
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`Petitioner seeks the counsel of Michael Ballanco due to his experience in other
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`patent-related matters and particularly due to his familiarity with the substantive
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`and technical issues involved in this proceeding. This motion is authorized by the
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`Notice of Filing Date Accorded to Petition and Time for Filing Patent Owner
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`Preliminary Response that was mailed on May 10, 2023.
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`Counsel for Petitioner conferred with counsel for Patent Owner prior to
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`filing this motion, and Patent Owner does not oppose this motion. A deposition
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`for this matter was noticed on April 30, 2024, and is scheduled for May 9, 2024.
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`I.
`Statement of Facts
`Michael Ballanco is a patent litigation attorney with more than 9 years of
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`experience representing clients in cases involving computer software and
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`electronic systems. Mr. Ballanco regularly litigates patent cases before various
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`U.S. district courts around the country, the International Trade Commission and
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`the Court of Appeals for the Federal Circuit. Through his practice in such cases,
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`Mr. Ballanco has gained substantial experience in jury trials, bench trials,
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`discovery, Markman hearings, and appeals. Apart from a clerkship at the Court
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`of Appeals for the Federal Circuit, Mr. Ballanco has spent his entire career at
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`1
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`Proceeding No.: IPR2023-00701
`Attorney Docket: 39843-0149IP1
`Fish & Richardson P.C., focusing on patent litigation and patent issues.
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`Petitioner provides Appendix A, as evidence of Mr. Ballanco’s biography.
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`Mr. Ballanco also has particular experience and familiarity with the
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`substantive and technical issues involved in this inter partes review proceeding
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`and other inter partes review proceedings challenging other patents that have
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`been asserted in Entropic Communications, LLC v. DISH Network Corp. et al.,
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`2:23-cv-01043-JWH-KES (C.D. Cal.). Petitioner has invested significant
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`financial resources in defending against the asserted patents, and Mr. Ballanco
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`will be taking an active role with respect to the patent that is the subject of the
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`present proceeding. Moreover, Petitioner has developed a particular relationship
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`with Mr. Ballanco such that Petitioner desires to continue the relationship with
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`Mr. Ballanco for the purpose of this proceeding.
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`II.
`Affidavit of Individual Seeking to Appear
`This Motion for Pro Hac Vice Admission is accompanied by an Affidavit
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`of Michael Ballanco. Accordingly, Petitioner submits that there is good cause
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`under 37 C.F.R. § 42.10(c) for the Board to recognize Michael Ballanco as
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`counsel pro hac vice during this proceeding.
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`Date: May 1, 2024
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`Proceeding No.: IPR2023-00701
`Attorney Docket: 39843-0149IP1
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`Respectfully submitted,
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`/Hyun Jin In/
`W. Karl Renner, Reg. No. 41,265
`Jeremy J. Monaldo, Reg. No. 58,680
`Hyun Jin In, Reg. No. 70,014
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`T: 202-783-5070
`F: 877-769-7945
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`Attorneys for Petitioner
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`Proceeding No.: IPR2023-00701
`Attorney Docket: 39843-0149IP1
`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR § 42.6(e), the undersigned certifies that on May 1, 2024,
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`a complete and entire copy of this Petitioner’s Unopposed Motion for Pro Hac
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`Vice Admission of Michael Ballanco and Exhibit 1027 were provided by email, to
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`the Patent Owner, by serving the correspondence addresses of record as follows:
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`Jason S. Charkow
`Richard Juang
`Chandran B. Iyer
`Ronald M. Daignault
`DAIGNAULT IYER LLP
`8618 Westwood Center Drive Suite 150
`Vienna, VA 22182
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`Email: dodotslit@daignaultiyer.com
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`/Diana Bradley/
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`Diana Bradley
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(858) 678-5667
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