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Filed on behalf of: Ford Motor Company
`
`
`
`
`
`
`
`
`Entered: May 10, 2023
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________________
`
`FORD MOTOR COMPANY,
`Petitioner,
`
`v.
`
`NEO WIRELESS, LLC,
`Patent Owner.
`_______________________
`IPR2023-00764
`Patent 10,965,512
`______________________
`
`
`
`PETITIONER’S UNOPPOSED MOTION TO WITHDRAW COUNSEL
`AND SUBSTITUTE LEAD COUNSEL
`
`
`
`
`
`
`
`

`

`IPR2023-00764 (USP 10,965,512)
`
`Petitioner’s Motion to Withdraw
`
`I.
`
`STATEMENT OF PRECISE RELIEF REQUESTED
`Pursuant to 37 C.F.R. § 42.10(e), Petitioner, Ford Motor Company
`
`(“Ford”), respectfully requests that the Board authorize the withdrawal of
`
`Latham & Watkins LLP including lead counsel, Jonathan M. Strang (Reg. No.
`
`61,724), and back-up counsel, Matthew J. Moore (Reg. No. 42,012), Ashley N.
`
`Finger (Reg. No. 78,093), and Kumar Ravula (Reg. No. 65,588) and the
`
`substitution of John S. LeRoy (Reg. No. 48,158) of Brooks Kushman as lead
`
`counsel and Christopher Smith (Reg. No. 59,669), also of Brooks Kushman, will
`
`remain as back-up counsel. The Board authorized the filing of the present motion
`
`in a May 9, 2023 email.
`
`Patent Owner does not oppose. Petitioner is certifying “service [of this
`
`motion] on the client and counsel for Patent Owner,” as directed by the Board’s
`
`email of May 9. See attached Certificate of Service.
`
`II.
`
`STATEMENT OF FACTS SHOWING GOOD CAUSE FOR THE
`BOARD TO AUTHORIZE WITHDRAWAL
`Jonathan M. Strang (Reg. No. 61,724) was appointed by Petitioner Ford and
`
`identified as lead counsel for the present inter partes review. Petitioner requests
`
`that the current designated lead counsel and back-up counsel, Matthew J. Moore
`
`(Reg. No. 42,012), Ashley N. Finger (Reg. No. 78,093), and Kumar Ravula (Reg.
`
`No. 65,588) be allowed to withdraw from the proceeding and John S. LeRoy (Reg.
`
`No. 48,158) be substituted as lead counsel. Christopher Smith (Reg. No. 59,669)
`
`1
`
`

`

`IPR2023-00764 (USP 10,965,512)
`
`Petitioner’s Motion to Withdraw
`
`will remain as back-up counsel. John S. LeRoy was added as back-up counsel in
`
`the May 5, 2023 Updated Mandatory Notices and meets the requirements of 37
`
`C.F.R. §42.10(c) for lead counsel.
`
`No extensions of time will be sought by Substitute Lead Counsel as a result
`
`of the proposed substitution. Accordingly, this substitution will not cause any
`
`delay. If granted, Petitioner will promptly file an Updated Power of Attorney and
`
`Updated Mandatory Notices identifying substitute lead counsel.
`
`III. CONCLUSION
`Petitioner respectfully requests that the Board grant its motion to authorize
`
`the withdrawal of counsel and substitution of lead counsel.
`
`
`
`
`
`
`
`
`
`Dated: May 10, 2023
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`By: / Jonathan M. Strang /
`
`Jonathan M. Strang (Reg. No. 61,724)
`jonathan.strang@lw.com
`Latham & Watkins LLP
`555 Eleventh Street, NW, Ste. 1000
`Washington, D.C. 20004-1304
`Telephone: 202.637.2200
`Fax: 202.637.2201
`
`Counsel for Petitioner Ford Motor
`Company
`
`
`
`
`
`
`
`2
`
`

`

`IPR2023-00764 (USP 10,965,512)
`
`Petitioner’s Motion to Withdraw
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), I certify that on this 10th day of May, 2023,
`
`a true and correct copy of the foregoing Petitioner’s Unopposed Motion to
`
`Withdraw Counsel and Substitute Lead Counsel was served by electronic mail
`
`on Patent Owner’s lead and back-up counsel at the following email addresses:
`
`Kenneth J. Weatherwax
`Parham Hendifar
`LOWENSTEIN & WEATHERWAX LLP
`1016 Pico Boulevard, Santa Monica, CA 90405
`Tel.: 310.307.4503
`Fax: 310.307.4509
`weatherwax@lowensteinweatherwax.com
`hendifar@lowensteinweatherwax.com
`NeoWireless_IPRs@lowensteinweatherwax.com
`
`Hamad M. Hamad
`CALDWELL, CASSADY, & CURRY P.C.
`2121 N. Pearl St., Ste 1200
`Dallas, TX 75201
`Tel.: 214.888.4848
`Fax: 214.888.4849
`hhamad@caldwellcc.com
`
`
`Pursuant to the Board’s email dated May 9, 2023, the undersigned certifies
`that a true and correct copy of the foregoing Petitioner’s Unopposed Motion to
`Withdraw Counsel and Substitute Lead Counsel was served on the official
`correspondence address for the patent shown in Patent Center:
`
`
`
`
`
`

`

`IPR2023-00764 (USP 10,965,512)
`
`Petitioner’s Motion to Withdraw
`
`Anthony Volpe
`C. Koenig
`VOLPE KOENIG
`30 SOUTH 17TH STREET, 18TH FLOOR
`PHILADELPHIA, PA 19103
`
`via FEDERAL EXPRESS next business day delivery, on May 10, 2023.
`
`
`
`
`
`
`
`
`By: / Jonathan M. Strang /
`
`
`
`
`
`
`
`Jonathan M. Strang (Reg. No. 61,724)
`jonathan.strang@lw.com
`Latham & Watkins LLP
`555 Eleventh Street, NW, Ste. 1000
`Washington, D.C. 20004-1304
`Telephone: 202.637.2200
`Fax: 202.637.2201
`
`Counsel for Petitioner Ford Motor
`Company
`
`
`
`
`
`

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