Filed on behalf of Securus Technologies, Inc.
`By:
`Justin B. Kimble (JKimble-IPR@bcpc-law.com)
`
`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
`
`Daniel F. Olejko (dolejko@bcpc-law.com)
`Nicholas C. Kliewer (nkliewer@bcpc-law.com)
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 West
`Dallas, TX 75201
`Tel: 214.785.6670
`Fax: 214.786.6680
`
`
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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`GLOBAL TEL*LINK CORPORATION,
`Petitioner,
`v.
`SECURUS TECHNOLOGIES, INC.,
`Patent Owner.
`
`
`Case IPR2016-01220
`U.S. Patent No. 9,007,420 B1
`
`
`
`PRO HAC VICE MOTION TO ADMIT ATTORNEY
`JEFFREY R. BRAGALONE PURSUANT TO 37 C.F.R. § 42.10(c)
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
`
`By:
`Justin B. Kimble (JKimble-IPR@bcpc-law.com)
`
`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
`
`Daniel F. Olejko (dolejko@bcpc-law.com)
`Nicholas C. Kliewer (nkliewer@bcpc-law.com)
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 West
`Dallas, TX 75201
`Tel: 214.785.6670
`Fax: 214.786.6680
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`GLOBAL TEL*LINK CORPORATION,
`Petitioner,
`v.
`SECURUS TECHNOLOGIES, INC.,
`Patent Owner.
`
`
`Case IPR2016-01220
`U.S. Patent No. 9,007,420 B1
`
`
`
`PRO HAC VICE MOTION TO ADMIT ATTORNEY
`JEFFREY R. BRAGALONE PURSUANT TO 37 C.F.R. § 42.10(c)
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
`
`
`Case IPR2016-01220
`Patent 9,007,420
`
`
`
`Patent Owner Securus Technologies, Inc. (“Securus”) hereby files this motion
`
`pursuant to 37 C.F.R. § 42.10(c) for Jeffrey R. Bragalone to appear pro hac vice on
`
`its behalf before the Patent Trial and Appeal Board in IPR2016-01220. This motion
`
`follows the guidelines set forth in IPR2013-00639, Paper 7, entered October 15,
`
`2013.
`
`A. Lead Counsel is a Registered Practitioner.
`
`Securus has already designated a registered practitioner, Justin B. Kimble
`
`(Reg. No. 58,591) as lead counsel. Securus intends to designate Jeffrey R. Bragalone
`
`as back-up counsel in the event this motion is granted.
`
`B. There is Good Cause for the Board to Recognize Jeffrey R. Bragalone
`pro hac vice During This Proceeding.
`
`1. Mr. Bragalone is an Experienced Patent Litigator.
`
`Jeffrey R. Bragalone is an experienced litigator with over 29 years of
`
`experience. He has argued three patent cases before the Federal Circuit: (1)
`
`Greenliant Sys., Inc. v. Xicor LLC, 692 F.3d 1261 (Fed. Cir. 2012); (2) United Access
`
`Technologies, LLC v. Earthlink, Inc., 432 F. App’x 976 (Fed. Cir. 2011); (3) Board
`
`of Regents of the University of Texas System v. BenQ America Corp., 533 F.3d 1362
`
`(Fed. Cir. 2008); and appeared on brief in a fourth case: (4) Tegic Commc’ns Corp.
`
`v. Board of Regents of the University of Texas System, 458 F.3d 1335 (Fed. Cir.
`
`2006). In addition to his argument before the Federal Circuit, Mr. Bragalone has
`
`represented numerous clients in patent litigation and general litigation as lead
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`1
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`Case IPR2016-01220
`Patent 9,007,420
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`counsel in district courts and state courts across the United States. Mr. Bragalone
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`also currently represents plaintiffs in the patent litigation styled Cellular
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`Communications Equipment LLC v. AT&T, Inc. et al., No. 2:15-cv-00576 (E.D.
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`Tex.). Mr. Bragalone has also participated in several oral arguments before the
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`PTAB, including in IPR2014-00785, IPR2014-00824, and IPR2015-00487.
`
`2. Mr. Bragalone Has an Established Familiarity with the Subject
`Matter at Issue in this Proceeding.
`
`Mr. Bragalone has represented Securus in previous patent litigation as well as
`
`general litigation, through which he has familiarized himself with the subject matter
`
`at issue in the proceeding, i.e., inmate telecommunications and management
`
`systems. Specifically, Mr. Bragalone represented Securus in the patent litigation
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`Howlink Global LLC v. Securus Technologies, Inc., No. 4:13-cv-562 (E.D. Tex.,
`
`filed Sept. 24, 2013). In that matter, Mr. Bragalone defended against the plaintiff’s
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`allegations that Securus’s inmate telecommunications systems infringed patents
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`related to collect calls. In connection with that representation, Mr. Bragalone spent
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`significant
`
`time
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`learning
`
`the
`
`technology
`
`involved
`
`in Securus’s
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`inmate
`
`telecommunications systems.
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`Mr. Bragalone has also represented Securus in other litigation matters that
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`have enhanced his familiarity with Securus’s inmate telecommunications and
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`management systems. Those matters include SecureAlert, Inc. et al. v. Satellite
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`2
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`Case IPR2016-01220
`Patent 9,007,420
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`Tracking of People, LLC,1 No. 2:13-cv-01107 (D. Utah, filed Dec. 17, 2013) and
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`SecureAlert, Inc. et al. v. Derrick Brooks et al., No. 140901343 (3rd Judicial District
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`Court, Salt Lake County, Utah, filed Feb. 21, 2014).
`
`Mr. Bragalone has previously appeared pro hac vice representing Securus
`
`before the Patent Trial and Appeal Board in 11 post-grant proceedings. Those
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`proceedings include IPR2014-00785, IPR2014-00810, IPR2014-00824, IPR2014-
`
`00825, CBM2014-00166, IPR2014-01282, IPR2014-01283, IPR2014-01278,
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`IPR2015-0153, IPR2015-00155, and IPR2015-00156. Additionally, Mr. Bragalone
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`currently represents Securus in a number of pending appeals before the U.S. Court
`
`of Appeals for the Federal Circuit, which are all appeals from final written decisions
`
`in post-grant proceedings before the Board. See, e.g., Securus Techs., Inc. v. Global
`
`Tel*Link Corp., Nos. 2016-1992, -1993 (Fed. Cir. docketed May 4, 2016) (appealing
`
`from IPR2014-01278 and IPR2014-01282, involving U.S. Patent No. 7,860,222);
`
`Global Tel*Link Corp. v. Securus Techs., Inc., No. 16-2573 (Fed. Cir. docketed May
`
`26, 2016) (appealing from IPR2015-00156, involving U.S. Patent No. 7,551,732);
`
`Securus Techs., Inc. v. Global Tel*Link Corp., No. 16-2573 (Fed. Cir. docketed Aug.
`
`29, 2016) (appealing from IPR2015-00155, involving U.S. Patent No. 7,853,243).
`
`In preparation for the above identified matters, Mr. Bragalone has become
`
`very familiar with the patents, technology, and prior-art that cover the technology of
`
`
`1 Satellite Tracking of People LLC is a subsidiary of Securus.
`
`3
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`Case IPR2016-01220
`Patent 9,007,420
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`the patent at issue in this proceeding (e.g., institutional telephone systems). Given
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`Mr. Bragalone’s familiarity with the underlying technology, patents, and prior art,
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`Securus asks that the Board grant this Motion to afford Securus the benefit of having
`
`its chosen representation to be authorized to practice before the PTAB in this matter.
`
`C. Mr. Bragalone has Submitted a Declaration2 Herewith Attesting the
`Following Facts.
`
`1. Mr. Bragalone is a member in good standing of the Texas State Bar.
`
`2. Mr. Bragalone has never been subject to any suspensions or
`
`disbarments from practice before any court or administrative body.
`
`3.
`
`None of Mr. Bragalone’s applications for admission to practice before
`
`any court or administrative body has ever been denied.
`
`4. Mr. Bragalone has never been sanctioned nor had contempt citations
`
`imposed by any court or administrative body.
`
`5. Mr. Bragalone has read and will comply with the Office Patent Trial
`
`Practice Guide and the Board’s Rules of Practice for Trials set forth in
`
`part 42 of 37 C.F.R.
`
`6. Mr. Bragalone will be subject to the USPTO Rules of Professional
`
`Conduct set forth in 37 C.F.R. §§ 11.101 et. seq. and disciplinary
`
`jurisdiction under 37 C.F.R. § 11.19(a).
`
`
`2 See Declaration of Jeffrey R. Bragalone, attached hereto as Exhibit 2002.
`
`4
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`Case IPR2016-01220
`Patent 9,007,420
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`7.
`
`During the past three years, Mr. Bragalone has appeared pro hac vice
`
`before the PTAB in 21 proceedings, 11 of which involve the same
`
`parties as Petitioner and Patent Owner as this proceeding and also
`
`involve institutional telecommunication systems technology.
`
`8. Mr. Bragalone has familiarity with the subject matter at issue in the
`
`proceeding as set forth in Section B.2 above.
`
`
` Dated: January 13, 2017
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`
`Justin B. Kimble
`Attorney for Patent Owner
`Registration No. 58,591
`Bragalone Conroy PC
`2200 Ross Avenue, Suite 4500W
`Dallas, TX 75201
`Phone: (214) 785-6670
`Email: JKimble-IPR@bcpc-law.com
`
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`Case IPR2016-01220
`Patent 9,007,420
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`CERTIFICATE OF SERVICE
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`
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`The undersigned hereby certifies that this document has been served via
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`electronic mail on January 13, 2017, to Petitioner via counsel, Michael D. Specht,
`
`and Joseph E. Mutschelknaus at the email addresses: mspecht-PTAB@skgf.com,
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`jmutsche-PTAB@skgf.com, and PTAB@SKGF.com, pursuant to Petitioner’s
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`consent in its Petition at page 60.
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`Justin B. Kimble
`Attorney for Patent Owner
`Registration No. 58,591
`Bragalone Conroy PC
`2200 Ross Avenue, Suite 4500W
`Dallas, TX 75201
`Phone: (214) 785-6670
`Email: JKimble-IPR@bcpc-law.com
`
`6
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