`
`
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`___________________
`
`
`
`Juniper Networks, Inc.,
`Petitioners
`v.
`ChriMar Systems, Inc.,
`Patent Owner
`
`______________________
`
`U.S. Patent No. 9,019,838
`Case No. IPR2016-01397
`
`
`
`
`
`
`
`
`
`JUNIPER NETWORKS., INC.'S UNOPPOSED MOTION FOR
`ADMISSION PRO HAC VICE OF TALIN GORDNIA
`UNDER 37 C.F.R. § 42.10
`
`
`
`Case IPR2016-01397
`Patent No. 9,019,838
`
`RELIEF REQUESTED
`
`
`
`I.
`
`Pursuant to 37 C.F.R. § 42.10(c) and the Board's "Notice of Filing Date
`
`Accorded to the Petition and Time for Filing Patent Owner's Preliminary
`
`Response" entered July 12, 2016, Paper 3, granting authorization to file motions
`
`for pro hac vice admission under 37 C.F.R. § 42.10(c), Petitioner Juniper
`
`Networks, Inc., requests that the Board admit Talin Gordnia pro hac vice in this
`
`proceeding.
`
`II.
`
`STATEMENT OF FACTS
`
`Pursuant to 37 C.F.R. § 42.10(c), the Board
`
`may recognize counsel pro hac vice during a proceeding
`upon a showing of good cause, subject to the condition
`that lead counsel be a registered practitioner and to any
`other conditions as the Board may impose. For
`example, where the lead counsel is a registered
`practitioner, a motion to appear pro hac vice by counsel
`who is not a registered practitioner may be granted upon
`showing that counsel is an experienced litigating
`attorney and has an established familiarity with the
`subject matter at issue in the proceeding.
`
`37 C.F.R. § 42.10(c). The facts, supported by the Declaration of Talin Gordnia in
`
`Support of Motion for Admission Pro Hac Vice ("Gordnia Decl.", Ex. 1017),
`
`establish good cause to admit Talin Gordnia pro hac vice in this proceeding.
`
`10131092
`
`
`- 1 -
`
`
`
`
`
`Case IPR2016-01397
`Patent No. 9,019,838
`
`
`1.
`
`Lead counsel Nima Hefazi is a registered practitioner and is
`
`experienced in inter partes proceedings before the USPTO.
`
`2.
`
`Backup counsel Michael R. Fleming is a registered practitioner and
`
`experienced in inter partes proceedings before the USPTO.
`
`3.
`
`Talin Gordnia is an experienced litigating attorney. Ms. Gordnia has
`
`extensive experience in patent law and has been litigating patent cases for over six
`
`(6) years. Gordnia Decl. ¶ 11. Ms. Gordnia is a member in good standing of the
`
`California State Bar, with no suspensions or disbarments from practice, nor any
`
`application for admission to practice denied, nor any sanctions or contempt
`
`citations. Gordnia Decl. ¶¶ 1-6. Ms. Gordnia is also admitted to practice before
`
`the United States District Courts for the Central District of California and
`
`Northern District of California. Gordnia Decl. ¶ 2.
`
`4. Ms. Gordnia has familiarity with the subject matter at issue in this
`
`proceeding. Gordnia Decl. ¶ 12.
`
`5. Ms. Gordnia has read and will comply with the Office Patent Trial
`
`Practice Guide and the Board's Rules for Practice for Trials set forth in Title 42 of
`
`the C.F.R., and she agrees to be subject to the USPTO Code of Professional
`
`Responsibility set forth in 37 C.F.R. §§ 11.101 et seq., and to disciplinary
`
`jurisdiction under 37 C.F.R. § 11.19(a). Gordnia Decl. ¶¶ 7-8.
`
`
`
`
`- 2 -
`
`
`
`
`
`Case IPR2016-01397
`Patent No. 9,019,838
`
`
`6. Ms. Gordnia has appeared pro hac vice before the Patent Trial and
`
`Appeal Board in connection with IPR Nos. IPR2015-01764, IPR2015-01767, and
`
`IPR2015-01768. Gordnia Decl. ¶ 10.
`
`7. Ms. Gordnia is seeking pro hac vice admission in co-pending matters
`
`IPR2016-01389, IPR2017-01391, and IPR2016-01399. Ms. Gordnia also has pro
`
`hac vice motions pending in IPR Nos. IPR2017-00607, IPR2017-00608, IPR2017-
`
`00617, IPR2017-00619, IPR2017-00620, IPR2017-00621 and IPR2017-00623.
`
`Gordnia Decl. ¶ 9.
`
`III. ANALYSIS
`The facts contained in the Statement of Facts above, and contained in the
`
`Gordnia Declaration, establish that there is good cause to admit Talin Gordnia pro
`
`hac vice in this proceeding under 37 C.F.R. § 42.10. Lead and backup counsel are
`
`registered practitioners, Ms. Gordnia is an experienced litigating attorney, and Ms.
`
`Gordnia has an established familiarity with the subject matter at issue in the
`
`proceeding.
`
`
`
`
`- 3 -
`
`
`
`
`
`Case IPR2016-01397
`Patent No. 9,019,838
`
`
`IV. NO OPPOSITION TO THIS MOTION
`Petitioner has confirmed with Patent Owner that they do not oppose the
`
`present motion.
`
`V. CONCLUSION
`For the foregoing reasons, Juniper Networks, Inc. respectfully requests that
`
`the Board admit Talin Gordnia pro hac vice in this proceeding.
`
`
`
`
`
`
`- 4 -
`
`
`
`
`
`Case IPR2016-01397
`Patent No. 9,019,838
`
`
`Dated: February 17, 2017
`
`
`
`Respectfully submitted,
`
`By:
`
` /s/ Nima Hefazi /
` Nima Hefazi
`
`Nima Hefazi (Reg. No. 63,658)
`Michael R. Fleming (Reg. No. 67,633)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067-4276
`Telephone: (310) 277-1010
`Fax: (310) 203-7199
`Email: Juniper-ChrimarIPR@irell.com
`Attorneys for Petitioner,
`Juniper Networks, Inc.
`
`
`
`
`- 5 -
`
`
`
`
`
`Case IPR2016-01397
`Patent No. 9,019,838
`
`
`CERTIFICATE OF SERVICE
`
`
`
`Pursuant to 37 C.F.R. § 42.6, the undersigned certifies that on February 17,
`
`2017, a copy of the foregoing document and supporting Declaration (Ex. 1017)
`
`were served, by electronic mail, as agreed to by the parties, upon the following:
`
`
`
`THOMPSON & KNIGHT LLP
`1722 Routh Street, Suite 1500
`Dallas, TX 75201
`Justin.Cohen@tklaw.com
`
`
`
`Richard W. Hoffman
`Reising Ethington PC
`755 West Big Beaver Road Suite 1850
`Troy, Michigan 48084
` Direct: 248.786.0163
`Fax: 248.689.4071
`Hoffmann@reising.com
`
`
`
`Chrimar@tklaw.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` /s/ Susan M. Langworthy/
` Susan M. Langworthy
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
