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` Paper No. __
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`TAIWAN SEMICONDUCTOR MANUFACTURING CO., LTD,
`Petitioner,
`
`v.
`
`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`____________
`
`Case IPR2017-018431
`Patent 7,893,501
`____________
`
`MOTION FOR PRO HAC VICE ADMISSION OF
`JOSHUA J. MILLER
`
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`1 Case IPR2017-01844 has been consolidated with this proceeding.
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`6080218.1
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`
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`APPENDIX LISTING OF EXHIBITS
`
`
`Exhibit Description
`2201 Request for Continued Examination dated March 29, 2010
`2202 U.S. Patent No. 6,437,404 (“Xiang”)
`2203 U.S. Patent No. 6,870,230 (“Matsuda”)
`2204 Office Action dated March 29, 2010
`2205 U.S. Patent No. 3,390,022
`2206 McGraw-Hill Dictionary of Scientific and Technical Terms (2003)
`2207 Declaration of Joshua J. Miller in Support of Motion for Admission Pro
`Hac Vice
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`i
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`I.
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`STATEMENT OF PRECISE RELIEF REQUESTED
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`Pursuant to 37 C.F.R. § 42.10(c) and Paper No. 3, Godo Kaisha IP Bridge 1
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`(“Patent Owner”) respectfully requests that the Patent Trial and Appeal Board
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`admit Joshua J. Miller pro hac vice in this proceeding, IPR2017-01843. Patent
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`Owner is concurrently seeking admission of Mr. Miller pro hac vice in related case
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`IPR2017-01841.
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`II.
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`STATEMENT OF FACTS SHOWING GOOD CAUSE FOR THE
`BOARD TO RECOGNIZE COUNSEL PRO HAC VICE DURING
`THE PROCEEDING
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`In accordance with 37 C.F.R. § 42.10(c), the Board may recognize counsel
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`pro hac vice during a proceeding upon a showing of good cause, subject to the
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`condition that lead counsel be a registered practitioner and to any other conditions
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`that the Board may impose. Section 42.10(c) indicates that “where lead counsel is
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`a registered practitioner, a motion to appear pro hac vice by counsel who is not a
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`registered practitioner may be granted upon a showing that counsel is an
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`experienced litigating attorney and has an established familiarity with the subject
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`matter at issue in the proceeding.” The facts here establish good cause for the
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`Board to recognize Mr. Miller pro hac vice in this proceeding.
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`
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`1
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`
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`First, as set forth in Mr. Miller’s declaration (Ex. 2207) at paragraphs H
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`through J, Mr. Miller has familiarity with the subject matter at issue in these
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`proceedings. He has worked on preparing and reviewing the materials submitted
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`in this proceeding.
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`Second, Mr. Miller has extensive patent litigation experience and is expected
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`to use his experience to support Lead Counsel during the proceedings, including
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`during depositions. Good cause exists to have Patent Owner appoint as counsel
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`Mr. Miller, as a litigator, to assist Lead Counsel.
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`Furthermore, as set forth in his declaration, Mr. Miller attests to all of the
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`remaining matters set forth in Paper No. 7 from Unified Patents v. Parallel Iron,
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`Case IPR2013-00639 (PTAB Oct. 15, 2013).
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`III. CONCLUSION
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`For the foregoing reasons, Patent Owner respectfully requests that the Board
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`admit Joshua J. Miller pro hac vice in this proceeding.
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`Dated: March 14, 2018
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`Respectfully submitted,
`Godo Kaisha IP Bridge 1
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`By /Gerald B. Hrycyszyn /
`Gerald B. Hrycyszyn, Reg. No. 50,474
`Richard F. Giunta, Reg. No. 36,149
`Edmund J. Walsh, Reg. No. 32,950
`WOLF GREENFIELD & SACKS, P.C.
`600 Atlantic Ave.
`Boston, MA 02210-2206
`Tel: 617-646-8000/Fax: 617-646-8646
`
`2
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`
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
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`I certify that on March 14, 2018, I will cause a copy of the foregoing
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`document, including any exhibits referred to therein, to be served via electronic
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`mail, as previously consented to by Petitioner, upon the following:
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`David L. Cavanaugh
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`David.Cavanaugh@wilmerhale.com
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`Dominic E. Massa
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`Dominic.Massa@wilmerhale.com
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`Michael H. Smith
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`MichaelH.Smith@wilmerhale.com
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`Date: March 14, 2018
`
`/MacAulay Rush /
`MacAulay Rush
`Patent Paralegal
`WOLF, GREENFIELD & SACKS, P.C.
`
`
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