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`Paper No. ___
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`SONY CORPORATION,
`Petitioner,
`
`v.
`
`FUJIFILM CORPORATION,
`Patent Owner.
`_____________
`
`Case No. IPR2018-00876
`Patent No. 6,462,905
`_____________
`
`
`PETITIONER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF NATHAN R. SPEED
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`EXHIBITS
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`Exhibit Description
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`1001 U.S. Patent No. 6,462,905
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`1002
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`File History for U.S. Patent No. 6,462,905
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`1003 CV of Mr. Thomas W. von Alten
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`1004 Declaration of Mr. Thomas W. von Alten
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`1005 U.S. Patent No. 5,901,916 (“McAllister-I”)
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`1006
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`Japanese Patent Publication No. H11-273307 (“Mizutani”)
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`1007
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`European Patent Publication No. 0 284 687 A2 (“Laverriere”)
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`1008 U.S. Patent No. 5,927,633 (“McAllister-II”)
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`1009
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`File History for European Patent No. 1 098 320 B1
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`1010
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`Japanese Patent Publication No. S63-11776 (“Morita-I”)
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`1011
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`EP 0 926 676 A1 (“Morita-II”)
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`1012
`
`Japanese Patent Publication No. H11-288571 (“Tsuyuki”)
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`1013
`
`International Patent Publication No. WO 99/41513 (“Betzler”)
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`1014
`
`Fujifilm Corp. and Fujifilm Recording Media U.S.A., Inc.’s Proposed
`Constructions in Certain Magnetic Data Storage Tapes and Cartridges
`Containing the Same, 337-TA-1076 (dated Jan. 18, 2018)
`
`1015
`
`Summary of Petitioner’s Proposed Claim Constructions
`
`1016 Redline Comparison of Issued Claim 4 of U.S. Patent No. 6,462,905 and
`Original Claim 4 of EP 1 098 320 B1
`
`1017 U.S. Patent No. 2,778,636
`
`1018
`
`1019
`
`1020
`
`Excerpt from FUNK & WAGNALLS NEW INTERNATIONAL DICTIONARY OF
`THE ENGLISH LANGUAGE (2000)
`
`Excerpt from THE AMERICAN HERITAGE DICTIONARY OF THE ENGLISH
`LANGUAGE (2011)
`
`Excerpt from THE AMERICAN HERITAGE DICTIONARY OF THE ENGLISH
`LANGUAGE (2011)
`
`1021 Works, G., “CURVIC COUPLING DESIGN,” Gear Technology
`
`i
`
`
`
`
`
`
`(November/December 1986)
`
`1022
`
`Excerpt from WEBSTER’S ENCYCLOPEDIC UNABRIDGED DICTIONARY OF
`THE ENGLISH LANGUAGE (1989)
`
`1023
`
`Excerpt from RANDOM HOUSE UNABRIDGED DICTIONARY (1993)
`
`1024 U.S. Patent No. 1,660,792
`
`1025 Claim Comparison of Original Claim 4 of EP 1 098 320 B1and
`Amended Claim 1 of EP 1 098 320 B1
`
`1026 Claim Element Comparison of Primary References
`
`1027
`
`Standard ECMA-120 (Dec. 1993)
`
`1028
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`Standard ECMA-196 (Dec. 1993)
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`1029
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`European Patent No. 1 098 320 B1
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`1030 Declaration of Nathan R. Speed in Support of Motion for Admission
`Pro Hac Vice
`
`ii
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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, Sony Corporation
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`(“Petitioner”) respectfully requests that the Patent Trial and Appeal Board admit
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`Nathan R. Speed pro hac vice in this proceeding, IPR2018-00876. Petitioner is
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`concurrently seeking admission of Mr. Speed pro hac vice in related case,
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`IPR2018-00877. Patent Owner has been consulted and has indicated it does not
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`object to Mr. Speed being admitted pro hac vice in this proceeding.
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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. Speed pro hac vice in this proceeding.
`
`1
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`
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`First, as set forth in Mr. Speed’s declaration (Ex-1030) at paragraphs H
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`through J, Mr. Speed 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. Speed 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 Petitioner appoint as counsel Mr.
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`Speed, as a litigator, to assist Lead Counsel.
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`Furthermore, as set forth in his declaration, Mr. Speed 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, Petitioner respectfully requests that the Board
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`admit Nathan R. Speed pro hac vice in this proceeding.
`
`
`Date: July 23, 2018
`
`
`
`Respectfully submitted
`Sony Corporation
`
`/ Richard Giunta/
`Richard F. Giunta, Reg. No. 36,149
`Michael N. Rader, Reg. No. 52,146
`Randy J. Pritzker, Reg. No. 35,986
`WOLF, GREENFIELD & SACKS, P.C.
`600 Atlantic Avenue
`Boston, MA 02210
`(617) 646-8000 Phone
`(617) 646-8646 Fax
`
`2
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (E)(4)
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`I certify that on July 23, 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 Patent Owner, upon the following:
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`Eliot D. Williams
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`Robert C. Scheinfeld
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`Robert L. Maier
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`Jennifer Tempesta
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`Margaret M. Welsh
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`Date: July 23, 2018
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`eliot.williams@bakerbotts.com
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`robert.scheinfeld@bakerbotts.com
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`robert.maier@bakerbotts.com
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`jennifer.tempesta@bakerbotts.com
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`margaret.welsh@bakerbotts.com
`
`/MacAulay S. Rush /
`MacAulay S. Rush
`Patent Paralegal
`WOLF, GREENFIELD & SACKS, P.C.
`
`3
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`
`
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