UNITED STATES PATENT AND TRADEMARK OFFICE
`___________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`HEWLETT PACKARD ENTERPRISE COMPANY,
`Petitioner,
`
`v.
`
`CHRIMAR SYSTEMS, INC.,
`Patent Owner.
`___________
`Case No. IPR2019-00033
`Patent No. 8,902,760
`___________
`
`PETITIONER’S UNOPPOSED MOTION FOR ADMISSION
`PRO HAC VICE OF KARON N. FOWLER
`PURSUANT TO 37 C.F.R. § 42.10
`
`
`___________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`HEWLETT PACKARD ENTERPRISE COMPANY,
`Petitioner,
`
`v.
`
`CHRIMAR SYSTEMS, INC.,
`Patent Owner.
`___________
`Case No. IPR2019-00033
`Patent No. 8,902,760
`___________
`
`PETITIONER’S UNOPPOSED MOTION FOR ADMISSION
`PRO HAC VICE OF KARON N. FOWLER
`PURSUANT TO 37 C.F.R. § 42.10
`
`
`
`Motion for Admission Pro Hac Vice
`IPR of U.S. Patent No. 8,902,760
`Pursuant to 37 C.F.R. §42.10, Petitioner respectfully requests the pro hac
`
`vice admission of attorney Karon N. Fowler in this proceeding. The facts,
`
`supported by the attached Declaration of Karon N. Fowler in Support of Motion
`
`for Admission Pro Hac Vice (“Fowler Decl.”), establish good cause to admit
`
`Ms. Fowler pro hac vice in this proceeding. Petitioner conferred with Patent
`
`Owner, and Patent Owner confirmed that it does not oppose this Motion.
`
`I.
`
`STATEMENT OF FACTS
`
`Lead counsel Hersh Mehta is a registered practitioner (Reg. No. 62,336) and
`
`experienced in inter partes proceedings in the USPTO. Backup counsel Brent A.
`
`Hawkins is a registered practitioner (Reg. No. 44,146) and experienced in inter
`
`partes proceedings in the USPTO. Along with Hersh Mehta and Brent Hawkins,
`
`Karon Fowler represents Hewlett Packard Enterprise in connection with the
`
`pending district court action captioned Cisco Sys., Inc. v. Hewlett-Packard
`
`Enterprise Co., Case No. 2:17-cv-13770-AC-RSW (E.D. Mich.).
`
`Karon N. Fowler joined Morgan Lewis as an intellectual property litigation
`
`associate in 2016 after serving as a judicial law clerk for the Honorable Eduardo C.
`
`Robreno in the U.S. District Court of the Eastern District of Pennsylvania. (Fowler
`
`Decl. ¶ 1.)
`
`Since joining Morgan Lewis, Ms. Fowler has primarily focused her practice
`
`on patent litigation. (Id. at ¶ 2.) In that time, Ms. Fowler has gained experience
`
`2
`
`
`
`Motion for Admission Pro Hac Vice
`IPR of U.S. Patent No. 8,902,760
`conducting technical infringement and validity analysis, working with technical
`
`experts to prepare reports on infringement and validity issues, preparing for
`
`depositions of technical experts and fact witnesses, briefing claim construction
`
`issues, preparing for Markman hearings, drafting dispositive motions on a range of
`
`technical issues, and representing clients in patent litigation trials and hearings
`
`before district courts around the country, arbitral panels, and the International
`
`Trade Commission. (Id.) Further, Ms. Fowler has assisted her colleagues at
`
`Morgan Lewis in proceedings before the Board, and she is familiar with its
`
`established practices. (Id.)
`
`Ms. Fowler is a member in good standing of the California State Bar
`
`admitted to practice in the United States Court of Appeals for the Federal Circuit,
`
`the United States Court of Appeals for the Ninth Circuit, and the United States
`
`District Courts for the Central, Eastern, Northern, and Southern Districts of
`
`California. (Id. at ¶ 3.)
`
`She has never been suspended or disbarred from practice before any court or
`
`administrative body. (Id. at ¶ 4.) She has never had an application for admission
`
`to practice before any court or administrated body denied. Id. Nor has any court
`
`or administrative body imposed sanctions or contempt citations against her. (Id.)
`
`Ms. Fowler has read and will comply with the Office Patent Trial Practice
`
`Guide and the Board’s Rules for Practice for Trials set forth in part 42 of 37 C.F.R.
`
`3
`
`
`
`Motion for Admission Pro Hac Vice
`IPR of U.S. Patent No. 8,902,760
`(Id. at ¶ 5.) She acknowledges and 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). (Id.) While Ms. Fowler has
`
`not previously applied to appear pro hac vice before the Office, she is concurrently
`
`applying for admission pro hac vice in IPR2019-00032 and IPR2019-00033. (Id.
`
`at ¶ 6.)
`
`Ms. Fowler has established familiarity with the subject matter at issue this
`
`proceeding. (Id. at ¶ 7.) She has reviewed in detail and is familiar with U.S.
`
`Patent No. 8,902,760 and all exhibits relied upon by Petitioner in this proceeding.
`
`(Id.) Ms. Fowler also participated in drafting the Petition in this proceeding. (Id.)
`
`Moreover, Ms. Fowler has engaged and will continue to engage in extensive
`
`strategic and substantive discussions regarding this proceeding with Hersh Mehta,
`
`who is a registered practitioner and the lead counsel for Petitioner in this
`
`proceeding. (Id.)
`
`In addition to the foregoing, Ms. Fowler has gained experience with a range
`
`of network communication technologies as a patent litigator. (Id. at ¶ 8.) For
`
`example, Ms. Fowler has been involved in district court matters concerning
`
`computer network activity monitors (Packet Intelligence LLC v. NetScout Systems,
`
`Inc., No. 2:16-CV-230-JRG (E.D. Tex.)), fax-to-e-mail communication systems
`
`via data network (OpenPrint LLC v. HP Inc., 1:17-cv-01077-GMS (D. Del.)), and
`
`4
`
`
`
`Motion for Admission Pro Hac Vice
`IPR of U.S. Patent No. 8,902,760
`serial data communication technology for movable barrier operators (Certain
`
`Access Control Systems And Components Thereof, Inv. No. 337-TA-1016
`
`(U.S.I.T.C.)). (Id.)
`
`II. ANALYSIS
`
`The facts contained in the Statement of Facts above and Ms. Fowler’s
`
`Declaration establish that there is good cause to admit Ms. Fowler pro hac vice in
`
`this proceeding under 37 C.F.R. § 42.10. Lead counsel Hersh Mehta and backup
`
`counsel Brent A. Hawkins are registered practitioners and experienced in inter
`
`partes proceedings in the USPTO. Ms. Fowler is an experienced patent litigation
`
`attorney, and she has an established familiarity with the subject matter at issue in
`
`this proceeding.
`
`III. CONCLUSION
`
`For the foregoing reasons, Petitioner respectfully requests the Board admit
`
`Karon N. Fowler pro hac vice in this proceeding.
`
`Dated: October 26, 2018
`
`Respectfully Submitted,
`
`/Hersh H. Mehta/
`Hersh H. Mehta
`Reg. No. 62,336
`
`MORGAN, LEWIS & BOCKIUS LLP
`77 West Wacker Drive
`Chicago, IL 60601
`Telephone: 312.324.1000
`Facsimile: 312.324.1001
`
`5
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on October 26,
`2018, a complete and entire copy of PETITIONER’S UNOPPOSED MOTION
`FOR ADMISSION PRO HAC VICE OF KARON N. FOWLER PURSUANT
`TO 37 C.F.R. § 42.10, was served on all Patent Owner’s counsel of record via
`electronic mail as follows:
`
`LEAD COUNSEL
`Frank A. Angileri (Reg. No. 36,733)
`BROOKS KUSHMAN P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`Telephone (248) 358-4400
`Facsimile (248) 358-3351
`fangileri@brookskushman.com
`CHRMC0123IPR1@brookskushman.com
`
`BACK-UP COUNSEL
`Thomas A. Lewry (Reg. No. 30,770)
`Marc Lorelli (Reg. No. 43,759)
`Christopher C. Smith
`(Reg. No.
`59,669)
`BROOKS KUSHMAN P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`Telephone (248) 358-4400
`Facsimile (248) 358-3351
`tlewry@brookskushman.com
`mlorelli@brookskushman.com
`csmith@brookskushman.com
`
`Dated: October 26, 2018
`
`/Hersh H. Mehta/
`Hersh H. Mehta (Reg. No. 62,336)
`
`6
`
`
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