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`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`ENSIGN US SOUTHERN DRILLING LLC,
`Petitioner,
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`v.
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`C&M OILFIELD RENTALS, LLC
`D/B/A C-MOR ENERGY SERVICES
`Patent Owner.
`
`Case No. IPR2023-00804
`
`Patent 10,976,016
`_____________________________________________________________
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`PATENT OWNER’S
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF
`KARON N. FOWLER PURSUANT TO 37 C.F.R. § 42.10(c)
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`
`
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`Case IPR2023-00804
`Patent 10,976,016
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`Pursuant to 37 C.F.R. § 42.10 (c), Patent Owner C&M Oilfield Rentals, LLC
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`
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`d/b/a C-MOR Energy Services (“Patent Owner”) hereby submits this motion for
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`Karon N. Fowler to appear pro hac vice in this proceeding. Patent Owner
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`respectfully requests the Board to recognize Ms. Fowler as counsel pro hac vice
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`during this proceeding and demonstrates good cause for doing so as shown below.
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`Patent Owner conferred with Petitioner, and Petitioner confirmed that it does not
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`oppose this Motion.
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`I.
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`AUTHORIZATION FOR THIS MOTION
`This motion is authorized by the Notice of Filing Date Accorded to Petition
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`(“Notice”) (Paper 5) in the IPR and is made no sooner than twenty-one (21) days
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`after service of the Petition.
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`II. GOOD CAUSE EXISTS
`Pursuant to the Notice, the following statement of facts shows that good
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`cause exists for the Board to recognize Ms. Fowler pro hac vice.
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`Lead counsel for this proceeding, Dion M. Bregman, is a registered
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`practitioner (Registration No. 45,645).
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`Ms. Fowler is an attorney with over eight years of litigation experience. Ex.
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`2004 ¶ 9. She has been involved in dozens of patent infringement cases in federal
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`district courts across the United States. Id. She has experience in various aspects
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`2
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`of patent infringement matters, including all aspects of litigation leading up to and
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`Case IPR2023-00804
`Patent 10,976,016
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`including jury trials and bench trials. Id.
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`Ms. Fowler is a member in good standing of the Bars of the States of
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`California and Illinois. Id. at ¶ 2. She is admitted to practice before the U.S.
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`Courts of Appeals for the Federal and the Ninth Circuits and the following U.S.
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`District Courts: the Northern District of California, the Central District of
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`California, the Eastern District of California, and the Southern District of
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`California. Id.
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`Ms. Fowler has not been suspended or disbarred from practice before any
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`court or administrative body. She has never had any application for admission to
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`practice denied, and she has never had any sanctions or contempt citations imposed
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`against her. Id. at ¶ 3-6.
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`Ms. Fowler has obtained substantial familiarity with the subject matter at
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`issue in this proceeding. Id. at ¶ 10. She has reviewed in detail and is familiar
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`with U.S. Patent No. 10,976,016, the Petition, and all exhibits relied upon by
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`Petitioner in this proceeding. Id. In addition, Ms. Fowler is serving as counsel in
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`the co-pending district court litigation, C&M Oilfield Rentals, LLC d/b/a C-MOR
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`Energy Services v. Ensign US Southern Drilling LLC, Case No. 4:22-cv-00965
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`(S.D. Tex.). Id.
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`3
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`Ms. Fowler has read and will comply with the Office Patent Trial Practice
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`Case IPR2023-00804
`Patent 10,976,016
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`Guide and the Board’s Rules for Practice for Trials set forth in Part 42 of Title 37
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`of the Code of Federal Regulations. Id. at ¶ 7-8. Ms. Fowler acknowledges and
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`agrees to be subject to the USPTO’s Code of Professional Conduct as set forth in
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`37 C.F.R. §§ 11.101 et seq., and to disciplinary jurisdiction under 37 C.F.R. §
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`11.19(a). Id.
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`In the last three (3) years, Ms. Fowler has not appeared pro hac vice before
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`this administrative body. Id. at ¶ 5. However, Ms. Fowler will also apply to
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`appear pro hac vice in Case No. IPR2024-00005. Id.
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`Because Ms. Fowler is an experienced litigation attorney and has established
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`familiarity with the subject matter at issue in the proceeding, Patent Owner
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`respectfully submits that it has shown good cause for the Board to recognize Ms.
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`Fowler as counsel pro hac vice during this proceeding.
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`III. DECLARATION OF INDIVIDUAL SEEKING TO APPEAR
`This Motion is accompanied by the Declaration of Karon N. Fowler.
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`IV. CONCLUSION
`For the foregoing reasons, Patent Owner respectfully requests the Board
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`admit Karon N. Fowler pro hac vice in this proceeding.
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`4
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`Dated: December 11, 2023
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`Case IPR2023-00804
`Patent 10,976,016
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`Respectfully Submitted,
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` / Dion M. Bregman /
`Dion M. Bregman, Reg. No. 45,645
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`5
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`CERTIFICATE OF SERVICE
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`Case IPR2023-00804
`Patent 10,976,016
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`Pursuant to 37 C.F.R. § 42.6(e)(4), lead counsel for Patent Owner hereby
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`certifies that on December 11, 2023, a copy of this PATENT OWNER’S
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`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF KARON N.
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`FOWLER was served to the email correspondence address of record for
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`Petitioner’s counsel of record:
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`Gregory L. Porter
`gregporter@HuntonAK.com
`Daniel Shanley
`danshanley@HuntonAK.com
`Neil Kelly
`neilkelly@HuntonAK.com
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`Respectfully Submitted,
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` / Dion M. Bregman /
`Dion M. Bregman, Reg. No. 45,645
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`Dated: December 11, 2023
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`6
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