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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.
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`Case No. IPR2023-00804
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`Patent 10,976,016
`_____________________________________________________________
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`PATENT OWNER’S
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF
`GENNADIY T. LOZNEV PURSUANT TO 37 C.F.R. § 42.10(c)
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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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`d/b/a C-MOR Energy Services (“Patent Owner”) hereby submits this motion for
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`Gennadiy T. Loznev to appear pro hac vice in this proceeding. Patent Owner
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`respectfully requests the Board to recognize Mr. Loznev 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 Mr. Loznev 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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`Mr. Loznev joined Morgan, Lewis & Bockius LLP as an intellectual
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`property litigation attorney in October 2022. Ex. 2005 ¶ 9. While at Morgan,
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`Lewis & Bockius LLP, Mr. Loznev primarily focused his practice on patent
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`litigation. Id. Mr. Loznev has experience conducting technical infringement and
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`2
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`validity analyses, working with technical experts to prepare reports on
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`Case IPR2023-00804
`Patent 10,976,016
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`infringement and validity issues, briefing and preparing for hearing on claim
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`construction issues, and preparing for and assisting in patent litigation trials across
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`the country before district courts and the United States International Trade
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`Commission. Id.
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`Ms. Loznev is a member in good standing of the Bar of the State of
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`California. Id. at ¶ 2. He is admitted to practice before the Northern and the
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`Central Districts of California. Id.
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`Mr. Loznev has not been suspended or disbarred from practice before any
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`court or administrative body. He has never had any application for admission to
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`practice denied, and he has never had any sanctions or contempt citations imposed
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`against him. Id. at ¶ 3-6.
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`Mr. Loznev has obtained substantial familiarity with the subject matter at
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`issue in this proceeding. Id. at ¶ 10. He has reviewed in detail and is familiar with
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`U.S. Patent No. 10,976,016, the Petition, and all exhibits relied upon by Petitioner
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`in this proceeding. Id.
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`Mr. Loznev has read and will comply with the Office Patent Trial Practice
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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. Mr. Loznev 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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`3
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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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`Case IPR2023-00804
`Patent 10,976,016
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`11.19(a). Id.
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`In the last three (3) years, Mr. Loznev has not appeared pro hac vice before
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`this administrative body. Id. at ¶ 5. However, Mr. Loznev will also apply to
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`appear pro hac vice in Case No. IPR2024-00005. Id.
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`Because Mr. Loznev 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 Mr.
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`Loznev 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 Gennadiy T. Loznev.
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`IV. CONCLUSION
`For the foregoing reasons, Patent Owner respectfully requests the Board
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`admit Gennadiy T. Loznev pro hac vice in this proceeding.
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`Dated: December 11, 2023
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`Respectfully Submitted,
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` / Dion M. Bregman /
`Dion M. Bregman, Reg. No. 45,645
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`4
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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 MOTION
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`FOR PRO HAC VICE ADMISSION OF GENNADIY T. LOZNEV was served to
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`the email correspondence address of record for 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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`5
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