Statement of the Facts In this proceeding, the designated lead counsel, Mr. Lawrence Sung, is a registered practitioner with the Board.

Ms. Summers has been actively practicing as an attorney in the field of intellectual property, including patent litigation, for more than seventeen (17) years.

C. Good Cause Exists for Admission Pro Hac Vice In accordance with 37 C.F.R. § 42.10(c), the Board may recognize counsel pro hac vice during a proceeding upon showing of good cause, subject to the condition that lead counsel be a registered practitioner and to any other condition the Board may impose.

As supported by her Declaration, Ms. Summers is an experienced litigator who has litigated patent infringement cases for various parties in federal district courts throughout the United States, the U.S. Court of Appeals for the Federal Circuit, the Patent Trial and Appeal Board, and the International Trade Commission.

Ms. Summers also has established a familiarity with the subject matter at issue in this proceeding and has participated in strategic discussions with co-counsel.

Pursuant to 37 C.F.R. § 42.10, Patent Owner respectfully requests that the Board authorize withdrawal of Dion M. Bregman, Alexander B. Stein, and Brad A. Wilson of Morgan, Lewis & Bockius LLP (and all other attorneys from Morgan, Lewis & Bockius LLP) as its counsel, and authorize designation of Todd R. Tucker (Reg. No. 40,850) as lead counsel, and Kyle T. Deighan (Reg. No. 75,525) and John Reulbach (will apply pro hac vice) as back-up counsel (“Substitute Counsel”), all of Calfee, Halter & Griswold LLP.

Granting this motion will not delay these proceedings, because Substitute Counsel has indicated that no extension of time will be sought to the preliminary response filing deadline.

Patent Owner respectfully requests that the Board grant this motion.

Updated Mandatory Notices and a new Power of Attorney will promptly be filed after the Board has granted this motion.

Dated: February 3, 2021 Respectfully Submitted, / Dion M. Bregman / Dion M. Bregman, Reg. No. 45,645 Case No. PGR2021-00026

But for the reasons set forth in this Petition, none of the ’391 Patent claims may be accorded priority to an earlier application.

None of these terms provides adequate written description support for a right edge or a left edge as required in the Challenged Claims.

By contrast, none of the purported priority applications to the CIP ’329 Application, specifically, the ’350 Application (now the ’947 Patent, Ex. 1005), the ’374 PCT Application (Ex. 1006), and the ’611 Provisional (Ex. 1007) disclose the ...