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`PI- NET 2014PI- NET 2014
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`PI- NET 2014
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`Filed on behalf of Pi-Net International, Inc.
`By: Bryan Boyle
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`Gerald P. Dodson
`CARR & FERRELL LLP
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`120 Constitution Drive
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`Menlo Park, CA 94025
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`Tel: (650) 812-3400
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`Fax: (650) 812-3444
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`Covered Business Method Review of U.S. Patent No. 8,037,158
`_____________________
`SAP America, Inc.
`Petitioner
`v.
`Pi-Net International, Inc.
`Patent Owner
`_____________________
`CASE CBM 2014-00018
`Patent 8,037,158
`_____________________
`
`Declaration of Colby B. Springer in Support of
`Motion for Pro Hac Vice Admission
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`1
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`Declaration of Colby B. Springer in Support of
`Motion for Pro Hac Vice Admission
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`I, COLBY B. SPRINGER, hereby declare as follows:
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`1.
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`I am an attorney licensed to practice law by the State Bar of California
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`(California Bar Number 214868).
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`2.
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`I am admitted to practice law before the Supreme Court of the United
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`States of America; the United States Court of Appeals for the Ninth
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`Circuit; the United States Court of Appeals for the Federal Circuit; the
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`United States District Courts for the Northern, Central, Southern, and
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`Eastern District of California; the United States District Court for the
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`District of Colorado; the United States District Court for the Eastern
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`District of Texas; and the United States International Trade
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`Commission.
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`3.
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`I have been admitted pro hac vice one or more times before the
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`United States District Court for Arizona; the United States District
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`Court for New Mexico; the United States District Court for Nevada;
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`the United States District Court for the Middle District of Florida; the
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`United States District Court for the Western District of Washington;
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`and the United States District Court for Delaware.
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`2
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`4.
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`I am not admitted to practice before the United States Patent and
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`Trademark Office.
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`5.
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`I graduated cum laude from the University of Notre Dame in Notre
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`Dame, Indiana, in 1998 and the Santa Clara University School of Law
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`in Santa Clara, California, in 2001 with a specialty certificate in high
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`technology law (i.e., intellectual property).
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`6.
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`I took and passed the California bar exam on my first attempt and
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`began practicing law in August 2001.
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`7.
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`I served as an adjunct faculty member at the Santa Clara University
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`School of Law in Santa Clara, California, following my graduation in
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`2001 until approximately 2006. During my time as an adjunct faculty
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`member at the Santa Clara University School of Law, I taught classes
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`in appellate advocacy and appellate brief writing (specifically with
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`respect to intellectual property and patent law), the protection of
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`intellectual property (including patent law), and international
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`intellectual property. As an adjunct faculty member, I taught both
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`candidates for a Juris Doctor (JD) degree as well as candidates
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`seeking a master of laws (LLM) in intellectual property.
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`8.
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`I have been and continue to be invited to present as a guest lecturer at
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`continuing legal education events like those sponsored by the
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`3
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`Practicing Law Institute (PLI) as well as at panels and programs
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`hosted by the likes of the Santa Clara University School of Law, the
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`University of Nevada Las Vegas, and the University of Arizona. I
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`often speak on matters related to patents and patent litigation,
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`including inter partes review.
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`9.
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`I have published numerous articles on various aspects of intellectual
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`property and litigation. I was a contributing author to the Matthew
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`Bender Practice Guide for California Unfair Competition and
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`Business Torts.
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`10.
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`I am an equity partner in the law firm of Lewis Roca Rothgerber LLP,
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`which is counsel of record in the present inter partes review
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`proceeding.
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`11. Lewis Roca Rothgerber LLP maintains nine offices in six states
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`through the western United States: Albuquerque, New Mexico;
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`Casper, Wyoming; Colorado Springs, Colorado; Denver, Colorado;
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`Las Vegas, Nevada; Phoenix, Arizona; Reno, Nevada; Mountain
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`View, California; and Tucson, Arizona.
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`12.
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`I am the equity partner in charge of the Mountain View (Silicon
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`Valley) office, which focuses exclusively on intellectual property and
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`intellectual property litigation.
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`13.
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`In addition to being the equity partner in charge of the Mountain View
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`(Silicon Valley) office for Lewis Roca Rothgerber LLP, I am
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`generally involved in any and all patent litigation matters for which
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`Lewis Roca Rothgerber LLP is counsel of record before any United
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`States District Court, United States Court of Appeal, or other
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`administrative tribunal regardless of which office of Lewis Roca
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`Rothgerber LLP any such litigation originated.
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`14. My personal practice consists of intellectual property counseling and
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`intellectual property litigation, the latter of which is almost entirely
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`patent litigation.
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`15. My bar membership is current and I am in good standing before any
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`and all courts in which I am admitted to practice (either by actual
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`admission or pro hac vice admission) with no known complaints of
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`misconduct, sanction, or other disciplinary proceeding pending,
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`closed, or otherwise having ever been in existence.
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`16.
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`I have never been subject to a suspension, disbarment, or any
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`proceeding concerning suspension or disbarment before any court or
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`administrative body.
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`17.
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`I have never had an application for admission to practice before any
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`court or administrative body denied.
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`5
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`18.
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`I have never had an application for admission to practice pro hac vice
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`before any court or administrative body denied.
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`19.
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`I have never been sanctioned or cited for contempt by any court or
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`administrative body.
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`20.
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`I have read and reviewed Paper No. 7 in IPR2013-00639 as that paper
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`concerns pro hac vice admissions in inter partes review proceedings
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`and agree to be abound by any and all requirements set forth therein
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`and as further and explicitly detailed below.
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`21.
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`I have read all papers of record in the present inter partes review
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`proceeding.
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`22.
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`I have read the Patent Trial Practice Guide from the United States
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`Patent and Trademark Office.
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`23.
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`I will comply with the Patent Trial Practice Guide from the United
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`States Patent and Trademark Office.
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`24.
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`I have read the Patent Trial and Appeal Board Rules of Practice set
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`forth at part 42 of title 37 of the Code of Federal Regulations,
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`including but not limited to 37 C.F.R. § 42.10(c).
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`25.
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`I will comply with the Patent Trial and Appeal Board Rules of
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`Practice set forth at part 42 of title 37 of the Code of Federal
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`Regulations.
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`6
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`26.
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`I am specifically familiar with the quasi-litigation nature of an inter
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`partes review proceeding—including but not limited to limited
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`document discovery, protective orders, motion practice, direction
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`examination via declaration, cross-examination via deposition, oral
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`argument, and the Federal Rules of Evidence.
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`27.
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`I hereby submit to the disciplinary jurisdiction of the United States
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`Patent and Trademark Office in accordance with 37 C.F.R. § 11.19(a).
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`28.
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`I have read the United States Patent and Trademark Office’s Rules of
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`Professional Conduct as set forth at 37 C.F.R. § 1.101 et seq.
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`29.
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`I hereby agree to be governed by the United States Patent and
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`Trademark Office’s Rules of Professional Conduct as set forth at 37
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`C.F.R. § 1.101 et seq.
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`30.
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`I have previously been admitted by the United States Patent and
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`Trademark Office to practice pro hac vice before the Board of Patent
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`Appeals and Interferences in Interference No. 105,660 (Novotny v.
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`Tsuboi).
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`31.
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`I have applied to appear before the United States Patent and
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`Trademark Office to practice pro hac vice in the matters of IPR 2014-
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`00413 and IPR 2014-00414 on March 10, 2014 and IPR 2013-00194
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`and IPR-2013-00195 and CBM 2013-00013 on March 11, 2014.
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`7
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`32.
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`I do not presently intend to apply to appear before the United States
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`Patent and Trademark Office to practice pro hac vice in any further
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`matters.
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`33.
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`I am familiar with the subject matter at issue in the present proceeding
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`having worked with Ms. Arunachalam—the named inventor for the
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`patent at issue—in various facets since late 2008 or early 2009.
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`34.
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`I respectfully request recognition to practice before the Patent Trial
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`and Appeal Board in this matter pro hac vice.
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`35.
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`I agree to, recognize, submit to, and further insist that lead counsel be
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`a registered practitioner for this matter and will not undertake any
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`action before the Patent Trial and Appeal Board without the counsel
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`of that registered practitioner;
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`36.
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`I will agree to, recognize, and submit to any other conditions that the
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`Patent Trial and Appeal Board may impose as a part of my request to
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`practice before the Patent Trial and Appeal Board in this matter pro
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`hac vice.
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`37.
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`I believe that in light of the foregoing, I constitute an experienced
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`litigation attorney as required by 37 C.F.R. § 42.10(c).
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`8
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`In accorrdance with 38 U.S.CC. § 1746, I declare uunder penaalty of perjuury under tthe
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`laws of the Unitedd States of America that the forregoing staatements arre true and
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`correct.
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` I understaand that willful false statementts and the llike are punnishable byy
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`fine or iimprisonmment, or botth (18 U.S..C. § 1001)) and may
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`jeopardizee the validiity
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`of the patent at isssue herein. All statemments madde of my owwn knowleedge are truue
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`and all sstatementss made on iinformation and belieef are belieeved to be
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`true.
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`Resspectfully ssubmitted,
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`24440 W. El CCamino Reaal, Sixth Flloor
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`___________________________________
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`Collby B. Spriinger
`RBER LLP
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`LEWWIS ROCA
`ROTHGER
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`Mo
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`untain Vieew, CA 940040
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`6500.391.13944
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`csprringer@lrrrlaw.com
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`March 111, 2014
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`9
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