UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`GARMIN INTERNATIONAL, INC. ET AL.
`Petitioner
`
`v.
`
`Patent of CUOZZO SPEED TECHNOLOGIES LLC
`Patent Owner
`____________
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`
`
`IPR2012-00001
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`6,778,074
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`March 18, 2002
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`August 17, 2004
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`Giuseppe A. Cuozzo
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`Speed Limit Indicator and Method for Displaying Speed and the Relevant
`Speed Limit
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`Case:
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`Patent No.:
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`Filed:
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`Issued:
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`Inventors:
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`Title:
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`Docket No.:
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`CUO0001-RE
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`____________
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`PATENT OWNER’S MOTION FOR ADMISSION PRO HAC VICE OF DAVID A.
`SKEELS UNDER 37 C.F.R. §42.10
`
`
`
`Mail Stop "PATENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`

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`Case No.: IPR2012-00001
`Patent No: 6,778,074
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`Attorney’s Docket No.: CUO0001-RE
`Page 2
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`Patent Owner Cuozzo Speed Technologies LLC respectfully submits the following:
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`I.
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`RELIEF REQUESTED
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`Pursuant to 37 C.F.R. §42.10, Patent Owner Cuozzo Speed Technologies LLC requests
`that the Board admit David A. Skeels pro hac vice in this proceeding.
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`II.
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`STATEMENT OF FACTS
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`37 C.F.R. §42.10(c) states that the Board “may recognize counsel pro hac vice during a
`proceeding upon a showing of good cause, subject to the condition that lead counsel be a
`registered practitioner and to any other conditions as the Board may impose. For example,
`where the lead counsel is a registered practitioner, a motion to appear pro hac vice by counsel
`who is not a registered practitioner may be granted upon showing that counsel is an experienced
`litigating attorney and has an established familiarity with the subject matter at issue in the
`proceeding.” The facts, supported by the attached Declaration of David A. Skeels in Support of
`Motion for Admission Pro Hac Vice (“Skeels Declaration”), establish good cause to admit Mr.
`Skeels pro hac vice in this proceeding.
`
`1.
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`2.
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`Lead counsel, John R. Kasha, is a registered practitioner.
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`Backup counsel, Cabrach J. Connor, is a registered practitioner.
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`3.
`Counsel, David A. Skeels, is an experienced litigating attorney in his tenth year of
`law practice. Skeels Declaration at ¶ 1. Mr. Skeels has been litigating patent cases during the
`entirety of his law practice, and he has served as trial counsel in more than two dozen patent
`infringement lawsuits. Id. at ¶ 2. Mr. Skeels is a member in good standing of the State Bar of
`Texas, with no suspensions or disbarments from practice, nor any application for admission to
`practice denied, nor any sanctions or contempt citations, and is admitted to practice in the United
`States District Court for the Northern, Southern, and Eastern Districts of Texas, the United States
`Court of Appeals for the Fifth Circuit, and the United States Court of Appeals for the Federal
`Circuit. ¶¶ 3-6.
`
`

`

`Case No.: IPR2012-00001
`Patent No: 6,778,074
`
`
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`Attorney’s Docket No.: CUO0001-RE
`Page 3
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`1.
`Mr. Skeels has familiarity with the subject matter at issue in this proceeding and,
`more specifically, he is familiar with the patent at issue in this proceeding. Mr. Skeels represents
`Patent Owner in other pending cases that involve the same patent at issue in this proceeding:
`U.S. Patent No. 6,778,074: Cuozzo Speed Technologies LLC v. Garmin Int’l, Inc. et al., Civil
`Action No. 2:12-cv-03623-CCC-JAD; U.S.D.C. for the District of New Jersey; Cuozzo Speed
`Technologies LLC v. General Motors Company, Civil Action No. 2:12-cv-03624-CCC-JAD;
`U.S.D.C. for the District of New Jersey; Cuozzo Speed Technologies LLC v. JVC Americas
`Corporation, Civil Action No. 2:12-cv-03625-CCC-JAD; U.S.D.C. for the District of New
`Jersey; Cuozzo Speed Technologies LLC v. TomTom, Inc. and Mazda Motors of America, Inc.,
`Civil Action No. 2:12-cv-03626-CCC-JAD; U.S.D.C. for the District of New Jersey
`(collectively, the “Cuozzo Matters”). Id. at ¶ 7. During his involvement in the Cuozzo Matters,
`which began in approximately September or October 2012, Mr. Skeels has been actively
`involved in every phase of litigation, including, for example, Plaintiff’s disclosures under the
`local patent rules and review of Defendants’ invalidity contentions. Id. at ¶ 8.
`
`4.
`Mr. Skeels has read and will comply with the Office Patent Trial Guide and the
`Board’s Rules for Practices for Trials set forth in part 42 of the C.F.R. and he agrees to be
`subject to the USPTO Code of Professional Responsibility set forth in 37 C.F.R. §§10.20 et seq.
`and disciplinary jurisdiction under 37 C.F.R. §11.19(a). Id. at ¶¶ 9-10. Mr. Skeels has not
`previously applied to appear pro hac vice in any other proceedings before the Office. Id. at ¶ 11.
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`III. ANALYSIS
`
`The facts contained in the Statement of Facts above, and contained in the Skeels
`Declaration, establish that there is good cause to admit Mr. Skeels pro hac vice in this
`proceeding, under 37 C.F.R. §42.10. Lead and backup counsel are registered practitioners, Mr.
`Skeels is an experienced litigating attorney, and Mr. Skeels has an established familiarity with
`the subject matter at issue in this proceeding.
`
`

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`Case No.: IPR2012-00001
`Patent No: 6,778,074
`
`
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`IV. CONCLUSION
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`
`
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`Attorney’s Docket No.: CUO0001-RE
`Page 4
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`For the foregoing reasons, Patent Owner Cuozzo Speed Technologies LLC respectfully
`requests that the Board admit David A. Skeels pro hac vice in this proceeding.
`
`
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`Respectfully submitted,
`
`December 14, 2012
`Date
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`/John R. Kasha/
`Registration No. 53,100
`Attorney for Cuozzo Speed Technologies LLC
`
`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(703) 867-1886, telephone
`(301) 340-3022, facsimile
`Email: john.kasha@kashalaw.com
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