UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________
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`
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`MICROBOARDS TECHNOLOGY, LLC d/b/a AFINIA,
`Petitioner,
`
`
`v.
`
`
`STRATASYS INC.,
`Patent Owner.
`
`
`
`Patent No. 8,349,239
`Filing Date: SEPTEMBER 23, 2009
`Issue Date: JANUARY 8, 2013
`Title: SEAM CONCEALMENT FOR THREE-DIMENSIONAL MODELS
`_________________
`
`INTER PARTES REVIEW NO. IPR2015-00288
`_________________
`
`
`
`
`PATENT OWNER’S MOTION FOR PRO HAC VICE ADMISSION
`OF KENNETH A. LIEBMAN
`
`
`
`
`
`
`
`
`
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________
`
`
`
`MICROBOARDS TECHNOLOGY, LLC d/b/a AFINIA,
`Petitioner,
`
`
`v.
`
`
`STRATASYS INC.,
`Patent Owner.
`
`
`
`Patent No. 8,349,239
`Filing Date: SEPTEMBER 23, 2009
`Issue Date: JANUARY 8, 2013
`Title: SEAM CONCEALMENT FOR THREE-DIMENSIONAL MODELS
`_________________
`
`INTER PARTES REVIEW NO. IPR2015-00288
`_________________
`
`
`
`
`PATENT OWNER’S MOTION FOR PRO HAC VICE ADMISSION
`OF KENNETH A. LIEBMAN
`
`
`
`
`
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`
`
`IPR2015-00288
`U.S. Patent No. 8,349,239
`Patent Owner’s Motion for Pro Hac Vice Admission of Kenneth A. Liebman
`
`
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`Statement of Precise Relief Requested
`
`I.
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`Pursuant to 37 C.F.R. § 42.10(c) and Paper No. 5 authorizing the patent
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`owner to file motions for pro hac vice admission under 37 C.F.R. § 42.10(c),
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`Patent Owner Stratasys Inc., requests that the Patent Trial and Appeal Board
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`(the “Board”) admit Kenneth A. Liebman pro hac vice in this proceeding,
`
`IPR2015-00288.
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`This motion is being filed no sooner than twenty one (21) days after
`
`service of the petition.
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`II.
`
`Statement of Facts Showing Good Cause for the Board to Recognize
`Counsel Pro Hac Vice During the Proceeding
`
`In accordance with 37 C.F.R. § 42.10(c), 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
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`other conditions the Board may impose. Section 42.10(c) indicates that “where
`
`the lead counsel is a registered practitioner, a motion to appear pro hac vice by
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`counsel who is not a registered practitioner may be granted upon showing that
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`counsel is an experienced litigating attorney and has an established familiarity
`
`with the subject matter at issue in the proceeding.” The facts here establish
`
`good cause for the Board to recognize Kenneth A. Liebman pro hac vice in this
`
`proceeding.
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`
`
`1
`
`
`
`IPR2015-00288
`U.S. Patent No. 8,349,239
`Patent Owner’s Motion for Pro Hac Vice Admission of Kenneth A. Liebman
`
`
`1.
`
`Lead counsel, Walter C. Linder, is a registered practitioner.
`
`2.
`
`Counsel, Kenneth A. Liebman, is an experienced litigator and has
`
`an established familiarity with the subject matter at issue in the proceeding.
`
`Accompanying this motion as Exhibit 2002 is the Declaration of Kenneth A.
`
`Liebman in Support of Motion for Pro Hac Vice Admission (“Liebman Decl.”).
`
`In his declaration, Mr. Liebman asserts:
`
`
`
`“I am a member in good standing of the Bars of
`Minnesota and California as well as the following Federal
`Courts:
`(a) U. S. District Court for Central District of California
`(01/15/1980);
`(b) U.S. Court of Appeals for the Eleventh Circuit (09/19/1991);
`(c) U.S. District Court for Northern District of California
`(08/13/1992);
`(d) U.S. Court of Appeals for the Federal Circuit (09/03/1993); and
`(e) U.S. District Court for District of Minnesota (11/05/1993).”
`(Liebman Decl., ¶ 2).
`
`Mr. Liebman also asserts:
`
`“I have been in private practice for over 33 years, and litigating patent cases
`for over 20 years. Several of these patent litigations involve USPTO post-
`grant procedures. Other proceedings before the Office for which I have
`applied to appear pro hac vice (and authorized to appear) in the last three
`years are Inter Partes Review Nos.: IPR2014-00191, IPR 2014-00311 and
`
`
`
`2
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`
`
`IPR2015-00288
`U.S. Patent No. 8,349,239
`Patent Owner’s Motion for Pro Hac Vice Admission of Kenneth A. Liebman
`
`
`IPR 2014-00321. Concurrently with this declaration, I am submitting
`declarations in connection with motions to appear pro hac vice in Inter
`Partes Review Nos.: IPR2015-00284 and IPR 2015-00287 that also relate
`to patents at issue in the litigation referred to in paragraph 10 below.
`I am familiar with the subject matter at issue in this proceeding. I am trial
`counsel for the Patent Owner in the matter Stratasys Inc. v. Microboards
`Technology, LLC, No.0:13-cv-03228-DWF-JJG (filed on November 25,
`2013), which is related to and involves the same patent at issue in this
`proceeding.” (Liebman Decl., ¶¶ 9-10).
`
`3.
`
`In his declaration, Mr. Liebman also attests to each of the listed items
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`required by the “Order – Authorizing Motion for Pro Hac Vice Admission” in
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`Case IPR2013-00639, Paper 7. (See Liebman Decl., ¶¶ 1-11).
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`III. Conclusion
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`For the foregoing reasons, Patent Owner respectfully requests that the
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`Board admit Kenneth A. Liebman pro hac vice in this proceeding.
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`Respectfully submitted,
`
`Dated: March 19, 2015
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`3
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`
` /Walter Linder/
`Walter C. Linder
`Reg. No. 31,707
`FAEGRE BAKER DANIELS LLP
`2200 Wells Fargo Center
`90 South 7th Street
`Minneapolis, MN 55402-3901
`Tel.: (612) 766- 7000
`Fax.: (612) 766-1600
`Lead Counsel for Petitioner
`
`
`
`IPR2015-00288
`U.S. Patent No. 8,349,239
`Patent Owner’s Motion for Pro Hac Vice Admission of Kenneth A. Liebman
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6, I hereby certify that I caused a true and correct copy of the
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`Patent Owner’s Motion for Pro Hac Vice Admission of Kenneth A. Liebman, and associated
`Exhibit 2002, to be served via electronic mail on the following:
`
`William J. Cass
`Cantor Colburn LLP
`20 Church Street, 22nd Floor
`Hartford, Connecticut 06103
`wcass@cantorcolburn.com
`
`Herbert M. Bedingfield
`Cantor Colburn LLP
`20 Church Street, 22nd Floor
`Hartford, Connecticut 06103
`hbedingfield@cantorcolburn.com
`
`Brad D. Pedersen
`Patterson Thuente Pedersen, P.A.
`80 South 8th Street, Suite 4800
`Minneapolis, MN 55402
`prps@ptslaw.com
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`FAEGRE BAKER DANIELS LLP
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`By:
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`/ Walter Linder /
`Walter C. Linder
`Reg. No. 31,707
`Customer No. 25764
`Telephone: (612) 766-8801
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`Dated: March 19, 2015
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`Faegre Baker Daniels LLP
`2200 Wells Fargo Center
`90 South Seventh Street
`Minneapolis, MN 55402-3901
`Telephone: (612) 766-7000
`Facsimile: (612) 766-1600
`
`
`
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`4
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