`_____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
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`ASML NETHERLANDS B.V., EXCELITAS TECHNOLOGIES CORP., AND
`QIOPTIQ PHOTONICS GMBH & CO. KG,
`Petitioner,
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`v.
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`ENERGETIQ TECHNOLOGY, INC.,
`Patent Owner.
`_____________
`
`Case IPR2015-01279
`Patent 7,786,455
`_____________
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`
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`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`Post Office Box 1450
`Alexandria, Virginia 22313-1450
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`ENERGETIQ TECHNOLOGY, INC.’S MOTION FOR
`PRO HAC VICE ADMISSION OF JINNIE L. REED
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`I.
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`Statement of Precise Relief Requested
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`Pursuant to 37 C.F.R. § 42.10, Patent Owner Energetiq Technology, Inc.
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`(“Energetiq”) requests that the Board admit Jinnie L. Reed pro hac vice in this
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`proceeding.
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`II. Good Cause Exists for the Board to Recognize Counsel Pro Hac Vice
`During the Proceeding
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`In accordance with 37 C.F.R. § 42.10(c), the Board may recognize counsel
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`pro hac vice during a proceeding upon a showing of good cause, subject to the
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`condition that lead counsel be a registered practitioner and to any other conditions
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`as the Board may impose. More specifically, 37 C.F.R. § 42.10(c) indicates that
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`“where the lead counsel is a registered practitioner, a motion to appear pro hac vice
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`by 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
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`the subject matter at issue in the proceeding.” The facts here establish good cause
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`for the Board to recognize Jinnie L. Reed pro hac vice during this proceeding.
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`Lead Counsel, Steven M. Bauer, is a registered practitioner, having USPTO
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`Registration No. 31,481.
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`Counsel, Jinnie L. Reed, is an experienced patent litigator and has an
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`established familiarity with the subject matter at issue in the proceeding.
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`Accompanying this motion is the Declaration of Jinnie L. Reed in Support of
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`Motion for Admission Pro Hac Vice (Ex. 2002). Ms. Reed is a litigating attorney
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`2
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`with over 5 years of patent litigation experience. Ex. 2002 at ¶¶ 9-10. She is a
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`member in good standing with the Bar of the Commonwealth of Massachusetts.
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`Id. at ¶ 2. She has never been suspended, disbarred, sanctioned, denied admission
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`to practice, or cited for contempt by any court or administrative body. Id. at ¶ 3-5.
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`Ms. Reed is familiar with the subject matter at issue, and her technical experience
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`will aid Energetiq in this proceeding. Id. at ¶ 11. She also satisfies the remaining
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`conditions for admissibility identified by the Board. See Id. at ¶¶ 6-8.
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`III. Conclusion
`For the foregoing reasons, Energetiq respectfully requests that the Board
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`admit Jinnie L. Reed pro hac vice in this proceeding.
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`Respectfully submitted,
`Proskauer Rose LLP
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`
`
`/ Steven M. Bauer /
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`Steven M. Bauer, Reg. No. 31,481
`Attorney for Patent Owner
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`Date: January 13, 2016
`PROSKAUER ROSE LLP
`One International Place
`Boston, Massachusetts 02110
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`EXHIBIT LIST
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`Exhibit
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`Reference
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`2001
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`Declaration of Safraz W. Ishmael in Support of Motion for
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`Admission Pro Hac Vice
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`2002
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`Declaration of Jinnie L. Reed in Support of Motion for
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`Admission Pro Hac Vice
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`1
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`CERTIFICATE OF SERVICE
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`I hereby certify that on this 13th day of January, 2016 copies of this Motion
`for Pro Hac Vice Admission of Jinnie L. Reed, the Declaration of Jinnie L. Reed in
`Support of Motion for Admission Pro Hac Vice, and Exhibit list are being served
`pursuant to 37 C.F.R. § 42.6 electronically (by consent of the parties) on the
`following email addresses for Petitioner:
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`Don.Steinberg@wilmerhale.com
`David.Cavanaugh@wilmerhale.com
`MichaelH.Smith@wilmerhale.com
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`Respectfully submitted,
`Proskauer Rose LLP
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`/ Gerald E. Worth /
`Gerald E. Worth, Reg. No. 45, 238
`Attorney for Patent Owner
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`Date: January 13, 2016
`PROSKAUER ROSE LLP
`One International Place
`Boston, Massachusetts 02110
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