UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`LG ELECTRONICS, INC., and
`LG ELECTRONICS U.S.A., INC.,
`Petitioner
`
`v.
`
`TOSHIBA SAMSUNG STORAGE TECHNOLOGY KOREA CORPORATION,
`Patent Owner
`_______________
`
`Case IPR2015-01644
`Patent 6,785,065 B1
`_______________
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` Date filed: April 14, 2016
`
`Filed on behalf of: LG Electronics, Inc. and Paper ____
`
`
`
` LG Electronics U.S.A., Inc.
`
`
`
`
`By: Brian A. Tollefson, Lead Counsel
`Michael V. Battaglia, Back-up Counsel
`ROTHWELL, FIGG, ERNST & MANBECK, P.C.
`607 14th Street, N.W., Suite 800
`Washington, DC 20005
`Phone: 202-783-6040
`Facsimile: 202-783-6031
`Emails: btollefson@rothwellfigg.com
`
` mbattaglia@rothwellfigg.com
`
`
`
`
`
`PETITIONER’S MOTION FOR ADMISSION
`PRO HAC VICE OF MICHAEL H. JONES
`
`
`
`
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`LG ELECTRONICS, INC., and
`LG ELECTRONICS U.S.A., INC.,
`Petitioner
`
`v.
`
`TOSHIBA SAMSUNG STORAGE TECHNOLOGY KOREA CORPORATION,
`Patent Owner
`_______________
`
`Case IPR2015-01644
`Patent 6,785,065 B1
`_______________
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` Date filed: April 14, 2016
`
`Filed on behalf of: LG Electronics, Inc. and Paper ____
`
`
`
` LG Electronics U.S.A., Inc.
`
`
`
`
`By: Brian A. Tollefson, Lead Counsel
`Michael V. Battaglia, Back-up Counsel
`ROTHWELL, FIGG, ERNST & MANBECK, P.C.
`607 14th Street, N.W., Suite 800
`Washington, DC 20005
`Phone: 202-783-6040
`Facsimile: 202-783-6031
`Emails: btollefson@rothwellfigg.com
`
` mbattaglia@rothwellfigg.com
`
`
`
`
`
`PETITIONER’S MOTION FOR ADMISSION
`PRO HAC VICE OF MICHAEL H. JONES
`
`
`
`
`
`Case IPR2015-01644
`Patent 6,785,065 B1
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`I.
`
`Relief Requested
`
`
`
`Pursuant to 37 C.F.R. § 42.10, Petitioners LG Electronics, Inc. and LG
`
`Electronics U.S.A., Inc. (collectively “LGE” or “Petitioners”) requests that the
`
`Board admit Michael H. Jones pro hac vice in this proceeding to serve as back-up
`
`counsel.
`
`II.
`
`
`
`Statement of Facts Showing There is 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 other conditions
`
`as the Board may impose. § 42.10(c) indicates that, “where lead counsel is a
`
`registered practitioner, a motion to appear pro hac vice may be granted upon a
`
`showing that 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 Michael H. Jones pro hac vice
`
`during this proceeding, so that he may participate in, inter alia, oral hearings,
`
`depositions, and conferences with the Board.
`
`1.
`
`Lead counsel, Brian A. Tollefson, is a registered practitioner.
`
`
`
`2
`
`
`
`Case IPR2015-01644
`Patent 6,785,065 B1
`Counsel, Michael H. Jones, is an experienced litigating attorney and
`
`2.
`
`has an established familiarity with the subject matter at issue in the proceeding.
`
`Accompanying this motion is the Declaration of Michael H. Jones in Support of
`
`Patent Owner’s Motion for Admission Pro Hac Vice (“Jones Decl.”). Mr. Jones is
`
`a member in good standing of the Bars of the District of Columbia and the State of
`
`Virginia. Jones Decl., ¶ 2. Mr. Jones is also admitted to practice in the Courts of
`
`Appeals for the Federal Circuit. Id. Mr. Jones has been litigating patent cases
`
`since 2010. Id. at ¶ 3. Prior to that, Mr. Jones served for two summers as a law
`
`clerk working on various patent matters under the supervision of attorneys. Id.
`
`3. Mr. Jones is familiar with the subject matter at issue in this
`
`proceeding by virtue of his representing the Petitioners in two lawsuits. The first
`
`case was brought by Petitioners against the Patent Owner, LG Electronics, Inc. and
`
`LG Electronics U.S.A., Inc. v. Toshiba Samsung Storage Technology Korea
`
`Corporation, Case No. 1:12-cv-01063-LPS-CJB (D. Del.), and involves the patent
`
`at issue in this proceeding. The second case was brought by the Patent Owner
`
`against the Petitioners, Toshiba Samsung Storage Technology Korea Corporation
`
`v. LG Electronics, Inc., LG Electronics U.S.A., Inc. and LG International
`
`(America), Inc., Case No. 1:15-cv-00691-LPS-CJB (D. Del.), and involves the
`
`patent at issue in this proceeding. Jones Decl., ¶ 10.
`
`
`
`3
`
`
`
`Case IPR2015-01644
`Patent 6,785,065 B1
` 4. Mr. Jones attests to each of the listed items required by the “Order --
`
`Authorizing Motion for Pro Hac Vice Admission in Case IPR2013-00639”
`
`referenced in the Notice of Filing Date Accorded to Petition and Time for Filing
`
`Patent Owner Preliminary Response, mailed August 19, 2015 (Paper 3). See Jones
`
`Decl., ¶¶ 1-10.
`
`5. Mr. Jones has read and will comply with the Office Patent Trial
`
`Practice Guide and the Board’s Rules of Practice for Trials, as set forth in Part 42
`
`of 37 C.F.R. Jones Decl., ¶ 7. Mr. Jones agrees to be subject to the USPTO Rules
`
`of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary
`
`jurisdiction under 37 C.F.R. § 11.19(a) and to be subject to the USPTO Rules of
`
`Professional Conduct as set forth in Changes to Representation of Others Before
`
`the United States Patent and Trademark Office; Final Rule, 78 Fed. Reg. 20180
`
`(Apr. 3, 2013) (effective May 3, 2013). Jones Decl., ¶ 8.
`
`III. Conclusion
`
`The requirements for admission pro hac vice being hereby established,
`
`Petitioners LG Electronics, Inc. and LG Electronics U.S.A., Inc., respectfully
`
`requests that the Board admit Michael H. Jones pro hac vice in this proceeding.
`
`4
`
`
`
`
`
`
`
`Case IPR2015-01644
`Patent 6,785,065 B1
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
` / Brian A. Tollefson /
`By:
`
`Date: April 14, 2016
`Brian A. Tollefson, Reg. No. 46,338
`
`
`
`
`
`Michael V. Battaglia, Reg. No. 64,932
`
`
`
`
`
`ROTHWELL, FIGG, ERNST &
`
`
`
`
`
` MANBECK, P.C.
`607 14th Street, N.W., Suite 800
`Washington, DC 20005
`Phone: 202-783-6040
`Facsimile: 202-783-6031
`
`Counsel for Petitioners
`LG Electronics, Inc. and
`LG Electronics U.S.A., Inc.
`
`
`
`5
`
`
`
`
`
`
`
`
`
`Case IPR2015-01644
`Patent 6,785,065 B1
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 14th day of April, 2016, a true and correct copy
`
`of the foregoing PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE
`
`OF MICHAEL H. JONES was served, via electronic mail upon the following
`
`counsel for Patent Owner Toshiba Samsung Storage Technology Korea
`
`Corporation:
`
`Joseph A. Rhoa, Esq.
`Jonathan A. Roberts, Esq.
`Nixon & Vanderhye P.C.
`901 North Glebe Road, 11th Floor
`Arlington, VA 22203-1808
`Phone: 703-816-4000
`Facsimile: 703-816-4100
`Emails: jar@nixonvan.com
`jr@nixonvan.com
`
`
`
`6
`
`
`
`
`
`/ Erik van Leeuwen /
`Erik van Leeuwen
`Litigation Operations Coordinator
`Rothwell, Figg, Ernst & Manbeck, P.C.
`
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
