`By: Peter J. McAndrews
`McAndrews, Held & Malloy, Ltd.
`500 W. Madison St., 34th Floor
`Chicago, IL 60661
`Tel: 312-775-8000
`Fax: 312-775-8100
`E-mail:
`pmcandrews@mcandrews-ip.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`DISH NETWORK L.L.C.
`Petitioner
`
`v.
`
`TQ DELTA LLC
`Patent Owner
`_____________
`
`Case IPR2016-01470
`Patent No. 8,611,404
`_____________
`
`PATENT OWNER’S MOTION FOR PRO HAC VICE ADMISSION
`UNDER 37 C.F.R. § 41.10(c)
`
`1
`
`
`
`
`
`
`
`
`
`Patent Owner, TQ Delta LLC, respectfully requests that the Board recognize
`
`Rajendra A. Chiplunkar, Esq., as counsel pro hac vice during this proceeding.
`
`I. BACKGROUND
`
`Patent Owner’s Motion for Pro Hac Vice Admission is being filed in
`
`compliance with and pursuant to the “Order—Authorizing Motion for Pro Hac
`
`Vice Admission” in Case No. IPR2013-00639 (MPT) [“the Order”].
`
`II. STATEMENT OF FACTS
`
`As required by the Order, the following statement of facts shows that there is
`
`good cause for the Board to recognize Mr. Chiplunkar pro hac vice.
`
`Mr. Chiplunkar is an experienced litigation attorney and has been involved
`
`in numerous complex litigations in federal courts. Mr. Chiplunkar’s biography is
`
`attached hereto as Exhibit 2001 to this Motion.
`
`Mr. Chiplunkar has reviewed U.S. Patent No. 8,611,404, and the papers
`
`already filed in this proceeding. Further, Mr. Chiplunkar is familiar with the
`
`pending litigation between the parties pending before the United States District
`
`Court, District of Delaware, entitled TQ Delta LLC v. DISH Network Corporation,
`
`et al., Case No. 1-15-cv-00614; and, as such, is familiar with the subject matter at
`
`issue in this proceeding.
`
`Petitioner does not oppose this motion for admission pro hac vice of Mr.
`
`Chiplunkar.
`
`
`
`2
`
`
`
`Therefore, Patent Owner respectfully submits that there is good cause for the
`
`Board to recognize Mr. Chiplunkar as counsel pro hac vice during this proceeding.
`
`III. DECLARATION OF INDIVIDUAL SEEKING TO APPEAR
`
`Patent Owner’s Motion for Pro Hac Vice Admission is accompanied by a
`
`Declaration of Rajendra A. Chiplunkar attached hereto as Exhibit 2002 as required
`
`by the Order.
`
`Dated: April 10, 2017
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`/Peter J. McAndrews/
`Peter J. McAndrews
`Registration No. 38,547
`McANDREWS, HELD & MALLOY, LTD.
`500 West Madison Street, 34th Floor
`Chicago, Illinois 60661
`Office: (312) 775-8000
`Fax: (312) 775-8100
`pmcandrews@mcandrews-ip.com
`
`Lead Counsel for Patent Owner
`
`
`
`3
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify, pursuant to 37 C.F.R. Section 42.6, that a complete copy of
`
`the attached PATENT OWNER’S MOTION FOR PRO HAC VICE
`
`ADMISSION (Rajendra A. Chiplunkar) and related documents, are being
`
`served via electronic mail on this 10th day of April, 2017, by electronic mail to the
`
`following:
`
`Lead Counsel
`Heidi L. Keefe
`hkeefe@cooley.com
`zpatdcdocketing@cooley.com
`Cooley LLP
`Patent Group
`1299 Pennsylvania Ave., NW, Ste 700
`Washington, DC 20004
`
`
`Dated: April 10, 2017
`
`
`
`
`
`
`
`
`
`Back-up Counsel
`Stephen McBride
`smcbride@cooley.com
`Jennifer Volk
`jvolkfortier@cooley.com
`Cooley LLP
`Patent Group
`1299 Pennsylvania Ave., NW, Ste 700
`Washington, DC 20004
`
`
`
`
`/Peter J. McAndrews/
`
`
`
`
`
`
`
`Peter J. McAndrews
`Registration No. 38,547
`McANDREWS, HELD & MALLOY,
`LTD.
`500 West Madison Street, 34th Floor
`Chicago, Illinois 60661
`Telephone: (312) 775-8000
`
`4
`
`
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