UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
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`TELEFONAKTIEBOLAGET LM ERICSSON AND ERICSSON INC.
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`Petitioners,
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`v.
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`CELLULAR COMMUNICATIONS EQUIPMENT LLC,
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`Patent Owner
`
`________________
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`Case IPR2016-01484
`U.S. Patent No. 9,025,590
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`________________
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`PATENT OWNER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF DONALD PUCKETT UNDER 37 C.F.R. § 42.10(C)
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`________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`TELEFONAKTIEBOLAGET LM ERICSSON AND ERICSSON INC.
`
`Petitioners,
`
`v.
`
`CELLULAR COMMUNICATIONS EQUIPMENT LLC,
`
`Patent Owner
`
`________________
`
`Case IPR2016-01484
`U.S. Patent No. 9,025,590
`
`________________
`
`
`
`PATENT OWNER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF DONALD PUCKETT UNDER 37 C.F.R. § 42.10(C)
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`
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`Case IPR2016-01484
`U.S. Patent No. 9,025,590
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`RELIEF REQUESTED
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`I.
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`In the Notice of Filing Date Accorded to Petition (“Notice”) mailed August
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`11, 2016, the Board authorized the parties to file motions for pro hac vice
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`admission under 37 C.F.R. § 42.10(c). The Notice requires that such motions be
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`filed in accordance with the “Order – Authorizing Motion for Pro Hac Vice
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`Admission” in Case IPR2013-00639, Paper No. 7 (“Order”).
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`Patent Owner respectfully requests that the Board recognize Donald Puckett
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`as counsel pro hac vice during this proceeding.
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`II. NO OPPOSITION TO THIS MOTION
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`Patent Owner has conferred with Petitioner with regard to this Motion, and
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`Petitioner has confirmed that they will not oppose this Motion.
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`III. GOVERNING LAWS, RULES, AND PRECEDENT
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`The Board may recognize counsel pro hac vice during a proceeding on a
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`showing of good cause. “[W]here lead counsel is a registered practitioner, a
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`motion to appear pro hac vice may be granted upon a showing that counsel is an
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`experienced litigation attorney and has an established familiarity with the subject
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`matter at issue in the proceeding.” 37 C.F.R. § 42.10(c).
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`Case IPR2016-01484
`U.S. Patent No. 9,025,590
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`IV. STATEMENT OF FACTS
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`Based on the following statement of facts, and supported by the Declaration
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`of Donald Puckett submitted herewith as Exhibit 2001, Patent Owner submits that
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`a showing of good cause has been made and respectfully requests the pro hac vice
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`admission of Donald Puckett in this proceeding:
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`1. Patent Owner’s lead counsel, Matthew Juren, is a registered practitioner
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`(Reg. No. 68,233).
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`2. Patent Owner’s lead counsel, Barry Bumgardner, is a registered
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`practitioner (Reg. No. 38,397).
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`3. Mr. Puckett is an experienced litigation attorney with more than fifteen
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`years of experience litigating patent cases. Mr. Puckett also is an Adjunct
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`Professor at Texas A&M University School of Law, having taught classes related
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`to patent litigation practice. (Ex. 2001, ¶2). His patent litigation experience
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`includes representation of clients in the Patent Trial and Appeal Board (including
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`the presentation of oral arguments to the Board), work as lead trial counsel in
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`district court patent litigation, and advocacy before the United States Court of
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`Appeals for the Federal Circuit in patent appeals. (Id. at ¶3)
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`4. Mr. Puckett is a member in good standing of the Texas State Bar. (Ex.
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`2001, ¶ 4).
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`U.S. Patent No. 9,025,590
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`5. Mr. Puckett has never been suspended or disbarred from practice before
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`any court or administrative body, nor has he ever been the subject of any ethical
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`grievance procedure or investigation. (Ex. 2001, ¶ 5).
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`6. No application filed by Mr. Puckett for admission to practice before any
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`court or administrative body has ever been denied. (Ex. 2001, ¶ 6).
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`7. No sanctions or contempt citations have been imposed against Mr.
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`Puckett by any court or administrative body. (Ex. 2001, ¶ 7).
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`8. Mr. Puckett has read and agrees to comply with the Office Patent Trial
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`Practice Guide and the Board’s Rules of Practice for Trials set forth in part 42 of
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`Title 37 of the C.F.R. (Ex. 2001, ¶ 8).
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`9. Mr. Puckett understands that he will be subject to the USPTO Rules of
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`Professional Conduct as set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary
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`jurisdiction under 37 C.F.R. § 11.19(a). (Ex. 2001, ¶ 9).
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`10. Mr. Puckett has appeared before the Board pro hac vice in the last three
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`years in: (1) IPR2014-00411 and IPR2015-00065 (consolidated), (2) IPR2014-
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`01431 and IPR2014-01432 (consolidated), (3) IPR2016-00178, and (4) IPR2016-
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`00195. (Ex. 2001, ¶ 10). Mr. Puckett presented oral arguments to the Board in two
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`of these matters. See IPR2014-00411 at Paper No. 112; IPR2014-01431 at Paper
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`No. 47.
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`Case IPR2016-01484
`U.S. Patent No. 9,025,590
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`11. Mr. Puckett has an established familiarity with the subject matter at
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`issue in this proceeding. Mr. Puckett has substantively reviewed all materials filed
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`in this proceeding, including the Petition and all accompanying exhibits (1001-
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`1021). (Ex. 2001, ¶ 11).
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`V. GOOD CAUSE EXISTS FOR THE PRO HAC VICE ADMISSION OF
`MR. PUCKETT IN THIS PROCEEDING
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`The Board may recognize counsel pro hac vice during a proceeding upon a
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`showing of good cause, subject to the condition that lead counsel be a registered
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`practitioner and any other conditions as the Board may impose. 37 C.F.R. §
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`42.10(c). Patent Owner’s lead counsel, Matthew Juren, is a registered practitioner.
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`Based on the facts contained herein, as supported by Mr. Puckett’s declaration (Ex.
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`2001), good cause exists to admit Mr. Puckett pro hac vice as backup counsel in
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`this proceeding.
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`Patent Owner has a substantial need for Mr. Puckett’s pro hac vice
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`admission so that he may be involved in all aspects of this proceeding, including
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`depositions and the presentation of oral argument. Admission of Mr. Puckett also
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`will ease the burden on Patent Owner’s lead and backup counsel in this
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`proceeding.
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`U.S. Patent No. 9,025,590
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`VIII. CONCLUSION.
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`For the foregoing reasons as well as the reasons contained in the attached
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`declaration, Patent Owner respectfully requests admission of Donald Puckett as
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`counsel pro hac vice as backup counsel in this proceeding.
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`Respectfully Submitted,
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`
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`/s/ Matthew C. Juren
`Matthew C. Juren
`Registration No. 68,233
`Attorney for Patent Owner
`NELSON BUMGARDNER, P.C.
`3131 W. 7th Street, Suite 300
`Fort Worth, Texas 76107
`Telephone: (817) 377-9111
`Facsimile: (817) 377-3485
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`Dated: August 19, 2016
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`Case IPR2016-01484
`U.S. Patent No. 9,025,590
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`CERTIFICATE OF SERVICE
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`
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`I hereby certify that on this 19th day of August 2016, a copy of Patent
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`Owner’s Unopposed Motion for Pro Hac Vice Admission of Donald Puckett Under
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`37 C.F.R. § 42.10(C) has been served in its entirety via email on the following:
`
`Jacob K. Baron
`Reg. No. 48,961
`jacob.baron@hklaw.com
`10 St. James Avenue, 11th Floor
`Boston, MA 02116
`Allison M. Lucier
`Reg. No. 70,205
`Allison.lucier@hklaw.com
`10 St. James Avenue, 11th Floor
`Boston, MA 02116
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`clientteam-cce-ericsson@hklaw.com
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`Dated: August 19, 2016
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`Respectfully Submitted,
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`/s/ Matthew C. Juren
`Matthew C. Juren
`Registration No. 68,233
`Attorney for Patent Owner
`NELSON BUMGARDNER, P.C.
`3131 W. 7th Street, Suite 300
`Fort Worth, Texas 76107
`Telephone: (817) 377-9111
`Facsimile: (817) 377-3485
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`
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