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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________
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`NETFLIX, INC.,
`Petitioner,
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`v.
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`AFFINITY LABS OF TEXAS, LLC,
`Patent Owner.
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`____________
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`Case IPR2017-00122
`Patent No. 9,444,868 B2
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`PATENT OWNER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF RYAN E. DORNBERGER UNDER 37 C.F.R. § 42.10(C)
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`IPR2017-00122
`Patent 9,444,868
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`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner, Affinity Labs of Texas,
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`LLC., respectfully requests pro hac vice admission of Ryan E. Dornberger in this
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`proceeding. Patent Owner seeks Mr. Dornberger’s assistance because of his
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`experience assisting Patent Owner in its parallel litigation and his familiarity with
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`the substantive and technical issues involved in this proceeding.
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`1. Statement of Facts
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`Patent Owner’s lead counsel in this proceeding, Ryan M. Schultz, is a
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`registered practitioner. Mr. Dornberger is an experienced patent litigation
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`attorney, with over three years of experience in fact and expert discovery,
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`Markman hearings, and oral arguments in patent infringement matters before
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`both Federal district courts and the United States Court of Appeals for the
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`Federal Circuit.
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`Mr. Dornberger has established familiarity with the subject matter at issue
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`in this proceeding. U.S. Patent No. 9,444,868 is involved in the parallel litigation
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`filed by Patent Owner in the United States District Court for the Western District
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`of Texas (Civil Action No. 1:15–cv-00849–RP). Robins Kaplan LLP represents
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`Patent Owner in this litigation. Mr. Dornberger has appeared as counsel for
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`Patent Owner in this litigation and is actively involved in all aspects of the
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`litigation. For example, Mr. Dornberger participated in drafting the four
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`Markman briefs submitted to the district court and attended the Court’s day-long
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`IPR2017-00122
`Patent 9,444,868
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`Markman hearing, which included live testimony from both parties’ experts
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`regarding the ’868 Patent. Therefore, good cause exists to admit Mr. Dornberger
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`pro hac vice in this proceeding.
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`2. Affidavit or Declaration of Individual Seeking to Appear
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`This Motion for Pro Hac Vice Admission is accompanied by the required
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`Declaration of Mr. Dornberger.
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`Dated: November 14, 2017
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`Respectfully submitted,
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`By: /Ryan M. Schultz/
`Registration No. 65,143
`Robins Kaplan LLP
`800 LaSalle Avenue
`2800 LaSalle Plaza
`Minneapolis, MN 55402-2015
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`Attorney for Patent Owner
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`IPR2017-00122
`Patent 9,444,868
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`CERTIFICATE OF SERVICE
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`I hereby certify that on this November 14, 2017, a copy of Patent Owner’s
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`Motion for Pro Hac Vice Admission of Ryan E. Dornberger Under 37 C.F.R. §
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`42.10(C) and Declaration of Ryan E. Dornberger in Support of Motion for Pro Hac
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`Vice Admission have been served by electronic mail to the Petitioner:
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`David D. Schumann
`david@martonribera.com
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`Hector J. Ribera
`marton@martonribera.com
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`Dated: November 14, 2017
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`Respectfully submitted,
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`/Ryan M. Schultz/
`Registration No. 65,143
`Robins Kaplan LLP
`800 LaSalle Avenue
`2800 LaSalle Plaza
`Minneapolis, MN 55402-2015
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`Attorney for Patent Owner
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