IPR2017-01977
`U.S. Patent No. 8,755,376
`Motion for Sarah J. Guske to Appear Pro Hac Vice
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`TELESIGN CORPORATION
`Petitioner,
`
`v.
`
`TWILIO INC.
`Patent Owner
`
`––––––––––
`
`Case IPR2017-01977
`Patent 8,755,376
`
`––––––––––
`
`MOTION FOR SARAH J. GUSKE TO APPEAR PRO HAC VICE ON
`BEHALF OF PATENT OWNER TWILIO INC.
`
`
`
`U.S. Patent No. 8,755,376
`Motion for Sarah J. Guske to Appear Pro Hac Vice
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`TELESIGN CORPORATION
`Petitioner,
`
`v.
`
`TWILIO INC.
`Patent Owner
`
`––––––––––
`
`Case IPR2017-01977
`Patent 8,755,376
`
`––––––––––
`
`MOTION FOR SARAH J. GUSKE TO APPEAR PRO HAC VICE ON
`BEHALF OF PATENT OWNER TWILIO INC.
`
`
`
`
`IPR2017-01977
`U.S. Patent No. 8,755,376
`Motion for Sarah J. Guske to Appear Pro Hac Vice
`Patent Owner Twilio Inc. (“Twilio”) respectfully requests that the Board
`
`recognize Ms. Guske 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 – Authorization Motion for Pro Hac
`
`Vice Admission” in Case No. IPR2013-00639 [“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 Ms. Guske’s pro hac vice.
`
`Ms. Guske is an experienced litigation attorney and has been involved in
`
`numerous complex litigations in state and federal courts. Ms. Guske’s biography
`
`is attached hereto as Exhibit 2001.
`
`Ms. Guske has reviewed U.S. Patent 8,755,376 and the petition already filed
`
`in this proceeding, and as such, is familiar with the subject matter at issue in this
`
`proceeding.
`
`Therefore, Patent Owner Twilio respectfully submits that there is good cause
`
`for the Board to recognize Ms. Guske as counsel pro hac vice during this
`
`proceeding.
`
`
`
`1
`
`
`
`IPR2017-01977
`U.S. Patent No. 8,755,376
`Motion for Sarah J. Guske to Appear Pro Hac Vice
`III. AFFIDAVIT OR DECLARATION OF INDIVIDUAL SEEKING TO
`APPEAR
`
`Patent Owner’s Motion for Pro Hac Vice Admission is accompanied by an
`
`Affidavit of Ms. Sarah J. Guske as required by the Order.
`
`November 2, 2017
`
`BAKER BOTTS L.L.P.
`101 California Street, Suite 3600
`San Francisco, CA 94111
`Phone: (415) 291-6206
`Facsimile: (415) 291.6306
`E-mail: wayne.stacy@bakerbotts.com
`
`Respectfully submitted,
`BAKER BOTTS L.L.P.
`
`/Wayne O. Stacy/
`Wayne Stacy
`Lead Counsel
`Reg. No. 45,125
`
`
`
`
`
`
`
`
`
`
`
`2
`
`
`
`IPR2017-01977
`U.S. Patent No. 8,755,376
`Motion for Sarah J. Guske to Appear Pro Hac Vice
`
`AFFIDAVIT OF MS. SARAH J. GUSKE IN SUPPORT OF
`MOTION FOR PRO HAC VICE ADMISSION
`
`
`I, Sarah J. Guske, do hereby declare:
`
`1.
`
`I am a partner in the law firm Baker Botts L.L.P. Lead counsel in this
`
`inter partes review proceeding is Wayne O. Stacy, who is a partner in the law firm
`
`Baker Botts L.L.P. Mr. Stacy is registered to practice before the United States
`
`Patent and Trademark Office and holds Registration No. 45,125. With respect to
`
`this proceeding, I will work closely with Mr. Stacy.
`
`2.
`
`I hold a bachelor’s degree in electrical engineering from Washington
`
`State University and a bachelor’s degree in physics from Whitworth University. I
`
`hold a juris doctor degree from the University of California—Davis School of
`
`Law.
`
`3.
`
`I have over 10 years of experience as a litigating attorney representing
`
`clients in matters in various United States District Courts and Courts of Appeals,
`
`and before the International Trade Commission. My experience includes several
`
`litigation matters in telecommunication systems and components. I am, therefore,
`
`an experienced litigating attorney. Patent Owner desires, and has a need, to be
`
`represented in certain aspects of these proceedings by an experienced litigating
`
`attorney.
`
`
`
`1
`
`
`
`IPR2017-01977
`U.S. Patent No. 8,755,376
`Motion for Sarah J. Guske to Appear Pro Hac Vice
`
`4.
`
`I am familiar with U.S. Patent No. 8,755,376 and with the legal
`
`subject matter, technical subject matter, and prior art discussed in Petitioner’s
`
`Request for Inter Partes Review of U.S. Patent No. 8,755,376, which forms the
`
`basis for this proceeding.
`
`5.
`
`I am a member in good standing of the Supreme Court for the State of
`
`California and the Supreme Court for the State of Colorado. I am also admitted to
`
`practice before the United States District Court for the Northern District of
`
`California, the United States District Court for the Central District of California,
`
`the United States District Court for the Eastern District of Texas, the United States
`
`District Court for Colorado, and the United States Court of Appeals for the Federal
`
`Circuit.
`
`6.
`
`I have never been suspended or disbarred from practice before any
`
`court or administrative body.
`
`7.
`
`I have never had a court or administrative body deny my application
`
`for admission to practice.
`
`8.
`
`I have never been sanctioned or cited for contempt by any court or
`
`administrative body.
`
`9.
`
`I have read and will comply with the Office Patent Trial Practice
`
`Guide and the Board's Rules of Practice for Trials set forth in part 42 of the C.F.R.
`
`
`
`2
`
`
`
`IPR2017-01977
`U.S. Patent No. 8,755,376
`Motion for Sarah J. Guske to Appear Pro Hac Vice
`
`10.
`
`I agree to be subject to the United States Patent and Trademark Office
`
`Code of Professional Responsibility set forth in 37 C.F.R. §§ 11.101 et. seq. and
`
`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`11.
`
`In the past three (3) years, I have applied to appear before the Office
`
`and was granted pro hac vice admission in the IPR2014-01166, IPR2014-1276,
`
`IPR2016-01254, IPR2016-01257, IPR2016-00451, IPR2016-00450 and IPR2016-
`
`00360,
`
`IPR2016-01746,
`
`IPR2016-01889,
`
`IPR2016-01890,
`
`IPR2016-01891,
`
`IPR2016-01898, IPR2016-01899, IPR2016-01900, IPR2016-01259 and IPR2016-
`
`01263 proceedings. I am currently in the process of applying for pro hac vice
`
`admission in IPR2017-01976 and IPR2017-01978 proceedings.
`
`12.
`
`I declare that all statements made herein of my own knowledge are
`
`true and that all statements made on information and belief are believed to be true;
`
`and further that these statements were made with the knowledge that willful, false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 of Title 18 of the United States Code and that such willful false
`
`statements may jeopardize the validity of U.S. Patent No. 8,755,376.
`
`Date: November 2, 2017
`
`/Sarah J. Guske/
`Sarah J. Guske
`
`3
`
`
`
`IPR2017-01977
`U.S. Patent No. 8,755,376
`Motion for Sarah J. Guske to Appear Pro Hac Vice
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(b), the undersigned certifies
`
`that on November 2, 2017, the foregoing was served electronically via email on the
`
`following:
`
`PETITIONER:
`
`Jesse J. Camacho
`Elena K. McFarland
`Christine Guastello
`Mary J. Peal
`SHOOK, HARDY & BACON LLP
`jcamacho@shb.com
`emcfarland@shb.com
`cguastello@shb.com
`mpeal@shb.com
`
`
`Date: November 2, 2017
`
`
`
`Respectfully submitted,
`BAKER BOTTS L.L.P.
`
`/Wayne O. Stacy/
`Wayne Stacy
`Lead Counsel
`
`
`
`
`
`4
`
`
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