UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SHENZHEN ZHIYI TECHNOLOGY CO. LTD., D/B/A ILIFE,
`Petitioner,
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`v.
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`IROBOT CORP.,
`Patent Owner.
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`Case IPR2017-02061
`Patent 6,809,490
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`PATENT OWNER IROBOT’S
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF
`STEPHEN A. MARSHALL
`UNDER 37 C.F.R. § 42.10(c)
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SHENZHEN ZHIYI TECHNOLOGY CO. LTD., D/B/A ILIFE,
`Petitioner,
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`v.
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`IROBOT CORP.,
`Patent Owner.
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`Case IPR2017-02061
`Patent 6,809,490
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`PATENT OWNER IROBOT’S
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF
`STEPHEN A. MARSHALL
`UNDER 37 C.F.R. § 42.10(c)
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`Proceeding No.: IPR2017-02061
`Attorney Docket: 44360-0004IP1
`EXHIBIT LIST
`Prosecution History of U.S. Patent No. 6,809,490 (Serial No.
`10/167,851)
`U.S. Patent No. 6,076,025 to Ueno et al. (“Ueno-025”)
`Claim Construction Order from Investigation No. 337-TA-1057,
`August 18, 2017
`U.S. Provisional Application No. 60/297,718
`Declaration of Dr. J. Kenneth Salisbury
`Definition of “spot,” The Oxford Essential Dictionary: American
`Edition, p. 580 (1998)
`Definition of “spot,” Webster’s II New College Dictionary, p. 1068
`(1999)
`RESERVED
`European Patent Application Publication No. EP0145683 A1 to
`Brantmark et al. (“Brantmark”)
`U.S. Patent No. 6,452,348 to Toyoda (“Toyoda”)
`U.S. Patent No. 6,681,031 to Cohen et al. (“Cohen”)
`U.S. Patent No. 4,484,294 to Noss (“Noss”)
`U.S. Patent No. 4,360,886 to Kostas et al. (“Kostas”)
`Definition of “isolated,” The New Shorter Oxford English Dictionary,
`Volume 1, p. 1425 (1993)
`Transcript of Deposition of Dr. C. Douglass Locke taken June 20,
`2018
`Declaration of Stephen A. Marshall in Support of Pro Hac Vice
`Admission
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`IR2001
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`IR2002
`IR2003
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`IR2004
`IR2005
`IR2006
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`IR2007
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`IR2008
`IR2009
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`IR2010
`IR2011
`IR2012
`IR2013
`IR2014
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`IR2015
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`IR2016
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`Proceeding No.: IPR2017-02061
`Attorney Docket: 44360-0004IP1
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`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner, iRobot Corp. (“iRobot” or
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`“Patent Owner”) respectfully requests that the Board recognize Stephen A.
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`Marshall as counsel pro hac vice in this proceeding. Patent Owner seeks the
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`counsel of Mr. Marshall due to his experience in representing iRobot in other
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`patent-related matters and particularly due to his familiarity with the substantive
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`and technical issues involved in this proceeding. This motion is authorized by the
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`Notice of Filing Date Accorded to Petition and Time for Filing Patent Owner
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`Preliminary Response that was mailed on September 14, 2017.
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`Petitioner does not oppose this motion.
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`Statement of Facts
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`Mr. Marshall is a patent litigation attorney with nearly 12 years of
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`experience representing clients in cases involving telecommunications, computer
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`networking, embedded systems and software, and robotics. Mr. Marshall regularly
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`litigates patent cases before the United States Court of Appeals for the Federal
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`Circuit, various federal district courts, and the International Trade Commission.
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`Through his practice in such cases, Mr. Marshall has gained substantial experience
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`in jury trials, discovery, Markman hearings, and appeals. iRobot provides Exhibit
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`A (attached to the accompanying Declaration), as evidence of Mr. Marshall’s
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`biography.
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`Proceeding No.: IPR2017-02061
`Attorney Docket: 44360-0004IP1
`Mr. Marshall also has particular experience and familiarity with the
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`substantive and technical issues involved in this inter partes review proceeding. In
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`two related matters, Certain Robotic Vacuum Cleaning Devices and Components
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`Thereof Such as Spare Parts, Inv. No. 337-TA-1057 (Int’l Trade Comm’n), filed
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`April 18, 2017 and iRobot Corp. v. Shenzhen Zhiyi Technology Co., Ltd., d/b/a
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`iLife, Case No. 1:17-cv-10652 (D. Mass.), Mr. Marshall is serving as lead or co-
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`lead counsel for iRobot. These related litigations each involve the patent at issue
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`in this inter partes review proceeding.
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`1. Declaration of Individual Seeking to Appear
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`This Motion for Pro Hac Vice Admission is accompanied by a Declaration
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`of Stephen A. Marshall as required by the Order Authorizing Motion for Pro Hac
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`Vice mailed September 14, 2017.
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`Accordingly, iRobot submits that there is good cause under 37 C.F.R. §
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`42.10(c) for the Board to recognize Stephen A. Marshall as counsel pro hac vice
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`during this proceeding.
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`Proceeding No.: IPR2017-02061
`Attorney Docket: 44360-0004IP1
`Respectfully submitted,
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`/Jeremy J. Monaldo/
`Jeremy J. Monaldo
`Reg. No. 58,680
`Counsel for Petitioner
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`Date: August 28, 2018
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`Customer Number 26171
`Fish & Richardson P.C.
`Telephone: (612) 337-2508
`Facsimile: (612) 288-9696
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`Proceeding No.: IPR2017-02061
`Attorney Docket: 44360-0004IP1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR § 42.6(e)(4), the undersigned certifies that on August
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`28, 2018, a complete and entire copy of this Patent Owner’s Motion for Pro Hac
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`Vice Admission of Stephen A. Marshall and its supporting exhibit were provided
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`via email, to the Petitioner by serving the email correspondence address of record
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`as follows:
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`Patrick J. McCarthy
`Greenberg Traurig LLP
`2102 L Street, N.W., Suite 1000
`Washington, DC 20037
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`Cameron M. Nelson
`Greenberg Traurig LLP
`77 W. Wacker Dr.
`Suite 3100
`Chicago, IL 60601
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`Email: mccarthyp@gtlaw.com
`Email: Shenzhenzhiyiitcall@gtlaw.com
`Email: nelsonc@gtlaw.com
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`/Edward G. Faeth/
`Edward G. Faeth
`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`(202) 626-6420
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