`(317145-2073)
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`IPR2018-00458
`U.S. Patent No. 9,313,156
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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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`SNAP INC.,
`Petitioner
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`v.
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`VAPORSTREAM, INC.,
`Patent Owner
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`
`
`Case IPR2018-00458
`U.S. Patent No. 9,313,156
`
`
`PETITIONER'S MOTION FOR PRO HAC VICE ADMISSION
`UNDER 37 CFR § 42.10(c)
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`
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`
`
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`Atty Docket No. TYPA-030/00US
`(317145-2073)
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`
`
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`IPR2018-00458
`U.S. Patent No. 9,313,156
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`Petitioner Snap, Inc. respectfully requests that the Board recognize Reuben
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`Chen, Esq., as counsel pro hac vice during this proceeding.
`BACKGROUND
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`Petitioner’s Motion for Pro Hac Vice Admission is being filed in compliance
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`with and pursuant to the “Order—Authorizing Motion for Pro Hac Vice Admission”
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`in Case No. IPR2013-00639 (MPT) [“the Order”], and pursuant to the Board’s
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`advanced authorization expressed in the Board’s Notice of Filing Date Accorded and
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`Time for Filing Patent Owner’s Preliminary Response dated March 8, 2018 (Paper
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`No. 5).
`STATEMENT OF FACTS
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`As required by the Order, the following statement of facts shows that there is
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`good cause for the Board to recognize Mr. Chen pro hac vice.
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`Mr. Chen is an experienced litigation attorney and has been involved in
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`numerous complex litigations in state and federal courts. Mr. Chen’s biography is
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`attached hereto as Exhibit 1039 to this Motion.
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`Mr. Chen has reviewed U.S. Patent No. 9,313,156, and the petition already
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`filed in this proceeding. Further, Mr. Chen is familiar with, and counsel of record
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`for Petitioner and actively involved in, the pending litigation between the parties
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`pending before the U.S. District Court for the Central District of California entitled
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`Vaporstream, Inc. v. Snap Inc., Case No. 2:17-cv-00220-JAK-KS filed January 10,
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`2017; and, as such, is familiar with the subject matter at issue in this proceeding.
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`1
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`Atty Docket No. TYPA-030/00US
`(317145-2073)
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`IPR2018-00458
`U.S. Patent No. 9,313,156
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`Additionally, Petitioner seeks to have its counsel in the related District Court cases
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`involved in the related IPR proceedings.
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`Therefore, Petitioner respectfully submits that there is good cause for the
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`Board to recognize Mr. Chen as counsel pro hac vice during this proceeding.
`DECLARATION OF INDIVIDUAL SEEKING TO APPEAR
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`Petitioner’s Motion for Pro Hac Vice Admission is accompanied by a
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`Declaration of Reuben Chen attached hereto as Exhibit 1040 as required by the
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`Order.
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`Dated: September 19, 2018
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`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Avenue NW
`Suite 700
`Washington, DC 20004
`Tel: (650) 843-5001
`Fax: (650) 849-7400
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`By:
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`
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`Respectfully submitted,
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`
`/Heidi L. Keefe/
`Heidi L. Keefe
`Reg. No. 40,673
`Counsel for Petitioner
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`Atty Docket No. TYPA-030/00US
`(317145-2073)
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`IPR2018-00458
`U.S. Patent No. 9,313,156
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`
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`CERTIFICATE OF SERVICE
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`I hereby certify, pursuant to 37 C.F.R. Section 42.6, that a complete copy of
`the attached PETITIONER'S MOTION FOR PRO HAC VICE ADMISSION
`UNDER 37 CFR § 42.10(c) and related documents, are being served via
`electronic mail on the 19th day of September, 2018, upon the Patent Owner’s
`attorneys of record in this matter as follows:
`
`Douglas R. Wilson
`dwilson@hpcllp.com
`Michael F. Heim
`mheim@hpcllp.com
`Blaine A. Larson
`blarson@hpcllp.com
`HEIM PAYNE & CHORUSH LLP
`
`Jamie T. Gallagher
`(jamie@birchtreeip.com)
`(patents@birchtreeip.com)
`BIRCH TREE IP LAW & STRATEGY PLLC
`
`DATED: September 19, 2018
`
` / Heidi L. Keefe /
`Heidi L. Keefe
`Reg. No. 40,673
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`
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`COOLEY LLP
`ATTN: Patent Docketing
`1299 Pennsylvania Ave. NW, Suite 700
`Washington, D.C. 20004
`Tel: (650) 843-5001
`Fax: (650) 849-7400
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