`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`
`INGENICO INC.,
`Petitioner,
`
`v.
`
`IOENGINE, LLC,
`Patent Owner.
`____________________
`
`Case IPR2019-00929
`Patent 9,774,703
`____________________
`
`PATENT OWNER’S UNOPPOSED MOTION FOR
`PRO HAC VICE ADMISSION OF NOAH M. LEIBOWITZ
`
`
`
`IPR2019-00929
`Patent 9,774,703
`
`Pursuant to 37 C.F.R. § 42.10(c), the Board’s Notice of Filing Date
`
`Accorded (authorizing this motion), and the representative order in IPR2013-
`
`00639 Paper 7 (concerning the content of a motion for pro hac vice admission),
`
`the Patent Owner respectfully requests that the Board recognize Noah M.
`
`Leibowitz as counsel pro hac vice in this proceeding. Petitioner has indicated it
`
`will not oppose this motion.
`
`Statement of Facts
`
`1. Mr. Leibowitz is an experienced patent litigator. He has litigated
`
`numerous patent cases over the past 19 years and tried several patent cases to
`
`verdict. See Ex. 2001 ¶ 2.
`
`2. Mr. Leibowitz is longstanding counsel to Patent Owner. Mr.
`
`Leibowitz has been providing Patent Owner (privileged) legal advice in
`
`connection with the ’703 Patent and related patents, in connection with district
`
`court patent litigation involving the ’703 Patent, and in connection with district
`
`court patent litigation between the parties to this IPR. Patent Owner has
`
`requested that Mr. Leibowitz help to represent it at the Oral Hearing and during
`
`the remainder of this trial. See Ex. 2001 ¶ 3.
`
`3. Mr. Leibowitz is familiar with the technology and subject matter at
`
`issue in this trial. He has reviewed the patent, the papers and evidence filed by
`
`the Parties, and the orders of the Board. He also tried two cases involving the
`
`2
`
`
`
`IPR2019-00929
`Patent 9,774,703
`
`related ’047 Patent to jury verdict in 2017. See Ex. 2001 ¶ 4.
`
`4. Mr. Leibowitz is a member in good standing of the New York and
`
`New Jersey bars, and is admitted to practice before the United States Supreme
`
`Court, the U.S. Courts of Appeals for the Federal, Second, and Third Circuits,
`
`and the U.S. District Courts for the Eastern District of New York, Southern
`
`District of New York, and the District of New Jersey. See Ex. 2001 ¶ 5.
`
`5. Mr. Leibowitz has not been suspended or disbarred from practice
`
`before any court or administrative body. See Ex. 2001 ¶ 6.
`
`6. Mr. Leibowitz has not had any application for admission to practice
`
`before any court or administrative body denied. See Ex. 2001 ¶ 7.
`
`7. Mr. Leibowitz has not been the subject of any sanctions or contempt
`
`citations imposed by any court to administrative body. See Ex. 2001 ¶ 8.
`
`8. Mr. Leibowitz has read and will comply with the Office Patent Trial
`
`Practice Guide and the Board’s Rules of Practice for Trial set forth in part 42 of
`
`37 C.F.R. See Ex. 2001 ¶ 9.
`
`9. Mr. Leibowitz will be subject to the USPTO Rules of Professional
`
`Conduct set forth in 37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction
`
`under 37 C.F.R. § 11.19(a). See Ex. 2001 ¶ 10.
`
`10. Mr Leibowitz has either appeared or intends to appear pro hac vice
`
`before the Office in the related IPR proceedings identified in Patent Owner’s
`
`3
`
`
`
`IPR2019-00929
`Patent 9,774,703
`
`Mandatory Notices in this case. Mr. Leibowitz has not appeared pro hac vice in any
`
`other proceeding in the last three (3) years. See Ex. 2001 ¶ 11.
`
`11. Patent Owner’s lead counsel is a registered practitioner.
`
`12. Petitioner does not oppose this motion.
`
`Accordingly, good cause exists for the granting of this motion, and Patent
`
`Owner respectfully requests that Noah M. Leibowitz be admitted pro hac vice.
`
`Dated:
`
`June 26, 2019
`
`/ Derek J. Brader /
`Derek J. Brader, reg. no. 71,421
`Dechert LLP
`Cira Centre, 2929 Arch Street
`Philadelphia, PA 19104-2808
`Telephone: 215-994-2437
`Email: derek.brader@dechert.com
`Counsel for Patent Owner IOENGINE, LLC
`
`4
`
`
`
`CERTIFICATE OF SERVICE
`
`I certify that today in
`
`INGENICO INC. v. IOENGINE, LLC, IPR2019-00929
`
`I caused to be served a copy of:
`
`Patent Owner’s Unopposed Motion for Pro Hac Vice Admission of Noah M.
`Leibowitz
`Exhibit 2001
`Certificate of Service
`
`upon:
`
`via:
`
`INGENICO INC., c/o:
`Robert Asher, rasher@sunsteinlaw.com
`Timothy Murphy, tmurphy@sunsteinlaw.com
`Kerry L. Timbers, ktimbers@sunsteinlaw.com
`sunsteinip@sunsteinlaw.com
`
`electronic service to the email addresses above
`
`Dated:
`
`June 26, 2019
`
`/ Derek J. Brader /
`Derek J. Brader, reg. no. 71,421
`Dechert LLP
`Cira Centre, 2929 Arch Street
`Philadelphia, PA 19104-2808
`Telephone: 215-994-2437
`Email: derek.brader@dechert.com
`Counsel for Patent Owner IOENGINE, LLC
`
`
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