`571-272-7822
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Paper____
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________
`
`
`
`
`
`
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`MICROSOFT CORPORATION and HP Inc.
`Petitioner
`
`v.
`
`SYNKLOUD TECHNOLOGIES, LLC,
`Patent Owner
`________________
`
`Case No. IPR 2020-00316
`
`Patent No. 9,098,526
`________________
`
`
`
`MOTION TO WITHDRAW FROM REPRESENTATION
`37 C.F.R. §11.116
`
`
`
`
`
`
`
`
`
`
`Responsive to the communication from the Patent Trial and Appeal Board
`
`
`
`
`
`
`dated August 6, 2020, and pursuant to the provisions of Rule 116 of Chapter 11 of
`
`Title 37 of the Code of Federal Regulations, Steven B. Kelber, current designated
`
`counsel for Patent Owner Synkloud Technologies, LLC seeks the Board’s
`
`permission to withdraw from representation in this matter. As grounds for this
`
`request, and consistent with Rule 116(a), Movant Steven Kelber has been
`
`discharged from representation in this proceeding.
`
`
`
`As provided for in Rule 116(b), Movant’s withdrawal in this matter can be
`
`accomplished without material adverse effect on the interests of the client. This
`
`case is part of a multiple case litigation matter that has given rise to nine IPRs to
`
`date. Movant’s preexisting obligations, coupled with growing disagreements with
`
`the client and litigation counsel over how best to present the evidence in support of
`
`Patent Owner’s position, and the retention of experts consistent therewith, made it
`
`clear that alternate counsel that might better represent the Patent Owner would be
`
`of value.
`
`
`
`No action was taken until alternate experienced counsel, Dr. Greg
`
`Gonsalves, was located who had the time and interest to undertake the
`
`representation required was secured. Movant Steven Kelber spoke with Dr.
`
`Gonsalves repeatedly, and confirmed that in fact Dr. Gonsalves was experienced,
`
`
`
`able and prepared to represent Patent Owner’s interests. A power of attorney and
`
`Amended Mandatory Notice designating Dr. Gonsalves as lead counsel has already
`
`been filed.
`
`
`
`In this matter, Patent Owner’s Response is not due until September 21, 2020.
`
`The evidentiary basis for that Response has been prepared and an appropriate
`
`framework for the response is similarly prepared. There are no outstanding
`
`discovery disputes, no pending depositions or other actions contemplated at this
`
`time. All files and records in this matter have been maintained electronically, and
`
`made available to Dr. Gonsalves, but as noted Movant has discussed the matter
`
`with Dr. Gonsalves, and will provide any additional information consistent with
`
`the obligations provided for. Movant holds no property, resources or funds from or
`
`on behalf of Patent Owner. Accordingly, Movant submits that the requirements of
`
`37 C.F.R. §11.116(d) have been fully satisfied.
`
`
`
`Should this Board identify other actions to be taken or to be refrained from
`
`taking in this matter, Movant Steven B. Kelber will undertake those actions to the
`
`best of his ability.
`
`
`
`Date: August 7, 2020
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`/s/ Steven B. Kelber
`Steven B. Kelber
`240-506-6702
`steve@kelberlawgroup.com
`
`
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
