`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`JUNIPER NETWORKS, INC.
`Petitioner
`
`v.
`
`IMPLICIT, LLC
`Patent Owner
`
`Case: IPR2020-00587
`Patent No. 9,591,104
`
`
`
`
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`
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`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF
`WILLIAM ELLSWORTH DAVIS, III
`
`I. RELIEF REQUESTED
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`Pursuant to Rule 42.10(c), Patent Owner Implicit, LLC (“Implicit”)
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`respectfully requests pro hac vice admission of William E. Davis, III as counsel
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`in this proceeding.
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`II. GOVERNING LAW, RULES, AND PRECEDENT
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`37 C.F.R. § 42.10(c) states as follows:
`
`The Board may recognize counsel pro hac vice during a
`
`proceeding upon a showing of good cause, subject to the
`1
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`
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`
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`
`
`
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`condition that lead counsel be a registered practitioner and
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`to any other conditions as the Board may impose. For
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`example, where the lead counsel is a registered
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`practitioner, a motion to appear pro hac vice by counsel
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`who is not a registered practitioner may be granted upon
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`showing that counsel is an experienced litigating attorney
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`and has an established familiarity with the subject matter
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`at issue in the proceeding.
`III. STATEMENT OF FACTS
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`Based on the following statement of facts, and supported by the Declaration
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`of William E. Davis, III submitted herewith (Exhibit 2014), Implicit, LLC submits
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`that a showing of good cause has been made and respectfully requests the pro hac
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`vice admission of William E. Davis, III in this proceeding:
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`1. Mr. Davis is an experienced litigation attorney and has an established
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`familiarity with the subject matter at issue in this proceeding. Mr. Davis
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`has been practicing law since 2004 and has extensive experience
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`litigating patent infringement cases in many different District Courts
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`across the country. Among his experience in patent litigation matters,
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`Mr. Davis has been lead counsel in multiple trials, Markman hearings,
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`patent summary judgment proceedings, and other patent- related
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`hearings and pleadings concerning, inter alia, patent validity and
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`2
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`infringement issues.
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`2. Mr. Davis is familiar with U.S. Patent Nos. 8,694,683 (“the ’683
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`Patent”); 9,270,790 (“the ’790 Patent”); 9,591,104 (“the ’104 Patent”);
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`10,027,780 (“the ’780 Patent”); 10,033,839; (“the ’839 Patent”) and
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`10,225,378 (“the ’378 Patent”). Mr. Davis has been representing Patent
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`Owner Implicit in pending District Court litigation against Petitioner
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`asserting the ’683, ’790, ’104, ’780, ’839 and ’378 Patents. Among other
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`things, Mr. Davis has been involved in the infringement, claim
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`construction, and validity issues with regard to the ’683, ’790, ’104, ’780,
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`’839 and ’378 Patents.
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`3. Mr. Davis is currently admitted pro hac vice before the Patent Trial and
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`Appeal Board in Sonos, Inc. v. Implicit, LLC; IPR2018-00766 (Patent
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`7,391,791 B2) and Sonos, Inc. v. Implicit, LLC IPR2018-00767 (Patent
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`8,942,252 B2).
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`IV. GOOD CAUSE EXISTS FOR PRO HAC ADMISSION
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`
`
`The facts outlined above in the Statement of Facts, and contained in the
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`Declaration William E. Davis, III (Ex. 2014), establish that there is good cause to
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`admit Mr. Davis pro hac vice in this proceeding under 37 C.F.R. § 42.10.
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`Petitioner’s lead counsel and first back-up counsel are registered practitioners. Mr.
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`Davis is an experienced litigating attorney and has an established familiarity with
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`
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`3
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`the subject matter at issue.
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`V. NO OPPOSITION TO THE MOTION
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`Patent Owner, Implicit, LLC has conferred with Petitioner with regard to
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`this Motion, and Petitioner confirmed that it would not oppose the motion.
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`VI. CONCLUSION
`For the foregoing reasons as well as the reasons contained in the declaration
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`entered as Exhibit 2014, Implicit respectfully requests admission of William E.
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`Davis, III as counsel pro hac vice.
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`Respectfully submitted,
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`THE DAVIS FIRM, P.C.
`
`By: /s/ Christian Hurt Reg.No.63,659
` Christian Hurt
`
`
`
`DAVIS FIRM, PC
`213 N. Fredonia Street, Suite 230
`Longview, Texas 75601
`903-230-9090
`churt@davisfirm.com
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`4
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`CERTIFICATE OF SERVICE
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`I hereby certify that on July 23, 2020, a true copy of the following
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`document(s):
`
`PATENT OWNER IMPLICIT, LLC’S UNOPPOSED MOTION FOR PRO
`HAC VICE ADMISSION OF WILLIAM E. DAVIS, III UNDER 37 C.F.R. §
`42.10)C) and EXHIBIT 2014 were served as follows:
`Juniper-Implicit@irell.com
`Jonathan M. Lindsay
`David McPhie
`Courtney Dennis
`Irell & Manella LLP
`840 Newport Center Drive, Suite 400
`Newport Beach, CA 92660
`
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`I declare under penalty of perjury under the laws of the United States of
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`America that the foregoing is true and correct. Executed on July 23, 2020 at
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`Dallas, Texas.
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`/s/Christian J. Hurt
`Christian J. Hurt
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`5
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