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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Miami Division 

Case No.: 20-22051-CIV-GAYLES 

SISVEL INTERNATIONAL S.A., 3G 

LICENSING S.A., and SISVEL S.p.A., 

Plaintiffs, 

v. 

HMD AMERICA, INC. and HMD 

GLOBAL OY, 

Defendants. 

DEFENDANTS HMD AMERICA, INC. AND HMD GLOBAL OY’S 

IDENTIFICATION OF PROPOSED CANDIDATES FOR SPECIAL MASTER 

Pursuant to the Court’s order dated June 24, 2021 (ECF No. 101), defendants HMD 

America, Inc. and HMD Global Oy (“Defendants” or “HMD”), by their undersigned attorneys, 

hereby identify two proposed candidates for the role of Special Master to oversee the claim 

construction process: 

Steven M Bauer of JAMS, and 

William B. Dyer, III, of Lee & Hayes. 

The bases for HMD’s recommendation of Mr. Bauer and Mr. Dyer as Special Master 

candidates are set forth below. Mr. Bauer’s and Mr. Dyer’s CVs are attached. 

Case 1:20-cv-22051-DPG Document 104 Entered on FLSD Docket 07/08/2021 Page 1 of 5
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STEVEN M. BAUER OF JAMS 

Education and experience with relevant technology and experience as a neutral: 

Steven M. Bauer holds a B.S. in Electrical Engineering from MIT, a M.S. in Electrical 

Engineering and Computer Science from MIT, and a J.D. from Boston University School of 

Law. He started his career as a law clerk and technical advisor to Judge Philip Nichols at in the 

Federal Circuit. Mr. Bauer has 30-years of experience as an arbitrator, first for AAA, and 

currently with JAMS, where he specializes in cases involving technology and life sciences 

disputes. Before joining JAMS in 2020, Mr. Bauer was the co-chair of Proskauer’s national 

patent and intellectual property group, and a member of its Executive Committee, with 

experience litigating a variety of technologies, including wireless communications, data 

encryption, cable and internet communications protocols, digital signal processing in parallel 

computer architecture, and VoIP switching technologies. 

Experience with claim construction: Mr. Bauer worked on at least one decision a month 

involving claim construction while at the Federal Circuit. In private practice, Mr. Bauer has 

been lead counsel in, and presented at, over 50 claim construction hearings. Mr. Bauer was also 

lead counsel (and argued) to the Federal Circuit at its en banc session relating to the role of claim 

construction in the federal courts – the session that resulted in the seminal Markman decision. 

(Mr. Bauer argued a parallel companion case presented to the en banc court on the same day). 

Mr. Bauer currently teaches MIT’s introduction to IP Law class, and a patent litigation course at 

BU Law School, both of which involve claim construction. 

Experience in Florida: Mr. Bauer has appeared pro hac vice in Florida several times and 

is familiar with local practice. By way of example, he presented at a Markman hearing in S.D. 

Florida in a case involving digital television standards and communications patents in Zenith 

Elecs. v. Craig Elecs. (9:13-cv-80567), Zenith Elecs. v. Curtis Int’l (9:13-cv-80568), Mitsubishi 

Electric Corp. v. Motorola Mobility (9:13-cv-80745), and Mitsubishi Electric Corp. v. View 

Sonic (9:13-cv-80743). 

Other information: Mr. Bauer’s experience and credentials make him an excellent 

candidate to serve as a Special Master to assist the Court with claim construction in the present 

matter. His hourly rate is $600/hour. No travel is expected for this assignment, but Mr. Bauer 

has informed us that he does not intend to charge for travel time or expenses to Florida. JAMS 

will waive its normal administrative fee of 20% for this matter. 

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WILLIAM B. DYER, III, OF LEE & HAYES 

Education and experience with relevant technology: After earning a B.S. in Electrical 

Engineering, Bill Dyer’s professional career began as an engineer in the defense communications 

industry. After completing law school, his initial intellectual property practice was split between 

patent preparation and patent litigation. The majority of Mr. Dyer’s clients were in the 

electronics sectors, including BellSouth, Sony, HP, and Microsoft. 

Experience with patent litigation and claim construction: For the past 20 years, at least 

80% of Mr. Dyer’s practice has consisted of patent litigation, primarily in United States District 

Courts and before the U.S. International Trade Commission. He has been involved in over 60 

separate patent litigations, and has been lead counsel or co-lead counsel in at least 30 of those 

cases. The majority of those cases progressed to the stage where claim construction was 

required. Mr. Dyer was involved in developing proposed claim constructions in each case, and 

presented oral argument at the Markman hearings in approximately 20 of those cases. 

Experience as a neutral Special Master: Mr. Dyer has been appointed as Special Master 

for claim construction seven times. Of those seven appointments, five resulted in the conducting 

of a Markman hearing, followed by the drafting and filing of a Report and Recommendation on 

claim construction. In each case, the Court adopted Mr. Dyer’s Report and Recommendation in 

full, and he is not aware of any adverse ruling regarding his proposed claim constructions on 

appeal. Additionally, Mr. Dyer was appointed Special Master in two cases for matters other than 

claim construction. One appointment related to discovery disputes about complex electrical 

technology, and the other related to procedural issues. 

Other information: Mr. Dyer’s standard billing rate $595 per hour, but he offers a 

discounted rate of $550 per hour for this matter. Two judges for whom Mr. Dyer recently 

completed Reports and Recommendations on claim construction in the Northern District of 

Georgia, Judge Steven D. Grimberg and Judge William M. Ray II, would provide their 

impressions of his service. Mr. Dyer currently serves as the Commanding General for the United 

States Army Reserve Legal Command, Gaithersburg, Maryland. 

Case 1:20-cv-22051-DPG Document 104 Entered on FLSD Docket 07/08/2021 Page 3 of 5
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Dated: July 8, 2021 Respectfully submitted, 

WILLIAM J. MCCABE, Esq. 

Pro hac vice 

wmccabe@perkinscoie.com 

GENE W. LEE, Esq. 

Pro hac vice 

glee@perkinscoie.com 

MATTHEW J. MOFFA, Esq. 

Pro hac vice 

mmoffa@perkinscoie.com 

PERKINS COIE LLP 

1155 Avenue of the Americas, 22nd floor 

New York, NY 10036 

Telephone: (212) 262-6900 

Facsimile: (212) 977-1649 

 /joseph w. bain/

JOSEPH W. BAIN, ESQ. 

Florida Bar No. 860360 

Email Address: jbain@shutts.com 

SHUTTS & BOWEN LLP 

1100 CityPlace Tower 

525 Okeechobee Boulevard 

West Palm Beach, Florida 33401 

Telephone: (561) 835-8500 

Facsimile: (561) 650-8530 

ATTORNEYS FOR DEFENDANTS 

HMD AMERICA, INC., AND 

HMD GLOBAL OY

SHYAMKRISHNA PALAIYANUR, Esq. 

Admitted pro hac vice

spalaiyanur@perkinscoie.com 

PERKINS COIE LLP

500 W 2nd Street, Suite 1900 

Austin, TX 78701 

Telephone: (737) 256-6114 

Facsimile: (737) 256-6300

Case 1:20-cv-22051-DPG Document 104 Entered on FLSD Docket 07/08/2021 Page 4 of 5
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CERTIFICATE OF SERVICE 

I hereby certify that all counsel of record who have consented to electronic service are being 

served with a copy of this document on July 8, 2021. 

/s/ Joseph W. Bain 

Joseph W. Bain 

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