The Patent Trial and Appeal Board (PTAB) recently denied Patent Owner’s counsel’s motion to withdraw from representation of Patent Owner in Shire Dev. LLC v. LCS Group LLC, IPR2014-00739 (Nov. 21, 2014) (Paper 9). Under 37 C.F.R. § 42.10(e), counsel may not withdraw without PTAB authorization. The Shire Dev. request was denied because the inventor could not proceed pro se as the patent was assigned to LCS Group, LLC, which was also designated as the real party-in-interest.