`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`INTELLECTUAL VENTURES MANAGEMENT, LLC
`Petitioner
`
`V.
`
`Patent of XILINX, INC.
`Patent Owner
`
`Case IPR2012-00023
`
`Patent 7,994,609
`
`Issue Date: August 9, 2011
`Title: SHIELDING FOR INTEGRATED CAPACITORS
`
`Before Sally C. Medley, Karl D. Easthom, and Justin T. Arbes
`Administrative Patent Judges
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`Patent Owner Xilinx, Inc. (“Xilinx”) hereby requests the opportunity to have
`
`Patent Owner’s Request for Oral Argument
`IPR2012—00023
`
`an oral argument at the Board pursuant to 37 CFR 42.70.
`
`ISSUES TO BE ARGUED
`
`Original claim 2 is patentable.
`
`A. Claim 2 requires a shield capacitor portion made of polysilicon, which
`
`is not taught by Paul or the other cited prior art.
`
`II.
`
`Original claim 8 is patentable.
`
`A. Claim 8 requires an unbalanced capacitor core portion, which is not
`
`taught by Paul or the other cited prior art.
`
`III.
`
`Original claim 18 is patentable.
`
`A. Claim 18 requires a capacitor with a gate dielectric, which is not
`
`taught by the combination of references in the proposed rejection.
`
`IV.
`
`Original claim 19 is patentable.
`
`A. Claim 19 requires two poly layers, which is not taught by the cited
`
`prior art.
`
`The Motion to Amend is Proper
`
`A. No claims are broadened by the Motion to Amend, and all of the
`
`requirements of 37 CFR 42.121 are met.
`
`
`
`In light of these remarks, Patent owner respectfully requests the opportunity
`
`Patent Owner’s Request for Oral Argument
`IPR2012—00023
`
`to have an oral argument at the Board. If the Board has any questions, comments,
`
`or suggestions, the undersigned attorney earnestly requests a telephone conference.
`
`No fees are believed to be required for filing this request; however, the
`
`Commissioner is authorized to charge any additional fees which may be required,
`
`or credit any overpayment, to the Deposit Account No. 08-1394.
`
`Respectfully submitted,
`
`David M. O’Dell
`
`Registration No. 42,044
`
`HAYNES AND BOONE, LLP
`
`Customer No. 27683
`
`Telephone: 972/739—8635
`Facsimile: 214/200-0808
`
`Attorney Docket No.: 42299.45
`
`Dated: October 1, 2013
`
`R_344946
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Patent Owner’s Request for Oral Argument
`IPR2012—00023
`
`INTELLECTUAL VENTURES MANAGEMENT, LLC
`Petitioner
`V
`
`XILINX, INC.
`Patent Owner
`
`Case IPR2012—00023
`
`Patent 7,994,609
`Title: SHIELDING FOR INTEGRATED CAPACITORS
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies, in accordance with 37 C.F.R. § 42.205, that
`
`service was made on the Petitioner as detailed below.
`
`Date ofservice October 1, 2013
`
`Manner ofservice Electronic Mail (lgordon@skgf.com; rsterne@skgf.com)
`
`Document served Patent Owner’s Request For Oral Argument
`
`Persons served Sterne, Kessler, Goldstein & Fox P.L.L.C.
`
`l 100 New York Avenue, NW.
`Washington, DC 20005
`
`g;
`
`:2
`
`David M. O’Dell
`
`Registration No. 42,044
`
`
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