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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_______________
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`SCHRADER-BRIDGEPORT INTERNATIONAL, INC. et al.
`Petitioner
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`v.
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`CONTINENTAL AUTOMOTIVE SYSTEMS US, INC.
`Patent Owner
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`_______________
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`Case IPR2013-00014
`Patent 6,998,973
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`________________________________________________________
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`PURSUANT TO 37 C.F.R. § 42.70
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`Pursuant to the Board’s September 26, 2013, Scheduling Order (Paper 23),
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`the Patent Owner, Continental Automotive Systems US, Inc. (“Continental”)
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`respectfully requests oral argument for the trial currently scheduled for December
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`11, 2013.
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`Pursuant to 37 C.F.R. § 42.70, Continental specifies the following.
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`ISSUES TO BE ARGUED
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`A. Whether there is reason to combine Derbyshire and Bowers. In particular:
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`1. Whether critical data will be received in Derbyshire’s system and
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`whether there would be enhancement from use of the Bowers timer
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`circuit.
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`2. Whether non-critical data will be received in Derbyshire’s system and
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`whether there would be enhancement from use of the Bowers timer
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`circuit.
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`3. Whether Derbyshire already has other methods of dealing with critical
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`and non-critical data collisions.
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`B. Whether Derbyshire itself teaches against the modification suggested in the
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`rejection.
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`C. Whether Derbyshire and Bowers are from non-analogous art fields and can
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`even be combined.
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`D. Whether Bailie provides a reason for the proposed combination.
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`E. Whether the subject matter of claims 3 and 8 is taught by any of the
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`references.
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`CONCLUSION
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`Continental respectfully requests the opportunity to have an oral argument at
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`the Board. We respectfully request thirty (30) minutes to make our presentation to
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`the Board. If the Board has any questions, comments, or suggestions, the
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`undersigned attorney earnestly requests a telephone conference.
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`No fees are required for filing this request; however, the Commissioner is
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`authorized to charge any additional fees which may be required, or credit any
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`overpayment, to Deposit Account No. 06-1135.
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`Respectfully submitted,
`FITCH EVEN TABIN & FLANNERY LLP
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`By: / Timothy R. Baumann /
`Timothy R. Baumann
`Registration No. 40,502
`tbaumann@fitcheven.com
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`Dated: October 1, 2013
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`120 South LaSalle Street
`Suite 1600
`Chicago, Illinois 60603
`(312) 577-7000
`(312) 577-7007 (fax)
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of this REQUEST FOR ORAL
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`ARGUMENT PURSUANT TO 37 C.F.R. § 42.70 has been served via Express Mail on
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`October 1, 2013, upon the following:
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`Bryan P. Collins
`Robert M. Fuhrer
`Pillsbury Winthrop Shaw Pittman LLP
`1650 Tysons Boulevard
`McLean, Virginia 22102
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`A courtesy copy of the same was also emailed to
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`docket_ip@pillsburylaw.com, as requested by the petitioner.
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`Respectfully submitted,
`FITCH EVEN TABIN & FLANNERY LLP
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`By: / Timothy R. Baumann /
`Timothy R. Baumann
`Registration No. 40,502
`tbaumann@fitcheven.com
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`Dated: October 1, 2013
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`120 South LaSalle Street
`Suite 1600
`Chicago, Illinois 60603
`(312) 577-7000
`(312) 577-7007 (fax)
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