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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`
`SCHRADER-BRIDGEPORT INTERNATIONAL, INC. et al.
`Petitioner
`
`v.
`
`CONTINENTAL AUTOMOTIVE SYSTEMS US, INC.
`Patent Owner
`
`_______________
`
`Case IPR2013-00014
`Patent 6,998,973
`
`
`________________________________________________________
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`PURSUANT TO 37 C.F.R. § 42.70
`
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`
`
`Pursuant to the Board’s September 26, 2013, Scheduling Order (Paper 23),
`
`the Patent Owner, Continental Automotive Systems US, Inc. (“Continental”)
`
`respectfully requests oral argument for the trial currently scheduled for December
`
`11, 2013.
`
`
`
`Pursuant to 37 C.F.R. § 42.70, Continental specifies the following.
`
`
`
`ISSUES TO BE ARGUED
`
`A. Whether there is reason to combine Derbyshire and Bowers. In particular:
`
`1. Whether critical data will be received in Derbyshire’s system and
`
`whether there would be enhancement from use of the Bowers timer
`
`circuit.
`
`2. Whether non-critical data will be received in Derbyshire’s system and
`
`whether there would be enhancement from use of the Bowers timer
`
`circuit.
`
`3. Whether Derbyshire already has other methods of dealing with critical
`
`and non-critical data collisions.
`
`B. Whether Derbyshire itself teaches against the modification suggested in the
`
`rejection.
`
`C. Whether Derbyshire and Bowers are from non-analogous art fields and can
`
`even be combined.
`
`
`
`

`

`D. Whether Bailie provides a reason for the proposed combination.
`
`E. Whether the subject matter of claims 3 and 8 is taught by any of the
`
`references.
`
`
`
`
`
`CONCLUSION
`
`Continental respectfully requests the opportunity to have an oral argument at
`
`the Board. We respectfully request thirty (30) minutes to make our presentation to
`
`the Board. If the Board has any questions, comments, or suggestions, the
`
`undersigned attorney earnestly requests a telephone conference.
`
`
`
`No fees are required for filing this request; however, the Commissioner is
`
`authorized to charge any additional fees which may be required, or credit any
`
`overpayment, to Deposit Account No. 06-1135.
`
`Respectfully submitted,
`FITCH EVEN TABIN & FLANNERY LLP
`
`By: / Timothy R. Baumann /
`Timothy R. Baumann
`Registration No. 40,502
`tbaumann@fitcheven.com
`
`
`
`
`
`
`
`
`
`Dated: October 1, 2013
`
`
`
`120 South LaSalle Street
`Suite 1600
`Chicago, Illinois 60603
`(312) 577-7000
`(312) 577-7007 (fax)
`
`
`
`

`

`CERTIFICATE OF SERVICE
`
`
`
`The undersigned hereby certifies that a copy of this REQUEST FOR ORAL
`
`ARGUMENT PURSUANT TO 37 C.F.R. § 42.70 has been served via Express Mail on
`
`October 1, 2013, upon the following:
`
`Bryan P. Collins
`Robert M. Fuhrer
`Pillsbury Winthrop Shaw Pittman LLP
`1650 Tysons Boulevard
`McLean, Virginia 22102
`
`A courtesy copy of the same was also emailed to
`
`
`
`
`
`docket_ip@pillsburylaw.com, as requested by the petitioner.
`
`Respectfully submitted,
`FITCH EVEN TABIN & FLANNERY LLP
`
`By: / Timothy R. Baumann /
`Timothy R. Baumann
`Registration No. 40,502
`tbaumann@fitcheven.com
`
`
`
`
`
`
`
`Dated: October 1, 2013
`
`
`
`120 South LaSalle Street
`Suite 1600
`Chicago, Illinois 60603
`(312) 577-7000
`(312) 577-7007 (fax)
`
`
`
`
`

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