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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`DELL INC., HEWLETT-PACKARD COMPANY, and NETAPP, INC.,
`Petitioners,
`
`V.
`
`ELECTRONICS AND TELECOMMUNICATIONS RESEARCH INSTITUTE,
`
`Patent Owner.
`
`Case IPR2013-00635
`
`Patent No. 6,978,346
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`

`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`Case IPR20l3-00635 /Patent No. 6,978,346
`
`In accordance with 37 C.F.R. § 42.70(a), Petitioners Dell Inc., Hewlett-
`
`Packard Company, and NetApp, Inc. hereby request oral argument in the present
`
`inter partes review. The issues to be argued include:
`
`Hathorn discloses a “RAID,” “a first RAID controlling unit,” and “a
`
`second RAID controlling unit”
`
`II.
`
`PO’s explanations of “RAID” and “RAID controlling unit” are
`
`improperly narrow
`
`III.
`
`Hathorn’s ports teach “network [interface] controlling units”
`
`IV.
`
`PO’s construction of “network [interface] controlling unit” is not the
`
`broadest reasonable construction
`
`The term “connected” in claims 2, 3, and 8 includes connections through
`
`hubs or switches
`
`VI.
`
`Hathorn teaches the “hub equipment” of Claim 5
`
`VII.
`
`Hathorn teaches the “rest of the connection ports being provided
`
`as. .
`
`. [hub equipment/network switch equipment] connected with the
`
`numerous host computers” limitations recited in claims 5-7
`
`VIII.
`
`Other issues raised in papers filed in the present proceeding, including
`
`issues raised in papers yet to be filed.
`
`In light of these remarks, Petitioners respectfully request the opportunity to
`
`present oral arguments before the Board on December 18, 2014. (See Scheduling
`
`Order, Paper 20, p. 5). If the Board has any questions or comments, the
`
`undersigned attorney respectfully requests a telephone conference.
`
`

`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`Case IPR2013-00635 / Patent No. 6,978,346
`
`No fees are required for filing this request; however, the Commissioner is
`
`authorized to charge any required fees, or credit any overpayment, to Haynes and
`
`Boone, LLP’s Deposit Account No. 08-1394.
`
`Respectfully submitted,
`
`Dated: November 7, 2014
`
`By:
`
`David L. McCombs
`
`Registration No. 32,271
`Counsel for Petitioner
`
`HAYNES AND BOONE, LLP
`
`Customer No. 112792
`
`Telephone: 214-651-5533
`Facsimile: 214-200-0853
`
`Attorney Docket No.: 47415.430
`
`

`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`Case IPR20l3—00635 / Patent No. 6,978,346
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies service on
`
`the Patent Owner a copy of this Request for Oral Argument as detailed below.
`
`Date ofservice
`
`November 7, 2014
`
`Manner ofservice
`
`Electronic Mail:
`
`matthew.phillips@renaissanceiplaw.com;
`derek.meeker@renaissanceiplaw.com; agiza@raklaw.com
`
`Document served
`
`Petitioner’s Request for Oral Argument
`
`Persons served
`
`Matthew C. Phillips
`Derek Meeker
`
`Renaissance IP Law Group LLP
`9600 SW Oak Street, Suite 560
`
`Portland, Oregon 97223
`
`Alexander C.D. Giza
`
`Russ August & Kabat
`12424 Wilshire Boulevard, 12th Floor
`
`Los Angeles, California 90025
`
`%‘J\\2 5:9 3
`
`David L. McCombs
`
`Counsel for Petitioners
`
`Registration No. 32,271

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