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Paper No. __
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`
`GREENE’S ENERGY GROUP, LLC
`Petitioner
`
`
`v.
`
`
`OIL STATES ENERGY SERVICES, LLC
`Patent Owner
`
`____________
`
`
`Case IPR2014-00216
`Patent 6,179,053
`
`Case IPR2014-00364
`Patent 6,289,993
`
`________________________________________________
`
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`
`
`
`

`

`Case IPR2014-00216 (Patent No. 6,179,053)
`Case IPR2014-00364 (Patent No. 6,289,993)
`Petitioner’s Request For Oral Argument
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.70, Petitioner Greene’s Energy Group, LLC
`
`
`
`
`
`(“Petitioner”) hereby requests oral argument in the above-captioned matters,
`
`IPR2014-00216 and IPR2014-00364, for the following issues:
`
`(i)
`
`whether Canadian Application 2,195,118 (“Dallas ’118”)
`
`anticipates claims 1 and 22 of U.S. Patent No. 6,179,053 (the “’053
`
`patent”);
`
`(ii)
`
`whether Patent Owner’s motion to amend claims 1 and 22 of the
`
`’053 patent should be granted;
`
`(iii)
`
`the instituted grounds of unpatentability for the challenged claims
`
`of U.S. Patent No. 6,289,993 (the “’993 patent”);
`
`(iv)
`
`any issue raised in Patent Owner’s reply to Petitioner’s opposition
`
`to the motion to amend, which has yet to be filed;
`
`(v)
`
`any issues raised in any motions for observation regarding cross-
`
`examination of reply witness or motions to exclude evidence,
`
`which have yet to be filed; and
`
`(vi)
`
`any other issue raised by either Patent Owner or the Board.
`
`Further, for both matters, the Board has scheduled oral argument for
`
`February 11, 2015. See Paper 13, p. 6. Petitioner also requests that it be allowed
`
`to use computer equipment to display demonstrative exhibits, including the use of
`
`a projector and screen for PowerPoint display.
`2
`
`
`
`
`
`

`

`Case IPR2014-00216 (Patent No. 6,179,053)
`Case IPR2014-00364 (Patent No. 6,289,993)
`Petitioner’s Request For Oral Argument
`
`
`
`
`
`Last, the parties came to an agreement regarding a proposed schedule. The
`
`
`
`
`
`parties propose that each side be given a total of 90 minutes, which would be
`
`divided evenly amongst: (1) the ’053 patent petition; (2) the ’053 patent motion to
`
`amend; and (3) the ’993 patent petition. For each issue, the party bearing the
`
`burden of proof would open with 20 minutes of argument and reserve 10 minutes
`
`for reply arguments, and the opposing party would be given 30 minutes of rebuttal
`
`arguments. Accordingly, the parties propose the following schedule:
`
`(1) ’053 patent petition (total of 60 min.) – Petitioner argument (20 min.), Patent
`
`Owner rebuttal (30 min.), and Petitioner reply (10 min.);
`
`(2) ’053 patent motion to amend (total of 60 min.) – Patent Owner argument (20
`
`min.), Petitioner rebuttal (30 min.), and Patent Owner reply (10 min);
`
`(3) ’993 patent petition (total of 60 min.) – Petitioner argument (20 min.), Patent
`
`Owner rebuttal (30 min.), and Petitioner reply (10 min).
`
`
`
`Dated: January 7, 2015
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
` /John J. Feldhaus /
`John J. Feldhaus
`Reg. No. 28,822
`jfeldhaus@foley.com
`Foley & Lardner LLP
`3000 K Street NW, Suite 600
`Washington, DC 20007
`Tel: 202.672.5403
`3
`
`

`

`Case IPR2014-00216 (Patent No. 6,179,053)
`Case IPR2014-00364 (Patent No. 6,289,993)
`Petitioner’s Request For Oral Argument
`
`
`
`
`
`
`
`
`
`
`
`
`Fax: 202.672.5399
`
`Counsel for Petitioner
`
`
`
`
`
`
`
`
`
`4
`
`

`

`Case IPR2014-00216 (Patent No. 6,179,053)
`Case IPR2014-00364 (Patent No. 6,289,993)
`Petitioner’s Request For Oral Argument
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.6(e)(4)(i), the undersigned certifies that on
`
`January 7, 2015, a complete and entire copy of “Petitioner’s Request For Oral
`
`Argument” was provided via email, as previously agreed, to the representatives of
`
`the Patent Owner by serving the correspondence email address of record as follows
`
`(for both IPR2014-00216 and IPR2014-00364):
`
`Erik Hawes
`ehawes@morganlewis.com
`
`Archis (Neil) Ozarkar
`nozarkar@morganlewis.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
` /John J. Feldhaus /
`John J. Feldhaus
`Reg. No. 28,822
`jfeldhaus@foley.com
`Foley & Lardner LLP
`3000 K Street NW, Suite 600
`Washington, DC 20007
`Tel: 202.672.5403
`Fax: 202.672.5399
`
`Counsel for Petitioner
`
`5
`
`

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