`IPR2014-00802
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`FUJITSU SEMICONDUCTOR LIMITED, FUJITSU SEMICONDUCTOR
`AMERICA, INC., ADVANCED MICRO DEVICES, INC., RENESAS
`ELECTRONICS CORPORATION, RENESAS ELECTRONICS
`AMERICA, INC., GLOBAL FOUNDRIES U.S., INC.,
`GLOBALFOUNDRIES DRESDEN MODULE ONE LLC & CO. KG,
`GLOBALFOUNDRIES DRESDEN MODULE TWO LLC & CO. KG,
`TOSHIBA AMERICA ELECTRONIC COMPONENTS, INC., TOSHIBA
`AMERICA INC., TOSHIBA AMERICA INFORMATION SYSTEMS,
`INC., TOSHIBA CORPORATION, and THE GILLETTE COMPANY,
`
`Petitioners
`v.
`ZOND, LLC
`Patent Owner
`_____________________
`Inter Partes Review Case No. IPR2014-008021
`Patent 7,811,421
`_____________________
`
`
`
`
`
`PATENT OWNER’s REQUEST FOR ORAL ARGUMENT
`
`37 C.F.R. §42.70
`
`
`
`
`1 Cases IPR2014-00848, IPR2014-00992, and IPR2014-01071 have been joined
`with the instant proceeding.
`
`
`
`
`Patent No. 7,811,421
`IPR2014-00802
`
`Pursuant to 37 C.F.R. §42.70(a), Patent Owner, Zond, LLC, respectfully
`
`requests oral argument on the issues set forth below at a place and time set by
`
`the Board. Oral argument is presently scheduled for June 8, 2015 (Paper No.
`
`31). To allow for complete review of the issues presented in this proceeding,
`
`Patent Owner requests at least one hour of argument time.
`
`ISSUES TO BE ADRESSED DURING ORAL ARGUMENT
`
`1. Whether challenged claims 9, 21 and 35 are unpatentable under 35
`
`U.S.C. § 103 as obvious in view of Wang and Kudryavtsev.
`
`2. Whether challenged claims 14, 26, 37 are unpatentable under 35 U.S.C.
`
`§ 103 as obvious in view of Wang and Mozgrin’s Thesis.
`
`3. Reply to any arguments raised by Petition in its papers and its
`
`presentation on all matters.
`
`
`Date: May 17, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`/Bruce Barker/
`Bruce Barker
`Reg. No. 33,291
`Chao Hadidi Stark & Barker LLP
`176 East Main Street, Suite 6
`Westborough, MA 01581
`(508) 366-3800
`bbarker@chsblaw.com
`
`1
`
`
`
`Patent No. 7,811,421
`IPR2014-00802
`
`CERTIFICATE OF SERVICE
`
`
`The undersigned hereby certifies that a copy of the foregoing Patent
`
`Owner’s Request for Oral Argument was served pursuant to 37 CFR § 42.107
`
`via email on May 17, 2015, on the attorneys for the Petitioner:
`
`GlobalFoundries:
`David Tennant
`dtennant@whitecase.com
`Dohm Chankong
`dohm.chankong@whitecase.com
`
`Toshiba:
`Robinson Vu
`robinson.vu@bakerbotts.com
`
`Fujitsu:
`David L. McCombs
`david.mccombs.ipr@haynesboone.com
`David M O’Dell
`david.odell.ipr@haynesboone.com
`
`Gillette:
`David Cavanaugh
`david.cavanaugh@wilmerhale.com
`Larissa B. Park
`larissa.park@wilmerhale.com
`
`
`/Bruce Barker/
`Bruce Barker; Reg. No. 33,291
`Chao Hadidi Stark & Barker LLP
`176 East Main Street, Suite 6
`Westborough, MA 01581
`(508) 366-3800
`bbarker@chsblaw.com
`
`2
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