`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________
`
`
`
`
`
`VMWARE, INC., INTERNATIONAL
`BUSINESS MACHINES CORPORATION
`AND
`ORACLE AMERICA, INC.,
`Petitioners,
`
`v.
`
`ELECTRONICS AND TELECOMMUNICATIONS RESEARCH
`INSTITUTE,
`Patent Owner.
`
`________________
`
`
`
`Case IPR2014-00949
`Case IPR2014-00901
`Patent No. 6,978,346 B2
`
`__________________
`
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`Pursuant to 37 C.F.R. § 42.70(a) and the Board’s Scheduling Order (Paper
`
`15), the Patent Owner requests oral argument, which is currently scheduled for
`
`August 28, 2015. The Patent Owner expects to argue the following issues at the
`
`oral argument:
`
`(1) Whether the Petitioner has met its burden to show that Mylex in view
`
`of Hathorn renders obvious claims 1-9 of the ’346 Patent.
`
`(2) Claim interpretations relevant to issue (1), including, for example, the
`
`interpretation of “RAID,” “exchanges information,” “hub,” and
`
`“switch.”
`
`The Patent Owner also kindly requests that the Board provide a projector
`
`and screen for use during the oral argument.
`
`Respectfully submitted,
`
`Date: 2015 July 23
`
`By: / M.C. Phillips /
`
`Derek Meeker
`Reg. No. 53,313
`Backup Counsel for Patent Owner
`Renaissance IP Law Group LLP
`7327 SW Barnes Road #521
`Portland, Oregon 97223
`Telephone: (360) 606-8922
`Facsimile: (503) 517-9919
`derek.meeker@renaissanceiplaw.com
`
`Matthew C. Phillips
`Reg. No. 43,403
`Lead Counsel for Patent Owner
`Renaissance IP Law Group LLP
`7327 SW Barnes Road #521
`Portland, Oregon 97223
`Telephone: (503) 964-1129
`Facsimile: (503) 517-9919
`matthew.phillips@renaissanceiplaw.com
`
`IPR2014-00901
`IPR2014-00949
`
`Response
`
`Page 1 of 1
`
`
`
`CERTIFICATE OF SERVICE
`
`I certify that on July 24, 2015, the foregoing PATENT OWNER’S
`
`REQUEST FOR ORAL ARGUMENT, including all attached papers filed
`
`therewith, have been served on the Petitioners’ counsel of record via email, as
`
`agreed to by counsel, at the following email addresses:
`
`IPR2014-00901:
`
`Katherine Kelly Lutton: IPR27450-0011IP1@fr.com
`
`Timothy W. Riffe: IPR27450-0011IP1@fr.com
`
`Michael Rueckheim: IPR27450-0011IP1@fr.com
`
`Leeron Kalay: IPR27450-0011IP1@fr.com
`
`IPR2014-00949:
`
`Todd M. Friedman: IBM-Safe-Storage-KEService@kirkland.com
`
`Gregory S. Arovas: IBM-Safe-Storage-KEService@kirkland.com
`
`Eugene Goryunov: IBM-Safe-Storage-KEService@kirkland.com
`
`Benjamin Lasky: IBM-Safe-Storage-KEService@kirkland.com
`
`/ M.C. Phillips /
`Matthew C. Phillips
`Reg. No. 43,403
`
`IPR2014-00901
`IPR2014-00949
`
`Req. Oral Argument COS
`
`Page 1 of 1
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