`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`
`FORD MOTOR COMPANY
`Petitioner,
`
`v.
`
`PAICE LLC & ABELL FOUNDATION, INC.
`Patent Owner.
`
`______________
`
`
`U.S. Patent No. 7,237,634
`
`IPR Case No.: IPR2014-00904
`
`
`
`______________
`
`
`
`
`
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`
`
`Case No.: IPR2014-00904
`Attorney Docket No.: FPGP0104IPR1
`
`
`
`Pursuant to 37 C.F.R. § 42.70(a), Petitioner, Ford Motor Company submits
`
`this Request for Oral Argument on all of the instituted grounds of unpatentability
`
`of U.S. Patent No. 7,237,634.
`
`The Board has already scheduled the Oral Hearing for IPR2014-00904 as
`
`well as for the following related IPRs on July 1, 2015:
`
`1. IPR2014-00570 (USPN 8,214,097)
`
`2. IPR2014-00571 (USPN 7,104,347)
`
`3. IPR2014-00579 (USPN 7,104,347)
`
`4. IPR2014-00875 (USPN 7,559,388)
`
`5. IPR2014-00884 (USPN 7,104,347)
`
`Concerning the total oral hearing time for the above six IPRs, the Petitioner
`
`and the Patent Owner jointly propose a total of 3.5 hours per side, which averages
`
`to only 35 minutes per IPR. Additionally, the Board indicated in an order for
`
`related later-filed IPRs (see, e.g. IPR2015-00606, Paper 9, pp. 2-3) that the above
`
`IPRs may impact those later-filed IPRs, so the parties would appreciate whatever
`
`time the Board can grant.
`
`Concerning procedure, the parties also believe it would be helpful to group
`
`these IPRs into three groups, and finish one group before beginning the next. The
`
`parties agree on the following groups:
`
`
`
`1
`
`
`
`Case No.: IPR2014-00904
`Attorney Docket No.: FPGP0104IPR1
`
`1.
`
`2.
`
`3.
`
`IPR2014-00571 (‘347 Patent) and IPR2014-00904 (‘634 Patent)
`
`IPR2014-00579 (‘347 Patent) and IPR2014-00884 (‘347 Patent)
`
`IPR2014-00570 (‘097 Patent) and IPR2014-00875 (‘388 Patent)
`
`Without intent to waive consideration of any issue not requested, Petitioner
`
`requests oral argument on the following issues for IPR2014-00904:
`
`1. Whether Patent Owner’s proposed claim construction for “setpoint”
`
`should be rejected;
`
`2. Whether claims 1, 14, 16, 18, and 24 of the ’634 Patent are obvious
`
`under 35 U.S.C. § 103 in view of Severinsky, SAE, and Field;
`
`3.
`
`4.
`
`Any motion filed by Patent Owner, including any motion to exclude;
`
`Any argument not specifically identified that is raised by Patent
`
`Owner at oral argument; and
`
`5.
`
`Any issue that the Board requests.
`
`
`
`
`
`Dated: June 9, 2015
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
` /Frank A. Angileri/
`Frank A. Angileri (Reg. No. 36,733)
`BROOKS KUSHMAN P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`
`Lissi Mojica (Reg. No. 63,421)
`Kevin Greenleaf (Reg. No. 64,062)
`DENTONS US LLP
`1530 Page Mill Road, Suite 200
`Palo Alto, CA 94304-1125
`
`Attorneys for Petitioner
`
`2
`
`
`
`
`
`Case No.: IPR2014-00904
`Attorney Docket No.: FPGP0104IPR1
`
`Certificate of Service
`
`The undersigned hereby certifies that on June 9, 2015, a complete and entire
`
`copy of Petitioner’s Request For Oral Argument, was served via electronic mail
`
`by serving the correspondence email address of record as follows:
`
`LEAD COUNSEL
`Timothy W. Riffe, Reg. No. 43,881
`
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Tel: (202) 783-5070
`Email: IPR36351-0015IP1@fr.com;
`
`Riffe@fr.com; Greene@fr.com
`
`BACK-UP COUNSEL
`Kevin E. Greene, Reg. No. 46,031
`Ruffin B. Cordell, Reg. No. 33,487
`Linda L. Kordziel, Reg. No. 39,732
`
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Tel: (202) 783-5070
`Email: IPR36351-0015IP1@fr.com;
`
`Riffe@fr.com; Greene@fr.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
` /Frank A. Angileri/
`Frank A. Angileri (Reg. No. 36,733)
`John E. Nemazi (Reg. No. 30,876)
`John P. Rondini (Reg. No. 64,949)
`Erin K. Bowles (Reg. No. 64,705)
`Brooks Kushman P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`(248) 358-4400
`
`Lissi Mojica (Reg. No. 63,421)
`Kevin Greenleaf (Reg. No. 64,062)
`Dentons US LLP
`1530 Page Mill Road, Suite 200
`Palo Alto, CA 94304-1125
`650 798 0300
`
`Attorneys for Petitioner
`
`3
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
