`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________________________________________
`GLOBALFOUNDRIES U.S., INC., GLOBALFOUNDRIES DRESDEN
`MODULE ONE LLC & CO. KG, GLOBALFOUNDRIES DRESDEN
`MODULE TWO LLC & CO. KG, and THE GILLETTE COMPANY,
`Petitioners,
`
`v.
`
`ZOND, LLC,
`Patent Owner
`_____________________
`
`Case No. IPR2014-010891
`Patent 6,806,652 B2
`________________________
`
`
`
`
`
`
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`37 C.F.R. § 42.70
`
`
`
`
`
`
`
`1 Case IPR2014-01004 has been joined with the instant proceeding.
`
`
`
`1
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`
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`Pursuant to 37 C.F.R. § 42.70(a), Patent Owner, Zond, LLC, respectfully
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`requests oral argument on the issues set forth below at a place and time set by the
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`Board. Oral argument is presently scheduled for August 13, 2015 (Paper No. 15,
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`Scheduling Order).
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`U.S. Patent 6,806,652 is also the subject of IPR2014-00861 and IPR2014-
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`01088. Concurrently with this Request for Oral Argument, Patent Owner is
`
`requesting oral argument in each of these concurrent proceedings. Because the
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`issues presented in this IPR2014-01089 are similar to those presented in IPR2014-
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`00861 and IPR2014-01088, involve the same parties, and the same cited
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`references, Patent Owner requests that the oral hearings for IPR2014-00861,
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`IPR2014-01088 and IPR2014-01089 be consolidated in a single hearing. To allow
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`for a complete review of the issues presented in all of the pending proceedings,
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`Patent Owner requests a total of one hour of argument time.
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`
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`ISSUES TO BE ADDRESSED DURING CONSOLIDATED ORAL
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`HEARING.
`
`A. Claims 1-14, 16-30, and 33-35 are patentable over Mozgrin,
`
`Kudryavtsev, Fahey, and Iwamura.
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`B.
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`Claim 5 is patentable over Mozgrin, Kudryavtsev, Fahey, Vratny, and
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`Iwamura.
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` 2
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`
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`C.
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`Claims 8-10 are patentable over Mozgrin, Kudryavtsev, Fahey,
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`Lantsman, and Iwamura.
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`D. Claim 15 is patentable over Mozgrin, Kudryavtsev, Fahey, Wang, and
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`Iwamura.
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`E.
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`Claims 31 and 32 are patentable over Mozgrin, Kudryavtsev, Fahey,
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`Campbell, and Iwamura.
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`F.
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`Claims 18-30 are patentable over Mozgrin and Iwamura.
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`G. Claims 31 and 32 are patentable over Mozgrin, Iwamura, and Campbell.
`
`H. Claims 33-35 are patentable over Mozgrin, Iwamura, and Fahey.
`
`I.
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`Claim 35 is patentable over Mozgrin, Kudryavtsev, Iwamura, and Fahey.
`
`
`
`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
`
`Counsel for Patent Owner Zond LLC
`
`
`
` 3
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`
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`Date: July 20, 2015
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`
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`
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`CERTIFICATE OF SERVICE
`
`
`The undersigned hereby certifies that a copy of the foregoing
`PATENT OWNER’S REQUEST FOR ORAL HEARING
`
`was served on July 20, 2015, by filing this document though the Patent Review
`Processing System as well as delivering a copy via electronic mail directed to the
`attorneys of record for the Petitioner at the following address:
`For Petitioner:
`For Petitioner:
`GLOBALFOUNDRIES U.S., INC.,
`THE GILETTE COMPANY
`GLOBALFOUNDRIES DRESDEN
`David L. Cavanaugh, Reg. No. 36,476
`Larissa Park, Reg. No. 59,051
`MODULE ONE LLC & CO. KG, and
`Wilmer Cutler Pickering Hale and
`GLOBALFOUNDRIES DRESDEN
`Dorr LLP
`MODULE TWO LLC & CO. KG
`60 State Street
`David M. Tennant
`Boston, MA 02109
`WHITE & CASE LLP
`Tel: (617) 526-5000
`701 THIRTEENTH STREET, NW
`Email:
`WASHINGTON, DC 20005
`david.cavanaugh@wilmerhale.com;
`dtennant@whitecase.com
`Larissa.Park@wilmerhale.com
`dchankong@whitecase.com
`
`
`
`The parties have agreed to electronic service in this matter.
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`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
`
`by:
`
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`
`
`Date: July 20, 2015
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