`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`GLOBAL FOUNDRIES 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. IPR2014-011001
`Patent 7,604,716 B2
`____________
`
`
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`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`37 C.F.R. § 42.70
`
`
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`
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`1 Case IPR 2014-00973 has been joined with the instant proceeding.
`
`
`
`1
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`
`
`Pursuant to 37 C.F.R. § 42.70(a), Patent Owner, Zond, LLC, respectfully
`
`Patent No. 7,604,716
`IPR2014-01100
`
`
`
`requests oral argument at a place and time set by the Board. Oral argument is
`
`presently scheduled for June 12, 2015 (Paper No. 10, Scheduling Order).
`
`The present proceeding involves U.S. Patent 7,604,716, which is also at
`
`issue in IPR2014-00807, IPR2014-00808, and IPR2014-01099. Concurrently with
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`this request for oral argument, similar requests are being filed in each of these
`
`related proceedings. Patent Owner requests that, for the convenience of the parties
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`and the Board, a single oral hearing be conducted on all the issues in these
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`proceedings, as set forth below. To allow for a complete review of these issues,
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`Patent Owner requests one hour of argument time.
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`
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`ISSUES TO BE ADDRESSED DURING ORAL ARGUMENT
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`A. Claims 1-11, and 33 are patentable under 35 U.S.C. § 102 over Wang
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`(IPR2014-01099);
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`B.
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`Claims 12 and 13 are patentable under 35 U.S.C. § 103(a) over Wang and
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`Lantsman (IPR2014-01100);
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`C.
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`Claims 14-18 and 25-32 are patentable under 35 U.S.C. § 103(a) over
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`Wang and Kudryavtsev (IPR2014-00807);
`
`D. Claim 21 is patentable under 35 U.S.C. § 103(a) over Wang and
`
`Kudryavtsev (IPR2014-00808);
`
` 2
`
`
`
`Patent No. 7,604,716
`IPR2014-01100
`
`E.
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`Claims 19 and 20 are patentable under 35 U.S.C. § 103(a) over Wang,
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`Kudryavtsev, and Lantsman (IPR2014-00808); and
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`F.
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`Claims 22-24 are patentable under 35 U.S.C. § 103(a) over Wang,
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`Kudryavtsev, and Mozgrin (IPR2014-00808).
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`
`
`Date: May 15, 2015
`
`Respectfully submitted,
`
`
`/Tarek N. Fahmi/
`
`
`Tarek N. Fahmi, Reg. No. 41,402
`Ascenda Law Group, PC
`333 W. San Carlos St., Suite 200
`San Jose, CA 95110
`1 866 877 4883
`tarek.fahmi@ascendalaw.com
`
`Counsel for Patent Owner Zond, LLC
`
`
`
`
`
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` 3
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`CERTIFICATE OF SERVICE
`
`Patent No. 7,604,716
`IPR2014-01100
`
`
`The undersigned hereby certifies that a copy of the foregoing
`PATENT OWNER’S REQUEST FOR ORAL HEARING
`
`was served on May 15, 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:
`
`THE GILETTE COMPANY
`For Petitioner:
`
`GLOBAL FOUNDRIES U.S., INC.,
`David L. Cavanaugh, Reg. No. 36,476
`GLOBALFOUNDRIES DRESDEN
`Larissa Park, Reg. No. 59,051
`MODULE ONE LLC & CO. KG,
`Wilmer Cutler Pickering Hale and
`GLOBALFOUNDRIES DRESDEN
`Dorr LLP
`MODULE TWO LLC & CO. KG
`60 State Street
`
`Boston, MA 02109
`David M. Tennant
`Tel: (617) 526-5000
`WHITE & CASE LLP
`Email:
`701 THIRTEENTH STREET, NW
`David.Cavanaugh@wilmerhale.com;
`WASHINGTON, DC 20005
`Larissa.Park@wilmerhale.com
`dtennant@whitecase.com
`
`
`The parties have agreed to electronic service in this matter.
`
`
`
`Date: May 15, 2015
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`Respectfully submitted,
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`by:
`
`
` /Tarek N. Fahmi/
`
`
`Tarek N. Fahmi, Reg. No. 41,402
`
`
`
`Ascenda Law Group, PC
`333 W. San Carlos St., Suite 200
`San Jose, CA 95110
`1 866 877 4883
`
`
`
`
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