`___________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________
`
`ZHONGSHAN BROAD OCEAN MOTOR CO., LTD.;
`BROAD OCEAN MOTOR, LLC; AND
`BROAD OCEAN TECHNOLOGIES, LLC
`Petitioners
`
`v.
`
`NIDEC MOTOR CORPORATION
`Patent Owner
`___________________________
`
`Case IPR2014-011211
`Patent 7,626,349
`___________________________
`
`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
`
`1 Case IPR2015-00762 has been joined with this proceeding.
`
`NY 812599v.1
`
`
`
`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
`
`Pursuant to the Board’s October 13, 2015 Supplemental Scheduling
`
`Order (Paper No. 70), Petitioners Zhongshan Broad Ocean Motor Co., Ltd., Broad
`
`Ocean Motor, LLC, and Broad Ocean Technologies, LLC (collectively, “Broad
`
`Ocean”), respectfully request oral argument for the trial currently scheduled on
`
`February 23, 2016.
`
`Issues For Hearing
`
`Pursuant to 37 C.F.R. §42.70, Petitioners specify the following issues
`
`to be argued:
`
`I.
`
`Whether claims 1-3, 8, 9, 12, 16 and 19 of the ‘349 patent are
`
`anticipated by Hideji Japanese Patent Publication JP2003-348885.
`
`II. Whether claims 1-3, 8, 9, 12, 16 and 19 of the ‘349 patent are obvious
`
`over U.S. Patent No. 5,410,230 to Bessler, in view of Kocybik, Electronic Control
`
`of Torque Ripple in Brushless Motors (University of Plymouth, July 2000).
`
`III. Whether Patent Owner has established commercial success and the
`
`requisite nexus of any alleged commercial success to the challenged claims
`
`sufficient to overcome Petitioner’s prima facie case of obviousness;
`
`IV. Whether Patent Owner satisfied its burden of proof for showing
`
`support for proposed amended claims 21-23 in the ‘349 patent specification and for
`
`NY 812599v.1
`
`- 1 -
`
`
`
`showing the patentability of proposed amended claims 21-23 over the prior art of
`
`record known to Patent Owner.
`
`V. Whether evidence should be excluded as identified in Petitioner’s
`
`Motion to Exclude.
`
`Dated: February 3, 2016
`
`Respectfully submitted,
`
`/ Steven F. Meyer /
`Steven F. Meyer (Reg. No. 35,613)
`LOCKE LORD LLP
`Brookfield Place
`200 Vesey Street, 20th Floor
`New York, New York 10281-2101
`(212) 415-8535
`smeyer@lockelord.com
`
`Attorneys for Petitioners Zhongshan
`Broad Ocean Motor Co., Ltd.;
`Broad Ocean Motor LLC; and
`Broad Ocean Technologies, LLC
`
`NY 812599v.1
`
`- 2 -
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §42.6(e) and 37 C.F.R. §42.105(b), the undersigned
`hereby certifies that on February 3, 2016, a complete and entire copy of the
`foregoing Petitioners’ Request For Oral Argument was electronically served in
`its entirety on the Patent Owner of record (as agreed upon by counsel) at
`sbrown@hoveywilliams.com, mwalters@hoveywilliams.com,
`and litigation@
`hoveywilliams.com.
`
`Additionally, the undersigned certifies that on February 3, 2016, a complete
`this Petitioners’ Request For Oral Argument was
`and entire copy of
`electronically served on the Patent Owner’s below-listed counsel of record at
`jschwent@thompsoncoburn.com,
`djinkins@thompsoncoburn.com,
`and
`litigation Nidec Motor
`the
`syoo@thompsoncoburn.com,
`in
`co-pending
`Corporation
`v. Broad Ocean Motor LLC et
`al., Civil Action No.
`4:13-CV-01895-JCH (E.D. Mo.), as agreed upon by the parties.
`
`Dated: February 3, 2016
`
`/ Steven F. Meyer /
`Steven F. Meyer (Reg. No. 35,613)
`LOCKE LORD LLP
`Three World Financial Center
`New York, New York 10281-2101
`(212) 415-8535
`smeyer@lockelord.com
`
`Attorneys for Petitioner Zhongshan
`Broad Ocean Motor Co., Ltd.;
`Broad Ocean Motor LLC; and
`Broad Ocean Technologies, LLC
`
`NY 812599v.1
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