`
`_______________________________
`
`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 No. IPR2014-01121
`U.S. Patent No. 7,626,349
`
`_______________________________
`
`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
`
`Request for Oral Argument -:1810085
`
`
`
`Pursuant to the Board’s January 21, 2015, Scheduling Order (Paper No. 21),
`
`Petitioners Zhongshan Broad Ocean Motor Co., Ltd., Broad Ocean Motor, LLC,
`
`and Broad Ocean Technologies, LLC (collectively, “Broad Ocean”), respectfully
`
`requests oral argument for the trial currently scheduled on October 16, 2015.
`
`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 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).
`
`II. Whether Patent Owner has established commercial success and the requisite
`
`nexus of any alleged commercial success to the novel portions of the
`
`challenged claims sufficient to overcome Petitioner’s prima facie case of
`
`obviousness; and
`
`III. Whether evidence should be excluded as identified in Petitioner’s Motion to
`
`Exclude.
`
`Request for Oral Argument -:1810085
`
`
`
`Dated: September 21, 2015
`
`Respectfully submitted,
`
`By: /s/ Charles S. Baker
`Charles S. Baker
`(Admitted Pro Hac Vice)
`Locke Lord LLP
`2800 JPMorgan Chase Tower
`600 Travis
`Houston, TX 77002-3095
`Telephone: 713-226-1200
`Facsimile: 713-223-3717
`cbaker@lockelord.com
`
`Attorneys for Petitioners BROAD
`OCEAN MOTOR LLC, BROAD OCEAN
`TECHNOLOGIES, LLC, and
`ZHONGSHAN BROAD OCEAN
`MOTOR CO., LTD.
`
`Request for Oral Argument -:1810085
`
`
`
`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 September 21, 2015, 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.
`
`the undersigned certifies that on September 21, 2015, a
`Additionally,
`complete and entire copy of the foregoing PETITIONERS’ REQUEST FOR
`ORAL ARGUMENT was electronically served on the Patent Owner’s below-
`listed
`counsel
`of
`record
`at
`jschwent@thompsoncoburn.com,
`djinkins@thompsoncoburn.com,
`and
`syoo@thompsoncoburn.com,
`in
`the
`co-pending litigation Nidec Motor 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: September 21, 2015
`
`/s/ Charles S. Baker
`Steven F. Meyer (Reg. No. 35,613)
`Charles S. Baker (pro hac vice)
`LOCKE LORD LLP
`Three World Financial Center
`New York, New York 10281-2101
`
`Attorneys for Petitioners Zhongshan
`Broad Ocean Motor Co., Ltd.;
`Broad Ocean Motor LLC; and
`Broad Ocean Technologies, LLC
`
`Request for Oral Argument -:1810085
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