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UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`UMICORE AG & CO. KG
`
`Petitioner
`
`v.
`
`BASF CORPORATION
`
`Patent Owner
`
`Case IPR2015-01125
`U.S. Patent 7,601,662
`
`__________________________________________________________________
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`__________________________________________________________________
`
`

`
`Pursuant to 37 C.F.R. § 42.70(a), Petitioner Umicore AG & CO. KG
`
`(“Umicore”) hereby respectfully requests oral argument, as currently scheduled for
`
`July 28, 2016. Petitioner believes that the issues implicated by Cases IPR2015-
`
`1121, -1123, -1124, and -1125 can be addressed collectively at a single hearing.
`
`Petitioner respectfully requests that each side be allotted 2 hours to present its
`
`arguments regarding all four IPRs. Petitioner believes the following issues should
`
`be argued:
`
`I.
`
`All instituted grounds in IPR2015-1121:
`
`A. Whether claims 1–8 and 30 of the ’662 patent are unpatentable
`
`under 35 U.S.C. § 103 as obvious over the combination of
`
`Zones and Maeshima; and
`
`B. Whether claims 12–24 and 32–50 of the ’662 patent are
`
`unpatentable under 35 U.S.C. § 103 as obvious over the
`
`combination of Zones, Maeshima, and Patchett.
`
`II. All instituted grounds in IPR2015-1123:
`
`A. Whether claims 1, 14, 15, 17–22, 26, and 27 of the ’203 patent
`
`are unpatentable under 35 U.S.C. § 103(a) as obvious over the
`
`combination of Zones and Maeshima; and
`
`-1-
`
`

`
`B. Whether claims 2–13, 16, 23–25, and 28–31 of the ’203 patent
`
`are unpatentable under 35 U.S.C. § 103(a) as obvious over the
`
`combination of Zones, Maeshima, and Patchett.
`
`III. All instituted grounds in IPR2015-1124:
`
`A. Whether claims 1, 14, 15, 19, 20, 26, and 27 of the ’203 patent
`
`are unpatentable under 35 U.S.C. § 103(a) as obvious over the
`
`combination of Maeshima and Breck;
`
`B. Whether claims 2–13, 16, 23–25, and 28–31 of the ’203 patent
`
`are unpatentable under 35 U.S.C. § 103(a) as obvious over the
`
`combination of Maeshima, Breck, and Patchett;
`
`C. Whether claims 1, 14, 15, 19, 20, 26, and 27 of the ’203 patent
`
`are unpatentable under 35 U.S.C. § 103(a) as obvious over the
`
`combination of Dedecek and Breck; and
`
`D. Whether claims 2–13, 16, 23–25, and 28–31 of the ’203 patent
`
`are unpatentable under 35 U.S.C. § 103(a) as obvious over the
`
`combination of Dedecek, Breck, and Patchett.
`
`IV. All instituted grounds in IPR2015-1125:
`
`A. Whether claims 1, 2, 5, 6, and 30 of the ’662 patent are
`
`unpatentable under 35 U.S.C. § 103 as obvious over the
`
`combination of Maeshima and Breck;
`
`-2-
`
`

`
`B. Whether claims 12–24 and 32–38 of the ’662 patent are
`
`unpatentable under 35 U.S.C. § 103 as obvious over the
`
`combination of Maeshima, Breck, and Patchett;
`
`C. Whether claims 1, 2, 5, 6, and 30 of the ’662 patent are
`
`unpatentable under 35 U.S.C. § 103 as obvious over the
`
`combination of Dedecek and Breck; and
`
`D. Whether claims 12–24 and 32–38 of the ’662 patent are
`
`unpatentable under 35 U.S.C. § 103 as obvious over the
`
`combination of Dedecek, Breck, and Patchett.
`
`V.
`
`The issues raised by Petitioner’s motion to exclude.
`
`VI. Rebuttal on other matters properly before the Board.
`
`Petitioner also respectfully requests to use audio visual equipment to display
`
`possible demonstrative exhibits, including the use of a projector and screen.
`
`Date: 6/20/2016
`
`Respectfully Submitted,
`
`/ Elizabeth Gardner /
`Elizabeth Gardner (Reg. No. 36,519)
`Orrick, Herrington, & Sutcliffe LLP
`51 West 52nd Street
`New York, NY 10019
`Tel: 212-506-5000
`Fax. 212-506-5151
`Email: egardner@orrick.com
`
`-3-
`
`

`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby confirms that the foregoing PETITIONER’S
`
`REQUEST FOR ORAL ARGUMEN T was served on June 20, 2016 via e-mail
`
`upon the following counsel of record for Patent Owner:
`
`Brian E. Ferguson (brian.ferguson@weil.com)
`Anish R. Desai (anish.desai@weil.com)
`Weil, Gotshal & Manges LLP
`1300 Eye Street, NW Suite 900
`Washington, DC 20005
`
`/ Elizabeth Gardner /
`Elizabeth Gardner (Reg. No. 36,519)
`Orrick, Herrington, & Sutcliffe LLP
`51 West 52nd Street
`New York, NY 10019
`Tel: 212-506-5000
`Fax. 212-506-5151
`Email: egardner@orrick.com
`
`-4-

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