`U.S. Patent No. 6,366,130
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`Attorney Docket No.
`ELBRUS-IPR2
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD.
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`Petitioner
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`V.
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`ELBRUS INTERNATIONAL LIMITED
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`Patent Owner
`
`Case: IPR2015-01524
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`U.S. Patent No. 6,366,130
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`PATENT OWNER'S REQUEST FOR ORAL ARGUMENT
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`
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`Pursuant to 37 C.F.R. § 42.70(a) and the Board's Scheduling Order
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`(Paper 15), the Patent Owner requests oral argument, which is currently
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`scheduled for October 18, 2016. The Patent Owner expects to argue the
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`following issues at the oral argument:
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`(1)
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`The Petitioner has failed to make a primafacie case of
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`obviousness for claims 1, 2, 5, 6 and 9 in the combination
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`Sukegawa in View of Lu because:
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`(a) no differential data bus (second bus) is taught or
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`suggested in the combination; and
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`(b) the combination fails to teach or suggest precharging
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`two separate buses to Vpr = k * Vdd, where k is
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`between 0 and l.
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`(2)
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`The addition of the Wantanabe reference to the combination
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`still fails to make a primafacie case of obviousness for claim 3.
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`The Patent Owner acknowledges that the Petitioner filed a notice that
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`it would not request oral argument; but would appear if the Patent Owner so
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`requested. Hence, both sides will evidently appear.
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`The Patent Owner also kindly requests that the Board provide a
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`projector and screen for use during oral argument.
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`
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`Dated: Sept. 12, 2016
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`Respectfully submitted
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`/Clifford kraft/
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`Clifford H. Kraft
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`Reg. No. 35,229
`Lead Counsel for Patent Owner
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`/joseph hosteny/
`Joseph N. Hosteny
`Reg. No. 28,020
`Back-up Counsel for Patent Owner
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`
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`CERTIFICATE OF SERVICE
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`IPR 2015-01524
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`The undersigned hereby certifies that the foregoing Request for Oral
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`Argument was served on Sept. 12, 2016 by filing this document through the
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`Patent Review Processing System as well as delivering a copy via electronic
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`mail upon the following attorneys of record for the Petitioner:
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`Naveen Modi
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`naveenmodi@paulhastings.com
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`Steven L. Park
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`stevenpark@paulhastings.com
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`Dated: Sept. 12, 2016
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`Respectfully submitted
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`/clifford kraft/
`
`Clifford H. Kraft
`
`Reg. No. 35,229
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`/joseph hosteny/
`Joseph N. Hosteny
`Reg. No. 28,020