`__________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________
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`LAM RESEARCH CORP.,
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`Petitioner
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`v.
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`DANIEL L. FLAMM,
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`Patent Owner
`___________
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`U.S. Patent No. 6,017,221
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`Issued: January 5, 2000
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`Named Inventor: Daniel L. Flamm
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`Title: PROCESS DEPENDING ON PLASMA DISCHARGES
`SUSTAINED BY INDUCTIVE COUPLING
`___________
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`Case IPR2015-01767
`Patent 6,017,221
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`PETITIONER'S REQUEST FOR ORAL HEARING
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`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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` Case IPR2015-01767
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` U.S. Patent No. 6,017,221
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`Pursuant to 37 C.F.R. § 42.70(a) and the Scheduling Order entered on
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`February 24, 2016 (Paper No. 11), Petitioner, Lam Research Corp., (“Lam”)
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`requests an oral hearing regarding the patentability of all challenged claims of the
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`patent 6,017,221.
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`In particular, Lam requests (without any intent to waive consideration of any
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`issue not requested) 90 minutes of total argument time to present its arguments on
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`the following issues:
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`1. Whether claims 1 and 5-7 are unpatentable under § 102(b) as
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`anticipated by Lieberman93;
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`2. Whether claims 1 and 5-7 are unpatentable under § 102(b) as
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`anticipated by Lieberman94;
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`3. Whether claims 1 and 5-7 are unpatentable under § 103(a) as obvious
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`over the combination of Lieberman93 and Dible;
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`4. Whether claims 1 and 5-7 are unpatentable under § 103(a) as obvious
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`over the combination of Lieberman94 and Dible;
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`5. Whether claim 4 is unpatentable under § 103(a) as obvious over the
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`combination of Lieberman93 and Collins;
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`6. Whether claim 4 is unpatentable under § 103(a) as obvious over the
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`combination of Lieberman93, Dible and Collins;
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`7. Whether claim 4 is unpatentable under § 103(a) as obvious over the
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`combination of Lieberman94 and Collins;
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` Case IPR2015-01767
` U.S. Patent No. 6,017,221
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`8. Whether claim 4 is unpatentable under § 103(a) as obvious over the
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`combination of Lieberman94, Dible and Collins;
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`9.
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`Respond to any issues specified by Patent Owner in its request for oral
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`argument;
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`10. Respond to Patent Owner's presentation on all matters; and
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`11. Any additional issues on which the Board seeks clarification.
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`Lam understands that oral argument will be held on Tuesday, October 11,
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`2016. Lam requests the ability to use audio/visual equipment to display
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`demonstrative exhibits, including the use of a projector and screen for a
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`PowerPoint display. In accordance with the Trial Practice Guide, 77 Fed. Reg. at
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`48768, Lam will also contact the Board Trial Division paralegal to discuss this
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`request.
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`Dated: August 16, 2016.
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` Case IPR2015-01767
` U.S. Patent No. 6,017,221
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`Respectfully submitted,
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`By: /Michael Fleming/
` Michael Fleming
`Michael Fleming (Reg. No. 67,933)
`Samuel K. Lu (Reg. No. 40,707)
`Morgan Chu (pro hac vice)
`Talin Gordnia (pro hac vice)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Tel.: (310) 277-1010 | Fax: (310) 203-7199
`mfleming@irell.com; slu@irell.com;
`mchu@irell.com; tgordnia@irell.com
`Attorneys for Petitioner Lam Research Corp.
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` Case IPR2015-01767
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` U.S. Patent No. 6,017,221
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`CERTIFICATE OF SERVICE
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`I hereby certify, pursuant to 37 C.F.R. sections 42.6 and 42.105, that a
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`complete copy of the foregoing document is being served, pursuant to the parties'
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`service agreement, via electronic mail (e-mail) upon the following , on the 16th
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`day of August, 2016, the same day as the filing of the above-identified documents
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`in the United States Patent and Trademark Office/Patent Trial and Appeal Board:
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`Christopher Frerking
`Registration No. 42,557
`174 Rumford Street
`Concord, New Hampshire 03301
`chris@ntknet.com
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`George Summerfield
`STADHEIM & GREAR, LTD.
`400 N. Michigan Avenue, Suite 2200
`Chicago, IL 60611
`Summerfield@StadheimGrear.com
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` /Susan M. Langworthy/
` Susan M. Langworthy
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