`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`ASUSTEK COMPUTER, INC. and ASUS COMPUTER INTERNATIONAL,
`
`Petitioners
`
`v.
`
`AVAGO TECHNOLOGIES GENERAL IP (SINGAPORE) PTE. LTD.,
`
`Patent Owner
`
`
`
`Case: IPR2016-00646
`
`U.S. Patent No. 5,870,087
`
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.70(a), Patent Owner Avago Technologies
`
`General IP (Singapore) Pte. Ltd. (“Avago” or “Patent Owner”) requests oral
`
`argument before the Board in this inter partes review. Patent Owner respectfully
`
`requests one hour in which to present its arguments and the necessary equipment to
`
`project related demonstratives. Patent Owner requests that two counsel at the
`
`counsel’s table be allowed to use their computers at the hearing (in addition to the
`
`counsel making the argument using his or her computer to show the
`
`demonstratives), to avoid the need for the parties to bring entire paper copies of the
`
`record into the hearing room and to facilitate efficient answering of panel
`
`questions.
`
`Without intending to waive any issue not specifically identified, Patent
`
`Owner specifies the following issues to be argued:
`
`1. Whether Petitioners ASUSTeK Computer, Inc. and ASUS Computer
`
`International (collectively, “ASUS” or “Petitioners”) have met their burden of
`
`proving that claims 1, 7, 10, 11, and 16 of U.S. Patent No. 5,870,087 (“the ’087
`
`Patent”) are unpatentable under 35 U.S.C. § 102(e) over U.S. Patent No. 5,898,695
`
`(“Fujii”).
`
`2. Whether Petitioners have met their burden of proving that claims 1, 5,
`
`7-11, and 16 of the ’087 Patent are unpatentable under 35 U.S.C. § 103(a) over
`
`Fujii in view of U.S. Patent No. 5,960,464 (“Lam”).
`
`
`
`1
`
`
`
`
`
`
`
`3. Whether Petitioners have met their burden of proving that claims 7-9
`
`of the ’087 Patent are unpatentable under 35 U.S.C. § 103(a) over Fujii in view of
`
`U.S. Patent No. 5,847,771 (“Cloutier”).
`
`4. Whether Petitioners have met their burden of proving that claims 7-9
`
`of the ’087 Patent are unpatentable under 35 U.S.C. § 103(a) over Fujii in view of
`
`Lam in further view of Cloutier.
`
`5.
`
`6.
`
`7.
`
`8.
`
`The content of Patent Owner’s Response.
`
`The scope and content of Petitioners’ Petition and Reply.
`
`Any additional issues raised by Petitioners during oral argument.
`
`Any other issue(s) that the Patent Trial and Appeal Board desires to
`
`have addressed.
`
`Date: April 6, 2017
`
`
`
`
`
`Respectfully submitted,
`
`By: s/ Kristopher L. Reed
`Kristopher L. Reed
`Registration No. 58694
`Lead Counsel for Patent Owner
`
`2
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certified that on this
`
`6th day of April, 2017, I caused a true and correct copy of the foregoing
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT to be
`
`served via e-mail (as agreed by Counsel for Petitioners) on the following
`
`counsel of record for the Petitioners:
`
`Scott Stevens (Lead Counsel)
`Derek Neilson (Back-up Counsel)
`Alston & Bird LLP
`101 South Tryon Street, Suite 4000
`Charlotte, NC 28280
`scott.stevens@alston.com
`derek.neilson@alston.com
`
`By: s/ Kristopher L. Reed
`Kristopher L. Reed
`Registration No. 58,694
`Counsel for Patent Owner
`
`
`
`Date: April 6, 2017
`
`
`69264732V.1
`
`3
`
`