`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`
`
`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
`
`v.
`
`DSS TECHNOLOGY MANAGEMENT, INC.
`Patent Owner
`
`________________________
`
`Case IPR. No. 2016-00782
`U.S. Patent No. 6,784,552
`Title: STRUCTURE HAVING REDUCED LATERAL SPACER EROSION
`________________________
`
`PETITIONER’S RQUEST FOR ORAL ARGUMENT PURSUANT
`TO 37 C.F.R. § 42.70(a)
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.70(a), Petitioner respectfully requests oral
`
`argument on the issues set forth below. Oral argument is presently scheduled for
`
`June 20, 2017 (Scheduling Order, Paper 7). Petitioner specifies the following
`
`issues to be argued:
`
`I. Whether Claims 1, 2, and 4-12 of the ’552 Patent are unpatentable as
`
`being anticpated by Kuesters et al., “Self Aligned Bitline Contact For
`
`4 Mbit dRAM,” Proceedings of the First International Symposium on
`
`Ultra Large Scale Integration Science and Technology, 1987, pp. 640-
`
`649 (“Kuesters”).
`
`a. Argument regarding any issues raised in Patent Owner’s Response.
`
`II. Whether Claim 3 of the ’552 Patent is unpatentable as obvious over
`
`Kuesters in view of U.S. Patent No. 5,482,894 to Robert H.
`
`Havemann (“Havemann”).
`
`a. Argument regarding any issues raised in Patent Owner’s Response.
`
`III. Whether Claims 1, 2, and 4-7 of the ’552 Patent are unpatentable as
`
`obvious over Kuesters in view of U.S. Patent No. 4,686,000 to
`
`Barbara A. Heath (“Heath”).
`
`a. Argument regarding any issues raised in Patent Owner’s Response.
`
`IV. Whether Claim 3 of the ’552 Patent is unpatentable as obvious over
`
`Kuesters in view of Heath and Havemann.
`
`
`
`a. Argument regarding any issues raised in Patent Owner’s Response.
`
`V. Respond to Patent Owner’s presentation on all issues.
`
`VI. Any other issues the Board deems necessary for issuing a final written
`
`decision.
`
`Petitioner requests 1.0 hour for the hearing, with each side having 30
`
`Respectfully submitted,
`
`minutes for the argument.
`
`
`
`Dated: May 8, 2017
`
`By:
`
`
`
`
`
`Jeremy Jason Lang
`Lead Counsel for Petitioner
`Registration No. 73,604
`Weil, Gotshal & Manges LLP
`201 Redwood Shores Parkway
`Redwood Shores, CA 94065
`Telephone: 650-802-3237
`
`
`
`2
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies that on
`
`the 23rd day of March, 2017, a true and correct copy of PETITIONER’S
`
`REQUEST FOR ORAL ARGUMENT PURSUANT TO 37 C.F.R. § 42.70(a)
`
`was served on the counsel of record for the Patent Owner for IPR2016-00782 by
`
`filing this document through the Patent Review Processing System as well as
`
`delivering a copy via electronic mail to the following addresses:
`
`Attorneys of Record
`
`James C. Gumina (gumina@mbhb.com)
`Michael D. Clifford (clifford@mbhb.com)
`Michael D. Anderson (andersonm@mbhb.com)
`McDonnell Boehnen Hulbert & Berghoff LLP
`30 South Wacker Drive, Suite 3200
`Chicago, Illinois 60606
`Tel.: (312) 913-0001
`Fax: (312) 913-0002
`
`
`
`
`
`
`
`
`
`Jeremy Jason Lang
`Lead Counsel for Petitioner
`Registration No. 73,604
`
`Dated: May 8, 2017
`
`
`
`
`
`
`
`
`
`
`3
`
`
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