`By:
`James C. Gumina (gumina@mbhb.com)
`
`Michael D. Clifford (clifford@mbhb.com)
`
`Michael D. Anderson (andersonm@mbhb.com)
`
`McDonnell Boehnen Hulbert & Berghoff LLP
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`300 South Wacker Drive
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`Suite 3200
`
`Chicago, Illinois 60606
`
`Tel.: (312) 913-0001
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`Fax: (312) 913-0002
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`SAMSUNG GROUP
`Petitioner,
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`v.
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`
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`DSS TECHNOLOGY MANAGEMENT, INC.,
`Patent Owner.
`
`_____________
`
`Case IPR2016-00782
`Patent 6,784,552
`
`______________
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT PURSUANT
`TO 37 § C.F.R. § 42.70(a)
`
`
`
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`
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`I.
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`Request for Oral Argument
`
`
`
`Case IPR2016-00782
`U.S. Patent No. 6,784,552
`
`
`Patent owner DSS Technology Management, Inc., a wholly-owned
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`subsidiary of Document Security Systems, Inc., (“Patent Owner” or “DSS”)
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`respectfully requests oral argument on the issues set forth below pursuant to 37
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`C.F.R. 42.70(a). Additionally, pursuant to the Board’s scheduling order in this
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`matter, oral argument is set for June 20, 2017, and DSS respectfully requests the
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`opportunity to address and respond to the following issues on that date:
`
`A. Whether Petitioner has met its burden to prove that claims 1, 2, 4-12
`are anticipated 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”), as well as any other issues raised by Petitioner in its
`Petition for Inter Partes Review and/or its Reply to Patent Owner’s
`Response concerning this issue;
`B. Whether Petitioner has met its burden to prove that claim 3 is obvious
`over Kuesters and U.S. Patent No. 5,482,894 (“Havemann”), as well
`as any other issues raised by Petitioner in its Petition for Inter Partes
`Review and/or its Reply to Patent Owner’s Response concerning this
`issue;
`C. Whether Petitioner has met its burden to prove that claims 1, 2, 4-7
`are obvious over Kuesters and U.S. Patent No. 4,686,000 (“Heath”),
`as well as any other issues raised by Petitioner in its Petition for Inter
`Partes Review and/or its Reply to Patent Owner’s Response
`concerning this issue;
`D. Whether Petitioner has met its burden to prove that claim 3 is obvious
`over Kuesters, Heath, and Havemann, as well as any other issues
`raised by Petitioner in its Petition for Inter Partes Review and/or its
`Reply to Patent Owner’s Response concerning this issue;
`
`2
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`Case IPR2016-00782
`U.S. Patent No. 6,784,552
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`F.
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`E. Any other issues raised by Petitioner in its Petition for Inter Partes
`Review and/or its Reply to Patent Owner’s Response;
`If granted, any arguments or demonstratives presented by Petitioner at
`oral argument before the Board; and
`G. Any other issues the Board deems necessary to evaluate whether
`Petitioner has met its burden of proof in this matter.
`
`Additionally, DSS respectfully requests that the Board grant 1.0 hour for the
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`requested oral argument, with each side having 30 minutes to present its arguments
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`before the Board.
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`Respectfully submitted,
`
`/James C. Gumina/
`James C. Gumina (Reg. No. 32,898)
`Michael D. Clifford (Reg. No. 60,550)
`Michael D. Anderson (Reg. No. 66,839)
`McDonnell Boehnen Hulbert & Berghoff
`300 South Wacker Drive, Suite 3200
`Chicago, Illinois 60606
`(312) 913-0001
`
`
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`Date: May 15, 2017
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`3
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`Case IPR2016-00782
`U.S. Patent No. 6,784,552
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that, in accordance with 37 C.F.R. § 42.6(e), the
`
`Patent Owner’s Request for Oral Argument Pursuant to 37 C.F.R. § 42.70(a) was
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`served on opposing counsel by filing this document through the Patent Review
`
`Processing System, as well as by delivering copies of the same via first-class and
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`electronic mail, on May 15, 2017, upon the following:
`
`
`
`Jeremy Jason Lang
`Weil, Gotshal & Manges LLP
`201 Redwood Shores Parkway
`Redwood Shores, CA 94065
`650-802-3237
`jason.lang@weil.com
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`Respectfully submitted,
`
`/James C. Gumina/
`James C. Gumina
`Lead Counsel for Patent Owner
`Registration No. 32,898
`McDonnell Boehnen Hulbert & Berghoff
`300 South Wacker Drive, Suite 3200
`Chicago, Illinois 60606
`(312) 913-0001
`
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`Date: May 15, 2017
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`4
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