`U.S. Patent No. 7,126,174
`
`
`Filed on behalf of Godo Kaisha IP Bridge 1
`
`By: Neil F. Greenblum (ngreenblum@gbpatent.com)
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: (703) 716-1191
`Fax: (703) 716-1180
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY LIMITED,
`and GLOBALFOUNDRIES U.S. INC.,
`Petitioners,
`
`v.
`
`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`____________
`
`Case Nos. IPR2016-012461
`U.S. Patent No. 7,126,174 B2
`____________
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
` Case IPR2016-01247 has been consolidated with this proceeding.
`
`1
`
`GlobalFoundries U.S. Inc.’s motions for joinder in Cases IPR2017-00925 and
`
`IPR2017-00926 were granted.
`
`1
`
`
`
`IPR2016-01246
`U.S. Patent No. 7,126,174
`
`
`
`Pursuant to 37 C.F.R. §42.70(a) and the Scheduling Order dated January 4,
`
`2017 (Paper No. 9), Patent Owner respectfully requests oral argument regarding
`
`the patentability of the challenged claims of the ‘174 patent. The Scheduling Order
`
`indicates that oral argument (DUE DATE 7) will be held on August 8, 2017.
`
`Patent Owner believes that 1½ hours for each side will be sufficient to cover the
`
`issues in consolidated Cases IPR2016-01246 and IPR2016-01247.
`
`Patent Owner requests (without waiving consideration of any issue not listed
`
`below) to address the following issues during oral argument:
`
`1. Whether Petitioner has met its burden of proof that the challenged
`
`claims of the ‘174 patent, when properly construed, are unpatentable for
`
`obviousness based upon the grounds of rejection specified in the Petition, and for
`
`which institution was granted.
`
`2. Whether Petitioner failed to make out a prima facie case of
`
`obviousness in the Petition by not explaining “how” references would have been
`
`combined by a person having ordinary skill in the art at the time of the invention.
`
`3. Whether rejections properly before the Board based upon entirely
`
`conclusory Expert evidence can support a finding of invalidity in this case.
`
`4.
`
`The significance of Petitioner’s changes in position between the
`
`Petition and the Reply, and the weight to be given to the new arguments and
`
`evidence presented in the Reply.
`
`2
`
`
`
`IPR2016-01246
`U.S. Patent No. 7,126,174
`
`
`
`5.
`
`6.
`
`Claim construction for the phrase “L-shaped sidewalls”
`
`The issues raised in the Petitions, Patent Owner’s Preliminary
`
`Responses, the Decision to Institute, Patent Owner’s Response, Petitioner’s Reply
`
`to Patent Owner’s Response, and Patent Owner’s Sur-Reply.
`
`7. Whether evidence should be excluded as identified in Patent Owner’s
`
`Motion To Exclude Evidence.
`
`8.
`
`If filed, any additional issues raised by Patent Owner in any other
`
`motion or paper filed by Patent Owner before oral argument.
`
`9.
`
`If filed, any additional issues raised by Petitioner in a request for oral
`
`argument, in any motion to exclude, or in any other motion or paper filed by
`
`Petitioners before oral argument.
`
`10. Any other issues on which the Board seeks clarification.
`
`Patent Owner requests permission to present handouts of demonstrative
`
`exhibits and to use audio-visual equipment to display demonstrative exhibits,
`
`including a projector. In accordance with Trial Practice Guide, 77 Fed. Reg.
`
`45756, 48768, Patent Owner will also contact the Board Trial Division paralegal to
`
`discuss the request.
`
`
`
`
`
`3
`
`
`
`
`Dated: July 12, 2017
`
`IPR2016-01246
`U.S. Patent No. 7,126,174
`
`Respectfully Submitted by:
`
`
`
`
`
`/Neil F. Greenblum/
`Neil F. Greenblum
`Registration No. 28,394
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: 703-716-1191
`Fax: 703-716-1180
`Email: ngreenblum@gbpatent.com
`
`Attorney for Patent Owner,
`Godo Kaisha IP Bridge 1
`
`4
`
`
`
`IPR2016-01246
`U.S. Patent No. 7,126,174
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true copy of the foregoing:
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`was served by electronic mail on this 12th day of July, 2017, upon Counsel for
`
`Petitioners, as follows:
`
`Darren M. Jiron (Darren.Jiron@finnegan.com);
`J.P. Long (JP.Long@finnegan.com);
`E. Robert Yoches (Bob.Yoches@finnegan.com);
`Joshua L. Goldberg (Joshua.Goldberg@finnegan.com);
`TSMC-IPB-PTAB@finnegan.com;
`Kent Cooper (kent.cooper@kjcooperlaw.com); and
`Adam Floyd (floyd.adam@dorsey.com).
`
`
`
`
`
`
`/Neil F. Greenblum/
`Neil F. Greenblum
`Registration No. 28,394
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: 703-716-1191
`Fax: 703-716-1180
` Email: ngreenblum@gbpatent.com
`
`
`
`
`
`
`
`
`
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`
`
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