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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`Petitioner,
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`v.
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`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`
`
`Case IPR2016-012461
`Patent 7,126,174 B2
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`1 Case IPR2016-01247 has been consolidated with this proceeding.
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`IPR2016-01246, IPR2016-01247
`Patent 7,126,174 B2
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`Pursuant to 37 C.F.R. § 42.70(a) and in accordance with the Board’s
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`Scheduling Order as modified on July 6, 2017 (Paper 28), Petitioner Taiwan
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`Semiconductor Manufacturing Company Limited (“TSMC”) respectfully submits
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`this Request for Oral Argument. The Board has scheduled the oral argument in
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`IPR2016-01246 for August 8, 2017 (Paper 9 at 6).
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`TSMC specifies the following issues to be argued during oral argument:
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` Whether claims 1–3, 5–7, 9–12, and 14–18 of U.S. Patent No.
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`7,126,174 are unpatentable under pre-AIA 35 U.S.C. § 103 as obvious
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`over Lee in view of Noble;
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` Whether claims 1–3, 5–7, 9–12, and 14–18 of U.S. Patent No.
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`7,126,174 are unpatentable under pre-AIA 35 U.S.C. § 103 as obvious
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`over Lee in view of Ogawa;
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` Whether claims 1, 4, 5, 8–12, 14, and 16 of U.S. Patent No. 7,126,174
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`are unpatentable under pre-AIA 35 U.S.C. § 103 as obvious over
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`Lowrey in view of Noble;
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` Whether claims 1, 4, 5, 8–12, 14, and 16 of U.S. Patent No. 7,126,174
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`are unpatentable under pre-AIA 35 U.S.C. § 103 as obvious over
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`Lowrey in view of Ogawa;
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` Any issues identified in Patent Owner’s Request for Oral Hearing;
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` Any issues raised in either party’s Motions to Exclude;
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`IPR2016-01246, IPR2016-01247
`Patent 7,126,174 B2
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` Any issues raised by Patent Owner in its Sur-Reply (including any
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`issues regarding Dr. Banerjee’s deposition testimony); and
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` Any other issues the Board deems necessary for issuing a final written
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`decision.
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`Petitioner requests 60 minutes of argument time for the proposed hearing of
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`consolidated IPR2016-01246 and IPR2016-01247. The reason for this request is
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`that Patent Owner will file a sur-reply, and Petitioner will not have an opportunity
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`to respond, or even to comment on the cross examination, until the hearing. To the
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`extent the Board schedules the hearing to last longer than 120 minutes, Petitioner
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`requests half the length of the hearing be allocated to Petitioner to address these
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`issues.
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`Finally, Petitioner requests that ten spaces be reserved at the oral hearing to
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`accommodate its counsel and corporate representatives. Petitioner also requests an
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`easel for physical demonstratives, and that two attorneys at Petitioner’s counsel’s
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`table be allowed to use computers at the hearing (in addition to the counsel making
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`the argument using his or her computer to show electronic demonstratives) to
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`avoid the need for the parties to bring paper copies of the record into the hearing
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`room and to facilitate addressing panel questions.
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` 2
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`IPR2016-01246, IPR2016-01247
`Patent 7,126,174 B2
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`Dated: July 12, 2017
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`Respectfully submitted,
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`
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`By: /Darren M. Jiron/
`Darren M. Jiron
`Reg. No. 45,777
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`Lead Counsel for Petitioner
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` 3
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`IPR2016-01246, IPR2016-01247
`Patent 7,126,174 B2
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`CERTIFICATE OF SERVICE
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`Under 37 C.F.R. § 42.6(e), this is to certify that I served a true and correct
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`copy of the Petitioner’s Request for Oral Argument by electronic mail, on this
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`12th day of July, 2017, on counsel of record for the Patent Owner as follows:
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`Neil F. Greenblum
`ngreenblum@gbpatent.com
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`Michael J. Fink
`mfink@gbpatent.com
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`Arnold Turk
`aturk@gbpatent.com
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`Dated: July 12, 2017
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`By: /Lauren K. Young/
`Lauren K. Young
`Litigation Legal Assistant
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, L.L.P.
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