`U.S. Patent No. 6,538,324
`
`
`Filed on behalf of Godo Kaisha IP Bridge 1
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`By: Michael J. Fink (mfink@gbpatent.com)
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: (703) 716-1191
`Fax: (703) 716-1180
`
`
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`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. IPR2016-012491
`U.S. Patent No. 6,538,324
`____________
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`
`
`
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`1 GlobalFoundries U.S. Inc.’s motion for joinder in Case IPR2017-00919 was
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`granted.
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`
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`
`
`Case IPR2016-01249 for
`U.S. Patent No. 6,538,324
`
`
`Pursuant to 37 C.F.R. §42.70(a) and the Scheduling Order dated December
`
`21, 2016 (Paper No. 8), Patent Owner respectfully requests oral argument
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`regarding the patentability of the challenged claims of the ‘324 patent, and Patent
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`Owner’s Contingent Motion To Amend (Paper 16). A substantively similar
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`Request for Oral Argument has also been filed in related Case IPR2016-01264.
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`The Scheduling Order indicates that oral argument (DUE DATE 7) will be held on
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`August 8, 2017. The August 2017 PTAB Public Hearing Schedule confirms that
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`oral argument will be held on August 8, 2017 and indicates that the hearing will be
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`held in Alexandria, VA, Room A, beginning at 9:00 AM (EDT). Patent Owner
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`believes that 1½ hours for each side will be sufficient to cover the issues in both
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`Cases IPR2016-01249 and IPR2016-01264.
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`Patent Owner requests (without waiving consideration of any issue not listed
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`below) to address the following issues during oral argument:
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`1. Whether Petitioner has met its burden of proof that the challenged
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`claims of the ‘324 patent, when properly construed, are unpatentable for
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`obviousness over the combinations of references in the instituted grounds of
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`unpatentability.
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`2.
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`The issues raised in the Petition, Patent Owner’s Preliminary
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`Response, the Decision to Institute, Patent Owner’s Response, and Petitioner’s
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`Reply to Patent Owner’s Response.
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`
`
`1
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`
`
`The issues raised in Patent Owner’s Contingent Motion to Amend,
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`Case IPR2016-01249 for
`U.S. Patent No. 6,538,324
`
`
`3.
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`Petitioner’s Opposition To Patent Owner’s Contingent Motion to Amend, and
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`Patent Owner’s Reply To Petitioner’s Opposition To Patent Owner’s Contingent
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`Motion to Amend.
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`4.
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`5.
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`Patent Owner’s observations on cross-examination.
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`Patent Owner’s counter-designations of testimony regarding the
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`deposition of Dr. Harris.
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`6. Whether evidence should be excluded as identified in Patent Owner’s
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`Motion To Exclude Evidence.
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`7.
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`If filed, any additional issues raised by Patent Owner in any other
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`motion or paper filed by Patent Owner before oral argument.
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`8.
`
`If filed, any additional issues raised by Petitioner in a request for oral
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`argument, in a motion to exclude, or in any other motion or paper filed by
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`Petitioners before oral argument.
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`9.
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`Any other issues on which the Board seeks clarification.
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`Patent Owner requests permission to present handouts of demonstrative
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`exhibits and to use audio-visual equipment to display demonstrative exhibits,
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`including a projector. In accordance with Trial Practice Guide, 77 Fed. Reg.
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`45756, 48768, Patent Owner will also contact the Board Trial Division paralegal to
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`discuss the request.
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`
`
`2
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`
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`Dated: July 12, 2017
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`Respectfully Submitted by:
`
`Case IPR2016-01249 for
`U.S. Patent No. 6,538,324
`
`
`
`
`
`
`/Michael J. Fink/
`Michael J. Fink
`Registration No. 31,827
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: 703-716-1191
`Fax: 703-716-1180
`Email: mfink@gbpatent.com
`
`Attorney for Patent Owner,
`IP Bridge
`
`
`
`
`
`{R50501 03142132.DOCX 4}
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`3
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`Case IPR2016-01249 for
`U.S. Patent No. 6,538,324
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true copy of the foregoing:
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`was served by electronic mail on this 12th day of July, 2017, upon Counsel for
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`Petitioners, as follows:
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`E. Robert Yoches (bob.yoches@finnegan.com);
`Stephen E. Kabakoff (stephen.kabakoff@finnegan.com);
`Joshua L. Goldberg (joshua.goldberg@finnegan.com);
`TSMC-IPB-PTAB@finnegan.com;
`Christopher P. Carroll (christopher.carroll@whitecase.com); and
`Shamita Etienne-Cummings (setienne@whitecase.com).
`
`
`
`
`
`/Michael J. Fink/
`Michael J. Fink
`Registration No. 31,827
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: 703-716-1191
`Fax: 703-716-1180
`Email: mfink@gbpatent.com
`
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