`U.S. Patent No. 6,538,324
`
`
`Filed on behalf of Godo Kaisha IP Bridge 1
`
`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
`
`
`
`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. IPR2016-012641
`U.S. Patent No. 6,538,324
`____________
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`1 GlobalFoundries U.S. Inc.’s motion for joinder in Case IPR2017-00920 was
`
`granted.
`
`
`
`Case IPR2016-01264 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
`
`regarding the patentability of the challenged claims of the ‘324 patent, and Patent
`
`Owner’s Contingent Motion To Amend (Paper 16). A substantively similar
`
`Request for Oral Argument has also been filed in related Case IPR2016-01249.
`
`The Scheduling Order indicates that oral argument (DUE DATE 7) will be held on
`
`August 8, 2017. The August 2017 PTAB Public Hearing Schedule confirms that
`
`oral argument will be held on August 8, 2017 and indicates that the hearing will be
`
`held in Alexandria, VA, Room A, beginning at 9:00 AM (EDT). Patent Owner
`
`believes that 1½ hours for each side will be sufficient to cover the issues in both
`
`Cases IPR2016-01249 and IPR2016-01264.
`
`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 ‘324 patent, when properly construed, are unpatentable for
`
`obviousness over the combinations of references in the instituted grounds of
`
`unpatentability.
`
`2.
`
`The issues raised in the Petition, Patent Owner’s Preliminary
`
`Response, the Decision to Institute, Patent Owner’s Response, and Petitioner’s
`
`Reply to Patent Owner’s Response.
`
`
`
`1
`
`
`
`The issues raised in Patent Owner’s Contingent Motion to Amend,
`
`Case IPR2016-01264 for
`U.S. Patent No. 6,538,324
`
`
`3.
`
`Petitioner’s Opposition To Patent Owner’s Contingent Motion to Amend, and
`
`Patent Owner’s Reply To Petitioner’s Opposition To Patent Owner’s Contingent
`
`Motion to Amend.
`
`4.
`
`5.
`
`Patent Owner’s observations on cross-examination.
`
`Patent Owner’s counter-designations of testimony regarding the
`
`deposition of Dr. Harris.
`
`6. Whether evidence should be excluded as identified in Patent Owner’s
`
`Motion To Exclude Evidence.
`
`7.
`
`If filed, any additional issues raised by Patent Owner in any other
`
`motion or paper filed by Patent Owner before oral argument.
`
`8.
`
`If filed, any additional issues raised by Petitioner in a request for oral
`
`argument, in a motion to exclude, or in any other motion or paper filed by
`
`Petitioners before oral argument.
`
`9.
`
`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.
`
`
`
`2
`
`
`
`Dated: July 12, 2017
`
`Respectfully Submitted by:
`
`Case IPR2016-01264 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
`
`
`
`
`
`3
`
`{R50502 03159572.DOCX}
`
`
`
`Case IPR2016-01264 for
`U.S. Patent No. 6,538,324
`
`
`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:
`
`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
`
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
