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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`INTEL CORPORATION, GLOBALFOUNDRIES U.S., INC.,
`MICRON TECHNOLOGY, INC., and
`SAMSUNG ELECTRONICS COMPANY, LTD.,
`Petitioners,
`
`v.
`
`DANIEL L. FLAMM,
`Patent Owner.
`
`
`
`
`
`
`
`
`PTAB Case No. IPR2017-002801
`Patent No. RE40,264 E
`
`
`
`
`
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`
`
`REQUEST FOR ORAL ARGUMENT
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`
`
` 1
`
` Samsung Electronics Company, Ltd. was joined as a party to this proceeding via
`a Motion for Joinder in IPR2017-01750.
`
`
`
`PTAB Case No. IPR 2017-00280
`Patent No. RE40,264 E
`Petitioners’ Request for Oral Argument
`
`
`
`Petitioners Intel Corporation (“Intel”), Micron Technology, Inc. (“Micron”)
`
`and GLOBALFOUNDRIES U.S., Inc. (“Global”) hereby request an oral hearing
`
`pursuant to 37 C.F.R. § 42.70 and the Board’s Scheduling Order dated June 13,
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`2017, providing for an oral argument, if requested, on March 7, 2018.2 Petitioners
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`request that oral argument in IPR2017-00279; IPR2017-00280; IPR2017-00281;
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`and IPR2017-00282 be consolidated into a single argument. Petitioners intend to
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`discuss the issues raised in the parties’ filings under the ongoing reviews, including
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`but not limited to, the following items:
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`1.
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`Any issues addressed by Petitioners, including in the Petition for Inter
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`Partes Review and Reply in any of the proceedings, including the patentability of
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`claims 13-71 of U.S. Patent No. RE40,264 E.
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`2.
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`Any issues properly raised by Patent Owner, including in Patent
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`Owner’s Responses.
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`3.
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`Rebuttal to issues raised by Patent Owner, including in any Responses,
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`motions to exclude or requests for oral argument.
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`4.
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`Any other issues related to invalidity that the Board deems necessary
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`for issuing a final written decision.
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`
` 2
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` The Board’s Scheduling Order applied to four cases relating to the ’264 patent:
`Case Nos. IPR2017-00279; IPR2017-00280; IPR2017-00281; IPR2017-00282. An
`identical Request is being filed in each proceeding.
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`
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`
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`PTAB Case No. IPR 2017-00280
`Patent No. RE40,264 E
`Petitioners’ Request for Oral Argument
`Petitioners request that each side be given 45 minutes of total time to present
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`its arguments. Forty-five minutes are necessary and reasonable for a consolidated
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`argument of four IPR proceedings. Petitioners also request the ability to use
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`audio/visual equipment to display demonstrative exhibits, including the use of a
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`projector and screen for demonstrative slides. Because of the number of
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`anticipated attendees at the hearing, Petitioners request that the largest hearing
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`room available be reserved for the hearing.
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`
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`Dated: February 1, 2018
`
`
`PERKINS COIE LLP
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101
`206-359-8000
`
`WEIL, GOTSHAL & MANGES LLP
`201 Redwood Shores Parkway
`Redwood Shores, CA 94065
`650-802-3237
`
`WHITE & CASE LLP
`701 Thirteenth Street, NW
`Washington, DC 20005-3807
`202-626-3600
`
`Respectfully submitted,
`
` /Jonathan McFarland/
`Lead Counsel
`Jonathan McFarland, Reg. No. 61,109
`
`Back-up Counsel
`Chad Campbell, Pro Hac Vice
`Tyler Bowen, Reg. No. 60,461
`Daniel Keese, Reg. No. 69,315
`Jeremy Jason Lang, Reg. No. 73,604
`Jared Bobrow, Pro Hac Vice
`David M. Tennant, Reg. No. 48,362
`Nathan Zhang, Reg. No. 71,401
`
`Attorneys for Petitioners
`
`
`
`
`
`
`PTAB Case No. IPR 2017-00280
`Patent No. RE40,264 E
`Petitioners’ Request for Oral Argument
`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true copy of the foregoing
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`
`
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`REQUEST FOR ORAL ARGUMENT has been served in its entirety this 1st day
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`of February, 2018, by electronic mail on Patent Owner via its attorneys of record:
`
`BACK-UP COUNSEL
`Rolf Stadheim
`Stadheim@StadheimGrear.com
`STADHEIM & GREAR, LTD.
`400 N. Michigan Ave., Suite 2200
`Chicago, Illinois 60611
`312-755-4400
`
`Respectfully submitted,
`
` /Jonathan McFarland/
`Lead Counsel
`Jonathan McFarland, Reg. No. 61,109
`
`Back-up Counsel
`Chad Campbell, Pro Hac Vice
`Tyler Bowen, Reg. No. 60,461
`Daniel Keese, Reg. No. 69,315
`Jeremy Jason Lang, Reg. No. 73,604
`Jared Bobrow, Pro Hac Vice
`David M. Tennant, Reg. No. 48,362
`Nathan Zhang, Reg. No. 71,401
`
`Attorneys for Petitioners
`
`LEAD COUNSEL
`Christopher Frerking
`chris@ntknet.com
`174 Rumford Street
`Concord, New Hampshire 03301
`603-706-3127
`
`Dated: February 1, 2018
`
`
`PERKINS COIE LLP
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101
`206-359-8000
`
`WEIL, GOTSHAL & MANGES LLP
`201 Redwood Shores Parkway
`Redwood Shores, CA 94065
`650-802-3237
`
`WHITE & CASE LLP
`701 Thirteenth Street, NW
`Washington, DC 20005-3807
`202-626-3600
`
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