`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`INTEL CORP., CAVIUM, LLC, and DELL INC.,
`Petitioners,
`
`v.
`
`ALACRITECH, INC.,
`Patent Owner.
`______________________
`
`Case IPR2018-002341
`U.S. Patent No. 8,805,948
`______________________
`
`PETITIONER’S REQUEST FOR
`ORAL ARGUMENT PURSUANT TO 37 C.F.R. § 42.70(a)
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`1 Cavium LLC (formerly Cavium, Inc.), which filed a Petition in Case IPR2018-
`
`00403, and Dell Inc., which filed a Petition in Case IPR2018-01307, have been
`
`joined as petitioners in this proceeding.
`
`
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.70(a), Petitioner respectfully requests oral
`
`argument on the issues set forth below. Oral argument is presently scheduled for
`
`March 4, 2019. (Scheduling Order, Paper 8). Petitioner requests 1 hour (2 hours in
`
`total if Patent Owner also is allotted 1 hour) for all 3 IPRs (IPR2018-00226,
`
`IPR2018-00234, IPR2018-00401) being heard at the Oral Argument. Petitioner
`
`further requests that the hearing be split into two sessions, where 20 minutes per
`
`side (40 minutes in total) is closed to the public to allow for presentation of
`
`PETITIONER’S RESTRICTED – ATTORNEY’S EYES ONLY material related
`
`to real parties-in-interest. To accommodate this, Petitioner requests that the Board
`
`implement a procedure similar to that adopted in Baker Hughes Incorporated v.
`
`LiquidPower Specialty Products, Inc., IPR2016-00734, Paper 68 (PTAB May 31,
`
`2017) and in Snap-On Inc. v. Milwaukee Electric Tool Corp., IPR2015-01242,
`
`Paper 59 (Aug. 18, 2016), in which the hearing room was closed to the public for a
`
`portion of the hearing to allow for the presentation of confidential information.
`
`Petitioner respectfully requests oral argument on all instituted grounds and
`
`all related issues, specifically:
`
`I. Whether claims 1, 3, 6-8, 17, 19, and 21-22 of the 948 Patent are
`
`unpatentable as obvious over Thia, Tanenbaum96 and Steven2, under
`
`35 U.S.C. § 103.
`
`
`
`
`
`
`
`
`
`II. Whether the Petition was filed more than one year after the date on
`
`which alleged real parties-in-interest were served with a complaint
`
`alleging infringement of the 948 Patent.
`
`III. Whether the Petition correctly named all real parties-in-interest.
`
`IV. Respond to Patent Owner’s presentation on all matters.
`
`V. Any issues specified by Patent Owner in a Request for Oral
`
`Argument.
`
`VI. Any other issues the Board deems necessary for issuing a final written
`
`decision.
`
`
`
`Dated: January 28, 2019
`
`
`
`Respectfully submitted,
`
`/s/ Garland T. Stephens
`Garland T. Stephens, Reg. No. 37,242
`Justin L. Constant, Reg. No. 66,883
`Weil, Gotshal & Manges LLP
`700 Louisiana, Suite 1700
`Houston, TX 77002
`Tel: (713) 546-5000
`Fax: (713) 224-9511
`garland.stephens@weil.com
`justin.constant@weil.com
`Anne M. Cappella, Reg. No. 43,217
`Adrian Percer, Reg. No. 46,986
`Amanda Branch (admitted pro hac vice)
`Weil, Gotshal & Manges LLP
`201 Redwood Shores Parkway
`Redwood Shores, CA 94065
`3
`
`
`
`
`
`
`
`Tel: (650) 802-3000
`Fax: (650) 802-3100
`anne.cappella@weil.com
`adrian.percer@weil.com
`amanda.branch@weil.com
`
`William S. Ansley, Reg. No. 67,828
`Weil, Gotshal & Manges LLP
`2001 M Street, N.W, Suite 600
`Washington, DC 20036
`Tel: (202) 682-7000
`Fax: (202) 857-0940
`sutton.ansley@weil.com
`
`Attorneys for Petitioner Intel Corporation
`
`4
`
`
`
`
`
`CERTIFICATE OF SERVICE
`I hereby certify that on January 28, 2019, a copy of PETITIONER’S
`
`REQUEST FOR ORAL ARGUMENT PURSUANT TO 37 C.F.R. § 42.70(a)
`
`was served by filing this document through the PTAB’s E2E Filing System as well
`
`as delivering a copy via electronic mail upon the following:
`
`James M. Glass
`Registration No. 46,729
`Quinn Emanuel Urquhart & Sullivan LLP
`51 Madison Ave., 22nd Fl.
`New York, NY 10010
`Tel.: (212) 849-7000
`Email: jimglass@quinnemanuel.com
`Joseph M. Paunovich
`Registration No. 59,033
`Quinn Emanuel Urquhart & Sullivan LLP
`865 S. Figueroa Street, 10th Fl.
`Los Angeles, CA 90017
`Tel.: (213) 443-3000
`Email: joepaunovich@quinnemanuel.com
`Brian E. Mack
`Registration No. 57,189
`Quinn Emanuel Urquhart & Sullivan LLP
`50 California Street, 22nd Fl.
`San Francisco, CA 94111
`Tel.: (415) 875-6600
`Email: brianmack@quinnemanuel.com
`
`
`
`
`
`
`
`
`
`
`Mark Lauer
`Registration No. 36,578
`Silicon Edge Law Group LLP
`7901 Stoneridge Dr., Ste. 528
`Pleasanton, CA 94588
`Tel.: (925) 621-2121
`Email: mark@siliconedgelaw.com
`
`Dated: January 28, 2019
`
`/s/ Garland T. Stephens
`Garland T. Stephens
`Reg. No. 37,242
`
`
`
`
`
`
`
`2
`
`
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