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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`ADVANCED MICRO DEVICES, INC.
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`Petitioner
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`v.
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`AQUILA INNOVATIONS INC.
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`Patent Owner
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`Case IPR2019-01525
`Patent 6,239,614 B2
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`Pursuant to 37 C.F.R § 42.70 and the Board’s Scheduling Order, Patent
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`Owner Aquila Innovations Inc. respectfully requests oral argument, currently
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`scheduled for December 11, 2020.
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`Issues for argument: Without waiving any issue not specifically identified,
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`Patent Owner specifies at least the following issues it may discuss at argument:
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`Issues raised in the petition, including, for example, claim
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`construction, motivation to combine, and reasonable expectation of success:
`o Claims 1 - 3 are not obvious over Urano and Mutoh021;
`o Claims 1 - 3 are not obvious over Mutoh and Mutoh021;
`o Claims 4 and 5 are not obvious over Douseki and Ramus;
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`The timeliness of the arguments raised in the proceedings;
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`The constitutionality of this proceeding;
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`Any other relevant issues raised in papers filed in this proceeding,
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`including issues raised in papers yet to be filed; and
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`Any other issues that the Board deems necessary for issuing a Final
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`Written Decision, including any questions, rebuttals, or arguments that may arise
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`during the oral argument. The Board’s advance guidance is respectfully solicited as
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`to any questions the Board specifically wishes to be addressed.
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`Location: Patent Owner respectfully requests that oral argument be
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`conducted remotely.
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`-2-
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`Time of day: Because Patent Owner’s counsel is located in the Pacific Time
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`Zone, it is respectfully requested that, if possible, oral argument be held in the
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`afternoon.
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`Equipment: Patent Owner requests the ability to use a computer and screen
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`to display possible demonstratives and exhibits.
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`Date: October 30, 2020
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`/Jing H. Cherng/
`Jing H. Cherng
`Reg. No. 68,144
`Counsel for Patent Owner
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`-3-
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`CERTIFICATE OF SERVICE
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`It is certified that a copy of the foregoing has been served on Petitioner via
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`electronic mail transmission addressed to the person(s) at the address below:
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`Michael D. Specht
`mspecht-PTAB@sternekessler.com
`Christopher R. O’Brien
`COBrien-PTAB@sternekessler.com
`Wenchong Shu
`wshu-PTAB@sternekessler.com
`Michael B. Ray
`mray-PTAB@sternekessler.com
`Jonathan Tuminaro
`jtuminar-PTAB@sternekessler.com
`PTAB@sternekessler.com
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`Date: October 30, 2020
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`/Jing H. Cherng/
`Jing H. Cherng
`Reg. No. 68,144
`Counsel for Patent Owner
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`-4-
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