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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG DISPLAY CO., LTD., DELL INC., and APPLE INC.,
`Petitioner,
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`v.
`
`SOLAS OLED, LTD.,
`Patent Owner.
`
`Case No. IPR2020-001401
`U.S. Patent No. 6,072,450
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`
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`1 Apple Inc., who filed a petition in IPR2020-01059, has been joined as a petitioner
`in this proceeding.
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`
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`IPR2020-00140
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`Petitioner requests the opportunity to present oral argument on all of the
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`grounds of unpatentability for U.S. Patent No. 6,072,450 presented in this matter
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`(as listed below), as well as (i) the parties’ associated briefing, (ii) rebuttal to
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`Patent Owner’s presentation on all matters; and (iii) any other issues that the
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`Board deems necessary for issuing a final written decision. Petitioner
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`respectfully files this request at this date due to counsel’s unexpected illness.
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`Patent Owner does not oppose Petitioner’s filing of this request.
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`Petitioner respectfully requests 30 minutes per side of argument time. The
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`argument is scheduled for February 9, 2021 (Paper No. 10 at 10). The grounds
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`of unpatentability are:
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`I. Anticipation of claims 1–2, 4–8, and 15–16 under 35 U.S.C. § 102 by
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`Utsugi.
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`II. Obviousness of claims 1–2, 4–8, and 15–16 under 35 U.S.C. § 103 over
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`Utsugi.
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`III. Obviousness of claim 3 under 35 U.S.C. § 103 over the combination of
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`Utsugi and Manabe.
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`IV. Obviousness of claims 9, 11–13, and 17–18 under 35 U.S.C. § 103 over
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`the combination of Utsugi and Eida.
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`See Paper No. 1 at 5; Paper No. 9 at 26.
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`IPR2020-00140
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`Respectfully submitted,
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`/Peter P. Chen/
`David A. Garr, Reg. No. 74,932
`Jeffrey H. Lerner (pro hac vice)
`Jared Frisch (pro hac vice)
`Covington & Burling LLP
`One CityCenter, 850 Tenth St., NW
`Washington DC 20001
`
`Peter P. Chen, Reg. No. 39,631
`Robert T. Haslam (pro hac vice)
`Covington & Burling LLP
`3000 El Camino Real
`5 Palo Alto Square, Suite 1000
`Palo Alto, CA 94306
`
`Adam P. Seitz, Reg. No. 52,206
`Paul R. Hart, Reg. No. 59,646
`ERISE IP, P.A.
`
`Counsel for Petitioner
`
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`
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`Date: December 29, 2020
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`
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`Neil Rubin
`Kent Shum
`Reza Mirzaie
`Philip Wang
`RUSS AUGUST & KABAT
`nrubin@raklaw.com
`kshum@raklaw.com
`rmirzaie@raklaw.com
`pwang@raklaw.com
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`
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`/Peter P. Chen/
`Peter P. Chen
`Registration No. 39,631
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`IPR2020-00140
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6, I hereby certify that the foregoing document
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`was served by electronic mail, on the following counsel of record for Patent
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`Owner:
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`Date: December 29, 2020
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