`
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`LG ELECTRONICS INC.
`Petitioner
`
`v.
`
`IMMERVISION, INC.
`Patent Owner
`
`_________________
`
`Case IPR2020-00179
`
`Patent No. 6,844,990
`
`_________________
`
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`PURSUANT TO 37 CFR § 42.70
`
`
`
`
`
`
`Case No.: IPR2020-00179
`
`
`
`Docket No.: 688266-71IPR
`
`Pursuant to 37 C.F.R. § 42.70 and the Board’s May 26, 2020 Scheduling
`
`Order (Paper No. 7) (“Scheduling Order”), Patent Owner ImmerVision, Inc.
`
`(“Patent Owner”) hereby respectfully requests oral argument on the issues set forth
`
`below in connection with this proceeding (IPR2020-00179). As set forth in the
`
`Scheduling Order, oral argument is currently scheduled to take place on February
`
`8, 2021. Patent Owner is aware of the USPTO’s March 13, 2020 notice that all
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`oral hearings will be conducted remotely until further notice
`
`(https://www.uspto.gov/about-us/news-updates/uspto-update-person-meetings).
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`Accordingly, to the extent all hearings continue to be conducted remotely as of
`
`February 8, 2021, Patent Owner is willing and able to participate in a remote
`
`hearing.
`
`Patent Owner respectfully requests that each side be given thirty (30)
`
`minutes to present its arguments. Patent Owner further respectfully requests that
`
`the argument for IPR2020-00195, also scheduled for February 8, 2021, be
`
`consolidated with the oral argument in IPR2020-00179, given the substantial
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`similarity in disputed issues between the proceedings. Patent Owner specifies at
`
`least the following issues to be argued:
`
`
`
`2
`
`
`
`Case No.: IPR2020-00179
`
`
`
`Docket No.: 688266-71IPR
`
`(1) Whether the Tada reference contains an error readily apparent to one
`
`skilled in the art such that the person skilled in the art would disregard any
`
`alleged teaching of a lens modeled using only the data from Tada’s Table 5;
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`(2) Whether Petitioner has failed to demonstrate that claim 5 of the ‘990
`
`patent would have been obvious over Tada alone (Ground 1);
`
`(3) Whether Petitioner has failed to demonstrate that claim 5 of the ‘990
`
`patent would have been obvious over Tada in view of Nagaoka (Ground 2);
`
`(4) Whether Petitioner has failed to demonstrate that claim 5 of the ‘990
`
`patent would have been obvious over Tada in view of Baker (Ground 3); and
`
`(5) Any additional issues on which the Board seeks clarification.
`
`Patent Owner respectfully requests the ability to use audio-visual equipment
`
`to display exhibits.
`
`
`
`
`
`
`
`3
`
`
`
`Case No.: IPR2020-00179
`
`
`
`Docket No.: 688266-71IPR
`
`Date: December 28, 2020
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`By:
`
`
`/Stephen E. Murray/
`Stephen E. Murray, Reg. No. 63,206
`Keith A. Jones, Reg. No. 67,781
`PANITCH SCHWARZE BELISARIO & NADEL LLP
`Two Commerce Square
`2001 Market Street, Suite 2800
`Philadelphia, Pennsylvania 19103
`(215) 965-1330
`(215) 965-1331 (Fax)
`smurray@panitchlaw.com (E-Mail)
`kjones@panitchlaw.com (E-Mail)
`
`John D. Simmons, Reg. No. 52,225
`Dennis J. Butler, Reg. No. 51,519
`PANITCH SCHWARZE BELISARIO & NADEL LLP
`Wells Fargo Tower
`2200 Concord Pike, Suite 201
`Wilmington, DE 19803
`(302) 394-6030
`(302) 394-6031 (Fax)
`jsimmons@panitchlaw.com (E-mail)
`dbutler@panitchlaw.com (E-mail)
`
`4
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`
`
`Case No.: IPR2020-00179
`
`
`
`Docket No.: 688266-71IPR
`
`CERTIFICATE OF SERVICE UNDER 37 CFR § 42.6(e)
`
`I hereby certify that a true copy of the foregoing PATENT OWNER’S
`
`REQUEST FOR ORAL ARGUMENT PURSUANT TO 37 CFR § 42.70 has been
`
`served in its entirety this 28th day of December 2020, by electronic mail on
`
`Petitioner’s lead and back-up counsel, as follows:
`
`Dion M. Bregman
`Bradford A. Cangro
`Collin W. Park
`Andrew V. Devkar
`Jeremy D. Peterson
`Morgan, Lewis & Bockius LLP
`1400 Page Mill Road
`Palo Alto, CA, 94304
`LGE-ImmerVision-IPRs@morganlewis.com
`
`
`
`
`
`
`
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`
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`
`
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`
`
`
`/Stephen E. Murray/
`Stephen E. Murray
`Registration No. 63,206
`Attorney for ImmerVision, Inc.
`
`
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