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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`LKQ Corporation and Keystone Automotive Industries, Inc.,
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`Petitioner,
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`v.
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`GM Global Technology Operations LLC,
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`Patent Owner.
`____________
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`Case No. IPR2020-00534
`US. Design Patent No. D797,625
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`_____________________________________________________
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`PETITIONERS’ REQUEST FOR ORAL HEARING
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`Petitioners’ Request for Oral Hearing in IPR2020-00534
`D797,625
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`Pursuant to 37 C.F.R. § 42.70 and the Scheduling Order, Petitioners LKQ
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`Corporation and Keystone Automotive Industries, Inc. (“Petitioners”) respectfully
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`submit this request for an oral hearing regarding the patentability of the sole claim
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`of U.S. Design Patent No. D797,625 (“the ’625 Patent”). The oral hearing is
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`currently scheduled for April 27, 2021. Paper 11, at 10. Petitioners identify the
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`following issues for oral argument:
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`1. invalidity of the sole claim of the ’625 Patent as anticipated by prior art
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`U.S. Design Patent No. D773,340 (“Lian”) or obvious in view of Lian
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`alone and/or the combination of Lian and the asserted prior art
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`publication depicting the 2015 Hyundai Tucson;
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`2. failure of Patent Owner to establish basis in fact or law for arguments
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`advanced in its Response and Surreply, including regarding the legal
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`significance of the purported “crowded field” of prior art and the
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`knowledge and skill of a designer of ordinary skill in the art;
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`3. rebuttal to all arguments advanced in Patent Owner’s presentation;
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`4. any motion to exclude filed in this proceeding; and
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`5. any additional issues regarding which the Board seeks clarification.
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`Petitioners request ninety (90) minutes per side to present arguments in this
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`case. To the extent the Board schedules the hearing to last more than three hours,
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`Petitioners request half the time allotted by the Board to address the above-listed
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`1
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`Petitioners’ Request for Oral Hearing in IPR2020-00534
`D797,625
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`issues. To the extent the hearing is not held via videoconference, Petitioners
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`request that a screen or projector be made available for displaying demonstrative
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`exhibits (a PowerPoint presentation or the like). In accordance with the Trial
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`Practice Guide, Petitioner will contact the Board Trial Division paralegal to discuss
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`this request.
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`Dated: March 23, 2021
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`Respectfully submitted,
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`/Barry F. Irwin, P.C./
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`Barry F. Irwin, P.C.
`Irwin IP LLC
`222 South Riverside Plaza
`Suite 2350
`Chicago, Illinois 60606
`Phone: 312.667.6081
`birwin@irwinip.com
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`Lead Counsel for Patent Owner
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`2
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`Petitioners’ Request for Oral Hearing in IPR2020-00534
`D797,625
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies that a true
`copy of the Petitioners’ Request for Oral Hearing was served on this 23rd Day of
`March, 2021, by e-mail upon the following:
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`LEAD COUNSEL
`Dorothy P. Whelan, Reg. No. 33,814
`3200 RBC Plaza
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`60 South Sixth Street
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`Minneapolis, MN 55402
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`Tel: 612-335-5070/Fax 877-769-7945
`IPR45343-0031IP1@fr.com
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`BACK-UP COUNSEL
`Craig A. Deutsch, Reg. No. 69,264
`Grace J. Kim, Reg. No. 71,977
`Jennifer J. Huang, Reg. No. 64,297
`Joseph A. Herriges, Pro Hac Vice
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Tel: 612-335-5070/Fax 877-769-7945
`PTABInbound@fr.com
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`/Barry F. Irwin, P.C./
`Barry F. Irwin, P.C.
`Registration No. 36,557
`Irwin IP LLC
`222 South Riverside Plaza, Suite 2350
`Chicago, IL 60606
`Phone: 312.667.6081
`birwin@irwinip.com
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`Additional electronic service to:
`whelan@fr.com;
`deutsch@fr.com;
`gkim@fr.com;
`jhuang@fr.com; and
`herriges@fr.com.
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`Patent Owner has consented to service by electronic means.
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`Dated: March 23, 2021
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