`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Motherson Innovations Co., Ltd.,
`Petitioner,
`
`v.
`
`Magna Mirrors of America, Inc.,
`Patent Owner.
`
`Case IPR2020-00777
`Patent No. 10,261,648
`
`Patent Owner’s Request for Oral Argument
`
`
`
`IPR2020-00777
`
`Patent No. 10,261,648
`
`Pursuant to 37 C.F.R. § 42.70(a) and the Board’s Scheduling Order (Paper
`
`8), Patent Owner, Magna Mirrors of America, Inc., hereby submits this Request for
`
`Oral Argument, which is currently scheduled for July 13, 2021.
`
`Without waiving consideration of any issue not identified below, Patent
`
`Owner respectfully requests one hour to address all grounds on which trial was
`
`instituted and all issues raised by the parties’ papers, including the following issues:
`
`1.
`
`Claim construction of the following terms:
`
`a.
`
`“Exterior mirror reflective element fixedly attached at said
`
`mirror head”
`
`b.
`
`“A bracket to which said exterior mirror reflective element is
`
`fixedly attached”
`
`c.
`
`“Wherein the outermost front perimeter edge of said exterior
`
`mirror reflective element is rounded”
`
`d.
`
`e.
`
`“Rearward field of view”
`
`“Yaw” and “roll”
`
`2.
`
`Lupo, alone or in combination with McCabe, Tsuyama, and/or any
`
`other reference, does not disclose or render obvious all of the elements of the
`
`challenged claims;
`
`1
`
`
`
`IPR2020-00777
`
`Patent No. 10,261,648
`
`3.
`
`Tsuyama, alone or in combination with McCabe and/or any other
`
`reference, does not disclose or render obvious all of the elements of the challenged
`
`claims;
`
`4.
`
`5.
`
`6.
`
`Patent Owner’s and Petitioner’s Motions To Exclude Evidence, if any;
`
`Rebuttal of any arguments made by Petitioner;
`
`Response to any issues Petitioner raises in its Request for Oral
`
`Argument; and
`
`7.
`
`Any additional issues on which the Board seeks clarification or any
`
`other issues the Board deems necessary for issuing a final written decision.
`
`Patent Owner may reserve a portion of its time for reply to Petitioner’s
`
`presentation on any issues. Patent Owner also respectfully requests the ability to
`
`use audio-visual equipment to display demonstratives and exhibits, including the
`
`use of a computer, projector, and screen.
`
`2
`
`
`
`IPR2020-00777
`
`Patent No. 10,261,648
`
`Dated: June 1, 2021
`
`Respectfully submitted,
`
`/Dennis J. Abdelnour, Reg. No. 77,172/
`
`Dennis J. Abdelnour
`Registration No. 77,172
`HONIGMAN LLP
`155 N. Wacker Drive, Suite 3100
`Chicago, IL 60606-1734
`Tel: (312) 701-9300
`Fax: (312) 701-9335
`dabdelnour@honigman.com
`
`Timothy A. Flory
` Registration No. 42,540
`HONIGMAN LLP
`300 Ottawa Avenue NW, Suite 400
`Grand Rapids, MI 49503-2308
`Tel: (616) 649-1900
`tflory@honigman.com
`
`David J. Thomas
`Registration. No. 75,471
`HONIGMAN LLP
`39400 Woodward Ave., Suite 101
`Bloomfield Hills, MI 48304
`Telephone: (248) 566-8642
`dthomas@honigman.com
`
`Counsel for Patent Owner Magna Mirrors of
`America, Inc.
`
`3
`
`
`
`IPR2020-00777
`
`Patent No. 10,261,648
`
`CERTIFICATE OF SERVICE
`Under 37 C.F.R. § 42.6, I hereby certify that I served a copy of the foregoing
`
`document on counsel of record for the Petitioner by filing this document through
`
`the Patent Trial and Appeal Board End to End (PTAB E2E) System and by
`
`delivering a copy via e-mail to the addresses below.
`
`Lead Counsel
`
`Back-up Counsel
`
`Kenneth S. Luchesi (Reg. No. 58,673)
`JONES DAY
`901 Lakeside Ave.
`Cleveland, OH 44114
`(216) 586-7059
`kluchesi@jonesday.com
`
`Joseph M. Sauer (Reg. No. 47,919)
`David B. Cochran (Reg. No. 39,142)
`Robert M. Breetz (Reg. No. 75,550)
`JONES DAY
`901 Lakeside Ave.
`Cleveland, OH 44114
`jmsauer@jonesday.com
`dcochran@jonesday.com
`rbreetz@jonesday.com
`
`Dated: June 1, 2021
`
`HONIGMAN LLP
`
`/Dennis J. Abdelnour, Reg. No. 77,172/
`
`Dennis J. Abdelnour
`Registration No. 77,172
`HONIGMAN LLP
`155 N. Wacker Drive, Suite 3100
`Chicago, IL 60606-1734
`Tel: (312) 701-9300
`Fax: (312) 701-9335
`dabdelnour@honigman.com
`
`Counsel for Patent Owner Magna Mirrors of
`America, Inc.
`
`4
`
`
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