`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________
`
`
`MOTHERSON INNOVATIONS CO., LTD.,
`
`Petitioner
`
`v.
`
`MAGNA MIRRORS OF AMERICA, INC.,
`
`Patent Owner
`
`__________________
`
`IPR2020-00777
`U.S. Patent No. 10,261,648
`__________________
`
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`IPR2020-00777
`Patent 10,261,648
`
`Pursuant to 37 C.F.R. § 42.70(a), Petitioner Motherson Innovations Co., Ltd.
`
`(“Motherson”) hereby requests an opportunity to present oral argument regarding the
`
`issues set forth below.
`
`1. All grounds on which trial was instituted and all issues raised by the
`
`parties’ papers, including:
`
`a. Why claims 1, 3, 5-13, and 15 are obvious under § 103 in view of
`
`Lupo;
`
`b. Why claims 2, 16-17, and 19-36 are obvious under § 103 over
`
`Lupo in view of McCabe;
`
`c. Why claim 4 is obvious under § 103 over Lupo in view of
`
`Tsuyama
`
`d. Why claim 18 is obvious under § 103 over Lupo in view of
`
`McCabe in further view of Tsuyama;
`
`e. Why claims 1, 5, 8-9, 12, and 15 are obvious under § 103 in view
`
`of Tsuyama;
`
`f. Why claims 2, 16, 19-20, 24-27, 31, 33, and 36 are obvious under
`
`§ 103 over Tsuyama in view of McCabe;
`
`2. Any issue raised by either party in a motion to exclude, objections to
`
`demonstrative exhibits, or any other motion or paper filed by either party
`
`
`
`1
`
`
`
`
`
`
`
`
`
`
`
`
`
`IPR2020-00777
`Patent 10,261,648
`
`before oral argument;
`
`3. Rebuttal to any issue raised by Patent Owner during its presentation at
`
`oral argument; and
`
`4. Any additional issue on which the Board seeks information or
`
`clarification.
`
`
`Date: June 1, 2021
`
`
`
`
`Respectfully submitted,
`
`By: /Kenneth S. Luchesi/
`
`Kenneth S. Luchesi
`Reg. No. 58,673
`JONES DAY
`901 Lakeside Ave.
`Cleveland , OH 44114
`Telephone: (216) 586-3939
`Facsimile: (216) 579-0212
`Email: kluchesi@jonesday.com
`
`
`
`2
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`Under 37 C.F.R § 42.6, I hereby certify
`that on June 1, 2021,
`
`IPR2020-00777
`Patent 10,261,648
`
`I served a copy of the foregoing document on counsel of record for the Patent Owner
`
`by filing this document through the Patent Trial and Appeal Board End to End System
`
`and by delivering a copy via e-mail to the addresses listed below:
`
`dabdelnour@honigman.com
`
`tflory@honigman.com
`
`dthomas@honigman.com
`
`Counsel for Patent Owner, Magna Mirrors of America, Inc.
`
`Date: June 1, 2021
`
`
`
`
`
`
`
`
`/Kenneth S. Luchesi/
`Counsel for Petitioner
`
`
`
`
`
`
`
`
`
`3
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
