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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`BAYERISCHE MOTOREN WERKE AKTIENGESELLSCHAFT & BMW
`OF NORTH AMERICA, LLC,
`Petitioners
`
`v.
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`PAICE LLC & THE ABELL FOUNDATION, INC.
`Patent Owners
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`Inter Partes Review No.: IPR2020-00994
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`U.S. Patent No. 7,104,347 K2
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`___________________
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`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
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`Petitioners’ Request for Oral Argument, IPR2020-00994
`U.S. Patent No. 7,104,347
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`Pursuant to the Board’s Scheduling Order dated November 19, 2020 (Paper
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`20), Petitioners Bayerische Motoren Werke Aktiengesellschaft & BMW of North
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`America, LLC (“BMW”) respectfully request oral argument in the above-identified
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`proceeding, currently scheduled for August 25, 2021 (Paper 30 at 2).
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`Pursuant to 37 C.F.R. § 42.70(a), and without waiving the right to raise any
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`additional issues not listed below, BMW requests an oral hearing on the following
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`issues:
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`1. Any issues raised in BMW’s Petition and Reply, including whether
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`claims 2, 11, 17, 24, 33, and 38 of U.S. Patent No. 7,104,347 are unpatentable over
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`one or more of Grounds 1a, 1b, 1c, 2a, 2b, 2c, 3a, 3b, 4a, 4b, and 4c;
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`2. Any issues raised in the Board’s Institution Decision (Paper 19);
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`3. Any issues raised by Patent Owners Paice LLC and The Abell
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`Foundation, Inc. (“Paice”) in these proceedings, including the Patent Owner
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`Response and Patent Owner Sur-Reply in this proceeding;
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`4. Any other issues raised by BMW, Paice, or the Board during these
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`proceedings;
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`5. Any Motions to Exclude Evidence filed by BMW or Paice;
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`6. Any other motions or filings pending before this Board;
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`7. Any additional issues raised by Paice in its Request for Oral Argument;
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`and
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`1
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`
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`Petitioners’ Request for Oral Argument, IPR2020-00994
`U.S. Patent No. 7,104,347
`
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`8. Any additional issues raised by this Board or Paice at oral argument.
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`
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`BMW requests that each side have 60 minutes for oral argument.
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`Dated: July 8, 2021
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`
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`Respectfully submitted,
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`/Vincent J. Galluzzo/
`Jeffrey D. Sanok (Reg. No. 32,169)
`Vincent J. Galluzzo (Reg. No. 67,830)
`Crowell & Moring LLP
`1001 Pennsylvania Avenue NW
`Washington, DC 20004-2595
`Tel.: (202) 624-2500
`Fax.: (202) 628-8844
`jsanok@crowell.com
`vgalluzzo@crowell.com
`
`Scott L. Bittman (Reg. No. 55,007)
`Jacob Z. Zambrzycki (pro hac vice)
`Crowell & Moring LLP
`590 Madison Avenue, 20th Floor
`New York, NY 10022-2544
`Telephone No.: (212) 223-4000
`Facsimile No.: (212) 223-4134
`sbittman@crowell.com
`jzambrzycki@crowell.com
`
`Counsel for Petitioners
`Bayerische Motoren Werke Aktiengesellschaft
`and BMW of North America, LLC
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`
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`
`
`2
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`
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`Petitioners’ Request for Oral Argument, IPR2020-00994
`U.S. Patent No. 7,104,347
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`
`Certificate of Service
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`Pursuant to 37 C.F.R. § 42.6(e)(4), I certify that the foregoing Petitioners’
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`Request for Oral Argument was served on July 8, 2021 via electronic mail on the
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`following counsel of record for Patent Owners:
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`Ruffin B. Cordell (Reg. No. 33,487)
`Brian J. Livedalen (Reg. No. 67,450)
`Timothy W. Riffe (Reg. No. 43,881)
`FISH & RICHARDSON P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`IPR36351-0004IP1@fr.com
`PTABInbound@fr.com
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`Respectfully submitted,
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`/Vincent J. Galluzzo/
`Vincent J. Galluzzo
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`Dated: July 8, 2021
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`3
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