`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Paper No. 43
`Filed: October 20, 2021
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`INTEL CORPORATION and XILINX, INC.1,
`Petitioners
`
` v.
`
`FG SRC LLC,
`Patent Owner
`
`Case IPR2020-01449
`
`Patent No. 7,149,867 B2
`
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT PURSUANT TO
`37 C.F.R. § 42.70(a)
`
`1 Xilinx, Inc. filed a petition and motion for joinder in IPR2021-00633, which were
`granted and, therefore, has been joined as petitioner in this proceeding.
`
`
`
`
`
`
`
`Patent Owner, FG SRC LLC, by and through its attorneys, respectfully
`
`requests oral argument, currently scheduled for January 6, 2022. Patent Owner
`
`requests a total of 60 minutes to present its arguments, as well as to reserve a portion
`
`of its total time for presenting rebuttal arguments after Petitioners’ presentation.
`
`Pursuant to 37 C.F.R § 42.70, and without intending to waive any issue not
`
`specifically identified, Patent Owner specifies the following issues to be argued
`
`regarding the present IPR:
`
`1. That claims 1, 2, 4-8, and 13-19 of U.S. Patent No. 7,149,867 are not obvious
`
`under 35 U.S.C. § 103 over Zhang, Exhibit 1003, in view of Gupta, Exhibit
`
`1004;
`
`2. That claims 3 and 9-12 of U.S. Patent No. 7,149,867 are not obvious under 35
`
`U.S.C. § 103 over Zhang, Exhibit 1003, including Gupta, Exhibit 1004, in
`
`view of Chien, Exhibit 1005;
`
`3. That neither Zhang, Exhibit 1003, Gupta, Exhibit 1004, nor Chien, Exhibit
`
`1005, qualify as printed publications within the meaning of 35 U.S.C. § 102;
`
`4. That revised amended claims 20-38 are patentable and not obvious or
`
`anticipated;
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`5. Proper claim construction for claim limitations raised in Patent Owner’s
`
`Response, Patent Owner’s Motion to Amend, and Patent Owner’s Revised
`
`Motion to Amend;
`
`6. Any issue identified in Petitioners’ Request for Oral Argument;
`
`7. Any other issues raised in papers yet to be filed, such as Motions to Exclude;
`
`and
`
`8. Any other issues the Board deems necessary to consider for issuing a Final
`
`Written Decision.
`
`
`
`Patent Owner requests that the Board provide audio-visual equipment to
`
`display demonstrative exhibits, including a projector to be connected to a laptop and
`
`a screen for displaying documents.
`
`Date: October 20, 2021
`
`
`
`Respectfully submitted,
`
`/Jay P. Kesan/
`Jay P. Kesan
`Reg. No. 37,488
`Cecil E. Key
`Henning Schmidt
`DIMURO GINSBURG P.C.-
`DGKEYIP GROUP
`1750 Tyson’s Blvd., Suite 1500
`Alexandria, Virginia 22102
`(703) 289-5118
`jkesan@dimuro.com
`ckey@dimuro.com
`hschmidt@dimuro.com
`
`
`
`
`3
`
`
`
`
`
`
`
`Ari Rafilson
`Reg. No. 58,693
`SHORE CHAN LLP
`901 Main Street, Suite 3300
`Dallas, TX 75202
`arafilson@shorechan.com
`(214) 593-9110
`
`Counsel for Patent Owner FG
`SRC LLC
`
`4
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.70(a), the undersigned certifies that a complete
`
`copy of Patent Owner’s Request for Oral Argument was filed electronically through
`the Patent Trial and Appeal Board’s PTAB E2E System and provided, via
`
`electronic service, to the Petitioner by serving the correspondence address of
`
`record as follows:
`
`Brian C. Nash
`PILLSBURY WINTHROP SHAW PITTMAN LLP
`401 Congress Avenue, Suite 1700
`Austin, TX 78701
`brian.nash@pillsburylaw.com
`
`Evan Finkel, Reg. No. 49,059
`PILLSBURY WINTHROP SHAW PITTMAN LLP
`725 South Figueroa Street, Suite 2800
`Los Angeles, CA 90017-5406
`Telephone: (213) 488-7307
`Facsimile: (213) 226-4058
`evan.finkel@pillsburylaw.com
`
`Matthew W. Hindman, Reg. No. 57,396
`PILLSBURY WINTHROP SHAW PITTMAN LLP
`2550 Handover Street
`Palo Alto, CA 94304
`Telephone: 650.233.4087
`Facsimile: 650.233.4545
`matthew.hindman@pillsburylaw.com
`
`Dated: October 20, 2021
`
`/Jay P. Kesan /
`Jay P. Kesan
`Reg. No. 37,488
`
`
`
`
`
`5
`
`
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
