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`Paper No. 43
`Filed: October 20, 2021
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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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`INTEL CORPORATION and XILINX, INC.1,
`Petitioners
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` v.
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`FG SRC LLC,
`Patent Owner
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`Case IPR2020-01449
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`Patent No. 7,149,867 B2
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT PURSUANT TO
`37 C.F.R. § 42.70(a)
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`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.
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`Patent Owner, FG SRC LLC, by and through its attorneys, respectfully
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`requests oral argument, currently scheduled for January 6, 2022. Patent Owner
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`requests a total of 60 minutes to present its arguments, as well as to reserve a portion
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`of its total time for presenting rebuttal arguments after Petitioners’ presentation.
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`Pursuant to 37 C.F.R § 42.70, and without intending to waive any issue not
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`specifically identified, Patent Owner specifies the following issues to be argued
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`regarding the present IPR:
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`1. That claims 1, 2, 4-8, and 13-19 of U.S. Patent No. 7,149,867 are not obvious
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`under 35 U.S.C. § 103 over Zhang, Exhibit 1003, in view of Gupta, Exhibit
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`1004;
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`2. That claims 3 and 9-12 of U.S. Patent No. 7,149,867 are not obvious under 35
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`U.S.C. § 103 over Zhang, Exhibit 1003, including Gupta, Exhibit 1004, in
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`view of Chien, Exhibit 1005;
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`3. That neither Zhang, Exhibit 1003, Gupta, Exhibit 1004, nor Chien, Exhibit
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`1005, qualify as printed publications within the meaning of 35 U.S.C. § 102;
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`4. That revised amended claims 20-38 are patentable and not obvious or
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`anticipated;
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`5. Proper claim construction for claim limitations raised in Patent Owner’s
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`Response, Patent Owner’s Motion to Amend, and Patent Owner’s Revised
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`Motion to Amend;
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`6. Any issue identified in Petitioners’ Request for Oral Argument;
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`7. Any other issues raised in papers yet to be filed, such as Motions to Exclude;
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`and
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`8. Any other issues the Board deems necessary to consider for issuing a Final
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`Written Decision.
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`Patent Owner requests that the Board provide audio-visual equipment to
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`display demonstrative exhibits, including a projector to be connected to a laptop and
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`a screen for displaying documents.
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`Date: October 20, 2021
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`Respectfully submitted,
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`/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
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`3
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`Ari Rafilson
`Reg. No. 58,693
`SHORE CHAN LLP
`901 Main Street, Suite 3300
`Dallas, TX 75202
`arafilson@shorechan.com
`(214) 593-9110
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`Counsel for Patent Owner FG
`SRC LLC
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`4
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.70(a), the undersigned certifies that a complete
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`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
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`electronic service, to the Petitioner by serving the correspondence address of
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`record as follows:
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`Brian C. Nash
`PILLSBURY WINTHROP SHAW PITTMAN LLP
`401 Congress Avenue, Suite 1700
`Austin, TX 78701
`brian.nash@pillsburylaw.com
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`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
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`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
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`Dated: October 20, 2021
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`/Jay P. Kesan /
`Jay P. Kesan
`Reg. No. 37,488
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