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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`INTEL CORPORATION and XILINX, INC.,1
`Petitioners
`v.
`FG SRC LLC,
`Patent Owner
`____________________
`CASE NO.: IPR2020-01449
`PATENT NO. 7,149,867
`____________________
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`1 Xilinx, Inc. filed a motion for joinder and petition in IPR2021-00633, which were
`granted, and, therefore, has been joined as petitioner in this proceeding
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`1
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`Pursuant to 37 C.F.R. § 42.70(a), and the Board’s October 7, 2021 Revised
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`Scheduling Order (Paper 42), Petitioner Intel Corporation respectfully requests oral
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`argument, which is currently scheduled for January 6, 2022, on at least the following
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`issues:
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`1.
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`The unpatentability of challenged claims 1-19 of the ’867 patent as set
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`forth in each of the instituted grounds;
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`2.
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`Patent Owner’s failure to meet its many burdens on the Revised Motion
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`to Amend, including by proposing amendments that add new matter, lack
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`written description support, and improperly enlarge the original claim scope;
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`3.
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`4.
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`The unpatentability of Patent Owner’s proposed amended claims 20-38;
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`Any issues subsidiary to the above issues, including, but not limited to,
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`publication status, claim construction, priority date, assessment of evidence,
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`and admissibility and sufficiency of evidence; and
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`5.
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`Any other issues raised in papers filed in the present proceeding,
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`including issues raised in any papers filed between today and the oral hearing.
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`The Office’s notice regarding oral hearings occurring after March 13, 2020
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`requires that hearings be conducted remotely by video or telephone until further
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`notice. Petitioner is available to participate in that manner. To the extent that notice
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`is not in effect by the time of the hearing in this proceeding and the Board would
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`1
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`prefer to hold the hearing in-person, Petitioner respectfully requests that the hearing
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`be held at the USPTO headquarters in Alexandria.
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`Petitioner respectfully requests that the Board provide audio-visual equipment
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`to display demonstrative exhibits, including a projector and a screen configured to
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`display documents from a laptop computer (e.g., PowerPoint display) and ELMO
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`document camera/projector if available.
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`Petitioner believes the ordinary amount of time set forth in the Trial Practice
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`Guide (i.e., one hour of argument per side) will be sufficient to present its argument
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`in this proceeding.
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`Dated: November 17, 2021
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` Respectfully submitted,
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`By: /s/ Brian C. Nash
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`Brian C. Nash (Reg. No. 58,105)
`Pillsbury Winthrop Shaw Pittman LLP
`401 Congress Avenue, Suite 1700
`Austin, TX 78701
`Telephone: (512) 580-9629
`Facsimile: (512) 580-9601
`Email: brian.nash@pillsburylaw.com
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`Counsel for Petitioner Intel Corporation
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`2
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true copy of “PETITIONER’S REQUEST FOR
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`ORAL ARGUMENT” was served electronically via e-mail on November 17, 2021,
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`in its entirety on the following:
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`Jay P. Kesan, Reg. No. 37,488
`DIMUROGINSBERG, PC
`DGKEYIP GROUP
`1750 Tyson’s Blvd. Suite 1500
`Tysons Corner, VA 22102
`jkesan@dimuro.com
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`Ari Rafilson, Reg. No. 58,693
`Shore Chan DePumpo LLP
`901 Main Street, Suite 3300
`Dallas, TX 75202
`arafilson@shorechan.com
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`Dated: November 17, 2021
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`By: /s/ Brian C. Nash
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`Brian C. Nash (Reg. No. 58,105)
`Pillsbury Winthrop Shaw Pittman LLP
`401 Congress Avenue, Suite 1700
`Austin, TX 78701
`Telephone: (512) 580-9629
`Facsimile: (512) 580-9601
`Email: brian.nash@pillsburylaw.com
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`Counsel for Petitioner Intel Corporation
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`3
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