`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`PHILIP MORRIS PRODUCTS, S.A.,
`Petitioner,
`
`v.
`
`RAI STRATEGIC HOLDINGS, INC.,
`Patent Owner.
`
`
`IPR2020-01602
`Patent 9,901,123 B2
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`IPR2020-01602
`U.S. Patent No. 9,901,123
`
`Pursuant to 37 C.F.R. § 42.70(a), Patent Owner RAI Strategic Holdings, Inc.
`
`
`
`hereby requests oral argument. The oral argument is presently set for Thursday,
`
`January 6, 2022. In view of the year-end holidays, Patent Owner respectfully
`
`requests that the Board schedule oral argument for January 10, 11, 13, or 14,
`
`instead of January 6. Patent Owner has conferred with Petitioner, and Petitioner
`
`does not oppose Patent Owner’s request that oral argument be scheduled for
`
`January 10, 11, 13, or 14.
`
`
`
`The issues to be argued include the following:
`
`
`
`1.
`
`The alleged unpatentability of claims 1, 2, 5, 7, 9, 11, 12,
`
`14, 15, 18, 21, and 23-26 as obvious in view of Hon alone or in
`
`combination with Whittemore and/or Brooks.
`
`
`
`2.
`
`The alleged unpatentability of claims 3, 4, 13, 16, and 17
`
`as obvious in view of Hon, Whittemore, Brooks, and Susa.
`
`
`
`3.
`
`The alleged unpatentability of claim 6 and 19 in view of
`
`Hon, Whittemore, Brooks, and Ray.
`
`
`
`4.
`
`Any additional issues the parties raise or propose to raise
`
`at or before the oral argument; and
`
`
`
`5.
`
`Any additional
`
`issues on which
`
`the Board seeks
`
`information or clarification.
`
`
`
`1
`
`
`
`
`
`
`
`
`IPR2020-01602
`U.S. Patent No. 9,901,123
`
`Patent Owner requests 60 minutes of time per side for argument, with the
`
`opportunity to reserve some of the allotted amount of its time for a sur-rebuttal, if
`
`needed.
`
`
`
`Patent Owner further requests the use of audio-visual equipment to assist its
`
`arguments, including a computer-connectable projector and a screen.
`
`
`
`Patent Owner also requests the services of a court reporter to transcribe the
`
`proceeding.
`
`Date: November 19, 2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By: /David M. Maiorana/
`David M. Maiorana, Reg. No. 41,449
`David B. Cochran, Reg. No. 39,142
`Kenneth S. Luchesi, Reg. No. 58,673
`JONES DAY
`North Point, 901 Lakeside Avenue
`Cleveland, OH 44114
`(216) 586-7499
`
`Anthony M. Insogna, Reg. No. 35,203
`JONES DAY
`4655 Executive Drive, Suite 1500
`San Diego, CA 92121
`
`Geoffrey K. Gavin, Reg. No. 47,591
`JONES DAY
`1221 Peachtree Street, N.E., Suite 400
`Atlanta, GA 30361
`
`2
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`IPR2020-01602
`U.S. Patent No. 9,901,123
`
`
`Joshua R. Nightingale, Reg. No. 67,865
`JONES DAY
`500 Grant Street, Suite 4500
`Pittsburgh, PA 15219
`
`Counsel for Patent Owner
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`3
`
`
`
`
`
`
`IPR2020-01602
`U.S. Patent No. 9,901,123
`
`
`CERTIFICATE OF SERVICE
`
`Patent Owner hereby certifies that the foregoing PATENT OWNER’S
`
`REQUEST FOR ORAL ARGUMENT was served electronically via email on
`
`November 19, 2021, on Petitioner’s lead and backup counsel as follows:
`
`Jonathan Strang
`jonathan.strang@lw.com
`
`Matthew Moore
`matthew.moore@lw.com
`
`Lawrence Gotts
`Lawrence.gotts@lw.com
`
`Clement Naples
`clement.naples@lw.com
`
`Gregory K. Sobolski
`greg.sobolski@lw.com
`
`Dale Chang
`Dale.chang@lw.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/David M. Maiorana/
`Counsel for Patent Owner
`
`
`
`
`4
`
`
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
