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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
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`APPLIED MATERIALS, INC.
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`Petitioner,
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`v.
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`OCEAN SEMICONDUCTOR LLC,
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`Patent Owner.
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`_____________________
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`Case IPR: IPR2021-01342
`U.S. Patent No. 6,968,248
`_____________________
`PETITIONER’S REQUEST FOR CONSOLIDATED ORAL ARGUMENT
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`Petitioner’s Request for Consolidated Oral Argument
`IPR2021-01342
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`Pursuant to 37 C.F.R. § 42.70(a), Petitioner Applied Materials, Inc.
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`respectfully requests oral argument in IPR2021-01342, currently scheduled for
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`November 15, 2022. See Feb. 10, 2022 Scheduling Order (Paper 18) at 12.
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`Petitioner proposes consolidating oral argument in this proceeding with oral
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`argument in IPR2021-01339, -1340, and -1344, all of which are assigned to the
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`same panel and scheduled for the same date, for a combined total of ninety (90)
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`minutes per side.1
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`Petitioner specifies the following issues to be argued that are unique to
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`IPR2021-01342: All issues raised in the Petition (Paper 1) and the Board’s
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`Institution Decision (Paper 17) remaining in dispute which were addressed and not
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`waived in the Patent Owner Response (Paper 21), Petitioner’s Reply (Paper 30),
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`and Patent Owner’s Amended Sur-Reply (Paper 41), subject to the Board’s
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`determination of the authorized motions to strike new arguments and motion to
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`exclude new evidence to be filed. Such issues include the following:
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` The scope and content of the prior art;
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` The patentability of claims 1 and 14 of U.S. Patent No. 6,968,248
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`1 In its request for oral argument filed September 20, 2022 (Paper 40), Patent
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`Owner Ocean Semiconductor LLC has requested 45 minutes for each of these
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`proceedings, for a total of 3 hours per side.
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`1
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`Petitioner’s Request for Consolidated Oral Argument
`IPR2021-01342
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`over Schulze (Ex. 1007) in view of Gupta (Ex. 1008) under 35 U.S.C.
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`§ 103 (Ground I);
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` Any issues properly raised and preserved by Patent Owner, or
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`permitted to be presented by Patent Owner;
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` Any other issues raised in papers filed in this proceeding, including
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`any which may be raised in papers not yet filed;
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` Any issues on which the Board may seek additional information or
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`clarification.
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`Subject to the Board’s approval, Petitioner plans to use demonstrative
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`exhibits during the oral argument, which will be served and filed in accordance
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`with 37 C.F.R. § 42.70(b). Petitioner defers to the Board’s preference on whether
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`the hearing is conducted in person or remotely, provided that the same format
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`applies to both sides. If in person, Petitioner requests the use of audio-visual
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`equipment during its presentation, including a computer, projector, and screen on
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`which to display demonstrative exhibits.
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`2
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`Petitioner’s Request for Consolidated Oral Argument
`IPR2021-01342
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`Dated: September 28, 2022
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`Respectfully submitted,
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`/Eric A. Krause/
`Eric A. Krause (Reg. No. 62,329)
`Lead Attorney for Petitioner
`Applied Materials, Inc.
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`Axinn Veltrop & Harkrider LLP
`55 Second Street
`San Francisco, CA 94105-3491
`(415) 490-1491
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`3
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`Petitioner’s Request for Consolidated Oral Argument
`IPR2021-01342
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`CERTIFICATION OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies that the
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`above-captioned Petitioner’s Request for Consolidated Oral Argument was served
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`in its entirety on September 28, 2022 upon counsel for Patent Owner Ocean
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`Semiconductor LLC via email indicated below:
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`Timothy Devlin (Lead Counsel)
`Alex Chan (Backup Counsel)
`Joel W. Glazer (Backup Counsel)
`Henrik Parker (Backup Counsel)
`Peter Mazur (Backup Counsel)
`Joseph Zito (Backup Counsel)
`Devlin Law Firm LLC
`1526 Gilpin Avenue
`Wilmington, DE 19806
`TD-PTAB@devlinlawfirm.com
`achan@devlinlawfirm.com
`jglazer@devlinlawfirm.com
`hparker@devlinlawfirm.com
`pmazur@devlinlawfirm.com
`jzito@devlinlawfirm.com
`dlflitparas@devlinlawfirm.com
`oceansemi-dlf@devlinlawfirm.com
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`Dated: September 28, 2022k
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`/Eric A. Krause/
`Eric A. Krause (Reg. No. 62,329)
`Lead Attorney for Petitioner
`Applied Materials, Inc.
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`Axinn Veltrop & Harkrider LLP
`55 Second Street
`San Francisco, CA 94105
`(415) 490-1491
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`4
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