`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MICRON TECHNOLOGY, INC.,
`Petitioner,
`
`v.
`
`VERVAIN, LLC,
`Patent Owner
`
`____________________________
`
`Case No.: IPR2021-01549
`U.S. Patent No. 9,997,240
`Original Issue Date: June 12, 2018
`
`Title: LIFETIME MIXED LEVEL NON-VOLATILE MEMORY SYSTEM
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`Pursuant to 37 C.F.R. § 42.70 and the Board’s Scheduling Order dated April
`
`8, 2022 (Paper No. 11), Petitioner Micron Technology, Inc. (“Petitioner”) requests
`
`Oral Argument on issues related to the patentability of claims 1, 2, 6, and 7 of U.S.
`
`Patent No. 9,997,240.
`
`Petitioner requests to present arguments on the following issues:
`
` All grounds on which trial was instituted, including all issues raised by
`
`the parties’ papers;
`
` Any issue raised by either party in a motion to exclude (if any),
`
`objections to demonstrative exhibits (if any), or any other motion or
`
`paper filed by either party before oral argument;
`
` Rebuttal to any issue raised by either party in its presentation at the oral
`
`argument; and
`
` Any additional issue on which the Board seeks clarification.
`
`There are four IPR proceedings covering four patents that all share a common
`
`specification:
`
`1. IPR2021-01547 (298 Patent) ;
`
`2. IPR2021-01548 (385 Patent);
`
`3. IPR2021-01549 (240 Patent) (which this Request covers); and
`
`4. IPR2021-01550 (300 Patent).
`
`1
`
`
`
`Given common Patent Owner arguments among the four proceedings, and
`
`subject to any preferences of the Board, Petitioner believes that it would be most
`
`efficient for arguments to proceed as follows:
`
`1. Combine oral argument for IPR2021-01547 (298 Patent) and IPR2021-
`
`01548 (385 Patent) into a single, consolidated hearing. Petitioner
`
`respectfully proposes that each party be given 60 minutes of argument time
`
`for the consolidated hearing, inclusive of any rebuttal time.
`
`2. Following this argument, the parties will argue IPR2021-01549 (240
`
`Patent). Petitioner respectfully proposes that each party be given 45
`
`minutes of argument time for the hearing, inclusive of any rebuttal time.
`
`3. Following this argument, the parties will argue IPR2021-01550 (300
`
`Patent). Petitioner respectfully proposes that each party be given 45
`
`minutes of argument time for the hearing, inclusive of any rebuttal time.
`
`Petitioner also respectfully requests the ability to use audio-visual equipment
`
`to display demonstrative exhibits, including use of a computer, a projector, a digital
`
`projector / document camera (“Elmo”), and a screen.
`
`To the extent the Oral Argument is conducted by video or telephone,
`
`Petitioner respectfully requests permission to file its demonstratives with the Board
`
`and to refer to its demonstratives during argument.
`
`2
`
`
`
`Dated: November 23, 2022
`
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`
`By:
`Jeremy Jason Lang
`Lead Counsel for Petitioner
`Reg. No. 73,064
`1000 Marsh Road
`Menlo Park, CA 94025-1015
`T: (650) 614-7400
`F: (650) 614-7401
`Email: PTABDocketJJL2@orrick.com
`Attorney for Petitioner
`
`3
`
`
`
`CERTIFICATE OF SERVICE
`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e), that service
`
`was made on the Patent Owner as detailed below.
`
`Date of Service
`
`November 23, 2022
`
`Manner of Service
`
`Electronic Mail
`
`Documents Served
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`Persons Served
`
`Patent Owner’s Counsel of Record
`Alan Whitehurst
`awhitehurst@mckoolsmith.com
`Christopher P. McNett
`cmcnett@mckoolsmith.com
`Arvind Jairam
`ajairam@mckoolsmith.com
`MCKOOL SMITH, P.C.
`1999 K St. NW, Suite 600
`Washington, DC 20006
`
`James E. Quigley
`Reg. No. 78,596
`jquigley@mckoolsmith.com
`MCKOOL SMITH, P.C.
`303 Colorado Street, Suite 2100
`Austin, Texas 78701
`
`Copy: Vervain-Mic-MS@McKoolSmith.com
`
`/Karen Johnson/
` Karen Johnson
`
`4
`
`
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