`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MICRON TECHNOLOGY, INC.,
`Petitioner,
`
`v.
`
`VERVAIN, LLC,
`Patent Owner
`
`____________________________
`
`Case No.: IPR2021-01550
`U.S. Patent No. 10,950,300
`Original Issue Date: March 16, 2021
`
`Title: LIFETIME MIXED LEVEL NON-VOLATILE MEMORY SYSTEM
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`
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`Pursuant to 37 C.F.R. § 42.70 and the Board’s Scheduling Order dated April
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`11, 2022 (Paper No. 12), Petitioner Micron Technology, Inc. (“Petitioner”) requests
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`Oral Argument on issues related to the patentability of claims 1-12 of U.S. Patent
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`No. 10,950,300.
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`Petitioner requests to present arguments on the following issues:
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` All grounds on which trial was instituted, including all issues raised by
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`the parties’ papers;
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` Any issue raised by either party in a motion to exclude (if any),
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`objections to demonstrative exhibits (if any), or any other motion or
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`paper filed by either party before oral argument;
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` Rebuttal to any issue raised by either party in its presentation at the oral
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`argument; and
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` Any additional issue on which the Board seeks clarification.
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`There are four IPR proceedings covering four patents that all share a common
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`specification:
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`1. IPR2021-01547 (298 Patent);
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`2. IPR2021-01548 (385 Patent);
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`3. IPR2021-01549 (240 Patent); and
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`4. IPR2021-01550 (300 Patent) (which this Request covers).
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`1
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`
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`Given common Patent Owner arguments among the four proceedings, and
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`subject to any preferences of the Board, Petitioner believes that it would be most
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`efficient for arguments to proceed as follows:
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`1. Combine oral argument for IPR2021-01547 (298 Patent) and IPR2021-
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`01548 (385 Patent) into a single, consolidated hearing. Petitioner
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`respectfully proposes that each party be given 60 minutes of argument time
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`for the consolidated hearing, inclusive of any rebuttal time.
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`2. Following this argument, the parties will argue IPR2021-01549 (240
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`Patent). Petitioner respectfully proposes that each party be given 45
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`minutes of argument time for the hearing, inclusive of any rebuttal time.
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`3. Following this argument, the parties will argue IPR2021-01550 (300
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`Patent). Petitioner respectfully proposes that each party be given 45
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`minutes of argument time for the hearing, inclusive of any rebuttal time.
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`Petitioner also respectfully requests the ability to use audio-visual equipment
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`to display demonstrative exhibits, including use of a computer, a projector, a digital
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`projector / document camera (“Elmo”), and a screen.
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`To the extent the Oral Argument is conducted by video or telephone,
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`Petitioner respectfully requests permission to file its demonstratives with the Board
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`and to refer to its demonstratives during argument.
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`2
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`
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`Dated: November 23, 2022
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`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
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`3
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`
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`CERTIFICATE OF SERVICE
`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e), that service
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`was made on the Patent Owner as detailed below.
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`Date of Service
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`November 23, 2022
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`Manner of Service
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`Electronic Mail
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`Documents Served
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`Persons Served
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`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
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`Copy: Vervain-Mic-MS@McKoolSmith.com
`
`/Karen Johnson/
` Karen Johnson
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`4
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