`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`SAMSUNG ELECTRONICS CO., LTD., DELL TECHNOLOGIES INC.,
`and ANKER INNOVATIONS LTD.,1
`
`Petitioner,
`v.
`MYPAQ HOLDINGS LTD.,
`Patent Owner.
`
`
`IPR2022-00311
`Patent No. 8,477,514
`
`
`
`
`
`
`PETITIONER’S REQUEST FOR ORAL HEARING
`37 C.F.R. § 42.70
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`1 Anker Innovations Ltd. filed a motion for joinder and a petition in IPR2022-01134
`and has been joined as a petitioner in this proceeding.
`
`
`
`Pursuant to 37 C.F.R. § 42.70(a), Petitioner respectfully requests the
`
`opportunity to present oral argument. As specified in the Board’s May 23, 2022
`
`Scheduling Order (Paper No. 12), oral argument for this IPR and IPR2022-00307,
`
`IPR2022-00308 and IPR2022-00312 are scheduled for February 23 and 24, 2023.
`
`Given the overlap in issues between this IPR and IPR2022-00312, Petitioner
`
`believes it would be efficient for these two IPRs to be argued together in a single
`
`combined hearing.
`
`Petitioner therefore requests a single combined hearing for this IPR and
`
`IPR2022-00312 with 90 minutes of argument per side (180 minutes total),
`
`including any time reserved for rebuttal, with Petitioner arguing first as the party
`
`with the burden of showing unpatentability. Alternatively, if the Board will hold a
`
`separate hearing in each of this IPR and IPR2022-00312, Petitioner requests 60
`
`minutes of argument per side (120 minutes total).
`
`Petitioner requests that the oral argument be held remotely by
`
`videoconference, rather than in person, consistent with the Board’s notice that the
`
`Board “will only conduct an in-person hearing when requested by all parties.” See
`
`<https://www.uspto.gov/patents/ptab/hearings>. Petitioner requests the ability to
`
`present demonstratives and exhibits to the Board during the videoconference (e.g.,
`
`using a “screen share” function), and the ability to have additional counsel attend
`
`the videoconference from separate locations (e.g., from Korea and Austin, TX,
`
`
`
`where Petitioner’s in-house counsel are located).
`
`If the Board requires an in-person hearing, then Petitioner requests that its
`
`attorneys be allowed to use computers at the hearing to avoid the need for the
`
`parties to bring entire paper copies of the record into the hearing room and to
`
`facilitate efficient answering of panel questions. Petitioner would also request the
`
`following equipment: an ELMO by the lectern to display printed documents, and
`
`an HDMI cable at counsel’s table to permit the display of documents from
`
`counsel’s laptop computer (e.g., PowerPoint or PDF slides).
`
`Petitioner requests oral hearing on all instituted grounds of unpatentability,
`
`disputed claim constructions, any motions to exclude, any procedural or
`
`evidentiary issues raised by the parties, and any additional issues or questions
`
`raised by the Board or the parties before or during the oral argument. Petitioner
`
`also requests oral argument on any issues raised by Patent Owner in its Request for
`
`Respectfully submitted,
`
` /
`
`
`
` Eliot D. Williams /
`Eliot D. Williams
`Reg. No. 50,822
`BAKER BOTTS L.L.P.
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`T: (650) 739-7511
`F: (650) 739-7611
`
`
`Oral Argument.
`
`Dated: January 9, 2023
`
`
`
`Neil P. Sirota
`Reg. No. 38,306
`Eric J. Faragi
`Reg. No. 51,259
`Frank Zhu
`Reg. No. 71,214
`BAKER BOTTS L.L.P.
`30 Rockefeller Plaza
`New York, NY 10112
`T: (212) 408-2500
`F: (212) 408-2501
`
`Counsel for Petitioner
`Samsung Electronics Co., Ltd.
`
`/ Paula Heyman /
`Paula Heyman
`Reg. No. 48,363
`Brett Thompsen
`Reg. No 69,985
`MCDERMOTT WILL & EMERY
`303 Colorado Street, Suite 2200
`Austin, TX 78701
`T: (512) 726-2600
`F: (512) 684-7732
`
`Counsel for Petitioner
`Dell Technologies Inc.
`
`
` /
`
` Ping Wang /
`Ping Wang
`Reg. No. 48,328
`RIMON PC
`1990 K Street, N.W., Suite 420
`Washington, DC 20006
`T: 202-519-2151
`
`Eric Cohen
`
`
`
`
`
`
`
`
`
`
`Registration No. 27,429
`RIMON PC
`P.O. Box B1113
`150 Fayetteville St, Suite 2800
`Raleigh, NC 27601-2960
`T: 919-825-4877
`
`Counsel for Petitioner
`Anker Innovations Ltd.
`
`
`
`
`
`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), I certify that on this 9th day of January,
`
`2023, the foregoing was served by email on the following counsel:
`
`For Patent Owner:
`
`
`
`James T. Carmichael, Reg. No. 45,306
`jim@carmichaelip.com
`Stephen McBride, Reg. No. 78,396
`stevemcbride@camichaelip.com
`Minghui Yang, Reg No. 71,989
`mitch@carmichaelip.com
`Carmichael IP, PLLC
`8000 Towers Crescent Dr., 13th Floor
`Tysons, VA 22182
`
`
`
`Dated: January 9, 2023
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`/ Eliot D. Williams /
`Eliot D. Williams
`Reg. No. 50,822
`BAKER BOTTS L.L.P.
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`T: (650) 739-7511
`F: (650) 739-7611
`Counsel for Petitioner Samsung
`Electronics Co., Ltd.
`
`