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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD., DELL TECHNOLOGIES INC.,
`and ANKER INNOVATIONS LTD.,1
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`Petitioner,
`v.
`MYPAQ HOLDINGS LTD.,
`Patent Owner.
`
`
`IPR2022-00311
`Patent No. 8,477,514
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`PETITIONER’S REQUEST FOR ORAL HEARING
`37 C.F.R. § 42.70
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`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.
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`Pursuant to 37 C.F.R. § 42.70(a), Petitioner respectfully requests the
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`opportunity to present oral argument. As specified in the Board’s May 23, 2022
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`Scheduling Order (Paper No. 12), oral argument for this IPR and IPR2022-00307,
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`IPR2022-00308 and IPR2022-00312 are scheduled for February 23 and 24, 2023.
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`Given the overlap in issues between this IPR and IPR2022-00312, Petitioner
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`believes it would be efficient for these two IPRs to be argued together in a single
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`combined hearing.
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`Petitioner therefore requests a single combined hearing for this IPR and
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`IPR2022-00312 with 90 minutes of argument per side (180 minutes total),
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`including any time reserved for rebuttal, with Petitioner arguing first as the party
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`with the burden of showing unpatentability. Alternatively, if the Board will hold a
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`separate hearing in each of this IPR and IPR2022-00312, Petitioner requests 60
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`minutes of argument per side (120 minutes total).
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`Petitioner requests that the oral argument be held remotely by
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`videoconference, rather than in person, consistent with the Board’s notice that the
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`Board “will only conduct an in-person hearing when requested by all parties.” See
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`<https://www.uspto.gov/patents/ptab/hearings>. Petitioner requests the ability to
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`present demonstratives and exhibits to the Board during the videoconference (e.g.,
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`using a “screen share” function), and the ability to have additional counsel attend
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`the videoconference from separate locations (e.g., from Korea and Austin, TX,
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`where Petitioner’s in-house counsel are located).
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`If the Board requires an in-person hearing, then Petitioner requests that its
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`attorneys be allowed to use computers at the hearing to avoid the need for the
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`parties to bring entire paper copies of the record into the hearing room and to
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`facilitate efficient answering of panel questions. Petitioner would also request the
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`following equipment: an ELMO by the lectern to display printed documents, and
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`an HDMI cable at counsel’s table to permit the display of documents from
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`counsel’s laptop computer (e.g., PowerPoint or PDF slides).
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`Petitioner requests oral hearing on all instituted grounds of unpatentability,
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`disputed claim constructions, any motions to exclude, any procedural or
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`evidentiary issues raised by the parties, and any additional issues or questions
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`raised by the Board or the parties before or during the oral argument. Petitioner
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`also requests oral argument on any issues raised by Patent Owner in its Request for
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`Respectfully submitted,
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` /
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`
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` 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
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`Oral Argument.
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`Dated: January 9, 2023
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`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
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`Counsel for Petitioner
`Samsung Electronics Co., Ltd.
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`/ 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
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`Counsel for Petitioner
`Dell Technologies Inc.
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` /
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` Ping Wang /
`Ping Wang
`Reg. No. 48,328
`RIMON PC
`1990 K Street, N.W., Suite 420
`Washington, DC 20006
`T: 202-519-2151
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`Eric Cohen
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`Registration No. 27,429
`RIMON PC
`P.O. Box B1113
`150 Fayetteville St, Suite 2800
`Raleigh, NC 27601-2960
`T: 919-825-4877
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`Counsel for Petitioner
`Anker Innovations Ltd.
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`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), I certify that on this 9th day of January,
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`2023, the foregoing was served by email on the following counsel:
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`For Patent Owner:
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`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
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`Dated: January 9, 2023
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`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.
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