`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`VOLKSWAGEN GROUP OF AMERICA, INC.,
`FORD MOTOR COMPANY, GENERAL MOTORS LLC,
`NISSAN NORTH AMERICA, INC., TESLA, INC., and
`AMERICAN HONDA MOTOR CO., INC.,1
`Petitioner,
`
`v.
`
`NEO WIRELESS LLC,
`Patent Owner,
`____________
`
`Case IPR2022-01539
`Patent 10,965,512 B2
`____________
`
`PATENT OWNER NEO WIRELESS LLC’S
`REQUEST FOR ORAL ARGUMENT
`
`
`
`1 Ford Motor Company filed a motion for joinder and a petition in IPR2023-00764,
`and General Motors LLC, Nissan North America, Inc., Tesla, Inc., and American
`Honda Motor Co., Inc., filed their own motion for joinder and petition in IPR2023-
`00961. Both motions were granted, and, therefore, Ford Motor Company, General
`Motors LLC, Nissan North America, Inc., Tesla, Inc., and American Honda Motor
`Co., Inc., have been joined as petitioners in this proceeding.
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.70 and the Board’s Scheduling Order (Paper 9)
`
`and the Board’s Order Modifying Due Date 8 (Paper 34), Neo Wireless LLC
`
`(“Patent Owner”) respectfully requests oral argument. The parties have met and
`
`conferred, and agree to request oral argument in this proceeding to be held on
`
`February 2, 2024. See Paper 34, 2.
`
`Request For In-Person Hearing: Patent Owner respectfully requests an in-
`
`person hearing in this matter.
`
`Time Allotment: In view of the multiple issues raised, Patent Owner
`
`respectfully requests 1 hour (60 minutes) per side for argument.
`
`Reservation Of Time: Patent Owner requests an opportunity to reserve sur-
`
`rebuttal time to respond to rebuttal arguments by Petitioner, and an opportunity to
`
`provide a closing statement. Compare, e.g., Mangrove Partners Master Fund, Ltd.
`
`et al. v. VirnetX, Inc., IPR2015-01046/01047, Paper 60, 2 (PTAB June 2, 2016)
`
`(“Both parties may reserve some of their argument time for rebuttal, and Patent
`
`Owner will be afforded an opportunity to provide a closing statement along with
`
`any rebuttal.”).
`
`Issues For Argument: Without waiving any issue not specifically identified,
`
`Patent Owner specifies at least the following issues it may discuss at argument:
`
`1
`
`
`
`
`
`• Issues related to the instituted grounds, including, for example, claim
`
`construction, anticipation, obviousness, motivation to combine, and
`
`reasonable expectation of success;
`
`• The timeliness of the arguments raised by Petitioner in the proceedings;
`
`• Any motion to exclude filed by the parties;
`
`• Any other relevant issues raised in papers filed in this proceeding, including
`
`issues raised in papers yet to be filed; and
`
`• Any other issues that the Board deems necessary for issuing a Final Written
`
`Decision, including any questions, rebuttals, or arguments that may arise
`
`during the oral argument.
`
`The Board’s advance guidance is respectfully solicited as to any questions
`
`the Board specifically wishes to be addressed.
`
`Equipment: Patent Owner requests the ability to use a computer, projector,
`
`and screen to display possible demonstratives and exhibits.
`
`
`
`Respectfully submitted,
`
`/ Kenneth Weatherwax /
`
`
`Kenneth J. Weatherwax, Reg. No. 54,528
`LOWENSTEIN & WEATHERWAX LLP
`
`Date: December 21, 2023
`
`2
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the following documents were served
`
`by electronic service, by agreement between the parties, on the date below:
`
`PATENT OWNER NEO WIRELESS LLC’S
`REQUEST FOR ORAL ARGUMENT
`
`The names and address of the parties being served are as follows:
`
`rrichardson-PTAB@sternekessler.com
`ttang-PTAB@sternekessler.com
`mspecht-PTAB@sternekessler.com
`dyonan-PTAB@sternekessler.com
`PTAB@sternekessler.com
`
`FPGP0139IPR@brookskushman.com
`
`
`
`
`
`IPR18768-0206IP1@fr.com
`PTABInbound@fr.com
`
`
`rhill@jenner.com
`nkeenan@jenner.com
`
`Ryan C. Richardson
`Timothy L. Tang
`Michael D. Specht
`Daniel E. Yonan
`
`
`John S. LeRoy
`Christopher Smith
`Kyle G. Konz
`
`Timothy W. Riffe
`Usman A. Khan
`John T. Johnson
`Jeffrey C. Mok
`Reginald J. Hill
`Nicole A. Keenan
`
`
`
`Respectfully submitted,
`
`/ Robert Pistone /
`
`Date: December 21, 2023
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
