`___________________
`
`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
`U.S. Patent No. 10,965,512
`___________________
`
`
`
`PETITIONER VOLKSWAGEN GROUP OF AMERICA, INC.’S
`REQUEST FOR ORAL ARGUMENT
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`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.
`
`
`
`Case IPR2022-01539
`U.S. Patent No. 10,965,512
`Pursuant to the Board’s May 5, 2023 Scheduling Order (Paper 8), Petitioner
`
`respectfully requests oral argument. Pursuant to the Board’s November 20, 2023
`
`Order (Paper 34), the parties have agreed to present their oral arguments for this
`
`proceeding on February 2, 2024.2 Petitioner requests one hour in which to present
`
`its arguments. Under 37 C.F.R. § 42.70, and without intending to waive any issue
`
`not specifically identified, Petitioner specifies the following issues to be argued:
`
`1. Whether claims 1-30 of U.S. Patent No. 10,965,512 (“the ’512 patent”)
`
`are unpatentable under 35 U.S.C. § 103(a) over Kim and Tong;
`
`2. Whether claims 1, 3, 4, 6–8, 10, 11, 13–15, 17, 18, 20, 22, 23, 25, 26, 28,
`
`and 30 of the ’512 patent are unpatentable under 35 U.S.C. § 103(a) over
`
`Ketchum and Li;
`
`3. Whether claims 5, 12, 21, and 29 of the ’512 patent are unpatentable
`
`under 35 U.S.C. § 103(a) over Ketchum, Li, and Smee;
`
`4. Any issues specified by Patent Owner in its Request for Oral Argument;
`
`and
`
`5. Any other issues the Board deems necessary for issuing a final written
`
`decision (e.g., any motion to exclude evidence and any motion to seal
`
`evidence).
`
`2 The parties have further agreed to present the oral arguments for IPR2022-
`
`01537 and IPR2022-01567 on February 1, 2024.
`
`- 1 -
`
`
`
`Case IPR2022-01539
`U.S. Patent No. 10,965,512
`Petitioner also requests that the Board provide audio-visual equipment to
`
`display demonstrative exhibits, including a projector and screen for displaying
`
`documents from a computer.
`
`Further, Petitioner requests that the hearing be held at the USPTO’s
`
`Alexandria, Virginia office because that location will be more convenient, have
`
`simpler logistics, and be less costly for Petitioner. Petitioner notes that its counsel
`
`are located in the Washington, DC area.
`
`Respectfully submitted,
`
`STERNE, KESSLER, GOLDSTEIN & FOX PLLC
`
`/Ryan C. Richardson, Reg. No. 67,254/
`
`Ryan C. Richardson (Reg. No. 67,254)
`Attorney for Petitioner
`Volkswagen Group of America, Inc.
`
`Date: December 21, 2023
`1101 K Street, NW, 10th Floor
`Washington, DC 20005
`(202) 371-2600
`
`- 2 -
`
`
`
`Case IPR2022-01539
`U.S. Patent No. 10,965,512
`CERTIFICATE OF SERVICE (37 C.F.R. § 42.6(e))
`I certify that the above-captioned PETITIONER’S REQUEST FOR
`
`ORAL ARGUMENT was served in its entirety on December 21, 2023 upon the
`
`following parties via electronic mail:
`
`Counsel for Patent Owner
`Kenneth J. Weatherwax (Lead Counsel)
`Nathan Lowenstein (Back-up Counsel)
`Parham Hendifar (Back-up Counsel)
`Nick Yakoobian (Back-up Counsel)
`Xu Zhou (Back-up Counsel)
`LOWENSTEIN & WEATHERWAX LLP
`CALDWELL, CASSADY, & CURRY P.C
`weatherwax@lowensteinweatherwax.com
`NeoWireless_IPRs@lowensteinweatherwax.com
`
`Counsel for Petitioner Ford Motor Company (IPR2023-00764)
`John S. LeRoy (Lead Counsel)
`Christopher Smith (Back-up Counsel)
`Kyle G. Konz (Back-up Counsel)
`BROOKS KUSHMAN P.C.
`FPGP0139IPR@brookskushman.com
`
`
`
`
`
`
`
`
`
`
`Counsel for Petitioners General Motors LLC, Nissan North America, Inc.,
`Tesla, Inc., and American Honda Motor Co., Inc. (IPR2023-00961)
`Timothy W. Riffe (Lead Counsel)
`Usman A. Khan (Back-up Counsel)
`John T. Johnson (Back-up Counsel)
`Jeffrey C. Mok (Back-up Counsel)
`FISH & RICHARDSON P.C.
`Reginald J. Hill (Back-up Counsel)
`Nicole A. Keenan (Back-up Counsel)
`JENNER & BLOCK LLP
`IPR18768-0206IP1@fr.com
`PTABInbound@fr.com
`rhill@jenner.com
`nkeenan@jenner.com
`
`
`
`Respectfully submitted,
`
`STERNE, KESSLER, GOLDSTEIN & FOX PLLC
`
`/Ryan C. Richardson, Reg. No. 67,254/
`
`Ryan C. Richardson (Reg. No. 67,254)
`Attorney for Petitioner
`Volkswagen Group of America, Inc.
`
`Date: December 21, 2023
`1101 K Street, NW, 10th Floor
`Washington, DC 20005
`(202) 371-2600
`
`
`
`
`
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