`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`WEATHERFORD INTERNATIONAL, LLC,
`Petitioner,
`
`v.
`
`BAKER HUGHES OILFIELD OPERATIONS, LLC,
`Patent Owner.
`______________
`
`Case IPR2019-00768
`Patent RE46,137
`______________
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`
`
`Case IPR2019-00768
`Patent RE46,137
`
`Patent Owner requests oral argument to address this proceeding together with
`
`IPR2019-00708, with each side receiving 60 minutes to argue.
`
`Without waiving consideration of other issues or limiting its ability to address
`
`those raised by Petitioner at oral argument, Patent Owner specifies the following
`
`issues to be argued:
`
`1.
`
`Petitioner’s failure to show that:
`
`a.
`
`b.
`
`either of claims 1 and 34 are anticipated by Patel ’427;
`
`any of claims 1, 8-11, 16, 17, 31, 34, 41, and 42 are obvious over
`
`Patel ’427 and Giroux; and
`
`c.
`
`any of claims 1, 8-11, 16, 17, 31, 34, 41, and 42 are obvious over
`
`Patel ’427, Giroux, the alleged admitted prior art, and the
`
`knowledge of a POSITA;
`
`2.
`
`Petitioner’s improper attempt to use reply EXs. 1027-1029 to establish
`
`its prima facie case;
`
`3.
`
`Petitioner’s failure to show that any of EXs. 1027-1029 are printed
`
`publications;
`
`4.
`
`5.
`
`any issues raised in a motion to exclude; and
`
`any issues at the Board’s request.
`
`
`
`
`
`Case IPR2019-00768
`Patent RE46,137
`
`Patent Owner also requests that audio/visual equipment, including a display
`
`and a VGA or HDMI cable for connecting the display to a laptop, be made available
`
`for displaying demonstrative exhibits.
`
`Dated: April 29, 2020
`
`Respectfully submitted,
`
`/Mark T. Garrett/
` Mark T. Garrett (Reg. No. 44,699)
`
`
`
`
`
`
`
`
`
`Case IPR2019-00768
`Patent RE46,137
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on April 29,
`
`2020, a copy of Patent Owner’s Request for Oral Argument was served on Lead and
`
`Backup Counsel for Petitioner via email (by consent) to:
`
`Lead Counsel:
`
`Douglas R. Wilson (Reg. No. 54,542)
`doug.wilson@armondwilson.com
`ipr@armondwilson.com
`
`Backup Counsel:
`
`Boone Baxter (Reg. No. 69,363)
`bbaxter@hpcllp.com
`
`Michelle Armond (Reg. No. 53,954)
`michelle.armond@armondwilson.com
`
`/Mark T. Garrett/
` Mark T. Garrett (Reg. No. 44,699)
`
`
`
`
`
`
`
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