`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`JIAWEI TECHNOLOGY (HK) LTD., JIAWEI TECHNOLOGY (USA) LTD.,
`SHENZHEN JIAWEI PHOTOVOLTAIC LIGHTING CO., LTD., ATICO
`INTERNATIONAL (ASIA) LTD., ATICO INTERNATIONAL USA, INC.,
`CHIEN LUEN INDUSTRIES CO., LTD., INC. (CHIEN LUEN FLORIDA),
`CHIEN LUEN INDUSTRIES CO., LTD., INC. (CHIEN LUEN CHINA),
`COLEMAN CABLE, LLC, NATURE’S MARK, RITE AID CORP., SMART
`SOLAR, INC., AND TEST RITE PRODUCTS CORP.
`Petitioner,
`
`v.
`
`SIMON NICHOLAS RICHMOND
`Patent Owner.
`______________
`
`IPR Case No.: IPR2014-00936 (U.S. Patent No. 7,196,477)
`IPR Case No.: IPR2014-00938 (U.S. Patent No. 7,429,827)
`______________
`
`
`Before JUSTIN T. ARBES, Administrative Patent Judge
`
`BARRY L. GROSSMAN, Administrative Patent Judge
`
`WILLIAM V. SAINDON, Administrative Patent Judge
`
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`
`
`
`
`
`
`
`
`IPR2014-00936 (U.S. Patent No. 7,196,477)
`IPR2014-00938 (U.S. Patent No. 7,429,827)
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`Pursuant to the Board’s December 22, 2014, Scheduling Order and 37 CFR
`
`§ 42.70 (a), Patent Owner respectfully requests oral argument, currently scheduled
`
`on September 21, 2015.
`
`Relationship to Other Proceedings
`
`
`
`Patent Owner notes that related proceedings (IPR2014-00935 (’935 IPR),
`
`IPR2014-00936 (’936 IPR) and IPR2014-00938 (’938 IPR)) also have oral
`
`argument scheduled for the same day. Petitioner and Patent Owner agreed to
`
`consolidate the hearings for the ’938 and ’936 IPRs due to similarities, but agreed
`
`that the ’935 oral argument should remain separate. Therefore, the parties request a
`
`4-hour oral argument—two hours for each party. Patent Owner further requests
`
`that the time allotted to each side (i.e., 2-hours) be equally divided between the
`
`‘935 IPR oral argument and the combined ‘936/’938 IPRs oral argument, i.e., 1-
`
`hour per side per oral argument.
`
`Issues For Hearing
`
`
`
`Pursuant to 37 C.F.R. § 42.70, Patent Owner specifies the following issues
`
`to be argued, without intent to waive consideration of any allowable issue not
`
`requested:
`
`I. The level of skill in the art.
`
`1
`
`
`
`
`
`II.
`
`IPR2014-00936 (U.S. Patent No. 7,196,477)
`IPR2014-00938 (U.S. Patent No. 7,429,827)
`
`
`Issues related to any motion to exclude evidence and/or Patent Owner’s
`
`motion to terminate the proceedings for Petitioner’s failure to identify
`
`Southwire Company, LLC as a real party-in-interest.
`
`III. The patentability of claims 1–29 of U.S. Patent No. 7,196,477 over the
`
`refereces cited in Case No. IRP2014-00936.
`
`a. Claims 1, 2, 4–9, 20-22, and 26 are nonobvious in view of Chliwnyj,
`
`Wu, and Hung
`
`b. Claims 10–12, 23-25, and 27-29 are nonobvious in view of Chliwnyj,
`
`Wu, Hung and Pu
`
`c. Claims 3 and 13-16 are nonobvious in view of Chliwnyj, Wu, Hung
`
`and Xu
`
`d. Claims 17-19 are nonobvious in view of Chliwnyj, Wu, Hung, Xu,
`
`and Pu
`
`IV. The patentability of claims 24–30 and 35 of U.S. Patent No. 7,429,827
`
`over the refereces cited in Case No. IRP2014-00938.
`
`a. Claims 24–26 are nonobvious in view of Chliwnyj, Wu, Pu, and
`
`Dowling
`
`b. Claims 27–29 and 35 are nonobvious in view of Chliwnyj and Wu
`
`c. Claim 30 is nonobvious in view of Chliwnyj, Wu, and Lau
`
`2
`
`
`
`
`
`
`
`V. Any issues noted in Petitioner’s request for oral argument or
`
`IPR2014-00936 (U.S. Patent No. 7,196,477)
`IPR2014-00938 (U.S. Patent No. 7,429,827)
`
`
`otherwise raised by the Board.
`
`Additional Requests
`
`Patent Owner requests the availability of a video projector with VGA-type
`
`interface and an easel for holding poster boards, as well as permission to use a
`
`laptop computer that Patent Owner will provide.
`
`
`
`Patent Owner additionally requests permission to present handouts of
`
`demonstrative exhibits during the oral argument.
`
`Respectfully submitted,
`
`__/Theodore F. Shiells/_______
`Theodore F. Shiells
`Reg. No. 31,569
`SHIELLS LAW FIRM P.C.
`Pacific Place Building
`1910 Pacific Avenue - Suite 14000
`Dallas, Texas 75201
`Attorney for Patent Owner
`
`
`
`
`
`Dated: August 19, 2015
`
`3
`
`
`
`
`
`
`
`IPR2014-00936 (U.S. Patent No. 7,196,477)
`IPR2014-00938 (U.S. Patent No. 7,429,827)
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6(e)(4)(i) et seq. and 42.105(b), the undersigned
`
`
`
`
`
`certifies that on August 19, 2015, a copy of the PATENT OWNER’S REQUEST
`
`FOR ORAL ARGUMENT was served on Lead and Backup Attorneys for
`
`Petitioner, via the consented to method of email to the following email addresses:
`
`mark.nelson@dentons.com, lissi.mojica@dentons.com,
`
`kevin.greenleaf@dentons.com, daniel.valenzuela@dentons.com, and
`
`iptdocketchi@dentons.com,
`
`Respectfully submitted,
`______/Theodore F. Shiells/________
`Theodore F. Shiells
`
`4
`
`
`
`
`Dated: August 19, 2015
`
`
`
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
