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BEFORE THE PATENT TRIAL AND APPEAL BOARD
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`Trial No.:
`
`IPR 2015-01644
`
`In re:
`
`U.S. Patent No. 6,785,065
`
`Patent Owner:
`
`Toshiba Samsung Storage Technology Korea Corporation
`
`Petitioners:
`
`LG Electronics, Inc., and LG Electronics U.S.A., Inc.
`
`Inventors:
`
`Byung-youn Song and Kyung-sik Shin
`
`For: OPTICAL PICKUP ACTUATOR DRIVING METHOD AND APPARATUS
`THEREFOR
`
`* * * * * * * * * * *
`
`
`
`
`August 29, 2016
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`PURSUANT TO 37 C.F.R. § 42.70(a)
`
`2652945
`
`

`
`Patent Owner’s Request for Oral Argument
`
`IPR 2015-01644
`
`Pursuant to 37 C.F.R. § 42.70(a), Patent Owner Toshiba Samsung Storage
`
`Technology Korea Corporation hereby requests an oral argument on the issues set
`
`forth below at a time set by the Board. Oral argument is presently scheduled for
`
`October 6, 2016.
`
`Patent Owner respectfully requests 30 minutes of total argument time in
`
`which to present arguments on the issues listed below.
`
`ISSUES TO BE ARGUED
`
`I. Whether claims 1-2 and 5-9 are unpatentable as obvious under 35
`
`U.S.C. § 103(a) over Akanuma and the Admitted Prior Art (APA).
`
`II. Whether claims 1-2 and 5-9 are unpatentable as obvious under 35
`
`U.S.C. § 103(a) over Akanuma, the APA, and Ikegame.
`
`III. Whether claims 3-4 are unpatentable as obvious under 35 U.S.C.
`
`§ 103(a) over Akanuma, the APA, and Wakabayashi.
`
`IV. Whether claims 3-4 are unpatentable as obvious under 35 U.S.C.
`
`§ 103(a) over Akanuma, the APA, Ikegame, and Wakabayashi.
`
`V.
`
`Patent Owner’s responses to and addressing of: new claim
`
`interpretations, new arguments, new inherency allegations, new § 103
`
`modifications, and new obviousness rationales set forth in Petitioners’
`
`Reply Brief dated July 29, 2016.
`
`VI. All instituted grounds.
`
`VII. All arguments and issues in Patent Owner’s Response.
`
`1
`
`2652945
`
`

`
`Patent Owner’s Request for Oral Argument
`
`IPR 2015-01644
`
`Patent Owner also respectfully requests the ability to use audio visual equipment to
`
`display possible demonstrative exhibits, including the use of a projector and
`
`Respectfully submitted,
`
`NIXON & VANDERHYE P.C.
`
`
`
`By: /Joseph A. Rhoa/
`Joseph A. Rhoa
`Reg. No. 37,515
`Jonathan A. Roberts
`Reg. No. 68,565
`Counsel for Patent Owner
`Toshiba Samsung Storage Technology
`Korea Corporation
`
`screen.
`
`
`
`JAR:jr
`Nixon & Vanderhye, PC
`901 North Glebe Road, 11th Floor
`Arlington, VA 22203-1808
`Telephone: (703) 816-4000
`Facsimile: (703) 816-4100
`
`2
`
`2652945
`
`

`
`Patent Owner’s Request for Oral Argument
`
`IPR 2015-01644
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true copy of the foregoing Patent
`
`Owner’s Request for Oral Argument was served on Petitioners LG Electronics,
`
`Inc. and LG Electronics, U.S.A., Inc. on August 29, 2016 by emailing a copy to
`
`counsel at the email addresses listed below:
`
`Brian A. Tollefson
`Michael V. Battaglia
`Michael H. Jones
`ROTHWELL, FIGG, ERNST & MANBECK, P.C.
`607 14th Street, N.W., Suite 800
`Washington, DC 20005
`btollefson@rothwellfigg.com
`mbattaglia@rothwellfigg.com
`mjones@rothwellfigg.com
`lge-rfem-110team@rothwellfigg.com
`
`
`
`By: /Jonathan A. Roberts/
`Jonathan A. Roberts
`Reg. No. 68,565
`
`
`
`
`
`2652945

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