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` LG Electronics U.S.A., Inc.
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` Date filed: August 29, 2016
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`By: Brian A. Tollefson, Lead Counsel
`Syeven Lieberman, Back-up Counsel (Pro Hac Vice)
`Michael V. Battaglia, Back-up Counsel
`Michael H. Jones, Back-up Counsel (Pro Hac Vice)
`ROTHWELL, FIGG, ERNST & MANBECK, P.C.
`607 14th Street, N.W., Suite 800
`Washington, DC 20005
`Phone: 202-783-6040
`Facsimile: 202-783-6031
`Emails: btollefson@rothwellfigg.com
` slieberman@rfem.com
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` mbattaglia@rothwellfigg.com
` mjones@rothwellfigg.com
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`LG ELECTRONICS, INC. and
`LG ELECTRONICS U.S.A., INC.,
`Petitioner,
`
`v.
`
`TOSHIBA SAMSUNG STORAGE TECHNOLOGY KOREA CORPORATION,
`Patent Owner.
`_______________
`
`Case IPR2015-01644
`Patent 6,785,065 B1
`_______________
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`PURSUANT TO 37 C.F.R. § 42.70(a)
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`
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`
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`
`
`Case IPR2015-01644
`Patent No. 6,785,065
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`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`Pursuant to the Scheduling Order, dated February 1, 2016 (Paper No. 10),
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`and Notice of Stipulation to Extend Due Dates 2, 4, and 5, filed June 28, 2016
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`(Paper No. 22), Petitioners LG Electronics, Inc. and LG Electronics U.S.A., Inc.
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`(“Petitioner”) respectfully request oral argument on the issues set forth below. The
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`Oral Hearing is scheduled to be held on October 6, 2016. Paper No. 28.
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`Petitioner submits that 45 minutes of oral argument per side will be adequate
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`to present arguments on the issues listed below.
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`Pursuant to 37 C.F.R. § 42.70(a), Petitioner identifies the following issues as
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`among those to be argued:
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`1. The unpatentability of claims 1, 2, and 5-9 under 35 U.S.C. § 103(a) over
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`Akanuma (Ex. 1002) and the Admitted Prior Art (“APA”) (Ex. 1001).
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`2. The unpatentability of claims 1, 2, and 5-9 under 35 U.S.C. § 103(a) over
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`Akanuma, the APA, and Ikegame (Ex. 1005).
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`3. The unpatentability of claims 3 and 4 under 35 U.S.C. § 103(a) over
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`Akanuma, the APA, and Wakabayashi (Ex. 1007).
`
`
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`2
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`
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`4. The unpatentability of claims 3 and 4 under 35 U.S.C. § 103(a) over
`
`Case IPR2015-01644
`Patent No. 6,785,065
`
`
`Akanuma, the APA, Ikegame, and Wakabayashi.
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`5. All arguments and issues in the Petition and cited exhibits.
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`6. All arguments and issues in Patent Owner’s Response and cited exhibits.
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`7. All arguments and issues in Petitioner’s Reply to Patent Owner’s Response
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`and cited exhibits.
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`Petitioner requests the ability to use audio/visual equipment to display
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`demonstrative exhibits and evidence of record, including the use of a projector and
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`screen for a PowerPoint presentation and other visual display.
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`Respectfully submitted,
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`
`
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`Dated: August 29, 2016
`
`By: / Michael V. Battaglia /
`Brian A. Tollefson, Reg. No. 46,338
`Michael V. Battaglia, Reg. No. 64,932
`Steven Lieberman, Pro Hac Vice
`Michael H. Jones, Pro Hac Vice
`ROTHWELL, FIGG, ERNST &
`
`
`
`
`
` MANBECK, P.C.
`607 14th Street, N.W., Suite 800
`Washington, DC 20005
`Phone: 202-783-6040
`Facsimile: 202-783-6031
`
`Counsel for Petitioners
`LG Electronics, Inc. and
` LG Electronics U.S.A., Inc.
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`3
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`
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`CERTIFICATE OF SERVICE
`I hereby certify that on this 29nd day of August, 2016, a true and correct copy
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`of the foregoing PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`PURSUANT TO 37 C.F.R. § 42.70(a) was served, via electronic mail upon the
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`following counsel of record for Patent Owner Toshiba Samsung Storage
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`Technology Korea Corporation:
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`Joseph A. Rhoa, Esq.
`Jonathan A. Roberts, Esq.
`Nixon & Vanderhye P.C.
`901 North Glebe Road, 11th Floor
`Arlington, VA 22203-1808
`Phone: 703-816-4000
`Facsimile: 703-816-4100
`Emails: jar@nixonvan.com
`jr@nixonvan.com
`
`
`
`
`
`
`
`/ Erik van Leeuwen /
`Erik van Leeuwen
`Litigation Operations Coordinator
`Rothwell, Figg, Ernst & Manbeck, P.C.
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`
`
`
`
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