`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`DONGHEE AMERICA, INC. and DONGHEE ALABAMA, LLC,
`Petitioners
`
`v.
`
`PLASTIC OMNIUM ADVANCED INNOVATION AND RESEARCH,
`Patent Owner
`
`IPR2017-01633 (U.S. Patent 6,866,812)
`IPR2017-01647 (U.S. Patent 6,814,921)
`IPR2017-01654 (U.S. Patent 9,079,490)
`
`Petitioners’ Request for Oral Argument
`
`
`
`Petitioners Request for Oral Argument, IPR2017-01633, -01647, -01654
`
`Petitioners Donghee America, Inc. and Donghee Alabama, LLC hereby
`
`request oral argument pursuant to 37 C.F.R. § 42.70, the Board’s Scheduling
`
`Orders and Conduct of the Proceedings entered in IPR2017-01633, -01647, and
`
`-01654.
`
`The oral argument in each proceeding is scheduled for October 22, 2018.
`
`Petitioners and Patent Owner have met and conferred regarding the scheduling of
`
`the oral argument in IPR2017-01654 regarding U.S. Patent 9,079,490 (“’490
`
`patent”). The parties agree that, because the subject matter of the ’490 patent is
`
`more closely related to the patents-at-issue in IPR2017-01890 and -01945 than the
`
`patents-at-issue in IPR2017-01633 and -01647, it may be beneficial to the Board if
`
`the oral argument in IPR2017-01654 is continued to November 5, 2018 (the same
`
`day as oral arguments in IPR2017-01890 and -01945). Accordingly, Petitioners
`
`request that the oral argument in IPR2017-01654 be continued to November 5,
`
`2018. Petitioners’ understand that Patent Owner intends to make a similar request
`
`to continue the oral argument in IPR2017-01654.
`
`Petitioners intend to discuss the issues raised in the parties’ filings, including
`
`but not limited to, the following items:
`
`1.
`
`The unpatentability of claims 16, 24-27, 30-32, 38-41, 44, and 45 of
`
`U.S. Patent 6,866,812 based on the instituted grounds;
`
`-1-
`
`
`
`Petitioners’ Request for Oral Argument, IPR2017-01633, -01647, -01654
`
`2.
`
`The unpatentability of claims 1-5, 8, and 9 of U.S. Patent 6,814,921
`
`based on the instituted grounds;
`
`3.
`
`The unpatentability of claims 1, 2, 7-9, and 12-14 of U.S. Patent
`
`9,079,490 based on the instituted grounds (in the event that the request to continue
`
`oral argument on this patent is not granted);
`
`4.
`
`5.
`
`Rebuttal to Patent Owner’s presentation on all matters; and
`
`Any other issues that the Board deems necessary for issuing a final
`
`written decision.
`
`Given the unique issues pertaining to each of the patents, Petitioners request
`
`that each side be given 60 minutes to present its arguments (40 minutes if the
`
`request to continue is granted) and request that Petitioners be permitted to reserve
`
`time to be the last party to present rebuttal arguments. Petitioners also request the
`
`ability to use computers and audio/visual equipment to display demonstrative
`
`exhibits and evidence, including the use of a projector and screen.
`
`-2-
`
`
`
`Petitioners’ Request for Oral Argument, IPR2017-01633, -01647, -01654
`
`Dated: September 17, 2018
`
`Respectfully submitted,
`
`By: /Alyssa Caridis/
`
`Alyssa Caridis
`acaridis@orrick.com
`Registration No. 57,545
`CA Bar No. 260,103
`ORRICK, HERRINGTON, &
`SUTCLIFFE LLP
`777 South Figueroa Street
`Suite 3200
`Los Angeles, CA 90017
`Tel: 213-629-2020
`Fax: 213-612-2499
`Attorneys for Petitioners
`Donghee America Inc. and
`Donghee Alabama LLC.
`
`-3-
`
`
`
`Petitioners’ Request for Oral Argument, IPR2017-01633, -01647, -01654
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies service pursuant to 37 C.F.R. §§ 42.6(e) of this
`
`document on counsel of record for Patent Owner by filing it on the PTAB E2E
`
`System as well as delivering a copy via email to their email addresses:
`
`Robert Mattson - cpdocketmattson@oblon.com
`Christopher Ricciuti - cpdocketricciuti@oblon.com
`Vincent Shier - cpdocketshier@oblon.com
`
`Attorneys for Plastic Omnium Advanced
`Innovation and Research
`
`Dated: September 17, 2018
`
`By:
`
`/Anita Chou/
`Anita Chou
`
`-4-
`
`
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