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IPR2018-01334
`U.S. Patent No. 8,838,949
`
`
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`Intel Corporation
`Petitioner
`
`v.
`
`Qualcomm Incorporated
`Patent Owner
`
`
`
`IPR2018-013341
`U.S. Patent No. 8,838,949
`
`
`
`
`
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT ON REMAND
`
`
`
`
`1 IPR2018-01335 and IPR2018-01336 have been consolidated with the instant
`
`proceeding.
`
`
`
`
`

`

`IPR2018-01334
`U.S. Patent No. 8,838,949
`
`
`
`Pursuant to 37 § C.F.R. 42.70(a) and the Board’s February 23, 2022
`
`Scheduling Order on Remand (Paper 34), Petitioner respectfully requests oral
`
`argument, virtually, for the trial currently scheduled for August 4, 2022. Petitioner
`
`requests to appear virtually for the oral argument, pursuant to the Board’s June 23,
`
`2022 guidance.
`
`Petitioner specifies the following issues to be argued:
`
`•
`
`The broadest reasonable interpretation of the claim term “hardware
`
`buffer” in U.S. Patent No. 8,838,949.
`
`•
`
`The meaning of the term “system memory” as it relates to the
`
`“hardware buffer.”
`
`•
`
`The applicability of the broadest reasonable interpretation of
`
`“hardware buffer” to the asserted prior art disclosures.
`
`• Whether the Board can resolve the prior art challenge to the
`
`patentability of claims 16 and 17 despite the potential indefiniteness of the means-
`
`plus function terms, along with whether these means-plus-function terms of claims
`
`16 and 17 are indefinite.
`
`•
`
`Respond to any arguments raised in the Patent Owner’s Response
`
`Brief on Remand and Patent Owner’s Sur-Reply on Remand.
`
`
`
`1
`
`

`

`IPR2018-01334
`U.S. Patent No. 8,838,949
`All grounds on which trial was instituted, including all issues raised
`
`•
`
`by the parties’ papers.
`
`•
`
`Respond to issues specified by Patent Owner in its request for oral
`
`argument.
`
`Additionally, Petitioner reserves the right to address any arguments
`
`presented by Patent Owner and any other issues about which the Board wishes to
`
`hear argument during the oral hearing.
`
`Petitioner requests the ability to use a computer, projector, and screen to
`
`display possible demonstratives and/or exhibits.
`
`
`
`Dated: July 20, 2022
`
`Respectfully Submitted,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Joseph F. Haag/
`Joseph F. Haag
`
`Reg. No. 42,612
`Counsel for Petitioner
`
`
`
`
`
`2
`
`
`
`
`
`
`
`
`

`

`IPR2018-01334
`U.S. Patent No. 8,838,949
`CERTIFICATE OF SERVICE
`I hereby certify that on July 20, 2022, I caused a true and correct copy of the
`
`foregoing materials:
`
`• Petitioner’s Request for Oral Argument on Remand
`
`to be served via email, as previously agreed by the parties, on the following
`
`attorneys of record:
`
`Matthew W. Johnson (mwjohnson@jonesday.com)
`Joseph M. Sauer (jmsauer@jonesday.com)
`Joshua R. Nightingale (jrnightingale@jonesday.com)
`David B. Cochran (dcochran@jonesday.com)
`David M. Maiorana (dmaiorana@jonesday.com)
`
`
`
`Dated: July 20, 2022
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Joseph F. Haag/
`Joseph F. Haag
`
`Reg. No. 42,612
`Counsel for Petitioner
`
`
`
`
`
`i
`
`
`
`
`
`
`
`
`

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