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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`DELL, INC.,
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`Petitioner
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`v.
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`3G LICENSING S.A.,
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`Patent Owner
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`Case IPR2020-01157
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`Patent No. 7,274,933
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`Patent Owner, 3G Licensing S.A. (“3G”) hereby requests oral argument
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`under 37 C.F.R. § 42.70 and the Board’s February 17, 2021 Scheduling Order
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`(Paper 13). Oral argument is currently scheduled for December 15, 2021. (Revised
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`Scheduling Order, Paper 36 at 7.)
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`Patent Owner requests argument on all grounds accepted for trial in the
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`Institution Decision, including:
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`1. Whether claims 1-3, 5-7, 9, and 10 are unpatentable under 35 U.S.C. § 103
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`over Chen;
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`2. Whether claims 1-10 are unpatentable under 35 U.S.C. § 103 over Chen in
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`Combination with Eriksson;
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`3. Whether claims 1-10 are unpatentable under 35 U.S.C. § 103 over Chen in
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`Combination with GSM 03.64
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`4. Patent Owner’s Revised Motion to Amend
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`Furthermore, Patent Owner requests argument on any additional issues that
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`Petitioners may seek to raise on oral argument, including rebuttal to any material in
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`Petitioners’ presentation, any additional issues raised in papers which are yet to be
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`filed such as Motions to Exclude, and any other filings, motions, pleadings, or
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`issues deemed necessary by the Board for issuing a Final Written Decision.
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`Given the number of combinations of prior art and number of challenged
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`claims, Patent Owner suggests that an allocation of one hour per side would be
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`2
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`appropriate for the oral argument in a combined hearing with IPR2020-01158,
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`IPR2020-01159, IPR2020-01160, IPR2020-01161, and IPR2020-01162.
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`In accordance with the USPTO’s online notice of March 13, 2020
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`(https://www.uspto.gov/patents-application-process/patent-trial-and-
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`appealboard/hearings), Patent Owner understands that until further notice hearings
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`will be conducted remotely by video or telephone. Accordingly, Patent Owner
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`requests the ability to participate remotely in this manner and to use screen sharing
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`software to display demonstratives and record documents/exhibits. In the event the
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`hearing is to be held in-person, Patent Owner requests the ability to use audio-
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`visual equipment at the hearing, including an Elmo, laptop, projector and screen to
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`display demonstratives and exhibits.
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`Finally, Patent Owner hereby notifies the Board, pursuant to the Scheduling
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`Order (Paper 13 at 6-7), that it anticipates that more than five (5) individuals will
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`attend the argument on its behalf.
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`Dated: November 3, 2021
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`Respectfully submitted,
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`
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`
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`/ Timothy Devlin /
` Timothy Devlin (Reg. 41,706)
`Devlin Law Firm LLC
`1526 Gilpin Ave.
`Wilmington, DE 19806
`Telephone: (302) 449-9010
`Email: tdevlin@devlinlawfirm.com
`
`Attorney for Patent Owner
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`4
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`CERTIFICATE OF SERVICE
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`
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`The undersigned certifies that on November 3, 2021 the foregoing document
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`was served via electronic mail upon the following counsel of record for Petitioners:
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`LEAD COUNSEL
`
`Brian M. Buroker (Reg. 39,125)
`bburoker@gibsondunn.com
`
`Gibson, Dunn & Crutcher LLP
`1050 Connecticut Ave. NW
`Washington, DC 20036
`Phone: (202) 955-8500
`
`
`Counsel for Dell, Inc.
`FIRST BACKUP COUNSEL
`
`Paul Torchia (Reg. 55,683)
`ptorchia@gibsondunn.com
`
`Gibson, Dunn, & Crutcher LLP
`200 Park Avenue
`New York, NY 10166
`Phone: (212) 351-3953
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`ADDITIONAL BACKUP COUNSEL
`
`Nathan R. Curtis (Reg. 70,471)
`ncurtis@gibsondunn.com
`
`Gibson, Dunn & Crutcher LLP
`2001 Ross Ave., Ste. 2100
`Dallas, TX 75201
`Phone: (214) 698-3100
`Additional email for service: Dell-IPRService@gibsondunn.com
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`
`
`
`/Timothy Devlin/
` Timothy Devlin
`
`
`
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