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` Request for Oral Argument in IPR2020-01157
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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.,
`Petitioner,
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`v.
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`3G LICENSING S.A.,
`Patent Owner.
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`Case No. IPR2020-01157
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`U.S. Patent No. 7,274,933
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`Petitioner’s Request for Oral Argument
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` Request for Oral Argument in IPR2020-01157
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`Petitioner Dell Inc. hereby requests oral argument under 37 C.F.R. § 42.70
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`and the Board’s September 21, 2021 Revised Scheduling Order (Paper 38). Oral
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`argument is currently scheduled for December 15, 2021.
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`Petitioner requests argument on all Grounds accepted for trial in the Institution
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`Decision, including:
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`1. Whether claims 1‒3, 6‒8, 11‒13, and 19 are unpatentable under 35
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`U.S.C. § 103 over McElwain;
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`2. Whether claims 1‒3, 6‒8, 11‒13, and 19 are unpatentable under 35
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`U.S.C. § 103 over McElwain in view of Uchida;
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`3. Whether claims 4, 9, and 14 are unpatentable under 35 U.S.C. § 103
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`over McElwain in view of Uchida and Hicks;
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`4. Whether claims 1‒4, 6‒9, 11‒14, and 19 are unpatentable under 35
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`U.S.C. § 103 over McElwain in view of Hicks; and
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`5. Whether claims 1‒4, 6‒9, 11‒14, and 19 are unpatentable under 35
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`U.S.C. § 103 over the 3GPP Standards in view of McElwain.
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`Furthermore, Petitioner requests argument on any additional issues that Patent
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`Owner may seek to raise on oral argument, including rebuttal to any material in
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`Patent Owner’s presentation, Patent Owner’s Motion to Amend and Patent’s
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`Owner’s Revised Motion to Amend, any additional issues raised in papers which are
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`yet to be filed such as Motions to Exclude, and Oppositions to Motions to Exclude,
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` Request for Oral Argument in IPR2020-01157
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`and any other filings, motions, pleadings, or issues deemed necessary by the Board
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`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, Petitioner suggests that an allocation of ninety minutes of time per side
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`would be appropriate for an oral argument in a combined hearing with IPR2020-
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`01158, IPR2020-01159, IPR2020-001160, IPR2020-001161, 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-applications-process/patent-trial-and-appealboard/
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`hearings), Petitioner understand that until further notice hearings will be conducted
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`remotely by video or telephone. Accordingly, Petitioner requests the ability to
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`participate remotely in this manner and to use screen sharing software to display
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`demonstratives and record documents/exhibits. In the event the hearing is to be held
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`in-person, Petitioner request the ability to use audio-visual equipment at the hearing
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`including an Elmo, laptop, projector and screen to display demonstratives and
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`exhibits.
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`Finally, Petitioner hereby notifies the Board, pursuant to the Scheduling Order
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`(Paper 13 at 7), that it anticipates that more than five (5) individuals will attend the
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`argument on its behalf.
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` Request for Oral Argument in IPR2020-01157
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`DATED: November 3, 2021
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`Respectfully Submitted,
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`/Brian M. Buroker/
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`Brian M. Buroker (Reg. No. 39,125)
`GIBSON, DUNN & CRUTCHER LLP
`1050 Connecticut Ave. NW
`Washington, DC 20036
`Phone: (202) 955-8500
`Fax: (202) 467-0539
`Email: bburoker@gibsondunn.com
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`Attorney for Petitioner Dell Inc.
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` Request for Oral Argument in IPR2020-01157
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`CERTIFICATE OF SERVICE
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`The undersigned certifies service on the Patent Owner, pursuant to 37 C.F.R.
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`§ 42.6(e), by electronic (e-mail) delivery of a true copy of the foregoing
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`PETITIONER’S OPPOSITION TO PATENT OWNER’S REVISED MOTION TO
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`AMEND to lead and back-up counsel of record for Patent Owner as follows:
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`TD-PTAB@devlinlawfirm.com
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`nbenchell@devlinlawfirm.com
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`sberger@devlinlawfirm.com
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`ademarco@devlinlawfirm.com
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`dlflitparas@devlinlawfirm.com
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`DATED: November 3, 2021
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`By:
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`/Brian M. Buroker/
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`Brian M. Buroker (Reg. No. 39,125)
`GIBSON, DUNN & CRUTCHER LLP
`1050 Connecticut Ave. NW
`Washington, DC 20036
`Phone: (202) 955-8500
`Fax: (202) 467-0539
`Email: bburoker@gibsondunn.com
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`Attorney for Petitioner Dell Inc.
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