`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`IBG LLC; INTERACTIVE BROKERS LLC;
`TRADESTATION GROUP, INC.; and
`TRADESTATIONS SECURITIES, INC.
`Petitioners
`
`v.
`
`TRADING TECHNOLOGIES INTERNATIONAL, INC.
`Patent Owner
`_____________________
`
`Case CBM2016-00054
`Patent 7,693,768
`_____________________
`
`
`
`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`Mail Stop “Patent Board”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`
`
`CBM2016-00054
`U.S. Patent No. 7,693,768
`
`Pursuant to 37 C.F.R. § 42.70 and the Board’s October 18, 2016 Scheduling
`
`Order (Paper 11), Petitioners respectfully request oral argument, which is currently
`
`scheduled for June 23, 2017, on the issues raised in the Petition for Inter Partes
`
`Review of U.S. Patent 7,693,768 (“the ’768 patent”), Patent Owner’s Response,
`
`and Petitioners’ Reply to Patent Owner’s Response.
`
`The issues to be argued are:
`
`• The construction of certain terms of the ’768 patent;
`
`• The instituted grounds of unpatentability, namely:
`
`o whether claims 1-23 of the ’768 patent are directed to
`patent-ineligible subject matter under 35 U.S.C. § 101;
`
`o whether claims 1-13, 15, 16, 18, and 21-23 of the ’768
`patent are unpatentable under 35 U.S.C. § 103 over TSE and
`
`Belden; and
`
`o whether claims 14, 17, 19, and 20 of the ’768 patent are
`unpatentable under 35 U.S.C. § 103 over TSE, Belden, and
`
`Cooper;
`
`• Any issues identified in Patent Owner’s Request for Oral Argument;
`
`• Rebuttal to Patent Owner’s presentation on all matters;
`
`• Any other issues raised in papers filed in this proceeding, including
`
`issues raised in papers yet to be filed, such as Motions to Exclude; and
`
`
`
`- 1 -
`
`
`
`
`
`CBM2016-00054
`U.S. Patent No. 7,693,768
`
`• Any other outstanding motions and pleadings, and other issues that
`
`the Board deems necessary for issuing a Final Written Decision.
`
`Petitioners request the ability to use audio visual equipment to display
`
`possible demonstratives and exhibits, including the use of an Elmo, a computer, a
`
`projector, and a screen.
`
`
`
`Respectfully submitted,
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`
`/Richard M. Bemben/
`
`
`Richard M. Bemben, Reg. No. 68,658
`Attorney for Petitioners
`
`Date: May 24, 2017
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`(202) 371-2600
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`- 2 -
`
`
`
`
`
`CBM2016-00054
`U.S. Patent No. 7,693,768
`
`CERTIFICATION OF SERVICE
`
`The undersigned hereby certifies that a true and correct copy of the
`
`foregoing PETITIONERS’ REQUEST FOR ORAL ARGUMENT was served
`
`electronically via e-mail on May 24, 2017, in its entirety on the following:
`
`Leif R. Sigmond, Jr. (Lead Counsel) sigmond@mbhb.com
`Cole B. Richter (Back-up Counsel) richter@mbhb.com
`Michael D. Gannon (Back-up Counsel) gannon@mbhb.com
`Jennifer M. Kurcz (Back-up Counsel) kurcz@mbhb.com
`MCDONNELL, BOEHNEN, HULBERT & BERGHOFF LLP
`
`Steven F. Borsand (Back-up Counsel) tt-patent-cbm@tradingtechnologies.com
`Jay Q. Knobloch (Back-up Counsel) jay.knobloch@tradingtechnologies.com
`Trading Technologies International, Inc.
`
`
`
`
`/Richard M. Bemben/
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`
`
`Richard M. Bemben, Reg. No. 68,658
`Attorney for Petitioners
`
`
`
`
`
`
`
`
`
`
`
`
`
`Date: May 24, 2017
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`(202) 371-2600
`
`5343364_1.docx
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