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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.,
`VISA INC., and VISA U.S.A. INC.,1
`Petitioners,
`v.
`UNIVERSAL SECURE REGISTRY, LLC,
`Patent Owner.
`_________________________________________
`Case CBM2018-00024
`U.S. Patent No. 8,577,813
`________________________________________
`
`PETITIONER APPLE INC.’S REQUEST FOR ORAL ARGUMENT
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`1 Visa Inc. and Visa U.S.A. Inc., which filed a petition in CBM2019-00025, have
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`been joined as a party to this proceeding.
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`
`
`CBM2018-00024
`U.S. Patent No. 8,577,813
`Petitioner Apple Inc.’s Request for Oral Argument
`
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`Pursuant to the Board’s November 20, 2018 Scheduling Order (Paper No.
`
`11) and January 31, 2019 email granting the joint stipulation modifying certain
`
`deadlines, Petitioner Apple Inc. (“Apple”) respectfully requests oral argument
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`currently scheduled on August 27, 2019. Petitioner requests the ability to use a
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`computer, projector, and screen to display demonstrative exhibits. Petitioner
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`requests 30 minutes per side for each of IPR2018-00812, CBM2018-00024, and
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`CBM2018-00025, all of which are scheduled concurrently on August 27, 2019, for
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`a total of 90 minutes per side for all three proceedings. Petitioner respectfully
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`submits that the differences in claim scope between the two patents at issue in
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`addition to the varied grounds and different prior art references relied upon among
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`the IPR2018-00812, and the CBM2018-00024, and CBM2018-00025 proceedings
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`warrant additional time over the 60 minutes per side allotted for oral hearing in
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`IPR2018-00809, IPR2018-00810, and IPR2018-00813, arguments for which were
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`heard on July 16, 2019 between the same parties as this proceeding.
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`Pursuant to 37 C.F.R. § 42.70, Apple specifies the following issues to be
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`argued:
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`I. Whether the ’813 patent qualifies as a CBM patent under 37 C.F.R.
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`§ 42.302.
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`1
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`CBM2018-00024
`U.S. Patent No. 8,577,813
`Petitioner Apple Inc.’s Request for Oral Argument
`
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`II. Whether challenged claims 1-2, 4-5, 11, 13, 16-20, and 24 are
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`unpatentable under 35 U.S.C. § 103(a) as obvious over Maes (Ex.
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`1213) and the ’585 reference (Ex. 1214).
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`III. Whether challenged claims 6-10 are unpatentable under 35 U.S.C. §
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`103(a) as obvious over Maes (Ex. 1213), the ’585 reference (Ex.
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`1214), and Maritzen (Ex. 1214).
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`IV. Whether challenged claims 14, 15, 22, 23, 25, and 26 are unpatentable
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`under 35 U.S.C. § 103(a) as obvious over Maes (Ex. 1213), the ’585
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`reference (Ex. 1214), and Labrou (Ex. 1216).
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`V. Respond to any arguments raised in Patent Owner’s Preliminary
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`Response (Paper No. 9), Patent Owner’s Response (Paper No. 22) and
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`Patent Owner’s Sur-Reply (Paper No. 38).
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`VI. Respond to Patent Owner’s Motion to Strike (Paper No. 35) and any
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`arguments raised in Patent Owner’s Sur-Reply to Petitioner’s
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`Opposition to the Motion to Strike (if filed).
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`VII. Respond to Patent Owner’s Motion to Exclude, if one is submitted.
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`VIII. Respond to any issues specified by Patent Owner in its request for oral
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`argument.
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`IX. Respond to Patent Owner’s presentation on all matters.
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`2
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`CBM2018-00024
`U.S. Patent No. 8,577,813
`Petitioner Apple Inc.’s Request for Oral Argument
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`X. Any arguments raised by the Parties in their respective papers,
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`motions, oppositions, responses, replies, and sur-replies.
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`XI.
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`Issues related to the Board’s Decision on Institution and the grounds
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`instituted in the Decision.
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`XII. Any issues raised in the briefing pursuant to the schedule.
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`XIII. Any other outstanding motions and pleadings, and other issues that
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`the Board deems necessary for issuing a Final Written Decision.
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`Respectfully Submitted,
`
`
`/Monica Grewal/
`
`Monica Grewal
`Registration No. 40,056
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`3
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`Date: July 19, 2019
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`CBM2018-00024
`U.S. Patent No. 8,577,813
`Petitioner Apple Inc.’s Request for Oral Argument
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`CERTIFICATE OF SERVICE
`I hereby certify that on July 19, 2019, I caused a true and correct copy of
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`
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`Petitioner Apple Inc.’s Request for Oral Argument to be served via electronic mail
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`on the following correspondents of record as listed in Patent Owners’ Mandatory
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`Notices and in Paper 34 (Decision to Institute CBM2019-00025 Granting Motion
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`for Joinder):
`
`For PATENT OWNER:
`James M. Glass (jimglass@quinnemanuel.com)
`Tigran Guledjian (tigranguledjian@quinnemanuel.com)
`Christopher A. Mathews (chrismathews@quinnemanuel.com)
`Nima Hefazi (nimahefazi@quinnemanuel.com)
`Richard Lowry (richardlowry@quinnemanuel.com)
`Razmig Messerian (razmesserian@quinnemanuel.com)
`Jordan B. Kaericher (jordankaericher@quinnemanuel.com)
`Harold A. Barza (halbarza@quinnemanuel.com)
`Quinn Emanuel USR IPR (qe-usr-ipr@quinnemanuel.com)
`QUINN, EMANUEL, URQUHART & SULLIVAN, LLP
`
`
`For PETITIONER:
`(CBM2019-00025):
`Matthew Argenti (margenti@wsgr.com)
`Michael Rosato (mrosato@wsgr.com)
`WILSON SONSINI GOODRICH & ROSATI
`
`
`
`
`Date: July 19, 2019
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`
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`Respectfully Submitted,
`
`
`/Monica Grewal/
`Monica Grewal
`Registration No. 40,056
`
`4
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`
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