`
`Filed on behalf of Patent Owner Network-1 Security Solutions, Inc.
`
`By: Robert G. Mukai, Esq.
`Charles F. Wieland III, Esq.
`BUCHANAN INGERSOLL & ROONEY PC
`1737 King Street, Suite 500
`Alexandria, Virginia 22314-2727
`Telephone (703) 836-6620
`Facsimile (703) 836-2021
`robert.mukai@bipc.com
`charles.wieland@bipc.com
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`
`AVAYA INC., DELL INC., SONY CORP. OF AMERICA, and
`HEWLETT-PACKARD CO.
`Petitioners
`
`v.
`
`NETWORK-1 SECURITY SOLUTIONS, INC.
`Patent Owner
`
`____________________
`
`Case IPR2013-000711
`Patent 6,218,930
`Administrative Patent Judges Jameson Lee, Joni Y. Chang and Justin T. Arbes
`____________________
`
`NETWORK-1’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`1
`IPR2013-00385 and IPR2013-00495 have been joined with this proceeding.
`
`
`
`
`
`
`
`Pursuant to (a) the Board’s Scheduling Order dated November 15, 2013
`
`Case No. IPR2013-00071
`Network-1’s Request for Oral Argument
`
`(Paper 69), and (b) 37 C.F.R. § 42.70, Patent Owner Network-1 Security Solutions,
`
`Inc. (“Network-1”) respectfully requests oral argument, currently scheduled for
`
`January 9, 2014. Pursuant to 37 C.F.R. § 42.70(a), Patent Owner specifies,
`
`without waiving any issues not requested, the following issues to be argued:
`
`1.
`
` Rebuttal of each ground of unpatentability on which trial was
`
`instituted for Claims 6 and 9 of the ‘930 Patent, including the following issues:
`
`Ground 1:
`
`Does Matusno disclose the claimed:
`
`(a) “low level current,”
`
`(b) “on the data signaling pair,”
`
`(c) “data network,” and
`
`(d) Claim 9,
`
`in the context of the ‘930 Patent.
`
`Ground 2:
`
`a. Does De Nicolo disclose the claimed “low level current,” “on the
`
`data signaling pair,” and Claim 9 in the context of the ‘930 Patent?
`
`b. Are Claims 6 and 9 of the ‘930 Patent obvious over Matsuno and
`
`De Nicolo?
`
`2
`
`
`
`
`
`2.
`
` Each ground asserted by the Patent Owner for the proposed amended
`
`Case No. IPR2013-00071
`Network-1’s Request for Oral Argument
`
`claims, and rebuttal of each ground the Petitioners asserted against the proposed
`
`amended claims, including the following issues:
`
`a. Do the proposed additional limitations expand the scope of the
`
`original claims?
`
`b. Do the proposed additional limitations have written description
`
`support?
`
`c. What is the proper construction of the prosed phrase “determining
`
`whether the device is capable of accepting remote power” in the
`
`context of the ‘930 Patent?
`
`d. Does Matsuno anticipate proposed Claim 10?
`
`e. Does Woodmas anticipate proposed Claim 10?
`
`f. Is proposed Claim 10 patentable over the known prior art?
`
`3. Should Network-1’s Motion to Exclude Exhibit AV-1042 be granted?
`
`4.
`
`Rebuttal of any arguments made by Petitioners in support of any
`
`Motion to Exclude that Petitioners may file.
`
`Network-1 respectfully requests 60 minutes of total time to present its
`
`arguments and rebut Petitioners’ arguments (with respect to Network-1’s Motion
`
`to Amend), or as much time as the Petitioners are granted if greater than 60
`
`minutes.
`
`3
`
`
`
`Case No. IPR2013-00071
`Network-1’s Request for Oral Argument
`
`
`
`Patent Owner also requests the ability to use audio visual equipment to
`
`display demonstrative exhibits, including the use of a projector and screen for
`
`displaying demonstrative exhibits (e.g., PowerPoint slides).
`
`
`
`
`
`
`
`
`
`
`
`Date: December 11, 2013
`
`1737 King Street, Suite 500
`Alexandria, VA 22314
`Telephone (703) 836-6620
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`BUCHANAN INGERSOLL & ROONEY PC
`
`By: /Charles F. Wieland III/
`Charles F. Wieland III
`Registration No. 33,096
`Counsel for NETWORK-1 SECURITY
`
` SOLUTIONS, INC.
`
`
`
`
`
`4
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing NETWORK-
`
`1’S REQUEST FOR ORAL ARGUMENT is being served upon counsel for
`
`Petitioners this 11th day of December, 2013, via electronic mail, as follows:
`
`Jeffrey D. Sanok and Jonathan Lindsay
`AV1-PRPS@Crowell.com
`JSanok@Crowell.com
`JLindsay@Crowell.com
`Counsel for Avaya Inc.
`
`Michael J. Scheer and Thomas M. Dunham
`WINSTON & STRAWN LLP
`mscheer@winston.com
`tdunham@winston.com
`Counsel for Dell, Inc.
`
`Lionel M. Lavenue and Erika Arner
`FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, LLP
`lionel.lavenue@finnegan.com
`erika.arner@finnegan.com
`Counsel for Sony Corp. of America
`
`Robert J. Walters and Charles J. Hawkins
`McDERMOTT WILL & EMERY LLP
`rwalters@mwe.com
`chawkins@mwe.com
`Counsel for Hewlett-Packard Co.
`
`Date: December 11, 2013
`
`
`
`
`
`
`
`/Charles F. Wieland III/
`Charles F. Wieland III
`Registration No. 33,096
`Counsel for NETWORK-1 SECURITY
` SOLUTIONS, INC.
`
`
`
`
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