`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________________________________________________________
`
`SONY CORPORATION
`Petitioner
`
`v.
`
`YISSUM RESEARCH DEVELOPMENT COMPANY OF THE
`HEBREW UNIVERSITY OF JERUSALEM
`Patent Owner
`
`Case No. IPR2013-00219 (SCM)1
`
`
`
`Patent No. 7,477,284
`Issue Date: Jan. 13, 2009
`Title: SYSTEM AND METHOD FOR CAPTURING AND VIEWING
`STEREOSCOPIC PANORAMIC IMAGES
`__________________________________________________________________
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`PURSUANT TO 37 C.F.R. § 42.70(a)
`
`__________________________________________________________________
`
`
`
`1 The IPR2013-00327 proceeding has been joined with this proceeding.
`
`
`
`IPR2013-00219, Inter Partes Review of U.S. Pat. No. 7,477,284
`Petitioner’s Request for Oral Argument
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
` Pursuant to 37 C.F.R. § 42.70(a) and the Board’s September 23, 2013 Scheduling
`
`Order, Paper No. 17, Petitioner Sony Corporation (“Sony”) respectfully requests one
`
`hour for oral argument on June 18, 2014, as scheduled by the Board. Sony intends to
`
`argue the following issues, which Sony understands fall within the matters that the
`
`Board may address in its Final Written Decision:
`
` A. Arguments Regarding Patentability of Claims 1-4, 7, 10, 20, 27-29, and
`36-38 of the ’284 Patent
`
` With respect to the patentability of the claims 1-4, 7, 10, 20, 27-29, and 36-38 of
`
`U.S. Patent No. 7,477,284 (“the ’284 Patent”), Sony intends to argue issues framed by
`
`Sony’s Petition, the Board’s September 23, 2013 Decision on Institution, and Patent
`
`Owner’s December 19, 2013 Response:
`
`1. As to Kawakita and Asahi:
`
`a. Whether “a processor [to] generate a plurality of mosaics . . . [that] provide a
`
`sense of depth of the scene” is a limitation of the claims at issue.
`
`2. As to Kawakita:
`
`a. Whether Kawakita discloses generating a stereoscopic panoramic image pair
`
`that does not require adjustment for “faithful” stereoscopic viewing.
`
`b. Whether a stereoscopic image pair generated by Kawakita’s method that
`
`requires adjustment for “faithful” stereoscopic viewing is within the scope
`
`of the claims at issue.
`
`2
`
`
`
`
`
`IPR2013-00219, Inter Partes Review of U.S. Pat. No. 7,477,284
`Petitioner’s Request for Oral Argument
`3. As to Asahi:
`
`a. Whether the Board’s construction of the term “stereoscopic image pair”
`
`encompasses image pairs recorded from positions separated by distances
`
`larger or smaller than the human inter-ocular distance.
`
`b. Whether a person of ordinary skill in the art as of 1998 would have
`
`understood the term “stereoscopic viewing” as it is used in Asahi to mean
`
`human viewing of Asahi’s mosaic images to obtain a perception of depth (as
`
`Sony contends), or to mean calculating height (as Yissum contends).
`
`c. Whether Asahi discloses generating a stereoscopic mosaic image pair that, if
`
`viewed, provides a perception of depth, within the scope of the claims at
`
`issue.
`
`B. Arguments Regarding Procedural Matters
`
`With respect to Patent Owner’s Motion for Observation on Cross-Examination,
`
`Sony intends to argue that Patent Owner has raised new issues and has belatedly
`
`presented evidence that should not be considered.
`
`Sony also intends to respond to any arguments of Patent Owner that Sony has
`
`raised new issues and belatedly presented evidence in its Reply.
`
`C. Arguments Regarding Admissibility of Evidence
`
`With respect to evidentiary issues, Sony intends to argue that the exhibits YRD-2012
`
`and YRD-2013 are inadmissible, as stated in Sony’s Motion to Exclude Evidence.
`
`
`
`3
`
`
`
`IPR2013-00219, Inter Partes Review of U.S. Pat. No. 7,477,284
`Petitioner’s Request for Oral Argument
`Sony also intends to respond to any arguments of Patent Owner that Sony-1042,
`
`Sony-1043, and Sony-1044 are inadmissible, as stated in Patent Owner’s in Motion to
`
`Exclude Evidence.
`
`
`Dated: May 14, 2014
`
`
`
`
`
`
`
`
`_/s/ Walter Hanley__
`Walter Hanley, Lead Counsel, Reg. No 28,720
`whanley@kenyon.com
`Michelle Carniaux, Backup Counsel, Reg. No. 36,098
`mcarniaux@kenyon.com
`KENYON & KENYON LLP
`One Broadway, New York, NY 10004-1007
`
`
`
`4
`
`
`
`
`
`
`
`
`
`Certificate of Service Under 37 C.F.R. § 42.6(e)(4)
`
`I certify that I caused a true and correct copy of the forgoing to be served via
`
`Electronic Mail on the following:
`
`William Nelson and Robert Gerrity
`Robert.gerrity@tensegritylawgroup.com
`William.nelson@tensegritylawgroup.com
`Tensegrity Law Group LLP
`555 Twin Dolphin Dr., Suite 360
`Redwood Shores, CA 94065
`
`
`David McCombs and David O’Dell
`David.mccombs.ipr@haynesboone.com
`David.odell.ipr@haynesboone.com
`Haynes and Boone, LLP
`2323 Victory Avenue, Suite 700
`Dallas, Texas 75219
`
`
`
`
`
`
`
`Dated: _ May 14, 2014___
`
`
`
`
`
`
`
`
`_/s/ Michael E. Sander __
`Michael E. Sander
`Reg. No. 71,667
`msander@kenyon.com
`KENYON & KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel: 212-425-7200
`
`
`
`
`
`
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