`
`_____________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________________________
`
`CARDIOCOM, LLC
`Petitioner
`
`v.
`
`ROBERT BOSCH HEALTHCARE SYSTEMS, INC.
`Patent Owner
`
`_____________________________________
`
`Case IPR2013-00451
`Patent No. 7,587,469
`
`_____________________________________
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`PURSUANT TO 37 C.F.R. §42.70
`
`
`
`Pursuant to 37 C.F.R. § 42.70(a), Patent Owner, Robert Bosch Healthcare
`
`Systems, Inc. (“Bosch”) hereby requests oral argument currently scheduled for
`
`September 9, 2014, in the present inter partes review proceeding. Bosch
`
`specifies the following issues to be argued:
`
`1. Whether Petitioner has met its burden to prove that a person of
`
`ordinary skill would have combined the teachings of Cohen (Exhibit
`
`1002) and Wahlquist (Exhibit 1003), as alleged in the Petition;
`
`2. Whether Petitioner has met its burden to prove that a person of
`
`ordinary skill would have combined the teachings of Cohen, Wahlquist,
`
`Neumann (Exhibit 1004), and Jacobs (Exhibit 1005), as alleged in the
`
`Petition;
`
`3. Whether Petitioner’s expert applied a proper methodology in his
`
`obviousness analysis;
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`4. Whether claims 1, 2, and 5-10 of US Patent No. 7,587,469 (the
`
`“’469 Patent”) (Exhibit 1001) are obvious over Cohen and Wahlquist;
`
`5. Whether claims 1, 2, and 5-10 of the ’469 Patent are obvious over
`
`Cohen, Wahlquist, Neumann, and Jacobs;
`
`6.
`
`7.
`
`The appropriate construction to be given the disputed claim terms;
`
`Reply to any arguments raised in the Petitioner’s Reply;
`
`2
`
`
`
`8.
`
`Response to any issues specified by Petitioner in its request for
`
`oral argument;
`
`9. Whether Bosch’s Motion to Exclude should be granted;
`
`10. Response to Petitioner’s presentation on all matters; and
`
`11. Any other issues briefed or presented by the parties throughout this
`
`trial.
`
`Respectfully submitted,
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`
`Dated: July 30, 2014
`
`By:
`
`/Don Daybell/
`Don Daybell
`Reg. No. 50,877
`Attorney for Patent Owner
`
`3
`
`
`
`CERTIFICATION OF SERVICE (37 C.F.R. § 42.6(e))
`
`The undersigned hereby certifies that the above-captioned “PATENT
`
`OWNER’S REQUEST FOR ORAL ARGUMENT PURSUANT TO 37 C.F.R.
`
`§42.70” was served in its entirety on July 30, 2014, upon the following parties via
`
`e-mail:
`
`Counsel for Petitioner
`
`Daniel W. McDonald
`Andrew J. Lagatta
`Merchant & Gould
`80 South 8th St., Suite 3200
`Minneapolis, MN 55402
`CardiocomIPR@merchantgould.com
`
`By:
`
`/Karen Johnson/
`Karen Johnson
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