`Merchant & Gould P.C.
`3200 IDS Center
`80 South 8th Street
`Minneapolis, MN 55402
`Tel: (612) 332-5300
`Fax: (612) 332-9081
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`CARDIOCOM, LLC
`Petitioner
`
`v.
`
`ROBERT BOSCH HEALTHCARE SYSTEMS, INC.
`Patent Owner
`____________
`
`Case IPR2013-00451
`Patent 7,587,469
`____________
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`
`
`Case IPR2013-00451
`Patent No. 7,587,469
`
`Petitioner, Cardiocom, LLC (“Cardiocom”) hereby requests an oral hearing
`
`pursuant to 37 C.F.R. § 42.70 and the Board’s Scheduling Order (Paper No. 24).
`
`As set forth in its Order, the Board has currently scheduled the oral hearing for
`
`September 9, 2014. Cardiocom requests oral argument to discuss the issues
`
`specified below.
`
`ISSUES TO BE ARGUED
`
`1. Whether challenged claims 1, 2, and 5-10 of U.S. Patent No. 7,587,469
`
`(Ex. 1001) are unpatentable for the grounds instituted.
`
`a. Whether claims 1, 2, and 5-10 are unpatentable under 35 U.S.C. § 103
`
`as obvious over U.S. Patent Nos. 6,014,626 (“Cohen”) and 5,367,667
`
`(“Wahlquist”).
`
`b. Whether claims 1, 2, and 5-10 are unpatentable under 35 U.S.C. § 103
`
`as obvious over Cohen, Wahlquist, European Patent Application
`
`Publication No. EP 0505627A2 (“Neumann”), and U.S. Patent No.
`
`5,956,683 (“Jacobs”).
`
`2.
`
`Response to any issues raised by Patent Owner in its Request for Oral
`
`Argument.
`
`
`
`
`
`
`
`1
`
`
`
`Respectfully submitted,
`
`Date: July 31, 2014
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` /Daniel W. McDonald/
`Daniel W. McDonald, Reg. No. 32,044
`Attorneys for Petitioner Cardiocom
`
`
`
`
`
`2
`
`
`
`CERTIFICATE OF SERVICE
`
`
`Pursuant to 37 C.F.R § 42.6(e), the undersigned hereby certifies that a copy
`of this PETITIONER’S REQUEST FOR ORAL ARGUMENT has been served on
`July 31, 2014, by email on counsel of record for the patent owner at the following
`name and address:
`
`Don Daybell (ddaybell@orrick.com)
`Davin M. Stockwell (dstockwell@orrick.com)
`Bas de Blank (basdeblank@orrick.com)
`Lillian Mao (lmao@orrick.com)
`BoschvCardiocom-IPRServiceList@orrick.com
`D2DPTABDocket@orrick.com
`ORRICK, HERRINGTON, &
`SUTCLIFFE LLP
`2050 Main St., Suite 1100
`Irvine, CA 92614
`Tel: 949-567-6700
`Fax: 949-567-6710
`
`Respectfully submitted,
`MERCHANT & GOULD P.C.
`P.O. Box 2903
`Minneapolis, Minnesota 55402-0903
`(612) 332-5300
`
`
` / Daniel W. McDonald /
`Daniel W. McDonald (Lead Counsel)
`USPTO Reg. No.: 32,044
`
`
`
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`
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`
`3
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`
`Date: July 31, 2014
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