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`_____________________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________________________________
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`CARDIOCOM, LLC
`Petitioner
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`v.
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`ROBERT BOSCH HEALTHCARE SYSTEMS, INC.
`Patent Owner
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`_____________________________________
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`Case IPR2013-00468
`Patent No. 7,516,192
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`_____________________________________
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`PURSUANT TO 37 C.F.R. §42.70
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`
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`Pursuant to 37 C.F.R. § 42.70(a), Patent Owner, Robert Bosch Healthcare
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`Systems, Inc. (“Bosch”) hereby requests oral argument currently scheduled for
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`September 9, 2014, in the present inter partes review proceeding. Bosch
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`specifies the following issues to be argued:
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`1. Whether Petitioner has met its burden to prove that a person of
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`ordinary skill would have combined the teachings of Wright Jr. (Exhibit
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`1002) and Goodman (Exhibit 1003), as alleged in the Petition;
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`2. Whether Petitioner has met its burden to prove that a person of
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`ordinary skill would have combined the teachings of Goodman and
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`Wahlquist (Ex 1004), as alleged in the Petition;
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`3. Whether Petitioner’s expert applied a proper methodology in his
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`obviousness analysis;
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`4. Whether claims 1-3, 6, 7, 11, 12, 17-19, 20-23, 29-30, and 35-36 of
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`US Patent No. 7,516,192 (the “’192 Patent”) (Exhibit 1001) are obvious
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`over Wright Jr.;
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`5. Whether claims 1-37 of the ’192 Patent are obvious over Wright Jr.
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`and Goodman;
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`6. Whether claims 20-37 of the ‘192 Patent are obvious over
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`Goodman in combination with Wahlquist;
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`2
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`
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`7. Whether Petitioner has disproved Patent Owner’s significant
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`evidence of objective indicia of nonobviousness for the ’192 Patent;
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`8.
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`9.
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`The appropriate construction to be given the disputed claim terms;
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`Reply to any arguments raised in the Petitioner’s Reply;
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`10. Response to any issues specified by Petitioner in its request for
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`oral argument;
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`11. Whether Bosch’s Motion to Exclude should be granted;
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`12. Response to Petitioner’s presentation on all matters; and
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`13. Any other issues briefed or presented by the parties throughout this
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`trial.
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`Respectfully submitted,
`ORRICK, HERRINGTON & SUTCLIFFE LLP
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`Dated: July 30, 2014
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`By:
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`/Don Daybell/
`Don Daybell
`Reg. No. 50,877
`Attorney for Patent Owner
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`3
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`
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`CERTIFICATION OF SERVICE (37 C.F.R. § 42.6(e))
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`The undersigned hereby certifies that the above-captioned “PATENT
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`OWNER’S REQUEST FOR ORAL ARGUMENT PURSUANT TO 37 C.F.R.
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`§42.70” was served in its entirety on July 30, 2014, upon the following parties via
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`e-mail:
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`Counsel for Petitioner
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`Daniel W. McDonald
`Andrew J. Lagatta
`Merchant & Gould
`80 South 8th St., Suite 3200
`Minneapolis, MN 55402
`CardiocomIPR@merchantgould.com
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`By:
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`/Karen Johnson/
`Karen Johnson
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`