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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`Yamaha Corporation of America
`Petitioner
`
`v.
`
`Black Hills Media, LLC
`Patent Owner
`
`
`Patent No. 8,050,652
`Issue Date: November 1, 2011
`Title: METHOD AND DEVICE FOR AN INTERNET RADIO CAPABLE OF
`OBTAINING PLAYLIST CONTENT FROM A CONTENT SERVER
`_______________
`
`Inter Partes Review No. IPR2013-00594 (SGW)
`____________________________________________________________
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`
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`la-1263689
`
`
`
`IPR2013-00594
`
`
`
`
`393032805800
`
`Pursuant to 37 C.F.R. § 42.70(a), Petitioner submits this Request for Oral
`
`Argument on all the instituted grounds of unpatentability for U.S. Patent No.
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`8,050,652 (see Decision (Paper 17) at 33), which encompass each of the claim
`
`construction and obviousness issues addressed in Petitioner’s Petition and Reply, the
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`Patent Owner’s Response, and all exhibits thereto, including declarations and
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`depositions. These issues include obviousness of claims 1-4, 6, 7, 13, 21, 22, 24, 25,
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`27, 28, 34, 42-45, 47 and 48 based upon U.S. Patent No. 7,187,947 to White,
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`obviousness of claims 1-4, 6-8, 10, 13, 21, 22, 24-29, 31, 42-45, 47-50 and 52 based
`
`upon PCT Pub. No. WO99/38266 to Qureshey (“Qureshey”) and U.S. Patent No.
`
`6,502,194 to Berman (“Berman”), and obviousness of claims 11, 32 and 53 based
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`upon Qureshey, Berman and U.S. Patent No. 6,587,127 to Leeke.
`
`Petitioner will also address any issues raised by any motion to exclude filed by
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`Patent Owner.
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`Petitioner requests thirty minutes of oral argument time for its side. The Board
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`has already scheduled Oral Argument for October 20, 2014. (Revised Scheduling
`
`Order (Paper 32) at 2).
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`la-1263689
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`2
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`IPR2013-00594
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`
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`393032805800
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`Petitioner authorizes the Board or the Commissioner to charge the cost of any
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`fees due in connection with the filing of this document to Deposit Account No. 03-
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`1952 referencing Docket No. 393032805800.
`
`
`
`Dated: September 12, 2014
`
`
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`
`
`Respectfully submitted,
`
`
`
`By /s/ David L. Fehrman
`David L. Fehrman
` Registration No.: 28,600
`MORRISON & FOERSTER LLP
`707 Wilshire Boulevard
`Los Angeles, California 90017
`(213) 892-5601
`dfehrman@mofo.com
`
`la-1263689
`
`3
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`
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`IPR2013-00594
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`393032805800
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`Certificate of Service (37 C.F.R. § 42.6(e)(4))
`
`I hereby certify that the attached PETITIONER’S REQUEST FOR ORAL
`
`ARGUMENT was served as of the below date via e-mail (by agreement) to the
`
`following counsel of record for the Patent Owner:
`
`Thomas Engellenner (engellennert@pepperlaw.com)
`Reza Mollaaghababa (mollaaghababar@pepperlaw.com)
`PEPPER HAMILTON LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`
`Theodosios Thomas (ted.thomas@sceneralabs.com)
`BLACK HILLS MEDIA, LLC
`5400 Trinity Road, Suite 303
`Raleigh, NC 27607
`
`Christopher Horgan (chris.horgan@concerttechonology.com)
`Concert Technology
`1438 Dahlia Loop
`San Jose, CA 95126
`
`
`
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`Dated: September 12, 2014
`
`
`
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`/s/ David L. Fehrman
`
`David L. Fehrman
`MORRISON & FOERSTER LLP
`707 Wilshire Boulevard
`Los Angeles, California 90017
`
`la-1263689
`
`4
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