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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
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`BROADCOM CORPORATION
`Petitioner
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`v.
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`WI-FI ONE, LLC
`Patent Owner
`____________________
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`Case IPR2013-00601
`Patent 6,772,215
`____________________
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`37 C.F.R. § 42.70
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`Case IPR2013-00601
`Patent 6,772,215
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`In accordance with 37 C.F.R. § 42.70(a), Patent Owner respectfully requests
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`an opportunity to present oral argument before the Board. Oral argument is
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`presently scheduled for December 8, 2014 in IPR2013-00601 relating to U.S.
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`Patent No. 6,772,215 (“the ’215 patent”).1 (See Scheduling Order, Paper 30, p.5).
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`The issues to be argued include:
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`1. Petitioner does not have standing to file the Petition;
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`2. The Petition is barred by 35 U.S.C. § 315(b);
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`3. The broadest reasonable construction of “responsive to the receiving step,
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`constructing a message field for a second data unit, said message field
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`including a type identifier field”;
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`4. The printed matter doctrine does not apply to the “type identifier field”;
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`5. U.S. Pat. No. 6,581,176 to Seo does not anticipate claims 1, 2, 4, 6, 8, 15,
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`22, 25, 26, 29, 32, 34, 45, 46, 49, 52, and 54 of the ’215 Patent under 35
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`U.S.C. § 102 (Ground 1);
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`6. Patent Owner’s Motion to Exclude Evidence;
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`1 In addition, the Board also has scheduled the oral hearing for December 8, 2014,
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`in two other co-pending inter partes review proceedings, IPR2013-00602 and -
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`00636.
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` REQUEST FOR ORAL ARGUMENT
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`2
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`Case IPR2013-00601
`Patent 6,772,215
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`7. Any other issues briefed by or presented by the parties throughout this trial;
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`and
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`8. Any issue argued by Petitioner during the oral argument.
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`Patent Owner requests 60 minutes to present its argument. Patent Owner
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`also requests the ability to use audio-visual equipment to display demonstrative
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`exhibits, including the use of a projector and screen for power point display.
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`
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`LEE & HAYES PLLC
`
` /Peter J. Ayers/
`Peter J. Ayers, Reg. No. 38,374
`John Shumaker, Reg. No. 52,223
`LEE & HAYES, PLLC
`13809 Research Blvd., Suite 405
`Austin, TX 78750
`Phone: (512) 605-8162
`Fax: (509) 944-4693
`peter@leehayes.com
`jshumaker@leehayes.com
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`J. Christopher Lynch, Reg. No. 34,216
`LEE & HAYES, PLLC
`601 W. Riverside Ave., Suite 1400
`Spokane, WA 99201
`Telephone: 509.324.9256
`Fax: 509.323.8979
`chris@leehayes.com
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`Counsel for Patent Owner
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` REQUEST FOR ORAL ARGUMENT
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`3
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`Case IPR2013-00601
`Patent 6,772,215
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that on November 12, 2014 the foregoing
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT was served on Lead
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`and Back-up Counsel for Broadcom Corporation by sending the same via
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`electronic mail to the address provided by Broadcom:
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`Dominic E. Massa, Lead Counsel
`Michael A. Diener, Back-up Counsel
`Wilmer Cutler Pickering Hale and Dorr, LLP
`60 State Street
`Boston, MA 02109
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`LEE & HAYES PLLC
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` /Peter J. Ayers/
`Peter J. Ayers
`Reg. No. 38,374
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` REQUEST FOR ORAL ARGUMENT
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`4
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