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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`
`BROADCOM CORPORATION
`Petitioner
`
`v.
`
`WI-FI ONE, LLC
`Patent Owner
`____________________
`
`Case IPR2013-00602
`Patent 6,466,568
`____________________
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`37 C.F.R. § 42.70
`
`
`
`

`

`Case IPR2013-00602
`Patent 6,466,568
`
`
`
`In accordance with 37 C.F.R. § 42.70(a), Patent Owner respectfully requests
`
`
`
`an opportunity to present oral argument before the Board. Oral argument is
`
`presently scheduled for December 8, 2014 in IPR2013-00602 relating to U.S.
`
`Patent No. 6,466,568 (“the ’568 patent”).1 (See Scheduling Order, Paper 28, p.5).
`
`The issues to be argued include:
`
`1. Petitioner does not have standing to file the Petition;
`
`2. The Petition is barred by 35 U.S.C. § 315(b);
`
`3. The broadest reasonable construction of the term “service type identifier
`
`which identifies a type of payload information”;
`
`4. U.S. Pat. No. 5,488,610 to Morley does not anticipate claims 1-6 of the ’568
`
`Patent under 35 U.S.C. § 102 (Ground 1);
`
`5. Claims 1-6 of the ’568 Patent are patentable over U.S. Pat. No. 5,541,662 to
`
`Adams under 35 U.S.C. § 103 (Ground 2);
`
`6. Proposed substitute claims 8-13 do not add new matter;
`
`7. Proposed substitute claims 8-13 are patentable over the known prior art;
`
`                                                            
`1 In addition, the Board also has scheduled the oral hearing for December 8, 2014,
`
`in two other co-pending inter partes review proceedings, IPR2013-00601 and -
`
`00636.
`
` REQUEST FOR ORAL ARGUMENT
`
`2
`
`

`

`Case IPR2013-00602
`Patent 6,466,568
`
`
`8. Any other issues briefed by or presented by the parties throughout this trial;
`
`and
`
`9. Any issue argued by Petitioner during the oral argument.
`
`
`
`Patent Owner requests 90 minutes to present its argument. Patent Owner
`
`also requests the ability to use audio-visual equipment to display demonstrative
`
`exhibits, including the use of a projector and screen for power point display.
`
`
`
`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
`
`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
`
`Counsel for Patent Owner
`
`
`
`
`
` REQUEST FOR ORAL ARGUMENT
`
`3
`
`

`

`Case IPR2013-00602
`Patent 6,466,568
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on November 12, 2014 the foregoing
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT was served on Lead
`
`and Back-up Counsel for Broadcom Corporation by sending the same via
`
`electronic mail to the address provided by Broadcom:
`
`Dominic E. Massa, Lead Counsel
`Michael A. Diener, Back-up Counsel
`Wilmer Cutler Pickering Hale and Dorr, LLP
`60 State Street
`Boston, MA 02109
`
`
`
`
`
`
`
`
`
`
`
`LEE & HAYES PLLC
`
`
`
`
`
`
`
`
`
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`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` /Peter J. Ayers/
`Peter J. Ayers
`Reg. No. 38,374
`
` REQUEST FOR ORAL ARGUMENT
`
`4
`
`

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