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`__________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`__________________________________________________________________
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`SONY MOBILE COMMUNICATIONS (USA) INC.
`Petitioner
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`v.
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`B.E. TECHNOLOGY, L.L.C.
`Patent Owner
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`Patent No. 6,771,290
`Issue Date: Aug. 3, 2004
`Title: COMPUTER INTERFACE METHOD AND APPARATUS WITH
`PORTABLE NETWORK ORGANIZATION SYSTEM AND TARGETED
`ADVERTISING
`__________________________________________________________________
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`PETITIONER’S JOINT REQUEST FOR ORAL ARGUMENT
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`No. IPR2014-00029
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`__________________________________________________________________
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`Petitioner’s Joint Request for Oral Argument
`IPR2014-00029
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`Pursuant to 37 C.F.R. § 42.70(a), requiring a separate paper requesting oral
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`argument and specifying issues to be argued, Petitioner Sony Mobile Communications
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`(USA) Inc. (“SoMC”) submits this joint Request for Oral Argument. The Board has
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`already scheduled the Oral Hearing for December 11, 2014. See Paper 8, at 5
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`(Scheduling Order).
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`Inter partes review nos. IPR2014-00029 (SoMC), IPR2014-00031(Google),
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`IPR2014-0033 (Google), IPR2014-00040 (Microsoft) and IPR2014-00044 (Samsung)
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`all challenge the patentability of claims in U.S. Patent No. 6,771,290 (“the ’290
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`Proceedings”). Accordingly, the petitioners of the ’290 Proceedings (“Petitioners”) are
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`coordinating their efforts so that the Board can efficiently conduct a single hearing on
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`these related proceedings. Petitioners propose that they jointly present argument on
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`the issues as identified below, that Patent Owner follows with its response, and that
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`Petitioners use their remaining time for rebuttal. Because some of the grounds in the
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`five proceedings overlap and others do not, Petitioners plan to present their opening
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`and rebuttal views through two designees, with other representatives offering
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`additional views only if necessary.
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`The Petitioners collectively request 90 minutes of argument time for Petitioners
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`and 90 minutes of argument time for Patent Owner to address the following issues:
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`1.
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`Grounds for which inter partes review was instituted as to claims 2-3 of
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`the ’290 patent in IPR2014-00029, Paper No. 7 (Institution Decision).
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`2
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`Petitioner’s Joint Request for Oral Argument
`IPR2014-00029
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`2.
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`Grounds for which inter partes review was instituted as to claims 2-3 of
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`the ’290 patent in IPR2014-00031, Paper No. 9 (Institution Decision).
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`3.
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`Grounds for which inter partes review was instituted as to claims 2-3 of
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`the ’290 patent in IPR2014-00033, Paper No. 9 (Institution Decision).
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`4.
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`Grounds for which inter partes review was instituted as to claims 1-3 of
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`the ’290 patent in IPR2014-00040, Paper No. 12 (Institution Decision).
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`5.
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`Grounds for which inter partes review was instituted as to claims 2-3 of
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`the ’290 patent in IPR2014-00044, Paper No. 11 (Institution Decision).
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`6.
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`Any issues properly raised by Patent Owner, including in Patent Owner’s
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`Responses in the ’290 Proceedings.
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`7.
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`Any issues addressed by Petitioners, including in the Petitions for Inter
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`Partes Review and Replies in the ’290 Proceedings.
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`8.
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`Respond to Patent Owner’s arguments regarding the claim construction
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`standard to be used in these proceedings, and relevance, if any, to the patentability
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`issues raised by the original claims.
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`9.
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`Issues related to all exhibits filed in this proceeding.
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`10. Rebuttal to issues raised by the Patent Owner.
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`SoMC requests permission to use audio/visual equipment to display
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`demonstrative exhibits, including a projector and screen for PowerPoint or PDF
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`slides.
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`3
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`Petitioner’s Joint Request for Oral Argument
`IPR2014-00029
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`Dated: October 31, 2014
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`_/s/ _John Flock_
`John Flock, Lead Counsel, Reg. No. 39,670
`jflock@kenyon.com
`Michael E. Sander, Reg. No. 71,667
`msander@kenyon.com
`KENYON & KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel: 212-908-7200
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`Paul Qualey, Backup Counsel, Reg. No. 45,027
`pqualey@kenyon.com
`KENYON & KENYON LLP
`1500 K Street, NW
`Washington, DC 20005-1257
`Tel: (202) 220-4200
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`4
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`Petitioner’s Joint Request for Oral Argument
`IPR2014-00029
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`Certificate of Service Under 37 C.F.R. § 42.6(e)(4)
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`I certify that I caused a true and correct copy of the forgoing to be served via
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`electronic mail on the following:
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`Jason S. Angell (Reg. No. 51,408)
`jangell@fawlaw.com
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`Robert E. Freitas (pro hac vice)
`rfreitas@fawlaw.com
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`Daniel J. Weinberg (pro hac vice)
`rfreitas@fawlaw.com
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`Jessica N. Leal (pro hac vice)
`jleal@fawlaw.com
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`BEIPR@fawlaw.com
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`Freitas Angell & Weinberg LLP
`350 Marine Parkway, Suite 200
`Redwood Shores, CA 94065
`Telephone: (650) 593-6300
`Facsimile: (650) 593-6301
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`Dated: _October 31, 2014___
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`_/s/ Michael E. Sander __
`Michael E. Sander, Reg. No. 71,667
`msander@kenyon.com
`KENYON & KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel: 212-425-7200
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`1