`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`GOOGLE INC.
`Petitioner
`
`v.
`
`B.E. TECHNOLOGY, LLC
`Patent Owner
`____________
`
`Case IPR2014-00033
`Patent 6,771,290 B1
`____________
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`
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`PETITIONER’S JOINT REQUEST FOR ORAL ARGUMENT
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`
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`Before SALLY C. MEDLEY, KALYAN K. DESHPANDE, and LYNNE E.
`PETTIGREW, Administrative Patent Judges.
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
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`Cases IPR2013-00033
`Patent 6,771,290 B1
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`Pursuant to 37 C.F.R. § 42.70(a), requiring a separate paper requesting oral
`
`argument and specifying issues to be argued, Petitioner Google Inc. submits this
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`joint Request for Oral Argument. The Board has already scheduled the Oral
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`Argument for December 11, 2014. Paper 10, p. 5 (Scheduling Order).
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`Inter partes review nos. IPR2014-00029 (Sony), IPR2014-00031(Google),
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`IPR2014-0033 (Google), IPR2014-00040 (Microsoft) and IPR2014-00044
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`(Samsung) all challenge the patentability of claims in U.S. Patent No. 6,771,290
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`(“the ’290 Proceedings”). Accordingly, the petitioners of the ’290 Proceedings
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`(“Petitioners”) are coordinating their efforts so that the Board can efficiently
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`conduct a single hearing on these related proceedings. Petitioners propose that
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`they jointly present argument on the issues as identified below, that Patent Owner
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`follows with its response, and that Petitioners use their remaining time for rebuttal.
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`Because some of the grounds in the five proceedings overlap and others do not,
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`Petitioners plan to present their opening and rebuttal views through two designees,
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`with other representatives offering additional views only if necessary.
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`The Petitioners collectively request 90 minutes of argument time for
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`Petitioners and 90 minutes of argument time for Patent Owner to address the
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`following issues:
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`1
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`Cases IPR2013-00033
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`Patent 6,771,290 B1
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`Grounds for which inter partes review was instituted as to claims 2-3
`
`1.
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`of the ’290 patent in IPR2014-00029, Paper No. 7 (Institution Decision).
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`2.
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`Grounds for which inter partes review was instituted as to claims 2-3
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`of 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
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`of 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
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`of 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
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`of 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
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`Owner’s Responses in the ’290 Proceedings.
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`7.
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`Any issues addressed by Petitioners, including 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
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`construction standard to be used in these proceedings, and relevance if any to the
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`patentability 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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`2
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`Cases IPR2013-00033
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`Patent 6,771,290 B1
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`Google 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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`Respectfully submitted,
`
`By: /Clinton H. Brannon/
`
`Clinton H. Brannon
`
`Reg. No. 57,887
`
`
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`slides.
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`
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`Dated: October 31, 2014
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`3
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`Cases IPR2013-00033
`Patent 6,771,290 B1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.6(e), I, Clinton Brannon, hereby certify that a
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`copy of the foregoing PETITIONER’S JOINT REQUEST FOR ORAL
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`ARGUMENT has been served via electronic mail transmission on the Attorney of
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`Record for related inter partes review petitions of U.S. Patent No. 6,771,290 (No.
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`IPR2014-00033) at the following address:
`
`Jason S. Angell
`Robert E. Freitas
`Daniel J. Weinberg
`Jessica N. Leal
`FREITAS ANGELL & WEINBERG LLP
`350 Marine Parkway, Suite 200
`Redwood Shores, CA 94065
`jangell@fawlaw.com
`rfreitas@fawlaw.com
`dweinberg@fawlaw.com
`jleal@fawlaw.com
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`
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`
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`Dated: October 31, 2014
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`Respectfully submitted,
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`
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`
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`By: /Clinton H. Brannon/
`
`Clinton H. Brannon
`
`Reg. No. 57,887
`
`Counsel for Petitioner
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`1
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`
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