`
`Patent 6,771,290 B1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS AMERICA, INC.
`
`Petitioner V.
`
`BE. TECHNOLOGY, L.L.C.
`
`Patent Owner
`
`Case IPR2014—00044
`
`Patent 6,771,290 B1
`
`Before SALLY C. MEDLEY, KALYAN K. DESI-IPANDE, and LYNNE E.
`PETTIGREW, Administrative Patent Judges.
`
`PETITIONER’S JOINT REQUEST FOR ORAL ARGUMENT
`
`
`
`Case IPR2014-00044
`
`Patent 6,771,290 B1
`
`Pursuant to 37 CPR. § 42.70(a), requiring a separate paper requesting oral
`
`argument and specifying issues to be argued, Petitioner Samsung Electronics
`
`America Inc. (“Samsung”) submits this Joint Request for Oral Argument. The
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`Board has already scheduled the Oral Argument for December 11, 2014. Paper 12,
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`p. 5 (Scheduling Order).
`
`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) (“the ‘290 proceedings”), all challenge the patentability of claims in
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`US. Patent No. 6,771,290. 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 identified below, that Patent Owner
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`follow 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 request 90 minutes of argument time for Petitioners and 90
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`minutes of argument time for Patent Owner to address the following issues:
`
`1.
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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 IPR2014-00029, Paper No. 7 (Institution Decision).
`
`2
`
`
`
`Case IPR2014-00044
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`Patent 6,771,290 B1
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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).
`
`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).
`
`4.
`
`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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`Response 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.
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`Rebuttal to issues raised by the Patent Owner.
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`
`
`Case IPR2014-00044
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`Patent 6,771,290 B1
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`The Petitioners request 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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`GREENBERG TRAURIG, LLP
`
`
`
`Date: October 31 2014 /h]'b/
`Heath J. Briggs
`Registration No. 54,919
`1200 17th Street, Suite 2400
`Denver, CO 80202
`
`Phone: (303) 572—6500
`Fax: (303) 572-6540
`
`
`
`Case IPR2014—00044
`
`Patent 6,771,290 B1
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`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 31St day of October 2014, a copy of this
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`PETITIONER’S JOINT REQUEST FOR ORAL ARGUMENT has been
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`served on Patent Owner as provided in 37 CPR. § 42.6(e) via electronic mail
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`transmission addressed to the person(s) at the below address(es):
`
`Jason S. Angell (Reg. No. 51408)
`jangell@fawlaw.com
`beiplawgagfawlawcom
`FREITAS ANGELL & WEINBERG LLP
`
`350 Marine Parkway, Suite 200
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`Date: October 31 2014
`
`
`Respectfully submitted,
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`GREENBERG TRAURIG, LLP
`
`/
`\J
`Heath J. Briggs
`Registration No. 54,919
`1200 17th Street, Suite 2400
`Denver, CO 80202
`
`Phone: (303) 572-6500
`Fax: (303) 572-6540
`
`
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