`By: Thomas Engellenner
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`(617) 204-5100 (telephone)
`(617) 204-5150 (facsimile)
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`WAVEMARKET, INC. D/B/A LOCATION LABS
`Petitioner
`
`v.
`
`LOCATIONET SYSTEMS, LTD.
`Patent Owner
`___________________
`
`Case No. IPR2014-00199
`U.S. Patent 6,771,970
`___________________
`
`
`PATENT OWNER’S REQUEST FOR ORAL
`ARGUMENT UNDER 37 C.F.R. § 42.70
`
`
`
`IPR2014-00199
`U.S. Patent 6,771,970
`
`
`Patent Owner LocatioNet Systems, Ltd. (“Patent Owner”) respectfully requests
`
`oral argument in IPR2014-00199 under 37 C.F.R. § 42.70(a). Pursuant to the
`
`Scheduling Order dated May 9, 2014 (Paper 19), oral argument is currently scheduled
`
`for February 3, 2015 (Paper 19, Due Date 7).
`
`Oral argument will focus on the patentability of the challenged claim of U.S.
`
`Patent No. 6,771,970 (“the ’970 Patent”), and Patent Owner specifies the following
`
`principal issues to be argued, without intent to waive consideration of any allowable
`
`issue not requested or raised by Petitioners:
`
`A. An technical overview of the ’970 Patent and claim 18.
`
`B.
`
`C.
`
`The proper construction of the claim term “map database.”
`
`The proper construction of the claim term “map engine for manipulating
`
`said map database.”
`
`D.
`
`The teachings of the art relied upon for which trial was instituted, i.e.,
`
`U.S. Patent No. 6,243,039 to Elliot (Exhibit 1003).
`
`E.
`
`Petitioner’s failure to prove by a preponderance of the evidence that
`
`claim 18 of U.S. Patent No. 6,771,970 is unpatentable under 35 U.S.C.
`
`102(e) as allegedly being anticipated by Elliot.
`
`F.
`
`Issues raised by Patent Owner’s motion to exclude, including whether the
`
`declaration of Petitioner’s reply witness, Dr. Craig Rosenberg, is
`
`inadmissible evidence.
`
`#31877986 v1
`
`1
`
`
`
`G. Any additional issues for which the Board requests argument or any other
`
`issue raised by Petitioner prior to or at oral argument.
`
`Patent Owner additionally requests permission to present handouts of
`
`demonstrative exhibits during the oral argument.
`
`
`
`Dated: December 30, 2014
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`By: /Thomas Engellenner/
`Thomas Engellenner, Reg. No. 28,711
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`(617) 204-5100 (telephone)
`(617) 204-5150 (facsimile)
`Attorney for Patent Owner
`
`2
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 30th day of December, 2014, a true and correct copy
`
`of the foregoing Patent Owner’s Request for Oral Argument Under 37 C.F.R. § 42.70
`
`was served on the following counsel for Petitioner Wavemarket, Inc. d/b/a Location
`
`Labs via email and Federal Express Mail:
`
`
`
`
`
`Mark L. Hogge
`Scott W. Cummings
`Dentons US LLP
`1301 K Street, N.W., Suite 600
`Washington DC 20005
`Tel: (202)408-6400
`Fax: (202)408-6399
`
`Dated: December 30, 2014
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`mark.hogge@dentons.com
`scott.cummings@dentons.com
`
`Respectfully submitted,
`By: /Thomas Engellenner/
`Thomas Engellenner, Reg. No. 28,711
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`(617) 204-5100 (telephone)
`(617) 204-5150 (facsimile)
`Attorney for Patent Owner
`
`
`
`3
`
`
`
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