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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`_____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________
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`TOYOTA MOTOR NORTH AMERICA, INC., ET AL.
`Petitioners
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`v.
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`CRUISE CONTROL TECHNOLOGIES LLC
`Patent Owner
`_____________
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`Case IPR2014-00280
`Patent 6,324,463
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`_____________
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`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
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`Pursuant to the Board’s July 2, 2014 Scheduling Order (Paper 18), Petitioners
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`respectfully request oral argument for the trial currently scheduled on March 24, 2015 in
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`this proceeding. Pursuant to 37 C.F.R. § 42.70, Petitioners request one hour of argument
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`time and specify the following issues, without intent to waive consideration of any issue
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`not requested, to be argued:
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`I.
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`The Proper Construction and Scope of the Claims under the Broadest
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`Reasonable Interpretation Standard.
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`II. Whether Claims 1-3, 5, 12-16, 21, 25, 26, and 28 are Unpatentable Under
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`35 U.S.C. § 102 as anticipated by Diamante Owner's Manual.
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`III. Whether Claims 15, 16, and 21 are Unpatentable Under 35 U.S.C. § 103 as
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`obvious over Diamante Owner's Manual in view of Diamante Preview
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`Distance Control Manual.
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`IV. Whether Claim 12 is Unpatentable Under 35 U.S.C. § 103 as obvious over
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`Diamante Owner's Manual in view of Watanabe.
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`V. Whether Claims 18 and 19 are Unpatentable Under 35 U.S.C. § 102 as
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`anticipated by Watanabe.
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`VI. Whether Claims 2-5, 26-28, and 34-36 are Unpatentable Under 35 U.S.C. §
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`102 as anticipated by Celsior.
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`VII. Rebuttal to Patent Owner’s presentation on all matters including the issues
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`listed above.
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`TOYOTA ET AL.’S REQUEST FOR ORAL ARGUMENT
`Case IPR2014-00280
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`Petitioners additionally request permission to use audiovisual display
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`equipment to present demonstratives, including a projector and screen for computer-
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`generated slides. Any demonstrative exhibits beyond those attached to the Petition
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`will be served at least five business days before the oral argument as required by 37
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`C.F.R. § 42.70(b).
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`This filing is timely, being submitted no later than DUE DATE 4 (February 23,
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`2015), according to the Scheduling Order.
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`
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`Sughrue Mion, PLLC
`CUSTOMER NUMBER: 23373
`Date: February 20, 2015
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`Respectfully submitted,
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` /William H. Mandir/
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`William H. Mandir
`Registration No. 32,156
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`2
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a copy of the attached Petitioner’s Request for
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`Oral Argument was sent via e-mail on XXXX, to the following:
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`John R. Kasha, Reg. No. 53,100
`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(703) 867-1886
`john.kasha@kashalaw.com
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`Counsel of Record for U.S. Patent No.
`6,324,463
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`Date: February 20, 2015
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`Respectfully submitted,
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` /William H. Mandir/
`William H. Mandir
`Registration No. 32,156
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