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