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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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`FORD MOTOR COMPANY, JAGUAR LAND ROVER NORTH AMERICA,
`LLC, VOLVO CARS OF NORTH AMERICA, LLC, TOYOTA MOTOR
`NORTH AMERICA, INC., AND SUBARU OF AMERICA, INC.
`Petitioner
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`v.
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` CRUISE CONTROL TECHNOLOGIES LLC
`Patent Owner
`____________
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`Case No. IPR2014-00281
`Patent 6,324,463
` ____________
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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),
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`Petitioners respectfully request oral argument for the trial currently scheduled on
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`March 24, 2015 in this proceeding. Pursuant to 37 C.F.R. § 42.70, Petitioners
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`request one hour of argument time and specify the following issues, without intent
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`to waive consideration of any issue not requested, to be argued:
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`I.
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`The Proper Construction and Scope of the Claims under the
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`Broadest Reasonable Interpretation Standard.
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`II. Whether Claims 1-3, 5, 12-16, 18, 19, 21, 25, 26, and 28 are
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`Unpatentable Under 35 U.S.C. § 102 as anticipated by Narita.
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`III. Whether Claims 17 and 22-24 are Unpatentable Under 35 U.S.C. §
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`103 as obvious over Narita in view of the knowledge of a person of
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`ordinary skill.
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`IV. Whether Claims 17 and 22-24 are Unpatentable Under 35 U.S.C. §
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`103 as obvious over Narita in view of Beiswenger.
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`V. Whether Claims 17, 23, and 24 are Unpatentable Under 35 U.S.C. §
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`103 as obvious over Narita in view of Nagashima.
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`VI. Whether Claims 1-3, 5, 12, and 15 are unpatentable under 35 U.S.C.
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`§ 103 as obvious over Narita in view of Admitted Prior Art.
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`VII. Whether Claims 1-3, 5, 12, and 15 are unpatentable under 35 U.S.C.
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`§ 103 as obvious over Narita in view of the NHTSA Report.
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`VIII. Whether Claims 18, 19, 26, and 29-31 are unpatentable under 35
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`U.S.C. § 102 as anticipated by Nagashima.
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`IX. Rebuttal to Patent Owner’s presentation on all matters including the
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`issues listed above.
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`Petitioner additionally requests permission to use audiovisual display
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`equipment to present demonstratives, including a projector and screen for
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`computer-generated slides. Any demonstrative exhibits beyond those attached
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`to the Petition will be served at least five business days before the oral
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`argument as required by 37 C.F.R. § 42.70(b).
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`This filing is timely, being submitted no later than DUE DATE 4
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`(February 23, 2015), according to the Scheduling Order.
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`Date: February 20, 2015
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`Respectfully submitted,
`ERISE IP, P.A.
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`BY: /s/ Eric A. Buresh
`Eric A. Buresh, Reg. No. 50,394
`Jason R. Mudd, Reg. No. 57,700
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`P: (913) 777-5600
`F: (913) 777-5601
`eric.buresh@eriseip.com
`jason.mudd@eriseip.com
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`ATTORNEYS FOR PETITIONERS
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`
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`CERTIFICATE OF SERVICE ON PATENT OWNER
`UNDER 37 C.F.R. § 42.105(a)
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`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(b), the undersigned certifies that on
`February 20, 2015, a complete and entire copy of Petitioners’ Request for Oral Argument
`was served by electronic mail to Counsel for Patent Owner at the e-mail addresses
`identified below:
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`John R. Kasha, Reg. No. 53,100
`Kelly L. Kasha, Reg. No. 47,743
`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(703) 867-1886
`john.kasha@kashalaw.com
`kelly.kasha@kashalaw.com
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`Respectfully submitted,
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`ERISE IP, P.A.
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`BY: /s/ Eric A. Buresh
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`Eric A. Buresh, Reg. No. 50,394
`Jason R. Mudd, Reg. No. 57,700
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`P: (913) 777-5600
`F: (913) 777-5601
`eric.buresh@eriseip.com
`jason.mudd@eriseip.com
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`ATTORNEYS FOR PETITIONERS
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`
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