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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`TOYOTA MOTOR NORTH AMERICA, INC., SUBARU OF AMERICA, INC.,
`FORD MOTOR COMPANY, JAGUAR LAND ROVER NORTH AMERICA,
`LLC, AND VOLVO CARS OF NORTH AMERICA, LLC,
`Petitioner
`v.
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`CRUISE CONTROL TECHNOLOGIES LLC,
`Patent Owner
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`____________
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`CASE IPR: 2014-00291
`Patent 6,324,463
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`____________
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`Pursuant to the Board’s July 2, 2014 Scheduling Order (Paper 12), Patent
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`Owner respectfully requests oral argument for the trial currently scheduled on
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`March 25, 2015 in this proceeding. Pursuant to 37 C.F.R. § 42.70, Patent Owner
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`requests one hour of argument time and specifies the following issues, without
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`intent to waive consideration of any issue not requested, to be argued.
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`ISSUES TO BE ADDRESSED DURING ORAL ARGUMENT
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`I.
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`Proper construction and scope of the claims.
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`II. Ground A: whether claims 1-3, 5, 12-14, 18, 19, 25-27, 29-31, and 34-36
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`are unpatentable under 35 U.S.C. § 102 as anticipated by Prometheus.
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`III. Ground B: whether claims 3, 5, 12, 15, 16, 21, and 28 are unpatentable
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`under 35 U.S.C. § 103 as obvious over Prometheus in view of Narita.
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`IV. Ground C: whether claim 4 is unpatentable under 35 U.S.C. § 103 as
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`obvious over Prometheus in view of Celsior.
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`V. Rebuttal to Petitioner’s presentation on all matters including the issues listed
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`above.
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`Patent Owner 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 will be served at least five
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`business days before the oral 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 (February
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`23, 2015), according to the Scheduling Order.
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`CONCLUSION
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`In light of the remarks herein, Patent Owner respectfully requests the
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`opportunity to have an oral argument before the Board. If the Board has any
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`questions, comments, or suggestions, the undersigned attorney earnestly requests a
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`telephone conference.
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`No fees are required for filing this amendment; however, the Commissioner
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`is authorized to charge any additional fees which may be required, or credit any
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`overpayment, to Kasha Law LLC, Deposit Account No. 50-4075.
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`Date: February 23, 2014
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`Customer No. 67050
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`Respectfully submitted,
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`/John R. Kasha/___________________
`John R. Kasha, Lead Counsel
`Registration No. 53,100
`Attorney for Patent Owner
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`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(703) 867-1886, telephone
`(301) 340-3022, facsimile
`Email: john.kasha@kashalaw.com
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`CERTIFICATE OF SERVICE
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`I hereby certify that on the 23th day of February 2015, a true and correct
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`copy of Patent Owner’s Request for Oral Argument by Cruise Control
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`Technologies LLC was served via electronic mail upon Toyota-CCT-
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`IPR@sughrue.com – counsel of record for Petitioner Toyota Motor North
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`America, Inc., Subaru of America, Inc., Ford Motor Company, Jaguar Land Rover
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`North America, LLC, and Volvo Cars of North America, LLC (collectively
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`“Petitioner”).
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`Respectfully submitted,
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`/John R. Kasha/_________________
`John R. Kasha
`Registration No. 53,100
`Attorney for Patent Owner
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`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(703) 867-1886, telephone
`(301) 340-3022, facsimile
`Email: john.kasha@kashalaw.com
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