`
`US. Patent No. 8,217,612
`
`Filed on behalf of UUSI, LLC
`By: Monte L. Falcoff (mlfalcoff@hdp.comz
`Michael R. Nye (mnye@hdp.com)
`HARNESS, DICKEY & PIERCE, P.L.C.
`
`5445 Corporate Drive, Ste. 200
`Troy, MI 48098
`Telephone: (248) 641-1600
`Facsimile: (248) 641-0270
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`BROSE NORTH AMERICA, INC.
`and
`
`BROSE FAHRZEUGTEILE GMBH & CO. KG, HALLSTADT
`Petitioner
`
`V.
`
`UUSI, LLC
`Patent Owner
`
`Case IPR2014-00416
`
`Patent 8,217,612
`
`PATENT OWNER’S CONTINGENT REQUEST FOR PARTICIPATION IN
`ORAL ARGUMENT
`
`
`
`IPR2014-00416
`
`US. Patent No. 8,217,612
`
`Pursuant to Rule 42.70(a) and the Board’s Scheduling Order, Patent Owner
`
`UUSI does n_ot request oral argument for the hearing currently scheduled for April
`
`30, 2015 in IPR2014-00416 relating to US. Patent No. 8,217,612 (the “’612
`
`Patent”). But if Petitioner requests oral argument then Patent Owner requests to
`
`participate and argue in the hearing. Patent Owner relies on its briefing and
`
`evidence in the record for any and all remaining issues not specifically identified
`
`for oral argument.
`
`I.
`
`Issues to Be Argued
`
`A.
`
`Excluding evidence as requested in Patent Owner’s Motion to
`
`Exclude filed concurrently herewith.
`
`B.
`
`Lack of anticipation of Claims 1, 2 and 6-8 of the ‘612 Patent
`
`by Itoh, including the insufficiency and unreliability of Petitioner’s evidence.
`
`C.
`
`Lack of obviousness of Claims 1, 2 and 5-8 of the ‘612 Patent
`
`by Itoh, including the insufficiency and unreliability of Petitioner’s evidence.
`
`D.
`
`Lack of obviousness of Claims 1, 2 and 5-8 of the ‘612 Patent
`
`by Itoh and Kinzl.
`
`E.
`
`Lack of obviousness of Claims 1, 2 and 5 of the ‘612 Patent by
`
`Itoh and Zuckerman.
`
`F.
`
`Lack of obviousness of Claims 1, 2 and 5 of the ‘612 Patent by
`
`Itoh, Kinzl and Zuckerman.
`
`
`
`IPR2014-00416
`
`US. Patent No. 8,217,612
`
`G.
`
`Lack of anticipation of Claims 6-8 of the ‘612 Patent by Kinzl,
`
`including the insufficiency and unreliability of Petitioner’s evidence.
`
`H.
`
`Lack of obviousness of Claims 6-8 of the ‘612 Patent by Kinzl,
`
`including the insufficiency and unreliability of Petitioner’s evidence.
`
`1.
`
`Lack of obviousness of Claims 6-8 of the ‘612 Patent by Kinzl
`
`and Itoh, including the insufficiency and unreliability of Petitioner’s evidence.
`
`J.
`
`Issues noted in Petitioner’s request
`
`for oral arguments or
`
`otherwise raised by the Board.
`
`11.
`
`Format of Oral Argument
`
`If rebuttals are allowed then Patent Owner requests that it be allowed to
`
`reserve some of its allotted time for rebuttal argumentation.
`
`
`
`IPR2014-00416
`
`US Patent No. 8,217,612
`
`III. Related Proceedings
`
`The issues raised in this proceeding and in IPR2014-00417 present
`
`overlapping issues, and Patent Owner suggests that oral argument
`
`in these
`
`proceedings be handled together if Petitioner requests oral argument.
`
`
`
`SS, DICKEY & PIERCE, P.L.C.
`nte L. Falcoff (Reg. No. 37,617)
`ichael R. Nye (Reg. No. 62,126)
`5445 Corporate Drive, Ste. 200
`Troy, MI 48098
`(248) 641-1600
`(248) 641-0270 Fax
`mlfalcoff@hdp.com
`mnye@hdp.com
`
`Attorneys for Patent Owner
`
`
`
`Certificate of Service Under 37 C.F.R. § 426(c)(4)
`
`IPR2014-00416
`
`US. Patent No. 8,217,612
`
`A copy of this Patent Owner’s Contingent Request for Participation in Oral
`
`Argument has been served to counsel for the Petitioner at the following electronic
`
`mail addresses, pursuant to consent of Petitioner, on this 26th day of March, 2015.
`
`Craig D. Leavell (Reg. No. 48505)
`Craig.leavell@kirkland.com
`Elizabeth A. Cutri
`
`Luke L. Dauchot, P.C. (pro hac vice)
`Luke.dauchot@kirkland.com
`KIRKLAND & ELLIS LLP
`
`Elizabeth.cutri@kirkland.com
`KIRKLAND & ELLIS LLP
`300 North LaSalle Street
`Chicago, Illinois 60654
`Telephone: (312) 862—2000
`Fax: (312) 862-2200
`
`333 South Hope Street
`Los Angeles, California 90071
`Telephone: (213) 680-8400
`Fax: (213) 680-8500
`
`Attorneys ofRecordfor Brose North America, Inc.
`
`
`
`onte L. Falcoff (Reg. No. 37,617)
`Michael R. Nye (Reg. No. 62,126)
`5445 Corporate Drive, Ste. 200
`Troy, MI 48098
`(248) 641—1600
`(248) 641-0270 Fax
`mlfalcoff@hdp_.com
`mnye@hdp.com
`
`Attorneys for Patent Owner
`
`
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