`Filed: May 26, 2015
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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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`WEBASTO ROOF SYSTEMS, INC.
`Petitioner,
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`v.
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`UUSI, LLC
`Patent Owner.
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`—————
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`Case IPR2014-00648
`Patent 8,217,612
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`—————
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`Attorney Docket: 130163.231151
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`IPR2014-00648
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`Patent 8,217,612
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`Pursuant to 37 C.F.R. § 42.70(a) and the Scheduling Order (Paper 15),
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`Petitioner respectfully requests oral argument. Oral argument in this proceeding
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`(IPR2014-00648) is scheduled for June 29, 2015. Oral argument in IPR2014-
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`00649 and IPR2014-00650 is also scheduled for June 29, 2015. Petitioner
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`proposes that these three proceedings be argued together, and Patent Owner has
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`indicated in its contingent request for oral argument that Patent Owner agrees with
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`this approach. Paper 25 at 3.
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`Petitioner respectfully requests a total of two (2) hours to present its
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`arguments, with the opportunity to reserve a portion of its time for rebuttal.
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`Petitioner proposes to present its arguments in IPR2014-00649 regarding U.S.
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`Patent No. 7,548,037 first because the Board has not yet heard arguments
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`regarding this patent. Petitioner would then present its arguments in IPR2014-
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`00648 regarding U.S. Patent No. 8,217,612 and in IPR2014-00650 regarding U.S.
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`Patent No. 7,579,802. Those patents were addressed in a combined argument
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`involving a different petitioner on April 30, 2015.
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`With respect to this proceeding (IPR2014-00648), Petitioner intends to argue
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`the instituted grounds of unpatentability, namely that:
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`(1) Claims 6 – 8 are anticipated under 35 U.S.C. § 102(b) by Bernard;
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`(2) Claims 1 – 2 and 5 – 8 are unpatentable under 35 U.S.C. § 103(a) over
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`Lamm, Itoh, and Bernard; and
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`1
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`IPR2014-00648
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`Patent 8,217,612
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`(3) Claims 1 – 2 and 6 – 8 are unpatentable under 35 U.S.C. § 103(a) over
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`Duhame and Kinzl.
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`In addressing these grounds of unpatentability, Petitioner intends to address
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`the constructions of the claim terms at issue in this proceeding: the meanings of
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`“identifying a collision” and “sensing a collision” in claim 1 and the meaning of
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`“deactivate said motor in response to a sensing said window or panel has stopped
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`moving” in claim 6. Petitioner also would address the reasons for combining
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`references under 35 U.S.C. § 103(a) and Patent Owner’s challenges to enablement.
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`Finally, Petitioner would address its motion to exclude being filed concurrently.
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`Petitioner requests that a projector and screen, or alternative means to
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`display files from a laptop computer, be made available for use at the oral
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`argument.
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`Dated: May 26, 2015
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`Respectfully submitted,
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`/Charles H. Sanders/
`Charles H. Sanders
`Reg. No.: 47,053
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`2
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`IPR2014-00648
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`Patent 8,217,612
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing Petitioner’s
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`Request for Oral Argument was served on May 26, 2015, by email directed to the
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`attorneys of record for Patent Owner at the following addresses:
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`Monte L. Falcoff (mlfalcoff@hdp.com)
`Hemant M. Keskar (hkeskar@hdp.com)
`HARNESS, DICKEY & PIERCE, P.L.C.
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`Dated: May 26, 2015
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`By:
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`/Charles H. Sanders/
`Charles H. Sanders
`Reg. No.: 47,053
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