`Filed: May 26, 2015
`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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`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 IPR2014-00650
`Patent 7,579,802
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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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`IPR2014-00650
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`
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`Patent 7,579,802
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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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`(IPR2014-00650) is scheduled for June 29, 2015. Oral argument in IPR2014-
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`00648 and IPR2014-00649 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 24 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 (IPR2014-00650), Petitioner intends to argue
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`the instituted grounds of unpatentability, namely that:
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`A. Claims 15 and 16 are unpatentable under 35 U.S.C. § 103(a) as
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`obvious over Itoh and Kinzl;
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`B. Claim 11 is unpatentable under 35 U.S.C. § 103(a) as obvious over
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`1
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`IPR2014-00650
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`Patent 7,579,802
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`Itoh, Kinzl, and Jones;
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`C. Claims 1, 6–9, 15, and 16 are unpatentable under 35 U.S.C. § 103(a)
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`as obvious over Lamm and Itoh;
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`D. Claim 11 is unpatentable under 35 U.S.C. § 103(a) as obvious over
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`Lamm, Itoh, and Duhame; and
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`E. Claims 1, 7–9, 11, 15, and 16 are unpatentable under 35 U.S.C. §
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`103(a) as obvious over 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 meaning of “a
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`sensor for measuring a parameter of a motor that varies in response to a resistance
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`to motion” in claim 1, and the meaning of “a travel path” in claims 7 and 15, the
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`meaning of “in response to a specified input the controller conducts a calibration
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`motor energization sequence to determine parameters of object” in claim 11, and
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`the meaning of “a logic unit” in claim 15. Petitioner also would address the
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`reasons for combining references under 35 U.S.C. § 103(a) and Patent Owner’s
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`challenges to enablement. Finally, Petitioner would address its motion to exclude
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`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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`2
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`IPR2014-00650
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`Patent 7,579,802
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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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`3
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`IPR2014-00650
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`Patent 7,579,802
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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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`
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`/Charles H. Sanders/
`Charles H. Sanders
`Reg. No.: 47,053