`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`Eastman Kodak Company, AGFA Corporation,
`Esko Sofiware BVBA, and Heidelberg, USA,
`Petitioners,
`
`V.
`
`CTP Innovations, LLC
`Patent Owner.
`
`
`
`Case IPR2014-00788
`
`Patent 6,738,155
`
`
`CTP INNOVATIONS, LLC’S
`
`REQUEST FOR ORAL ARGUMENT
`
`Filed on behalf of CTP Innovations, LLC
`
`By:
`
`L. Clint Crosby (Back—up Counsel)
`W. Edward Ramage (Lead Counsel)
`Reg. No. 47,508
`Reg. No. 50,810
`BAKER, DONELSON, BEARMAN, BAKER, DONELSON, BEARMAN,
`CALDWELL & BERKOWITZ, PC.
`CALDWELL & BERKOWITZ, PC.
`Baker DoneIson Center
`Monarch Plaza, Suite I600
`211 Commeree Sweet, Sniie 800
`3414 Peaehtree Ave, NE.
`Nashville, Tennessee 37201
`Atlania, Georgia 30326
`Tel: (615) 726-677},
`Tel: (678) 406~8702
`Fax: (615) 744—5771
`Fax: (678) 406~8802
`Email: eramage@bakerdonelson.corn
`Email: ccrosby@bakerdonelson.com
`
`
`
`Case 1PR2014-00788
`
`Patent 6,738,155
`
`Pursuant to 37 C.F.R. § 42.70 and the Board’s Scheduling Order, Patent
`
`Owner CTP Innovations, LLC (“Patent Owner”)
`
`respectfully requests oral
`
`argument. Specifically, Patent Owner requests oral argument on the following:
`
`1.
`
`Each ground of unpatentability on which trial was instituted.
`
`a. Whether the Jebens reference in combination with other prior art
`
`renders some or all of the su ject claims Obvious.
`
`b. Whether the Dorfman reference in combination with other prior art
`
`renders some or all of the subject claims obvious.
`
`c. Whether the Apogee reference in combination with other prior art
`
`renders some or all of the subject claims obvious.
`
`2.
`
`Whether Patent Owner’s motions to exclude evidence should be
`
`granted.
`
`a. Whether the Apogee reference (Ex. 1007) should be excluded.
`
`b. Whether the Suetens Declaration (Ex. 1022) should be excluded.
`
`c. Whether the Jahns Declaration (Ex. 1023) should be excluded.
`
`d. Whether the Supplemental Suetens Declaration (Ex. 1024) should
`
`be excluded.
`
`e. Whether the .1ahns Declaratien or the Supplemental Suetens
`
`Declaration comprise supplemental evidence or supplemental
`
`information.
`
`
`
`Case IPR2014—00788
`
`Patent 6,7385153
`
`3.
`
`Any arguments made by Petitioners in support ef any metiea te
`
`exciude evidence; or set forth in Petitiener’s Re uest fer Ore}
`q
`
`Argument,
`
`Patent Owner further requests the ability to use audio-Visual projection
`
`equipment to display demonstrative exhibits via a PowerPoint presentation.
`
`Dated: June 11, 2015
`
`Respectfully submitted,
`
`BAKER, DONELSON3 BEARMAN,
`
`CALDWELL & BERKOWITZ, RC.
`
`/W. Edward Ramage/
`W. Edward Ramage, Reg. No. 50,810
`(Lead Counsel)
`BAKER, DONELSON, BEARMANE
`
`CALDWELL & BERKOWITZ, RC.
`
`211 Commerce Street, Suite 800
`Nashvifle, Tennessee 37201
`Tel: (615) 726-5771
`Fax: (615) 744-5771
`Email: eramage@bakerdonelsomeone
`
`L. Clint Crosby, Reg. No. 47,508
`(Back-up Ceunsel}
`BAKER, DONELSON? BEARMAN,
`
`CALDWELL & BERKOWITZ, RC.
`Monarch Plaza} Suite 1600
`3414 Peeehtz‘ee Ave? ”NE.
`Aileetej ‘Geeegia 38326
`Te}: (678) §§6~833£32
`Fax: {578) 495-88132
`Email: eereseyggbekerdenelseme911:
`
`Ceuesef fer Patent
`Ieee‘mziem, ELC
`
`(meme CTP
`
`
`
`Case IPRZQi4~90788
`
`13am: 6,738,155
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that, en June 11, 2615? the foregoing
`
`Request fer Ora} Aegumem was served in its entireiy Via US. Express Mail,
`
`postage prepaid, and eleetmflic mail upon the foliewing:
`
`Scott A. McKeown
`
`Michael L. Kiddie
`
`OBLON, SPIVAK, MCCLELLAND,
`MAIER & NEUSTADT, LLP
`
`1940 Duke Street
`
`Alexandria, VA 22314
`
`/W. Edward Ramage/
`W. Edward Ramage, Reg. No. 50,810
`
`
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