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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`ORACLE CORPORATION,
`NETAPP INC. and
`HUAWEI TECHNOLOGIES CO., LTD.
`
`Petitioners,
`
`v.
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`CROSSROADS SYSTEMS, INC.
`
`Patent Owner.
`
`____________
`
`Case IPR2014-01209
`
`U.S. Patent No. 7,051,147
`
`____________
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`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
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`
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`
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`Petitioners’ Request for Oral Argument.
`Case IPR2014-01209
`U.S. Patent No. 7,051,147
`
`Petitioners respectfully request oral argument. Pursuant to 37 C.F.R. §
`
`
`
`
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`42.70, Petitioners specify the following issues to be argued:
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`1. Patent Owner has failed to apply the broadest reasonable construction to
`claim terms, including the “map” and “access control” limitations;
`2. Claims 1, 2, 4, 10, 11 and 13 are rendered obvious by Kikuchi and
`Bergsten;
`3. Claim 5 is rendered obvious by Kikuchi, Bergsten and Smith;
`4. Claims 1, 2, 4, 10, 11 and 13 are rendered obvious by Bergsten and Hirai;
`5. Claim 5 is rendered obvious by Bergsten, Hirai and Smith;
`6. Patent Owner has not antedated Kikuchi;
`7. Patent Owner has not provided objective evidence of nonobviousness;
`and
`8. Other issues raised in papers filed in the present proceeding, including
`issues raised in any papers filed between today and the oral hearing.
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`
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`Because issues across IPR2014-01197, IPR2014-01207, and IPR2014-01209
`
`are similar, Petitioners suggest a single consolidated oral argument for these
`
`proceedings, with Petitioners and Patent Owner each allocated one hour to present
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`oral arguments. Petitioners further suggest that the Board set the hearing for the
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`afternoon of October 30, 2015. Doing so would allow the Board to hold the
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`hearings in related case numbers IPR2014-01226, IPR2014-01463 and IPR2014-
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`01544 during the morning of October 30, 2015 as requested by the petitioners in
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`1
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`
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`Petitioners’ Request for Oral Argument.
`Case IPR2014-01209
`U.S. Patent No. 7,051,147
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`
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`
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`those proceedings. See, e.g., Paper No. 37 in IPR2014-1226. During the morning
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`hearing the Board can focus on the CRD references, as those are the only
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`references at issue in those cases. During the afternoon hearing the Board will
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`additionally hear arguments on Kikuchi, Bergsten and Hirai.
`
`In the event any fees are required for this Request, please charge Deposit
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`Account No. 15-0030.
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`
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`Dated: September 21, 2015
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`
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`
`
` /Greg H. Gardella/
`
`Greg H. Gardella
`Reg. No. 46,045
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`2
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies service of
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`PETITIONERS’ REQUEST FOR ORAL ARGUMENT on the counsel of record
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`for the Patent Owner by filing this document through the Patent Review Processing
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`System as well as delivering a copy via electronic mail to the following addresses:
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`crossroadsipr@sprinklelaw.com
`CrossroadsIPR@blankrome.com
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`
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`
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`
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`/Greg H. Gardella/
`
`Greg H. Gardella (Reg. No. 46,045)
`Counsel for Petitioners
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`
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`
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`Dated: September 21, 2015
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