`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CISCO SYSTEMS, INC., QUANTUM CORP.
`and ORACLE CORP.,
`
`Petitioners,
`
`V.
`
`CROSSROADS SYSTEMS, INC.,
`
`Patent Owner
`
`Case IPR2014-01544‘
`
`Patent 7,051,147
`
`CONSOLIDATED PETITIONERS’ REQUEST FOR ORAL HEARING
`
`1 Case IPR2015-00852 has been joined with this proceeding
`
`
`
`Consolidated Petitioners’ Request for Oral Hearing
`
`U.S. Patent No. 7,051,147
`
`IPR20l4-01544
`
`In accordance with 37 C.F.R. § 42.70(a), Petitioners Cisco Systems, Inc.,
`
`Quantum Corp., and Oracle Corp. hereby request an oral hearing in the present
`
`inter partes review. The issues to be argued include:
`
`1. Patent Owner has failed to apply the broadest reasonable constructions of
`
`the “map” and “access control” limitations;
`
`2. The combination of the CRD—550O Manual and the HP Journal renders
`
`obvious the “map” limitation under any construction;
`
`3. The combination of the CRD-5500 Manual and the HP Journal renders
`
`obvious the “access control” limitation under any construction;
`
`4. The CRD-5500 Manual discloses the “allow access” limitation;
`
`5. Patent Owner has not shown objective evidence of nonobviousness; and
`
`6. Other issues raised in papers filed in the present proceeding, including
`
`issues raised in any papers filed between today and the oral hearing.
`
`In light of these remarks, Petitioners respectfully request the opportunity to
`
`present oral arguments before the Board on October 30, 2015. See Revised
`
`Scheduling Order, Paper 14 at 3. Because the issues across IPR20l4-01226,
`
`IPR2014-01463, and IPRZO14-01544 are nearly identical, Petitioners suggest a
`
`single consolidated oral argument for these proceedings, with each side allocated a
`
`
`
`Consolidated Petitioners’ Request for Oral Hearing
`
`U.S. Patent No. 7,051,147
`
`IPR20l4-01544
`
`total of one hour to present oral arguments. Petitioners respectfully request the
`
`scheduling of a morning session, if available.
`
`If the Board has any questions or comments, the undersigned attorney
`
`respectfully requests a telephone conference. No fees are believed to be required
`
`for filing this request; however, the Commissioner is authorized to charge any
`
`required fees, or credit any overpayment, to Haynes and Boone, LLP's Deposit
`
`Account No. 08-1394.
`
`Dated: September 17, 2015
`
`Respectfully submitted,
`
` \\ N4; 3
`
`David L. McCombs
`
`USPTO Reg. No. 32,271
`Haynes and Boone, LLP
`Counsel for Petitioners Cisco
`
`Systems, Inc. and Quantum Corp.
`
`
`
`IPR2014-01544
`Consolidated Petitioners’ Request for Oral Hearing U.S. Patent No. 7,051,147
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e), that
`
`service was made on Patent Owner and Oracle Corp. as detailed below.
`
`Date ofservice September 17, 2015
`
`Manner ofservice Electronic Mail
`
`Documents served Consolidated Petitioners’ Request for Oral Hearing
`
`Persons served Steven R. Sprinkle
`Russell Wong
`John L. Adair
`
`James Hall
`
`Sprinkle IP Law Group
`ATTN: Crossroads IPR
`1301 W. 25”‘ Street, Suite 408
`Austin, TX 78705
`
`crossroadsipr@sprinklelaw.com
`CrossroadsIPR@blankrome.com
`
`Greg Gardella (Lead Counsel for Oracle Corp.)
`cpdocketgardella@oblon.com
`Oblon
`
`1940 Duke Street
`
`Alexandria, VA 22314
`
`gk (7
`
`David L. McCombs
`
`USPTO Reg. No. 32,271
`Haynes and Boone, LLP
`Counsel for Petitioners Cisco Systems, Inc.
`and Quantum Corp.
`
`3
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