`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`
`
`
`
`APPLE INC., HTC CORPORATION, HTC AMERICA, INC., SAMSUNG
`ELECTRONICS CO. LTD, SAMSUNG ELECTRONICS AMERICA, INC., AND
`AMAZON.COM, INC.,
`
`Petitioners,
`
`v.
`
`MEMORY INTEGRITY, LLC,
`
`Patent Owner
`
`____________
`
`
`
`Case IPR2015-00163
`Patent 7,296,121
`____________
`
`
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`Proceeding No. IPR2015-00163
`Attorney Docket No. 39521-0007IP4
`
`
`
`Pursuant to 37 C.F.R. § 42.70(a) and the Updated Scheduling Order (Paper
`
`23), Petitioners submit this Request for Oral Argument on all of the instituted
`
`grounds of unpatentability of U.S. Patent No. 7,296,121. A Requests for Oral
`
`Argument in the related IPR proceeding. IPR2015-00159, is being filed on this
`
`same day.
`
`Petitioners respectfully request that the Board allocate two hours for
`
`Petitioner and two hours for Patent Owner (i.e., four hours total) to present oral
`
`arguments in a consolidated hearing for IPR2015-00159 and IPR2015-00163.
`
`Petitioners suggest an allocation of an hour per side to address the Pong and Koster
`
`references presented in the IPR2015-00159 and IPR2015-00163 petitions (where
`
`the parties present in the standard order of Petitioners, then Patent Owner, and
`
`finally Petitioners), a short break, and then an hour per side to address the motion
`
`to amend submitted by Patent Owner in IPR2015-00159 and IPR2015-00163
`
`(where the parties present in the standard motion to amend order of Patent Owner,
`
`then Petitioners, and finally Patent Owner).
`
`With regard to this particular proceeding, Petitioners request (without
`
`waiving consideration of any issue not listed below) to address the following
`
`issues:
`
`1. Whether claims 4–6 and 11 are unpatentable under 35 U.S.C. § 102 as
`
`
`
`1
`
`
`
`anticipated by Koster;
`
` Case IPR2015-00163
`Attorney Docket No: 39521-0007IP4
`
`
`2. Whether claims 19–24 are unpatentable under 35 U.S.C. § 103 as
`
`obvious over Koster and Smith;
`
`3. Whether Patent Owner has carried its burden to demonstrate that
`
`substitute claims 29-34 are patentable over the prior art of record and
`
`known to the Patent Owner, including Culler and Laudon; and
`
`4. Any additional issues on which the Board seeks clarification. The Board
`
`has already scheduled Oral Hearing for February 8, 2016. See Updated
`
`Scheduling Order of July 9, 2015, Paper No. 23.
`
`Respectfully submitted,
`
`
`
`
`
`/ Roberto J. Devoto /
`
`Roberto Devoto, Reg. No. 55,108
`Fish & Richardson P.C.
`P.O. Box 1022
`Minneapolis, MN 55440-1022
`T: 202-783-6830
`F: 202-783-2331
`Attorneys for Petitioner
`
`
`
`
`
`
`
`
`2
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Dated: 1-11-16
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Proceeding No. IPR2015-00163
`Attorney Docket No. 39521-0007IP4
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 CFR §§ 42.6(e)(4) and 42.205(b), the undersigned certifies that
`
`on January 11, 2016, a complete and entire copy of this Petitioner’s Request for Oral
`
`Argument was provided via email to the Patent Owner by serving the
`
`correspondence email address of record as follows:
`
`
`Jonathan D. Baker
`Michael D. Saunders
`Gurtej Singh
`Farney Daniels PC
`411 Borel Avenue, Suite 350
`San Mateo, California 94402
`
`
`
`Email:
`
`jbaker@farneydaniels.com
`msaunders@farneydaniels.com
`tsingh@farneydaniels.com
`MemoryIntegrityIPR@farneydaniels.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Diana Bradley/
`Diana Bradley
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(858) 678-5667
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