UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`LG ELECTRONICS, INC., TOSHIBA CORP.,
`VIZIO, INC., HULU, LLC,
`CISCO SYSTEMS, INC., and AVAYA INC.,
`Petitioner,
`v.
`
`STRAIGHT PATH IP GROUP, INC.
`Patent Owner.
`
`____________
`
`Case IPR2015-001981
`Patent No. 6,009,469 C1
`____________
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`FOR INTER PARTES REVIEW OF U.S. PATENT 6,009,469
`
`
`
`
`
`
`
`
`
`
`1 IPR2015-01400 has been joined with this proceeding.
`
`1016334.01
`
`
`
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`LG ELECTRONICS, INC., TOSHIBA CORP.,
`VIZIO, INC., HULU, LLC,
`CISCO SYSTEMS, INC., and AVAYA INC.,
`Petitioner,
`v.
`
`STRAIGHT PATH IP GROUP, INC.
`Patent Owner.
`
`____________
`
`Case IPR2015-001981
`Patent No. 6,009,469 C1
`____________
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`FOR INTER PARTES REVIEW OF U.S. PATENT 6,009,469
`
`
`
`
`
`
`
`
`
`
`1 IPR2015-01400 has been joined with this proceeding.
`
`1016334.01
`
`
`
`
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.70(a) and the Scheduling Order entered on May
`15, 2015 (Paper No. 25), Petitioner respectfully requests oral argument on
`February 9, 2016. Petitioner proposes that the Board conduct a consolidated
`proceeding in Inter Partes Review Nos. 2015-00196, 2015-00198, and 2015-
`00209, given that all of these cases (i) are scheduled for hearing on February 9,
`2016; and (ii) contain overlapping and related subject matter. For these three
`proceedings, Petitioner respectfully requests a total of ninety (90) minutes to
`present its arguments, including time to be reserved for rebuttal, and proposes that
`Patent Owner have a total of ninety (90) minutes to present its responsive
`arguments.
`Without waiving any issue not specifically listed below, Petitioner identifies
`the following issues to be argued at the February 9, 2016 proceeding:
`1.
`The obviousness of claims 1–3, 9, 10, 14, 17, and 18 of the ’469
`patent over the WINS, NetBIOS, and Pinard prior art references, and
`the obviousness of claims 5 and 6 of the ’469 patent over the WINS
`and NetBIOS prior art references;
`Construction of the foregoing claims of the ’469 patent, including but
`not limited to the construction, and discussion thereof, in the Federal
`Circuit’s November 25, 2015 opinion in the appeal Straight Path IP
`Group, Inc. v. Sipnet EU S.R.O., No. 15-1212;
`Arguments and evidence in response to issues raised in Patent
`Owner’s preliminary response (Paper No. 19), response (Paper No.
`34), potential motion(s) to exclude evidence, and request for oral
`argument; and
`
`2.
`
`3.
`
`1016334.01
`
`1
`
`
`
`
`
`
`
`
`
`4.
`
`Any other issues that the Board deems necessary to issue a final
`written decision.
`
`In addition, Petitioner requests that the Board provide audio‐visual
`
`equipment to display demonstrative exhibits, including a projector to be connected
`to a laptop and a screen for displaying documents.
`
`
`Respectfully submitted,
`
`KEKER & VAN NEST LLP
`
`By:
`
`
`/s/ Sharif E. Jacob
`SHARIF E. JACOB
`633 Battery Street
`San Francisco, CA 94111-1809
`Telephone: 415 391 5400
`Facsimile: 415 397 7188
`
`Attorneys for Petitioner HULU, LLC
`
`Dated: January 5, 2016.
`
`
`
`
`
`1016334.01
`
`2
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on January 5, 2016, I caused a true and correct copy of
`this PETITIONER’S REQUEST FOR ORAL ARGUMENT FOR INTER
`PARTES REVIEW OF U.S. PATENT 6,009,469 to be served upon the Patent
`Owner by filing this document through the Patent Review Processing System as
`well as by delivering a copy via email to the following attorneys of record for the
`Patent Owner:
`Counsel for Straight Path IP Group, Inc.
`William A. Meunier (Lead Counsel) (Registration No. 41,193)
`Matthew D. Durell (Backup Counsel) (Registration No. 55, 136)
`Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
`One Financial Center
`Boston, Massachusetts 02111
`Email:
`StraightPathIPRs@mintz.com
`
`Counsel for Hulu, LLC
`Leo Lam (Registration No. 38,528)
`Matthias Kamber
`Keker & Van Nest LLP
`633 Battery Street
`San Francisco, California 94111
`Email:
`llam@kvn.com
`
`mkamber@kvn.com
`
`Counsel for Toshiba
`Clint Conner (Registration No. 52,764)
`Paul Meiklejohn (Registration No. 26,569)
`Jennifer Spaith (Registration No. 51,916)
`Dorsey & Whitney
`50 South Sixth Street, Suite 1500
`Minneapolis, Minnesota 55402
`Email:
`conner.clint@dorsey.com
`
`meiklejohn.paul@dorsey.com
`
`spaith.jennifer@dorsey.com
`
`
`
`
`
`Counsel for VIZIO
`Kevin O’Brien (Registration No. 30,578)
`Richard V. Wells (Registration No. 53,757)
`Baker & McKenzie LLP
`815 Connecticut Avenue, N.W.
`Washington, D.C. 20006
`Email:
`kevin.obrien@bakermckenzie.com
`
`
`richard.wells@bakermckenzie.com
`
`Counsel for Avaya Inc.
`Dorothy P. Whelan (Registration No. 33,814)
`Fish & Richardson
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, Minnesota 55402
`Email:
`whelan@fr.com
`
`Christopher O. Green (Registration No. 52,964)
`Fish & Richardson
`1180 Peachtree Street NE, 21st Floor
`Atlanta, Georgia 30309
`Email:
`cgreen@fr.com
`
`Counsel for CISCO Systems
`David L. Cavanaugh (Registration No. 36,476)
`Wilmer Cutler Pickering Hale and Dorr LLP
`1875 Pennsylvania Avenue, NW
`Washington, DC 20006
`Email:
`david.cavanaugh@wilmerhale.com
`
`Jason D. Kipnis (Registration No. 40,680)
`Wilmer Cutler Pickering Hale and Dorr LLP
`950 Page Mill Road
`Palo Alto, California 94304
`Email:
`jason.kipnis@wilmerhale.com
`
`
`
`
`
`
`Dated: January 5, 2016
`
`Respectfully submitted,
`
`/Rajeev Gupta/
`Darren M. Jiron, Registration No. 45,777
`Rajeev Gupta, Registration No. 55,873
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, L.L.P.
`901 New York Avenue, N.W.
`Washington, D.C. 20001-4413
`Telephone: 202-408-4000
`Facsimile: 202-408-4400
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