`
`IPR2015-00229
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________________
`
`SONY COMPUTER ENTERTAINMENT AMERICA LLC
`Petitioner
`
`v.
`
`APLIX IP HOLDINGS CORPORATION
`Patent Owner
`
`________________________
`
`Case No. IPR2015-00229
`Patent No. 7,667,692
`
`____________________
`
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT UNDER 37
`C.F.R. § 42.70
`
`Patent Owner, Aplix IP Holdings Corporation, requests oral argument
`
`
`
`
`
`pursuant to 37 C.F.R. § 42.70. Pursuant to the Scheduling Order entered May 29,
`
`2015 (Paper 16), Patent Owner respectfully requests two and a half hours of oral
`
`argument, in total, for the proceedings currently scheduled for hearing on January
`
`
`
`U.S. Patent No. 7,667,692
`
`IPR2015-00229
`
`
`19, 2016.1 Patent Owner specifies the following issues, without waiving other
`
`issues, to be argued:
`
`1. Petitioner cites no evidence of obviousness of claims 1-3, 5, 7-10, 12, 13,
`
`15-18, and 20;
`
`2. Person of ordinary skill in the art;
`
`3. Hedberg does not qualify as prior art for an obviousness determination since
`
`it is not analogous to the ’692 patent;
`
`4. Liebenow and Armstrong do not render claims 3 and 5 unpatentable under
`
`35 U.S.C. § 103(a) as obvious;
`
`5. Liebenow and Hedberg do not render claims 11, 13, and 19 unpatentable
`
`under 35 U.S.C. § 103(a) as obvious;
`
`
`1 The Board has scheduled hearings for January 19, 2016, in five proceedings:
`
`IPR2015-00229 (’692 patent)
`
`IPR2015-00230 (’245 patent)
`
`IPR2015-00396 (’313 patent)
`
`IPR2015-00476 (’313 patent)
`
`IPR2015-00533 (’313 patent)
`
`Patent Owner requests 2 ½ hours for its presentation regarding all of these
`
`proceedings, which would be the equivalent of affording each proceeding
`
`approximately 30 minutes. Patent Owner anticipates that some proceedings may
`
`require more or less time within the 2 ½ hours.
`
`
`
`U.S. Patent No. 7,667,692
`
`IPR2015-00229
`
`
`
`6. Secondary considerations show that the ’692 patent’s claims are not
`
`obvious;
`
`7. Petitioner’s Expert Declarations of Gregory F. Welch (Exhibits 1008 and
`
`1041);
`
`8. Response to arguments raised in Petitioner’s Reply;
`
`9. Response to any issues specified by Petitioner in its request for oral
`
`argument; and
`
`10. Any other issues briefed or presented by the parties throughout this trial.
`
`Finally, Aplix requests authorization to use audio-visual equipment—a
`
`projector and screen—at the hearing for displaying demonstrative exhibits.
`
`
`
`U.S. Patent No. 7,667,692
`
`IPR2015-00229
`
`By: ___/Sybil L. Dunlop/________________________
` Robert J. Gilbertson (pro hac vice)
`Sybil L. Dunlop (pro hac vice)
`X. Kevin Zhao (pro hac vice)
`GREENE ESPEL PLLP
`222 South Ninth Street, Suite 2200
`Minneapolis, MN 55402
`Telephone: (612) 373-0830
`Facsimile:
`(612) 373-0929
`E-mail: BGilbertson@GreeneEspel.com
` SDunlop@GreeneEspel.com
` KZhao@GreeneEspel.com
`
`Michael Mauriel, USPTO Reg. No. 44,226
`Sherman W. Kahn (pro hac vice)
` MAURIEL KAPOUYTIAN WOODS LLP
`15 West 26th Street, Floor 7
`New York, NY 10010
`Telephone: (212) 529-5131
`Facsimile:
`(212) 529-5132
`E-mail:
`mmauriel@mkwllp.com
` skahn@mkwllp.com
`
` Attorneys for Patent Owner
` Aplix IP Holdings Corporation
`
`
`
`
`
`Dated: December 23, 2015.
`
`
`
`
`
`
`
`U.S. Patent No. 7,667,692
`
`IPR2015-00229
`
`
`
`CERTIFICATE OF SERVICE
`
`
`
`Pursuant to 37 C.F.R. § 42.6, I hereby certify that on this 23rd day of
`December 2015, the foregoing Patent Owner Aplix IP Holdings Corporation’s
`Request for Oral Argument is being served via email on the following counsel
`of record for petitioner.
`
`
`Lead Counsel
`Eric A. Buresh (Reg. No. 50,394)
`Eric.buresh@eriseip.com
`
`Postal and Hand-Delivery Address:
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, Kansas 66211
`Telephone: (913) 777-5600
`Fax: (913) 777-5601
`
`Back-Up Counsel
`Abran J. Kean (Reg. No. 58,540)
`Abran.kean@eriseip.com
`
`Postal and Hand-Delivery Address:
`ERISE IP, P.A.
`5600 Greenwood Plaza Blvd., Suite
`200
`Greenwood Village, Colorado 80111
`Telephone: (913) 777-5600
`Fax: (913) 777-5601
`
`_____/Sybil L. Dunlop/_________________________
`Robert J. Gilbertson (pro hac vice)
`Sybil L. Dunlop (pro hac vice)
`X. Kevin Zhao (pro hac vice)
`GREENE ESPEL PLLP
`222 South Ninth Street, Suite 2200
`Minneapolis, MN 55402
`Telephone: (612) 373-0830
`Facsimile: (612) 373-0929
`
`
`Counsel for Patent Owner Aplix IP Holdings
`Corporation
`
`
`
`
`Dated: December 23, 2015.
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