`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`MAKO SURGICAL CORP.,
`Petitioner,
`
`v.
`
`BLUE BELT TECHNOLOGIES, INC.,
`Patent Owner.
`
`_____________________
`
`IPR2015-00629
`U.S. Patent No. 6,757,582
`_____________________
`
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.70(a), Patent Owner hereby respectfully requests
`
`oral argument in the present inter partes review proceedings. Patent Owner
`
`specifies the following issues to be argued:
`
`• Whether claims 1, 5, 6, 8, 9, 13, 14, 16, 17, 21–30, 34–42, 47, and 50–
`
`58 are unpatentable under 35 U.S.C. § 102(b) as anticipated by Taylor
`
`(Ex. 1008);
`
`• Whether claim 3 is unpatentable under 35 U.S.C. § 103(a) as obvious
`
`over Taylor (Ex. 1008) in view of Glassman (Ex. 1009);
`
`• Whether claims 48 and 49 are unpatentable under 35 U.S.C. § 103(a)
`
`as obvious over Taylor (Ex. 1008) in view of Delp (Ex. 1011);
`
`• Whether claim 7 is unpatentable under 35 U.S.C. § 103(a) as obvious
`
`over Taylor (Ex. 1008) in view of DiGioia (Ex. 1010);
`
`• Whether claim 11 is unpatentable under 35 U.S.C. § 103(a) as obvious
`
`over Taylor (Ex. 1008);
`
`• Whether Patent Owner’s Motion to Exclude should be granted;
`
`• Response to any issues specified by Petitioner in its request for oral
`
`argument;
`
`• Response to Petitioner’s presentation on all matters; and
`
`
`
`1
`
`
`
`
`
`• Any other issue briefed or presented by the parties throughout this
`
`trial.
`
`Given the significant overlap of issues between IPR2015-00630 and
`
`IPR2015-00629, Patent Owner requests 60 minutes of cumulative argument time
`
`for these proceedings. In particular, Patent Owner proposes that Petitioner present
`
`argument on both IPR2015-00630 and IPR2015-00629, Patent Owner follow with
`
`its response, and that Petitioner use its remaining time for rebuttal.
`
`
`
`Dated: March 9, 2016
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`By: /Brian M. Buroker/
`Brian M. Buroker (Reg. No. 39,125) (lead)
`GIBSON, DUNN & CRUTCHER LLP
`1050 Connecticut Avenue, N.W.
`Washington, DC 20036-5306
`Telephone: 202.955.8500
`Facsimile: 202.467.0539
`bburoker@gibsondunn.com
`Attorney for Patent Owner Blue Belt
`Technologies, Inc.
`
`
`
`
`
`2
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies service pursuant to 37 C.F.R. § 42.6(e) of a copy
`
`of this Request for Oral Argument by electronic mail on March 9, 2016 on the
`
`counsel of record of the Petitioner:
`
`Matthew I. Kreeger, mkreeger@mofo.com
`
`Walter Wu, wwu@mofo.com
`
`
`
`DATED: March 9, 2016
`
`
`
`
`
`
`
`By: /Brian M. Buroker/
`
`
`
`Brian M. Buroker (Reg. No. 39,125)
`
`Attorney for Patent Owner Blue Belt
`Technologies, Inc.
`
`
`
`3
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