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UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`
`
`MAKO SURGICAL CORP.,
`Petitioner
`
`v.
`
`BLUE BELT TECHNOLOGIES, INC.,
`Patent Owner
`
`______________________
`
`Case IPR2015-00630
`Patent No. 6,205,411 B1
`_______________________
`
`
`PETITIONER MAKO SURGICAL CORP.’S
`REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`1
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`sf-3631607
`
`

`
`Pursuant to 37 C.F.R. § 42.70(a) and the Board’s August 4, 2015 Scheduling
`
`Order, Petitioner Mako Surgical Corp. respectfully requests oral argument as
`
`currently scheduled for April 7, 2016. Petitioner requests an opportunity to
`
`address all issues raised in this matter in the Petition, the Patent Owner Response,
`
`Petitioner’s Reply, Patent Owner’s Contingent Motion to Amend, Petitioner’s
`
`Opposition to the Motion to Amend, and Patent Owner’s Reply in Support of the
`
`Motion to Amend, including:
`
`• DiGioia’s qualification as prior art;
`
`• The obviousness of claims 1-15 and 17 in light of the DiGioia prior art
`
`reference;
`
`• The obviousness of claim 16 in light of the combination of both DiGioia
`
`prior art references;
`
`• Patent Owner’s failure to distinguish its proposed amended claims over the
`
`material prior art of record; and
`
`• The obviousness of the proposed amended claims in light of the prior art of
`
`record.
`
`Mako also requests an opportunity to present arguments on any issues raised
`
`by the Patent Owner at Oral Argument, and any additional issues on which the
`
`Board seeks information or clarification. Subject to the Board’s approval, Mako
`
`sf-3631607
`
`2
`
`

`
`may use appropriate demonstrative exhibits during the oral argument and such
`
`demonstrative exhibits will be served according to 37 C.F.R. § 42.70(b).
`
`Dated: March 9, 2016
`
`Respectfully submitted,
`
`
`
`By: /s/ Matthew I. Kreeger
`Matthew I. Kreeger
`Registration No. 56,398
`MORRISON & FOERSTER LLP
`425 Market Street
`San Francisco, California 94105-2482
`Tel: (415) 268-6468
`Fax: (415) 268-7522
`
`Attorney for Petitioner Mako Surgical
`Corp.
`
`
`
`
`
`sf-3631607
`
`3
`
`

`
`
`
`
`
`Certificate of Service (37 C.F.R. § 42.6(e)(4))
`
`I hereby certify that the above captioned Request for Oral Argument was
`
`served as of the below date via electronic mail by agreement on the Patent Owner
`
`at the following correspondence address:
`
`Brian M. Buroker
`GIBSON, DUNN & CRUTCHER LLP
`1050 Connecticut Avenue, N.W.
`Washington, DC 20036-5306
`
`
`
`
`
`
`Dated: March 9, 2016
`
`
`
`/s/ Matthew I. Kreeger
`Matthew I. Kreeger
`Registration No. 56,398
`MORRISON & FOERSTER LLP
`425 Market Street
`San Francisco, California 94105-2482
`(415) 268-7000
`
`Attorney for Petitioner Mako Surgical
`Corp.
`
`sf-3631607
`
`4

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