`____________________________________________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
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`GOOGLE INC., SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner
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`v.
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`SUMMIT 6 LLC
`Patent Owner
`____________________
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`Case: IPR2015-008061
`Patent No. 7,765,482 B2
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`Title: Web-Based Media Submission Tool
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`PURSUANT TO 37 C.F.R. § 42.70
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`1 Samsung Electronics Co., Ltd., who filed a Petition in IPR2016-00029,
`has been joined as a petitioner in the instant proceeding.
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`IPR2015-00806
`U.S. Pat. No. 7,765,482
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`
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`In accordance with 37 C.F.R. § 42.70(a), Patent Owner respectfully requests
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`an opportunity to present oral argument before the Board. Oral argument is presently
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`scheduled for May 18, 2016 in IPR2015-00806 relating to U.S. Patent No. 7,765,482
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`(“the ’482 patent”).2 (See Order, Paper 36, p.2). As to the ’482 patent, Patent Owner
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`anticipates addressing the following issues in its argument:
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`1. Whether challenged claims 12, 13, 16, 18, 19, 21–25, 35–38, 40–42,
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`44–46, and 49 are obvious under 35 U.S.C. § 103 over Creamer and
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`Aihara in view of the differences between the challenged claims and
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`the prior art, especially when viewed in light of the objective evidence
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`of non-obviousness;
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`2. Whether challenged claims 12, 13, 16, 18, 19, 21–25, 35–38, 40–42,
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`44–46, and 49 are obvious under 35 U.S.C. § 103 over Mayle and
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`Narayen in view of the differences between the challenged claims and
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`the prior art, especially when viewed in light of the objective evidence
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`of non-obviousness;
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`3.
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`Reply to any arguments raised in Petitioner’s Petition and Reply;
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`2 In addition, the Board has scheduled the oral hearing for May 18, 2016 in one other
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`co-pending inter partes review proceeding, IPR2015-00807.
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`1
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`IPR2015-00806
`U.S. Pat. No. 7,765,482
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`4.
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`Respond to any issues specified by Petitioner in its request for oral
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`argument;
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`5.
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`6.
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`Respond to Petitioner’s presentation on all matters; and
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`Any additional issues on which the Board seeks clarification.
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`Lead counsel for Patent Owner met and conferred with lead counsel for
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`Petitioner and the parties agree that the hearings in IPR2015-00806 and IPR2015-
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`00807 could be concluded in one half-day session. Patent Owner requests 60
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`minutes collectively to present its arguments on both matters. Patent Owner also
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`requests the ability to use audio-visual equipment to display demonstrative exhibits,
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`including the use of a projector and screen for power point display.
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`Respectfully submitted,
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`
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`
` /Peter J. Ayers/
`Peter J. Ayers, Reg. No. 38,374
`Email: peter@leehayes.com
`John Shumaker, No. 52,223
`Email: jshumaker@leehayes.com
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`LEE & HAYES, PLLC
`11501 Alterra Parkway, Suite 450
`Austin, TX 78758
`Phone: (512) 605-0252
`Facsimile: (512) 605-0269
`Attorneys for Patent Owner
`Summit 6 LLC
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`2
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`Dated: April 6, 2016
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`IPR2015-00806
`U.S. Pat. No. 7,765,482
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`I hereby certify that on this 6th day of April, 2016, the foregoing PATENT
`OWNER’S REQUEST FOR ORAL ARGUMENT PURSUANT TO 37 C.F.R.
`§ 42.70 was served on lead and back-up counsel for Petitioner by sending the same
`by electronic means to the address provided by Petitioner:
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`John Alemanni, Reg. No. 47,384
`Lead Counsel
`Kilpatrick Townsend & Stockton LLP
`1001 West Fourth Street
`Winston-Salem, NC 27101-2400
`JAlemanni@kilpatricktownsend.com
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`Michael Morlock, Reg. No. 62,245
`Back-up Counsel
`Kilpatrick Townsend & Stockton LLP
`1001 West Fourth Street
`Winston-Salem, NC 27101-2400
`MMorlock@kilpatricktownsend.com
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`Brian K. Erickson, Reg. No. 48,895
`DLA Piper LLP(US)
`401 Congress Avenue, Ste. 2500
`Austin, TX 787011-3799
`Samsung_Summit-IPR@dlapiper.com
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`James M. Heintz, Reg. No. 41,828
`DLA Piper LLP (US)
`11911 Freedom Drive, Ste. 300
`Reston, VA 20190
`Samsung_Summit-IPR@dlapiper.com
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`
` /Peter J. Ayers/
`Peter J. Ayers, Reg. No. 38,374
`Attorney for Patent Owner
`Summit 6 LLC
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`CERTIFICATE OF SERVICE
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`3
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