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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC. and MOTOROLA MOBILITY, LLC,
`
`
`
`Petitioners,
`
`
`
`v.
`
`
`
`GLOBAL TOUCH SOLUTIONS, LLC,
`
`Patent Owner
`
`
`
`Case IPR2015-01175
`
`Patent 8,288,952 B2
`
`
`
`PATENT OWNER’S
`REQUEST FOR ORAL ARGUMENT
`
`
`
`

`
`Patent Owner Global Touch Solutions, LLC. ("Global Touch Solutions")
`
`
`
`requests oral argument under 37 C.F.R. § 42.70 and the Board's Scheduling Order.
`
`Oral argument is currently scheduled for August 3, 2016.
`
`Global Touch Solutions specifies the following issues to be argued, without
`
`intent to waive consideration of any allowable issue not requested or raised by
`
`Petitioners:
`
`1.
`
`2.
`
`3.
`
`functions."
`
`Claim construction of "user interface."
`
`Claim construction of "energy consuming load."
`
`Claim construction of "touch sensor functions"/"touch sensing
`
`4.
`
`Claim construction of "selection and activation of a function or mode
`
`of the product in response to a further activation signal(s) received from the user
`
`interface."
`
`5.
`
`Claim construction of "a function that was activated in response to an
`
`activation signal, received from said user interface."
`
`6.
`
`Claim construction of "production functions."
`
`7. Whether claims 1-3, 16, 17, 19, 22-24, 26, 27, and 38-40 are obvious
`
`over Beard in view of Rathmann.
`
`
`
`1
`
`

`
`
`8. Whether claims 4 and 14 are obvious over Beard in view of Rathmann
`
`and Danielson.
`
`9.
`
`Petitioners are the party with the burden of proof and therefore will
`
`present first at the oral hearing. Global Touch Solutions also will address any
`
`issues raised by Petitioners, or questions raised by the Board during Petitioners'
`
`presentation.
`
`Global Touch Solutions requests the ability to use an overhead projector or
`
`other audio-visual equipment for demonstrative exhibits such as PowerPoint slides.
`
`
`
`
`
`Respectfully submitted,
`Global Touch Solutions, LLC
`
`/Fadi N. Kiblawi/___________
`William H. Mandir
`Registration No. 32,156
`wmandir@sughrue.com
`
`Fadi N. Kiblawi
`Registration No. 61,973
`fkiblawi@sughrue.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Date: July 11, 2016
`
`
`
`
`2
`
`

`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that a copy of the attached Patent Owner's Request
`
`for Oral Argument and this Certificate of Service are being served on July 11, 2016
`
`by electronic mail upon the following:
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`/Fadi N. Kiblawi/
`Fadi N. Kiblawi
`Registration No. 61,973
`
`
`3
`
`Robert Steinberg
`Matthew J. Moore
`Gabriel S. Gross
`Phillip E. Morton
`DeAnna Allen
`Joseph M. Drayton
`bob.steinberg@lw.com
`matthew.moore@lw.com
`gabe.gross@lw.com
`pmorton@cooley.com
`dallen@cooley.com
`jdrayton@cooley.com
`
`
`
`Date: July 11, 2016

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