`Patent 6,101,534
`Paper No. 19
`Filed: June 16, 2016
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`SONY COMPUTER ENTERTAINMENT AMERICA LLC,
`Petitioner,
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`v.
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`ROTHSCHILD DIGITAL MEDIA INNOVATIONS, LLC,
`Patent Owner.
`____________
`
`Case IPR2015-01364
`Patent 6,101,534
`____________
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`Mail Stop: Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`–1–
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`Case IPR2015-01364
`Patent 6,101,534
`Pursuant to 37 C.F.R. § 42.70(a) and the Scheduling Order (see Paper No. 9
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`at 7) as modified (see Paper No. 14 at 2), Patent Owner respectfully requests oral
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`argument, which is currently scheduled for August 18, 2016.
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`The issues to be argued are those related to the grounds upon which inter
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`partes review has been instituted, specifically:
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`(1) claim construction, including the use of the terms “direct” and
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`“indirect” in construing the claims, and the significance of the
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`recitation that the auxiliary site addresses are structured to be
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`remotely accessed so as to initiate utilization of auxiliary site data;
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`(2) whether U.S. Patent No. 5,724,103 (“Batchelor”) constitutes non-
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`analogous art with respect to the claimed inventions;
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`(3) whether claims 1, 6-9, 21, 23 and 24 are obvious over U.S. Patent
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`No. 5,892,825 (“Mages”) in view of Batchelor; and
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`(4) whether claim 22 is obvious over Mages in view of Batchelor, in
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`further view of U.S. Patent No. 5,736,977 (“Hughes”).
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`Patent Owner respectfully requests one hour of argument time.
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`Respectfully submitted,
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`/Thomas K. Landry/
`Thomas K. Landry, Lead Counsel
`Registration No. 33,939
`Telephone: (305) 372-7474
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`
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`Date: June 16, 2016
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`–2–
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`CERTIFICATE OF SERVICE
`UNDER 37 C.F.R. §§ 42.6(e)
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`Pursuant to 37 C.F.R. §§ 42.6(e), I certify that I caused to be served
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`electronically by agreement of the parties on this 16th day of June 2016, a true and
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`correct copy of the foregoing Patent Owner’s Request for Oral Argument on
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`counsel of record for Petitioner as follows:
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`Eric A. Buresh, Esq.
`eric.buresh@eriseip.com
`Abran J. Kean, Esq.
`abran.kean@eriseip.com
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`Telephone: (913) 777-5600
`Facsimile: (913) 777-5601
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`Respectfully submitted,
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`/Thomas K. Landry/
`Thomas K. Landry (Reg. No. 33,939)
`tlandry@careyrodriguez.com
`CAREY RODRIGUEZ
`MILIAN GONYA, LLP
`1395 Brickell Avenue, Suite 700
`Miami, Florida 33131
`Telephone: (305) 372-7474
`Facsimile: (305) 372-7475
`Counsel for Rothschild Digital Media
`Innovations, LLC
`
`Dated: June 16, 2016
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