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`Filed on behalf of Petitioner
`By: Richard F. Giunta
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`Elisabeth H. Hunt
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`Randy J. Pritzker
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`Michael N. Rader
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`WOLF, GREENFIELD & SACKS, P.C.
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`600 Atlantic Avenue
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`Boston, MA 02210
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`Tel: (617) 646-8000
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`Fax: (617) 646-8646
`RGiunta-PTAB@wolfgreenfield.com
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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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`RPX CORPORATION,
`Petitioner,
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`v.
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`APPLICATIONS IN INTERNET TIME, LLC,
`Patent Owner.
`_____________
`
`
`Case No. IPR2015-01752
`Patent No. 7,356,482
`_____________
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`PURSUANT TO 37 C.F.R. § 42.70(a)
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`Petitioner, RPX Corporation, by and through its attorneys, respectfully
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`requests oral argument, currently scheduled for November 8, 2016. Given the
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`overlap of issues between this proceeding and related cases IPR2016-01750 and
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`IPR2016-01751, Petitioner requests that the oral arguments for the proceedings be
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`merged and conducted as a consolidated hearing. Petitioner requests a total of 90
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`minutes to present its arguments for all three cases, and requests the ability to
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`move between the cases during its argument, as well as to reserve a portion of its
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`total time for presenting rebuttal arguments after Patent Owner’s presentation.
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`Pursuant to 37 C.F.R § 42.70, and without intending to waive any issue not
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`specifically identified, Petitioner specifies the following issues to be argued:
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`1.
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`Proper construction of the claimed “automatically detecting changes
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`that affect an application;”
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`2.
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`Anticipation of claim 22 under 35 U.S.C. § 102(e) by Popp under both
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`Petitioner’s and Patent Owner’s constructions;
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`3. Obviousness of claims 3–6 and 23–26 under 35 U.S.C. § 103(a) in
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`view of Popp and Cobb under both Petitioner’s and Patent Owner’s constructions;
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`4. Obviousness of claim 22 under 35 U.S.C. § 103(a) in view of
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`Balderrama and Java Complete under both Petitioner’s and Patent Owner’s
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`constructions;
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`1
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`5. Obviousness of claims 3–6 and 23–26 under 35 U.S.C. § 103(a) in
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`view of Balderrama, Java Complete, and Codd under both Petitioner’s and Patent
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`Owner’s constructions;
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`6. Obviousness of claims 3–6 and 23–26 under 35 U.S.C. § 103(a) in
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`view of Kovacevic and Codd under both Petitioner’s and Patent Owner’s
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`constructions;
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`7.
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`Real party-in-interest;
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`8. Any issue identified in Patent Owner’s Request for Oral Argument;
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`9.
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`Any other issues raised in papers yet to be filed, such as Motions to
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`Exclude; and
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`10. Any other issues the Board deems necessary to consider for issuing a
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`Final Written Decision.
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`2
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`Petitioner requests that the Board provide audio-visual equipment to display
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`demonstrative exhibits, including a projector to be connected to a laptop and a
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`screen for displaying documents.
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`Dated:
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`Respectfully submitted,
`RPX Corporation
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`By_/Elisabeth Hunt/______________
`Richard F. Giunta, Reg. No. 36,149
`Elisabeth H. Hunt, Reg. No. 67,336
`Randy J. Pritzker, Reg. No. 35,986
`Michael N. Rader, Reg. No. 52,146
`WOLF GREENFIELD & SACKS, P.C.
`600 Atlantic Ave.
`Boston, MA 02210-2206
`Tel: 617-646-8000/Fax: 617-646-8646
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`3
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
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`I certify that on this 3rd day of October, 2016, I will cause a copy of the
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`foregoing document to be served via electronic mail, as previously consented to by
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`Patent Owner, upon the following counsel of record:
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`Jonathan Pearce (Reg. No. 60,972)
`M. Kala Sarvaiya (Reg. No. 58,912)
`SoCal IP Law Group LLP
`310 N. Westlake Boulevard, Suite 120
`Westlake Village, CA 91362
`uspto@socalip.com
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`Date: October 3, 2016
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`/MacAulay Rush /
`MacAulay Rush
`Patent Paralegal
`WOLF GREENFIELD & SACKS, P.C.
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