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`Patent No. 6,829,634 B1
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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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`ACTIVISION BLIZZARD, INC.,
`ELECTRONIC ARTS INC.,
`TAKE-TWO INTERACTIVE SOFTWARE, INC.,
`2K SPORTS, INC., ROCKSTAR GAMES, INC., and
`BUNGIE, INC.,
`Petitioners,
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`v.
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`ACCELERATION BAY, LLC,
`Patent Owner.
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`Case IPR2015-019961
`Patent No. 6,829,634 B1
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`Before the Honorable SALLY C. MEDLEY, LYNNE E. PETTIGREW, and
`WILLIAM M. FINK, Administrative Patent Judges.
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`PETITIONERS’ CONSOLIDATED REQUEST FOR ORAL HEARING
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`Pursuant to 37 C.F.R. § 42.70(a), requiring a separate paper requesting oral
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`hearing and specifying issues to be argued, Petitioners Activision Blizzard, Inc.,
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`Electronic Arts Inc., Take-Two Interactive Software, Inc., 2K Sports, Inc.,
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`1 Bungie, Inc., who filed Petition IPR2016-00964, has been joined as a petitioner in
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`this proceeding.
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`Case IPR2015-01996
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`Patent No. 6,829,634 B1
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`Rockstar Games, Inc., and Bungie, Inc. (“Petitioners”) submit this Request for Oral
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`Hearing on the instituted grounds of unpatentability for claims 10, 11, 15, and 18
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`of U.S. Patent No. 6,829,634 (the “’634 patent”) under 35 U.S.C. § 102, claims 1-
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`18 of the ’634 patent under 35 U.S.C. § 103, and Patent Owner Acceleration Bay,
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`LLC’s Contingent Motion to Amend original claims 5, 8, and 10 as reflected in
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`substitute claims 25-27, respectively. To account for the expected number of
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`counsel (including litigation counsel in related district court proceedings) and party
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`representatives, Petitioners respectfully request that the Oral Hearing for this
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`proceeding take place in Courtroom A. In the event Courtroom A is not available,
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`Petitioners respectfully request audio equipment enabling access to the Oral
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`Hearing through a teleconference so that non-arguing counsel and/or party
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`representatives may observe the Oral Hearing via teleconference. The Board has
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`already scheduled the Oral Hearing in this proceeding for December 7, 2016, along
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`with Oral Hearings in IPR2015-01951, IPR2015-01953, IPR2015-01964,
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`IPR2015-01970, and IPR2015-01972 (Pap. 12 at 3) involving the same parties and
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`related patents. Petitioners respectfully request that the oral arguments for all of
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`these proceedings relating to Patent Owner’s patents that are scheduled for
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`December 7, 2016, be grouped and presented together in one Oral Hearing.
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`Petitioners further respectfully request equal amounts of argument time for
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`Petitioners and Patent Owner, and respectfully propose two hours of total argument
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`Case IPR2015-01996
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`Patent No. 6,829,634 B1
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`time for Petitioners and two hours of total argument time for Patent Owner in
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`connection with the foregoing issues and proceedings. Petitioners note that various
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`documents and exhibits in this proceeding are the subject of pending Motions to
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`Seal based on Patent Owner's assertion that they contain “highly confidential
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`information,” and that such information may be presented or may otherwise be the
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`subject of discussion during the hearing. See Paps. 32, 35, 55, 68.
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`Dated: November 10, 2016
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`Respectfully submitted,
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`By: /J. Steven Baughman/
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`J. Steven Baughman (lead counsel)
`Reg. No. 47,414
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`Ropes & Gray LLP
`2099 Pennsylvania Avenue, N.W.
`Washington, D.C. 20006- 6807
`P: 202-508-4606/ F: 202-383-8371
`Steven.Baughman@ropesgray.com
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`Mailing address for all correspondence: ROPES & GRAY LLP, IPRM –
`Floor 43, Prudential Tower, 800 Boylston Street, Boston, MA 02199-3600
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`Case IPR2015-01996
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`Patent No. 6,829,634 B1
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a copy of the foregoing PETITIONERS’
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`CONSOLIDATED REQUEST FOR ORAL HEARING was served on November
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`10, 2016 in its entirety by causing the aforementioned document to be
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`electronically mailed, pursuant to the parties’ agreement, to the following attorneys
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`of record:
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`James Hannah
`Reg. No. 56,369
`Kramer Levin Naftalis & Frankel LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Phone: 650-752-1712
`Fax: 650-752-1812
`jhannah@kramerlevin.com
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`Michael Lee
`Reg. No. 63,941
`Kramer Levin Naftalis & Frankel LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Phone: 650-752-1716
`Fax: 650-752-1812
`mhlee@kramerlevin.com
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`Shannon Hedvat
`Reg. No. 68,417
`Kramer Levin Naftalis & Frankel LLP
`1177 Avenue of the Americas
`New York, NY 10036
`Phone: 212-715-9185
`Fax: 212-715-8000
`shedvat@kramerlevin.com
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`Case IPR2015-01996
`Patent No. 6,829,634 B1
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`Jeffrey Price
`Reg. No. 69,141
`Kramer Levin Naftalis & Frankel LLP
`1177 Avenue of the Americas
`New York, NY 10036
`Phone: 212-715-7502
`Fax: 212-715-8000
`jprice@kramerlevin.com
`svdocketing@kramerlevin.com
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`Counsel for Patent Owner Acceleration Bay
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`Dated:
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`November 10, 2016
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`/Bridget McAuliffe/
`Bridget McAuliffe
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`ROPES & GRAY LLP
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`- 5 -
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