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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`SONY CORPORATION,
`SAMSUNG ELECTRONICS, CO. LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., and
`SAMSUNG SEMICONDUCTOR, INC.,
`PETITIONERS
`
`v.
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`RAYTHEON COMPANY,
`PATENT OWNER
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`
`
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`____________
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`Case IPR2016-00209, -00962
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`Patent 5,591,678
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`____________
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`Pursuant to the Board’s Updated Scheduling Order (Paper No. 21), Patent
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`Owner Raytheon Company hereby respectfully requests oral argument, already
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`scheduled for October 13, 2016.
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`Pursuant to 37 CFR § 42.70, Patent Owner hereby identifies the following
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`issues to be argued:
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`1. Whether ’678 patent claims 1-18 are unpatentable based on the
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`instituted grounds of unpatentability:
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`a.
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`’678 Claims 1-4, 6, 7, 10 and 11 are unpatentable under 35 U.S.C.
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`§102(b) as anticipated by Liu;
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`b.
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`’678 Claims 2-4 and 11 are unpatentable under 35 U.S.C. §103(a) as
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`obvious in view of Liu and Black;
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`c.
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`’678 Claims 5 and 12-16 are unpatentable under 35 U.S.C. §103(a) as
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`obvious in view of Liu and Riseman;
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`d.
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`’678 Claim 8 is unpatentable under 35 U.S.C. §103(a) as obvious in
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`view of Liu and Oldham;
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`e.
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`’678 Claim 10 is unpatentable under 35 U.S.C. §103(a) as obvious in
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`view of Liu and Wen
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`f.
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`’678 Claim 9 is unpatentable under 35 U.S.C. §103(a) as obvious in
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`view of Liu, Wen and Ying;
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`2
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`g.
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`’678 Claim 17 is unpatentable under under 35 U.S.C. §103(a) as
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`
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`obvious in view of Liu, Riseman and Kusunoki; and
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`h.
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`’678 Claim 18 is unpatentable under 35 U.S.C. §103(a) as obvious in
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`view of Liu, Riseman and Oldham.
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`2.
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`Any issues specified by Petitioner in a Request for Oral Argument.
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`Patent Owner requests the ability to use audio-visual equipment for
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`demonstrative exhibits such as PowerPoint slides. Patent Owner notes that a
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`portion of the record is subject to confidentiality restrictions, including material
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`and information subject to The International Traffic in Arms Regulations (“ITAR”)
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`found in Title 22 of the Code of Federal Regulations, parts 120 to 130, and that
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`portions of any argument might need to be closed. The panel and parties should
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`discuss the required procedures in a conference call if the panel orders argument.
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`3
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`Date: September 8, 2016
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`
`Customer Number: 27890
`Steptoe & Johnson, LLP
`115 S. LaSalle Street, Suite 3100
`Chicago, IL 60603
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`Telephone: (312) 577-1252
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`Respectfully submitted,
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`/Thomas J. Filarski/
`Thomas J. Filarski
`Reg. No. 31,612
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`Counsel for Raytheon Company
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`4
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a copy of the foregoing PATENT OWNER’S
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`REQUEST FOR ORAL ARGUMENT was served on September 8, 2016 in its
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`entirety by filing this document through the Patent Trial and Appeal Board End to
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`End system (PTAB E2E) as well as by delivering a copy via electronic mail to the
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`following:
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`
`
`
`Matthew A. Smith
`Jennifer Seraphine
`Jacob Zweig
`TURNER BOYD LLP
`smith@turnerboyd.com
`seraphine@turnerboyd.com
`zweig@turnerboyd.com
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`Robert Hails
`T. Cy Walker
`BAKER & HOSTETLER LLP
`rhails@bakerlaw.com
`cwalker@bakerlaw.com
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`Attorneys for Petitioner Sony
`Corporation
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`Date: September 8, 2016
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`
`
`
`Heath J. Briggs
`Patrick J. McCarthy
`GREENBERG TRAURIG, LLP
`briggs@gtlaw.com
`mccarthy@gtlaw.com
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`Attorneys for Petitioner Samsung
`Electronics, Co. Ltd., Samsung
`Electronics America, Inc. and Samsung
`Semiconductor, Inc.
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`By:
`
`/Thomas J. Filarski/
`Thomas J. Filarski
`Reg. No. 31,612
`Steptoe & Johnson LLP
`115 S. LaSalle Street, Suite 3100
`Chicago, IL 60603
`
`Telephone: (312) 577-1252
`
`Counsel for Raytheon Company
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`
`
`
`
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