`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`MICROSOFT CORPORATION,
`Petitioner
`
`v.
`
`BRADIUM TECHNOLOGIES LLC,
`Patent Owner
`____________________
`
`CASE IPR2016-00449
`Patent 8,924,506 B2
`____________________
`
`PATENT OWNER BRADIUM TECHNOLOGIES LLC’S
`REQUEST FOR ORAL ARGUMENT UNDER 37 C.F.R. § 42.70
`
`
`
`
`
`
`
`
`
`
`
`PATENT OWNER’S REQUEST FOR
`ORAL ARGUMENT UNDER 37 C.F.R. § 42.70
`
`Pursuant to the Board’s Scheduling Order dated July 27, 2016 (Paper 10),
`
`and Petitioner and Patent Owner’s Stipulation to Modify Due Date 4 dated March
`
`15, 2017 (Paper 36), Patent Owner Bradium Technologies LLC (“Bradium”)
`
`respectfully requests oral argument.1 DUE DATE 7 (Oral argument) is currently
`
`scheduled for April 18, 2017.
`
`Pursuant to 37 C.F.R. § 42.70(a), Bradium intends to argue the following
`
`issues:
`
`1. Any issues addressed by Patent Owner in IPR2016-00449, including in
`
`the Patent Owner Response (Paper 16)2 and Patent Owner’s Motion for
`
`Observations. In particular, as to the patentability of claims 1–21 of
`
`Untied States Patent No. 8,924,506, whether claims 1–21 are obvious
`
`under 35 U.S.C. § 103(a) over the combination of Reddy and Hornbacker.
`
`2. Any issues properly raised by Petitioners in IPR2016-00449, including in
`
`the Petition (Paper 1) and Petitioner’s Reply (Paper 31).
`
`3. Rebuttal to issues raised by Petitioner.
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`4. Patent Owner’s motion to exclude.
`
`
`1 On a March 6, 2017 telephone conference that the Board held with the parties,
`Bradium informed the Board that it intended to request oral argument, and
`requested that DUE DATE 4 be moved to March 22, 2017.
`2 The public redacted version of Patent Owner’s Response is Paper No. 17.
`
`
`
`
`
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`5. To the extent necessary, any motion to expunge or strike, or any related
`
`motion, filed by Patent Owner regarding Exhibit 1017 (Yonatan Lavi
`
`Declaration) and Petitioner’s papers and exhibits that rely on Exhibit
`
`1017.
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`6. Any motion to exclude evidence by Petitioner.
`
`Bradium requests 60 minutes per side of oral argument in consolidated
`
`hearing for IPR2016-00448 and IPR2016-00449.3 Bradium also requests the
`
`ability to use audio/visual equipment to display demonstrative exhibits, including
`
`the use of an Elmo/digital projector and screen for projection of electronic and
`
`
`
`paper materials.
`
`
`
`
`3 The Board has also set April 18, 2017 as DUE DATE 7 (Oral argument) in
`IPR2016-00448 for U.S. Patent No.7,908,343. (IPR2016-00448 Paper 10 at 6.) In
`accordance with the Board’s Scheduling Orders, Patent Owner’s request for
`argument time encompasses both inter partes review proceedings for a total of 60
`minutes.
`
`
`
`
`
`
`
`
`
`
`
`
`Dated: March 22, 2017
`
`
`
`
`
`
`
`
`
`
`/Chris J. Coulson/
`Chris J. Coulson (Reg. No. 61,771)
`Lead Counsel for Patent Owner
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel.: (212) 425-7200
`Fax: (212) 425-5288
`chriscoulson@andrewskurthkenyon.com
`
`Michael Zachary (admitted pro hac vice)
`Clifford Ulrich (Reg. No. 42,194)
`Attorneys for Bradium Technologies LLC
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on March 22,
`
`2017, the foregoing Patent Owner’s Request for Oral Argument were served via
`
`electronic mail upon the following counsel of record for the Petitioner:
`
`
`Chun M. Ng (Reg. No. 36,878)
`Matthew Bernstein (pro hac vice)
`Patrick McKeever (Reg. No. 66,019)
`Vinay Sathe (Reg. No. 55,595)
`Evan S. Day (pro hac vice)
`PerkinsServiceBradiumIPR@perkinscoie.com
`
`
`
`
`
`
`
`
`
`
`
`/Chris J. Coulson /
`Chris J. Coulson (Reg. No. 61,771)
`Lead Counsel for Patent Owner
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel.: (212) 425-7200
`Fax: (212) 425-5288
`chriscoulson@andrewskurthkenyon.com
`
`
`
`
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`
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