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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS
`AMERICA, INC., and APPLE INC.,
`Petitioners,
`
`v.
`
`ROSETTA-WIRELESS CORPORATION,
`Patent Owner.
`
`1
`Case IPR2016-00622
`Patent No. 7,149,511 B1
`
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`
`Before the Honorable JUSTIN T. ARBES, PATRICK R. SCANLON, and JOHN A.
`HUDALLA, Administrative Patent Judges.
`
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`PURSUANT TO 37 C.F.R. §42.70(a)
`
`                                                            
`1 Case IPR2016-00616 has been consolidated with this proceeding.
`
`

`

`Pursuant to 37 C.F.R. § 42.70(a), the Scheduling Order entered August 22,
`
`2016 (Paper 13), the Decision instituting this proceeding and consolidating
`
`IPR2016-006162 with it (Paper 15), and the Order modifying due dates entered
`
`January 24, 2017 (Paper 31), Patent Owner Rosetta-Wireless Corporation (“Patent
`
`Owner”) respectfully requests oral argument on all the instituted grounds of
`
`alleged unpatentability in IPR2016-00616 and IPR2016-0622, as listed below:
`
`References
`
`21 and 70
`22 and 71
`1–10, 19, 58–65, and 68
`2 and 59
`8 and 9
`20 and 69
`
`Basis
`Challenged Claim(s)
`1–6, 8–10, 58–63, and 65 35 U.S.C. § 103(a) Kimura
`1–10, 19, 58–65, and 68
`35 U.S.C. § 103(a) Goggin
`2 and 59
`35 U.S.C. § 103(a) Goggin, Bodnar
`8 and 9
`35 U.S.C. § 103(a) Goggn, Jornada
`20 and 69
`35 U.S.C. § 103(a) Goggin, DeLorme Receiver,
`DeLorme Accessories
`35 U.S.C. § 103(a) Goggin, Ogasawara
`35 U.S.C. § 103(a) Goggin, CapShare
`35 U.S.C. § 103(a) Goggin, Proxim
`35 U.S.C. § 103(a) Goggin, Proxim, Bodnar
`35 U.S.C. § 103(a) Goggin, Proxim, Jornada
`35 U.S.C. § 103(a) Goggin, Proxim, DeLorme
`Receiver, DeLorme Accessories 
`35 U.S.C. § 103(a) Goggin, Proxim, Ogasawara
`35 U.S.C. § 103(a) Goggin, Proxim, CapShare
`
`21 and 70
`22 and 71
`
`The Board has scheduled DUE DATE 7, the date of the Oral Hearing if
`
`requested, to be June 1, 2017 (Paper 31 at 3). Patent Owner respectfully requests a
`
`two-hour hearing, with 60 minutes of argument time allotted to Patent Owner
`
`individually and 60 minutes of argument time allotted to Petitioners collectively in
`
`                                                            
`2 The Decision in IPR2016-00616 is contained in Paper 11 of that proceeding.
`
`

`

`connection with the foregoing issues and proceedings. The parties have conferred
`
`and Petitioners agree to the amount and division of time for the hearing. Patent
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`Owner further respectfully requests that the Board provide audio/visual equipment
`
`to display demonstrative exhibits and evidence of record, including a projector and
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`screen for displaying documents.
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`Respectfully submitted,
`
`By: /s/Miranda Y. Jones
`Miranda Y. Jones (Reg. No. 64.721)
`Michael Ng (pro hac vice)
`Daniel A. Zaheer (pro hac vice)
`Attorneys for Patent Owner
`Rosetta-Wireless Corp.
`
`
`
`
`Dated: April 19, 2017
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`

`

`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that pursuant to 37 C.F.R. § 42.6(e), a copy of the
`
`foregoing PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`PURSUANT TO 37 C.F.R. §42.70(A) was served via email to lead and backup
`
`counsel of record for Petitioners as follows:
`
`Megan Raymond
`Steven Baughman
`Paul, Weiss, Rifkind, Wharton & Garrison LLP
`mraymond@paulweiss.com
`sbaughman@paulweiss.com
`
`
`Brian E. Ferguson
`Anish R. Desai
`Megan H. Wantland
`Weil, Gotshal & Manges LLP
`Brian.Ferguson@weil.com
`Anish.Desai@weil.com
`Megan.Wantland@weil.com
`
`Richard T. McCaulley
`Andrew J. Sutton
`Ropes & Gray LLP
`Richard.McCaulley@ropesgray.com
`Andrew.Sutton@ropesgray.com
`
`By:
`
`
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`
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`Dated: April 19, 2017
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`
`/Miranda Jones
`Miranda Y. Jones (Reg. No. 64,721)
`Attorney for Patent Owner
`Rosetta-Wireless Corp.
`
`

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