`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`APPLE, INC.
`Petitioner
`
`v.
`
`CHESTNUT HILL SOUND INC.
`Patent Owner
`
`
`
`Case IPR2016-00794
`Patent 8,090,309
`
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`
`
`
`Patent Owner, Chestnut Hill Sound Inc., by and through its attorneys,
`
`respectfully requests oral argument, currently scheduled for April 20, 2017. Patent
`
`Owner requests that each party be granted one (1) hour of oral argument time to
`
`present its arguments. Patent Owner respectfully requests that it be permitted to
`
`reserve up to fifteen (15) minutes of its’ oral argument time for after Petitioner’s
`
`reply to highlight issues in petitioner’s reply that exceed the proper scope of a
`
`reply.
`
`Pursuant to 37 C.F.R. § 42.70, and without intending to waive any issue not
`
`specifically identified, Patent Owner specifies the following issues to be argued:
`
`1.
`
`Petitioner failed to meet its burden of proving that claims 1-14 are
`
`obvious under any of Grounds 1-2 in the Petition;
`
`2.
`
`Petitioner’s Reply (Paper 20) raises issues that go beyond the scope of
`
`a proper reply;
`
`3.
`
`4.
`
`Any issues identified in Petitioner’s Request for Oral Argument;
`
`Any other issues raised in papers filed in this proceeding, including
`
`issues raised in papers yet to be filed, such as Motions to Exclude; and
`
`5.
`
`Any other issues the Board deems necessary for issuing a final written
`
`decision.
`
`Patent Owner requests that the Board provide audio-visual equipment to
`
`display demonstrative exhibits, including a projector to be connected to a laptop
`1
`
`
`
`
`
`
`
`and a screen for displaying documents.
`
`
`
`
`
`Dated: March 13, 2017
`
`
`
`
`
`
`
`Respectfully submitted,
`
`Chestnut Hill Sound Inc.
`
`
`
`By /Hamad M. Hamad/
`Hamad M. Hamad, Reg. No. 64,641
`John Austin Curry (pro hac pending)
`Alexis (Steinberg) Mosser, Reg. No. 74,650
`CALDWELL CASSADY CURRY, P.C.
`2101 Cedar Springs Road, Suite 1000
`Dallas, Texas 75201
`Telephone: 214.888.4848
`Facsimile: 214.888.4849
`hhamad@caldwellcc.com
`acurry@caldwellcc.com
`amosser@caldwellcc.com
`chillsound@caldwellcc.com
`ccc-ptab@caldwellcc.com
`
`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
`
`It is hereby certified that on this 13th day of March, 2017, a copy of the
`
`foregoing document was served via electronic mail, as previously consented to by
`
`Petitioner upon the following counsel of record:
`
`
`
`
`
`
`
`
`W. Karl Renner, IPR39521-0016IP2@fr.com
`Joshua A. Griswold, PTABInbound@fr.com
`Katherine A. Vidal, PTABInbound@fr.com
`Dan Smith, PTABInbound@fr.com
`
`
`
`
`Date: March 13, 2017
`
`
`
`
`
`
`
`
` /Hamad M. Hamad/
`
`Hamad M. Hamad, Reg. No. 64,641
`
`
`
`2
`
`