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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________
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`
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`APPLE INC., HTC CORPORATION, AND HTC AMERICA, INC.,
`Petitioners
`
`v.
`
`PARTHENON UNIFIED MEMORY ARCHITECTURE LLC,
`Patent Owner
`
`___________________
`
`
`
`Case IPR2016-009231
`Patent No. 5,812,789
`
`_____________________
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`PETITIONERS’ REQUEST FOR ORAL HEARING
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`1 Case No. IPR2016-00847 has been joined with this proceeding
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`
`
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`Petitioners’ Request for Oral Hearing
`
`IPR2016-00923
`U.S. Patent No. 5,812,789
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`
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`In accordance with 37 C.F.R. § 42.70(a), Petitioners Apple Inc., HTC
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`Corporation, and HTC America, Inc. hereby request an oral hearing in the present
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`inter partes review. The issues to be argued include:
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`1. Lambrecht anticipates each and every element of claims 1, 3, 5, 11, and
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`13 including:
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`a. a decoder that accesses memory sufficient to maintain real time
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`operation; and
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`b. a “shared bus” having sufficient bandwidth to enable a decoder to
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`access the memory and operate in real time when another device
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`simultaneously accesses the bus.
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`2. Other issues raised in papers filed in the present proceeding, including
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`issues raised in any papers filed between today and the oral hearing.
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`In light of these remarks, Petitioners respectfully request the opportunity to
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`present oral arguments before the Board on May 18, 2017. See Scheduling Order,
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`Paper No. 11 at 3, 6.
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`Petitioners suggest a single consolidated oral argument for IPR2016-00923
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`and IPR2016-00924. These proceedings involve the same counsel, experts, and
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`litigation proceedings. Additionally, because of the similar subject matter, the
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`parties have previously sought to consolidate conducting depositions of each of the
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`
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`1
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`
`
`Petitioners’ Request for Oral Hearing
`
`IPR2016-00923
`U.S. Patent No. 5,812,789
`
`
`party’s respective expert. Petitioners have conferred with Patent Owner’s counsel
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`and Patent Owner’s counsel is not opposed to consolidating the oral arguments.
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`Petitioners therefore propose that each side be allocated a total of one hour to
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`present oral arguments for IPR2016-00923 and IPR2016-00924 in a consolidated
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`proceeding. Petitioners respectfully request the scheduling of a morning session, if
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`available.
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`If the Board has any questions or comments, the undersigned attorney
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`respectfully requests a telephone conference. No fees are believed to be required
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`for filing this request; however, the Commissioner is authorized to charge any
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`required fees, or credit any overpayment, to Haynes and Boone, LLP's Deposit
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`Account No. 08-1394.
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`Dated: April 14, 2017
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`
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`
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`Respectfully submitted,
`
`/Andrew S. Ehmke/
`Andrew S. Ehmke
`Lead Counsel for Petitioners
`Registration No. 50,271
`
`HAYNES AND BOONE, LLP
`Customer No. 27683
`Telephone: 214/651-5116
`Facsimile: 214/200-0853
`
`
`
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`
`
`2
`
`
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`
`
`
`Petitioners’ Request for Oral Hearing
`
`IPR2016-00923
`U.S. Patent No. 5,812,789
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e), that
`
`service was made on Patent Owner as detailed below.
`
`Date of service April 14, 2017
`
`Manner of service Electronic Mail to: manjom@azalaw.com
`aalavi@azalaw.com; sclark@azalaw.com;
`mmcbride@azalaw.com
`
`Documents served Petitioners’ Request for Oral Hearing;
`
`Masood Anjom
`Amir Alavi
`Scott Clark
`Michael McBride
`AHMAD, ZAVITSANOS, ANAIPAKOS, ALAVI &
`MENSING P.C.
`1221 McKinney, Suite 2500
`Houston, TX 77010
`
`Persons served
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`
`
`Respectfully submitted,
`
`/Andrew S. Ehmke/
`Andrew S. Ehmke
`Registration No. 50,271
`
`
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`3
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`
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`
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`Dated: April 14, 2017
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