`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________
`
`
`HTC CORPORATION, HTC AMERICA, INC., AND APPLE INC.,
`Petitioners
`
`v.
`
`PARTHENON UNIFIED MEMORY ARCHITECTURE LLC,
`Patent Owner
`
`___________________
`
`
`Case IPR2016-011351
`Patent No. 5,812,789
`
`_____________________
`
`
`
`PETITIONERS’ REQUEST FOR ORAL HEARING
`
`
`
`
`
`
`
`
`
`1 Case No. IPR2017-00512 has been joined with this proceeding
`
`
`
`
`Petitioners’ Request for Oral Hearing
`
`IPR2016-01135
`U.S. Patent No. 5,812,789
`
`
`
`In accordance with 37 C.F.R. § 42.70(a), Petitioners HTC Corporation, HTC
`
`America, Inc., and Apple Inc. hereby request an oral hearing in the present inter
`
`partes review. The issues to be argued include:
`
`1. The combination of Bowes, TMS and Thomas renders obvious each and
`
`every element of claims 1-5 and 12-14 including a “shared bus” having
`
`sufficient bandwidth to enable a decoder to access the memory and
`
`operate in real time when another device simultaneously accesses the
`
`bus;
`
`2. The combination of Bowes, TMS, Thomas, and Gove renders obvious
`
`each and every element of claims 6 and 8;
`
`3. The combination of Bowes, TMS, Thomas, and Ran renders obvious
`
`each and every element of claim 7;
`
`4. The combination of Bowes, TMS, Thomas, and Celi renders obvious
`
`each and every element of claim 11; and
`
`5. Other issues raised in papers filed in the present proceeding, including
`
`issues raised in any papers filed between today and the oral hearing.
`
`In light of these remarks, Petitioners respectfully request the opportunity to
`
`present oral arguments before the Board on September 5, 2017. See Order, Paper
`
`No. 14 at 3; see also Scheduling Order, Paper No. 8 at 5, 8.
`
`
`
`1
`
`
`
`
`
`
`Petitioners’ Request for Oral Hearing
`
`IPR2016-01135
`U.S. Patent No. 5,812,789
`
`
`
`Petitioners request that the oral hearings for IPR2016-01114, IPR2016-
`
`01121, and IPR2016-01135 be conducted seriatim. Petitioners also request that
`
`each side be allocated a total of 20 minutes to present oral arguments for each of
`
`IPR2016-01121 and IPR2016-01135 and 30 minutes to present oral arguments for
`
`IPR2016-01114. Petitioners have conferred with Patent Owner’s counsel regarding
`
`the duration for each proceeding and have not come to an agreement.
`
`If the Board has any questions or comments, the undersigned attorney
`
`respectfully requests a telephone conference. No fees are believed to be required
`
`for filing this request; however, the Commissioner is authorized to charge any
`
`required fees, or credit any overpayment, to Haynes and Boone, LLP's Deposit
`
`Account No. 08-1394.
`
`Dated: July 31, 2017
`
`
`
`
`
`
`
`
`
`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
`
`
`
`
`
`
`
`2
`
`
`
`
`
`
`Petitioners’ Request for Oral Hearing
`
`IPR2016-01135
`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 July 31, 2017
`
`Manner of service Electronic Mail to: manjom@azalaw.com
`aalavi@azalaw.com; sclark@azalaw.com;
`mmcbride@azalaw.com; jchen@azalaw.com; and
`gonsalves@gonsalveslawfirm.com
`
`Documents served Petitioners’ Request for Oral Hearing
`
`Masood Anjom
`Amir Alavi
`Scott Clark
`Michael McBride
`Justin Chen
`Gregory J. Gonsalves
`AHMAD, ZAVITSANOS, ANAIPAKOS, ALAVI &
`MENSING P.C.
`1221 McKinney, Suite 2500
`Houston, TX 77010
`
`Persons served
`
`
`
`
`
`
`Dated: July 31, 2017
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/Andrew S. Ehmke/
`Andrew S. Ehmke
`Registration No. 50,271
`
`
`
`3
`
`
`
`