`
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________
`
`SAMSUNG ELECTRONICS AMERICA, INC. and
`SAMSUNG ELECTRONICS CO. LTD.
`Petitioners,
`
`v.
`
`FASTVDO LLC
`Patent Owner.
`
`_________________
`
`U.S. Patent No. 5,850,482
`Case IPR2016-01179
`
`_________________
`
`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`
`
`IPR2016-01179
`U.S. Patent No. 5,850,482
`
`
`Pursuant to the Board’s Scheduling Order dated December 16, 2016 (Paper
`
`16), Petitioners Samsung Electronics America, Inc. and Samsung Electronics Co.
`
`Ltd. (collectively, “Petitioners”), respectfully request oral argument. Per an email
`
`dated June 26, 2017 from the Supervisory Paralegal, such oral argument is
`
`presently scheduled for August 24, 2017.
`
`Pursuant to 37 C.F.R. § 42.70(a), Petitioners intend to argue the invalidity of
`
`the challenged claims based on the instituted grounds for trial including:
`
`
`
`
`
`Claims 1-3, 5, 12-14, 16 and 28 are an obvious combination of Kato’s
`
`embodiments (35 U.S.C. § 103); and
`
`Claims 6 and 17 are obvious over Kato in view of Wei (id.).
`
`Petitioners are also prepared to argue, as needed, their contention that the
`
`challenged claims are obvious based on the grounds stated above under any of the
`
`claim constructions relevant to the instituted grounds for trial, including, but not
`
`limited to: “code word,” “first portion of each code word,” and “second portion of
`
`each code word,” as set forth in:
`
`
`
`
`
`
`
`Petitioners’ Petition and Reply (Paper 3 at, e.g., pgs. 18-21, and Paper
`
`24 at, e.g., pgs. 16-17, respectively);
`
`the institution Decision (Paper 15 at, e.g., pgs. 8-11); and
`
`FastVDO’s Response (Paper 22 at, e.g., pgs. 12-16);
`
`1
`
`
`
`IPR2016-01179
`U.S. Patent No. 5,850,482
`
`
`as well as the construction of FastVDO’s proposed additional term, “storage
`
`medium,” as addressed in:
`
`
`
`
`
`FastVDO’s Response (Paper 22 at, e.g., pgs. 12-16), and
`
`Petitioners’ Reply (Paper 24 at, e.g., pgs. 16-22).
`
`Finally, Petitioners also intend to argue any motions (if any) pending at the
`
`time of the hearing.
`
`Petitioner requests the ability to use audio/visual equipment to display
`
`demonstrative exhibits, including the use of a projector and screen for a
`
`PowerPoint display.
`
`July 12, 2017
`
`
`
`
`
`Respectfully submitted,
`
`By
`/Derrick W. Toddy/
`Derrick W. Toddy, Reg. No. 74,591
`Garth A. Winn, Reg. No. 33,220
`Todd M. Siegel, Reg. No. 73,232
`Klarquist Sparkman, LLP
`One World Trade Center, Suite 1600
`121 S.W. Salmon Street
`Portland, Oregon 97204
`Telephone: (503) 595-5300
`Facsimile: (503) 595-5301
`derrick.toddy@klarquist.com
`garth.winn@klarquist.com
`todd.siegel@klarquist.com
`Lead Counsel for Petitioners
`
`2
`
`
`
`IPR2016-01179
`U.S. Patent No. 5,850,482
`
`
`Certificate Of Service In Compliance With 37 C.F.R. § 42.6(e)(4)
`
`The undersigned certifies that a complete copy of PETITIONERS’
`
`REQUEST FOR ORAL ARGUMENT was served on the correspondence email
`
`addresses of record for lead and backup counsel for Patent Owner:
`
`Wayne M. Helge
`whelge@dbjg.com
`Walter D. Davis
`wdavis@dbjg.com
`Davidson, Berquist, Jackson & Gowdey, LLP
`8300 Greensboro Drive, Suite 500
`McLean, VA 22102
`
`via email, on July 12, 2017.
`
`A courtesy copy of this Request was also served upon the following
`
`litigation counsel for Patent Owner via email:
`
`Marc A. Fenster
`mfenster@raklaw.com
`Jeffrey Z.Y. Liao
`jliao@raklaw.com
`Reza Mirzaie
`rmirzaie@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, California 90025
`
`By /Derrick W. Toddy/
`Derrick W. Toddy, Reg. No. 74,591
`Lead Counsel for Petitioners
`
`
`
`1
`
`
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