`IPR2016-01639
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________
`
`
`Sony Corporation,
`Petitioner,
`
`v.
`
`One-E-Way, Inc.
`Patent Owner.
`
`_________________________
`
`Case No. IPR2016-01639
`U.S. Patent No. 9,282,396
`_________________________
`
`
`
`
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`-i-
`
`
`
`Patent No. 9,282,396
`IPR2016-01639
`Pursuant to 37 C.F.R. § 42.70(a) and the Scheduling Order (Paper 9),
`
`
`
`Petitioner submits this Request for Oral Argument on all of the instituted grounds
`
`of unpatentability of U.S. Patent No. 9,282,396. Requests for Oral Argument in the
`
`related IPR proceeding IPR2016-01638 is being filed simultaneously.
`
`
`
`Petitioner respectfully requests that the Board allocate sixty minutes for
`
`Petitioner and sixty minutes for Patent Owner (i.e., two hours total) to present oral
`
`arguments in a consolidated hearing for IPR2016-01638 and IPR2016-01639. With
`
`regard to this particular proceeding, Petitioner requests (without waiving
`
`consideration of any issue not listed below) to address the following issues:
`
`1. Whether claims 1–17 of the ’396 patent are unpatentable under 35 U.S.C. §
`
`102 as anticipated by U.S. Patent No. 6,563,892 and documents incorporated
`
`by reference therein;
`
`2. Whether claims 1–17 of the ’396 patent are unpatentable under 35 U.S.C. §
`
`103 as obvious over U.S. Patent No. 6,563,892 (including documents
`
`incorporated by reference therein) and a paper by G.B. Giannakis et al.,
`
`Load-Adaptive MUI/ISI-Resilient Generalized Multi-Carrier CDMA with
`
`Linear and DF Receivers, Vol. 11, No. 6, EUROPEAN TRANSACTIONS
`
`ON TELECOMMUNICATIONS 527–37 (2000);
`
`1
`
`
`
`Patent No. 9,282,396
`IPR2016-01639
`3. Any additional issues on which the Board seeks clarification. The Board has
`
`already scheduled Oral Hearing for November 6, 2017. See Scheduling
`
`Order of February 22, 2017, Paper No. 9.
`
`
`
`Petitioner also requests that the Board provide audio-visual equipment to
`
`display a demonstrative PowerPoint presentation. The requested equipment
`
`includes a projector to be connected to Petitioner’s laptop computer, and a screen
`
`for displaying the projected image.
`
`
`
`Dated: September 27, 2017
`
`
`
`Respectfully submitted,
`
`/ John Flock /
`John Flock (Reg. No. 39,670)
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel: 212-425-7200
`Fax: 212-425-5288
`Email: jflock@andrewskurthkenyon.com
`
`Lead Counsel for Petitioner,
`Sony Corporation
`
`2
`
`
`
`CERTIFICATE OF SERVICE
`
`Patent No. 9,282,396
`IPR2016-01639
`
`The undersigned certifies that a true and correct copy of the Petitioner’s
`
`Request for Oral Argument has been served on the Patent Owner’s attorneys of
`
`record via electronic mail on September 27, 2017 at the following addresses:
`
`Daphne Burton (Reg. No. 45,323)
`Burton IP Law Group
`2029 Century Park East
`Suite 400N
`Los Angeles, CA 90067
`Tel: +1.310.867.2754
`Fax: +1.888.972.1879
`dburton@burtoniplaw.com
`
`Thomas D. Robbins (Reg. No. 43,369)
`10351 Southern Maryland Blvd.
`Suite 102, P.O. Box 361
`Dunkirk, MD 20754
`Tel: +1.410.257.1647
`Fax: +1.410.257.1648
`tom@trpatents.com
`
`Douglas G. Muehlhauser (Reg. No. 42,018)
`KNOBBE, MARTENS, OLSON & BEAR, LLP
`2040 Main Street, 14th Floor
`Irvine, CA 92614
`2dgm@knobbe.com
`
`
`Dated: September 27, 2017
`
`
`
`/s/ John Flock
`John Flock (Reg. No. 39,670)
`
`Lead Counsel for Petitioner,
`Sony Corporation
`
`
`
`
`
`
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