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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`CISCO SYSTEMS, INC.,
`Petitioner
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`v.
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`TQ DELTA, LLC,
`Patent Owner
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`_____________________
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`Case IPR2016-01760
`Patent 9,094,268
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`PETITIONER’S REQUEST FOR ORAL HEARING
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`Petitioner’s Request for Oral Hearing
`IPR2016-01760
`In accordance with 37 C.F.R. § 42.70(a), Petitioner hereby requests an oral
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`hearing in the present inter partes review. Per the Board’s Scheduling Order, the
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`oral hearing is scheduled for November 8, 2017. See Order, Paper 10, at 8.
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`1. Request to Consolidate Cases for Oral Hearing
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`The schedule in this case is aligned with the schedule of IPR2016-01466
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`such that the oral hearing in both cases is set for the same date. See Order, Paper
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`10, at 8; IPR2016-01466, Order, Paper 8, at 8. Because of overlapping subject
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`matter and issues in both cases, and to expedite the proceedings, Petitioner
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`respectfully requests a single consolidated oral hearing, with each side having 30
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`minutes to present.
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`2. Issues to be Presented During Oral Hearing
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`During the oral hearing, Petitioner requests the opportunity to present oral
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`argument on all of the issues raised in the papers pertaining to the instituted
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`grounds, including:
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` The combination of Bowie and Yamano rendering obvious the limitation “a
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`transmitter portion of the transceiver does not transmit data… and a
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`receiver portion of the transceiver receives data ….”;
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` The combination of Bowie and Yamano rendering obvious the limitation
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`“maintaining synchronization with a second transceiver during the low
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`power mode”;
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`Petitioner’s Request for Oral Hearing
`IPR2016-01760
` Bowie disclosing the limitation “storing, during the low power mode, at
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`least one parameter associated with a full power mode”; and
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` Combining the teachings of Bowie and Yamano would have been obvious to
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`a POSITA.
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`3. Conclusion
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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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`October 2, 2017
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`Respectfully submitted,
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`/David L. McCombs/
`David L. McCombs
`Counsel for Petitioner
`Registration No. 32,271
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`3
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`CERTIFICATE OF SERVICE
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`The undersigned certifies, in accordance with 37 C.F.R. § 42.205, that
`service was made on the Patent Owner as detailed below.
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`Date of service
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`October 2, 2017
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`Manner of service
`Email: pmcandrews@mcandrews-ip.com;
`twimbiscus@mcandrews-ip.com; smcbride@mcandrews-ip.com;
`cscharff@mcandrews-ip.com; rchiplunkar@mcandrews-ip.com;
`dpetty@mcandrews-ip.com; TQD-CISCO@mcandrews-ip.com
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`Documents served
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`Persons served
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`Petitioner’s Request for Oral Hearing
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`Peter J. McAndrews
`Thomas J. Wimbiscus
`Scott P. McBride
`Christopher M. Scharff
`Rajendra A. Chiplunkar
`David Z. Petty
`MCANDREWS, HELD & MALLOY, LTD
`500 West Madison Street, 34th Floor
`Chicago, IL 60661
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`/David L. McCombs/
`David L. McCombs
`Counsel for Petitioner
`Registration No. 32,271
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`4
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