`
`
`
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`
`
`
`REACTIVE SURFACES LTD. LLP,
`
`Petitioner,
`
`v.
`
`TOYOTA MOTOR CORPORATION,
`
`Patent Owner.
`
`
`
`
`
`
`
`
`
`Case IPR2016-01914
`
`Patent No. 8,394,618 B2
`
`
`
`
`
`
`
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`
`
`IPR2016-01914
`U.S. Patent No. 8,394,618 B2
`Pursuant to 37 C.F.R. § 42.70 and the Board’s March 23, 2017
`
`Scheduling Order (Paper 27),1 Patent Owner Toyota Motor Corporation
`
`respectfully requests oral argument in this inter partes review, currently scheduled
`
`on January 9, 2018. Patent Owner requests oral argument on all issues raised in
`
`the parties’ filings, including:
`
`1. Whether Petitioner has carried its burden to prove that claims 1-11 of
`
`U.S. Patent No. 8,394,618 B2 are unpatentable based on the grounds on which this
`
`inter partes review was instituted;
`
`2.
`
`Any issues specified by Petitioner in its Request for Oral Argument, if
`
`it chooses to file such;
`
`3.
`
`Any other issues raised in papers filed in this proceeding, including
`
`issues raised in papers yet to be filed, such as Motions to Exclude or Motions for
`
`Observations on Cross Examination; and
`
`4.
`
`Any other issues that the Board deems necessary for issuing a final
`
`written decision.
`
`
`
`1 Although the parties have modified DUE DATE 4 pursuant to a joint stipulation,
`
`see Paper 35, the Scheduling Order provides that, notwithstanding any such
`
`stipulation, “any request for oral argument should be filed by original DUE DATE
`
`4 [November 14, 2017] as set forth in the DUE DATE APPENDIX.” Paper 27 at
`
`2, 6.
`
`
`
`1
`
`
`
`IPR2016-01914
`U.S. Patent No. 8,394,618 B2
`Patent Owner requests that each side be allowed 30-45 minutes in which to
`
`present its arguments.
`
`Patent Owner requests that the Board provide audio-visual equipment to
`
`display demonstrative exhibits, including a projector to be connected to a laptop
`
`
`
`
`
`
`
` /s/ Joshua A. Lorentz
`Joshua A. Lorentz
`Reg. No. 52,406
`Dinsmore & Shohl LLP
`255 E. Fifth St., Ste. 1900
`Cincinnati, OH 45202
`T: (513) 977-8200
`E: joshua.lorentz@dinsmore.com
`Attorney for Patent Owner
`Toyota Motor Corporation
`
`and a screen for said projector.
`
`Dated: November 14, 2017
`
`
`
`
`
`
`
`
`
`
`
`
`2
`
`
`
`IPR2016-01914
`U.S. Patent No. 8,394,618 B2
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing PATENT
`
`OWNER’S REQUEST FOR ORAL ARGUMENT was served on November 14,
`
`2017 by email on the following counsel of record for Petitioner:
`
`David O. Simmons (dsimmons@ivcpatentagency.com)
`
`Jonathan D. Hurt (jhurt@technologylitigators.com)
`
`Mark A.J. Fassold (mfassold@wattsguerra.com)
`
`Jorge Mares (jmares@wattsguerra.com)
`
`
`
`Dated: November 14, 2017
`
`
`
`
`
`
`
`
`
`
`
`
` /s/ Joshua A. Lorentz
`Joshua A. Lorentz
`Reg. No. 52,406
`Attorney for Patent Owner
`Toyota Motor Corporation
`
`
`
`
`
`