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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`
`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
`
`
`
`
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`
`
`

`

`
`
`Pursuant to 37 C.F.R. § 42.70, Petitioner hereby respectfully request oral
`
`argument in the present inter partes review proceedings. As set forth in its
`
`Scheduling Order, the Board in these proceedings has currently scheduled the oral
`
`hearing for January 9, 2018. Petitioner specifies that the issues to which its
`
`arguments can be made include:
`
`• Unpatentability of Claims 1-11 under 35 U.S.C. § 103 on the basis of
`
`Van Antwerp (Ex. 1006);
`
`• Unpatentability of Claims 1-11 under 35 U.S.C. § 103 on the basis of
`
`Schneider (Ex. 1004);
`
`• Unpatentability of Claims 1-11 under 35 U.S.C. § 103 on the basis of
`
`Drevon (Ex. 1003);
`
`• Construction and broadest reasonable interpretation to be given to
`
`disputed claim terms;
`
`• Issues raised in Patent Owner’s Response;
`
`• Issues raised in Patent Owner’s Sur-reply;
`
`• Issues specified by Patent Owner in its request for oral argument;
`
`• Rebuttal to Patent Owner’s oral arguments on all matters; and
`
`• Any other issue briefed or presented by the parties throughout these
`
`proceedings.
`
`
`
`
`
`2
`
`

`

`
`
`Petitioner requests 45 minutes of time for Petitioner’s oral argument and
`
`rebuttal in this proceeding. Petitioner proposes that it present its arguments first
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`(estimated 30 minutes of requested 45 minutes), Patent Owner follow with its
`
`arguments, and that Petitioner use its remaining time for rebuttal (balance of
`
`requested 45 minutes). Additionally, Petitioner requests permission to use visual
`
`equipment to display PowerPoint demonstrative slides.
`
`Dated: November 16, 2017
`
`Respectfully submitted,
`
`
`
`
`
`By:
`
`/s/ David O. Simmons
`
`David O. Simmons, Reg. No. 43,124
`Lead Counsel
`
`
`
`
`
`
`
`
`
`
`Email: dsimmons@ivcpatentagency.com
`
`Counsel for Petitioner, Reactive
`Surfaces Ltd., LLP
`
`
`
`3
`
`

`

`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 CFR §§ 42.6(e)(4)(i) and 42.105(b), the undersigned hereby
`
`certifies that a copy of this PETITIONER’S REQUEST FOR ORAL
`
`ARGUMENT for inter partes review of U.S. Patent No. 8,394,618 B2 was served
`
`on November 16, 2017 by email on the following counsel of record for Patent
`
`Owner:
`
`
`
`Joshua A. Lorenz (joshua.lorentz@dinsmore.com)
`
`Richard H. Schabowsky (richard.schabowsky@dinsmore.com)
`
`John D. Luken (john.luken@dinsmore.com)
`
`Oleg Khariton (oleg.khariton@dinsmore.com)
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ David O. Simmons
`
`David O. Simmons, Reg. No. 43,124
`Lead Counsel
`
`Email: dsimmons@ivcpatentagency.com
`
`Counsel for Petitioner, Reactive
`Surfaces Ltd., LLP
`
`
`
`4
`
`

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