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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________
`
`VALVE CORPORATION
`
`Petitioner,
`
`v.
`
`IRONBURG INVENTIONS LTD.
`
`Patent Owner.
`
`_______________________
`
`IPR2017-00136 (Patent 8,641,525 B2)
`
`IPR2017-00137 (Patent 9,089,770 B2)
`
`_______________________
`
` PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`

`

`IPR2017-00136
`IPR2017-00137
`
`Subject to the Board’s anticipated decision on the pending Motion to
`
`
`
`Terminate (Paper 26) for IPR2017-00136 and IPR2017-00137, and pursuant to the
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`Board’s May 4, 2017 Scheduling Order (Paper 11) and the parties’ August 11,
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`2017 Joint Stipulated Schedule Change (Paper 18), Patent Owner Ironburg
`
`Inventions Ltd. (“Patent Owner”) respectfully requests oral argument, which is
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`currently scheduled for December 4, 2017. Patent Owner requests a combined
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`argument and transcript for IPR2017-00136 and IPR2017-00137 because the oral
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`arguments overlap in substance and are both scheduled for the same day with the
`
`same panel.
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`
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`Without waiving consideration of any issue not identified below, Patent
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`Owner requests a 1PM ET start time and three hours (90 minutes per side) to
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`address the following issues in both IPR2017-00136 and IPR2017-00137:
`
`1. The construction of certain terms of (a) U.S. Pat. No. 8,641,525 (“the ‘525
`
`Patent”), which is the subject of the IPR2017-00136 proceeding, and
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`(b) U.S. Pat. No. 9,089,770 (“the ‘770 Patent”), which is the subject of the
`
`IPR2017-00137 proceeding;
`
`2. For IPR2017-00136, the patentability of challenged claim 20 of the ‘525
`
`Patent over the Wörn reference.
`
`3. For IPR2016-00949, the patentability of the challenged claims 1-4, 12, 15-
`
`18 and 20 of the ‘770 Patent over the Wörn reference.
`
`
`
`1
`
`

`

`IPR2017-00136
`IPR2017-00137
`
`4. Any new issues raised in Petitioner’s Reply that exceed the proper scope of a
`
`reply;
`
`5. Any issues specified by Petitioner in its Request for Oral Argument;
`
`6. Rebuttal to Petitioner’s presentation on all matters;
`
`7. Any other issues raised in papers filed in this proceeding, including issues
`
`raised in papers yet to be filed; and
`
`8. Any other outstanding motions and pleading, and other issues that the Board
`
`deems necessary for issuing a Final Written Decision.
`
`
`
`Patent Owner requests the ability to use audio visual equipment to display
`
`possible demonstratives and exhibits, including the use of a computer, projector,
`
`Elmo, and screen.
`
`Date: October 30, 2017
`
`
`
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`
`
`Respectfully submitted,
`
`By: /s/ Ehab M. Samuel
`Ehab Samuel, Reg. No. 57,905
`Yasser El-Gamal, Reg. No. 45,339
`MANATT, PHELPS & PHILLIPS, LLP
`
`2
`
`

`

`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(b), the undersigned certifies
`
`IPR2017-00136
`IPR2017-00137
`
`
`
`
`that the foregoing PATENT OWNER’S REQUEST FOR ORAL ARGUMENT,
`
`was served electronically via PTAB E2E to Petitioner’s counsel of record at the
`
`following address:
`
`
`
`
`Joshua C. Harrison, Reg. No. 45,686, josh@bhiplaw.com
`Reynaldo C. Barcelo, Reg. No. 42,290, rey@bhiplaw.com
`
`
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`
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`Respectfully submitted,
`
`By: /s/ Ehab M. Samuel
`Ehab Samuel, Reg. No. 57,905
`Yasser El-Gamal, Reg. No. 45,339
`MANATT, PHELPS & PHILLIPS, LLP
`
`Attorneys for Patent Owner
`IRONBURG INVENTIONS LTD.
`
`
`
`Date: October 30, 2017
`
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`318536553.1
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`3
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`

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