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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioner
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`v.
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`IMAGE PROCESSING TECHNOLOGIES LLC,
`Patent Owner
`____________________
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`CASE IPR2017-00336
`Patent No. 6,959,293
`____________________
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`PATENT OWNER IMAGE PROCESSING TECHNOLOGIES LLC’S
`REQUEST FOR ORAL ARGUMENT UNDER 37 C.F.R. § 42.70
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`NY01:4398129.1
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`Pursuant to the Scheduling Order (Paper 16 at pages 4, 6) for case no.
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`IPR2017-00336, Image Processing Technologies LLC (“Patent Owner”)
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`respectfully requests oral argument. DUE DATE 7 (Oral argument) is currently
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`scheduled for February 21, 2018.
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`Petitioner notes that DUE DATE 7 (Oral argument) is also scheduled for
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`February 21, 2018, in IPR2017-00353, for which, pursuant to the parties’
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`stipulation (IPR2017-00353 Paper 20), oral argument requests are due on January
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`25, 2018.
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`Pursuant to 37 C.F.R § 42.70(a), Image Processing intends to argue the
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`following issues:
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`1. Any issues addressed by Patent Owner in IPR2017-00336, including
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`in the Patent Owner response (Paper 21), in particular the patentability
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`of claim 22 of U.S. Patent No. 6,959,293 in view of the Pirim
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`(WO99/36893) reference that was previously considered by the
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`examiner during prosecution of the ’293 patent, and the construction
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`the claim language “an input multiplexer adapted to receive data
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`describing one or more parameters of the event being detected, and to
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`output data describing a selected one of the one or more parameters in
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`response to a selection signal”.
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`2. Any issues properly raised by Petitioner in IPR2017-00336.
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`NY01:4398129.1
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`3. Rebuttal to issues raised by Petitioner.
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`4. To the extent necessary, any motion to exclude or other motion filed
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`by Petitioner.
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`Image Processing requests 30 minutes per side for oral argument for
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`IPR2017-00336. Image Processing also requests the ability to use audio/visual
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`equipment to display demonstrative exhibits, including the use of an Elmo/digital
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`projector and screen for projection of electronic and paper materials.
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`
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`Dated: January 16, 2018
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`/s/ Chris J. Coulson
`Chris J. Coulson (Reg. No. 61,771)
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel.: (212) 425-7200
`Fax: (212) 425-5288
`Attorney for Patent Owner
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`NY01:4398129.1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on January 16,
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`2018, the foregoing was served via electronic mail upon the following counsel of
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`record for the Petitioner:
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`John Kappos (Reg. No. 37,861)
`O’Melveny & Myers LLP
`610 Newport Center Drive, 17th Floor
`Newport Beach, CA 92660
`jkappos@omm.com
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`Marc J. Pensabene (Reg. No. 37,416)
`O’Melveny & Myers LLP
`Times Square Tower
`7 Times Square
`New York, NY 10036
`mpensabene@omm.com
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`Nicholas J. Whilt (Reg. No. 72,081)
`Brian M. Cook (Reg. No. 59,356)
`Clarence Rowland (Reg. No. 73,775)
`O’Melveny & Myers LLP
`400 South Hope Street, 18th Floor
`Los Angeles, CA 90071
`nwhilt@omm.com
`bcook@omm.com
`crowland@omm.com
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`E-Mail: IPTSAMSUNGOMM@OMM.COM
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`/s/ Chris J. Coulson
`Chris J. Coulson
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel.: (212) 425-7200
`Fax: (212) 425-5288
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`NY01:4398129.1
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