`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`
`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioner
`
`v.
`
`IMAGE PROCESSING TECHNOLOGIES LLC,
`Patent Owner
`
`____________________
`
`Case No. IPR2017-00353
`U.S. Patent No. 8,983,134
`____________________
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`Case No. IPR2017-00353
`U.S. Patent No. 8,983,134
`Petitioner Samsung Electronics Co., Ltd. and Samsung Electronics America
`
`Inc. (collectively “Petitioner”) respectfully requests oral argument in connection
`
`with IPR2017-00353 for U.S. Patent No. 8,983,134 (“the ’134 Patent”). Pursuant
`
`to 37 C.F.R. § 42.70, Petitioner specifies the following issues to be argued:
`
`• Grounds for which inter partes review was instituted for the ’134
`
`Patent and any issue raised in the Board’s Institution Decision;
`
`• Any issue addressed in Petitioner’s papers, including but not limited
`
`to the Petition and Petitioner’s Reply Brief;
`
`• Rebuttal to Patent Owner’s presentation on all issues, including the
`
`issues identified above and any issues raised in Patent Owner’s
`
`Response and exhibits cited therein.
`
`• Any issues raised by the Board or Patent Owner at oral argument;
`
`• Any other issues raised in papers filed in this proceeding, including
`
`issues raised in papers yet to be filed; and
`
`• Any other issues that the Board deems necessary for issuing a final
`
`written decision.
`
`Pursuant to the Scheduling Order (Paper 13 at 4, 6) the oral hearing for this
`
`case IPR2017-00353 is currently scheduled for February 21, 2018. Petitioner
`
`requests half of the time that the Board determines is appropriate for oral argument
`
`and expressly reserves the right to use a portion of its time for rebuttal. Petitioner
`
`-1-
`
`
`
`Case No. IPR2017-00353
`U.S. Patent No. 8,983,134
`additionally requests that the Board provide audio-visual equipment to display
`
`demonstrative exhibits, including a monitor or projector to be connected to a
`
`laptop, a screen, and an ELMO for displaying documents of record.
`
`
`
`Date: January 24, 2018
`
`
`
`Respectfully submitted,
`
`
`/s/ John Kappos
`
`John Kappos (Reg. No. 37,861)
`Counsel for Petitioner
`
`-2-
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies pursuant to 37 C.F.R. § 42.6(e) and § 42.105 that on
`
`January 24, 2018, a true and correct copy of PETITIONER’S REQUEST FOR
`
`ORAL ARGUMENT was served via express mail on the Patent Owner at the
`
`following correspondence address of record:
`
`Gregory Nelson
`FOX ROTHSCHILD LLP
`222 Lakeview Avenue, Suite 700
`West Palm Beach, FL 33401
`
`Gregory Nelson
`FOX ROTHSCHILD LLP
`997 Lennox Drive, Bld. 3
`Lawrenceville, NJ 08648
`
`
`
`Copies were also sent to Patent Owner’s litigation counsel via electronic mail:
`
`S. Calvin Capshaw
`CAPSHAW DERIEUX, LLP
`114 E. Commerce Ave.
`Gladewater, TX 75647
`ccapshaw@capshawlaw.com
`
`Michael N. Zachary
`ANDREWS KURTH KENYON LLP
`1801 Page Mill Road, Suite 210
`Palo Alto, CA 94304
`MichaelZachary@AndrewsKurthKenyon.com
`Respectfully submitted,
`
`Christopher J. Coulson
`Mark Chapman
`Rose Cordero Prey
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004
`ChrisCoulson@AndrewsKurthKenyon.com
`MarkChapman@AndrewsKurthKenyon.com
`RosePrey@AndrewsKurthKenyon.com
`
`/s/ John Kappos .
`John Kappos (Reg. No. 37,861)
`O’Melveny & Myers LLP
`610 Newport Center Drive, 17th Floor
`Newport Beach, CA 92660
`Telephone: (949) 760-9600
`
`Attorney for Petitioner
`
`-1-
`
`
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