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UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`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 IPR2017-00353
`Patent No. 8,983,134
`____________________
`
`PATENT OWNER IMAGE PROCESSING TECHNOLOGIES LLC’S
`REQUEST FOR ORAL ARGUMENT UNDER 37 C.F.R. § 42.70
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`Pursuant to the Scheduling Order (Paper 13) for case no. IPR2017-00353
`
`and the parties’ Joint Stipulation to Modify Schedule (Paper 20), Image
`
`Processing Technologies LLC (“Patent Owner”) respectfully requests oral
`
`argument. DUE DATE 7 (Oral argument) is currently scheduled for February 21,
`
`2018. Petitioner has previously requested oral argument for IPR2017-00336 (’293
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`Patent), for which DUE DATE 7 is also February 21, 2018. (IPR2017-00336,
`
`Paper 25.)
`
`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 raised by Patent Owner in IPR2017-00353, including but
`
`not limited to issues of record in the Patent Owner response (Paper
`
`17) and in cross-examination and redirect of Dr. Alan Bovik (Exhibit
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`1011), including the patentability of claims 1 and 2 of U.S. Patent No.
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`8,983,134 and the construction of the claim language of claim 1
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`“wherein forming the at least one histogram further comprises
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`determining X minima and maxima and Y minima and maxima of
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`boundaries of the target”.
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`2. Rebuttal to issues raised by Petitioner.
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`3. To the extent necessary, any motion to exclude or other motion filed
`
`by Petitioner.
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`
`
`

`

`
`
`Image Processing requests 30 minutes per side for oral argument for
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`IPR2017-00353. Image Processing also requests the ability to use audio/visual
`
`equipment to display demonstrative exhibits, including the use of an Elmo/digital
`
`projector and screen for projection of electronic and paper materials.
`
`
`
`Dated: January 25, 2018
`
`
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`
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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
`
`
`
`
`
`
`

`

`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on January 25,
`
`2018, the foregoing was served via electronic mail upon the following counsel of
`
`record for the Petitioner:
`
`John Kappos (Reg. No. 37,861)
`O’Melveny & Myers LLP
`610 Newport Center Drive, 17th Floor
`Newport Beach, CA 92660
`jkappos@omm.com
`
`Marc J. Pensabene (Reg. No. 37,416)
`O’Melveny & Myers LLP
`Times Square Tower
`7 Times Square
`New York, NY 10036
`mpensabene@omm.com
`
`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
`
`E-Mail: IPTSAMSUNGOMM@OMM.COM
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`
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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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