`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`KAWASAKI RAIL CAR, INC.
`Petitioner,
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`v.
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`SCOTT BLAIR,
`Patent Owner.
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`Case No. IPR2017-01036
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`Patent No. 6,700,602
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`Issue Date: March 2, 2004
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`Title: Subway TV Media System
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`Pursuant to 37 C.F.R. § 42.70(a) and the Scheduling Order (Paper No. 11),
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`Petitioner, Kawasaki Rail Car Inc., respectfully requests oral argument, currently
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`scheduled for June 5, 2018. See Scheduling Order of September 12, 2017, Paper
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`No. 11.
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`Petitioner requests that it be permitted to address the following issues at the
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`hearing (without waiving consideration of any issue not listed below):
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`1.
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`The unpatentability of claims 5, 7-9 and 11-29 of U.S. Patent No.
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`6,700,602 as obvious under 35 U.S.C. § 103 in view of Namikawa,
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`Sasao, Amano, Maekawa, Yamada, Sedighzadeh and Schwenkler;
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`2.
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`The arguments and evidence in Petitioner’s Petition, Petitioner’s Reply,
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`and the supporting declarations of Petitioner’s expert, Lowell Malo,
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`including Petitioner’s responses to Patent Owner’s arguments and
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`evidence in the Patent Owner Response and the supporting declarations
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`of Patent Owner’s expert, Joseph Zicherman.
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`3.
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`Patent Owner’s motion to exclude evidence and Petitioner’s opposition
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`and supplemental evidence in response to Patent Owner’s motion (if
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`Patent Owner files a motion to exclude);
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`4.
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`Patent Owner’s observations on the April 24, 2018 deposition of Lowell
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`Malo and Petitioner’s response to those observations (if Patent Owner
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`files observations);
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`- 1 -
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`5.
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`6.
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`Petitioner’s rebuttal to Patent Owner’s presentation on all matters; and
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`Any additional issues on which the Board seeks clarification.
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`Petitioner requests no more than one hour per side of oral argument time.
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`Petitioner also respectfully requests the ability to use audio visual equipment
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`to display demonstrative exhibits, including the use of a projector and screen that
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`may be connected to a laptop computer of Petitioner’s counsel. The laptop
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`computer will have a VGA-type connector. In addition, Petitioner requests that an
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`ELMO-type projector be made available for use.
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`- 2 -
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`Dated: April 30, 2018
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`Respectfully submitted,
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`/s/ Mark A. Chapman
`Sheila Mortazavi (Reg. No. 43,343)
` Lead Counsel
`Mark A. Chapman (admitted pro hac vice)
` Backup Counsel
`Zaed M. Billah (Reg. No. 71,418)
` Backup Counsel
`Armin Ghiam (Reg. No. 72,717)
` Backup Counsel
`HUNTON ANDREWS KURTH LLP
`One Broadway
`New York, NY 10004
`Telephone: (212) 425-7200
`Fax: (212) 425-5288
`Email:
`SMortazavi@HuntonAK.com
`MChapman@HuntonAK.com
`ZBillah@HuntonAK.com
`AGhiam@HuntonAK.com
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that on April 30, 2018, a complete and entire copy
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`of this PETITIONER’S REQUEST FOR ORAL ARGUMENT was served via
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`e-mail on the following:
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`Jennifer Meredith
`jmeredith@meredithkeyhani.com
`205 Main Street
`East Aurora, New York 14052
`Tel: (212) 760-0098
`Fax: (212) 202-3819
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`Respectfully submitted,
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`/s/ Armin Ghiam
`Armin Ghiam
`HUNTON ANDREWS KURTH LLP
`One Broadway
`New York, NY 10004
`Telephone: (212) 425-7200
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`- 4 -
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