`________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
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`UNIFIED PATENTS INC.
`Petitioner,
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`v.
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`VILOX TECHNOLOGIES LLC
`Patent Owner
`________________
`
`IPR2018-00044
`Patent 7,302,423
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`________________
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`Petitioner’s Request for Oral Argument
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`In accordance with 37 C.F.R. § 42.70(a), Petitioner hereby requests oral
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`IPR2018-00044
` Patent 7,302,423
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`
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`argument in the present inter partes review to be held on December 11, 2018 as set
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`forth in the Scheduling Order. Paper 10 at 4, 6.
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`I. Issues to be Presented During Oral Argument
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`Petitioner requests the opportunity to present oral argument on all issues
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`raised in the papers pertaining to the instituted grounds, including:
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`• how the combination of Maloney and Bertram renders obvious claims 1–
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`4, 7–9, and 13 of the ’423 Patent;
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`• how the combination of Excel and Bertram renders obvious claims 1–4,
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`7–9, and 13 of the ’423 Patent;
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`• how the combination of Maloney, Bertram, and Kanevsky renders
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`obvious claims 5 and 6;
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`• how the combination of Excel, Bertram, and Kanevsky renders obvious
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`claims 5 and 6;
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`• how the proposed claims 24–27 lack written description support in the
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`disclosure of the ’423 Patent;
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`• how the combination of Maloney and Bertram renders obvious proposed
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`claims 24 and 25;
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`• how the combination of Excel and Bertram renders obvious proposed
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`claims 24 and 25;
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`1
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`Petitioner’s Request for Oral Argument
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`• how the combination of Maloney, Bertram, and Kanevsky renders
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`IPR2018-00044
` Patent 7,302,423
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`obvious proposed claims 26 and 27;
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`• how the combination of Excel, Bertram, and Kanevsky renders obvious
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`proposed claims 26 and 27;
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`• how the combination of Maloney, Bertram, and Goldberg renders
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`obvious proposed claims 26 and 27;
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`• how the combination of Excel, Bertram, and Goldberg renders obvious
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`proposed claims 26 and 27;
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`• how Excel and Goldberg are prior art to the ’423 patent;
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`• motions to exclude (if any); and
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`• any responses to issues raised by the Board at the argument.
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`Dated: November 2, 2018
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`Respectfully submitted,
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`By: /David M. O’Dell/
`
`David M. O’Dell
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`Registration No. 42,044
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`Lead Counsel for Petitioner
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`2
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`Petitioner’s Request for Oral Argument
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`IPR2018-00044
` Patent 7,302,423
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.6, this is to certify that a true and correct copy
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`of the foregoing “Petitioner’s Request for Oral Argument” service was made on
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`the Patent Owner as detailed below:
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`Date of service November 2, 2018
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`Manner of service Email: harrop@vapatent.com
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`Documents served Petitioner’s Request for Oral Argument
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`Persons Served John K. Harrop
`Cecil E. Key
`Jay Kesan
`P.O. Box 320171
`Alexandria, VA 22320
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`440 Belmont Bay Drive, Unit 202
`Woodbridge, VA 22191
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`By: /David M. O’Dell/
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`David M. O’Dell
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`Registration No. 42,044
`Lead Counsel for Petitioner
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`3
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