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Case IPR2018-00044
`Patent No. 7,302,423
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
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`BEFORE THE PATENT AND TRIAL AND APPEAL BOARD
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`UNIFIED PATENTS, INC.
`Petitioner
`
`v.
`
`VILOX TECHNOLOGIES, LLC.
`Patent Owner
`
`
`
`Case IPR2018-00044
`Patent No. 7,302,423
`
`
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT PURSUANT TO
`37 C.F.R. § 42.70(a)
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`
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`

`

`Case IPR2018-00044
`Patent No. 7,302,423
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`
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`Patent Owner, Vilox Technologies, LLC, by and through its attorneys,
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`respectfully requests oral argument, currently scheduled for December 11, 2018.
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`Patent Owner requests a total of 60 minutes to present its arguments, as well as to
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`reserve a portion of its total time for presenting rebuttal arguments after
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`Petitioner’s presentation.
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`
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`Pursuant to 37 C.F.R § 42.70, and without intending to waive any issue not
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`specifically identified, Patent Owner specifies the following issues to be argued:
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`1. Prior art status of Excel 2000 Bible, Exhibit 1009;
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`2. Prior art status of Goldberg, USP 6,452,597, Exhibit 1014, if not excluded in
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`this IPR;
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`3. Proper claim construction for claim limitations raised in Patent Owner
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`Response and Patent Owner’s Motion to Amend;
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`4. Specification support under 35 U.S.C. § 112 for all claims and all proposed
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`claims in this IPR;
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`5. That claims 1, 2, and 3 are non-obvious under 35 U.S.C. § 103(a) over
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`Maloney, USP 5,701,453, Exhibit 1006 in view of Bertram, USP 7,168,039,
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`Exhibit 1007;
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`6. That claims 1 and 3 are non-obvious under 35 U.S.C. § 103(a) over Excel
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`2000 Bible in view of Bertram;
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`1
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`

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`Case IPR2018-00044
`Patent No. 7,302,423
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`7. That claim 6 is non-obvious under 35 U.S.C. § 103(a) over Maloney in view
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`of Bertram and further in view of Kanevsky, USP 6,300,947, Exhibit 1008;
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`8. That claim 6 is non-obvious under 35 U.S.C. § 103(a) over Excel Bible 2000
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`in view of Bertram and further in view of Kanevsky;
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`9. That proposed claims 24 and 25 are non-obvious under 35 U.S.C. § 103(a)
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`over Maloney in view of Bertram;
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`10. That proposed claims 24 and 25 are non-obvious under 35 U.S.C. § 103(a)
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`over Excel 2000 Bible in view of Bertram;
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`11. That proposed claims 26 and 27 are non-obvious under U.S.C. § 103(a) over
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`Maloney in view of Bertram, Kanevsky, and Goldberg;
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`12. That proposed claims 26 and 27 are non-obvious under U.S.C. § 103(a) over
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`Excel 2000 Bible in view of Bertram, Kanevsky, and Goldberg;
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`13. Real party-in-interest;
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`14. Any issue identified in Petitioner’s Request for Oral Argument;
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`15. Any other issues raised in papers yet to be filed, such as Motions to Exclude;
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`and
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`16. Any other issues the Board deems necessary to consider for issuing a Final
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`Written Decision.
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`2
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`

`

`Case IPR2018-00044
`Patent No. 7,302,423
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`
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`Patent Owner requests that the Board provide audio-visual equipment to
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`display demonstrative exhibits, including a projector to be connected to a laptop
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`and a screen for displaying documents.
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`Dated: November 5, 2018
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`Respectfully submitted,
`
`/s/ John K. Harrop
`John K. Harrop
`Counsel for Patent Owner
`Vilox Technologies, LLC
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`3
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`

`

`Case IPR2018-00044
`Patent No. 7,302,423
`
`
`
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`Certificate of Service
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`The undersigned certifies service pursuant to 37 CFR § 42.6(e) that
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT was served on the
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`Petitioner by email as authorized by the Petitioner in the Petition, as follows:
`
`David.odell.ipr@haynesboone.com
`David.mccombs.ipr@haynesboone.com
`Thomas.kelton.ipr@haynesboone.com
`Scott.cunning.ipr@haynesboone.com
`jonathan@unifiedpatents.com
`roshan@unifiedpatents.com
`russ.emerson@haynesboone.com
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`Dated: November 5, 2018
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`
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`John K. Harrop
`/s/
`John K. Harrop
`
`Counsel for Patent Owner
`Vilox Technologies, LLC
`
`4
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`

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