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`IPR2018-00067
`U.S. Patent 8,577,813
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`
`UNIVERSAL SECURE REGISTRY LLC
`Patent Owner
`________________
`
`Case IPR2018-00067
`U.S. Patent No. 8,577,813
`________________
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`
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`
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`Pursuant to the parties Notice of Joint Stipulation and Authorized Request to
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`IPR2018-00067
`U.S. Patent 8,577,813
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`
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`Modify Schedule, (Paper 40), Petitioner respectfully requests oral argument for the trial
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`currently scheduled on January 30, 2019. Petitioner and Patent Owner have conferred
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`and jointly propose that each side be allotted a total of forty-five (45) minutes per side
`
`for oral argument. Petitioner requests the opportunity to present oral argument on all
`
`issues raised in the papers, and identifies the following issues, without intent to waive
`
`consideration of any issue not requested, to be argued for this proceeding:
`
`I.
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`Whether claims 1, 2, 3, 5, 11, 13–17, 20, and 22–26 are obvious under
`
`§103(a) over the combination of U.S. Patent 6,016,476 to Maes, et al.
`
`(“Maes”) and U.S. Patent 5,870,723 to Pare, et al. (“Pare”);
`
`II.
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`Whether claims 1, 2, 3, 5, 11–17, and 20–26 are obvious under §103(a)
`
`over
`
`the combination of Maes and U.S. Patent Publication
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`2004/0107170 A1 to Labrou, et al. (“Labrou”);
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`III.
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`Whether claims 12–15, 17, 20–23, 25, and 26 are obvious under
`
`§103(a) over the combination of Maes, Pare, and Labrou;
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`IV.
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`Whether claims 6-9 and 18 are obvious over the combination of Maes,
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`Pare, and PCT Patent Publication WO 2001/024123 to Burger, et al.
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`(“Burger”);
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`V.
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`Whether claims 6-9 and 18 are obvious over the combination of Maes,
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`Labrou and Burger;
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`1
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`IPR2018-00067
`U.S. Patent 8,577,813
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`VI.
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`Whether claims 1-2, 5, 11, 13, 16-17 and 24 are obvious under §103(a)
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`over U.S. Patent 7,865,448 to Pizarro (“Pizarro”) in view of Pare;
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`VII.
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`Whether Patent Owner’s contingently proposed amended claims 27-
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`52 are patentable and should be allowed:
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`a. Whether proposed amended claims 27-31, 37-44, and 46-52 are
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`obvious under §103(a) over the combination of Maes and
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`Labrou;
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`b. Whether proposed amended claims 27-31, 37-41, and 50-52 are
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`obvious under §103(a) over the combination of Maes, Labrou,
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`and U.S. Patent 5,280,527 (“Gullman”);
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`c. Whether proposed amended claims 27-31, 37-41, and 50-52 are
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`obvious under §103(a) over the combination of Maes, Labrou,
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`and U.S. Patent Publication 2004/0172535 (“Jakobsson”);
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`d. Whether proposed amended claims 42-43 and 46-49 are obvious
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`under §103(a) over the combination of Maes, Labrou, and U.S.
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`Patent 5,479,512 (“Weiss”)
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`e. Whether proposed amended claim 45 is obvious under §103(a)
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`over the combination of Maes, Labrou, Weiss, and Gullman;
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`f. Whether proposed amended claim 45 is obvious over the
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`combination of Maes, Labrou, Weiss, and Jakobsson;
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`2
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`IPR2018-00067
`U.S. Patent 8,577,813
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`g. Whether proposed amended claims 32-36 are obvious under
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`§103(a) over the combination of Maes, Labrou, Gullman, and
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`Burger;
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`h. Whether proposed amended claims 32-36 are obvious under
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`§103(a) over the combination of Maes, Labrou, Jakobsson, and
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`Burger;
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`i. Whether proposed amended claim 44 is obvious under §103(a)
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`over the combination of Maes, Labrou, Weiss, and Burger;
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`j. Whether the proposed amended claims 27-52 are unpatentable
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`under 35 U.S.C. § 101;
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`VIII.
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`The proper construction of disputed claim terms, if any;
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`IX.
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`X.
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`Whether Petitioner is the sole real-party-in-interest; and
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`Response to any issues specified by Patent Owner in its papers and/or
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`request for oral argument.
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`Date: January 5, 2019
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`Respectfully submitted,
`
`
`
` /s/ Jason R. Mudd
`Jason R. Mudd, Reg. No. 57,700
`Roshan Mansinghani, Reg. No. 62,429
`Eric A. Buresh, Reg. No. 50,394
`Jonathan Stroud, Reg. No. 72,518
`
`ATTORNEYS FOR PETITIONER
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`3
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`IPR2018-00067
`U.S. Patent 8,577,813
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies that
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`the foregoing PETITIONER’S REQUEST FOR ORAL ARGUMENT was
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`served on January 5, 2019 by filing these documents with the Patent Trial and
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`Appeal Board End to End System (PTAB E2E), as well as by e-mailing copies
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`to attorneys of record, as follows:
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`• jimglass@quinnemanuel.com
`• nimahefazi@quinnemanuel.com
`• chrismathews@quinnemanuel.com
`• tigranguledjian@quinnemanuel.com
`• richardlowry@quinnemanuel.com
`• qe-usr-ipr@quinnemanuel.com
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`
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`
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`Date: January 5, 2019
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`
`
`/s/ Jason R. Mudd
`Jason R. Mudd, Reg. No. 57,700
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`4
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