`Patent 7,092,671
`
`DOCKET NO.: 2211726-00152US1
`Filed on behalf of Unified Patents Inc.
`By: David L. Cavanaugh, Reg. No. 36,476
`Daniel V. Williams, Reg. No. 45,221
`Ellyar Y. Barazesh, Reg. No. 74,096
`Wilmer Cutler Pickering Hale and Dorr LLP
`1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: David.Cavanaugh@wilmerhale.com
`
`
`
`
`
`
`
`
`
`Jonathan Bowser, Reg. No. 54,574
`Roshan Mansinghani, Reg. No. 62,429
`Jonathan Stroud, Reg. No. 72,518
`Unified Patents Inc.
`1875 Connecticut Ave. NW, Floor 10
`Washington, DC, 20009
`Tel: (202) 805-8931
`Email: jonathan@unifiedpatents.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`
`UNILOC LUXEMBOURG S.A. & UNILOC USA
`Patent Owner
`
`
`IPR2018-00199
`Patent 7,092,671
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`Petitioner’s Request for Oral Argument
`IPR2018-00199
`
`
`INTRODUCTION
`Pursuant to the Board’s June 8, 2018 Scheduling Order (Paper 8) and the
`
`I.
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`parties’ August 25, 2018 Notice of Joint Stipulation to Modify Trial Due Dates
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`(Paper 9), Petitioner respectfully requests oral argument for the trial currently
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`scheduled on February 28, 2019. See Paper 8, 7. Petitioner respectfully requests
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`that the oral argument take place at the Alexandria, VA headquarters of the U.S.
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`Patent and Trademark Office, and requests the ability to use a computer, projector,
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`and screen to display possible demonstratives and exhibits.
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`Petitioner respectfully requests that that the portion of the hearing addressing
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`whether Petitioner is the sole real party-in-interest be closed to the public. It is
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`possible that the parties may discuss Petitioner’s confidential business information
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`that is subject to the Protective Order in this case during that portion of the hearing
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`and in response to questions from the Board. Petitioner respectfully requests that
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`accommodations be made for anyone who has not signed the protective order
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`acknowledgment to leave the hearing room if such confidential business information
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`needs to be discussed or presented by either Petitioner or Patent Owner.
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`II. REQUEST FOR ORAL ARGUMENT
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`Pursuant to 37 C.F.R. § 42.70, Petitioner specifies the following issues to be
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`argued:
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`1
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`
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`Petitioner’s Request for Oral Argument
`IPR2018-00199
`
`• Issues related to the Board’s Decision on Institution (Paper 7) and the
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`grounds Instituted.
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`• Whether claims 1-6 and 9-14 are unpatentable under 35 U.S.C. § 103(a)
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`as obvious over Yun, Langlois, and Dykes.
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`• Whether claims 7, 8, 15, and 16 are unpatentable under 35 U.S.C. §
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`103(a) as obvious over Yun, Langlois, Dykes, and Husemann.
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`• Whether claims 1-7 and 9-15 are unpatentable under 35 U.S.C. § 103(a)
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`as obvious over Harris, Langlois, and Dykes.
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`• Whether claims 8 and 16 are unpatentable under 35 U.S.C. § 103(a) as
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`obvious over Harris, Langlois, Dykes, and Husemann.
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`• Whether Petitioner is the sole real party-in-interest in this proceeding.
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`• Reply to any arguments raised in the Patent Owner’s Response.
`• Response to any issues specified by Patent Owner in its request for oral
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`argument.
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`• Issues related to Petitioner’s Opposed Motion to Seal (Paper 16) which
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`are not yet resolved by the Board.
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`III. CONCLUSION
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`Petitioner respectfully requests that the Board grant its Request for Oral
`
`Argument.
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`
`
`2
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`
`
`Dated: January 28, 2019
`
`Petitioner’s Request for Oral Argument
`IPR2018-00199
`
`
`Respectfully Submitted,
`
`/Ellyar Y. Barazesh/
`
`David L. Cavanaugh
`Registration No. 36,476
`
`Jonathan Bowser
`Registration No. 54,574
`
`Roshan Mansinghani
`Registration No. 62,429
`
`Jonathan Stroud
`Registration No. 72,518
`
`Daniel V. Williams
`Registration No. 45,221
`
`Ellyar Y. Barazesh
`Registration No. 74,096
`
`3
`
`
`
`Petitioner’s Request for Oral Argument
`IPR2018-00199
`
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`CERTIFICATE OF SERVICE
`
`I certify that on January 28, 2019, I caused a copy of the foregoing
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`materials:
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`Petitioner’s Request for Oral Argument
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`•
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`to be served via email, as agreed by the parties, to the attorneys of record for Patent
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`Owner at the following email addresses:
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`Ryan Loveless
`ryan@etheridgelaw.com
`
`Brett Mangrum
`brett@etheridgelaw.com
`
`James Etheridge
`jim@etheridgelaw.com
`
`Jeffrey Huang
`jeff@etheridgelaw.com
`
`Sean D. Burdick
`sean.burdick@unilocusa.com
`
`
`
`
`
`/Ellyar Y. Barazesh/
`Ellyar Y. Barazesh
`Registration No. 74,096
`
`i
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`
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