`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`APPLE INC.,
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`Petitioner,
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`v.
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`UNILOC LUXEMBOURG S.A.
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`Patent Owner.
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`Case No. IPR2018-00294
`U.S. Patent No. 6,736,759
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`IPR2018-00294
`U.S. Patent No. 6,736,759
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`Pursuant to the Board’s May 21, 2018, Scheduling Order (Paper 8), Petitioner
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`respectfully requests oral argument for the trial currently scheduled on January 23,
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`2019. Petitioner respectfully requests that the Oral Argument be held in Alexandria,
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`Virginia. In support of this request, Petitioner notes that it has consecutive hearings in
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`both this matter on January 23 and another matter involving the same parties on
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`January 24 (IPR2018-289). The Oral Argument in the IPR2018-289 proceeding
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`already has been set and is scheduled to take place in Alexandria, Virginia. (IPR2018-
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`289, Paper 18). If the oral arguments for these two matters are set in different
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`locations, Petitioner’s in-house counsel runs the risk of being unable to attend one of
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`these arguments. Conducting both oral arguments in Alexandria would alleviate any
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`issues with travel and attendance.
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`Pursuant to 37 C.F.R. § 42.70(a), Petitioner requests 45 minutes of total time
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`and specifies the following issues, without intent to waive consideration of any issue
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`not requested, to be argued for this proceeding:
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`I.
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`The proper construction of “displaying real-time data”;
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`II. Whether claims 1-7, 9, 12, 14, 17-22 and 26 are unpatentable under 35
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`U.S.C. § 103(a) over Fry and Newell;
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`III. Whether claims 20 and 22-23 are unpatentable under 35 U.S.C. § 103(a)
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`over Fry, Newell, and Arcelus;
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`IV. Whether claims 9 and 29-32 are unpatentable under 35 U.S.C. § 103(a)
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`over Fry, Newell and Richardson;
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`IPR2018-00294
`U.S. Patent No. 6,736,759
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`V. Whether claim 32 is unpatentable under 35 U.S.C. § 103(a) over Newell,
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`Richardson and Arcelus;
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`VI. Whether claims 4, 13, 15, 16, and 27-28 are unpatentable under 35
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`U.S.C. § 103(a) over Fry, Newell and Chance;
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`VII. Whether claims 24-25 are unpatentable under 35 U.S.C. § 103(a) over
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`Fry, Newell and French;
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`VIII. Whether claims 1-5, 8-12, 14, 17 and 19-26 are unpatentable under 35
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`U.S.C. § 103(a) over Vock and Arcelus;
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`IX. Whether claim 6 is unpatentable under 35 U.S.C. § 103(a) over Vock,
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`Arcelus, and Richardson;
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`X. Whether claims 4, 13, 15, 16, and 27-28 are unpatentable under 35
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`U.S.C. § 103(a) over Vock, Arcelus and Chance;
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`XI. The proposed definitions of a person having ordinary skill in the art;
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`XII. Any issues specified in Patent Owner’s Response; and
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`XIII. Any issues otherwise raised by the Board.
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`IPR2018-00294
`U.S. Patent No. 6,736,759
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`Dated:
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`December 12, 2018
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`ERISE IP, P.A.
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`BY: /s/ Adam P. Seitz
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`
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`Adam P. Seitz, Reg. No. 52,206
`Paul R. Hart, Reg. No. 59,646
`Chris R. Schmidt, Reg. No. 63,982
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`ATTORNEYS FOR PETITIONER
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`IPR2018-00294
`U.S. Patent No. 6,736,759
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on December
`12, 2018, Petitioner’s Request for Oral Argument was served via electronic service
`on the following counsel of record for Patent Owner:
`
`Ryan Loveless at ryan@etheridgelaw.com
`Brett Mangrum at brett@etheridgelaw.com
`James Etheridge at jim@etheridgelaw.com
`Jeffrey Huang at jeff@etheridgelaw.com
`ETHERIDGE LAW GROUP
`2600 E. Southlake Blvd, Suite 120-324
`Southlake, Texas 76092
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`BY:
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` /s/ Adam P. Seitz
`Adam P. Seitz, Reg. No. 52,206
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`ATTORNEY FOR PETITIONER
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