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`_____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________________
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`APPLE INC., SAMSUNG ELECTRONICS AMERICA, INC.,
`HTC CORP., HTC AMERICA, INC., and LG ELECTRONICS, INC.,
`Petitioner,
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`v.
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`UNILOC 2017 LLC,
`Patent Owner
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`_____________________
`
`
`Case IPR2018-004241
`Patent No. 7,881,902 B1
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`_____________________
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`1 HTC Corp., HTC America, Inc., and LG Electronics, Inc., who collectively filed
`a petition in IPR2018-01631, and Samsung Electronics America, Inc., who filed a
`petition in IPR2018-01653, have been joined as petitioner in this proceeding.
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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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`IPR2018-00424
` Patent No. 7,881,902
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`
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`argument in the present inter partes review to be held on April 2, 2019 as set forth
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`in the Scheduling Order. See Paper 8 at 7.
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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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` Mitchnik renders obvious each and every element of claims 1-2;
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` The combination of Mitchnik and Sheldon renders obvious each and
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`every element of claim 3;
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` The combination of Mitchnick and Tanenhaus renders obvious each
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`and every element of claim 4;
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` The combination of Fabio and Pasolini renders obvious each and
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`every element of claims 5-6 and 9-10;
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` Other issues raised in papers filed in the present proceeding, including
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`issues raised in any papers filed between today and the oral hearing.
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`Petitioner also requests that the oral hearing for this case, IPR2018-00424,
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`be combined with the oral hearing for IPR2018-01028, which is also directed to
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`the ’902 patent. Petitioner further requests that each side be allocated a total of 30
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`minutes to present oral arguments for the combined oral hearing of IPR2018-00424
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`and IPR2018-01028.
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`1
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`Petitioner’s Request for Oral Argument
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`If the Board has any questions or comments, the undersigned attorney
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`IPR2018-00424
` Patent No. 7,881,902
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`respectfully requests a telephone conference. No fees are believed to be required
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`for filing this request; however, the Commissioner is authorized to charge any
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`required fees, or credit any overpayment, to Haynes and Boone, LLP's Deposit
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`Account No. 08-1394.
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`Dated: March 1, 2019
`HAYNES AND BOONE, LLP
`2323 Victory Avenue, Suite 700
`Dallas, Texas 75219
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`Telephone: 214-651-5116
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`Facsimile: 214-200-0853
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`Respectfully submitted,
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`/Andrew S. Ehmke/
`Andrew S. Ehmke
`Lead Counsel for Petitioner
`Registration No. 50,271
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`2
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`Petitioner’s Request for Oral Argument
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`CERTIFICATE OF SERVICE
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`IPR2018-00424
` Patent No. 7,881,902
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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 March 1, 2019
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`Manner of service Electronic Mail to: ryan@etheridgelaw.com;
`brett@etheridgelaw.com; jim@etheridgelaw.com;
`jeff@etheridgelaw.com; sean.burdick@unilocusa.com
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`Documents served Petitioner’s Request for Oral Argument
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`Persons Served Ryan Loveless
`Brett Mangrum
`James Etheridge
`Jeffrey Huang
`ETHERIDGE LAW GROUP
`2600 E. Southlake Blvd., Ste 120-324
`Southlake, Texas 76092
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`Sean D. Burdick
`UNILOC USA, INC.
`7160 Dallas Parkway, Ste. 380
`Plano, TX 75024
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`By: /Andrew S. Ehmke/
`Andrew S. Ehmke
`Lead Counsel for Petitioner
`Registration No. 50,271
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