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`IPR2018-00952
`Patent No. 9,253,239
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
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`UNIFIED PATENTS INC.
`Petitioner
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`v.
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`BRADIUM TECHNOLOGIES LLC
`Patent Owner
`____________________________________________
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`IPR2018-00952
`Patent No. 9,253,239
`____________________________________________
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`IPR2018-00952
`Patent No. 9,253,239
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`Pursuant to the Scheduling Order (Paper 32 at page 4), Patent Owner Bradium
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`Technologies LLC requests oral argument. DUE DATE 7 (Oral argument) is
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`currently scheduled for September 17, 2019.
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`Pursuant to 37 C.F.R. § 42.70(a), Patent Owner intends to argue the following
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`issues:
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`1. Any issued addressed by Patent Owner in IPR2018-00952, including in
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`Patent Owner’s Response (Paper 37, 38) and Sur-reply (Paper 45, 46).
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`2. Whether Claim 20 of U.S. Patent No. 9,253,239 (the “’239 Patent”) is
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`unpatentable as obvious over the asserted combination of Reddy,
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`Hornbacker, and Rosasco.
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`3. The construction of the claim language “user-controlled image
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`viewpoint” of Claim 1 of the ’239 Patent.
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`4. Bradium’s contingent Motion to Amend and any issue addressed by
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`Patent Owner in relation to its Motion to Amend (Papers 39, 44).
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`5. Whether Petitioner Unified Patents has failed to identify all real-
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`parties-in-interest, and the remedy for its failure to do so.
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`6. Whether the Board should exercise its discretion to terminate this IPR
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`in accordance with § 314(d), § 318(d), and/or § 325(d).
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`IPR2018-00952
`Patent No. 9,253,239
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`7. Whether the Board lacks the authority under the United States
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`Constitution to institute, maintain, and issue a final written decision in
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`this IPR.
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`8. Rebuttal of any issue properly raised by Petitioner in this proceeding.
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`Bradium requests 30 minutes per side of oral argument. Bradium also
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`requests the use audio/visual equipment to display demonstrative exhibits, including
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`the use of an Elmo/digital projector and screen for projection of electronic and paper
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`materials.
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`IPR2018-00952
`Patent No. 9,253,239
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`Respectfully submitted,
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`
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`/Chris J. Coulson/
`Chris J. Coulson (Reg. No. 61,771)
`Bunsow De Mory LLP
`101 Brambach Rd.
`Scarsdale, NY 10583
`Tel: (646) 502-6973
`ccoulson@bdiplaw.com
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`Michael N. Zachary (pro hac vice)
`Bunsow De Mory LLP
`701 El Camino Real
`Redwood City, CA 94063
`Tel: (650) 351-7248
`mzachary@bdiplaw.com
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`Michael E. Shanahan (Reg. No. 43,914)
`Bradium Technologies LLC
`75 Montebello Rd.
`Suffern, NY 10901
`Tel: (845) 368-4000
`mshanahan@generalpatent.com
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`Counsel for Patent Owner
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`Dated: August 20, 2019
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`CERTIFICATE OF SERVICE
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`IPR2018-00952
`Patent No. 9,253,239
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`I hereby certify that on August 20, 2019, I caused a true and correct copy of
`the foregoing to be served via electronic mail to the attorneys of record at the
`following email addresses:
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`Roshan Suresh Mansinghani (Reg. No. 62,429)
`Unified Patents Inc.
`13355 Noel Road, Suite 1100
`Dallas, TX 75240
`Tel: (214) 945-0200
`Email: roshan@unifiedpatents.com
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`Alyssa J. Holtslander (Reg. No. 64,026)
`Jonathan Stroud (Reg. No. 72,518)
`Unified Patents Inc.
`1875 Connecticut Ave. NW, Floor 10
`Washington, DC 20009
`Tel: (202) 750-3605
`Email: alyssa@unifiedpatents.com
`Email: jonathan@unifiedpatents.com
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`David L. Cavanaugh (Reg. No. 36,476)
`Daniel V. Williams (Reg. No. 45,221)
`Jonathan E. Robe (Reg. No. 76,033)
`WILMER, CUTLER, PICKERING, HALE AND DORR, LLP
`1875 Pennsylvania Avenue, NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: David.Cavanaugh@wilmerhale.com
`Email: Daniel.Williams@wilmerhale.com
`Email: Jonathan.Robe@Wilmerhale.com
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`IPR2018-00952
`Patent No. 9,253,239
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` Respectfully submitted,
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`/Chris J. Coulson/
`Chris J. Coulson (Reg. No. 61,771)
`Bunsow De Mory LLP
`101 Brambach Rd.
`Scarsdale, NY 10583
`
`Counsel for Patent Owner
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`5
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