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`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
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`Petitioner’s Request for Oral Argument, IPR2018-00952
`U.S. Patent 9,253,239
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`Petitioner respectfully requests oral argument which has been tentatively
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`scheduled for September 17, 2019. Paper 32, Scheduling Order, at 7. Pursuant to 37
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`C.F.R. § 42.70, Petitioner specifies the following issues to be argued:
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`• whether Petitioner has met its burden in demonstrating that the
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`challenged claims are unpatentable in view of issues in the Petition and
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`Petitioner’s Reply as well as supporting evidence;
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`• issues related to the Board’s Decision on Institution and the ground
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`instituted in the Decision;
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`• whether claim 20 is unpatentable for obviousness under 35 U.S.C. §
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`103;
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`• whether Petitioner is the sole real party-in-interest;
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`• reply to any arguments raised in the Patent Owner’s Response and Sur-
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`Reply;
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`• whether Patent Owner’s Motion to Amend should be denied in view of
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`issues raised in Petitioner’s Opposition and Sur-Reply as well as
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`supporting evidence;
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`• reply to any arguments raised in the Motion to Amend and Reply to
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`Opposition;
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`1
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`Petitioner’s Request for Oral Argument, IPR2018-00952
`U.S. Patent 9,253,239
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`• response to any issues specified by Patent Owner in its request for oral
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`argument; and
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`• any issues raised in briefing pursuant to the schedule.
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`Petitioner requests that each party have 30 minutes of time for argument for a
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`total of 60 minutes for the session. To the extent the Board schedules this hearing to
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`last more than the total hearing time requested by Petitioner, Petitioner request that
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`it be given half the total length.
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`Petitioner requests the ability to use a computer, projector, and screen to
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`display possible demonstratives and exhibits. Petitioners also request that two
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`attorneys at Petitioner’s counsel’s table be allowed to use computers at the hearing
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`(in addition to the counsel making the argument using his or her computer to show
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`the demonstratives), to avoid the need for the parties to bring entire paper copies of
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`the record into the hearing room and to facilitate efficient answering of panel
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`questions.
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`No fee is believed due with this request; however, the Director is hereby
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`authorized to charge any shortfall or credit any overpayment to Deposit Account 50-
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`6990.
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`2
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`Petitioner’s Request for Oral Argument, IPR2018-00952
`U.S. Patent 9,253,239
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`Date: August 20, 2019
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`Respectfully,
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` /s/ Roshan S. Mansinghani
`Roshan S. Mansinghani
`Registration No. 62,429
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`3
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`Petitioner’s Request for Oral Argument, IPR2018-00952
`U.S. Patent 9,253,239
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`CERTIFICATE OF SERVICE
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`I certify that on August 20, 2019, I served a copy of Petitioner’s Request for
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`Oral Argument via email, as agreed by the parties, on the following counsel for
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`Patent Owner:
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`
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`Chris J. Coulson
`Michael N. Zachary
`Bunsow De Mory LLP
`701 El Camino Real Redwood City, CA 94063
`Email: ccoulson@bdiplaw.com
`Email: mzachary@bdiplaw.com
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`
`Michael E. Shanahan
`Email: mshanahan@generalpatent.com
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`Respectfully,
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`Date: August 20, 2019
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`/s/ Roshan S. Mansinghani
`Roshan S. Mansinghani
`Registration No. 62,429
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