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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.,
`Petitioner
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`v.
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`COREPHOTONICS, LTD.,
`Patent Owner
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`_____________________
`
`
`Case IPR2018-01133
`Patent No. 9,538,152
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`_____________________
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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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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`
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`IPR2018-01133
`Patent 9,538,152
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`argument in the present inter partes review to be held on September 3, 2019 as set
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`forth in the Scheduling Order. Paper 9 at 4, 9.
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`I.
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`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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` how the combination of Border and Parulski renders obvious claims 1-4
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`of the ’152 Patent;
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` Patent Owner’s claim construction arguments (overt and covert) and its
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`non-obviousness arguments;
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` any responses to issues raised by the Patent Owner in sur-reply or relative
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`to testimony of experts; and
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` any responses to issues raised by the Board or Patent Owner at the
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`argument.
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`II. Organization of the Oral Argument
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`Petitioner requests that each side be allocated 45 minutes to present oral
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`argument in IPR2018-01133. For purposes of scheduling relative to other
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`proceedings, Petitioner notes that it also expects to argue IPR2018-01140 and
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`IPR2018-01146 (each involving the same parties as the present proceeding);
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`however, as there are no apparent common issues with the present proceeding
`1
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`Petitioner’s Request for Oral Argument
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`(IPR2018-01133), consolidation of all three proceedings is not indicated. Rather,
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`
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`IPR2018-01133
`Patent 9,538,152
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`since IPR2018-01140 and IPR2018-01146 involve related patents sharing the same
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`specification and related issues, separate requests for consolidated argument are
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`being filed in those proceedings.
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`Respectfully submitted,
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`
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`Dated: August 5, 2019
`HAYNES AND BOONE, LLP
`600 Congress Ave., Suite 1300
`Austin, Texas 78701
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`Telephone: 512-867-8457
`Facsimile: 512-867-8644
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`
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`
`
`/David W. OBrien/
`David W. O’Brien
`Registration No. 40,107
`Lead Counsel for Petitioner
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`
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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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`
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`IPR2018-01133
`Patent 9,538,152
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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 August 5, 2019
`Manner of service Electronic Mail
`Documents served Petitioner’s Request for Oral Argument
`Persons Served Neil A. Rubin (nrubin@raklaw.com)
`C. Jay Chung (jchung@raklaw.com)
`Reza Mirzaie (rmirzaie@raklaw.com)
`Marc A. Fenster (mfenster@raklaw.com)
`Russ August & Kabat
`12424 Wilshire Blvd., 12th Fl.
`Los Angeles, CA 90025
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`
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`
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`
`
`By: /David W. OBrien/
`David W. O’Brien
`Registration No. 40,107
`Lead Counsel for Petitioner
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`3
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