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`UNITED STATES PATENT AND TRADEMARK OFFICE
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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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`QUALCOMM INCORPORATED,
`Patent Owner
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`Case No. IPR2018-01279
`Patent No. 7,844,037
`______________________
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`Proceeding No.: IPR2018-01279
`Attorney Docket: 39521-0050IP1
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`Pursuant to 37 C.F.R. § 42.70(a) and the Board’s Scheduling Order (Paper
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`12) and the Board’s Order Modifying the Scheduling Order (Paper 33), Petitioner
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`submits this Request for Oral Argument on all of the instituted grounds against the
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`Challenged Claims of U.S. Patent No. 7,844,037 and all of the grounds raised
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`against the substitute claims proposed in Patent Owner’s Motion to Amend (Paper
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`24). Petitioner requests 90 minutes for each side (180 minutes total) to present
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`arguments for this proceeding.
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`Specifically, Petitioner requests (without waiving consideration of any issue
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`not listed below) to address the following issues:
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`1.
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`The obviousness of claims 1-8, 12-14 and 16-18 in view Mäkelä in
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`view of Moran;
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`2.
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`The obviousness of claims 7-11 in view of Mäkelä in view of Moran
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`and Tsampalis;
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`3.
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`4.
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`The substitute claims 26-42 enlarging the scope of the claims;
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`The non-responsiveness of proposed substitute claims 26-27, 30 and
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`40-41;
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`5.
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`The obviousness of proposed substitute claims 26-33, and 37-42 in
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`view of Mäkelä and Moran in view of Pirskanen;
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`6.
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`The obviousness of proposed substitute claim 30 in view of Mäkelä,
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`Moran, and Pirskanen in view of Viinikanoja;
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`1
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`Proceeding No.: IPR2018-01279
`Attorney Docket: 39521-0050IP1
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`7.
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`The obviousness of proposed substitute claims 32-36 in view of
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`Mäkelä Moran and Tsampalis in view of Pirskanen;
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`Discussion of any motions to exclude;
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`Rebuttal to Patent Owner’s presentation on all matters; and
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`8.
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`9.
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`10. Any additional issues on which the Board seeks clarification.
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`Petitioner also respectfully requests the ability to use audio visual equipment
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`to display demonstrative exhibits, including the use of a projector and screen that
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`connects to a laptop computer. Petitioner’s counsel will use a laptop computer
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`with a VGA-type connector. In addition, Petitioner requests that an ELMO-type
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`projector be made available for use.
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`Dated October 30, 2019
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` Respectfully submitted,
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`/Dan Smith/
`W. Karl Renner, Reg. No. 41,265
`Thomas A. Rozylowicz, Reg. No. 50,620
`Timothy W. Riffe, Reg. No. 43,881
`Dan Smith, Reg. No. 71,278
`Fish & Richardson P.C.
`3200 RBC Plaza, 60 South Sixth Street
`Minneapolis, MN 55402
`T: 202-783-5070
`F: 877-769-7945
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` Attorneys for Petitioner
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`2
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`Proceeding No.: IPR2018-01279
`Attorney Docket: 39521-0050IP1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR § 42.8(b), the undersigned certifies that on October 30,
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`2019, a complete and entire copy of this Petitioner’s Request for Oral Argument
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`was provided via email to the Patent Owner by serving the correspondence email
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`addresses of record as follows:
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`Brian W. Oaks
`Eliot Williams
`Chad Walters
`Joseph Akalski
`Charles Yeh
`Jessica Lin
`Puneet Kohli
`Baker Botts L.L.P.
`1001 Page Mill Road, Building One, Suite 200
`Palo Alto, California 94304-1007
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`Email: Qualcomm_037IPR@bakerbotts.com
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`/Diana Bradley/
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`Diana Bradley
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(858) 678-5667
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`
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`3
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