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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS AMERICA, INC.
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`Petitioner
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`v.
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`UNILOC LUXEMBOURG, S.A.1
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`Patent Owner
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`IPR2018-01664
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`PATENT 8,872,646
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`1
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` The owner of this patent is Uniloc 2017 LLC.
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`Patent Owner Uniloc 2017 LLC hereby requests oral argument in
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`accordance with 37 C.F.R. §42.70 and pursuant to the Scheduling Order (Paper
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`8) entered March 8, 2019. In that Patent Owner’s counsel is located in the Dallas,
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`Texas area, Patent Owner respectfully requests that the Board conduct the hearing
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`at the Texas Regional Office in Dallas, Texas.
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`Patent Owner proposes no more than thirty (30) minutes per side. Patent
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`Owner also requests permission to use audiovisual display equipment to present
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`demonstratives, including a projector and screen for computer-generated slides,
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`and a document camera/projector. Patent Owner expects to have two people at the
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`hearing.
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`Issues to be argued include:
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`1.
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`Any issues pertaining to the grounds on which this IPR was instituted.
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`This may include, for example, the level of ordinary skill in the art, claim
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`construction, the absence of elements in the prior art, and reasons/motivations to
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`combine references.
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`2.
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`3.
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`4.
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`5.
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`6.
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`Any issues specified in the Petition.
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`Any issues specified in Patent Owner’s Motion to Amend.
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`Any issues specified in Petitioner’s Opposition.
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`Any issues specified in Patent Owner’s Reply.
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`Any issues specified in Petitioner’s Sur-Reply in Opposition to the
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`Motion to Amend.
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`7.
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`Any issues otherwise raised by the Board.
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`Date: November 12, 2019
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`Respectfully submitted,
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`/s/ Brett A. Mangrum
`Brett A. Mangrum
`brett@etheridgelaw.com
`Reg. No. 64,783
`Counsel for Patent Owner
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.6(e), the undersigned certifies that an electronic
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`copy of the foregoing was served, along with any accompanying exhibits not
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`previously served, via the PTAB E2E system and/or via email to Petitioner’s counsel
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`at the following addresses identified in the Petition’s consent to electronic service:
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`Lead Counsel
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`Naveen Modi
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`naveenmodi@paulhastings.com
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`PH-Samsung-Uniloc-IPR@paulhastings.com
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`First Back Up Counsel
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`Joseph Palys
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`josephpalys@paulhastings.com
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`Back Up Counsel
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`Phillip Citroen
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`phillipcitroen@paulhastings.com
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`Back Up Counsel
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`Michael Wolfe
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`michaelwolfe@paulhastings.com
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`Date: November 12, 2019
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`Respectfully submitted,
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`/s/ Brett A. Mangrum
`Brett A. Mangrum
`brett@etheridgelaw.com
`Reg. No. 64,783
`Counsel for Patent Owner
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