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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`______________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________________
`
`CANON INC. and CANON U.S.A., INC., and
`AXIS COMMUNICATIONS AB,
`
`Petitioners,
`v.
`
`AVIGILON FORTRESS CORPORATION,
`Patent Owner.
`______________________________
`
`Case: IPR2019-00311
`U.S. Patent No. 7,932,923
`______________________________
`
`PARTIES’ JOINT REQUEST FOR ORAL ARGUMENT
`
`

`

`IPR2019-00311
`U.S. Patent No. 7,932,923
`
`Pursuant to 37 C.F.R. § 42.70 and the Board’s Scheduling Order (Paper No.
`
`9), Patent Owner and Petitioners hereby request oral argument. Pursuant to the
`
`Scheduling Order, oral argument is scheduled to occur on April 8, 2020. The
`
`Parties intend to discuss the issues raised in the filings, including, but not limited
`
`to, the following items:
`
`1.
`
`The patentability/unpatentability of all challenged claims based on the
`
`instituted grounds, including the appropriate claim construction of the material
`
`disputed terms;
`
`2.
`
`Rebuttal to the respective opposing side’s presentation on all matters;
`
`and;
`
`3.
`
`Any other issues that the Board deems necessary for issuing a final
`
`written decision.
`
`The Parties jointly request that each side be given a total of 75 minutes to
`
`present its arguments with respect to the issues identified in this request for oral
`
`argument, as well as the issues identified in the requests for oral argument
`
`Petitioners are concurrently submitting in the related proceeding IPR2019-00314.
`
`The Parties jointly request that they be permitted to reserve time to present
`
`rebuttal arguments, if necessary.
`
`1
`
`

`

`IPR2019-00311
`U.S. Patent No. 7,932,923
`
`The Parties also jointly request the ability to use computers and audio/visual
`
`equipment to display demonstrative exhibits and evidence, including the use of a
`
`projector and screen.
`
`2
`
`

`

`IPR2019-00311
`U.S. Patent No. 7,932,923
`
`Dated: February 24, 2020
`
`By: /C. Gregory Gramenopoulos/
`
` By: /Joseph A. Calvaruso/
`
`C. Gregory Gramenopoulos
`Reg. No. 36,532
`
`Joseph A. Calvaruso
`
` Reg. No. 28,287
`
`
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER LLP
`
` ORRICK, HERRINGTON & SUTCLIFFE
`LLP
`
`901 New York Avenue, NW
`Washington, DC 20001-4413
`Tel. 202.408.4263; Fax 202.408.4400
`
`51 West 52nd Street
`
` New York, NY 10019-6142
` Tel. 212.506.5140; Fax 212.506.5151
`
`gramenoc@finnegan.com
`
`JVCPTABDocket@orrick.com
`
` Attorney for Petitioners
`Canon Inc. and Canon U.S.A., Inc.
`
`Attorney for Petitioner
`Axis Communications AB
`
`By: /Reza Dokhanchy/
`
`Reza Dokhanchy
`Reg. No. 62,795
`
`KIRKLAND & ELLIS LLP
`
`555 California Street
`San Francisco, CA 94104
`Tel. 415.439.1400; Fax 415.439.1500
`
`reza.dokhanchy@kirkland.com
`
`Attorney for Patent Owner
`Avigilon Fortress Corporation
`
`3
`
`

`

`IPR2019-00311
`U.S. Patent No. 7,932,923
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Parties’ Joint
`
`Request For Oral Argument was served on February 24, 2020, via email directed to
`
`counsel of record for Avigilon at the following addresses:
`
`Reza Dokhanchy
`Adam R. Alper
`Akshay S. Deoras
`Kirkland & Ellis LLP
`555 California Street
`San Francisco, CA 94104
`reza.dokhanchy@kirkland.com
`adam.alper@kirkland.com
`akshay.deoras@kirkland.com
`Avigilon_Axis@kirkland.com
`
`Michael W. De Vries
`Kirkland & Ellis LLP
`555 Flower Street
`Los Angeles, CA 90071
`michael.devries@kirkland.com
`
`Dated: February 24, 2020
`
`By: /Joseph A. Calvaruso/
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`
`4
`
`

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