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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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`UUSI, LLC d/b/a NARTRON,
`Patent Owner
`
`____________________
`
`
`Case IPR2019-00359
`Patent No. 5,796,183
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` ____________________
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`
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`
`
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`Case IPR2019-00359
`Patent No. 5,796,183
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`Pursuant to 37 C.F.R. § 42.70(a), Patent Owner UUSI, LLC d/b/a
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`NARTRON, hereby requests an oral argument on the issues set forth below at a
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`time and in a manner set by the Board.
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`Oral argument is presently scheduled for May 7, 2020 at the San Jose,
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`California, USPTO Regional Office. In view of the USPTO Notices1 regarding
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`COVID-19, Patent Owner respectfully requests that oral argument in this IPR
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`proceeding be conducted remotely by video in the event that in-person oral
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`argument is prohibited.
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`Patent Owner respectfully requests one (1) hour of total argument time, per
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`side, in which to present arguments on the issues listed below.
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`ISSUES TO BE ARGUED
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`I. Whether claims 27, 83-85, and 90 are unpatentable as obvious over Chiu
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`alone or Chiu combined with Schwarzbach under 35 U.S.C. § 103;
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`II. Whether claims 86-88 are unpatentable as obvious over Chiu, Schwarzbach,
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`and Meadows under 35 U.S.C. § 103;
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`III. Whether claim 91 is unpatentable as obvious over Chiu, Schwarzbach, and
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`Ingraham ’548 under 35 U.S.C. § 103;
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`1 See https://www.uspto.gov/coronavirus (currently prohibiting in-person oral
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`hearings and closing USPTO offices to the public).
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`1
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`IV. Whether claims 28 and 92 are unpatentable as obvious over Chiu,
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`Case IPR2019-00359
`Patent No. 5,796,183
`
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`Schwarzbach, and Tucker under 35 U.S.C. § 103;
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`V. Whether claims 32, 36, and 93 are unpatentable as obvious over Chiu and
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`Lawson or Chiu, Schwarzbach, and Lawson under 35 U.S.C. § 103;
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`VI. Patent Owner’s responses to and addressing of: Petitioner’s new claim
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`interpretations, new arguments, and new rationales, set forth in Petitioners’
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`Reply dated February 4, 2020;
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`VII. All instituted grounds for which the PTAB’s Institution Decision found that
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`Petitioner established a reasonable likelihood that it would prevail in
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`establishing unpatentability;
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`VIII. All instituted grounds for which the PTAB’s Institution Decision found that
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`Petitioner did not establish a reasonable likelihood that it would prevail in
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`establishing unpatentability that Petitioner continues to challenge;
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`IX. All arguments and issues raised in Patent Owner’s Preliminary Response,
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`Patent Owner’s Response, and Patent Owner’s Sur-Reply; and
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`X. All arguments and issues raised by Petitioner in the Petition, Reply, and
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`during oral argument.
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`2
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`Case IPR2019-00359
`Patent No. 5,796,183
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`Patent Owner also respectfully requests the ability to use audiovisual
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`equipment to display possible demonstrative exhibits, including the use of a
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`projector and screen should oral argument take place in person, and permission to
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`share a presentation via remote connection should oral argument take place
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`remotely via video.
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`Dated: March 24, 2020
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`
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`By:
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`
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`Respectfully submitted,
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`
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`/ Lawrence M. Hadley /
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`Lawrence M. Hadley (pro hac vice)
`Stephen Underwood (Reg. # 77,977)
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`GLASER WEIL FINK HOWARD
`AVCHEN & SHAPIRO LLP
`10250 Constellation Blvd., 19th Floor
`Los Angeles, California 90067
`Telephone: (310) 553-3000
`lhadley@glaserweil.com
`sunderwood@glaserweil.com
`
`Joseph A. Rhoa (Reg. # 37,515)
`Jonathan A. Roberts (Reg. # 68,565)
`
`NIXON & VANDERHYE P.C.
`901 North Glebe Road, 11th Floor
`Arlington, VA 22203-1808
`Tel.: 703-816-4043
`Tel.: 703-816-4414
`Email: jar@nixonvan.com
`Email: jr@nixonvan.com
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`Counsel for Patent Owner
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`3
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`CERTIFICATE OF SERVICE
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`Case IPR2019-00359
`Patent No. 5,796,183
`
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on the date
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`indicated below, a complete and entire copy of the foregoing Patent Owner’s
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`Request for Oral Argument was provided by email to Petitioner’s counsel via
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`email, as agreed to by Petitioner’s Service Information in the Petition submission,
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`by serving the email address of record as follows:
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`
`W. Karl Renner, Reg. No. 41,265
`Jeremy Monaldo, Reg. No. 58,680
`Daniel D. Smith, Reg. No. 71,278
`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Tel: 202-783-5070
`Fax: 877-769-7945
`IPR39521-0062IP5@fr.com
`PTABInbound@fr.com
`axf-ptab@fr.com
`monaldo@fr.com
`dsmith@fr.com
`
`
`Date: March 24, 2020
`
`By: /Jonathan A. Roberts/
`Jonathan A. Roberts
`Reg. No. 68,565
`NIXON & VANDERHYE, PC
`901 N. Glebe Rd., Suite 1100
`Arlington, Virginia 22203
`Telephone: (703) 816-4414
`Email: jr@nixonvan.com
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