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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`ROKU, INC.,
`Petitioner,
`
`v.
`
`UNIVERSAL ELECTRONICS INC.,
`Patent Owner.
`
`____________
`
`Case IPR2019-01614
`U.S. Patent 9,911,325
`
`____________
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`
`Case IPR2019-01614
`U.S. Patent 9,911,325
`
`Pursuant to 37 C.F.R. § 42.70 and the Board’s Scheduling Order dated April
`
`16, 2020 (Paper 8), Patent Owner Universal Electronics Inc. (“Patent Owner”),
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`requests Oral Argument on issues related to the patentability of the challenged
`
`claims of U.S. Patent No. 9,911,325 (“the ’325 Patent”). Without intending to
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`waive any issue not specifically identified, Patent Owner wishes to present
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`arguments on the following issues:
`
`•
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`The proper construction of the terms “key code signal” and “generate
`
`a key code using the keystroke indicator signal” in the claims of the ’325 Patent;
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`•
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`Grounds at issue in this proceeding, including all issues raised by the
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`parties relating to the instituted grounds in this proceeding (Grounds 1-2);
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`•
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`Any issues addressed in the Patent Owner’s papers, including but not
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`limited to, the Patent Owner’s Response and Patent Owner’s Sur-Reply;
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`•
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`Rebuttal to Petitioner’s presentation and positions on all issues,
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`including the issues listed above and any issues raised in Petitioner’s Petition,
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`Petitioner’s Reply, or elsewhere in the record for this proceeding;
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`Any motions to exclude filed by any party;
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`Any other issues the Board deems necessary for issuing a final written
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`•
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`•
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`decision.
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`Patent Owner believes the parties need no more than sixty minutes per side
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`to present arguments in this case. To the extent the oral argument will be
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`1
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`
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`Case IPR2019-01614
`U.S. Patent 9,911,325
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`conducted in-person at the offices of the United States Patent and Trademark
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`Office, Patent Owner respectfully requests permission to use audio/visual
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`equipment to display demonstrative exhibits. To the extent the oral arguments will
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`be conducted by video conference in light of the COVID-19 pandemic, Patent
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`Owner respectfully requests that the Board provide a video conferencing platform
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`and a public telephone line.
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`
`Dated: November 10, 2020
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`
`
`
`
`
`
`
`/S. Benjamin Pleune/
`S. Benjamin Pleune
`Reg. No. 52,421
`ALSTON & BIRD LLP
`Bank of America Plaza, Suite 4000
`101 South Tryon Street
`Charlotte, NC 28280-4000
`Telephone: (704) 444-1000
`Facsimile: (704) 444-1111
`Email: ben.pleune@alston.com
`
`Counsel for Patent Owner
`Universal Electronics Inc.
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`2
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`
`
`Case IPR2019-01614
`U.S. Patent 9,911,325
`
`
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.8 and 42.6(e), the undersigned hereby certifies
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`that the foregoing Patent Owner’s Request for Oral Argument was served
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`electronically in their entirety on the following:
`
`Jon E. Wright, Reg. No. 50,720
`jwright-PTAB@sternekessler.com
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`Tel.: 202-772-8651
`Fax: 202-371-2540
`
`Lestin L. Kenton, Reg. No. 72,314
`lkenton-PTAB@sternekessler.com
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`Tel.: 202-772-8594
`Fax: 202-371-2540
`
`Daniel S. Block, Reg. No. 68,395
`dblock-PTAB@sternekessler.com
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`Tel.: 202-772-8735
`Fax: 202-371-2540
`
`Timothy L. Tang, Reg. No. 75,187
`ttang-PTAB@sternekessler.com
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`1100 NEW YORK AVENUE, N.W.
`WASHINGTON, D.C. 20005
`TEL.: 202-772-8758
`FAX: 202-371-2540
`
`
`3
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`
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`Case IPR2019-01614
`U.S. Patent 9,911,325
`
`
`
`Dated: November 10, 2020
`
`
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`
`
`
`
`
`
`
`/S. Benjamin Pleune/
`S. Benjamin Pleune
`Reg. No. 52,421
`ALSTON & BIRD LLP
`Bank of America Plaza, Suite 4000
`101 South Tryon Street
`Charlotte, NC 28280-4000
`Telephone: (704) 444-1000
`Facsimile: (704) 444-1111
`Email: ben.pleune@alston.com
`
`Counsel for Patent Owner Universal
`Electronics Inc.
`
`4
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`
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