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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.,
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`Petitioner
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`v.
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`LBT IP I LLC,
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`Patent Owner
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`Case No. IPR2020-01192
`U.S. Patent No. 8,421,618
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`Inter Partes Review No. IPR2020-01192
`U.S. Patent No. 8,421,618
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`Pursuant to the Board’s March 4, 2021, Scheduling Order (Paper 10),
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`Petitioner respectfully requests oral argument for the trial currently scheduled on
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`December 9, 2021. Petitioner requests oral argument for this IPR (IPR2020-01192)
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`be combined with oral argument for IPR2020-01189 and IPR2020-01191 (for which
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`a Request for Oral Argument is concurrently filed). Although the patents of the three
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`IPRs are related, the grounds and arguments are varied amongst the three patents,
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`and each IPR includes a Contingent Motion to Amend. The Parties conferred and
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`jointly request a total argument time of 120 minutes for each Party. Petitioner also
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`requests a single set of demonstratives be used for all IPRs. If the Board is allowing
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`in-person hearings, Petitioner further requests the hearing take place in Alexandria,
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`Virginia.
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`Pursuant to 37 C.F.R. § 42.70(a), Petitioner specifies the following issues,
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`without intent to waive consideration of any issue not requested, to be argued for this
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`proceeding:
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`1. Whether Claims 1, 3, 9-11, 14-16, 19-21, and 24 are obvious under § 103
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`over Japanese Patent Application No. JP2004-37116A to Sakamoto (“Sakamoto”) in
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`view of U.S. Patent No. 5,583,776 to Levi, et al. (“Levi”);
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`2. Whether Claims 4-6 are obvious under § 103 over Sakamoto in view of
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`Levi in further view of U.S. Patent Application Publication No. 2006/0272413 A1 to
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`Vaganov, et al. (“Vaganov”);
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`Inter Partes Review No. IPR2020-01192
`U.S. Patent No. 8,421,618
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`3. Whether Claims 7, 12-13, 17, and 22-23 are obvious under § 103 over
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`Sakamoto in view of Levi in further view of U.S. Patent No. 7,053,823 B2 to Cervinka,
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`et al. (“Cervinka”);
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`4. Whether Claim 2 is obvious under § 103 over Sakamoto in view of Levi
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`in further view of U.S. Patent No. 6,799,050 B1 to Krasner (“Krasner”);
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`5. Whether Claims 8 and 18 are obvious under § 103 over Sakamoto in view
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`of Levi and Cervinka and in further view of Krasner.
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`6.
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`Any claim constructions, unpatentability grounds, or other issues raised in
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`the Petition or Petitioner Reply, the Patent Owner Preliminary Response, Patent Owner
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`Response, the Patent Owner Sur-Reply, or the Board’s Institution Decision;
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`7.
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`Any claim constructions, unpatentability grounds, or other issues raised in
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`the Patent Owner Motion to Amend and follow-up briefing by the Parties, including the
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`Petitioner Objection to Motion to Amend and Patent Owner Reply;
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`8.
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`Any issues regarding motions to exclude or motions to strike that may be
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`filed or pending; and
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`9.
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`Any issues otherwise raised by the Board.
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`Inter Partes Review No. IPR2020-01192
`U.S. Patent No. 8,421,618
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`Respectfully submitted,
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`ERISE IP, P.A.
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`BY: /s/Jennifer C. Bailey
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`Jennifer C. Bailey Reg. No. 52,583
`Adam P. Seitz, Reg. No. 52,206
`Jocelyn D. Ram, Reg. No. 54,898
`7015 College Blvd., Suite 700
`Overland Park, KS 66211
`P: (913) 777-5600
`F: (913) 777-5601
`jennifer.bailey@eriseip.com
`adam.seitz@eriseip.com
`Jocelyn.ram@eriseip.com
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`ATTORNEYS FOR PETITIONER
`APPLE INC.
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`Inter Partes Review No. IPR2020-01192
`U.S. Patent No. 8,421,618
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`CERTIFICATE OF SERVICE ON PATENT OWNER
`UNDER 37 C.F.R. § 42.6
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on October 25,
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`2021, the foregoing Petitioner’s Request for Oral Argument was served via
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`electronic filing with the Board and via Electronic Mail on the following
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`practitioners of record for Patent Owner:
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`Mitchell S. Zajac (zajac@butzel.com)
`Brian S. Seal (seal@butzel.com)
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`/s/ Jennifer C. Bailey
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`Jennifer C. Bailey, Reg. No. 52,583
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