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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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`BAYERISCHE MOTOREN WERKE AKTIENGESELLSCHAFT and BMW OF
`NORTH AMERICA, LLC,
`Petitioners,
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`v.
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`PAICE LLC and THE ABELL FOUNDATION, INC.,
`Patent Owners.
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`Case IPR2020-01386
`Patent 7,237,634
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`PATENT OWNERS’ REQUEST FOR ORAL ARGUMENT
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`Proceeding No. IPR2020-01386
`Attorney Docket No. 36351-0018IP1
`Pursuant to 37 C.F.R. § 42.70(a) and the Scheduling Order (Paper 14), Paice
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`LLC and the Abell Foundation, Inc. (Patent Owners) submit this Request for Oral
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`Argument on all of the instituted grounds of unpatentability of U.S. Patent No.
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`7,237,634. Patent Owners request (without waiving consideration of any issue not
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`listed below) to address the grounds on which the IPR was instituted and any
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`additional issues on which the Board seeks clarification. Patent Owners request 60
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`minutes for each side to present arguments collectively for this proceeding. Due to
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`the substantial overlap in issues and prior art, Patent Owners respectfully request
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`that the Board refrain from issuing its Final Written Decision in IPR2020-00994
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`until after the oral argument in this proceeding.
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`To the extent the oral argument, which will be held November 9, 2021, is
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`scheduled as an in-person hearing, Patent Owners request to use video equipment
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`to display exhibits, including the use of a projector/screen for a PowerPoint display
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`or the like.
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`Respectfully submitted,
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`/Brian J. Livedalen/
`Brian J. Livedalen, Reg. No. 67,450
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`Attorney for Patent Owner
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`Dated: September 7, 2021
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`Customer Number 26191
`Fish & Richardson P.C.
`Telephone: (612) 337-2569
`Facsimile: (612) 288-9696
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`Proceeding No. IPR2020-01386
`Attorney Docket No. 36351-0018IP1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR § 42.6(e)(4), the undersigned certifies that on September
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`7, 2021, a complete and entire copy of this Patent Owner’s Request for Oral
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`Argument was provided via email, to the Petitioner by serving the email
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`correspondence addresses of record as follows:
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`Jeffrey D. Sanok
`Vincent J. Galluzzo
`Crowell & Moring LLP
`Intellectual Property Group
`1001 Pennsylvania Avenue, N.W.
`Washington, DC 20004-2595
`
`
`Scott L. Bittman
`Jacob Z. Zambrzycki
`Crowell & Moring LLP
`Intellectual Property Group
`590 Madison Avenue, 20th Floor
`New York, NW 10022-2544
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`Email:
`jsanok@crowell.com
`vgalluzzo@crowell.com
`sbittman@crowell.com
`jzambrzycki@crowell.com
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` /Kristyn Waldhauser/
`Kristyn Waldhauser
`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`(612) 638-5731
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