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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO. LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC. AND
`APPLE, INC.
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`Petitioners
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`v.
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`NEONODE SMARTPHONE LLC,
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`Patent Owner
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`Case IPR2021-00144
`U.S. Patent No. 8,095,879
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`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
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`Petitioners’ Request for Oral Argument
`IPR2021-00144 (U.S. Patent No. 8,095,879)
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`Pursuant to 37 C.F.R. § 42.70(a), Petitioners hereby submit this Request for
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`Oral Argument on all of the instituted grounds of unpatentability of claims 1–6 and
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`12-17 of U.S. Patent No. 8,095,879. Petitioners request that the oral argument take
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`place virtually via remote video conference. The Board has already scheduled the
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`hearing for September 6, 2022. See Paper 27, p. 11.
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`At the oral arguments, Petitioners request (without waiving consideration of
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`any issue not listed below) to address the following issues:
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`1. Whether claims 1, 2, 4, 5, and 14–17 are unpatentable over Hirayama307
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`(EX1006) in view of Ren (EX1004) pursuant to 35 U.S.C. §103;
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`2. Whether claim 3 is unpatentable over Hirayama307 (EX1006) in view of
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`Ren (EX1004) and Hirayama878 (EX1009) pursuant to 35 U.S.C. §103;
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`3. Whether claims 6 and 13 are unpatentable over Hirayama307 (EX1006) in
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`view of Ren (EX1004) and Allard (EX1010) pursuant to 35 U.S.C. §103;
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`4. Whether claim 12 is unpatentable over Hirayama307 (EX1006) in view of
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`Ren (EX1004) and Henckel (EX1013) pursuant to 35 U.S.C. §103;
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`5. Any claim construction issues;
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`6. Any procedural and/or evidentiary issues;
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`7. Rebuttal to Patent Owner's presentation on all matters; and
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`Petitioners’ Request for Oral Argument
`IPR2021-00144 (U.S. Patent No. 8,095,879)
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`8. Any additional issues on which the Board seeks clarification.
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`Petitioner requests one hour per side of oral argument time to address the
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`above issues.
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`Dated: July 22, 2022
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`Respectfully Submitted,
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`/David L. Holt/
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`W. Karl Renner, Reg. No. 41,265
`David L. Holt, Reg. No. 65,161
`Tiffany C. Miller, Reg. No. 52,032
`James M. Heintz, Reg. No. 41,828
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`Attorneys Petitioner
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`CERTIFICATE OF SERVICE
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`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e), that service
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`was made on the Patent Owner as detailed below:
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`Date of Service:
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`July 22, 2022
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`Manner of Service:
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`Electronic Mail
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`Kenneth J. Weatherwax
`Nathan Lowenstein
`Parham Hendifar
`Vinson Lin
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`Philip Graves
`weatherwax@lowensteinweatherwax.com
`lowenstein@lowensteinweatherwax.com
`hendifar@lowensteinweatherwax.com
`lin@lowensteinweatherwax.com
`Neonode_IPRs@lowensteinweatherwax.com
`philipg@hbsslaw.com
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`Documents Served:
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`Petitioners’ Request for Oral Argument
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`/Crena Pacheco/
`Crena Pacheco
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(617) 956-5938
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