`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`____________________________________________________
`
`SAMSUNG ELECTRONICS CO. LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Petitioners,
`
`v.
`
`GUI GLOBAL PRODUCTS, LTD.,
`Patent Owner.
`
`____________________________________________________
`
`Case IPR2021-00337
`Patent 10,562,077
`____________________________________________________
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.70(a) and the Board’s July 2, 2021, Scheduling
`
`Order (Paper 12), Patent Owner, GUI Global Products, Ltd. (“Patent Owner”),
`
`requests the opportunity to present oral argument in this matter. The oral argument
`
`is scheduled to be held on April 12, 2022. Paper 12 at 9.
`
`Related IPR2021-00335 re U.S. Patent 10,259,020, IPR2021-00336 re U.S.
`
`Patent 10,259,021, and IPR2021-00338 re U.S. Patent 10,589,320 are currently
`
`pending between the same parties as are involved in this proceeding and Patent
`
`Owner is concurrently requesting oral argument in these related proceedings, which
`
`also have a hearing date scheduled for April 12, 2022. The issues presented for
`
`review in IPRs 2021-00335, 2021-00336, and 2021-00338 are substantially similar
`
`as those presented for review in this proceeding. Therefore, Patent Owner requests
`
`that a single, consolidated hearing for all of these proceedings be conducted for
`
`convenience of the parties and the Board. Patent Owner requests a total of 90 minutes
`
`per side argument time for the single, consolidated hearing. Alternatively, if the
`
`Board does not desire a single, consolidated hearing, then Patent Owner requests a
`
`total of 60 minutes per side for the hearing on this IPR 2021-00337.
`
`Issues to be addressed during oral argument:
`
`1. Whether Petitioner has met its burden of proving that Claims 1-8 of
`
`the ‘077 patent are unpatentable as obvious over Kim.
`IPR2021-00337
`PO Request for Oral Argument
`
`
`Page 1
`
`
`
`
`
`2. Whether Petitioner has met its burden of proving that Claim 11 of
`
`the ‘077 patent is unpatentable as obvious over Kim and Koh.
`
`3. Whether Petitioner has met its burden of proving that Claims 9-10
`
`and 12-13 of the ‘077 patent are unpatentable as obvious over Kim
`
`and Lee.
`
`4.
`
`5.
`
`Any other issues raised in Petitioner’s Petition.
`
`Any issues raised in Patent Owner’s Response.
`
`6. Whether any matters asserted in Petitioner’s Reply that were not
`
`asserted in Petitioner’s Petition should be considered by the Board.
`
`Subject to the foregoing, any issues raised in Patent Owner’s Sur-
`
`Reply.
`
`7.
`
`8.
`
`9.
`
`Patent Owner’s and Petitioner’s Motions to Exclude Evidence, if any;
`
`Rebuttal of any arguments made by Petitioner;
`
`Any additional issues on which the Board seeks clarification; and
`
`10. Response to any issues Petitioner raises in its Request for Oral
`
`Argument.
`
`Patent Owner respectfully reserves the right to supplement and/or amend the
`
`foregoing statement of issues to the extent the Rules permit.
`
`IPR2021-00337
`
`
`
`
`PO Request for Oral Argument
`
`Page 2
`
`
`
`Petitioner is the party with the burden of proof and will present first at the
`
`oral hearing. Patent Owner will address any issues raised by Petitioner, or
`
`questions raised by the Board during presentation.
`
`Patent Owner understands it is likely that oral argument may be conducted
`
`remotely by video or telephone in view of the ongoing COVID-19 coronavirus
`
`pandemic. In the event that oral argument is conducted in-person, Patent Owner
`
`requests the use of audio/visual equipment to display demonstrative exhibits,
`
`including the use of a projector and screen.
`
`Date: March 1, 2022
`
`
`
`Respectfully submitted,
`
`
`/ John J. Edmonds /
`John J. Edmonds, Reg. No. 56,184
`ad Counsel for Patent Owner
`
`
`
`
`
`
`
`IPR2021-00337
`
`
`
`
`PO Request for Oral Argument
`
`Page 3
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`was served on March 1, 2022, by filing this document though the PTAB E2E System
`
`as well as by delivering a copy via email directed to the attorneys of record for the
`
`Petitioner at the following addresses:
`
`Ali.Sharifahmadian@arnoldporter.com
`Jin.Park@arnoldporter.com
`Chris.Moulder@arnoldporter.com;
`Mark.Patrick@arnoldporter.com
`xSamsungGUIIPRAP@arnoldporter.com
`
`
`
`The parties have agreed to electronic service in this proceeding.
`
`Date: March 1, 2022
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/ John J. Edmonds /
`John J. Edmonds, Reg. No. 56,184
`ad Counsel for Patent Owner
`
`
`IPR2021-00337
`
`
`
`
`PO Request for Oral Argument
`
`Page 4
`
`