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`Paper No. 45
`Filed: April 12, 2022
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`QUALCOMM INCORPORATED and
`ZYXEL COMMUNICATIONS CORPORATION1,
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`Petitioners,
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`v.
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`UNM RAINFOREST INNOVATIONS,
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`Patent Owner.
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`PTAB Case No. IPR2021-00375
`Patent 8,265,096 B2
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`PURSUANT TO 37 C.F.R. § 42.70(a)
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`1 ZyXEL Communications Corporation was joined as a petitioner in this
`proceeding based on a petition and motion for joinder filed in IPR2021-00734,
`which were granted.
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`Patent Owner UNM Rainforest Innovations respectfully requests oral
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`argument, which is currently scheduled for May 12, 2022. Patent Owner requests
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`a total of 30 minutes to present its arguments, as well as to reserve a portion of its
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`total time for presenting rebuttal arguments after Petitioner’s presentation.
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`Pursuant to 37 C.F.R § 42.70, and without intending to waive any issue not
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`specifically identified, Patent Owner specifies the following issues to be argued
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`regarding the present IPR:
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`1. The patentability of challenged claims 1–4 and 6–8 of the ’096 Patent with
`respect to each ground set forth in the Petition;
`2. The patentability of the contingent proposed amended claims subject of
`Patent Owner’s Revised Motion to Amend;
`3. The admissibility of the declaration testimony of Petitioner’s expert Dr. Roy;
`4. Any issues subsidiary to the above issues, including, but not limited to,
`publication status, claim construction, priority date, assessment of evidence,
`and admissibility and sufficiency of evidence;
`5. Any other issues raised in papers filed in the present proceeding, including
`issues raised in any papers filed between today and the oral hearing; and
`6. Any other issue raised addressed by Petitioner.
`Patent Owner requests that the Board provide audio-visual equipment to
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`display demonstrative exhibits, including a projector to be connected to a laptop
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`and a screen for displaying documents.
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`Respectfully submitted,
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`/s/ Jay P. Kesan
`Jay P. Kesan, Reg. No. 37,488
`DIMUROGINSBERG, PC
`DGKEYIP GROUP
`1750 Tysons Blvd. Suite 1500
`Tysons Corner, VA 22102
`jkesan@dimuro.com
`Telephone: (703) 289-5118
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`Alfonso Chan, Reg. No. 45,964
`SHORE CHAN LLP
`901 Main Street, Suite 3300
`Dallas, TX 75202
`achan@shorechan.com
`Telephone: (214) 593-9110
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`Attorneys for Patent Owner
`UNM RAINFOREST INNOVATIONS
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`Dated: April 12, 2022
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.6(e)(4) and 42.25(b), the undersigned certifies
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`that on April 12, 2022, a complete copy of the foregoing document was filed
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`electronically through the Patent Trial and Appeal Board’s PTAB E2E System and
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`provided, via electronic service, to the Petitioner by serving the correspondence
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`address of record.
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`Dated: April 12, 2022
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`/s/ Jay P. Kesan
`Jay P. Kesan
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