`_____________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`QUALCOMM INCORPORATED,
`
`Petitioner,
`
`v.
`
`UNM RAINFOREST INNOVATIONS,
`
`Patent Owner.
`_____________________
`Case IPR2021-00375
`
`Patent No. 8,265,096 B2
`_____________________
`
`
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`PURSUANT TO 37 C.F.R. § 42.70(a)
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.70(a) and the Board’s Second Revised Scheduling
`
`Order dated December 10, 2021 (Paper 29), Petitioner requests oral argument on the
`
`issues set forth below at a time and place set by the Board. Oral argument is currently
`
`scheduled for May 12, 2022.
`
`Oral argument in IPR2021-00377 and IPR2021-00582 also is scheduled for
`
`May 12, 2022. Given the overlap in issues between this proceeding and those two,
`
`particularly with respect to Petitioner’s oppositions to Patent Owner’s motions to
`
`amend, Petitioner requests that the Board hold a consolidated oral argument. If the
`
`Board holds a consolidated oral argument, Petitioner respectfully requests that it and
`
`Patent Owner each be allotted two hours of argument time for a total of four hours
`
`for the consolidated session for all three IPRs. If the Board does not hold a
`
`consolidated argument, Petitioner respectfully requests that it and Patent Owner each
`
`be allotted 45 minutes of argument time for a total of one and a half hours for the
`
`session for the instant IPR only. To the extent that the Board schedules this hearing
`
`to last more or less than the total hearing time requested by Petitioner, Petitioner
`
`requests that it be given half of the total hearing time.
`
`Petitioner respectfully requests oral argument on all issues raised in the
`
`parties’ filings, including but not limited to the following:
`
`1. Whether claims 1–4 and 6–8 of U.S. Patent No. 8,265,096 are
`
`unpatentable based on the grounds on which the Board instituted trial.
`
`
`
`-1-
`
`
`
`2. Whether UNM’s Motion to Amend should be denied.
`
`3. Whether UNM’s “Objection To The Expert Report Of Dr. Roy,” which
`
`UNM filed as a motion to exclude (Paper 39), should be denied.
`
`4. Rebuttal to issues raised by Patent Owner in this proceeding.
`
`5. Any issues specified by Patent Owner in a request for oral argument.
`
`6. Rebuttal to Patent Owner’s presentation on all matters.
`
`7. Any other issues briefed or presented by the parties throughout this
`
`trial.
`
`8. Any other issues that may affect the Board’s determinations in this
`
`proceeding.
`
`Petitioner understands that the Board has been conducting certain hearings by
`
`videoconference. Petitioner agrees to a videoconference for the hearing. If the Board
`
`decides to hold an in-person hearing, Petitioner requests the ability to use a
`
`computer, projector, and screen to display possible demonstratives and exhibits.
`
`Petitioner also asks that three spaces be reserved for counsel at counsel’s table, and
`
`that three additional spaces be reserved in the hearing room to accommodate
`
`additional counsel and corporate representatives. Petitioner also requests that three
`
`attorneys at Petitioner’s counsel’s table be allowed to use computers.
`
`Dated: April 12, 2022
`
`
`
`Respectfully submitted,
`
`
`-2-
`
`
`
`/s/ Jonathan I. Detrixhe
`Lead Counsel
`Jonathan I. Detrixhe (Reg. No. 68,556)
`Reed Smith LLP
`101 Second Street
`Suite 1800
`San Francisco, CA 94105
`Tel: 415.543.8700
`Fax: 415.391.8269
`jdetrixhe@reedsmith.com
` Back‐up Counsel
`Jonah D. Mitchell (admitted pro hac vice)
`Christine M. Morgan (admitted pro hac vice)
`Reed Smith LLP
`101 Second Street
`Suite 1800
`San Francisco, CA 94105
`Tel: 415.543.8700
`Fax: 415.391.8269
`jmitchell@reedsmith.com
`cmorgan@reedsmith.com
` Peter J. Chassman (Reg. No. 38,841)
`Michael J. Forbes (Reg. No. 73,898)
`Reed Smith LLP
`811 Main Street
`Suite 1700
`Houston, TX 77002
`Tel: 713.469.3800
`Fax: 713.469.3899
`pchassman@reedsmith.com
`
`mforbes@reedsmith.com
`
`Counsel for Petitioner
`
`-3-
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6(e)(4) and 42.25(b), the undersigned certifies
`
`that on April 12, 2022, a complete copy of Petitioner’s Request for Oral Argument
`
`was filed electronically through the Patent Trial and Appeal Board’s PTABE2E
`
`System and provided, via electronic service, to the Patent Owner by serving the
`
`correspondence address of record.
`
`Dated: April 12, 2022
`
`Respectfully submitted,
`
`/ Jonathan I. Detrixhe /
`Jonathan I. Detrixhe (Reg. No. 68,556)
`Reed Smith LLP
`101 Second Street
`Suite 1800
`San Francisco, CA 94105
`Tel: 415.543.8700
`Fax: 415.391.8269
`jdetrixhe@reedsmith.com
`
`Counsel for Petitioner
`
`
`
`
`- 4 -
`
`
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