UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE, INC.,
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`Petitioner,
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`v.
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`GUI GLOBAL PRODUCTS, LTD.,
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`Patent Owner.
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`Case IPR2021-00470
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`U.S. Patent No. 10,259,020
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE, INC.,
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`Petitioner,
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`v.
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`GUI GLOBAL PRODUCTS, LTD.,
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`Patent Owner.
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`Case IPR2021-00470
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`U.S. Patent No. 10,259,020
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`Pursuant to 37 C.F.R. § 42.70(a) and the Board’s August 13, 2021, Scheduling
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`Order (Paper 11), Patent Owner, GUI Global Products, Ltd. (“Patent Owner”),
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`requests the opportunity to present oral argument in this matter. The oral argument
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`is scheduled to be held on May 19, 2022. Paper 11 at 11.
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`Related IPR2021-00471 re U.S. Patent 10,259,021, IPR2021-00472 re U.S.
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`Patent 10,562,077, and IPR2021-00473 re U.S. Patent 10,589,320 are currently
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`pending between the same parties as are involved in this proceeding and Patent
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`Owner is concurrently requesting oral argument in these related proceedings, which
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`also have a hearing date scheduled for May 19, 2022. The issues presented for review
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`in IPRs 2021-00471, 2021-00472, and 2021-00473 are substantially similar as those
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`presented for review in this proceeding. Therefore, Patent Owner requests that a
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`single, consolidated hearing for all of these proceedings be conducted for
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`convenience of the parties and the Board. Patent Owner requests a total of 90 minutes
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`per side argument time for the single, consolidated hearing. Alternatively, if the
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`Board does not desire a single, consolidated hearing, then Patent Owner requests a
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`total of 60 minutes per side for the hearing on this IPR 2021-00470.
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`Issues to be addressed during oral argument:
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`1. Whether Petitioner has met its burden of proving that Bohbot and
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`Gundlach render claims 1-3, 5-7, 10, 16, and 19 obvious.
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`2. Whether Petitioner has met its burden of proving that Bohbot,
`IPR2021-00470
`PO Request for Oral Argument
`Page 1
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`Gundlach, and Nishikawa render claim 2 obvious.
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`3. Whether Petitioner has met its burden of proving that Bohbot,
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`Gundlach, and Li render claims 4, 18, and 19 obvious.
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`4. Whether Petitioner has met its burden of proving that Bohbot,
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`Gundlach, and Stevinson render claims 8 and 9 obvious.
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`5. Whether Petitioner has met its burden of proving that Bohbot,
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`Gundlach, and Rosener render claim 10 obvious.
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`6. Whether Petitioner has met its burden of proving that that Bohbot,
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`Gundlach, Stevinson, and Iio render claim 17 obvious.
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`7. Whether Petitioner has met its burden of proving that Bohbot,
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`Gundlach, and Diebel render claims 1-3, 5-7, 10, 16, and 19
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`obvious.
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`8. Whether Petitioner has met its burden of proving that Bohbot,
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`Gundlach, Diebel, and Nishikawa render claim 2 obvious.
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`9. Whether Petitioner has met its burden of proving that 4, 18, 19
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`§103: Bohbot, Gundlach, Diebel, and Li render claims 4, 18 and 19
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`obvious.
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`10. Whether Petitioner has met its burden of proving that Bohbot,
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`Gundlach, Diebel, and Stevinson render claims 8 and 9 obvious.
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`11. Whether Petitioner has met its burden of proving that Bohbot,
`IPR2021-00470
`PO Request for Oral Argument
`Page 2
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`Gundlach, Diebel, and Rosener render claim 10 obvious.
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`12. Whether Petitioner has met its burden of proving that Bohbot,
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`Gundlach, Diebel, Stevinson, and Iio render claim 17 obvious.
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`13. Any other issues raised in Petitioner’s Petition.
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`14. Any issues raised in Patent Owner’s Response.
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`15. Whether any matters asserted in Petitioner’s Reply that were not
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`asserted in Petitioner’s Petition should be considered by the Board.
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`Subject to the foregoing, any issues raised in Patent Owner’s Sur-
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`Reply.
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`16. Patent Owner’s and Petitioner’s Motions to Exclude Evidence, if any;
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`17. Rebuttal of any arguments made by Petitioner;
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`18. Any additional issues on which the Board seeks clarification; and
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`19. Response to any issues Petitioner raises in its Request for Oral
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`Argument.
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`Patent Owner respectfully reserves the right to supplement and/or amend the
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`foregoing statement of issues to the extent the Rules permit.
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`Petitioner is the party with the burden of proof and will present first at the
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`oral hearing. Patent Owner will address any issues raised by Petitioner, or
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`questions raised by the Board during presentation.
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`IPR2021-00470
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`PO Request for Oral Argument
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`Page 3
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`Patent Owner understands it is likely that oral argument may be conducted
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`remotely by video or telephone in view of the ongoing COVID-19 coronavirus
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`pandemic. In the event that oral argument is conducted in-person, Patent Owner
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`requests the use of audio/visual equipment to display demonstrative exhibits,
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`including the use of a projector and screen.
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`Date: April 4, 2022
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`Respectfully submitted,
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`/ John J. Edmonds /
`John J. Edmonds, Reg. No. 56,184
`ad Counsel for Patent Owner
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`IPR2021-00470
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`PO Request for Oral Argument
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`Page 4
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`was served on April 4, 2022, by filing this document though the PTAB E2E System
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`as well as by delivering a copy via email directed to the attorneys of record for the
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`Petitioner at the following addresses:
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`patrick@fr.com; rizzolo@fr.com; pacheco@fr.com; Leung@fr.com;
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`kdarby@fr.com; devoto@fr.com; renner@fr.com
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`The parties have agreed to electronic service in this proceeding.
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`Date: April 4, 2022
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`Respectfully submitted,
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`/ John J. Edmonds /
`John J. Edmonds, Reg. No. 56,184
`Lead Counsel for Patent Owner
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`IPR2021-00470
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`PO Request for Oral Argument
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`Page 5
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