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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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`TCT MOBILE (US), INC.; TCT MOBILE (US) HOLDINGS, INC.;
`HUIZHOU TCL MOBILE COMMUNICATION CO. LTD.; AND
`TCL COMMUNICATION, INC.,
`Petitioner,
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`v.
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`FUNDAMENTAL INNOVATION SYSTEMS INTERNATIONAL LLC,
`Patent Owner.
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`___________________
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`Case IPR2021-00599
`Patent No. 7,834,586
`___________________
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`IPR2021-00599
`Patent No. 7,834,586
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`Pursuant to 37 C.F.R. § 42.70(a), Fundamental Innovation Systems
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`International LLC (“Patent Owner”) respectfully requests an oral hearing in this
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`matter. Patent Owner requests each side be allocated 60 minutes of total argument
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`time to address the following issues:
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`1. The patentability of challenged claims 1-2 and 8-9 of the U.S. Pat. No.
`7,834,586 over all grounds asserted in the Petition;
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`2. Respond to any issues raised by Petitioner in its request for oral
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`argument or otherwise presented by the Petitioner;
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`3. Any other relevant issue raised in papers filed in this proceeding,
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`including issues raised in papers yet to be filed; and,
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`4. Any additional issues on which the Board seeks clarification.
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`Patent Owner understands that oral argument will be held on June 7, 2022 per
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`Scheduling Order, Paper 19.
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`Patent Owner requests the ability to use audio/visual equipment to display
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`demonstrative exhibits, including the use of a computer, projector and screen for a
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`PowerPoint display. In accordance with the Trial Practice Guide, 77 Fed. Reg. at
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`48768, Patent Owner will contact the Board Trial Division paralegal to discuss this
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`request.
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`- 2 -
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`IPR2021-00599
`Patent No. 7,834,586
`Dated: April 18, 2022
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`Respectfully submitted,
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`/Hong Zhong/
`H. Annita Zhong (Reg. No. 66,530)
`Jason Sheasby (pro hac vice)
`Irell & Manella LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067
`Tel: (310) 277-1010
`Fax: (310) 203-7199
`Email: HZhong@irell.com
`Email: JSheasby@irell.com
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`- 3 -
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`IPR2021-00599
`Patent No. 7,834,586
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6, the undersigned certifies that on April 18, 2022,
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`a copy of the foregoing document PATENT OWNER’S REQUEST FOR ORAL
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`HEARING has been served in its entirety via e-mail, as agreed, on counsel of
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`record for petitioner at the following address:
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` ORRICK, HERRINGTON & SUTCLIFFE, LLP
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` Jeffrey Johnson, Reg. No. 53,078
`3J6PTABDocket@orrick.com
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`Robert J. Benson
`R75PTABDocket@orrick.com
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`Jeremy Jason Lang
`PTABDocketJJL2@Orrick.com
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`TCL-FISI_OHS@orrick.com
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`/Susan M. Langworthy/
` Susan M. Langworthy
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`- 4 -
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