`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TCT MOBILE (US), INC.; TCT MOBILE (US) HOLDINGS, INC.;
`HUIZHOU TCL MOBILE COMMUNICATION CO. LTD.; AND TCL
`COMMUNICATION, INC.,
`Petitioners
`
`v.
`
`FUNDAMENTAL INNOVATION SYSTEMS INTERNATIONAL LLC,
`Patent Owner
`
`U.S. Patent No. 7,834,586
`Issue Date: November 16, 2010
`Title: MULTIFUNCTIONAL CHARGER SYSTEM AND METHOD
`
`Case No. IPR2021-00599
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`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`PO Box 1450
`Alexandria, Virginia 22313–1450
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`
`
`Pursuant to 37 C.F.R. § 42.70 and the Board’s Scheduling Order dated
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`August 7, 2021 (Paper No. 9), Petitioners TCT Mobile (US), Inc.; TCT Mobile
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`(US) Holdings, Inc.; Huizhou TCL Mobile Communication Co. Ltd.; and TCL
`
`Communication, Inc. (“Petitioners”) request Oral Argument on issues related to the
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`patentability of claims 1-2 and 8-9 of U.S. Patent No. 7,834,586.
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`Petitioners request to present arguments on the following issues:
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` All grounds on which trial was instituted, including all issues raised
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`by the parties’ papers;
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` Any issue raised by either party in a motion to exclude (if any),
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`objections to demonstrative exhibits (if any), or any other motion or
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`paper filed by either party before oral argument;
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` Rebuttal to any issue raised by either party in its presentation at the
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`oral argument; and
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` Any additional issue on which the Board seeks clarification.
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`In the Scheduling Order dated August 27, 2021 (Paper No. 9), the Board
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`scheduled Oral Argument for June 7, 2022. Petitioners respectfully propose that
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`they be provided 45 minutes of argument time, inclusive of any rebuttal time
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`Petitioners wish to reserve at the hearing.
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`1
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`
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`Petitioners also respectfully request the ability to use audio-visual equipment
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`to display demonstratives and exhibits, including the use of a computer, a projector,
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`an overhead projector (“Elmo”), and a screen.
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`To the extent the Oral Argument is conducted remotely by video or telephone,
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`Petitioners respectfully request permission to file their demonstratives with the
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`Board and to refer to their demonstratives during argument.
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`Dated: April 18, 2022
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`Respectfully submitted,
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`By:
`/Jeffrey Johnson/
`
`Jeffrey Johnson, Reg. No. 53,078
`Email: 3J6PTABDocket@orrick.com
`609 Main Street, 40th Floor
`Houston, TX 77002-3106
`Main: (713) 658-6400
`Fax: (713) 658-6401
`
`Robert J. Benson (to be admitted pro hac vice)
`Email: R75PTABDocket@orrick.com
`2050 Main Street, Suite 1100
`Irvine, CA 92614-8255
`Main: (949) 567-6700
`Fax: (949) 567-6710
`Jeremy Jason Lang
`USPTO Reg. No. 73,604
`Email: PTABDocketJJL2@orrick.com
`ORRICK, HERRINGTON & SUTCLIFFE,
`LLP
`1000 Marsh Road
`Menlo Park, CA 94025-1015
`Main: (650) 614-7400
`Fax: (650) 614-7401
`
`Attorneys for Petitioners
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`2
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`
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`CERTIFICATION OF SERVICE ON PATENT OWNER
`The undersigned certifies that on April 18, 2022, a copy of the foregoing
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`was served in its entirety by filing through the Patent Trial and Appeal Board End
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`to End System, as well as via electronic mail, upon the following attorneys of
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`record for the Patent Owner:
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`Hong Annita Zhong
`Jason Sheasby
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067
`
`hzhong@irell.com
`jsheasby@irell.com
`FundamentalIPRs@irell.com
`
`Attorneys for Patent Owner
`Fundamental Innovation Systems International LLC
`
` /Karen Johnson/
` Karen Johnson
`
`