`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`VOLKSWAGEN GROUP OF AMERICA, INC., MAZDA MOTOR
`OF AMERICA, INC., SUBARU OF AMERICA, INC., and
`VOLVO CAR USA, LLC,1
`Petitioner
`
`v.
`
`STRATOSAUDIO, INC.
`Patent Owner
`_____________________
`
`Case IPR2021-00716
`U.S. Patent No. 8,688,028
`_____________________
`
`
`PETITIONER VOLKSWAGEN GROUP OF AMERICA, INC.’S REQUEST
`FOR ORAL ARGUMENT
`
`
`
`
`Mail Stop “Patent Board”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`1 Mazda Motor of America, Inc., Subaru of America, Inc., and Volvo Car
`USA, LLC filed a motion for joinder and a petition in Case IPR2022-00204, which
`were granted, and, therefore, have been joined as petitioners in this proceeding.
`
`
`
`Case IPR2021-00716
`U.S. Patent No. 8,688,028
`Pursuant to 37 C.F.R. § 42.70 and the Board’s October 25, 2021 Scheduling
`
`Order (Paper 17), Petitioner Volkswagen Group of America, Inc. (“Petitioner”)
`
`respectfully requests oral argument, which is currently scheduled for July 21, 2022.
`
`Petitioner believes that one hour is an appropriate argument time for each side at
`
`the oral hearing in this case.
`
`Petitioner specifies the following issues to be argued:
`
`• The unpatentability of claims 11, 14-16, and 18 of U.S. Patent No.
`
`8,688,028 (“the ’028 patent”) as anticipated by Takahisa;
`
`• The unpatentability of claims 11, 14-16, and 18 of the ’028 patent as
`
`obvious over Mackintosh;
`
`• Any issues identified in Patent Owner’s Request for Oral Argument;
`
`• Rebuttal to Patent Owner’s presentation on all matters;
`
`• Any other issues raised in papers filed in this proceeding, including
`
`issues raised in papers yet to be filed, such as any Motions to Exclude
`
`and Oppositions to Motions to Exclude; and
`
`• Any other outstanding motions and pleadings, and other issues that
`
`the Board deems necessary for issuing a Final Written Decision.
`
`
`
`- 1 -
`
`
`
`Case IPR2021-00716
`U.S. Patent No. 8,688,028
`Petitioner recognizes that circumstances may require a telephonic hearing in
`
`light of the ongoing COVID-19 pandemic, subject to the Board’s guidance. If the
`
`oral argument will be live, Petitioner asks that it be held at USPTO headquarters
`
`in Alexandria, Virginia, since Petitioner’s counsel is located in Washington DC.
`
`If the hearing is conducted live, Petitioner also requests the ability to use audio-
`
`visual equipment to display possible demonstratives and exhibits, including the use
`
`of an ELMO, computer, projector, and screen.
`
`Respectfully submitted,
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`/Ryan C. Richardson, Reg. No. 67,254/
`
`Ryan C. Richardson
`Registration No. 67,254
`Counsel for Petitioner
`
`Date: June 13, 2022
`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`(202) 371-2600
`
`
`
`- 2 -
`
`
`
`Case IPR2021-00716
`U.S. Patent No. 8,688,028
`CERTIFICATION OF SERVICE
`
`The undersigned hereby certifies that a true and correct copy of the
`
`foregoing PETITIONER VOLKSWAGEN GROUP OF AMERICA, INC.’S
`
`REQUEST FOR ORAL ARGUMENT was served electronically via e-mail on
`
`June 13, 2022, in its entirety on the following parties:
`
`Counsel for Patent Owner StratosAudio, Inc.
`John Scheibeler (Lead Counsel)
`jscheibeler@whitecase.com
`Jonathan Lamberson (Backup Counsel)
`jonathan.lamberson@whitecase.com
`Ashley T. Brzezinski (Backup Counsel)
`ashley.brzezinski@whitecase.com
`Hallie Kiernan (Backup Counsel) Hallie.kiernan@whitecase.com
`WCStratosAudioIPR@whitecase.com
`
`Counsel for Petitioners Mazda Motor of America, Inc., Subaru of America,
`Inc., and Volvo Car USA, LLC
`Matthew D. Satchwell (Lead Counsel) matthew.satchwell@dlapiper.com
`Paul R. Steadman (Back-up Counsel) paul.steadman@dlapiper.com
`Lewis E. Hudnell, III (Back-up Counsel)
`lewis@hudnelllaw.com
`Nicolas S. Gikkas (Back-up Counsel) nick@hudnelllaw.com
`DLA-StratosAudio@us.dlapiper.com
`Respectfully submitted,
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`/Ryan C. Richardson, Reg. No. 67,254/
`
`Ryan C. Richardson
`Registration No. 67,254
`Counsel for Petitioner
`
`Date: June 13, 2022
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`(202) 371-2600
`18579850.1
`
`
`
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