`Patent No. 8,688,028
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`HYUNDAI MOTOR AMERICA,
`Petitioner
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`v.
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`STRATOSAUDIO, INC.,
`Patent Owner
`
`____________________
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`Case No. IPR2021-01303
`Patent No. 8,688,028
`____________________
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`
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`Case No. IPR2021-01303
`Patent No. 8,688,028
`Petitioner Hyundai Motor America ( “Petitioner”) respectfully requests oral
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`argument in connection with IPR2021-01303 for U.S. Patent No. 8,688,028 (“the
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`’028 Patent”). Given its similarity to IPR2021-01305 for U.S. Patent No.
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`8,903,307 (“the ’307 Patent”), Petitioner respectfully requests that IPR2021-01303
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`and IPR2021-01305 be heard together. Pursuant to 37 C.F.R. § 42.70, Petitioner
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`specifies the following issues to be argued:
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`•
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`Grounds for which inter partes review was instituted for the ’028 and
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`’307 Patents and any issue raised in the Board’s Institution Decisions (Paper 9),
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`instituting review on all claims and grounds presented in the Petitions;
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`•
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`Any issue addressed in Petitioner’s papers, including but not limited
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`to the Petitions and Petitioner’s Reply Briefs;
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`•
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`Rebuttal to Patent Owner’s presentation on all issues, including the
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`issues identified above and any issues raised in Patent Owner’s Responses and
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`exhibits cited therein.
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`•
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`•
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`Any issues raised by the Board or Patent Owner at oral argument;
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`Any other issues raised in papers filed in these proceedings, including
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`issues raised in papers yet to be filed; and
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`•
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`Any other issues that the Board deems necessary for issuing final
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`written decisions.
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`Pursuant to the Scheduling Order (Paper 10 at 11) the oral hearing for these
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`1
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`
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`Case No. IPR2021-01303
`Patent No. 8,688,028
`cases, IPR2021-01303 and IPR2021-01305, are currently scheduled for October
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`24, 2022. Petitioner requests 60 minutes per side for oral argument total on the
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`two proceedings, and expressly reserves the right to use a portion of its time for
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`rebuttal. Petitioner respectfully requests a video hearing for these proceedings.
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`Respectfully Submitted,
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`/s/ Ryan K. Yagura
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`Ryan K. Yagura (Reg. No. 47,191)
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`2
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`CERTIFICATE OF SERVICE
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`The undersigned certifies pursuant to 37 C.F.R. § 42.6(e) and § 42.105 that on
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`September 13, 2022, a true and correct copy of PETITIONER’S REQUEST FOR
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`ORAL ARGUMENT was served in its entirety by filing this document through the
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`PTAB E2E System, as well as by email, on the counsel of record for the Patent Owner.
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`
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`John Scheibeler, Reg. No. 35,346
`White & Case LLP
`1221 Avenue of the Americas
`New York, NY 10020-1095
`Phone: 212-819-8200
`jscheibeler@whitecase.com
`
`Ashley T. Brzezinski, Reg. No.
`58,651
`White & Case LLP
`75 State Street
`Boston, MA 02109
`Phone: 617-979-9344
`ashley.brzezinski@whitecase.com
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`Jonathan Lamberson, Reg. No. 57,352
`White & Case LLP
`2 Palo Alto Square, Suite 900
`3000 El Camino Real
`Palo Alto, California 94306-2109
`Phone: 650-213-0384
`jonathan.lamberson@whitecase.com
`
`Hallie Kiernan
`White & Case LLP
`1221 Avenue of the Americas
`New York, NY 10020-1095
`Phone: 212-819-8200
`hallie.kiernan@whitecase.com
`WCStratosAudioIPR@whitecase.com
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`
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`Respectfully submitted,
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`By: /s/ Ryan K. Yagura
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`Ryan K. Yagura (Reg. No. 47,191)
`O’Melveny & Myers LLP
`400 South Hope Street, 18th Floor
`Los Angeles, CA 90071
`Telephone: (213) 430-6000
`E-Mail: ryagura@omm.com
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`
`Attorney for Petitioner Hyundai Motor
`America
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`3
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