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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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`SAMSUNG ELECTRONICS CO., LTD. and DELL TECHNOLOGIES INC.
`Petitioners,
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`v.
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`MYPAQ HOLDINGS LTD.
`Patent Owner.
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`Case IPR2022-00311
`U.S. Patent No. 8,477,514
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`Case IPR2022-00311
`Patent 8,477,514
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`Pursuant to 37 C.F.R. § 42.70 and the Board’s May 23, 2022, Scheduling
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`Order (Paper 11), MyPAQ Holdings Ltd. (“Patent Owner”) respectfully requests oral
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`argument, currently scheduled for February 23 and 24, 2023. Patent Owner requests a
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`remote hearing, although Patent Owner can conduct an in-person hearing if that is
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`more convenient for the Board.
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`Reservation Of Time: Patent Owner requests an opportunity to reserve sur-
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`rebuttal time to respond to rebuttal arguments by Petitioner, and an opportunity to
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`provide a closing statement. Compare, e.g., Mangrove Partners Master Fund., Ltd.
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`et al. v. VirnetX Inc., IPR2015-01046/01047, Paper 60, 2 (PTAB June 2, 2016)
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`(“Both parties may reserve some of their argument time for rebuttal, and Patent
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`Owner will be afforded an opportunity to provide a closing statement along with any
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`rebuttal.”)
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`Issues For Argument: Without waiving any issue not specifically identified,
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`Patent Owner specifies at least the following issues it may discuss at argument:
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`• Issues related to the instituted grounds, including, for example, claim
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`construction, anticipation, obviousness, motivation to combine, and
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`reasonable expectation of success;
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`• Any other relevant issues 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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`Case IPR2022-00311
`Patent 8,477,514
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`• Any other issues that the Board deems necessary for issuing a Final
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`Written Decision, including any questions, rebuttals, or arguments that
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`may arise during the oral argument.
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`The Board’s advance guidance is respectfully solicited as to any questions the
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`Board specifically wishes to be addressed.
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`Time For Argument: Patent Owner respectfully requests 60 minutes of total
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`argument time per side. Patent Owner believes that this is a sufficient amount of time
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`to discuss all issues in this case. Patent Owner requests this IPR be argued
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`sequentially with IPR2022-0312 as the patents in both are related and there are
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`overlapping issues and prior art in both proceedings.
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`Equipment: Patent Owner requests teleconference software (e.g., Zoom,
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`Teams, etc.) with the ability to display possible demonstratives and exhibits during
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`the remote hearing.
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`Respectfully submitted,
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`/Stephen McBride/
`Stephen McBride, Reg. No. 78,396
`CARMICHAEL IP, PLLC
`8000 Towers Crescent Dr., 13th Floor
`Tysons, VA 22182
`Counsel for Patent Owner
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`Date: January 6, 2023
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`Case IPR2022-00311
`Patent 8,477,514
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`CERTIFICATE OF SERVICE
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`I hereby certify that on January 6, 2023, I caused a true and correct copy of
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`the foregoing PATENT OWNER’S REQUEST FOR ORAL ARGUMENT to be
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`served on the following counsel of record for Petitioner by electronic mail to the
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`following addresses:
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`Eliot D. Williams (eliot.williams@bakerbotts.com)
`Neil Sirota (neil.sirota@bakerbotts.com)
`Eric J. Faragi (eric.faragi@bakerbotts.com)
`Frank Zhu (frank.zhu@bakerbotts.com)
`Paula Heyman (pheyman@mwe.com
`Brett Thompsen (bthompsen@mwe.com)
`DLSamsung514IPR@BakerBotts.com
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`By:
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`/Stephen McBride/
`Stephen McBride
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