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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`ASSA ABLOY AB, ASSA ABLOY INC., ASSA ABLOY RESIDENTIAL
`GROUP, INC., AUGUST HOME, INC., HID GLOBAL CORPORATION,
`ASSA ABLOY GLOBAL SOLUTIONS, INC.,
`Petitioner,
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`v.
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`CPC PATENT TECHNOLOGIES PTY LTD.,
`Patent Owner.
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`Case IPR2022-01006
`Patent 9,665,705
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`Pursuant to 37 C.F.R. § 42.70 and the Board’s Scheduling Order of
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`December 1, 2022 (Paper 24) as modified by the Board’s Revised Scheduling
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`Order of June 12, 2023 (Paper 36) (the “Scheduling Order”), Patent Owner CPC
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`Patent Technologies Pty Ltd. (“Patent Owner”) respectfully requests oral argument
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`in connection with this proceeding (IPR2022-01006). Per the Scheduling Order,
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`the oral argument will take place on September 28, 2023.
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`Patent Owner proposes holding the hearing virtually. However, if the
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`hearing is held in-person hearings, Patent Owner requests the hearing take place in
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`Alexandria, Virginia.
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`Notwithstanding that the hearing will involve two patents across three
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`proceedings, the relevant issues are common to all three proceedings. For example,
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`all three of the proceedings involve the same limited number of claim elements, the
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`same asserted prior art combination, and the same claim construction disputes.
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`Patent Owner therefore requests forty-five (45) minutes for each side’s arguments
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`for the combined, concurrent hearings for all three IPR proceedings (IPR2022-
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`01006; IPR2022-01045; and IPR2022-01089)).
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`Patent Owner requests, without waiving consideration of any issue not listed
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`below, oral argument to address the following issues:
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`• Whether Claims 1, 3-5, and 9-17 are rendered obvious by Bianco and
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`Mathiassen.
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`1
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`• Whether Claims 2 and 6-7 are Rendered Obvious by Bianco and Mathiassen
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`in view of Houvener.
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`• Whether Claim 8 Is Rendered Obvious by Bianco, Mathiassen, Houvener,
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`and Richmond.
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`• The proper construction of the disputed claim terms.
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`• Any issues raised by Petitioner in its Request For Oral Argument.
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`• Rebuttal to issues raised by Petitioner.
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`• Any other outstanding motions and pleadings, and other issues that the
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`Board deems necessary for issuing a Final Written Decision
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`Patent Owner reserves the right to address any other arguments presented by
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`Petitioner and any other issues about which the Board wishes to hear argument.
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`Dated: July 20, 2023
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`By:
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`2
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`Respectfully submitted,
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`
`
`/Andrew C. Ryan/
`Andrew C. Ryan
`Reg. No. 43,070
`Steven M. Coyle (pro hac vice)
`CANTOR COLBURN LLP
`20 Church Street, 22nd Floor
`Hartford, CT 06103
`Tel: (860) 286-2929
`Fax: (860) 286-0115
`ryan@cantorcolburn.com
`scoyle@cantorcolburn.com
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`Attorneys for Patent Owner
`CPC Patent Technologies Pty Ltd.
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`
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on this 20th
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`day of July, 2023, service of the foregoing document was made on the counsel of
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`record for the Petitioner by filing this document through the PTAB’s P-TACTS
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`platform as well as delivering a copy via electronic mail to the following address:
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`Dion Bregman
`Andrew Devkar
`James J. Kritsas
`Morgan, Lewis & Bockius LLP
`1400 Page Mill Road
`Palo Alto, CA 94304
`HID-IPRs@morganlewis.com
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`Dated: July 20, 2023
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`By:
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`/Andrew C. Ryan/
`Andrew C. Ryan
`Reg. No. 43,070
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`3
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