`________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`ASSA ABLOY AB, ASSA ABLOY INC., ASSA ABLOY RESIDENTIAL
`GROUP, INC., AUGUST HOME, INC., HID GLOBAL CORPORATION,
`ASSA ABLOY GLOBAL SOLUTIONS, INC.,
`Petitioners,
`v.
`CPC PATENT TECHNOLOGIES PTY LTD.,
`Patent Owner.
`______________
`Case No. IPR2022-01045
`Patent No. 9,269,208
`______________
`________________________________________________________________
`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
`
`
`
`IPR2022-01045
`Patent No. 9,269,208
`
`Pursuant to 37 C.F.R. § 42.70 and the Board’s Scheduling Order of January
`
`3, 2023 (Paper 22) as modified by the Board’s Revised Scheduling Order of June
`
`12, 2023 (Paper 31) (the “Scheduling Order”), Petitioners ASSA ABLOY AB,
`
`ASSA ABLOY Inc., ASSA ABLOY Residential Group, Inc., August Home, Inc.,
`
`HID Global Corporation, ASSA ABLOY Global Solutions, Inc., (“Petitioners”)
`
`respectfully requests oral argument in connection with this proceeding (IPR2022-
`
`01045). Per the Scheduling Order, the oral argument will take place on September
`
`28, 2023.
`
`Petitioners propose holding the hearing virtually. However, if the Board is
`
`allowing in-person hearings, Petitioners further request the hearing take place in
`
`the USPTO’s Alexandria, Virginia location.
`
`In light of the fact that this hearing will address the unpatentability of two
`
`patents across three IPR Petitions, Petitioners request ninety (90) minutes in which
`
`to present its arguments for all three IPR proceedings (IPR2022-01006; IPR2022-
`
`01045; and IPR2022-01089).
`
`To comply with 37 C.F.R. § 42.70(a)’s requirement that this request “must
`
`specify the issues to be argued,” and without waiving argument on any issue not
`
`specifically identified below, Petitioners specify at least the following issues to be
`
`argued:
`
`1
`
`
`
`IPR2022-01045
`Patent No. 9,269,208
` That per 35 U.S.C. § 103, claims 1, 3-5, and 9 of U.S. Patent No.
`
`9,269,208 are unpatentable as obvious over Bianco in view of
`
`Mathiassen;
`
` That per 35 U.S.C. § 103, claims 2 and 6-7 of U.S. Patent No.
`
`9,269,208 are unpatentable as obvious over Bianco in view of
`
`Mathiassen and further in view of Houvener;
`
` That per 35 U.S.C. § 103, claim 8 of U.S. Patent No. 9,269,208 is
`
`unpatentable as obvious over Bianco in view of Mathiassen and
`
`further in view of Houvener and Richmond;
`
` Any claim constructions, unpatentability grounds, or other issues
`
`raised in the Petition or Petitioner Reply, the Patent Owner
`
`Preliminary Response, the Patent Owner Response, the Patent Owner
`
`Sur-Reply, or the Board’s Institution Decision;
`
` Rebuttal to issues raised by Patent Owner;
`
` Any other motions filed by either party; and
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` Any other issues that the Board deems necessary for issuing a final
`
`written decision in this proceeding.
`
`Dated: July 18, 2023
`
`Respectfully Submitted,
`
`/ Dion M. Bregman /
`Dion M. Bregman, Reg. No. 45,645
`
`2
`
`
`
`IPR2022-01045
`Patent No. 9,269,208
`
`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e)(4), it is hereby certified that on July 18,
`
`2023 an electronic copy of this PETITIONER’S REQUEST FOR ORAL
`
`ARGUMENT, was served via email to Patent Owner’s counsel of record in this
`
`proceeding:
`
`Andrew C. Ryan (ryan@cantorcolburn.com)
`Steven M Coyle (scoyle@cantorcolburn.com)
`Nicholas A. Geiger (ngeiger@cantorcolburn.com)
`
`Dated: July 18, 2023
`
` / Dion M. Bregman /
`Dion M. Bregman
`
`3
`
`