`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`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.,
`Petitioner,
`
`v.
`
`CPC PATENT TECHNOLOGIES PTY LTD.,
`Patent Owner.
`
`
`
`
`
`
`
`
`
`
`
`
`Case IPR2022-01089
`Patent 9,269,208
`
`
`
`
`
`
`
`
`
`
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`
`
`
`
`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”), Patent Owner CPC Patent
`
`Technologies Pty Ltd. (“Patent Owner”) respectfully requests oral argument in
`
`connection with this proceeding (IPR2022-01089). Per the Scheduling Order, the
`
`oral argument will take place on September 28, 2023.
`
`Patent Owner proposes holding the hearing virtually. However, if the
`
`hearing is held in-person hearings, Patent Owner requests the hearing take place in
`
`Alexandria, Virginia.
`
`Notwithstanding that the hearing will involve two patents across three
`
`proceedings, the relevant issues are common to all three proceedings. For example,
`
`all three of the proceedings involve the same limited number of claim elements, the
`
`same asserted prior art combination, and the same claim construction disputes.
`
`Patent Owner therefore requests forty-five (45) minutes for each side’s arguments
`
`for the combined, concurrent hearings for all three IPR proceedings (IPR2022-
`
`01006; IPR2022-01045; and IPR2022-01089).
`
`Patent Owner requests, without waiving consideration of any issue not listed
`
`below, oral argument to address the following issues:
`
`• Whether Claims 10-13 are rendered obvious by Bianco and Mathiassen.
`
`
`
`1
`
`
`
`• The proper construction of the disputed claim terms.
`
`• Any issues raised by Petitioner in its Request For Oral Argument.
`
`• Rebuttal to issues raised by Petitioner.
`
`• Any other outstanding motions and pleadings, and other issues that the
`
`Board deems necessary for issuing a Final Written Decision
`
`Patent Owner reserves the right to address any other arguments presented by
`
`Petitioner and any other issues about which the Board wishes to hear argument.
`
`
`Dated: July 20, 2023
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By:
`
`
`
`Respectfully submitted,
`
`
`
`/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
`
`Attorneys for Patent Owner
`CPC Patent Technologies Pty Ltd.
`
`
`
`
`
`
`
`2
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on this 20th
`
`day of July, 2023, service of the foregoing document was made on the counsel of
`
`record for the Petitioner by filing this document through the PTAB’s P-TACTS
`
`platform as well as delivering a copy via electronic mail to the following address:
`
`Dion Bregman
`Andrew Devkar
`James J. Kritsas
`Morgan, Lewis & Bockius LLP
`1400 Page Mill Road
`Palo Alto, CA 94304
`HID-IPRs@morganlewis.com
`
`Dated: July 20, 2023
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By:
`
`
`
`/Andrew C. Ryan/
`Andrew C. Ryan
`Reg. No. 43,070
`
`
`
`3
`
`
`
`