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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 IPR2022-01094
`Patent 8,620,039
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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 February
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`2, 2023 (Paper 20), Patent Owner CPC Patent Technologies Pty Ltd. (“Patent
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`Owner”) respectfully requests oral argument in connection with this proceeding
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`(IPR2022-01094). Per the Board’s Amended Scheduling Order (Paper 28), the oral
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`argument will take place on November 9, 2023.
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`Patent Owner proposes holding the hearing virtually.
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`The hearing will involve two IPR proceedings directed to the same patent.
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`The relevant issues are common to both proceedings. In particular, both
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`proceedings involve the same limited number of claim elements, the same asserted
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`prior art combination, and the same claim construction disputes. Patent Owner
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`therefore requests forty-five (45) minutes for each side’s arguments for the
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`combined, concurrent hearings for both proceedings (IPR2022-01093, -01094).
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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 3-4, 6-11, 15-16, and 18 are rendered obvious by Sanford
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`and Hsu.
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`• Whether Claims 3-4, 6-11, 15-16, and 18 are rendered obvious by Sanford,
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`Hsu, and Tsukamura.
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`• Whether Claim 5 is rendered obvious by Sanford, Hsu and Leu.
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`• Whether Claim 5 is rendered obvious by Sanford, Hsu, Tsukamura, and Leu.
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`• Whether Claim 12 is rendered obvious by Sanford, Hsu, and Houvener.
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`• Whether Claim 12 is rendered obvious by Sanford, Hsu, Tsukamura, and
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`Houvener.
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`• Whether Claim 17 is rendered obvious by Sanford, Hsu, and McCalley.
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`• Whether Claim 17 is rendered obvious by Sanford, Hsu, Tsukamura, and
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`McCalley.
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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: September 14, 2023
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`By:
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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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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on this 14th
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`day of September, 2023, service of the foregoing document was made on the
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`counsel of record for the Petitioner by filing this document through the PTAB’s
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`P-TACTS platform as well as delivering a copy via electronic mail to the following
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`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: September 14, 2023
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`By:
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`/Andrew C. Ryan/
`Andrew C. Ryan
`Reg. No. 43,070
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