`________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`ASSA ABLOY AB, ASSA ABLOY Inc.,
`ASSA ABLOY Residential Group, Inc., August Home, Inc., HID Global
`Corporation, and ASSA ABLOY Global Solutions, Inc.,
`Petitioners,
`
`v.
`CPC Patent Technologies PTY LTD.,
`Patent Owner.
`______________
`Case No. IPR2022-01094
`Patent No. 8,620,039
`______________
`________________________________________________________________
`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
`
`
`
`IPR2022-01094
`Patent No. 8,620,039
`
`Pursuant to 37 C.F.R. § 42.70 and the Board’s Scheduling Order of February
`
`2, 2023 (Paper 20) as modified by the Board’s Revised Scheduling Order of
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`September 8, 2023 (Paper 28) (the “Scheduling Order”), Petitioners ASSA
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`ABLOY AB, ASSA ABLOY Inc., ASSA ABLOY Residential Group, Inc., August
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`Home, Inc., HID Global Corporation, ASSA ABLOY Global Solutions, Inc.,
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`(“Petitioners”) respectfully requests oral argument in connection with this
`
`proceeding (IPR2022-01094). Per the Scheduling Order, the oral argument will
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`take place on November 9, 2023.
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`Petitioners request that oral argument be held virtually by videoconference.
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`Petitioners request sixty (60) minutes in which to present its arguments for
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`both of the consolidated IPR proceedings (IPR2022-01093 and IPR2022-01094).
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`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
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`specifically identified below, Petitioners specify at least the following issues to be
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`argued with respect to both IPR2022-01093 and IPR2022-01094:
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` That per 35 U.S.C. § 103, claims 1, 2, 13, 14, 19, and 20 of U.S.
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`Patent No. 8,620,039 are unpatentable as obvious over Hsu in view of
`
`Sanford;
`
`1
`
`
`
`IPR2022-01094
`Patent No. 8,620,039
` That per 35 U.S.C. § 103, claims 1, 2, 13, 14, 19, and 20 of U.S.
`
`Patent No. 8,620,039 are unpatentable as obvious over Hsu in view of
`
`Sanford and Tsukamura;
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` That per 35 U.S.C. § 103, claims 3, 4, 6-11, 15, 16, and 18 of U.S.
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`Patent No. 8,620,039 are unpatentable as obvious over Sanford in
`
`view of Hsu;
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` That per 35 U.S.C. § 103, claims 3, 4, 6-11, 15, 16, and 18 of U.S.
`
`Patent No. 8,620,039 are unpatentable as obvious over Sanford in
`
`view of Hsu and Tsukamura;
`
` That per 35 U.S.C. § 103, claim 5 of U.S. Patent No. 8,620,039 is
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`unpatentable as obvious over Sanford in view of Hsu and Leu;
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` That per 35 U.S.C. § 103, claim 5 of U.S. Patent No. 8,620,039 is
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`unpatentable as obvious over Sanford in view of Hsu, Tsukamura, and
`
`Leu;
`
` That per 35 U.S.C. § 103, claim 12 of U.S. Patent No. 8,620,039 is
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`unpatentable as obvious over Sanford in view of Hsu and Houvener;
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` That per 35 U.S.C. § 103, claim 12 of U.S. Patent No. 8,620,039 is
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`unpatentable as obvious over Sanford in view of Hsu, Tsukamura, and
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`Houvener;
`
`2
`
`
`
`IPR2022-01094
`Patent No. 8,620,039
` That per 35 U.S.C. § 103, claim 17 of U.S. Patent No. 8,620,039 is
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`unpatentable as obvious over Sanford in view of Hsu and McCalley;
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` That per 35 U.S.C. § 103, claim 17 of U.S. Patent No. 8,620,039 is
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`unpatentable as obvious over Sanford in view of Hsu, Tsukamura, and
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`McCalley;
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` Any claim constructions, unpatentability grounds, or other issues
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`raised in the Petition or Petitioner Reply, the Patent Owner
`
`Preliminary Response, the Patent Owner Response, the Patent Owner
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`Sur-Reply, or the Board’s Institution Decision;
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` Rebuttal to issues raised by Patent Owner;
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` Any other motions filed by either party; and
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` Any other issues that the Board deems necessary for issuing a final
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`written decision in this proceeding.
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`Dated: September 14, 2023
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`Respectfully Submitted,
`
`/ Dion M. Bregman /
`Dion M. Bregman, Reg. No. 45,645
`
`3
`
`
`
`IPR2022-01094
`Patent No. 8,620,039
`
`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e)(4), it is hereby certified that on
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`September 14, 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)
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`Dated: September 14, 2023
`
` / Dion M. Bregman /
`Dion M. Bregman
`
`4
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`