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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD., SAMSUNG
`ELECTRONICS AMERICA, INC., AND APPLE INC.
`Petitioner,
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`v.
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` SMART MOBILE TECHNOLOGIES LLC,
`Patent Owner.
`____________
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`Case IPR2022-01248
`Patent 8,842,653 B1
`____________
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`PATENT OWNER SMART MOBILE TECHNOLOGIES LLC’S
`REQUEST FOR ORAL ARGUMENT
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`Pursuant to 37 C.F.R. § 42.70 and the Board’s Scheduling Order (Paper 14),
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`Smart Mobile Technologies LLC (“Patent Owner”) respectfully requests oral
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`argument, as currently scheduled for October 24, 2023.
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`Request For Remote Hearing: Patent Owner respectfully requests a remote
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`hearing in this matter. Should the Board order an in-person hearing, Patent Owner
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`respectfully requests such hearing be held in the San Jose regional office, if
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`convenient for the panel, as all counsel of record for Patent Owner are based in
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`Southern California.
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`Start-Time For Hearing: Patent Owner respectfully requests the hearing (if
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`ordered) commence at 1:00 pm Eastern Time (10:00 am Pacific Time) or later in
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`view of the time difference between Virginia and California.
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`Time Allotment: In view of the multiple issues raised, Patent Owner
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`respectfully requests 1 hour (60 minutes) per side for argument.
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`Reservation Of Time: Patent Owner requests an opportunity to reserve sur-
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`rebuttal time to respond to rebuttal arguments by Petitioner, and an opportunity to
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`provide a closing statement. Compare, e.g., Mangrove Partners Master Fund, Ltd.
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`et al. v. VirnetX, Inc., IPR2015-01046/01047, Paper 60, 2 (PTAB June 2, 2016)
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`(“Both parties may reserve some of their argument time for rebuttal, and Patent
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`Owner will be afforded an opportunity to provide a closing statement along with
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`any rebuttal.”).
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`Issues For Argument: Without waiving any issue not specifically identified,
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`Patent Owner specifies at least the following issues it may discuss at argument:
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` Issues related to the instituted grounds, including, for example, claim
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`construction, anticipation, obviousness, motivation to combine, and
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`reasonable expectation of success;
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` The timeliness of the arguments raised by Petitioner in the proceedings;
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` Any motion to exclude filed by the parties;
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` Any other relevant issues raised in papers filed in this proceeding, including
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`issues raised in papers yet to be filed; and
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` Any other issues that the Board deems necessary for issuing a Final Written
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`Decision, including any questions, rebuttals, or arguments that may arise
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`during the oral argument.
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`The Board’s advance guidance is respectfully solicited as to any questions
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`the Board specifically wishes to be addressed.
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`Equipment: Should the Board order an in-person hearing, Patent Owner
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`requests the ability to use a computer, projector, and screen to display possible
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`demonstratives and exhibits.
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`Respectfully submitted,
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`/ Kenneth J. Weatherwax /
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`Kenneth J. Weatherwax, Reg. No. 54,528
`LOWENSTEIN & WEATHERWAX LLP
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`Date: September 12, 2023
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the following documents were served
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`by electronic service, by agreement between the parties, on the date below:
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`PATENT OWNER SMART MOBILE TECHNOLOGIES LLC’S
`REQUEST FOR ORAL ARGUMENT
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`The names and address of the parties being served are as follows:
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`W. Karl Renner
`Jeremy J. Monaldo
`Hyun Jin In
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`Sangki Park
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`Andrew S. Ehmke
`Clint S. Wilkins
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`IPR39843-0125IP1@fr.com
`jjm@fr.com
`in@fr.com
`spark@fr.com
`kazi@fr.com
`cgreen@fr.com
`axf-ptab@fr.com
`PTABInbound@fr.com
`andy.ehmke.ipr@haynesboone.com
`clint.wilkins.ipr@haynesboone.com
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`Respectfully submitted,
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`/ Robert Pistone /
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`Date: September 12, 2023
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