`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` APPLE INC.,
` Petitioner,
`
` v.
`
` ZENTIAN LTD.,
` Patent Owner.
` ____________________
`
` Case IPR2023-00037
` Patent No. 10,971,140
` ____________________
`
` PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
` IPR2023-00037
` PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
` Pursuant to 37 C.F.R. § 42.70 and the Board’s June 12, 2023
`
` Scheduling Order (Paper 11), Patent Owner respectfully requests an oral
`
` argument on the issues raised in the Petition for Inter Partes Review of U.S.
`
` Patent 10,971,140, Patent Owner’s Response, Petitioner’s Reply to Patent
`
` Owner’s Response, and Patent Owner’s Sur-Reply to the Petitioner’s Reply.
`
` Per the Board’s Scheduling Order (Paper 11), oral argument is currently
`
` scheduled for March 13, 2024.
`
` The parties have conferred and jointly request an in-person oral
`
` argument in the San Jose, California USPTO Regional Office. In addition,
`
` Patent Owner respectfully requests that the argument for IPR2023-00037 be
`
` set on the same day as the arguments for IPR2023-00033 and that the
`
` arguments across all five related IPRs be limited two consecutive days.
`
` Patent Owner does not, however, request or agree to reducing the time
`
` allocated to any argument or to consolidating arguments.
`
` The issues to be argued in IPR2023-00037 are:
`
` ● Whether the claims of U.S. Patent 10,971,140 are unpatentable under
`
` any instituted ground of unpatentability;
`
` ● Any issues identified in Petitioners’ Request for Oral Argument;
`
` ● Rebuttal to Petitioners’ presentation on all matters;
`
` 1
`
`
`
` IPR2023-00037
` PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
` ● Any other issues raised in papers filed in this proceeding, including
`
` issues raised in papers yet to be filed, such as Motions to Exclude; and
`
` ● Any other outstanding motions and pleadings, and other issues that
`
` the Board deems necessary for issuing a Final Written Decision.
`
` Additionally, Patent Owner requests the ability to use audio visual
`
` equipment to display possible demonstratives and exhibits, including the use
`
` of a computer, projector and screen.
`
` Respectfully submitted,
`
` /s/ Kayvan Noroozi
`
` Kayvan Noroozi, Admitted Pro Hac Vice
` Peter C. Knops, Reg. No. 37,659
` peter@noroozipc.com
` N OROOZI PC
` 11601 Wilshire Blvd., Suite 2170
` Los Angeles, CA 90025
` Tel.: 310-975-7074
`
` Date: January 19, 2024
`
` Counsel for Patent Owner
`
` 2
`
`
`
` IPR2023-00037
` PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
` CERTIFICATION OF SERVICE
`
` The undersigned hereby certifies that the foregoing Patent Owner’s
`
` Request for Oral Argument was served electronically via e-mail on
`
` January 19, 2024, on the following counsel of record for Petitioner:
`
` Adam P. Seitz
` Adam.Seitz@eriseip.com
` PTAB@eriseip.com
`
` Jennifer C. Bailey
` Jennifer.Bailey@eriseip.com
`
` Adam M. Sandwell
` Adam.Sandwell@eriseip.com
`
` Erise IP, P.A.
` 7015 College Blvd., Ste. 700
` Overland Park, Kansas 66211
`
` Christina Canino
` Christina.Canino@eriseip.com
`
` Erise IP, P.A.
` 5299 DTC Blvd., Suite 1340
` Greenwood Village, CO 80111
`
` Date: January 19, 2024
`
` /s/ Peter C. Knops
` Peter C. Knops
` Counsel for Patent Owner
`
`
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