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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.,
`Petitioner
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`v.
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`ZENTIAN LIMITED,
`Patent Owner
`_________________
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`Inter Partes Review Case No. IPR2023-00037
`U.S. Patent No. 10,971,140
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`Inter Partes Review Case No. IPR2023-00037
`U.S. Patent No. 10,971,140
`Pursuant to the Board’s June 12, 2023, Scheduling Order (Paper 11),
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`Petitioner respectfully requests oral argument for the trial currently scheduled on
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`March 13, 2024. Petitioner requests a total of forty-five (45) minutes of argument
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`time for each Party. Petitioner proposes holding the hearing in-person at the San Jose
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`regional Patent Office. Petitioner has conferred with counsel for Patent Owner, who
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`agrees to this in-person argument request.
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`Alternative Proposal for Oral Argument
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`If the Board is inclined to consider an alternative proposal for the oral
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`argument, Petitioner proposes that this argument for the ’140 Patent (IPR2023-
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`00037) be consolidated with the argument for the related patent, USPN 7,587,319
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`(IPR2023-00033), currently scheduled for March 11, 2024.
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`Many of the issues argued by both Parties in the briefing overlap between the
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`two IPRs. There are some arguments distinct to a respective one of the IPRs (e.g.,
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`Patent Owner’s argument for the ’140 Patent, IPR2023-00037, regarding
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`Limitations 1(d)-1(e) at Paper 19, 28-36), but Petitioner submits that these distinct
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`issues can be identified in an organized manner during the consolidated argument.
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`Petitioner submits that a consolidated argument would be the most efficient use of
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`the Board’s resources and prevent duplicative hearing transcripts.
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`1
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`Inter Partes Review Case No. IPR2023-00037
`U.S. Patent No. 10,971,140
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`Petitioner proposes a total argument time of sixty (60) minutes for each Party
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`for the consolidated argument, and that the argument be scheduled for March 11,
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`2024. If the consolidated argument is scheduled for March 11, 2024, then this allows
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`the argument for USPN 10,839,789 (IPR2023-00036) currently scheduled for March
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`13, 2024, to remain on its scheduled date. Thus, the argument for IPR2023-00036
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`would remain on March 13, 2024, such that the Board and Parties would have a
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`single argument on March 13th for the ’789 Patent and a single consolidated
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`argument on March 11th for the ’319 and ’140 Patents.
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`The below table provides Petitioner’s proposal for the five arguments related
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`to the Apple v. Zentian set of IPRs:
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`2
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`Inter Partes Review Case No. IPR2023-00037
`U.S. Patent No. 10,971,140
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`Pursuant to 37 C.F.R. § 42.70(a), Petitioner specifies the following issues,
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`without intent to waive consideration of any issue not requested, to be argued for this
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`proceeding:
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`1. Whether Claims 1-3, 5, and 7-8 are obvious over U.S. Patent No.
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`6,374,219 to Jiang (“Jiang”) and U.S. Patent No. 5,428,803 to Chen, et al. (“Chen”);
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`2. Whether Claims 1-3, 5, and 7-8 are obvious over Jiang, Chen, and U.S.
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`Patent Application Publication No. 2001/0053974 to Lucke, et al. (“Lucke”);
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`3. Whether Claim 4 is obvious over Jiang, Chen, and U.S. Patent No.
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`5,983,180 to Robinson (“Robinson”);
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`4. Whether Claim 4 is obvious over Jiang, Chen, Lucke, and Robinson;
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`5. Whether Claim 6 is obvious over Jiang, Chen, and U.S. Patent No.
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`5,036,539 to Wrench, Jr., et al. (“Wrench”);
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`6. Whether Claim 6 is obvious over Jiang, Chen, Lucke, and Wrench;
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`7.
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`Any claim constructions, unpatentability grounds, or other issues raised in
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`the Petition or Petitioner Reply, the Patent Owner Preliminary Response, the Patent
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`Owner Response, the Patent Owner Sur-Reply, or the Board’s Institution Decision;
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`8.
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`Any issues regarding motions to exclude or motions to strike that may be
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`filed or pending; and
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`9.
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`Any issues otherwise raised by the Board.
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`3
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`Inter Partes Review Case No. IPR2023-00037
`U.S. Patent No. 10,971,140
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`Respectfully submitted,
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`BY: /s/
`Jennifer C. Bailey
`Jennifer C. Bailey, Reg. No. 52,583
`Adam P. Seitz, Reg. No. 52,206
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`COUNSEL FOR PETITIONER
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`4
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`Inter Partes Review Case No. IPR2023-00037
`U.S. Patent No. 10,971,140
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`CERTIFICATE OF SERVICE ON PATENT OWNER
`UNDER 37 C.F.R. § 42.6
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on January 19,
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`2024, the foregoing Petitioner’s Request for Oral Argument was served via
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`electronic filing with the Board and via Electronic Mail on the following
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`practitioners of record for Patent Owner:
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`Peter C. Knops (peter@noroozipc.com)
`Kayvan B. Noroozi (kayvan@noroozipc.com)
`Katherine Rhoades (katherine.rhoades@bartlitbeck.com)
`Nevin Gewertz (nevin.gewertz@bartlitbeck.com)
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`BY: /s/
`Jennifer C. Bailey
`Jennifer C. Bailey, Reg. No. 52,583
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`COUNSEL FOR PETITIONER
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`5
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