`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`LG ELECTRONICS, INC.,
`Petitioner,
`
`v.
`
`CONSTELLATION DESIGNS, LLC,
`Patent Owner.
`
`Case No. IPR2023-00319
`U.S. Patent No. 10,693,700
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`Case No. IPR2023-00319
`Patent No. 10,693,700
`
`Pursuant to 37 C.F.R. § 42.70(a) and the Board’s July 12, 2023 Scheduling
`
`Order (Paper 11 at 11) (DUE DATE 8), Patent Owner Constellation Designs, LLC
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`respectfully requests an opportunity to present oral arguments before the Board.
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`Oral argument is presently scheduled for April 17, 2024 and Patent Owner states its
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`preference to have its arguments conducted in person at the USPTO headquarters in
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`Alexandria, Virginia.
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`Issues that the Patent Owner may present and address at the hearing include
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`proper construction of the challenged claims, written description support of the
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`challenged claims, Petitioners’ failure to prove the unpatentability of the challenged
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`claims, Petitioners’ Petition and Reply Brief, Petitioners’ Sur-Sur-Reply (if filed),
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`rebuttals to any arguments and record evidence presented by Petitioners, and any
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`additional issues raised by the Board or Petitioners at oral argument.
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`Patent Owner believes that an allocation of forty-five (45) minutes per side
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`will be sufficient. Patent Owner requests at least as much time as requested by
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`Petitioner, but no less than forty-five minutes of argument time.
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`Should the hearing be conducted in person, Patent Owner respectfully
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`requests the ability to use audio/visual equipment to display demonstrative exhibits,
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`including the use of a projector and screen for a PowerPoint Display. Patent Owner
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`requests that at least three spaces be reserved at the oral hearing.
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`1
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`
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`Dated: February 28, 2024
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`Respectfully submitted,
`
`Case No. IPR2023-00319
`Patent No. 10,693,700
`
`/William A. Meunier/
`William A. Meunier (Reg. No. 41,193)
`Michael T. Renaud (Reg. No. 44,299)
`Kevin C. Amendt (Reg. No. 69,361)
`MINTZ, LEVIN, COHN, FERRIS,
`GLOVSKY AND POPEO, P.C.
`One Financial Center
`Boston, MA 02111
`Telephone: 617-542-6000
`Facsimile: 617-542-2241
`E-mails: WAMeunier@mintz.com;
`MTRenaud@mintz.com;
`KCAmendt@mintz.com
`
`2
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`
`
`Case No. IPR2023-00319
`Patent No. 10,693,700
`
`CERTIFICATE OF SERVICE
`
`I certify that a copy of Patent Owner’s Request for Oral Argument is being
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`served by electronic mail on the following counsel of record:
`
`Lead Counsel
`W. Karl Renner
`(Reg. No. 41,265)
`FISH & RICHARDSON P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Telephone: (202) 783-5070
`Facsimile: (877) 769-7945
`Email: IPR19688-0196IP2@fr.com
`
`Backup Counsel
`Jeremy J. Monaldo (Reg. No. 58,680)
`Patrick Darno (Reg. No. 69,205)
`Usman Khan (Reg. No. 70,439)
`FISH & RICHARDSON P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Telephone: (202) 783-5070
`Facsimile: (877) 769-7945
`Email: PTABInbound@fr.com
`
`Dated: February 28, 2024
`
`/William A. Meunier/
`William A. Meunier (Reg. No. 41,193)
`
`3
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