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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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`CISCO SYSTEMS, INC. AND JUNIPER NETWORKS, INC.,1
`Petitioners,
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`v.
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`ORCKIT CORPORATION,
`Patent Owner.
`____________
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`Case IPR2023-00554
`U.S. Patent No. 10,652,111
`____________
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
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`1 IPR2024-00037 (Juniper Networks, Inc) has been joined with this proceeding.
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`Case IPR2023-00554
`Patent 10,652,111
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`Pursuant to 37 C.F.R. § 42.70 and the Board’s September 20, 2023
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`Scheduling Order (Paper 9), Orckit Corporation (“Patent Owner”) respectfully
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`requests oral argument, currently scheduled for July 9, 2024. Patent Owner
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`requests a remote hearing.
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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.,
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`Ltd. 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
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`identified, Patent Owner specifies at least the following issues it may discuss at
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`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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`• Any other relevant issues raised in papers filed in this proceeding,
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`including issues raised in papers yet to be filed; and
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`1
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`Case IPR2023-00554
`Patent 10,652,111
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`• Any other issues that the Board deems necessary for issuing a Final
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`Written Decision, including any questions, rebuttals, or arguments
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`that may arise 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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`Time For Argument: Patent Owner respectfully requests 60 minutes of total
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`argument time per side. Patent Owner believes that this is a sufficient amount of
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`time to discuss all issues in this case.
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`Equipment: Patent Owner requests teleconference software (e.g., Zoom,
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`Teams, etc.) with the ability to display possible demonstratives and exhibits during
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`the remote hearing. Patent Owner requests a real time audio and/or video stream
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`accessible to members of the public.
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`Respectfully submitted,
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`/Stephen McBride/
`Stephen McBride, Reg. No. 78,396
`CARMICHAEL IP, PLLC
`8607 Westwood Center Drive, Suite 270
`Tysons, VA 22182
`Counsel for Patent Owner
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`Date: May 9, 2024
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`2
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`Case IPR2023-00554
`Patent 10,652,111
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that, pursuant to 37 CFR § 42.6(e), a true
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`and correct copy of the foregoing PATENT OWNER’S REQUEST FOR ORAL
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`ARGUMENT has been served electronically via email on counsel of record for
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`Petitioner:
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`
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`Jeffrey D. Blake
`jblake@merchantgould.com
`alagatta@merchantgould.com
`Andrew J. Lagatta
`OrckitIPR@merchantgould.com
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`kyle.tsui@fischllp.com
`andrew.ramos@fischllp.com
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`Respectfully submitted,
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`By: /Stephen McBride/
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`Stephen McBride
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`Kyle Tsui
`Andrew Ramos
`ipr@fischllp.com
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`Dated: May 9, 2024
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