`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`H&S MANUFACTURING COMPANY, INC.
`
`Petitioner,
`v.
`
`OXBO INTERNATIONAL CORPORATION
`
`Patent Owner.
`
`Case No.: IPR2016—00950
`
`US. Patent No. 8,166,739
`
`PETITIONER’S REQUEST FOR ORAL HEARING
`
`PURSUANT TO 37 C.F.R. § 42.70(a)
`
`
`
`In accordance with 37 C.F.R. § 42.70(a), Petitioner I-I&S Manufacturing
`
`Company, Inc. respectfully requests oral argument for all of the issues remaining
`
`in this Inter Partes Review. Oral argument is currently scheduled for Tuesday,
`
`August 1, 2017.
`
`Petitioner submits that one-half hour of oral argument is appropriate to
`
`address the following issues:
`
`(i)
`
`Patentee’s proposed claim constructions of “windrow merger,”
`
`“pickup assembly,” and “material” are not BRI constructions;
`
`(ii)
`
`Patentee’s expert testimony is flawed because it is based on wrong
`
`claim constructions and because it is inconsistent;
`
`(iii) The reasoned rationale for combining the references supports a
`
`finding of obviousness based on the interchangeability of farm
`
`implement components and functions, and the limited number of
`
`available solutions involving mechanical rearrangements of known
`
`components as a product of ordinary skill and common sense in
`
`response to known advantages and market forces.
`
`
`
`Petitioner requests permission to use audio/visual equipment to display
`
`demonstrative exhibits, including a projector and screen for Power Point slides.
`
`Dated:
`
`June 23, 2017
`
`Respectfully submitted,
`
`Brad D. Pedersen
`
`Reg. No. 32,432
`
`:
`
`Attorney for Petitioner
`
`Certificate of Service
`
`I hereby certify that on June 23, 2017, a copy of the foregoing was
`
`electronically served on patent owner at the following addresses:
`
`alagatta@merchantgould.com
`jward@merchantgou1d.com
`sbrunner@rnerchantgould.corn
`gsebald@merchantgould.com
`tjohnson@1nerchantgould.com
`OxboIPR@merchantgouId.com
`
`Dated:
`
`June 23, 2017
`
`Respectfully submitted,
`
`_
`
`Brad D. Pedersen
`
`Reg. No. 32,432
`
`Attorney for Petitioner
`
`
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