`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`JUNIPER NETWORKS INC.,
`RUCKUS WIRELESS, INC.,
`BROCADE COMMUNICATION SYSTEMS, INC.,
`and NETGEAR, INC.,
`Petitioners,
`
`v.
`
`CHRIMAR SYSTEMS, INC.,
`Patent Owner.
`
`Case IPR2016-013971
`U.S. Patent No. 9,019,838 B2
`
`PATENT OWNER’S REQUEST FOR ORAL HEARING
`
`1 Ruckus Wireless, Inc., Brocade Communication Systems, Inc. and Netgear, Inc.
`
`(“Ruckus et al.”) filed a petition in (now terminated) IPR2017-00720, and Ruckus
`
`et al. has been joined to the instant proceeding.
`
`
`
`Case No.: IPR2016-01397
`Patent No.: 9,019,838
`
`Atty. Dkt. No.: CHRMC0111IPR1
`
`Pursuant to 37 C.F.R. § 42.70(a), Patent Owner Chrimar Systems, Inc.
`
`(“Chrimar”) request an oral hearing in IPR Nos. IPR2016-01389; IPR2016-
`
`01391; IPR2016-01397; and IPR2016-01399. The Board has set Due Date 7 for
`
`August 31, 2017 at 1:00 P.M. EDT for these IPRs.
`
`( Paper 22 at 3.) Chrimar
`
`requests (with no intent to waive consideration of any issue not requested below)
`
`a total of 120 minutes for Chrimar to address the following issues at the oral
`
`hearing for these IPRs:
`
`1. The alleged unpatentability of claims 31, 35, 36, 40, 43, 52, 55, 56,
`
`59, 60 and 65 of U.S. Patent No. 8,155,012 in view of the references
`
`relied upon in the Petition in IPR2016-01389;
`
`2. The alleged unpatentability of claims 1, 5, 31, 43, 70, 72, 74, 75, 83,
`
`103, 104, 111, 123, and 125 of U.S. Patent No. 8,942,107 in view of
`
`the references relied upon in the Petition in IPR2016-01391;
`
`3. The alleged unpatentability of claims 1, 2, 7, 26, 29, 38, 39, 40, 47,
`
`55, and 69 of U.S. Patent No. 9,019,838 in view of the references
`
`relied upon in the Petition in IPR2016-01397;
`
`4. The alleged unpatentability of claims 1, 31, 37, 59, 69, 72, 73, 106,
`
`112, 134, 142, and 145 of U.S. Patent No. 8,902,760 in view of the
`
`references relied upon in the Petition in IPR2016-01399;
`
`1
`
`
`
`Case No.: IPR2016-01397
`Patent No.: 9,019,838
`
`Atty. Dkt. No.: CHRMC0111IPR1
`
`5. Chrimar’s motion to exclude;
`
`6. Chrimar’s motion for observation;
`
`7. Responses to any issues specified by Petitioners; and
`
`8. Any additional issues on which the Board seeks clarification.
`
`Chrimar also request the ability to use audio/visual equipment to display
`
`demonstrative exhibits,
`
`including the use of a projector and screen for a
`
`PowerPoint display.
`
`In accordance with the Trial Practice Guide, 77 Fed. Reg. at
`
`48768, Chrimar will contact the Board Trial Division paralegal at the appropriate
`
`time to discuss this request.
`
`Dated: July 28, 2017
`
`Respectfully submitted,
`
`/Thomas A. Lewry/
`Frank A. Angileri (Reg. No. 36,733)
`Thomas A. Lewry (Reg. No. 30,770)
`Marc Lorelli (Reg. No. 43,759)
`Christopher C. Smith (Reg. No. 59,669)
`Brooks Kushman P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`(248) 358-4400
`
`Richard W. Hoffmann (Reg. No. 33,711)
`Reising Ethington PC
`755 West Big Beaver Rd., Suite 1850
`Troy, Michigan 48084
`248.786.0163
`
`Attorneys for Patent Owner
`
`2
`
`
`
`Case No.: IPR2016-01397
`Patent No.: 9,019,838
`
`Atty. Dkt. No.: CHRMC0111IPR1
`
`Certificate of Service
`
`On July 28, 2017, a copy of this PATENT OWNER’S REQUEST FOR
`ORAL HEARING has been served on Petitioner’s counsel via electronic mail at
`the email addresses shown below:
`
`Lead Counsel & Back-up Counsel for Juniper
`Nima Hefazi Reg. No. 63,658
`Jonathan Kagan, pro hac vice pending
`nhefazi@irell.com
`jkagan@irell.com
`Postal and Hand-Delivery Address:
`Postal and Hand-Delivery Address:
`IRELL & MANELLA, LLP
`IRELL & MANELLA, LLP
`840 Newport Center Drive, Suite 400
`1800 Avenue of the Stars, Suite 900
`Newport Beach, CA 92660
`Los Angeles, CA 90067
`Juniper-ChrimarIPR@irell.com
`Juniper-ChrimarIPR@irell.com
`
`Lead Counsel & Back up Counsel for Ruckus Wireless, Inc., Brocade
`Communication Systems, Inc., & Netgear, Inc.
`Joseph Powers (Reg. No. 47,006)
`Christopher Tyson (Reg. No. 63,850)
`Duane Morris LLP
`Duane Morris LLP
`30 South 17th Street
`505 9th St. NW, Ste 1000
`Philadelphia PA 19103-4196
`Washington DC 20004
`JAPowers@duanemorris.com
`CJTyson@duanemorris.com
`
`Matthew S. Yungwirth
`DUANE MORRIS LLP
`1075 Peachtree Street, NE
`Suite 2000
`Atlanta, Georgia 30309
`msyungwirth@duanemorris.com
`
`Respectfully submitted,
`/Thomas A. Lewry/
`Brooks Kushman P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`(248) 358-4400
`Attorneys for Patent Owner
`
`3
`
`
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