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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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`UNILOC 2017 LLC,
`Patent Owner.
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`Case IPR2019-00251
`Patent 6,993,049 B2
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`REQUEST FOR ORAL ARGUMENT
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`Pursuant to 37 C.F.R. § 42.70(a) and the Board’s Scheduling Order (Paper
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`Proceeding No.: IPR2019-00251
`Attorney Docket: 39521-0056IP1
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`8), Petitioner1 submits this Request for Oral Argument on all of the instituted
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`grounds against the Challenged Claims of U.S. Patent No. 6,993,049. Petitioner
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`requests 60 minutes for each side (120 minutes total) to present arguments for this
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`proceeding.
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`Specifically, Petitioner requests (without waiving consideration of any issue
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`not listed below) to address the following issues:
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`1. The claim construction of “additional data field,” “inquiry message,” and
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`“broadcasting”;
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`2. The obviousness of claims 11 and 12 in view of Larsson;
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`3. The obviousness of claims 11 and 12 in view of Larsson and BT Core;
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`4. The obviousness of claims 11 and 12 in view of IrOBEX;
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`5. The printed publication status of BT Core and IrOBEX;
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`6. Patent Owner’s improper introduction of new evidence and arguments
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`related to piggybacking in page 19, line 10 to page 20, line 15 of its sur-
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`reply;
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`1 LG Electronics, Inc., who filed a petition in IPR2019-01530, has been joined as a
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`petitioner in this proceeding. LG Electronics v UNILOC 2017, IPR2019-01530,
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`Paper 8 (March 3, 2020).
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`1
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`7. Rebuttal to Patent Owner's presentation on all matters; and
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`Proceeding No.: IPR2019-00251
`Attorney Docket: 39521-0056IP1
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`8. Any additional issues on which the Board seeks clarification.
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`Petitioner also respectfully requests the ability to use audio visual equipment
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`to display demonstrative exhibits, including the use of a projector and screen that
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`connects to a laptop computer. Petitioner’s counsel will use a laptop computer
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`with a VGA-type connector. In addition, Petitioner requests that an ELMO-type
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`projector be made available for use.
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`Dated: March 12, 2020
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`Respectfully submitted,
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`/Jeremy J. Monaldo/
`W. Karl Renner, Reg. No. 41,265
`Jeremy J. Monaldo, Reg. No. 58,680
`Roberto J. Devoto, Reg. No. 55,108
`Fish & Richardson P.C.
`3200 RBC Plaza, 60 South Sixth Street
`Minneapolis, MN 55402
`T: 202-783-5070
`F: 877-769-7945
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`Attorneys for Petitioners
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`2
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`Proceeding No.: IPR2019-00251
`Attorney Docket: 39521-0056IP1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR § 42.6(e)(4), the undersigned certifies that on March 12,
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`2020, a complete and entire copy of this Request for Oral Argument was provided
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`via email, to the Patent Owner by serving the email correspondence addresses of
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`record as follows:
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`Ryan Loveless
`Brett Mangrum
`James Etheridge
`Jeffrey Huang
`Etheridge Law Group
`2600 E. Southlake Blvd., Ste. 120-324
`Southlake, TX 76092
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`ryan@etheridgelaw.com
` brett@etheridgelaw.com
` jim@etheridgelaw.com
` jeff@etheridgelaw.com
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`Email:
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`/Diana Bradley/
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`Diana Bradley
`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`(858) 678-5667
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`3
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