`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.,
`Petitioner
`
`v.
`
`UNILOC 2017 LLC,
`Patent Owner
`
`U.S. Patent No. 8,018,877
`
`Inter Partes Review No.: IPR2019-00701
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`WEST\289921094.1
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`
`
`IPR2019-00701 – Petitioner’s Request for Oral Argument
`
`Pursuant to 37 C.F.R. 42.70(a), Petitioner, Apple Inc. requests oral argument
`
`on the issues set forth below at a place and time set by the Board. Oral argument is
`
`presently scheduled for May 21, 2020 (Paper No. 8, “Scheduling Order”).
`
`Issues to be Presented by Petitioner at Oral Argument:
`
`1.
`
`2.
`
`Proper construction of the relevant claims of the ’877 patent;
`
`Arguments and evidence that claims 1-20 are invalid under
`
`Section 103 over the combination of Kirmse and Chambers;
`
`3.
`
`Arguments and evidence that claims 1-20 are invalid under
`
`Section 103 over the combination of Chambers and RSIP;
`
`4.
`
`Arguments and evidence that claims 1-3, 5-10, 12-17, 19-20 are
`
`invalid under Section 103 over the combination of Cordenier and TURN; and
`
`5.
`
`Rebuttal to Patent Owner’s argument and evidence on all
`
`matters including the issues listed above.
`
`Per the U.S. Patent and Trademark Office’s notice of March 13, 2020,
`
`Petitioner understands that in-person oral hearings have been suspended for the
`
`foreseeable future. If this oral hearing cannot be held in person, Petitioner requests
`
`that the hearing take place via video conference. Petitioner requests the ability to
`
`present demonstratives and exhibits to the Board and the ability to have two of
`
`Petitioner’s counsel attend the video conference from separate locations.
`
`WEST\289921094.1
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`1
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`IPR2019-00701 – Petitioner’s Request for Oral Argument
`
`If this oral hearing can be held in person, Petitioner requests the ability to
`
`use a computer, projector, and screen to display possible demonstratives and
`
`exhibits. Petitioner also requests that two attorneys at Petitioner’s counsel’s table
`
`be allowed to use computers at the hearing (in addition to the counsel making the
`
`argument using his or her computer to show the demonstratives), to avoid the need
`
`for the parties to bring entire paper copies of the record into the hearing room and
`
`to facilitate efficient answering of panel questions.
`
`Dated: April 7, 2020
`
`
`
`Respectfully Submitted,
`
` /Brian K. Erickson 48,895/
`Brian Erickson
`Reg. No. 48,895
`DLA Piper LLP (US)
`401 Congress Avenue, Suite 2500
`Austin, TX 78701
`brian.erickson@dlapiper.com
`Phone: 512-457-7059
`Fax: 512-721-2263
`
`James M. Heintz
`Reg. No. 41,828
`DLA Piper LLP (US)
`11911 Freedom Drive, Suite 300
`Reston, VA 20190
`Jim.heintz@dlapiper.com
`Phone: 703-773-4148
`Fax: 703-773-5200
`Attorneys for Petitioner Apple Inc.
`
`WEST\289921094.1
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`IPR2019-00701 – Petitioner’s Request for Oral Argument
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies service of a copy of this document on the Patent
`
`Owner’s counsel of record pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(b) by
`
`electronic mail to the following:
`
`Ryan Loveless
`Brett Mangrum
`James Etheridge
`Jeffrey Huang
`Etheridge Law Group
`2600 E. Southlake Blvd., Suite 120-324
`Southlake, TX 76092
`ryan@etheridgelaw.com
`brett@etheridgelaw.com
`jim@etheridgelaw.com
`jeff@etheridgelaw.com
`
`/Brian Erickson/
`Brian Erickson, Reg. No. 48,895
`
`Attorney for Petitioner Apple Inc.
`
`Dated: April 7, 2020
`
`WEST\289921094.1
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`3
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