`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`GARMIN INTERNATIONAL, INC. ET AL.
`Petitioner
`
`v.
`
`Patent of CUOZZO SPEED TECHNOLOGIES LLC
`Patent Owner
`____________
`
`
`
`IPR2012-00001
`
`Case:
`
`
`
`Patent No.:
`
`6,778,074
`
`
`
`
`
`
`
`Filed:
`
`Issued:
`
`Inventors:
`
`Title:
`
`March 18, 2002
`
`August 17, 2004
`
`Giuseppe A. Cuozzo
`
`Speed Limit Indicator and Method for Displaying Speed and
`the Relevant Speed Limit
`
`Docket No.:
`
`CUO0001-RE
`
`____________
`
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`Case No.: IPR2012-00001
`
`Patent No: 6,778,074
`Cuozzo Speed Technologies LLC (“Patent Owner”) hereby requests the
`
`Attorney’s Docket No.: CUO0001-RE
`Page 1
`
`
`
`opportunity to have an oral argument at the Board pursuant to 37 C.F.R. § 42.70.
`
`
`
`ISSUES TO BE ARGUED
`
`
`
`The Proper Construction of “Integrally Attached” is “Joined or
`Combined to Work as a Complete Unit.”
`
`Cuozzo Antedates Aumayer and Awada.
`
`Alleged Combinations Do Not Disclose All Elements of Claim 10 and
`There Is No Motivation to Combine the Cited References.
`
`Should the Board Determine that Claims 10, 14 and 17 are Unpatentable,
`Patent Owner’s Motion to Amend Should be Granted.
`
`
`a. Substitute Claims 21-23 are Narrower in Scope than Original
`Claim 10.
`b. Substitute Claims 21-23 are Fully Supported by the Original
`Disclosure.
`c. Substitute Claims 21-23 are Patentable Over Nagoshi in view of
`Vaughn.
`
`
`Should the Board Confirm the Patentability of Claims 10, 14 And 17,
`Good Cause Exists for Entry of Claims 21-23 to Further Define the
`Invention.
`
`
`
`I.
`
`II.
`
`III.
`
`IV.
`
`V.
`
`
`
`
`
`Case No.: IPR2012-00001
`Patent No: 6,778,074
`
`
`
`Attorney’s Docket No.: CUO0001-RE
`Page 2
`
`
`
`CONCLUSION
`
`In light of these remark, Patent Owner respectfully requests the opportunity to
`
`have an oral argument at the Board. If the Board has any questions, comments, or
`
`suggestions, the undersigned attorney earnestly requests a telephone conference.
`
`No fees are required for filing this request; however, the Commissioner is
`
`authorized to charge any additional fees which may be required, or credit any
`
`overpayment, to Kasha Law LLC, Deposit Account No. 50-4075.
`
`
`
`
`
`
`
`Customer No. 67050
`Date: July 12, 2013
`
`Respectfully submitted,
`
`/John R. Kasha/
`John R. Kasha
`Reg. No. 53,100
`Attorney for the Patent Owner
`
`
`
`
`
`
`
`
`
`Case No.: IPR2012-00001
`Patent No: 6,778,074
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Attorney’s Docket No.: CUO0001-RE
`Page 3
`
`In accordance with 37 C.F.R § 1.550(f), a copy of the Patent Owner’s
`Request For Oral Argument by the Cuozzo Speed Technologies LLC on July 12,
`2013, was duly served on the Inter Partes Requester via e-mail on July 12, 2013 to
`the following e-mail addresses:
`
`jbailey@hoveywilliams.com (Jennifer C. Bailey, Lead Counsel)
`sbrown@hoveywilliams.com (Scott R. Brown, Back-Up Counsel)
`jcrawford@hoveywilliams.com (Justin Crawford, Paralegal)
`
`
`Respectfully submitted,
`
`/John R. Kasha/
`Registration No. 53,100
`Attorney for Cuozzo Speed Technologies
`LLC
`
`
`
`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(703) 867-1886, telephone
`(301) 340-3022, facsimile
`Email: john.kasha@kashalaw.com
`
`
`
`
`
`
`
`
`
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