`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________
`
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`PARROT S.A. and PARROT, INC.
`Petitioners
`
`v.
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`DRONE TECHNOLOGIES, INC.
`Patent Owner
`____________
`
`
`Case IPR2014-00732
`Patent 8,106,748
`____________
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`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`CASE IPR2014-00732
`
`
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`
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`Patent Owner’s Request for Oral Argument
`Case IPR2014-00732
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`Drone Technologies, Inc. (“Patent Owner”) hereby requests the
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`opportunity to have an oral argument at the Board pursuant to 37 C.F.R. §
`
`42.70.
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`
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`ISSUES TO BE ARGUED
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`Spirov fails as a primary reference
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`I.
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`A. Spirov operates as a single, multi-component system, and not in
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`multiple modes.
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`B. As such, there is no reason or motivation to retrofit Spirov’s
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`disclosure with a switch to select individual components of the
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`system
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`II.
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`The claims of the ’748 patent are non-obvious over Spirov in view of
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`the cited secondary references.
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`A. The secondary references do not cure the deficiencies of Spirov.
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`B. Neither Bathiche nor Shkolnikov is analogous art.
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`III. The Board’s reliance on the D’Andrea declaration is misplaced.
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`A. D’Andrea’s unsigned declaration is inadmissible.
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`B. Even if D’Andrea signed a declaration, a different declaration was
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`submitted to the Board.
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`C. Alternatively, D’Andrea’s declaration should be given little or no
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`weight.
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`2
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`
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`Patent Owner’s Request for Oral Argument
`Case IPR2014-00732
`
`CONCLUSION
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`In light of these remarks, Patent Owner respectfully requests the
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`opportunity to have an oral argument at the Board in the above-referenced
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`matter. If the Board has any questions, comments, or suggestions, the
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`undersigned attorney earnestly requests a telephone conference.
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`While the Patent Owner believes that no fee is due, the Patent Owner
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`authorizes the Board to charge any deficiencies in fees and credit any
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`overpayment of fees to deposit account no. # 502395/2664.
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`
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`The Patent Owner consents to electronic service of process and receipt
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`of any other correspondence when sent to all of these email addresses:
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`gtabachnick@beckthomas.com;
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`jdilmore@beckthomas.com; and
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`docket@beckthomas.com
`
`
`
`Respectfully submitted,
`
`/James G. Dilmore/
`
`Gene Tabachnick; Reg. No. 33,801
`James Dilmore; Reg. No. 51,618
`BECK & THOMAS, P.C.
`Pittsburgh, PA 15216-1808
`(412) 343-9700
`
`
`Date of Deposit: May 27, 2015
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`3
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`Patent Owner’s Request for Oral Argument
`Case IPR2014-00732
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`CERTIFICATE OF SERVICE
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`
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`Pursuant to 37 C.F.R. § 42.6, the undersigned certifies that on May 27,
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`2015, a copy of the foregoing document was served by email upon the
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`following:
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`James E. Hopenfeld (hopenfeld@oshaliang.com)
`Tammy J. Terry (terry@oshaliang.com)
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`
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`and via FedEx:
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`James E. Hopenfeld
`Tammy J. Terry
`Osha Liang LLP
`909 Fannin Street, Suite 3500
`Houston, Texas 77010
`
`/James G. Dilmore/
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`4
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