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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`ALARM.COM INC.
`Petitioner
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`v.
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`VIVINT, INC.
`Patent Owner
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`Case IPR2016-00116
`U.S. Patent No. 6,147,601
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`US Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`Case IPR2016-00116 of
`U.S. Patent No. 6,147,601
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`Pursuant to 37 C.F.R. § 42.70(a), Petitioner Alarm.com Inc. hereby requests
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`oral argument, currently scheduled for January 31, 2017, for case IPR2016-00116.
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`See Scheduling Order, Paper 15 at p. 6. Petitioner further requests that this case
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`be argued jointly with cases IPR2016-00161 and IPR2016-00173, which concern
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`patents from the same family with common claim terms, present largely the same
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`disputed issues, and which are also scheduled for oral argument on the same day.
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`See IPR2016-00161, Paper 17 at p. 6; IPR2016-00173, Paper 15 at p. 6. Petitioner
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`also requests that the hearing occur in Hearing Room A due to the number of
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`counsel and client representatives anticipated in the three cases. Petitioner
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`specifies the following issues to be argued, for all three cases (except for Issues 6
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`and 7 below):
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`1. That the Board has offered the broadest reasonable construction of the
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`term “message profile containing outgoing message routing instructions”.
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`2. That Shetty rendered obvious user-defined message profiles.
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`3. That Shetty rendered obvious remote configuration or modification of
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`user-defined message profiles.
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`4. That Shetty in view of Britton rendered obvious normal status messages.
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`5. That a person of ordinary skill in the art would have been motivated to
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`combine features of Levac with Shetty.
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`6. That Shetty in view of Levac rendered obvious selection of different
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`Case IPR2016-00116 of
`U.S. Patent No. 6,147,601
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`user-defined communication devices to receive outgoing exception
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`messages at different time periods. (IPR 2016-00116 only)
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`7. That Shetty rendered obvious communication device identification codes
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`stored in a second memory and configured in a plurality of user-defined
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`message profiles. (IPR2016-00116 and IPR2016-00173 only)
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`8. Any issues specified by Patent Owner or raised by Patent Owner at the
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`hearing.
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`Because these issues, with the exceptions of Issues 6 and 7 above, are
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`common to each of the cases to be argued, Petitioner requests a total of ninety (90)
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`minutes to address these issues in a single argument for all three cases combined.
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`In the event that the Board does not grant Petitioner’s request to argue these
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`cases in a single consolidated argument, Petitioner will need to present many of the
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`same arguments in each case. In that event, Petitioner requests sixty (60) minutes
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`of argument in the instant case.
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`Should Patent Owner argue any motions to exclude evidence in any of the
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`cases, Petitioner requests an additional five (5) minutes, or an amount of time
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`equivalent to Patent Owner’s time spent arguing such motions, whichever is
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`longer, to respond to those arguments.
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`Case IPR2016-00116 of
`U.S. Patent No. 6,147,601
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`Petitioner requests the ability to use a laptop projector, Elmo projector, and
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`screen for the purposes of displaying demonstrative exhibits.
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`Respectfully submitted,
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`Dated: December 20, 2016
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`By: / William H. Mandir/
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`William H. Mandir
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`Registration No. 32,156
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`Lead Counsel for Petitioner
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`Case IPR2016-00116 of
`U.S. Patent No. 6,147,601
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a copy of the attached PETITIONER'S
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`REQUEST FOR ORAL ARGUMENT was sent via electronic mail on December
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`20, 2016 to the following:
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`Robert G. Sterne (rsterne-PTAB@skgf.com)
`Jason D. Eisenberg (jasone-PTAB@skgf.com)
`PTAB@skgf.com
`STERNE, KESSLER, GOLDSTEIN & FOX
`1100 New York Avenue, N.W.
`Washington, DC 20005
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`Counsel of Record for the Patent Owner in this proceeding
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`Respectfully submitted,
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`By: /s/ Brian K. Shelton
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`Brian K. Shelton
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`Registration No. 50,245
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`Backup Counsel for Petitioner
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`Dated: December 20, 2016