`U.S. Patent No. 7,149,511
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS
`AMERICA, INC., AND APPLE INC.,
`Petitioners,
`
`v.
`
`ROSETTA-WIRELESS CORPORATION,
`Patent Owner
`
`———————
`
`Case No. IPR2016-006221
`Patent No. 7,149,511 B1
`
`———————
`
`
`
`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
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`
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`1 Case IPR2016-00616 has been consolidated with this proceeding.
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`
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`
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`IPR2016-00622
`U.S. Patent No. 7,149,511
`Pursuant to 37 C.F.R. § 42.70(a), the Scheduling Order entered August 22,
`
`
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`2016 (Paper 13), the Decision instituting this proceeding and consolidating
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`IPR2016-006162
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` with it (Paper 15), and the Order modifying due dates entered
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`January 24, 2017 (Paper 31), Petitioners Samsung Electronics Co., LTD., Samsung
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`Electronics America, Inc. and Apple Inc. (“Petitioners”) respectfully request oral
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`argument on all the instituted grounds of alleged unpatentability in IPR2016-00616
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`and IPR2016-0622, as listed below:
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`References
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`21 and 70
`22 and 71
`1–10, 19, 58–65, and 68
`2 and 59
`8 and 9
`20 and 69
`
`Basis
`Challenged Claim(s)
`1–6, 8–10, 58–63, and 65 35 U.S.C. § 103(a) Kimura
`1–10, 19, 58–65, and 68
`35 U.S.C. § 103(a) Goggin
`2 and 59
`35 U.S.C. § 103(a) Goggin, Bodnar
`8 and 9
`35 U.S.C. § 103(a) Goggn, Jornada
`20 and 69
`35 U.S.C. § 103(a) Goggin, DeLorme Receiver,
`DeLorme Accessories
`35 U.S.C. § 103(a) Goggin, Ogasawara
`35 U.S.C. § 103(a) Goggin, CapShare
`35 U.S.C. § 103(a) Goggin, Proxim
`35 U.S.C. § 103(a) Goggin, Proxim, Bodnar
`35 U.S.C. § 103(a) Goggin, Proxim, Jornada
`35 U.S.C. § 103(a) Goggin, Proxim, DeLorme
`Receiver, DeLorme
`Accessories
`35 U.S.C. § 103(a) Goggin, Proxim, Ogasawara
`35 U.S.C. § 103(a) Goggin, Proxim, CapShare
`
`21 and 70
`22 and 71
`
`
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`The Board has scheduled DUE DATE 7, the date of the Oral Hearing if
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`requested, to be June 1, 2017 (Paper 31 at 3). Petitioners respectfully request a
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`two-hour hearing, with 60 minutes of argument time allotted to Patent Owner
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`2 The Decision in IPR2016-00616 is contained in Paper 11 of that proceeding.
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`
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`2
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`
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`IPR2016-00622
`U.S. Patent No. 7,149,511
`individually and 60 minutes of argument time allotted to Petitioners collectively in
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`connection with the foregoing issues and proceedings. The parties have conferred
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`and Patent Owner agrees to the amount and division of time for the hearing.
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`Petitioners further respectfully requests that the Board provide audio/visual
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`equipment to display demonstrative exhibits and evidence of record, including a
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`projector and screen for displaying documents. Finally, given the multiple
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`Petitioners involved in this proceeding, Petitioners respectfully request Hearing
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`Room A, if available.
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`Dated: April 24, 2017
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`Respectfully submitted,
`
`/ Megan F. Raymond /
`Megan F. Raymond (Reg. No. 72,997)
`Lead Counsel
`Paul, Weiss, Rifkind, Wharton & Garrison
`LLP
`2001 K Street, NW
`Washington, DC 20006-1047
`T: 202-223-7401
`E: mraymond@paulweiss.com
`Attorney for Samsung Petitioners
`
`Brian E. Ferguson (Reg. No. 36,801)
`Back-up Counsel
`Weil, Gotshal & Manges LLP
`1300 Eye Street NW, Suite 900
`Washington, DC 20005
`T: 202-682-7094
`E: brian.ferguson@weil.com
`Attorney for Petitioner Apple Inc.
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`
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`3
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`IPR2016-00622
`U.S. Patent No. 7,149,511
`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that on April 24, 2017, the foregoing
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT was served via
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`electronic mail, upon the following:
`
`Miranda Y. Jones
`Michael F. Heim
`HEIM, PAYNE & CHORUSH, L.L.P.
`600 Travis Street, Suite 6710
`Houston, TX 77002
`Tel: (713) 221-2000
`Fax: (713) 221-2021
`mjones@hpcllp.com
`mheim@hpcllp.com
`rosettaIPR@hpcllp.com
`
`Attorneys for Patent Owner
`Rosetta-Wireless Corporation
`
`
`/ Megan F. Raymond /
`Megan F. Raymond
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`4
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