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`BEFORE THE PATENT AND APPEAL BOARD
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`TOMTOM, INC., and
`TOMTOM INTERNATIONAL, B.V.,
`Petitioner
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`v.
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`BLACKBIRD TECH, LLC d/b/a BLACKBIRD TECHNOLOGIES,
`Patent Owner.
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`Case IPR2017-02023
`U.S. Patent No. 6,434,212
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`Pursuant to 37 C.F.R. § 42.70(a), 35 U.S.C. § 316(a)(10), and the Board’s
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`Scheduling Order (Paper 8) and Amended Scheduling Orders (Papers 11 and 12),
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`Petitioner respectfully submits this Request for Oral Argument.
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`Petitioner specifies, without waiving any issue not specified, the following
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`issues to be argued: (1) any issues raised by Petitioner in this IPR, including in its
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`Petition (Paper 1) and Petitioner’s Reply (Paper 17); (2) any issues properly raised
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`by Patent Owner during this IPR, including in Patent Owner’s Preliminary
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`Response (Paper 6), Patent Owner’s Response (Paper 15), and Patent Owner’s Sur-
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`Reply1; (3) any issues raised in the Decision on Institution of this IPR Proceeding
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`(Paper 7) and the Order modifying the Institution Decision (Paper 10); (4) any
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`issue specified by Patent Owner in its Request for Oral Argument; and (5) any
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`other issue the Board deems necessary for issuing a final written decision.
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`Petitioner respectfully requests forty-five (45) minutes per side for oral
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`argument. Petitioner also requests the ability to reserve a portion of its total time
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`for presenting rebuttal arguments after Patent Owner’s presentation.
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`1 Patent Owner’s Sur-Reply is due October 25, 2018, and should be filed as Paper
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`19, if filed.
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`1
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`Petitioner additionally requests the ability to use audio-visual equipment to
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`display demonstrative exhibits and evidence of record, including the use of a
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`projector and a screen for displaying documents and PowerPoint slides.
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`Dated: October 24, 2018
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`Respectfully submitted,
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`By:_/s/ Dipu A. Doshi #60,373/___
`Dipu A. Doshi
` Registration No.: 60,373
`Michael S. Marcus
` Registration No. 31,727
`Megan R. Wood
` Registration. No. 72,367
`BLANK ROME LLP
`1825 Eye Street, NW
`Washington, DC 20006-5403
`(202) 420-2200
`Attorneys for Petitioner
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`CERTIFICATE OF SERVICE
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`I hereby certify that on October 24, 2018, a true and correct copy of the
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`foregoing PETITIONER’S REQUEST FOR ORAL ARGUMENT is being
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`filed and served via email, by consent, to Patent Owner at the correspondence
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`email addresses of record as follows:
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`Walter D. Davis, Jr.
`Wayne M. Helge
`Aldo Noto
`DAVIDSON BERQUIST JACKSON & GOWDEY, LLP
`wdavis@dbjg.com
`whelge@dbjg.com
`anoto@dbjg.com
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`Dated: October 24, 2018
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`Respectfully submitted,
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`By:_/s/ Dipu A. Doshi #60,373/___
`Dipu A. Doshi
` Registration No.: 60,373
`Attorney for Petitioner
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`3
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