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`
`
`
`IPR2018-00082
`U.S. Patent No. 6,088,802
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`
`
`
`WESTERN DIGITAL CORPORATION,
`Petitioner,
`
`
`v.
`
`
`SPEX TECHNOLOGIES, INC.,
`Patent Owner.
`
`
`
`Patent No. 6,088,802
`Filing Date: June 4, 1997
`Issue Date: July 11, 2000
`Title: PERIPHERAL DEVICE WITH INTEGRATED SECURITY
`FUNCTIONALITY
`
`
`__________________________________________________________________
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`Case No. IPR2018-00082
`__________________________________________________________________
`
`
`

`

`IPR2018-00082
`U.S. Patent No. 6,088,802
`
`In view of the Board's denial of Petitioner Western Digital Corporation’s
`
`(“Western Digital”) motion for leave to file a reply under 37 C.F.R. 42.5, Patent
`
`Owner respectfully submits that there are no issues necessitating oral argument.
`
`Paper 32. To the extent the Board permits oral argument in this proceeding and
`
`pursuant to 37 C.F.R. § 42.70(a) and the Board’s scheduling order (Paper 12),
`
`SPEX respectfully requests oral argument in IPR2018-00082, currently scheduled
`
`for January 14, 2019. Patent Owner requests thirty (30) minutes to present its
`
`arguments. Without intending to waive any issue not specifically identified below,
`
`Patent Owner identifies the following issues to be argued at trial:
`
`1.
`
`2.
`
`each ground of patentability upon which trial was instituted;
`
`the appropriate constructions to be given to the disputed claim
`
`terms;
`
`3.
`
`any issues specified by Petitioner in its request for oral
`
`argument;
`
`4.
`
`each argument presented or raised by Petitioner1 in briefing
`
`during this proceeding or at trial; and
`
`
`
`1 To the extent any joined petitioners are permitted to present oral arguments
`
`to the Board, SPEX reserves the right to respond to the joined petitioners’
`
`arguments and/or seek additional time.
`
`1
`
`

`

`
`
`5.
`
`IPR2018-00082
`U.S. Patent No. 6,088,802
`any other issues the Board deems necessary for issuing a final
`
`
`
`written decision.
`
`To the extent the Board permits oral argument under the circumstances
`
`described above, Patent Owner respectfully requests that the Board provide audio-
`
`visual equipment configured to display demonstrative exhibits, including a
`
`projector and a screen configured to display documents from a laptop computer.
`
`
`
`Dated: December 3, 2018
`
`
`
`/Peter Lambrianakos/
`
`Peter Lambrianakos (Reg. No. 58,279)
`Lead Counsel for Patent Owner
`BROWN RUDNICK LLP
`7 Times Square
`New York, NY 10036
`Telephone: 212-209-4800
`Facsimile: 212-209-4801
`Email: plambrianakos@brownrudnick.com
`
`Vincent J. Rubino, III (Reg. No. 68,594)
`Enrique W. Iturralde (Reg. No. 72,883)
`Back-up Counsel for Patent Owner
`Brown Rudnick LLP
`7 Times Square
`New York, NY 10036
`Tel: 212-209-4800
`Fax: 212-209-4801
`Email: vrubino@brownrudnick.com
`Email: eiturralde@brownrudnick.com
`
`
`
`
`
`2
`
`

`

`
`
`
`
`IPR2018-00082
`U.S. Patent No. 6,088,802
`
`CERTIFICATE OF SERVICE
`
`A copy of Patent Owner’s Request for Oral Argument has been served on
`
`Petitioner’s counsel of record as follows:
`
`Brian Buroker
`Gibson, Dunn & Crutcher LLP
`1050 Connecticut Avenue, N.W.
`Washington, D.C. 20036-5306
`bburoker@gibsondunn.com
`
`Blair Silver
`Gibson, Dunn & Crutcher LLP
`1050 Connecticut Avenue, N.W.
`Washington, D.C. 20036-5306
`bsilver@gibsondunn.com
`
`Rustin Mangum
`Gibson, Dunn & Crutcher LLP
`3161 Michelson Drive
`Irvine, CA 92612-4412
`rmangum@gibsondunn.com
`
`December 3, 2018
`
`
`
`By:
`
`/Peter Lambrianakos /
`
`Peter Lambrianakos (Reg. No. 58,279)
`Lead Counsel for Patent Owner
`Brown Rudnick LLP
`7 Times Square
`New York, NY 10036
`Tel: 212-209-4800
`Fax: 212-209-4801
`Email: plambrianakos@brownrudnick.com
`
`
`
`
`
`

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