`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________
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`
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`SAMSUNG ELECTRONICS CO., LTD. And
`GOOGLE LLC
`Petitioner,
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`v.
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`IRON OAK TECHNOLOGIES, LLC,
`Patent Owner.
`
`
`___________________________
`
`IPR2018-015531
`U.S. Patent No. 5,699,275
`___________________________
`
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`
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`PATENT OWNER REQUEST FOR ORAL ARGUMENT
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`PURSUANT TO 37 C.F.R. §42.70(a)
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`
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`1 Google LLC, who filed a petition in IPR 2019-00111, has joined as a petitioner in this proceeding.
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`
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`Patent Owner Iron Oak Technologies, LLC, hereby requests an oral argument
`
`pursuant to 37 C.F.R. § 42.70. The Board has previously scheduled oral argument
`
`in this case for November 4, 2019
`
`Patent Owner specifies the following issues to be argued:
`
`1. Whether Petitioner has met its burden of proving that claim 1 is obvious
`
`over Hapka in combination with Parrillo, including, in particular, whether Petitioner
`
`has shown that that the combination discloses or renders obvious the requirement of
`
`claim 1 that the Manager Host is operable to decide not to send to a Second Mobile
`
`Unit the at least one discrete patch message that was sent to the First Mobile Unit
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`even though the Second Mobile Unit is operable to create Patched Operating Code
`
`from the at least one discrete patch message?
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`2. Whether Petitioner has met its burden of proving that claim 1 is obvious
`
`over Hapka in combination with Parrillo and Wortham, including, in particular,
`
`whether Petitioner has shown that that the combination discloses or renders obvious
`
`the requirement of claim 1 that the Manager Host is operable to decide not to send
`
`to a Second Mobile Unit the at least one discrete patch message that was sent to the
`
`First Mobile Unit even though the Second Mobile Unit is operable to create Patched
`
`Operating Code from the at least one discrete patch message?
`
`
`
`2
`
`
`
`Patent Owner requests the ability use video equipment (including use of a
`
`computer, projector, and screen) to display exhibits, including potentially
`
`demonstrative exhibits, during oral argument.
`
`
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`Dated September 30, 2019
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`
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`
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`Respectfully submitted,
`
`
`
`
`
`
`
`By: /Al Deaver/
`
`
`
`Albert B. Deaver, Jr.
`Reg. No. 34,318
`Lead Counsel for Patent Owner
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`3
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`
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`CERTIFICATE OF SERVICE
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`
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`Pursuant to 37 C.F.R. §42.6(e), I certify that an electronic copy of the
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`foregoing PATENT OWNER’S REQUEST FOR ORAL ARGUMENT was served
`
`along with any accompanying exhibits via the Patent Review Processing System and
`
`via email to Petitioner’s counsel.
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`Date: September 30, 2019
`
`
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`
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`Respectfully submitted,
`
`By: /Al Deaver/
`
`
`
`Albert B. Deaver, Jr.
`Reg. No. 34,318
`Lead Counsel for Patent Owner
`
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