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Case IPR2019-00824
`Patent 9,712,502
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`APPLE INC.,
`Petitioner,
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`v.
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`MPH TECHNOLOGIES OY,
`Patent Owner,
`____________
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`Case IPR2019-00824
`Patent 9,712,502
`____________
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`PATENT OWNER MPH TECHNOLOGIES OY’S
`REQUEST FOR ORAL ARGUMENT
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`

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`Pursuant to 37 C.F.R. § 42.70 and the Board’s November 6, 2019
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`Scheduling Order (Paper 8), MPH Technologies Oy (“Patent Owner”) respectfully
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`requests oral argument, as currently scheduled for August 11, 2020.
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`Reservation Of Time: Patent Owner requests an opportunity to reserve sur-
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`rebuttal time to respond to rebuttal arguments by Petitioner, and an opportunity to
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`provide a closing statement. Compare, e.g., Mangrove Partners Master Fund.,
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`Ltd. et al. v. VirnetX Inc., IPR2015-01046/01047, Paper 60, 2 (PTAB June 2, 2016)
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`(“Both parties may reserve some of their argument time for rebuttal, and Patent
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`Owner will be afforded an opportunity to provide a closing statement along with
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`any rebuttal.”)
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`Issues For Argument: Without waiving any issue not specifically
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`identified, Patent Owner specifies at least the following issues it may discuss at
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`argument:
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`• Issues related to the instituted grounds, including, for example, claim
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`construction, anticipation, obviousness, motivation to combine, and
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`reasonable expectation of success;
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`• The timeliness of the arguments raised in the proceedings;
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`• Any other relevant issues raised in papers filed in this proceeding,
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`including issues raised in papers yet to be filed; and
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`- 1 -
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`• Any other issues that the Board deems necessary for issuing a Final
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`Written Decision, including any questions, rebuttals, or arguments
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`that may arise during the oral argument.
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`The Board’s advance guidance is respectfully solicited as to any questions
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`the Board specifically wishes to be addressed.
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`Time For Argument: Patent Owner respectfully requests 60 minutes of total
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`argument time per side. Patent Owner believes that this is a sufficient amount of
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`time to discuss all issues in this case.
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`Equipment: Patent Owner requests the ability to use a computer. projector,
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`and screen to display possible demonstratives and exhibits.
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`Respectfully submitted,
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` /
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` James T. Carmichael /_________
`James T. Carmichael, Reg. No. 45,306
`CARMICHAEL IP, PLLC
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`Date: June 10, 2020
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`- 2 -
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`

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`Case IPR2019-00824
`Patent 9,712,502
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the following documents were served
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`by electronic service, by agreement between the parties, on the date signed below:
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`
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`PATENT OWNER MPH TECHOLOGIES OY’S
`REQUEST FOR ORAL ARGUMENT
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`The names and address of the parties being served are as follows:
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`Michael D. Specht
`Daniel S. Block
`Steven M. Pappas
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`mspecht-PTAB@sternekessler.com
`dblock-PTAB@sternekessler.com
`spappas-PTAB@sternekessler.com
`PTAB@sternekessler.com
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`Respectfully submitted,
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` / James Carmichael /
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`Date: June 10, 2020
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