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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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`PARUS HOLDINGS, INC.,
`Patent Owner
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`____________
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`Case IPR2020-00686
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`U.S. Patent No. 7,076,431
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`Pursuant to the Board’s September 23, 2020, Scheduling Order (Paper 10),
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`Petitioner respectfully requests oral argument for the trial currently scheduled on
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`June 22, 2021. Petitioner requests oral argument for this IPR (IPR2020-00686) be
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`combined with oral argument for IPR2020-00687 (for which a Request for Oral
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`Argument is concurrently filed). The ’431 Patent, which is the subject of this ’686
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`IPR, is related to the ’084 Patent, which is the subject of the ’687 IPR. The issues
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`presented in the IPRs are similar, warranting a single oral argument for both IPRs.
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`Petitioner also requests a single set of demonstratives be used for both IPRs and a
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`total Petitioner argument time of 45 minutes. If the Board is allowing in-person
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`hearings, Petitioner further requests that the hearing take place in Alexandria,
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`Virginia.
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`Pursuant to 37 C.F.R. § 42.70(a), Petitioner specifies the following issues,
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`without intent to waive consideration of any issue not requested, to be argued for this
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`proceeding:
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`1. Whether Claims 1-6, 9-10, 13-14, 18, 20-21, and 25 are unpatentable
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`under § 103(a) over U.S. Patent No. 6,269,336 B1 to Ladd, et al. (“Ladd”) in view of
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`Japanese Unexamined Utility Patent Application Publication No. H9-311869 to
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`Kurosawa (“Kurosawa”) in further view of U.S. Patent No. 6,393,423 B1 to Goedken
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`(“Goedken”);
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`1
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`2. Whether Claims 7, 19, and 26-30 are unpatentable under § 103(a) over
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`Ladd in view of Kurosawa in further view of Goedken and U.S. Patent No. 5,913,214
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`to Madnick, et al (“Madnick”);
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`3. Whether Claims 5-6 are unpatentable under § 103(a) over Ladd in view
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`of Kurosawa in further view of Goedken and U.S. Patent No. 5,774,859 to Houser, et
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`al. (“Houser”);
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`4. Whether Claims 9 and 25 are unpatentable under § 103(a) over Ladd in
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`view of Kurosawa in further view of Goedken and U.S. Patent No. 6,650,998 B1 to
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`Rutledge, et al. (“Rutledge”);
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`5.
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`Any claim constructions raised in the Petition or Petitioner Reply, the
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`Patent Owner Preliminary Response, Patent Owner Response, or the Patent Owner Sur-
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`Reply, or the Board’s Institution Decision;
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`6.
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`Any issues specified in the Patent Owner Response and Patent Owner Sur-
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`Reply;
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`7.
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`8.
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`Any issues specified in the Petitioner Reply;
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`Any issues regarding motions to exclude or motions to strike that may be
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`filed or pending; and
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`9.
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`Any issues otherwise raised by the Board.
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`Respectfully submitted,
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`ERISE IP, P.A.
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`BY: /s/ Jennifer C. Bailey
`Jennifer C. Bailey, Reg. No. 52,583
`Adam P. Seitz, Reg. No. 52,206
`7015 College Blvd., Suite 700
`Overland Park, KS 66211
`P: (913) 777-5600
`F: (913) 777-5601
`jennifer.bailey@eriseip.com
`adam.seitz@eriseip.com
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`ATTORNEYS FOR PETITIONER
`APPLE INC.
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`CERTIFICATE OF SERVICE ON PATENT OWNER
`UNDER 37 C.F.R. § 42.6
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on May 12,
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`2021, the foregoing Petitioner’s Request for Oral Argument was served via
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`electronic filing with the Board and via Electronic Mail on the following
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`practitioners of record for Patent Owner:
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`Michael J. McNamara (mmcnamara@mintz.com)
`Michael T. Renaud (mtrenaud@mintz.com)
`William A. Meunier (wameunier@mintz.com)
`Andrew H. deVoogd (ahdevoogd@mintz.com)
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`/s/ Jennifer C. Bailey
`Jennifer C. Bailey, Reg. No. 52,583
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`ATTORNEY FOR PETITIONER
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`4
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