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`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`
`
`SONY INTERACTIVE ENTERTAINMENT LLC
`Petitioner
`
`v.
`
`BOT M8, LLC
`Patent Owner
`____________
`
`
`Case No. IPR2020-01288
`U.S. Patent No. 7,664,988
`____________
`
`
`
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`

`

`
`
`Pursuant to the Board’s February 16, 2021, Scheduling Order (Paper 12),
`
`Petitioner respectfully requests oral argument for the trial currently scheduled on
`
`November 10, 2021. If the Board is conducting in-person hearings, Petitioner further
`
`requests that the hearing take place in Alexandria, Virginia.
`
`Pursuant to 37 C.F.R. § 42.70(a), Petitioner respectfully proposes 45 minutes of
`
`time per side and specifies the following issues, without intent to waive consideration
`
`of any issue not requested, to be argued for this proceeding:
`
`1. Whether Claims 1-9 are unpatentable under § 103(a) over Japanese
`
`Unexamined Patent Application Publication No. JP 2000-35888 to Sugiyama
`
`(“Sugiyama”) in view of International Publication No. WO 2004/004855 to Gatto, et
`
`al. (“Gatto”);
`
`2. Whether Claims 1-9 are unpatentable under § 103(a) over U.S. Patent
`
`Publication No. 2004/0054952 to Morrow (“Morrow”) in view of U.S. Patent
`
`Publication No. 2003/0064771 to Morrow (“Morrow ’771”);
`
`3. Whether Claims 2 and 7 are unpatentable under § 103(a) over Sugiyama
`
`in view of Gatto, in further view of U.S. Patent No. 5,844,776 to Yamaguchi
`
`(“Yamaguchi”);
`
`4. Whether Claims 2 and 7 are unpatentable under § 103(a) over Morrow in
`
`view of Morrow ’771, in further view of Yamaguchi;
`
`
`
`1
`
`

`

`
`
`5. Whether Claim 8 is unpatentable under § 103(a) over Sugiyama in view
`
`of Gatto and Yamaguchi, in further view of International Publication No. WO 00/73904
`
`to Proudler (“Proudler”);
`
`6. Whether Claim 8 is unpatentable under § 103(a) over Morrow in view of
`
`Morrow ’771 and Yamaguchi, in further view of Proudler;
`
`7. Whether Claim 10 is unpatentable under § 103(a) over Sugiyama in view
`
`of Gatto, in further view of U.S. Patent Publication No. 2003/0135350 to Cheston
`
`(“Cheston”);
`
`8. Whether Claim 10 is unpatentable under § 103(a) over Morrow in view
`
`of Morrow ’771, in further view of Cheston;
`
`9.
`
`Any claim constructions raised in the Petition or Petitioner Reply, the
`
`Patent Owner Preliminary Response, Patent Owner Response, or the Patent Owner Sur-
`
`Reply, or the Board’s Institution Decision;
`
`10. Any issues specified in the Patent Owner Response and Patent Owner Sur-
`
`Reply;
`
`11. Any issues specified in the Petitioner Reply;
`
`12. Response to any issues specified by Patent Owner in its request for oral
`
`argument; and
`
`13. Any issues otherwise raised by the Board.
`
`
`
`
`
`
`
`2
`
`

`

`
`
`
`
`
`
`
`
`Respectfully submitted,
`
` BY: /s/ Eric A. Buresh
`
`Eric A. Buresh, Reg. No. 50,394
`Jason R. Mudd, Reg. No. 57,700
`Callie Pendergrass, Reg. No. 63,949
`
`COUNSEL FOR PETITIONER
`
`
`
`
`
`
`
`
`Dated: October 1, 2021
`
`
`
`
`
`
`
`3
`
`

`

`
`
`CERTIFICATE OF SERVICE ON PATENT OWNER
`UNDER 37 C.F.R. § 42.6(e)
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on October 1,
`
`2021, a true and correct copy of the foregoing Petitioner’s Request for Oral
`
`Argument were served by electronic mail on Patent Owner’s lead and backup
`
`counsel at the following email addresses:
`
`James Hannah: jhannah@kramerlevin.com
`
`Jonathan S. Caplan: jcaplan@kramerlevin.com
`
`Jeffrey H. Price: jprice@kramerlevin.com
`
`Aaron M. Frankel: afrankel@kramerlevin.com
`
`svdocketing@kramerlevin.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`BY: /s/ Eric A. Buresh
`
`Eric A. Buresh, Reg. No. 50,394
`
`COUNSEL FOR PETITIONER
`
`4
`
`

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