`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`PLAID TECHNOLOGIES, INC.,
`Petitioner,
`v.
`
`YODLEE, INC.,
`Patent Owner.
`
`_____________________
`
`IPR2016-00273
`U.S. Patent No. 6,317,783
`_____________________
`
`
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.70(a), Petitioner Plaid Technologies, Inc.
`
`(“Petitioner”) hereby respectfully requests oral argument in the present inter partes
`
`review proceeding. Petitioner specifies the following issues to be argued:
`
` Whether claims 1, 3–20, and 22–36 of U.S. Patent No. 6,317,783
`
`(“the ’783 patent”) are unpatentable under 35 U.S.C. § 103(a) as
`
`obvious over the combination of Sugiarto (Ex. 1004) and Brandt (Ex.
`
`1005);
`
` Whether claims 2 and 21 of the ’783 patent are unpatentable under 35
`
`U.S.C. § 103(a) as obvious over the combination of Sugiarto (Ex.
`
`1004), Brandt (Ex. 1005), and Chow (Ex. 1006);
`
` The appropriate constructions to be given to the disputed claim terms;
`
` Whether the claim term “non-public personal information” should be
`
`given patentable weight;
`
` Whether a person of ordinary skill in the art would have been
`
`motivated to combine Sugiarto (Ex. 1004), Brandt (1005), and Chow
`
`(1006) and would have had at least a reasonable expectation of
`
`successfully doing so;
`
` Response to any issues specified by Patent Owner in its request for
`
`oral argument;
`
`1
`
`
`
`
`
` Response to Patent Owner’s presentation on all matters; and
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` Any other issue briefed or presented by the parties throughout this
`
`trial.
`
`Petitioner requests 30 minutes of argument time. Petitioner proposes that
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`Petitioner present argument, Patent Owner follow with its response, and that
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`Petitioner use its remaining time for rebuttal.
`
`
`
`Dated: January 30, 2017
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`By: /Brian M. Buroker/
`Brian M. Buroker (Reg. No. 39,125) (lead)
`GIBSON, DUNN & CRUTCHER LLP
`1050 Connecticut Avenue, N.W.
`Washington, DC 20036-5306
`Telephone: 202.955.8500
`Facsimile: 202.467.0539
`bburoker@gibsondunn.com
`Attorney for Petitioner Plaid Technologies,
`Inc.
`
`
`
`
`
`2
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies service pursuant to 37 C.F.R. § 42.6(e) of a copy
`
`of this Request for Oral Argument by electronic mail on January 30, 2017, on the
`
`counsel of record of the Patent Owner:
`
`David Hoffman, IPR12233‐0047IP1@fr.com,
`
`David M. Barkan, barkan@fr.com,
`
`Mathew McCullough, mccullough@fr.com.
`
`
`
`DATED: January 30, 2017
`
`By: /Brian M. Buroker/
`
`
`
`
`
`
`
`Brian M. Buroker (Reg. No. 39,125)
`
`Attorney for Petitioner Plaid Technologies,
`Inc.
`
`3
`
`
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