`(309101-2163)
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`IPR2017-01155
`U.S. Patent No. 8,694,657
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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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`FACEBOOK, INC.
`Petitioner
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`v.
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`WINDY CITY INNOVATIONS, LLC
`Patent Owner
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`Case No. IPR2016-011551
`Patent No. 8,694,657
`__________________
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`PETITIONER’S REQUEST FOR ORAL HEARING
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`1 Case IPR2017-00622 has been joined with this proceeding.
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`Atty Docket No. FABO-041/01US
`(309101-2163)
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`IPR2017-01155
`U.S. Patent No. 8,694,657
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`Pursuant to 37 C.F.R. § 42.70(a), Petitioner respectfully requests oral
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`argument. The oral argument is presently scheduled for October 19, 2017.
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`(Paper 38.) The issues to be addressed include the following:
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`1.
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`Unpatentability of claims 189 and 465 of U.S. Patent No. 8,694,657
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`under 35 U.S.C. § 103(a) as obvious over Brown and Sociable Web;
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`2.
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`3.
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`Any procedural and evidentiary issues raised by the parties;
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`Any additional issue the parties raise or propose to raise at or before
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`the oral argument; and
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`4.
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`Any additional issues on which the Board seeks information or
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`clarification.
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`This proceeding is one of seven related IPR proceedings which are scheduled
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`for oral hearing together. Four of these matters (IPR2016-01156, -01157, -01158,
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`and -01159) are based on petitions originally filed by Facebook, Inc. The remaining
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`three (IPR2016-01067, -01141, and -01155) are based on petitions originally filed
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`by Microsoft, Inc. Each of these cases pertains to one of four issued patents that
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`share the same specification. Each of these cases thus present overlapping issues of
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`claim construction and patent disclosure. Furthermore, although the “Facebook”
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`group of cases and the “Microsoft” group of cases rely on different prior art
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`references, Petitioner submits that many of Patent Owner’s arguments against the
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`obviousness of the challenged claims are highly similar across all seven cases.
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`1
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`Atty Docket No. FABO-041/01US
`(309101-2163)
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`IPR2017-01155
`U.S. Patent No. 8,694,657
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`Accordingly, Petitioner requests that one hour of argument time per side be
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`used for the Facebook group of cases and thirty minutes of argument time per side
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`be used for the Microsoft group of cases, with the Facebook group of cases to
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`proceed first. Under this arrangement the combined total hearing time for all seven
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`cases would be completed in a single three hour hearing session.
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`Petitioner further requests that it be allowed to speak first at oral argument as
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`the party bearing the burden of showing the unpatentability of the challenged claims,
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`and that it be permitted to reserve time for rebuttal following Patent Owner’s allotted
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`argument time.
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`Petitioner further requests the use of audio-visual equipment to assist its
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`arguments and to display is demonstrative exhibits, including a computer-
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`connectable projector, an ELMO, and a screen. Petitioner requests the services of a
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`court reporter to transcribe the proceeding.
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`Dated: August 2, 2017
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`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Ave. NW, Suite 700
`Washington, DC 20004
`Tel: (650) 843-5001
`Fax: (650) 849-7400
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` Respectfully submitted,
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`By: /Heidi L. Keefe/
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`Heidi L. Keefe
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`Reg. No. 40,673
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`Counsel for Petitioner
`Facebook, Inc.
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`2
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`Atty Docket No. FABO-041/01US
`(309101-2163)
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`IPR2017-01155
`U.S. Patent No. 8,694,657
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`CERTIFICATE OF SERVICE
`I hereby certify, pursuant to 37 C.F.R. § 42.6, that a complete copy of the
`attached PETITIONER’S REQUEST FOR ORAL HEARING is being served in
`its entirety on the 2nd day of August, 2017, via electronic mail on counsel of record
`for the Patent Owner as follows:
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`/Heidi L. Keefe
`Heidi L. Keefe
`Reg. No. 40,673
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`
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`Peter Lambrianakos
`plambrianakos@brownrudnick.com
`Vincent J. Rubino, III
`vrubino@brownrudnick.com
`Alfred R. Fabricant
`afabricant@brownrudnick.com
`Shahar Harel
`sharel@brownrudnick.com
`Enrique W. Iturralde
`eiturralde@brownrudnick.com
`Brown Rudnick LLP
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`Dated: August 2, 2017
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`COOLEY LLP
`ATTN: Patent Docketing
`1299 Pennsylvania Ave. NW
`Suite 700
`Washington, DC 20004
`Tel: (650) 843-5001
`Fax: (650) 849-7400
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`3
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