`(309101-2121)
`
`
`
`
`IPR2016-01159
`U.S. Patent No. 8,694,657
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`FACEBOOK, INC.
`Petitioner
`
`v.
`
`WINDY CITY INNOVATIONS, LLC
`Patent Owner
`
`
`
`
`Case IPR2016-011591
`U.S. Patent No. 8,694,657
`
`
`
`PETITIONER’S REQUEST FOR ORAL HEARING
`
`
`
`
`
`
`1 Case IPR2017-00659 has been joined with this proceeding.
`
`
`
`
`
`Atty Docket FABO-041/00US
`(309101-2121)
`
`
`
`
`
`IPR2016-01159
`U.S. Patent No. 8,694,657
`
`Pursuant to 37 C.F.R. § 42.70(a), Petitioner respectfully requests oral
`
`argument. The oral argument is presently scheduled for October 19, 2017.
`
`(Paper 29.) The issues to be addressed include the following:
`
`1.
`
`Unpatentability of claims 189, 334, 342, 348, 465, 580, 584, and
`
`592 of U.S. Patent No. 8,694,657 under 35 U.S.C. § 103(a) as obvious over
`
`Roseman, Rissanen, Vetter, Pike and Lichty;
`
`2.
`
`Unpatentability of claims 203, 209, 215, 221, 477, 482, 487 and
`
`492 of U.S. Patent No. 8,694,657 under 35 U.S.C. § 103(a) as obvious over
`
`Roseman, Rissanen, Vetter, Pike and Lichty;
`
`3.
`
`4.
`
`Any procedural and evidentiary issues raised by the parties;
`
`Any additional issue the parties raise or propose to raise at or before
`
`the oral argument; and
`
`5.
`
`Any additional issues on which the Board seeks information or
`
`clarification.
`
`This proceeding is one of seven related IPR proceedings which are
`
`scheduled for oral hearing together. Four of these matters (IPR2016-01156, -
`
`01157, -01158, and -01159) are based on petitions originally filed by Facebook,
`
`Inc. The remaining three (IPR2016-01067, -01141, and -01155) are based on
`
`petitions originally filed by Microsoft, Inc. Each of these cases pertains to one of
`
`four issued patents that share the same specification. Each of these cases thus
`
`
`
`1
`
`
`
`Atty Docket FABO-041/00US
`(309101-2121)
`
`present overlapping
`
`
`
`
`IPR2016-01159
`U.S. Patent No. 8,694,657
`
`issues of claim construction and patent disclosure.
`
`Furthermore, although the “Facebook” group of cases and the “Microsoft” group
`
`of cases rely on different prior art references, Petitioner submits that many of
`
`Patent Owner’s arguments against the obviousness of the challenged claims are
`
`highly similar across all seven cases.
`
`Accordingly, Petitioner requests that one hour of argument time per side be
`
`used for the Facebook group of cases and thirty minutes of argument time per side
`
`be used for the Microsoft group of cases, with the Facebook group of cases to
`
`proceed first. Under this arrangement the combined total hearing time for all seven
`
`cases would be completed in a single three hour hearing session.
`
`Petitioner further requests that it be allowed to speak first at oral argument as
`
`the party bearing the burden of showing the unpatentability of the challenged
`
`claims, and that it be permitted to reserve time for rebuttal following Patent
`
`Owner’s allotted argument time.
`
`Petitioner further requests the use of audio-visual equipment to assist its
`
`arguments and to display is demonstrative exhibits, including a computer-
`
`connectable projector, an ELMO, and a screen. Petitioner requests the services of
`
`a court reporter to transcribe the proceeding.
`
`
`
`2
`
`
`
`
`
`
`Atty Docket FABO-041/00US
`(309101-2121)
`
`Dated: August 2, 2017
`
`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Ave. NW, Suite 700
`Washington, DC 20004
`Tel: (650) 843-5001
`Fax: (650) 849-7400
`
`IPR2016-01159
`U.S. Patent No. 8,694,657
`
`
`
`
`By:
`
`
`
`
`Respectfully submitted,
`
`
`/Heidi L. Keefe/
`Heidi L. Keefe
`Reg. No. 40,673
`Counsel for Petitioner
`Facebook, Inc.
`
`
`
`
`
`3
`
`
`
`Atty Docket FABO-041/00US
`(309101-2121)
`
`
`
`
`
`IPR2016-01159
`U.S. Patent No. 8,694,657
`
`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 and related
`documents, are being served on the 2d day of August, 2017, via electronic mail on
`counsel of record for the Patent Owner as follows:
`
`Vincent J. Rubino III
`vrubino@brownrudnick.com
`Alfred R. Fabricant
`afabricant@brownrudnick.com
`Peter Lambrianakos
`plambrianakos@brownrudnick.com
`BROWN RUDNICK LLP
`
`DATED: AUGUST 2, 2017
`
`COOLEY LLP
`ATTN: Patent Docketing
`1299 Pennsylvania Ave. NW
`Suite 700
`Washington, D.C. 20004
`Tel: (650) 843-5001
`Fax: (650) 849-7400
`
`
`
`
`/ Heidi L. Keefe /
`Heidi L. Keefe
`Reg. No. 40,673
`
`
`
`1
`
`
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