`
`___________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________
`
`CLOUDFLARE, INC. and
`SPLUNK, INC.,
`Petitioners,
`
`v.
`
`SABLE NETWORKS, INC.,
`Patent Owner.
`
`___________
`
`IPR2021-009091
`Patent 8,243,593 B2
`___________
`
`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
`
`1 Splunk, Inc., which filed a petition in IPR2022-00228, has been joined as a
`petitioner in this proceeding.
`
`
`
`IPR2021-00909 (Patent No. 8,243,593)
`
`The Board scheduled oral argument (if requested) for September 7, 2022.
`
`Paper 17 at 11. Pursuant to 37 C.F.R. § 42.70(a), Petitioners Cloudflare, Inc. and
`
`Splunk, Inc. respectfully request an oral argument on the issues set forth below
`
`(without waiving consideration of any issues not listed):
`
` Claims 9-13, 17-24, 29-33, and 37-44 are unpatentable under
`
`35 U.S.C. § 103(a) as being rendered obvious to a POSA by Yung and
`
`Copeland;
`
` Claim 3 is unpatentable under 35 U.S.C. § 103(a) as being rendered
`
`obvious to a POSA by Yung and the Four-Steps Whitepaper;
`
` Proper construction of the claim language;
`
` Any motions or issues that remain pending at the time of the hearing;
`
` Rebuttal to Patent Owner’s presentation on all matters; and
`
` Any additional issues raised by the Board or Patent Owner during the
`
`oral argument.
`
`Petitioners request 45 minutes to address these issues. To the extent the
`
`Board may allocate more or less than 45 minutes per side, Petitioners request that
`
`they be given half the length of the hearing to address these issues.
`
`Petitioners also request permission to use audio visual equipment to display
`
`demonstrative exhibits, including the use of a computer, projector, and screen.
`
`1
`
`
`
`IPR2021-00909 (Patent No. 8,243,593)
`
`Petitioners request that this be an in-person oral hearing. Petitioners
`
`anticipate having a total of six people in attendance.
`
`Respectfully submitted,
`
` /James L. Day/
`James L. Day
`(Registration No. 72,681)
`Lead Counsel for Petitioner
`Cloudflare, Inc.
`
`July 8, 2022
`
`2
`
`
`
`IPR2021-00909 (Patent No. 8,243,593)
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on July 8, 2022, I caused a complete and entire copy of
`
`PETITIONERS’ REQUEST FOR ORAL ARGUMENT to be served by
`
`electronic means to the following addresses:
`
`weatherwax@lowensteinweatherwax.com
`Sable_IPRs@lewensteinweatherwax.com
`
`
`
` /James L. Day/
`James L. Day
`Registration No. 72,681
`
`3
`
`
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