`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`CODE200, UAB; TESO LT, UAB; METACLUSTER LT, UAB; OXYSALES,
`UAB; AND CORETECH LT, UAB,
`Petitioners,
`
`v.
`
`BRIGHT DATA LTD.,
`Patent Owner.
`____________
`
`Case IPR 2021-01492
`Patent 10,257,319
`____________
`
`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
`
`
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`
`
`
`
`
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`Petitioners, by and through their attorneys, respectfully request oral argument.
`
`Per the communication from the Board dated April 21, 2023 (EX-3005), a single
`
`coordinated hearing between IPRs 2021-01492 and 2021-01493 (both styled
`
`Code200, UAB v. Bright Data Ltd.), and IPRs 2022-00915 and 2022-00916 (both
`
`styled Major Data UAB v. Bright Data Ltd.) is scheduled for June 9, 2023.
`
`Petitioners respectfully request that the Board hold a remote oral argument
`
`and Petitioners request a total of 60 minutes to present their arguments. As reflected
`
`in Exhibit 3005, the Code200 and Major Data Petitioners have agreed to split the
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`time for petitioner argument such that the two sets of petitioners will not take more
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`total time for the petitioners’ side than if there were only a single petitioner.
`
`Petitioners therefore propose to split the 60 minutes of argument time with the Major
`
`Data Petitioner.
`
`Petitioners also request the ability to reserve a portion of their total time for
`
`presenting rebuttal arguments after Patent Owner’s presentation. See November
`
`2019 Consolidated Trial Practice Guide at 83.
`
`Pursuant to 37 C.F.R § 42.70(a), and without intending to waive any issue not
`
`specifically identified, Petitioners request the ability to present arguments on all
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`instituted grounds of alleged unpatentability, any issues raised in the parties’ papers
`
`in this trial and the Board’s institution decision, and any other issues the Board
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`deems necessary for issuing a final written decision, including the following issues:
`
`1
`
`
`
`1. Grounds 1-6 of Invalidity as addressed in either the IPR 2021-01492
`
`Petition or IPR 2021-01493 Petition, or in the Response, Reply, or Sur-
`
`Reply thereto;
`
`2.
`
`The arguments and evidence raised in the Petition, Response, Reply, or
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`Sur-Reply in either IPR 2021-01492 or IPR 2021-01493, including
`
`claim construction issues; and
`
`3. Any issues raised at the Board’s request.
`
`
`
`Respectfully submitted,
`
`CHARHON CALLAHAN ROBSON
`& GARZA, PLLC
`
`
`
`
`/s/ Craig Tolliver
`Craig Tolliver (Reg. No. 45,975)
`(Lead Attorney for Petitioners)
`George “Jorde” Scott (Reg. No. 62,859)
`John C. Heuton (Reg. No. 62,467)
`
`3333 Lee Parkway
`Suite 460
`Dallas, TX 75219
`(214) 521-6400
`
`
`
`Dated: May 3, 2023
`
`
`
`
`
`
`
`
`
`
`
`2
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies that the
`
`above Petitioners’ Request for Oral Argument was served on counsel for Patent
`
`Owner via e-mail, as authorized by Patent Owner, at the following e-mail addresses:
`
`Thomas Dunham tomd@cherianllp.com
`Elizabeth O’Brien elizabetho@cherianllp.com
`Robert Harkins
`bobh@cherianllp.com
`
`
`
`CHARHON CALLAHAN ROBSON &
`GARZA, PLLC
`
`
`
`
`/s/ Craig Tolliver
`Craig Tolliver (Reg. No. 45,975)
`(Lead Attorney for Petitioners)
`
`
`
`
`
`
`
`
`
`
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`
`
`
`
`
`
`Dated: May 3, 2023
`
`
`
`
`3
`
`
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