`
`_________________________
`
`
`
`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 IPR2021-01492
`
`Patent No. 10,257,319
`
`_________________________
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`IPR2021-01492 of Patent No. 10,257,319
`
`Pursuant to 37 C.F.R. § 42.70 and the Board’s Revised Joint Scheduling Order
`
`(Paper 27), Patent Owner respectfully requests oral argument in this proceeding,
`
`IPR2021-01492.
`
`Given the similarity of issues among IPR2021-01492, IPR2021-01493,
`
`IPR2022-00915, and IPR2022-00916, Patent Owner respectfully requests a
`
`consolidated oral argument covering all four IPRs in a single hearing. The parties in
`
`the four IPRs have agreed that a consolidated oral argument would be appropriate.
`
`See generally EX. 3005 at 1-2. The parties in the four IPRs recently proposed that
`
`the single hearing be held on June 9, 2023. Id. at 2.
`
`As noted in the email dated April 20, 2023, the parties recognize that there is
`
`a difference between the panels in the above four IPRs, with two of the three Judges
`
`overlapping between the panels. EX. 3005 at 2. As further noted in that same email,
`
`the parties, of course, defer to the Board’s decision about how logistically to
`
`coordinate the panels if the Board agrees that a single, coordinated hearing is
`
`appropriate. Id.
`
`In the responsive email dated April 21, 2023, the Board indicated that it agrees
`
`a single hearing on June 9, 2023 would serve the interests of efficiency. See EX.
`
`3005 at 1.
`
`
`
`
`
`1
`
`
`
`
`
`IPR2021-01492 of Patent No. 10,257,319
`
`Patent Owner respectfully requests that each side be provided with sixty (60)
`
`minutes of argument time. That is, sixty minutes for Patent Owner’s side and sixty
`
`minutes for the petitioners’ side (including Petitioners Code200, UAB, et al. and
`
`Petitioner Major Data UAB). The parties have agreed that the petitioners in the four
`
`IPRs will split the allotted time for the petitioners’ side such that they would not take
`
`more total time for the petitioners’ side than if there were only a single petitioner.
`
`EX. 3005 at 2.
`
`Patent Owner respectfully requests that Patent Owner be provided the
`
`opportunity to present a brief sur-rebuttal within the allotted argument time for
`
`Patent Owner’s side.
`
`Without intending to waive any issues not specifically identified, Patent
`
`Owner wishes to present arguments on the following issues:
`
`1. The petitioners have not met their burden of proof that the challenged
`
`claims are unpatentable;
`
`2. Any of the preliminary findings in the Board’s Institution Decisions;
`
`3. Any of the arguments properly raised in the parties’ papers;
`
`4. Any issues specified in the petitioners’ Request for Oral Argument;
`
`5. Rebuttal of any issues properly raised by the petitioners;
`
`6. Any procedural or evidentiary issues; and
`
`
`
`2
`
`
`
`
`
`IPR2021-01492 of Patent No. 10,257,319
`
`7. Any other issues on which the Board seeks information or clarification.
`
`Patent Owner respectfully requests that the oral argument be held remotely.
`
`Patent Owner respectfully requests that the Board provide a video conferencing
`
`platform and a public telephone line for the oral argument. Patent Owner respectfully
`
`requests the opportunity to display demonstratives and exhibits during oral
`
`argument.
`
`
`
`
`
`
`
`
`
`
`Date: May 4, 2023
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`By: /s/ Thomas M. Dunham
`Thomas M. Dunham
`Reg. No. 39,965
`
`Cherian LLP
`1901 L Street NW, Suite 700
`Washington, D.C. 20036
`(202) 838-1567
`
`ATTORNEY FOR PATENT OWNER,
`BRIGHT DATA LTD.
`
`
`
`
`
`
`
`3
`
`
`
`
`
`
`
`
`
`IPR2021-01492 of Patent No. 10,257,319
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies this paper
`
`was served on the undersigned date via email, as authorized by Petitioners, at the
`
`following email addresses:
`
`jscott@ccrglaw.com
`
`jheuton@ccrglaw.com
`
`ctolliver@ccrglaw.com
`
`
`
`
`
`Date: May 4, 2023
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`By: /s/ Thomas M. Dunham
`Thomas M. Dunham
`Reg. No. 39,965
`
`Cherian LLP
`1901 L Street NW, Suite 700
`Washington, D.C. 20036
`(202) 838-1567
`
`ATTORNEY FOR PATENT OWNER,
`BRIGHT DATA LTD.
`
`
`4
`
`
`
`
`
`
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