`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________
`
`APPLE INC.,
`Petitioner
`
`v.
`
`BILLJCO LLC,
`Patent Owner
`
`
`CASE: IPR2022-00131
`U.S. PATENT NO. 8,639,267
`
`_______________________
`
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`PATENT OWNER'S REQUEST FOR ORAL ARGUMENT
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`Patent Owner’s Request for Oral Argument
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`IPR2022-00131
`U.S. Patent 8,639,267
`
`
`
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`Pursuant to 37 C.F.R. § 42.70 and the Board’s May 23, 2022 Scheduling Order
`
`(Paper 8), Patent Owner BillJCo, LLC respectfully requests oral argument on all
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`outstanding issues, specifically including, but not limited to the following issues.
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`Oral argument is presently scheduled for February 22, 2023 (Paper No. 8,
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`“Scheduling Order”).
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`
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`Without waiving any issue not specifically identified herein, Patent Owner
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`specifies at least the following issues to be presented by Patent Owner at oral
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`argument:
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`1.
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`2.
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`Proper construction of the relevant claims of the 8,639,267 Patent;
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`Arguments and evidence that the Challenged Claims of the 8,639,267
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`Patent are not obvious in view of Haberman.
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`3. Arguments and evidence that the Challenged Claims of the 8,639,267
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`Patent are not obvious in view of Haberman in view of Boger.
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`4. Arguments and evidence that the Challenged Claims of the 8,639,267
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`Patent are not obvious in view of Vanluijt.
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`5.
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`Rebuttal to Petitioner's arguments and evidence on all matters including
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`the issues listed above.
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`41019022.1
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`1
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`6.
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`Arguments on all issues specified by Petitioner and/or the Board for
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`argument;
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`7.
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`Any other issues raised in motions or papers filed and/or to be filed in
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`this proceeding, including any Motions to Strike/Exclude and/or Oppositions to
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`Motions to Strike/Exclude; and/or objections to demonstrative exhibits, and/or any
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`other motion or paper filed by any party before oral argument; and
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`8.
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`Any other outstanding motions and pleadings, and other issues upon
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`which the Board seeks clarification and/or that the Board deems necessary for
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`issuing a Final Written Decision.
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`
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`Patent Owner requests 45 minutes for argument time for a total of 1 hour and
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`30 minutes for the session. To the extent the Board schedules this hearing to last
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`more or less than the total hearing time requested by Patent Owner, Patent Owner
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`requests to be give half the total length.
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`
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`If this oral argument cannot be held in-person, Patent Owner requests the
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`hearing take place via video conference. Patent Owner requests the ability to present
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`demonstratives and exhibits to the Board and have the ability to have Patent Owner’s
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`counsel attend the video conference from separate locations.
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`
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`If this oral argument can be held in-person, Patent Owner requests the ability
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`to use audio-visual equipment to display demonstratives and exhibits. Patent Owner
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`41019022.1
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`2
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`also requests that the its counsel be allowed to use computers at counsel’s table,
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`including consultation and running audio-visual presentations.
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`Respectfully Submitted,
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`Brian R. Michalek
`Brian R. Michalek (Reg. No. 65,816)
`Joseph M. Kuo (Reg. No. 38,943)
`Saul Ewing, LLP
`161 N. Clark Street, Suite 4200
`Chicago, Illinois 60601
`Tel: (312) 876-7151
`Brian.Michalek@saul.com
`Joseph.Kuo@saul.com
`
`Brian Landry (Reg. No. 52,074)
`Saul Ewing, LLP
`131 Dartmouth Street, Suite 501
`Boston, MA 02116
`Tel: (617) 912-0969
`Brian.Landry@saul.com
`
`Counsel for Patent Owner, BillJCo, LLC
`
`
`Date: January 11, 2023
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`Mailing address for all correspondence:
`Saul Ewing, LLP
`Centre Square West
`1500 Market Street, 38th Floor
`Philadelphia, PA 19102-2186
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`41019022.1
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`3
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`Certification of Service Under 37 C.F.R. § 42.6(e)(4)
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`The undersigned hereby certifies that on January 11, 2023, I caused a true and
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`correct copy of the NOTICE OF REQUEST FOR ORAL ARGUMENT to be served
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`on the following counsel for Petitioner by electronic mail to the following email
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`addresses:
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`Larissa S. Bifano
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`Jonathan Hicks
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`Zachary Conrad
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`
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`larissa.bifano@dlapiper.com
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`jonathan.hicks@dlapiper.com
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`Zack.Conrad@dlapiper.com
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`Date: January 11, 2023
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`
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`
`
`/Brian R. Michalek/
`(Reg. No. 65,816)
`Attorney for Patent Owner
`
`41019022.1
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`4
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