`
`_________________________
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________________
`
` THE DATA COMPANY TECHNOLOGIES INC.,
`
`Petitioner
`
`v.
`
`BRIGHT DATA LTD.,
`
`Patent Owner
`
`_________________________
`
`Case IPR2022-00135
`
`Patent No. 10,257,319
`
`_________________________
`
`
`
`
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`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
`
`
`
`
`
`IPR2022-00135 of Patent No. 10,257,319
`
`Pursuant to 37 C.F.R. § 42.70 and the Board’s Scheduling Order (Paper 13),
`
`Patent Owner respectfully requests oral argument in this proceeding, IPR2022-
`
`00135, which is currently scheduled for March 1, 2023. See Paper 13 at 12.
`
`Patent Owner respectfully requests that each party be provided with sixty (60)
`
`minutes of argument time. Patent Owner respectfully requests that Patent Owner be
`
`provided the opportunity to present a brief sur-rebuttal within the allotted argument
`
`time.
`
`Without intending to waive any issues not specifically identified, Patent
`
`Owner wishes to present arguments on the following issues:
`
`1. Petitioner has not met its burden of proof that the challenged claims
`
`are unpatentable;
`
`2. Any of the preliminary findings in the Board’s Institution Decision
`
`(Paper 12);
`
`3. Any of the arguments raised in the parties’ papers;
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`4. Any issues specified in Petitioner’s Request for Oral Argument (Paper
`
`33);
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`5. Rebuttal of any issues properly raised by Petitioner in this proceeding;
`
`6. Any procedural or evidentiary issues in this proceeding; and
`
`7. Any other issues on which the Board seeks information or clarification.
`
`
`
`1
`
`
`
`
`
`IPR2022-00135 of Patent No. 10,257,319
`
`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: January 18, 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.
`
`
`
`2
`
`
`
`
`
`IPR2022-00135 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 Petitioner, at the
`
`following email addresses:
`
`MRader-PTAB@wolfgreenfield.com
`
`AWichman-PTAB@wolfgreenfield.com
`
`GNieberg-PTAB@wolfgreenfield.com
`
`Marie.McKiernan@wolfgreenfield.com
`
`
`
`
`
`
`Date: January 18, 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
`
`
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