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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`EPIC GAMES, INC.,
`Petitioner,
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`v.
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`INGENIOSHARE, LLC,
`Patent Owner
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`U.S. PATENT NO. 10,492,038
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`Case IPR2022-00294
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`Petitioner’s Request for Oral Argument
`IPR2022-00294
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`Pursuant to 37 C.F.R. § 42.70(a), Petitioner respectfully requests oral
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`argument. Petitioner requests a consolidated oral argument covering issues with
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`respect to IPR2022-00294 and IPR2022-00295. The issues to be argued with respect
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`to these cases include the following:
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`1. Obviousness of U.S. Patent No. 10,492,038 on the instituted grounds set
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`forth in IPR2022-00294:
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`• Ground I — Claims 7, 10–12, 22–24, 33–36, 38–41, 46, 49, 51–53,
`55, 57–58, and 64–66 are obvious under 35 U.S.C. § 103 in view of
`Diacakis;
`• Ground II — Claims 8, 9, 43, 44, 47, 48, 50, and 54 are obvious
`under 35 U.S.C. § 103 in view of Diacakis in combination with
`Loveland;
`• Ground III — Claims 37, 42, 56, 59–63, and 67 are obvious under
`35 U.S.C. § 103 in view of Diacakis in combination with Takahashi;
`• Ground IV — Claim 45 is obvious under 35 U.S.C. § 103 in view
`of Diacakis in combination with Loveland and Takahashi.
`2. Obviousness of U.S. Patent No. 10,492,038 on the instituted grounds set
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`forth in IPR2022-00295:
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`• Ground I — Claims 7, 10–12, 22–24, 33–36, 38–41, 46, 49, 51–53,
`55, 57–58, and 64–66 are obvious under 35 U.S.C. § 103 in view of
`Tanigawa in combination with Hullfish;
`• Ground II — Claims 8, 9, 43, 44, 47, 48, 50, and 54 are obvious
`under 35 U.S.C. § 103 in view of Tanigawa in combination with
`Hullfish and Loveland;
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`Petitioner’s Request for Oral Argument
`IPR2022-00294
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`• Ground III — Claims 37, 42, 56, 59–63, and 67 are obvious under
`35 U.S.C. § 103 in view of Tanigawa in combination with Hullfish
`and Takahashi;
`• Ground IV — Claim 45 is obvious under 35 U.S.C. § 103 in view
`of Tanigawa
`in combination with Hullfish, Loveland, and
`Takahashi.
`3. Procedural and evidentiary issues raised, e.g., in Objections to Evidence.
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`4. Any additional issues on which the Board seeks information or
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`clarification.
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`Petitioner requests that each party be allowed a total of sixty (60) minutes for
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`its argument. Petitioner may reserve a portion of its time for rebuttal. Petitioner
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`further requests the use of audio-visual equipment to assist its arguments and to
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`display its demonstrative exhibits. If the Board decides oral argument will be
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`conducted in person, Petitioner requests a computer connectable projector, an
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`ELMO, and a screen. If instead the Board decides oral argument will be conducted
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`by remote videoconferencing, Petitioner requests permission to use video-
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`conferencing software to allow the presentation of demonstratives.
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`2
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` Date: January 25, 2023
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`Petitioner’s Request for Oral Argument
`IPR2022-00294
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`Respectfully submitted,
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`/s/ W. Todd Baker
`W. Todd Baker (No. 45,265)
`todd.baker@kirkland.com
`Postal and Hand-Delivery Address:
`KIRKLAND & ELLIS LLP
`1301 Pennsylvania Ave., N.W.
`Washington, D.C. 20004
`Telephone: (202) 389-5000
`Facsimile: (202) 389-5200
`
`Yimeng Dou (No. 69,770)
`yimeng.dou@kirkland.com
`Lindsey Y. Shi (pro hac vice admission)
`lindsey.shi@kirkland.com
`KIRKLAND & ELLIS LLP
`555 South Flower Street, Suite 3700
`Los Angeles, CA 90071
`Telephone: (213) 680-8400
`Facsimile: (213) 680-8500
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`Attorneys for Petitioner Epic Games, Inc.
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`3
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`Petitioner’s Request for Oral Argument
`IPR2022-00294
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing document was
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`served on January 25, 2023 by electronic mail on the attorneys of record below:
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`Cortney Alexander
`cortneyalexander@kentrisley.com
`Stephen R. Risley
`steverisley@kentrisley.com
`A courtesy copy was also served by via overnight delivery directed to the
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`attorney/agent of record for the patent as identified on USPTO PAIR and associated
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`with USPTO Customer No. 34,071 at the following address:
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`C. Thomas (No. 32,947)
`Peter Tong (No. 35,757)
`4010 Moorpark Ave., Ste. 211
`San Jose, CA 95117
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`/s/ W. Todd Baker
`W. Todd Baker (No. 45,265)
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`4
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