Trials
`Craig Tolliver
`Elizabeth O"Brien; Tom Dunham; Jason Bartlett; Ray Huang; Vincent Ma; John Heuton; Jorde Scott; Trials
`RE: IPRs 2021-01492, 2021-01493, 2022-00915, 2022-00916; Alignment of hearing dates
`Friday, April 21, 2023 2:46:30 PM
`
`From:
`To:
`Cc:
`Subject:
`Date:
`
`Counsel,
`
`From the Board –
`
`We have reviewed the parties’ request for a single coordinated hearing in these cases on June 9,
`2023 and agree that this is an efficient approach for the hearing. Accordingly, we approve the
`request.
`
`Please include the requested specific procedures for the coordinated hearing in the Requests for
`Oral Argument in the cases, which are due May 4, 2023. The proposed procedures should be
`consistent with those proposed in your April 20, 2023 email, including that the time required for the
`coordinated hearing will not be longer than that required if there were only a single petitioner.
`
`Regards,
`
`Esther Goldschlager
`Supervisory Paralegal Specialist
`Patent Trial & Appeal Board
`U.S. Patent & Trademark Office
`
`From: Craig Tolliver <ctolliver@ccrglaw.com>
`Sent: Thursday, April 20, 2023 10:10 AM
`To: Trials <Trials@USPTO.GOV>
`Cc: Elizabeth O'Brien <elizabetho@cherianllp.com>; Tom Dunham <tomd@cherianllp.com>; Jason
`Bartlett <jbartlett@mkwllp.com>; Ray Huang <rhuang@mkwllp.com>; Vincent Ma
`<VMa@mkwllp.com>; John Heuton <jheuton@ccrglaw.com>; Jorde Scott <jscott@ccrglaw.com>
`Subject: Re: IPRs 2021-01492, 2021-01493, 2022-00915, 2022-00916; Alignment of hearing dates
`
`CAUTION: This email has originated from a source outside of USPTO. PLEASE CONSIDER THE SOURCE before
`responding, clicking on links, or opening attachments.
`
`To the Honorable Board:
`
`I write regarding 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.). I
`represent the Code200 Petitioners, and have copied counsel for Petitioner Major Data UAB and
`Patent Owner Bright Data Ltd. on this email.
`
`Counsel for all parties have conferred and agree to ask the Board to coordinate the hearing dates
`for the above four IPRs so that a single hearing would be held. The hearing date for IPRs 2022-
`00915 and 2022-00916 is currently scheduled for June 9, while the hearing date for IPRs 2021-
`
`Exhibit 3002
`
`

`

`01492 and 2021-01493 is currently scheduled for June 29. Otherwise, the schedules are the same.
`
`The parties propose a coordinated hearing on June 9, with the Code200 and Major Data
`Petitioners splitting the time for petitioner argument such that they would not take more total
`time for the petitioners’ side than if there were only a single petitioner.
`
`The parties agree that a coordinated hearing would be appropriate for at least three reasons,
`which are briefly stated below.
`
`First, IPRs 2021-01492 and 2022-00915 both concern the same claims of Patent 10,257,319 and
`the same grounds of invalidity, while IPRs 2021-01493 and 2022-00916 both concern the same
`claims of Patent 10,484,510 and the same grounds of invalidity.
`
`Second, the Petitions, Responses, and Replies filed in IPRs 2022-00915 and 2021-01492 (’319
`patent) are substantially similar, while the Petitions, Responses, and Replies filed in IPRs 2022-
`00916 and 2021-01493 (’510 patent) are substantially similar. There are no substantive differences
`between the positions raised by the parties in the above sets of IPRs.
`
`Third, the Board has recently heard argument regarding the same patents in IPRs 2022-00135 and
`2022-00138.
`
`Finally, 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. 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.
`
`The parties are prepared to file a joint/agreed motion or to participate in a teleconference with
`the Board in order to effectuate the above coordination of hearing dates, if the Board so desires.
`
`Thank you,
`Craig Tolliver
`
`
`Craig Tolliver
`CCRG
`469-587-7263
`ctolliver@ccrglaw.com
`
`
`