`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`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 No. IPR2022-01109
`Patent No. 10,257,319
`_____________
`
`
`
`PETITIONERS’ AUTHORIZED REPLY TO
`PATENT OWNER’S PRELIMINARY RESPONSE
`
`
`
`
`
`Exhibit
`1001
`1002
`1003
`1004
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`1012
`
`1013
`
`1014
`
`LISTING OF EXHIBITS
`
`
`Description
`U.S. Patent No. 10,257,319
`Prosecution History of U.S. Patent No. 10,257,319
`Declaration of Prof. Dave Levin (“Levin”)
`Curriculum Vitae of Prof. Dave Levin
`Patent Owner’s Opening Claim Construction Brief, Luminati Net-
`works Ltd. v. Teso LT et al., 2:19-cv-00395-JRG, D.I. 126 (E.D. Tex.
`Sept. 29, 2020)
`Claim Construction Opinion and Order, Luminati Networks Ltd. v.
`Teso LT et al., 2:19-cv-00395-JRG, D.I. 191 (E.D. Tex. Dec. 7, 2020)
`Patent Owner’s Opposition to Motion to Dismiss, Luminati Networks
`Ltd. v. Teso LT et al., 2:19-cv-00395-JRG, D.I. 28 (E.D. Tex. Apr. 7,
`2020)
`Corrected Patent Owner’s Preliminary Response, Code200, UAB, et
`al. v. Luminati Networks Ltd., IPR2020-01266, Paper 16 (PTAB Dec.
`9, 2020)
`Supplemental Claim Construction Order, Bright Data Ltd. v. Teso LT
`et al., 2:19-cv-00395-JRG, D.I. 453 (E.D. Tex. Aug. 6, 2021)
`U.S. Patent Application Publication No. 2008/0228938 (“Plamon-
`don”)
`Declaration of Sandy Ginoza for IETF
`Ginoza Decl. Exh. 1, RFC 793: Transmission Control Protocol -
`DARPA Internet Program Protocol Specification, Information Sci-
`ences Institute (September 1981) (“RFC 793”)
`Ginoza Decl. Exh. 2, RFC 1001: Protocol Standard for a NetBIOS
`Service on a TCP/UDP Transport: Concepts and Methods, NetBIOS
`Working Group (March 1987) (“RFC 1001”)
`Ginoza Decl. Exh. 3, RFC 1122: Requirements for Internet Hosts --
`Communication Layers, Internet Engineering Task Force (October
`1989) (“RFC 1122”)
`
`
`
`
`
`- i -
`
`
`
`1015
`
`1016
`
`1017
`
`1018
`
`1019
`
`1020
`
`1021
`1022
`
`1023
`1024
`1025
`1026
`
`1027
`1028
`1029
`
`Ginoza Decl. Exh. 4, RFC 1630: Universal Resource Identifiers in
`WWW - A Unifying Syntax for the Expression of Names and Ad-
`dresses of Objects on the Network as used in the World-Wide Web,
`Network Working Group (June 1994) (“RFC 1630”)
`Ginoza Decl. Exh. 5, RFC 1738: Uniform Resource Locators (URL),
`Network Working Group (December 1994) (“RFC 1738”)
`Ginoza Decl. Exh. 6, RFC 2187: Application of Internet Cache Proto-
`col (ICP), version 2, National Laboratory for Applied Network Re-
`search/UCSD (September 1997) (“RFC 2187”)
`Ginoza Decl. Exh. 7, RFC 2616: Hypertext Transfer Protocol --
`HTTP/1.1, The Internet Society (June 1999) (“RFC 2616”)
`Ginoza Decl. Exh. 8, RFC 2960: Stream Control Transmission Proto-
`col, The Internet Society (October 2000) (“RFC 2960”)
`Ginoza Decl. Exh. 9, RFC 6520: Transport Layer Security (TLS) and
`Datagram Transport Layer Security (DTLS) Heartbeat Extension, In-
`ternet Engineering Task Force (February 2012) (“RFC 6520”)
`Declaration of Gordon MacPherson for IEEE
`MacPherson Decl. Exh. A, IEEE 802.11-2007 - IEEE Standard for In-
`formation Technology - Telecommunications and Information Ex-
`change Between Systems – Local and Metropolitan Area Networks -
`Specific Requirements - Part 11: Wireless LAN Medium Access Con-
`trol (MAC) and Physical Layer (PHY) Specifications, June 12, 2007
`(“IEEE 802.11-2007”)
`U.S. Patent Application Publication No. 2006/0026304 (“Price”)
`U.S. Patent Application Publication No. 2009/0055471 (“Kozat”)
`U.S. Patent No. 10,484,510
`Pages from W. R. Stevens, TCP/IP Illustrated, Volume 1: The Proto-
`cols. Canada: Addison-Wesley, 1994, chs. 1 & 18, bibliography (“Ste-
`vens”)
`Prosecution History of U.S. Patent No. 10,491,712
`U.S. Patent Application Publication No. 2008/0072178 (“Budzisch”)
`U.S. Patent Application Publication No. 2002/0178217 (“Nguyen”)
`
`
`
`
`
`- ii -
`
`
`
`1030
`1031
`
`1032
`1033
`
`1034
`1035
`1036
`1037
`1038
`
`1039
`
`1040
`1041
`
`1042
`1043
`1044
`
`1045
`
`U.S. Patent Publication No. 2005/0125412 (“Glover”)
`U.S. Patent Application Publication No. 2007/0177513 (“Kuokkan-
`nen”)
`U.S. Patent No. 7,761,500 (“Eckert”)
`Pages from L.L. Peterson, B.S. Davie, Computer Networks: A Systems
`Approach, 4th ed. San Francisco, CA: Elsevier, 2007, chs. 1-2 (“Pe-
`terson”)
`U.S. Patent Application Publication No. 2009/0187654 (“Raja”)
`U.S. Patent Application Publication No. 2002/0169818 (“Stewart”)
`U.S. Patent No. 6,351,775 (“Yu-775”)
`U.S. Patent Application Publication No. 2002/0059371 (“Jamail”)
`P. Mell, T. Bergeron, and D. Henning, “Creating a Patch and Vulner-
`ability Management Program,” NIST Special Publication 800-40 Ver-
`sion 2.0, 2005 (“SP 800-40 Ver. 2”)
`U.S. Patent Application Publication No. 2004/0153473
`(“Hutchinson”)
`U.S. Patent Application Publication No. 2006/0236083 (“Fristch”)
`U.S. Patent Application Publication No. 2010/0115613
`(“Ramaswami”)
`U.S. Patent No. 8,041,784 (“Amidon”)
`U.S. Patent No. 8,655,838 (“Wright”)
`A. Rowstron and P. Druschel, “Pastry: Scalable, Decentralized Object
`Location, and Routing for Large-Scale Peer-to-Peer Systems.”
`IFIP/ACM International Conference on Distributed Systems Platforms
`and Open Distributed Processing: Middleware 2001, pp. 329-350
`(2001) (“Rowstron”)
`S. Ratnasamy, M. Handley, R. Karp and S. Shenker, “Topologically-
`aware overlay construction and server selection.” Proceedings
`Twenty-First Annual Joint Conference of the IEEE Computer and
`Communications Societies, vol. 3, pp. 1190-1199 (2002)
`(“Ratnasamy”)
`
`
`
` - iii -
`
`
`
`1046
`
`1047
`
`1048
`
`1049
`1050
`
`1051
`1052
`1053
`1054
`1055
`
`1056
`1057
`
`1058
`
`1059
`
`V. N. Padmanabhan and L. Subramanian, “An Investigation of Geo-
`graphic Mapping Techniques for Internet Hosts.” ACM SIGCOMM
`Computer Communication Review, vol. 3, No. 4, pp. 173–185 (2001)
`(“Padmanabhan”)
`M.J. Freedman, K. Lakshminarayanan, and D. Mazières, “OASIS:
`Anycast for Any Service.” Proceedings of the 3rd Conference on Net-
`worked Systems Design & Implementation, vol. 3, pp. 129-142 (2006)
`(“Freedman-2006”)
`S. Agarwal and J.R. Lorch, “Matchmaking for Online Games and
`Other Latency-Sensitive P2P Systems.” ACM SIGCOMM Computer
`Communication Review, vol. 39, No. 4, pp. 315-326 (2009)
`(“Agarwal”)
`U.S. Patent No. 8,144,611 (“Agarwal-611”)
`H. Casanova, “Benefits and Drawbacks of Redundant Batch Re-
`quests.” Journal of Grid Computing, vol. 5, pp. 235–250 (2007)
`(“Casanova”)
`U.S. Patent Application Publication No. 2008/0298328 (“Sharma”)
`U.S. Patent Application Publication No. 2009/0204700 (“Sudhakar”)
`U.S. Patent Application Publication No. 2006/0212584 (“Yu”)
`U.S. Patent No. 7,865,585 (“Samuels”)
`S. J. Murdoch, “New Tor distribution for testing: Tor Browser Bun-
`dle,” January 30, 2008 post to tor-talk mailing list, available at
`https://lists.torproject.org/pipermail/tor-talk/2008-Janu-
`ary/007837.html
`U.S. Patent Application Publication No. 2009/0222515 (“Thompson”)
`Defendants’ Section 282 Disclosure, Bright Data Ltd. v. Teso LT et
`al., Case No. 2:19-cv-00395-JRG, D.I. 450 (E.D. Tex. July 16, 2021)
`Docket, Bright Data Ltd. v. NetNut Ltd., Case No. 2:21-cv-00225-
`JRG (E.D. Tex.) (as of Nov. 2, 2021)
`Notice of Filing Invalidity Contentions, Bright Data Ltd. v. Tefincom
`S.A. d/b/a NordVPN, Case No. 2:19-cv-00414-JRG, D.I. 37 (E.D.
`Tex. Mar. 3, 2021)
`
`
`
` - iv -
`
`
`
`1060
`
`1061
`
`1062
`1063
`
`1064
`
`1065
`
`1066
`
`1067
`
`1068
`
`1069
`
`1070
`
`1071
`1072
`1073
`1074
`
`Docket, Luminati Networks Ltd. v. BI Science (2009) Ltd., Case No.
`2:19-cv-397-JRG (E.D. Tex.) (as of Nov. 2, 2021)
`Motion for Summary Judgement, Bright Data Ltd. v. Teso LT et al.,
`Case No. 2:19-cv-00395-JRG, D.I. 282 (E.D. Tex. Feb. 8, 2021)
`RESERVED
`Amended Complaint, Bright Data Ltd. v. Tefincom S.A. d/b/a
`NordVPN, Case No. 2:19-cv-00414-JRG, D.I. 22 (E.D. Tex. Nov. 12,
`2020)
`Docket, Bright Data Ltd. v. Teso LT et al., Case No. 2:19-cv-00395-
`JRG (E.D. Tex.) (as of Nov. 2, 2021)
`Docket, Bright Data Ltd. v. Tefincom S.A. d/b/a NordVPN, Case No.
`2:19-cv-00414-JRG (E.D. Tex.) (as of Nov. 2, 2021)
`Order Denying Motion to Stay Pending Inter Partes Review, Bright
`Data Ltd. v. Teso LT et al., Case No. 2:19-cv-00395-JRG, D.I. 157
`(E.D. Tex. Oct. 30, 2020)
`Decision Denying Institution of Inter Partes Review of U.S. Patent
`No. 10,257,319, Code200, UAB, et al. v. Luminati Networks Ltd.,
`IPR2020-01266, Paper 18 (PTAB Dec. 23, 2020)
`Decision Denying Institution of Inter Partes Review of U.S. Patent
`No. 10,484,510, Code200, UAB, et al. v. Luminati Networks Ltd.,
`IPR2020-01358, Paper 11 (PTAB Dec. 23, 2020)
`Petition for Inter Partes Review of U.S. Patent No. 10,257,319,
`Code200, UAB et al. v. Luminati Networks Ltd., IPR2020-01266, Pa-
`per 5 (PTAB Jul. 14, 2020)
`Petition for Inter Partes Review of U.S. Patent No. 10,484,510,
`Code200, UAB et al. v. Luminati Networks Ltd., IPR2020-01358, Pa-
`per 5 (PTAB Jul. 28, 2020)
`Prosecution History of U.S. Patent No. 8,560,604
`Prosecution History of U.S. Patent No. 10,069,936
`Prosecution History of U.S. Patent No. 10,484,510
`Order, Bright Data Ltd. v. Teso LT et al., Case No. 2:19-cv-00395-
`JRG, D.I. 493 (E.D. Tex. Sep. 21, 2021)
`
`
`
`
`
`- v -
`
`
`
`1075
`
`1076
`
`1077
`1078
`
`1079
`
`1080
`
`1081
`
`1082
`
`1083
`
`1084
`
`1085
`
`1086
`
`1087
`
`1088
`
`Plaintiff’s Motion for Partial Summary Judgment on Certain Invalid-
`ity Grounds, Bright Data Ltd. v. Tefincom S.A. D/B/A NordVPN, Case
`No. 2:19-cv-00414-JRG, D.I. 97 (E.D. Tex. Sep. 27, 2021)
`Defendant’s Motion for Summary Judgment of Invalidity of the ’319,
`’510, and ’511 Patents, Bright Data Ltd. v. Tefincom S.A. D/B/A
`NordVPN, Civil Action No. 2:19-CV-00414-JRG D.I. 99 (E.D. Tex.
`Sep. 29, 2021)
`Declaration of Adam R. Wichman
`Revised Joint Pretrial Order, Bright Data Ltd. v. Teso LT et al., Case
`No. 2:19-cv-00395-JRG, D.I. 490 (E.D. Tex. Sept. 17, 2021)
`Comparison between current Petition and petition in IPR2022-00135
`(TDC IPR petition)
`Jury Verdict Form, Bright Data Ltd. v. Teso LT et al., Case No. 2:19-
`cv-00395-JRG, D.I. 516 (E.D. Tex. Nov. 5, 2021)
`Trial Transcript (select pages), Bright Data Ltd. v. Teso LT et al., Case
`No. 2:19-cv-00395-JRG, Vol. 5 (E.D. Tex. Nov. 5, 2021)
`Order, Bright Data Ltd. v. Teso LT et al., Case No. 2:19-cv-00395-
`JRG, D.I. 543 (E.D. Tex. Dec. 15, 2021)
`Order, Bright Data Ltd. v. Teso LT et al., Case No. 2:19-cv-00395-
`JRG, D.I. 580 (E.D. Tex. Mar. 16, 2022)
`Defendants’ Response to Motion for Preliminary and Permanent In-
`junction Against infringement, Bright Data Ltd. v. Teso LT et al.,
`Case No. 2:19-cv-00395-JRG, D.I. 570 (E.D. Tex. Jan. 18, 2022)
`Non-Final Office Action, Ex Parte Reexamination 90/014,876 (March
`23, 2022)
`Defendants’ Section 282 Disclosure, Bright Data Ltd. v. Teso LT et
`al., Case No. 2:19-cv-00395-JRG, D.I. 450 (E.D. Tex. July 16, 2021)
`USPTO Listing of Patents Assigned to Citrix Systems (2,702 As-
`signed Properties)
`September 28, 2022 e-mail correspondence from Deputy Chief Clerk
`for Trials, Patent Trial and Appeal Board, authorizing Reply to POPR
`
`
`
` - vi -
`
`
`
`I.
`
`
`INTRODUCTION
`
`As authorized by the Board in its September 28, 2022 e-mail (see Ex. 1088),
`
`Petitioners submit this five-page reply in response to Patent Owner’s Preliminary
`
`Response (“POPR”) (Paper 16). The Board should not exercise its discretion to deny
`
`institution. As explained below, all discretionary factors, especially in view of Di-
`
`rector Vidal’s August 23, 2022 sua sponte Decision vacating the denial of institution
`
`in Petitioners’ IPR2022-00861 and IPR2022-00862 (“Vidal Dec.”), confirm that de-
`
`nial is not warranted in this case.
`
`A. The General Plastic factors weigh against denial.
`
`Petitioners filed one stand-alone IPR challenging the validity of the ’319 pa-
`
`tent, which the Board discretionarily denied under Fintiv without analyzing the
`
`IPR’s merits. See IPR2020-01266 (“Code200 First IPR”), Paper 18. Petitioners’ two
`
`subsequent IPRs have been “copycat” petitions with motions to join the underlying
`
`IPRs in an understudy role. See IPR2022-00861 (“Code200 Second IPR”); IPR2022-
`
`01109 (“Code200 Third IPR”). As such, many of the General Plastic factors either
`
`weigh against denial or do not apply here.
`
`In initially denying Petitioners’ Second IPR, the Board applied General Plas-
`
`tic Factor 1 and held that the failure to submit a Sand Revolution II stipulation
`
`“weighs strongly in favor of exercising discretion to deny institution and outweighs
`
`the fact that the Board did not substantively address the merits of the prior petition.”
`
`
`
`
`
`- 1 -
`
`
`
`Code200 Second IPR, Paper 17 at 12. In vacating the Board’s decision, Director
`
`Vidal disagreed and held that Petitioners should be allowed “‘the opportunity to pur-
`
`sue a decision on the merits’ in a second-filed petition, when the first-filed petition
`
`was not evaluated on the merits” to “‘best balance[] the desires to improve patent
`
`quality and patent-system efficiency against the potential for abuse of the review
`
`process by repeated attacks on patents.’” Vidal Dec. at 4-5 (quoting Intel Corp. v.
`
`VLSI Tech. LLC, IPR2022-00366, Paper 14 at 9-10 (June 8, 2022)); see also Cuozzo
`
`Speed Techs., LLC v. Lee, 579 U.S. 261, 272 (2016). This renders Patent Owner’s
`
`argument that the Board should discretionarily deny the present IPR because Peti-
`
`tioners did not provide a Sand Revolution II stipulation irrelevant.1 Instead, because
`
`both the Code200 First IPR and Code200 Second IPR were discretionarily denied
`
`without substantive analysis,2 Factor 1 weighs against denial.
`
`
`1 In any event, Petitioners could not have made such a stipulation when they filed
`
`the First IPR (based on different art) because Petitioners were not aware of Plamon-
`
`don and could not have found it with reasonable diligence. See Paper 14 at 3-4. Re-
`
`gardless, Petitioners have now stipulated not to use Plamondon as prior art in any
`
`future litigation involving the ’319 patent. Id. at 1.
`
`2 The Code200 Second IPR and related motion for joinder remain currently pending,
`
`given the Vidal Decision.
`
`
`
`
`
`- 2 -
`
`
`
`Further, Director Vidal determined that General Plastic Factor 1 must be read
`
`in conjunction with Factors 2 and 3. See Vidal Dec. at 5. “Where the first-filed peti-
`
`tion under factor 1 was discretionarily denied or otherwise was not evaluated on the
`
`merits, factors 1-3 only weigh in favor of discretionary denial when there are ‘road-
`
`mapping’ concerns under factor 3 or other concerns under factor 2.” Id. When ana-
`
`lyzing Factor 3, the Board found “no evidence of road-mapping” in Petitioners’ Sec-
`
`ond IPR because it is a “copycat” petition. See IPR2022-00861, Paper 17 at 12-13.
`
`The Board should conclude the same here. Factor 3 has limited relevance, if any,
`
`where, as here, the petition is a “copycat” petition.3 Because there is no “road-map-
`
`ping” in the present petition, the Board should not discretionarily deny the petition.
`
`With respect to “fairness” and “efficiency” under Factors 2 and 6, Patent
`
`Owner argues that Petitioners “should have known about the primary reference Pla-
`
`mondon before filing the First Code200 Petition” and that “Petitioners’ repeated at-
`
`tacks place a substantial and unnecessary burden on the Board.” Paper 16 at 11. The
`
`PTAB’s Consolidated Trial Practice Guide (“TPG”), however, contemplates multi-
`
`ple petitions in which “[t]wo or more petitions filed against the same patent at or
`
`about the same time (e.g., before the first preliminary response by the patent owner)
`
`
`3 Patent Owner acknowledges that Factors 3 and 7 have limited relevance here be-
`
`cause the present IPR is a “copycat” petition. Paper 16 at 8 and 10.
`
`
`
`
`
`- 3 -
`
`
`
`may place a substantial and unnecessary burden on the Board and the patent owner
`
`and could raise fairness, timing, and efficiency concerns.” TPG at 59 (emphases
`
`added). In this case, however, Petitioners’ second and third petitions are “copycat”
`
`petitions based on already-instituted IPRs and were filed over the course of two
`
`years. Thus, in this case, where Petitioners agree to an understudy role, there is no
`
`additional burden on either the Patent Owner or the Board. Factors 2 and 6 do not
`
`weigh in favor of denial. See Vidal Dec. at 6 (“the Patent Owner’s concerns of fair-
`
`ness are outweighed by the benefits to the patent system of improving patent quality
`
`by reviewing the merits of the challenges raised in the petitions, which have not been
`
`addressed to date.”).
`
`B.
`
`The Fintiv factors weigh against denial.
`
`The Petition presents compelling evidence of unpatentability. The Board has
`
`now determined in three proceedings that petitioners “demonstrated a reasonable
`
`likelihood of prevailing” with respect to four different primary references invalidat-
`
`ing the ’319 patent claims. See IPR2022-00915; IPR2022-00135; IPR2021-01492.
`
`On this basis alone, the Board should not discretionarily deny institution. See Direc-
`
`tor Vidal’s June 22, 2022 Interim Procedure for Discretionary Denials in AIA Post-
`
`Grant Proceedings with Parallel District Court Litigation (“Guidance”) at 4-5.
`
`Since the Guidance issued, the Board has repeatedly declined to deny institu-
`
`tion based on compelling merits alone, without considering the other Fintiv factors,
`
`
`
`
`
`- 4 -
`
`
`
`and the Board may do so here. See, e.g., Samsung Elecs. Co. v. MemoryWeb, LLC,
`
`No. IPR2022-00221, Paper 10 (Aug. 1, 2022); Avail Medsystems, Inc. v. Teladoc
`
`Health, Inc., No. IPR2022-00445, Paper 9 (July 22, 2022). Where, as here, the peti-
`
`tion’s merits are “compelling,” this “alone demonstrates that the PTAB should not
`
`discretionarily deny institution under Fintiv.” Guidance at 3-5. Given the compelling
`
`evidence of unpatentability that exists here, Petitioners respectfully request the
`
`Board institute the present IPR.
`
`If the Board analyzes additional Fintiv factors, the balance weighs against de-
`
`nial. With respect to Factor 1 and the pending E.D. Texas litigation, Patent Owner
`
`states that it “is not aware of any cases in which Judge Gilstrap has reversed a jury
`
`verdict of no anticipation/obviousness.” Paper 16 at 13. Petitioners, however, previ-
`
`ously cited Personal Audio, where Judge Gilstrap did just that. See Motion for Join-
`
`der, Paper 7 at 9 (citing Personal Audio, LLC v. CBS Corp. 946 F.3d 1348, 1350-51
`
`(Fed. Cir. 2020)). In Personal Audio, the Federal Circuit affirmed Chief Judge Gil-
`
`strap’s final judgment terminating proceedings and vacating the jury verdict after
`
`the Federal Circuit affirmed the PTAB’s decision of unpatentability. Personal Au-
`
`dio, 946 F.3d at 1354. Patent Owner’s additional arguments pertaining to Fintiv are
`
`redundant to its arguments pertaining to General Plastic and are addressed above.
`
`In sum, the Board should not discretionarily deny institution of the present IPR.
`
`
`
`
`
`- 5 -
`
`
`
`Dated: October 11, 2022
`
`
`
`Respectfully submitted,
`
`CHARHON CALLAHAN ROBSON &
`GARZA, PLLC
`
`
`/John C. Heuton/
`
`George “Jorde” Scott (Reg. No. 62,859)
`(Lead Attorney for Petitioners)
`John C. Heuton (Reg. No. 62,467)
`Craig Tolliver (Reg. No. 45,975)
`3333 Lee Parkway, Suite 460
`Dallas, TX 75219
`(214) 521-6400
`
`
`
`
`
`- 6 -
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies that the
`
`above Petitioners’ Authorized Reply to Patent Owner’s Preliminary Response was
`
`served on counsel for Patent Owner via e-mail on October 11, 2022, as authorized
`
`by Patent Owner, at the following e-mail addresses:
`
`Thomas Dunham tomd@cherianllp.com
`Elizabeth O’Brien elizabetho@cherianllp.com
`
`The above Petitioners’ Authorized Reply to Patent Owner’s Preliminary Re-
`
`sponse was also served via e-mail on October 11, 2022 on Petitioners’ counsel in
`
`pending The Data Company Technologies Inc. v. Bright Data Ltd., IPR2022-00135:
`
`Michael Rader MRader-PTAB@wolfgreenfield.com
`Adam Wichman AWichman-PTAB@wolfgreenfield.com
`Gregory Nieberg GNieberg-PTAB@wolfgreenfield.com
`
`
`CHARHON CALLAHAN ROBSON &
`GARZA, PLLC
`
`/John C. Heuton/
`
`
`
`
`
`
`
`John C. Heuton (Reg. No. 62,467)
`(Attorney for Petitioners)
`
`
`
`
`
`
` Dated: October 11, 2022
`
`
`
`
`
`
`7
`
`
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