`
`_____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________________
`
`The Walt Disney Company, Disney Streaming Services LLC, and Hulu LLC,
`
`Petitioner,
`
`- vs. -
`
`WAG Acquisition, LLC,
`
`Patent Owner.
`
`_____________________________
`
`IPR2022-01227
`U.S. Patent No. 9,762,636
`_____________________________
`
`PETITIONER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`IPR2022-01227
`Petitioner’s Request for Oral Argument
`Pursuant to 37 C.F.R. 42.70(a), Petitioner, The Walt Disney Company,
`
`Disney Streaming Services LLC, and Hulu LLC, requests oral argument on the
`
`issues set forth below at a place and time set by the Board. Oral argument is
`
`presently scheduled for November 13, 2023 (Paper No. 21, “Revised Scheduling
`
`Order”).
`
`Without waiving any issue not specifically identified herein, Petitioner
`
`specifies at least the following issues to be presented by Petitioner at oral
`
`argument:
`
`1. Proper construction of the relevant claims of the ’636 Patent;
`
`2. Arguments and evidence that claims 1-12 are obvious in view of Carmel
`
`alone and Carmel in view of Shteyn.
`
`3. Rebuttal to Patent Owner’s arguments and evidence on all matters
`
`including the issues listed above.
`
`Petitioner requests 45 minutes for argument time for a total of 1 hour and 30
`
`minutes for the session. To the extent the Board schedules this hearing to last more
`
`or less than the total hearing time requested by Petitioner, Petitioner requests to be
`
`given half the total length.
`
`The issues in this proceeding and the IPR2022-01228 proceeding substantially
`
`overlap and therefore Petitioner requests a single hearing to address the issues in
`
`both proceedings. Petitioner also submitted an email to the Board on September 26,
`
`
`
`IPR2022-01227
`Petitioner’s Request for Oral Argument
`2023 requesting to consolidate both hearings to a single hearing and currently
`
`waiting for approval from the Board.
`
`Petitioner requests the oral hearing to be held in person, Petitioner requests
`
`the ability to use a computer, projector, and screen to display demonstratives and
`
`exhibits. Petitioner also requests that two attorneys at Petitioner’s counsel’s table
`
`be allowed to use computers at the hearing (in addition to counsel making the
`
`argument using his or her computer to show the demonstratives), to avoid the need
`
`for the parties to bring entire paper copies of the record into the hearing room and to
`
`facilitate efficient answering of panel questions.
`
`If this oral hearing cannot be held in person, Petitioner requests that the
`
`hearing take place via video conference. Petitioner requests the ability to present
`
`demonstratives and exhibits to the Board and the ability to have Petitioner’s counsel
`
`attend the video conference from separate locations.
`
`Date: September 26, 2023
`
` Respectfully submitted,
`
`
`
`By: /Larissa S. Bifano/
`Larissa S. Bifano
`Reg. No. 59,051
`DLA PIPER
`33 Arch Street 26th Floor
`Boston, Massachusetts 02110-1447
`Phone: 617-406-6013
`larissa.bifano@dlapiper.com
`Counsel for Petitioner
`
`
`
`IPR2022-01227
`Petitioner’s Request for Oral Argument
`
`CERTIFICATE OF SERVICE
`The undersigned certifies that a true and correct copy of Petitioner’s Request
`
`for Oral Argument has been served on the Patent Owner via email to Patent Owner
`
`by serving the email correspondence addresses of record as follows:
`
`ron.abramson@listonabramson.com
`michael.lewis@listonabramson.com
`ari.jaffess@listonabramson.com
`gina.kim@listonabramson.com
`
`Date: September 26, 2023
`
`By: /Larissa S. Bifano/
`Larissa S. Bifano
`Reg. No. 59,051
`
`Counsel for Petitioner
`
`
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