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