`
`IPR2022-01433
`Petitioner’s Objections to Patent Owner’s Demonstrative Exhibit
`Filed on behalf of Amazon.com, Inc., Amazon Web Services, Inc., and
`Amazon.com Services LLC
`
`By:
`J. DAVID HADDEN (Reg. No. 40,629)
`SAINA SHAMILOV (Reg. No. 48,266)
`BRIAN HOFFMAN (Reg. No. 39,713)
`JOHNATHAN CHAI (Reg. No. 75,690)
`JOHNSON KUNCHERIA (Reg. No. 69,093)
`KEVIN X. MCGANN (Reg. 48,793)
`FENWICK & WEST LLP
`801 California Street
`Mountain View, CA 94041
`Telephone: 650.988.8500
`Facsimile: 650.938.5200
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`AMAZON.COM, INC., AMAZON WEB SERVICES, INC.,
`AND AMAZON.COM SERVICES LLC,
`Petitioner,
`
`v.
`
`WAG ACQUISITION, LLC,
`Patent Owner.
`
`
`Case No. IPR2022-01433
`Patent 9,762,636
`_____________
`PETITIONER’S OBJECTIONS TO PATENT OWNER’S
`DEMONSTRATIVE EXHIBIT
`
`
`
`
`
`
`IPR2022-01433
`Petitioner’s Objections to Patent Owner’s Demonstrative Exhibit
`In the Order Granting Requests for Oral Argument (IPR2022-01430, Paper
`
`19; IPR2022-01433, Paper 19) dated November 1, 2023, the Board instructed the
`
`parties regarding any objections that remain after meeting and conferring: “The
`
`objections must identify with particularity which portions of the demonstrative
`
`exhibits are subject to objection and include a one-sentence statement of the reason
`
`for each objection. No argument or further explanation is permitted. The Board will
`
`consider any objections and schedule a conference call if deemed necessary.
`
`Otherwise, the Board will reserve ruling on the objections. Any objection to
`
`demonstrative exhibits that is not timely presented will be considered waived.”
`
`IPR2022-01433, Paper 19 at 5.
`
`For the reasons indicated below, Petitioner puts forth objections of two slides.
`
`Slide
`No.
`13
`
`Reason
`
`Portion Objected To Shown In
`
`The diagram is not in
`the record or in the
`challenged patents.
`
`
`
`
`
`
`
`1
`
`
`
`IPR2022-01433
`Petitioner’s Objections to Patent Owner’s Demonstrative Exhibit
`Slide
`Reason
`Portion Objected To Shown In
`No.
`19
`
`The diagram is not in
`the record or in
`Carmel and is
`misleading.
`
`
`
`
`Dated: December 7, 2023
`
`
`
`
`
`
`
`
`
`FENWICK & WEST LLP
`
`
`/J. David Hadden/
`J. DAVID HADDEN
`Reg. No. 40,629
`Attorney for Petitioner
`
`
`
`2
`
`
`
`IPR2022-01433
`Petitioner’s Objections to Patent Owner’s Demonstrative Exhibit
`CERTIFICATION OF SERVICE
`Pursuant to 37 C.F.R. § 42.6, the undersigned certifies that on December 7,
`
`2023, a true and correct copy of the foregoing PETITIONER’S OBJECTIONS TO PATENT
`
`OWNER’S DEMONSTRATIVE EXHIBIT was electronically served on Patent Owner’s
`
`lead and backup counsel at the following addresses:
`
`
`Ronald Abramson
`Liston Abramson LLP
`405 Lexington Ave., 46th Floor
`New York, NY 10174
`Telephone: (212) 257-1630
`Facsimile: (914) 462-4175
`Email:
`ron.abramson@listonabramson.com
`
`
`
`
`Dated: December 7, 2023
`
`Fenwick & West LLP
`801 California Street
`Mountain View, CA 94041
`
`
`M. Michael Lewis
`Ari J. Jaffess
`Gina K. Kim
`Liston Abramson LLP
`405 Lexington Ave., 46th Floor
`New York, NY 10174
`Telephone: (212) 257-1630
`Facsimile: (914) 462-4175
`Email:
`michael.lewis@listonabramson.com
`ari.jaffess@listonabramson.com
`gina.kim@listonabramson.com
`
`
`FENWICK & WEST LLP
`
`
`/J. David Hadden/
`J. DAVID HADDEN
`Reg. No. 40,629
`Attorney for Petitioner
`
`
`
`3
`
`
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