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 IPR2023-00038
`
`Patent No. 10,257,319
`
`_________________________
`
`PATENT OWNER’S OPPOSITION TO
`PETITIONERS’ MOTION FOR JOINDER
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`_________________________
`
`
`
`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 IPR2023-00038
`
`Patent No. 10,257,319
`
`_________________________
`
`PATENT OWNER’S OPPOSITION TO
`PETITIONERS’ MOTION FOR JOINDER
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`IPR2023-00038 of Patent No. 10,257,319
`
`TABLE OF CONTENTS
`
`I.
`
`INTRODUCTION ........................................................................................................................ 1
`
`II. RESPONSE TO PETITIONERS’ STATEMENT OF MATERIAL FACTS
`(“SMF”) .................................................................................................................................................... 2
`
`III. ADDITIONAL STATEMENT OF MATERIAL FACTS (“AMF”) ....................... 5
`
`IV. LEGAL STANDARD ................................................................................................................. 6
`
`V. THE BOARD SHOULD EXERCISE ITS DISCRETION TO DENY
`JOINDER ................................................................................................................................................. 6
`
`A. WITHOUT JOINDER, THE PETITION IS TIME-BARRED ........................ 6
`
`B. PETITIONERS ATTEMPT TO MINIMIZE THE -1266 IPR ........................ 7
`
`C. PETITIONERS ATTEMPT TO MINIMIZE THE TEX. LITIGATION ........ 7
`
`D. PETITIONERS SHOULD NOT BE GIVEN UNLIMITED CHANCES TO
`CHALLENGE THE ‘319 PATENT ....................................................................... 9
`
`1. PETITIONERS ASK THE BOARD TO INSTITUTE TWO IDENTICAL
`PETITIONS WHICH IS INEFFICIENT AND UNFAIR .......................................... 10
`
`2. PETITIONERS FAIL TO PROVIDE A RANKING WHICH IS
`INEFFICIENT AND UNFAIR ............................................................................................. 12
`
`E. PETITIONERS FAIL TO MEET THEIR BURDEN ....................................12
`
`VI. CONCLUSION ............................................................................................................................ 13
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`
`
`ii
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`
`
`EX. 2001
`
`EX. 2002
`
`EX. 2003
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`IPR2023-00038 of Patent No. 10,257,319
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`PATENT OWNER’S LIST OF EXHIBITS
`
`Unopposed Motion to Extend Deadline to Answer or Otherwise
`Respond to Complaint and Set Briefing Schedule on Motion to
`Dismiss, Bright Data Ltd. v. Teso LT, UAB, et al., Case No.
`2:19-cv-00395, Dkt. 13 (E.D. Tex. Mar. 5, 2020)
`
`Defendants' Disclosure Pursuant to 35 U.S.C. § 282, Bright
`Data Ltd. v. Teso LT, UAB, et al., Case No. 2:19-cv-00395,
`Dkt. 450 (E.D. Tex. July 16, 2021)
`
`Motion for Summary Judgment, Bright Data Ltd. v. Teso LT,
`UAB, et al., Case No. 2:19-cv-00395, Dkt. 282 (E.D. Tex. Feb.
`8, 2021)(redacted version of Dkt. 277)
`
`
`
`
`
`
`
`
`iii
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`
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`
`
`I.
`
`INTRODUCTION
`
`IPR2023-00038 of Patent No. 10,257,319
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`Petitioners in IPR2023-00038 are seeking joinder to IPR2022-00915.
`
`Motion, Paper 13. The burden is on Petitioners to justify that joinder should be
`
`granted. 37 C.F.R. § 42.20(c). Petitioners have failed to meet their burden, as will
`
`be further discussed herein.
`
`Without joinder, the petition is time-barred under 35 U.S.C. § 315(b)
`
`because Patent Owner sued Petitioners for infringement of U.S. Patent No.
`
`10,257,319 (the “‘319 Patent”) in December 2019 in Case No. 2:19-cv-00395
`
`(E.D. Tex.)(the “Tex. Litigation”). The Tex. Litigation went to trial in November
`
`2021 where a jury entered a verdict finding the ‘319 Patent was not invalid based
`
`on Crowds.1
`
`Since being sued in December 2019, Petitioners admit they have repeatedly
`
`sought to challenge the ‘319 Patent in the USPTO, referencing:
`
`• IPR2020-01266 involving the same Crowds, Border, and Morphmix references;
`
`• Reexamination Control No. 90/014,875 involving the same Crowds, Border,
`
`and Morphmix references;
`
`
`1 Petitioner-defendants pursued invalidity based on Crowds, Border, and
`
`MorphMix throughout expert discovery, but chose to only present Crowds at trial.
`
`
`
`1
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`
`
`
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`• IPR2022-00861 involving the sane Crowds, Border, and Morphmix references;
`
`IPR2023-00038 of Patent No. 10,257,319
`
`• IPR2022-01109 involving a different reference, Plamondon; and
`
`• IPR2023-00038 involving the same Crowds, Border, and Morphmix references.
`
`See Motion at 1. Overall, this petition represents the petitioners’ sixth bite at the
`
`invalidity apple as to the ‘319 Patent. Petitioners have now filed four IPRs,
`
`requested 1 reexamination, and conducted 1 jury trial as to the ‘319 Patent. All but
`
`one of those challenges are based on the same Crowds, Border, and MorphMix
`
`references.
`
`As discussed below, Patent Owner respectfully requests the Board exercise
`
`its discretion and deny joinder of this petition for at least four reasons. First, the
`
`petition is time-barred, which favors denial. Second, the petitioners already had
`
`their chance to pursue invalidity of the ‘319 Patent based on the exact same
`
`references in the -1266 IPR and the Tex. Litigation. Third, given the unique
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`procedural posture of this petition, granting joinder raises concerns of inefficiency
`
`and unfairness. Fourth, the petitioners’ actions are not commensurate with an
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`“understudy” role.
`
`II. RESPONSE TO PETITIONERS’ STATEMENT OF MATERIAL
`
`FACTS (“SMF”)
`
`Response to SMF No. 2: This SMF is incomplete regarding executed
`
`
`
`2
`
`
`
`
`
`service. Defendants confirmed the Lithuanian Central Authority delivered a copy
`
`IPR2023-00038 of Patent No. 10,257,319
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`of the Complaint to Metacluster LT, UAB on 2/18/20, to Teso LT, UAB on
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`2/21/20, and to Oxysales, UAB on 3/3/20. EX. 2001. Regardless, Petitioners
`
`concede that the time-bar under 35 U.S.C. § 315(b) applies to the petition.
`
`Response to SMF No. 3: This SMF is misleading. The ‘319 Patent includes
`
`29 claims, with only claim 1 being independent. The Tex. Litigation involved
`
`invalidity challenges of anticipation/obviousness against the ‘319 Patent based on
`
`Crowds, Border, and MorphMix. EX. 2002. At trial, Defendants made the
`
`strategic decision to proceed with only alleged invalidity of claims 1 and 26 of the
`
`‘319 Patent based on anticipation by Crowds. The jury verdict was entered on
`
`11/5/21 finding no anticipation by Crowds. EX. 1024 at 5. The quotes from the
`
`11/5/21 trial transcript are taken out of context and regardless, the Court properly
`
`instructed the jury as to the burden for invalidity in district court trials.
`
`Response to SMF No. 4: This SMF is misleading regarding the status of
`
`post-trial briefing including the fully-briefed Motion for Enhanced Damages and
`
`Exception Case (Dkt. 541); Motion for Post-Trial Discovery (Dkt. 607); and Joint
`
`Motion for Entry of Post-Verdict Scheduling Order (Dkt. 613).
`
`Response to SMF No. 5: Patent Owner can neither admit nor deny this SMF
`
`because it is speculative. Petitioners cite only to Defendants’ Opposition (Dkt. 570)
`
`to Plaintiff’s Motion for injunctive relief which essentially argues dueling expert
`
`
`
`3
`
`
`
`
`
`testimony and makes no reference to Defendants’ intent to file post-trial motions.
`
`IPR2023-00038 of Patent No. 10,257,319
`
`Accordingly, Petitioners’ allegations in SMF No. 5 should be disregarded.
`
`Response to SMF No. 6: This SMF is incomplete because it does not
`
`identify the grounds/prior art in IPR2020-01266, which alleged
`
`anticipation/obviousness based on primary prior art references Crowds, Border,
`
`and MorphMix.
`
`Response to SMF No. 8: This SMF is incomplete because it does not
`
`identify the grounds/prior art in Control No. 90/014,875, which makes the exact
`
`same challenges as the petition in IPR2020-01266.
`
`Response to SMF No. 9: This SMF is incomplete because it does not
`
`identify the grounds/prior art in IPR2021-01492, filed by NetNut Ltd. (“NetNut”),
`
`which alleged anticipation/obviousness based on primary prior art references
`
`Crowds, Border, and MorphMix and is substantively identical to this petition.
`
`Response to SMF No. 10: This SMF is incomplete because it does not
`
`identify the grounds/prior art in IPR2022-00861, which makes the exact same
`
`challenges as in IPR2021-01492 and is substantively identical to this petition.
`
`Response to SMF No. 11: This SMF is incomplete because Patent Owner
`
`reached settlement with NetNut Ltd., the sole petitioner in IPR2021-01492, and the
`
`Board terminated NetNut from IPR2021-01492. See id., Paper 20 (PTAB May 27,
`
`2022).
`
`
`
`4
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`
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`
`
`Response to SMF No. 12: On October 19, 2022, the Board granted
`
`IPR2023-00038 of Patent No. 10,257,319
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`institution of IPR2022-00861 and joinder to IPR2021-01492. See IPR2022-00861,
`
`Paper 19. Patent Owner filed a request for rehearing on November 2, 2022 in view
`
`of, for example, IPR2022-00915, which was instituted on September 15, 2022. See
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`IPR2022-00861, Paper 22.
`
`Response to SMF No. 13: This SMF is incomplete because it does not
`
`identify the grounds/prior art in IPR2022-00135 and IPR2022-01109, which are
`
`based on a different primary prior art reference and are substantively identical.
`
`Response to SMF No. 17: Patent Owner can neither admit nor deny this
`
`SMF because Petitioners did not copy Patent Owner on their communications with
`
`Major Data UAB, the sole petitioner in IPR2022-00915.
`
`III. ADDITIONAL STATEMENT OF MATERIAL FACTS (“AMF”)
`
`AMF No. 1: Following the jury verdict on 11/5/2021, one or more of the
`
`instant petitioners have filed nine IPRs and two PGRs against Patent Owner:
`
`IPR2022-00353, IPR2022-00687, IPR2022-00861, IPR2022-00862, IPR2022-
`
`00936, IPR2022-01109, IPR2022-01110, PGR2022-00052, PGR2022-00061,
`
`IPR2023-00038 (this proceeding), and IPR2023-00039. In January 2022, Petitioner
`
`Metacluster LT, UAB also filed an infringement lawsuit against Patent Owner in
`
`Case No. 2:22-cv-00011 (E.D. Tex.). Patent Owner filed a Motion to Dismiss the
`
`Complaint (Dkt. 23) and Petitioner filed an Amended Complaint (Dkt. 26). Patent
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`
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`5
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`
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`Owner has since filed a Motion to Dismiss the Amended Complaint (Dkt. 32).
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`IPR2023-00038 of Patent No. 10,257,319
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`IV. LEGAL STANDARD
`
`Joinder may be authorized when warranted, but the decision to grant joinder
`
`is discretionary. See 35 U.S.C. § 315(c); 37 C.F.R. § 42.122. The Board determines
`
`whether to grant joinder on a case-by-case basis, taking into account the particular
`
`facts of each case, substantive and procedural issues, and other considerations. See
`
`157 CONG. REC. S1376 (daily ed. Mar. 8, 2011) (statement of Sen. Kyl).
`
`A motion for joinder should: (1) set forth the reasons why joinder is
`
`appropriate; (2) identify any new grounds of unpatentability asserted in the
`
`petition; (3) explain what impact (if any) joinder would have on the trial schedule
`
`for the existing review; and (4) address specifically how briefing and discovery
`
`may be simplified. See, e.g., Kyocera Corp. v. SoftView LLC, IPR2013-00004,
`
`Paper 15 at 4 (PTAB April 24, 2013).
`
`V. THE BOARD SHOULD EXERCISE ITS DISCRETION TO DENY
`
`JOINDER
`
`A. WITHOUT JOINDER, THE PETITION IS TIME-BARRED
`
`Petitioners concede that that without joinder, the petition is time-barred
`
`under § 315(b). See Response to SMF No. 2. A time-bar under 35 U.S.C. § 315(b)
`
`exists and thus, this factor weighs against granting joinder.
`
`6
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`
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`B. PETITIONERS ATTEMPT TO MINIMIZE THE -1266 IPR
`
`IPR2023-00038 of Patent No. 10,257,319
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`Petitioners already had their opportunity to obtain a merits-based decision on
`
`the ‘319 Patent from the Board, based on the exact same Crowds, Border, and
`
`MorphMix references.
`
`As Petitioners state, the Board denied the -1266 IPR under Fintiv because of
`
`the parallel Tex. Litigation. E.g., Motion at 4, SMF No. 7. However, the Board
`
`could have instituted the -1266 IPR, despite the parallel Tex. Litigation, if the
`
`merits had been compelling under Fintiv factor 6. However, Petitioners were
`
`unsuccessful in the -1266 IPR.
`
`The Board previously noted that the grounds presented in this petition are
`
`substantially similar to those in the -1266 IPR. See IPR2022-00861, Paper 17 at 8.
`
`The merits did not outweigh the other Fintiv factors in the -1266 IPR and the same
`
`reasoning should apply to this -038 IPR. Accordingly, Patent Owner respectfully
`
`submits that the merits of this petition do not justify redoing much of the work
`
`already completed in the Tex. Litigation. Institution and joinder in this -038 IPR
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`should be denied.
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`C. PETITIONERS ATTEMPT TO MINIMIZE THE TEX.
`
`LITIGATION
`
`Petitioner-defendants had a full and fair opportunity to litigate the validity of
`
`
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`7
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`
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`IPR2023-00038 of Patent No. 10,257,319
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`
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`the ‘319 Patent in district court and Patent Owner should be able to rely on the jury
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`verdict in the Tex. Litigation. Petitioners’ arguments regarding the Tex. Litigation
`
`fail for at least four additional reasons.
`
`First, Petitioner-defendants pursued invalidity based on Crowds, Border, and
`
`MorphMix throughout expert discovery, but made the strategic decision to only
`
`present invalidity based on Crowds to the jury at trial. See Response to SMF No. 3.
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`Petitioner-defendants were unsuccessful in the Tex. Litigation. Now, Petitioners
`
`should not be rewarded by getting a do-over based on the exact same prior art
`
`references.
`
`Second, Petitioners argument as to the overlap in claims at issue in the Tex.
`
`Litigation and this IPR is misleading. See Motion at 11. Only claim 1 of the ‘319
`
`Patent is independent. During the Tex. Litigation, Petitioner-defendants argued that
`
`the dependent claims “recite the usage of standard Internet communications and
`
`protocols” (see, e.g., EX. 2003 at 20) and Petitioners cannot now make
`
`contradictory arguments that resolution as to certain dependent claims in this IPR
`
`is of paramount importance. For example, claim 28 of the ‘319 Patent recites: “A
`
`non-transitory computer readable medium containing computer instructions that,
`
`when executed by a computer processor, cause the processor to perform the
`
`method according to claim 1.” Therefore, Patent Owner respectfully submits that
`
`many of the same validity issues related to claim 1 also relate to the dependent
`
`
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`8
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`
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`claims.
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`IPR2023-00038 of Patent No. 10,257,319
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`Third, Petitioners argue that “the jury was not provided the Court’s
`
`Supplemental Claim Construction Order” (Motion at 12), but this argument is a red
`
`herring. A jury is never provided the Orders, only the final claim constructions,
`
`and the testifying experts may only offer opinions in accordance with the guidance
`
`in the Orders.
`
`Fourth, Petitioners repeatedly emphasize that the Court has not yet entered a
`
`final judgment in the Tex. Litigation following the 11/5/2021 jury verdict of willful
`
`infringement and no invalidity. See, e.g., Motion at 2, 4, and 12. However, Patent
`
`Owner is not aware of any cases in which Judge Gilstrap has reversed a jury
`
`verdict of no invalidity on his own accord.
`
`In view of the foregoing, institution and joinder in this -038 IPR should be
`
`denied.
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`D. PETITIONERS SHOULD NOT BE GIVEN UNLIMITED
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`CHANCES TO CHALLENGE THE ‘319 PATENT
`
`Patent Owner is concerned that, after being unsuccessful in the -1266 IPR
`
`and in the Tex. Litigation, Petitioners will attempt to join any proceeding against
`
`the ‘319 Patent without regard to justice. See also AMF No. 1. Patent Owner
`
`continues to expend resources defending the ‘319 Patent against the same
`
`petitioners, including filing preliminary responses and oppositions to joinder in
`
`
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`9
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`
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`multiple IPRs. The Board continues to expend resources to evaluate institution and
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`IPR2023-00038 of Patent No. 10,257,319
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`joinder in multiple IPRs, including on remand.
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`As discussed herein, the Board should not expend its finite resources to give
`
`Petitioners a sixth bite at the invalidity apple given (1) the -1266 IPR, (2) the -875
`
`EPR, (3) the Tex. Litigation, (4) the -861 IPR, (5) the -1109 IPR, and (6) this -038
`
`IPR. As further discussed below, Petitioners’ repeated attacks against the ‘319
`
`Patent result in inefficiencies and unfairness, which weigh against granting
`
`institution/joinder.
`
`1. PETITIONERS ASK THE BOARD TO INSTITUTE TWO
`IDENTICAL PETITIONS WHICH IS INEFFICIENT AND
`UNFAIR
`
`Petitioners filed the -861 IPR. Both the -861 IPR and the -915 IPR were
`
`originally seeking joinder to the -1492 IPR. Thus, the petitions in the -861 IPR and
`
`the -915 IPR are substantively identical.
`
`Since May 27, 2022, there was no leading petitioner in the -1492 IPR. See
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`Response to SMF No. 11. The -861 IPR was instituted/joined on October 19, 2022
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`and the instant petitioners were given a leading role in the -1492 IPR. See
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`Response to SMF No. 12. Patent Owner filed a request for rehearing on November
`
`2, 2022. See id. Patent Owner respectfully submits that the -861 IPR should not
`
`have been instituted and joined to the -1492 IPR, given that the -915 IPR was
`
`already instituted and presents the same merits as the -861 IPR. See id.
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`
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`10
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`Accordingly, the instant petitioners should not be given a leading role in the -1492
`
`IPR2023-00038 of Patent No. 10,257,319
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`IPR. See id.
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`Petitioners filed the -038 IPR seeking joinder to the instituted -915 IPR.
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`Thus, the petitions in the -861 IPR, the -915 IPR, and this IPR are substantively
`
`identical. Petitioners fail to justify why they should be allowed to continue the
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`-1492 IPR (via the -861 IPR) and be an understudy in the -915 IPR (via this -038
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`IPR).
`
`Director Vidal stated that inefficiencies and unfairness under General Plastic
`
`factor 6 did not outweigh the Board’s mission to improve patent quality and restore
`
`confidence in the presumption of validity that comes with issued patents. IPR2022-
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`00861, Paper 18 at 6. However, the unique procedural posture of the instant
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`petition, in view of the October 19 institution decision in the -861 IPR, raises
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`substantial concerns of inefficiency and unfairness that Patent Owner respectfully
`
`submits cannot be outweighed by the Board’s mission. As of now, the Board is
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`already evaluating the validity of the ‘319 Patent based on the exact same prior art
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`references in the instituted -1492 IPR and in the instituted -915 IPR. The Board is
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`also evaluating the validity of the ‘319 Patent based on different art in the
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`instituted -135 IPR. The Board need not institute this -038 IPR in order to
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`accomplish its mission.
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`11
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`IPR2023-00038 of Patent No. 10,257,319
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`2. PETITIONERS FAIL TO PROVIDE A RANKING WHICH IS
`INEFFICIENT AND UNFAIR
`
`
`
`
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`Petitioners ignored the Board’s guidance in the Consolidated Trial Practice
`
`Guide (November 2019)(“TPG”) and did not rank their successive, co-pending
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`petitions against the ‘319 Patent in their motion. TPG at 59. At the time of filing
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`their motion, the -861 IPR, the -1109 IPR, and this -038 IPR were all co-pending,
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`pre-institution.2 This places a substantial and unnecessary burden on the Board and
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`the patent owner and raises fairness, timing, and efficiency concerns. See TPG at
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`59. Petitioners failed to provide a rationale to support the need for multiple
`
`petitions and to justify expending the Board’s resources to institute multiple
`
`proceedings against the same patent based on the same prior art. It appears that the
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`petitioners are attempting to hedge their bets in the multiple co-pending IPRs. For
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`at least the reasons discussed herein, institution and joinder in this -038 IPR should
`
`be denied.
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`E. PETITIONERS FAIL TO MEET THEIR BURDEN
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`Petitioners fail to meet their burden for at least two additional reasons.
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`First, there is no representation that the primary petitioner, Major Data,
`
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`2 The -861 IPR, the -1109 IPR, and the -038 IPR were filed on April 18, June 14,
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`and October 14 of 2022, respectively.
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`
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`12
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`would cooperate with the instant Petitioners. See Motion at 7, SMF No. 17.
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`IPR2023-00038 of Patent No. 10,257,319
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`Second, Petitioners argue that joinder is “the most efficient and economical
`
`manner to proceed in this case”. Motion at 14. However, Petitioners rely on two
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`cases that are both easily distinguishable at least because in both cases, joinder was
`
`unopposed. HTC v. Parthenon Unified Memory Architecture LLC, IPR2017-
`
`00512, Paper 12 at 7 (June 1, 2017); STMicroelectronics, Inc. v. Lone Star Silicon
`
`Innovations, LLC, IPR2018-00436, Paper 7 at 2 (PTAB May 4, 2018).
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`Additionally, in STMicroelectronics, the joinder petitioner agreed not to introduce
`
`any argument or discovery not introduced by the primary petitioner. See id. at 4.
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`That is not the case here where the instant petitioners have already introduced
`
`substantial arguments and evidence based on their involvement in the Tex.
`
`Litigation and their familiarity with the ‘319 Patent. E.g., Motion at 3, SMF No. 3;
`
`Motion at 4, SMF No. 5; and EXS. 1024-1029.
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`VI. CONCLUSION
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`In view of the foregoing, Patent Owner respectfully requests that institution
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`and joinder be denied.
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`13
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`Date: November 14, 2022
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`IPR2023-00038 of Patent No. 10,257,319
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`Respectfully submitted,
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`
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`
`
`By: /s/ Thomas M. Dunham
`Thomas M. Dunham
`Reg. No. 39,965
`
`Cherian LLP
`1901 L Street NW, Suite 700
`Washington, D.C. 20036
`(202) 838-1567
`
`ATTORNEY FOR PATENT OWNER,
`BRIGHT DATA LTD.
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`14
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`CERTIFICATE OF COMPLIANCE
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`IPR2023-00038 of Patent No. 10,257,319
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`Pursuant to 37 C.F.R. § 42.24(d), the undersigned hereby certifies that
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`PATENT OWNER’S OPPOSITION TO PETITIONERS’ MOTION FOR
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`JOINDER complies with the 15-page-limit under 37 C.F.R. § 42.24(b)(3). This
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`paper contains fewer than the limit of 15 pages, excluding the parts of this paper
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`exempted by 37 C.F.R. § 42.24(a)(1). This paper also complies with the format
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`requirements of 37 C.F.R. § 42.6(a).
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`Date: November 14, 2022
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`Respectfully submitted,
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`By: /s/ Thomas M. Dunham
`Thomas M. Dunham
`Reg. No. 39,965
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`Cherian LLP
`1901 L Street NW, Suite 700
`Washington, D.C. 20036
`(202) 838-1567
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`ATTORNEY FOR PATENT OWNER,
`BRIGHT DATA LTD.
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`15
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`CERTIFICATE OF SERVICE
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`IPR2023-00038 of Patent No. 10,257,319
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies the
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`PATENT OWNER’S OPPOSITION TO PETITIONERS’ MOTION FOR
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`JOINDER and accompanying exhibits thereto, were served on the undersigned
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`date via email, as authorized by Petitioners, at the following email addresses:
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`jscott@ccrglaw.com
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`jheuton@ccrglaw.com
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`ctolliver@ccrglaw.com
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`Date: November 14, 2022
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`Respectfully submitted,
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`By: /s/ Thomas M. Dunham
`Thomas M. Dunham
`Reg. No. 39,965
`
`Cherian LLP
`1901 L Street NW, Suite 700
`Washington, D.C. 20036
`(202) 838-1567
`
`ATTORNEY FOR PATENT OWNER,
`BRIGHT DATA LTD.
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`16
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