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`Filed: February 12, 2024
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`META PLATFORMS, INC.
`Petitioner,
`
`v.
`
`ANGEL TECHNOLOGIES GROUP LLC
`Patent Owner.
`__________________
`
`Case No. IPR2023-00057
`U.S. Patent No. 8,954,432
`__________________
`
`
`OBJECTIONS TO PATENT OWNER’S DEMONSTRATIVE EXHIBITS
`FOR ORAL ARGUMENT
`
`
`
`
`
`
`IPR2023-00057 (USP 8,954,432)
`
`Petitioner’s Objections to
` PO’s Demonstratives
`
`Pursuant to the Board’s January 30, 2024 Order (IPR2023-00057 Paper 32,
`
`
`
`-00058 Paper 32, -00059 Paper 33, -00060 Paper 32), Petitioner Meta Platforms,
`
`Inc. (“Meta” or “Petitioner”) submits the following objections1 to Patent Owner’s
`
`Demonstratives (Ex. 2023) for use at the oral argument scheduled for February 13,
`
`2024. Patent Owner introduces new argument that would supplement the existing
`
`record. Primarily, Patent Owner raises new argument in an effort to distinguish
`
`cases cited by Petitioner in its Replies despite not raising the arguments identified
`
`below in the Patent Owner Sur-Replies or Responses.
`
`Slide
`No.
`
`16
`
`Objection
`
`Petitioner objects to the text “Ex Parte Offenhartz: Field of endeavor is
`‘configured of software applications’” as new argument that was not
`presented in any paper of record, including at PO’s cite “-00060: Sur-Reply
`at 8.”
`
`
`1 Objectionable material is identified by the green box on each slide.
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`- 1 -
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`
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`IPR2023-00057 (USP 8,954,432)
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`
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`Petitioner’s Objections to
` PO’s Demonstratives
`
`
`16
`
`Petitioner objects to the snapshot of case text from Ex parte Offenhartz’s
`decision and the bullet listed text as new argument and new evidence not
`presented in any paper of record, including at PO’s cite “-00060: Sur-Reply
`at 8.”
`
`
`
`17
`
`Petitioner objects to the text “In re Mettke: Field of endeavor is ‘pay-for-
`use public communication terminals’” as new argument not presented in
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`
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`- 2 -
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`
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`IPR2023-00057 (USP 8,954,432)
`
`
`
`Petitioner’s Objections to
` PO’s Demonstratives
`
`
`any paper of record, including at PO’s cite “-00060: Sur-Reply at 8.”
`
`17
`
`Petitioner objects to the snapshot of the patent-at-issue in In re Mettke as
`new argument and new evidence not presented in any paper of record,
`including at “-00060: Sur-Reply at 8.”
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`18
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`Petitioner objects to the text “Snap v. Vaporstream: Field of endeavor is
`‘handling electronic messages’” as new argument not presented in any
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`- 3 -
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`IPR2023-00057 (USP 8,954,432)
`
`
`
`Petitioner’s Objections to
` PO’s Demonstratives
`
`
`paper of record, including at “-00060: Sur-Reply at 8.”
`
`18
`
`Petitioner objects to the snapshot of the patent-at-issue in Snap v.
`Vaporstream as new argument and new evidence not presented in any
`paper of record, including at “-00060: Sur-Reply at 8.”
`
`19
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`Petitioner objects to the snapshot of the patent-at-issue in Snap v.
`Vaporstream as new argument and new evidence not presented in any
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`- 4 -
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`IPR2023-00057 (USP 8,954,432)
`
`
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`Petitioner’s Objections to
` PO’s Demonstratives
`
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`paper of record, including at “-00060: Sur-Reply at 8.”
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`Respectfully submitted,
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`
`
`
`/Lisa K. Nguyen/
`Lisa K. Nguyen (Reg. No. 58,018)
`lisa.nguyen@allenovery.com
`Allen & Overy LLP
`550 High Street
`Palo Alto, CA 94301
`Telephone: (650) 388-1724
`
`Counsel for Petitioner
`Meta Platforms, Inc.
`
`Dated: February 12, 2024
`
`
`
`By:
`
`
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`- 5 -
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`CERTIFICATE OF SERVICE
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`
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`The undersigned certifies that a true and correct copy of Objections to
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`Patent Owner’s Demonstrative Exhibits for Oral Argument was served via
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`electronic email on Patent Owner’s counsel of record listed below, pursuant to its
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`Mandatory Notices, on February 12, 2024:
`
`Scott W. Hejny (Reg. No. 45,882)
`McKool Smith, P.C.
`300 Crescent Court, Suite 1500
`Dallas, TX 75201
`Telephone: (214) 978-4000
`Facsimile: (214) 978-4044
`shejny@mckoolsmith.com
`
`
`Eliza Beeney (pro hac vice)
`McKool Smith, P.C.
`One Manhattan West
`395 9th Avenue, 50th Floor
`New York, NY 10001
`Telephone: (212) 402-9818
`ebeeney@mckoolsmith.com
`
`
`
`
`
`
`
`Elizabeth Bernard (Reg. No. 51,465)
`Arvind Jairam (Reg. No. 62,759)
`McKool Smith, P.C.
`1999 K St. NW, Suite 600
`Washington, DC 20006
`Telephone: (202) 370-8300
`EBernard@mckoolsmith.com
`ajairam@mckoolsmith.com
`
`Kaylee Hoffner (pro hac vice)
`McKool Smith, P.C.
`600 Travis Street, Suite 7000
`Houston, TX 77002
`Telephone: (713) 485-7320
`khoffner@mckoolsmith.com
`
`
`
`
`
`
`/Lisa K. Nguyen/
`Lisa K. Nguyen (Reg. No. 58,018)
`lisa.nguyen@allenovery.com
`Allen & Overy LLP
`550 High Street
`Palo Alto, CA 94301
`Telephone: (650) 388-1724
`
`Counsel for Petitioner
`Meta Platforms, Inc.
`
`
`By:
`
`- 1 -
`
`
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