`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________
`
`
`
`
`AMAZON.COM, INC., AMAZON WEB SERVICES, INC., AND
`AMAZON.COM SERVICES LLC,
`Petitioners,
`v.
`
`LS CLOUD STORAGE TECHNOLOGIES LLC,
`Patent Owner.
`_________________________
`
`Case: IPR2023-00120, IPR2023-00733
`Patent: 10,154,092
`_________________________
`
`PATENT OWNER’S REQUEST FOR ORAL HEARING
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`IPR2023-00120, IPR2023-00733
`Request for Oral Hearing
`
`Patent Owner hereby respectfully requests oral argument pursuant to 37
`
`C.F.R. § 42.70(a) and the Board’s Scheduling Order (Paper 8, IPR2023-00120).
`
`Patent Owner respectfully requests a virtual hearing regarding IPR2023-00120,
`
`IPR2023-00733 be held February 21, 2024. Petitioner requests 45 minutes per side
`
`to address the issues identified in the papers in this proceeding and related issues
`
`identified in Petitioner’s Request for Oral Argument, if any.
`
`Pursuant to 37 C.F.R. § 42.70(a) and without waiving any issue not
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`specifically identified herein, Patent Owner hereby submits this Request for Oral
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`Argument on issues related to the patentability of the challenged claims of U.S.
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`Patent No. 10,154,092 (“ ’092 patent”) on the instituted grounds set forth in the
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`Board’s Institution Decision (Paper 7, IPR2023-00120; paper 10, IPR2023-00733),
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`and on any issues specified in any motions to exclude, or any other pending motions
`
`or briefing filed.
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`At the oral argument, Patent Owner requests (without waiving
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`consideration of any issue not listed below) to address the following issues:
`
`A. Claims 1–3, 7–12, 19–23 are not disclosed by Heil
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`B. Claims 1–3, 6–24 are not obvious over Heil and Nakayama
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`C. Claim 4 is not obvious over Heil, Nakayama, and Gulick
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`D. Claim 5 is not obvious over Heil, Nakayama, and Berman
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`E. Reply to any argument made by the Petitioner
`
`
`
`2
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`
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`F. Reply to Petitioner’s presentation at the Oral Argument
`
`IPR2023-00120, IPR2023-00733
`Request for Oral Hearing
`
`
`G. Any and all issues briefed or presented by Patent Owner or Petitioner
`throughout the trial
`
`
`
`Dated: January 8, 2024
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`RAMEY LLP
`/Jacob B. Henry/
`Jacob B. Henry
`Registration No. 61,093
`5020 Montrose Blvd., Suite 800
`Houston, Texas 77006
`Telephone: (13) 426-3923
`Telephone: (713) 426-3923
`Facsimile: (832) 900-4941
`jhenry@rameyfirm.com
`uspto@rameyfirm.com
`
`Attorneys for Patent Owner
`
`3
`
`
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