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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`AMAZON.COM, INC., AMAZON DIGITAL SERVICES, INC., AMAZON
`FULFILLMENT SERVICES, INC., HULU, LLC, and NETFLIX, INC.,
`Petitioners,
`
`v.
`
`UNILOC LUXEMBOURG, S.A.,
`Patent Owner.
`
`
`
`
`
`
`
`
`CASE: IPR2017-00948
`Patent No. 8,566,960
`
`
`
`
`
`
`
`
`Before DAVID C. MCKONE, BARBARA A. PARVIS, and MICHELLE N.
`WORMMEESTER, Administrative Patent Judges.
`
`
`PETITIONERS’ REQUEST FOR ORAL ARGUMENT
`
`
`
`
`LEGAL139288117.1
`
`

`

`Petitioners’ Request for Oral Argument
`U.S. Patent No. 8,566,960
`
`Pursuant to the Board’s Scheduling Order dated August 14, 2017 (Paper 11),
`
`Petitioners Amazon.com, Inc., Amazon Digital Services, Inc., Amazon Fulfillment
`
`Services, Inc., Hulu, LLC and Netflix, Inc. (“Petitioners”) respectfully requests
`
`oral argument, currently scheduled for May 8, 2018.
`
`5
`
`Pursuant to 37 C.F.R. § 42.70, Petitioners request the oral argument to dis-
`
`cuss the issues raised in the parties’ filings in the on-going review, including but
`
`not limited to, the following items:
`
`• whether claims 1-25 of U.S. Patent No. 8,566,960 are unpatentable
`
`under 35 U.S.C. §§ 102 and/or 103;
`
`10
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`• whether the amended claims in Patent Owner’s Contingent Motion
`
`•
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`•
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`to Amend are unpatentable under 35 U.S.C. §§ 101, 103, and 112;
`
`the issues raised in the Petition, including all exhibits thereto;
`
`the issues raised in Patent Owner’s Preliminary Response, Re-
`
`sponse, Contingent Motion to Amend, and Reply in Support of the
`
`15
`
`Motion to Amend, including all exhibits thereto;
`
`•
`
`the issues raised in Petitioner’s Reply and Opposition to the Con-
`
`tingent Motion to Amend, including all exhibits thereto;
`
`• rebuttal to the Patent Owner’s presentation on all issues; and
`
`• any other issues related to invalidity that the Board deems neces-
`
`20
`
`sary for issuing a final written decision.
`
`LEGAL139288117.1
`
`-1-
`
`

`

`Petitioners’ Request for Oral Argument
`U.S. Patent No. 8,566,960
`
`Petitioners request permission to use audio/visual equipment to display
`
`demonstratives and exhibits.
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`Petitioners ask the Board to decide the length of time for the requested oral
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`argument for each party. Petitioners suggest that 45 minutes per side should be ad-
`
`5
`
`equate to cover the arguments in this case. Petitioners currently plan to bring two
`
`individuals to the hearing.
`
`This request is timely filed by Due Date 4 pursuant to the Scheduling Order
`
`dated August 14, 2017 (Paper 11).
`
`
`
`Dated: April 4, 2018
`
`
`
`
`
`
`
`
`PERKINS COIE LLP
`3150 Porter Dr.,
`Palo Alto, CA 94304
`(650)838-4300
`
`
`Respectfully submitted,
`
`/ Daniel T. Shvodian /
`
`Lead Counsel
`Daniel T. Shvodian, Reg. No. 42,148
`
`Back-up Counsel
`Sarah E. Stahnke, Reg. No. 54,854
`
`Attorneys for AMAZON.COM, INC.,
`AMAZON DIGITAL SERVICES, INC.,
`AMAZON FULFILLMENT SERVICES,
`INC., HULU, LLC, and NETFLIX, INC.
`
`
`LEGAL139288117.1
`
`-2-
`
`

`

`Petitioners’ Request for Oral Argument
`U.S. Patent No. 8,566,960
`
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned hereby certifies that a true copy of the foregoing PETI-
`
`TIONERS’ REQUEST FOR ORAL ARGUMENT has been served in its entirety
`
`this 4th of April, 2018, via email and the PTAB E2E System to Patent Owner’s
`
`counsel of record at the following:
`
`Brett A. Mangrum (brett@etheridgelaw.com)
`Jeff Huang (jeff@etheridgelaw.com)
`
`Etheridge Law Group, PLLC
`2600 E. Southlake Blvd., Suite 120/324
`Southlake, TX 76092
`
`
`
`
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`
`
`
`
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`
`
`
`
`
`
`/ Daniel T. Shvodian /
`Lead Counsel
`Daniel T. Shvodian, Reg. No. 42,148
`
`Back-up Counsel
`Sarah E. Stahnke, Reg. 54,854
`
`
`
`
`
`Attorneys for AMAZON.COM, INC., AM-
`AZON DIGITAL SERVICES, INC., AMA-
`ZON FULFILLMENT SERVICES, INC.,
`HULU, LLC, and NETFLIX, INC.
`
`
`
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`LEGAL139288117.1
`
`

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