`U.S. Patent No. 8,755,376 B2
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`TELESIGN CORPORATION
`Petitioner,
`
`v.
`
`TWILIO INC.
`Patent Owner
`
`––––––––––
`
`Case IPR2017-01977
`Patent 8,755,376 B2
`
`––––––––––
`
`PATENT OWNER’S REQUEST FOR ORAL ARGUMENT
`
`
`
`IPR2017-01977
`U.S. Patent No. 8,755,376 B2
`
`Pursuant to the Board’s March 9, 2018 Scheduling Order (Paper 13),
`
`Patent Owner, Twilio Inc., respectfully requests oral argument, currently scheduled
`
`on November 15, 2018. Pursuant to 37 C.F.R. § 42.70, Patent Owner requests the
`
`oral argument to discuss the issues raised in the parties’ filings, including but not
`
`limited to, the following items:
`
`1. Whether Petitioner has established a prima
`
`facie case of
`
`unpatentability;
`
`2.
`
`The grounds of unpatentability, namely whether:
`
`a. Maes in view of Ransom renders obvious claims 1-3, 14, 16, and 19;
`
`b. Maes in view of Ransom and further in view of Jiang renders
`
`obvious claims 5 and 17;
`
`c. ETSI ES 202 391-4 in view of Ransom renders obvious claims 1-3,
`
`5, 14, and 16;
`
`d. ETSI ES 202 391-4 in view of Ransom and further in view of ETSI
`
`ES 202 391-7 renders obvious claim 17; and
`
`e. ETSI ES 202 391-4 in view of Ransom and further in view of ETSI
`
`ES 202 391-2 renders obvious claim 19.
`
`3. Whether the challenged claims are non-obvious due to secondary
`
`considerations of non-obviousness;
`
`1
`
`
`
`IPR2017-01977
`U.S. Patent No. 8,755,376 B2
`
`4.
`
`5.
`
`6.
`
`Any issues identified in Petitioner’s Request for Oral Argument;
`
`Rebuttal to Petitioner’s presentation on all matters;
`
`Any other issues raised in papers filed in this proceeding, including
`
`Motions to Exclude and Motions to Strike; and
`
`7.
`
` Any other issues that the Board deems necessary for issuing a final
`
`written decision.
`
`Petitioner and Patent Owner stipulated to consolidate the oral hearings of this
`
`case with IPR-2017-01976. See Paper 15. Patent Owner requests 30 minutes of
`
`argument time for each of Petitioner and Patent Owner in the consolidated hearing
`
`to address the above-listed topics for both proceedings.
`
`Additionally, Patent Owner respectfully requests the ability to use
`
`audio/visual equipment to display demonstrative exhibits and evidence of record,
`
`including the use of a computer, projector, and screen.
`
`2
`
`
`
`IPR2017-01977
`U.S. Patent No. 8,755,376 B2
`
`October 12, 2018
`
`BAKER BOTTS L.L.P.
`ATTN: Wayne O. Stacy
`101 California Street, Suite 3600
`San Francisco, CA 94111
`Phone: (415) 291-6206
`Facsimile: (415) 291.6306
`E-mail: wayne.stacy@bakerbotts.com
`
`Respectfully submitted,
`BAKER BOTTS L.L.P.
`
`/Wayne O. Stacy/
`Wayne Stacy
`Lead Counsel for Twilio Inc.
`Reg. No. 45,125
`
`3
`
`
`
`IPR2017-01977
`U.S. Patent No. 8,755,376 B2
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(b), the undersigned certifies that
`
`on October 12, 2018, the foregoing was served electronically via email on the
`
`following:
`
`Elena McFarland
`(emcfarland@shb.com)
`Jesse Camacho
`(jcamacho@shb.com)
`Christine Guastello
`(cguastello@shb.com)
`Mary J. Peal
`(mpeal@shb.com)
`Tawni Wilhelm
`(twilhelm@shb.com, TeleSignIPR@shb.com)
`Counsel for TeleSign Inc.
`Shook, Hardy & Bacon LLP
`2555 Grand Blvd.
`Kansas City, MO 64108
`
`Amy Foust
`(afoust@shb.com)
`Counsel for TeleSign Inc.
`Shook, Hardy & Bacon LLP
`201 S. Biscayne Blvd., Suite 3200
`Miami, FL 33131
`
`Date: October 12, 2018
`
`Respectfully submitted,
`BAKER BOTTS L.L.P.
`
`/Wayne O. Stacy/
`Wayne Stacy
`Lead Counsel
`Reg. No. 45,125
`
`
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