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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________
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`CHEGG, INC., MATCH GROUP, LLC, AND RPX CORPORATION
`
`Petitioners,
`
`v.
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`NETSOC, LLC
`
`Patent Owner
`
`_________________________
`
`IPR2019-01165 (Patent No. 9,978,107)
`_________________________
`
`
`
`PATENT OWNER NETSOC, LLC’S
`REQUEST FOR ORAL ARGUMENT
`
`
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
`
`
`1
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`

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`In accordance with 37 C.F.R. § 42.70(a) and the Scheduling Order
`
`(Paper No. 15) issued on December 5, 2019, the Patent Owner respectfully
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`requests the opportunity to present oral argument on the issues listed below.
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`
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`I. Claims 1-11 of the ‘107 Patent Are Not Obvious Over the Petition Art
`
` A. Claims 1-3, 5-8, 10, and 11 of the ‘107 Patent Are Not Obvious Over
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`Beaudoin and Shubov
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` 1. Claims 1 and 6 Are Patentable Over Beaudoin and Shubov
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`a. Beaudoin and Shubov Do Not Teach All Claim Elements
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`1. Beaudoin and Shubov Do Not Teach Claim Elements 1c and 6c
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`(a). Beaudoin and Shubov Do Not Teach “In Response To” in
`
`Claims 1c and 6c
`
`(b).
`
`Beaudoin and Shubov Do Not Teach “Shielding Contact
`
`Information Associated with Each of the Multiple Participants”
`
`in Claims 1c and 6c
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`
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`
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`2. Beaudoin and Shubov Do Not Teach Claim Elements 1e and 6e
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`2. Dependent Claims 2-5 and 7-11 Are Not Invalid Over the Cited Art
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`2
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`B. Claims 4 and 9 of the ‘107 Patent Are Not Obvious Over Beaudoin,
`
`Shubov, and Herz
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`II. Objection to the First Declaration of Goldberg and Motion to Exclude the First
`
`Declaration of Goldberg
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`III. Reply to any argument made by the Petitioner
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`IV. Response to Petitioner’s presentation at the Oral Argument
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`V. Any and all issues briefed or presented by Patent Owner or Petitioner
`
`throughout the aforementioned trial
`
`In accordance with the Scheduling Order (Paper No. 15) issued on
`
`December 5, 2019, oral argument is currently scheduled for September 9, 2020.
`
`Patent Owner and Petitioner conferred on July 22, 2020 and request that the oral
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`argument be held at USPTO Headquarters in Alexandria. Patent Owner requests
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`45 minutes for its presentation with an opportunity to hold a portion of that time
`
`in reserve for rebuttal to the Petitioner’s presentation.
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`
`
`Dated: July 23, 2020
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`Respectfully submitted,
`
`
`________________________
`
`William P. Ramey, III
`
`3
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`

`

`
`
`
`
`
`
`Ramey & Schwaller, LLP
`Registration No. 44,295
`Lead Counsel for Patent Owner
`5020 Montrose Blvd., Suite 800
`Houston, Texas 77006
`(713) 426-3923 (telephone)
`(832) 900-4941 (fax)
`wramey@rameyfirm.com
`Counsel for Patent Owner
`NETSOC, LLC
`
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`4
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`CERTIFICATE OF SERVICE
`
`I the undersigned, counsel with the law firm of Ramey & Schwaller, LLP,
`hereby certify that the following statements are true and correct under penalty of
`perjury, pursuant to 28 U.S.C.§ 1746:
`
`
`
`On July 23, 2020 this PATENT OWNER NETSOC, LLC’S REQUEST FOR
`ORAL ARGUMENT was served via email to the address below:
`
`
`
`
`
`Nathan J. Rees (Reg. No. 63,820)
`NORTON ROSE FULBRIGHT US LLP
`2200 Ross Avenue, Suite 3600
`Dallas, Texas 75201-7932
`Tel: 214.855.7164
`Fax: 214.855.8200
`nate.rees@nortonrosefulbright.com
`Attorney for Petitioners
`
`RPX__IPR_Service@nortonrosefulbright.com
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`
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`Dated: July 23, 2020
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`____
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`__________
`
`
`
`William P. Ramey, III
`Ramey & Schwaller, LLP
`Registration No. 44,295
`Lead Counsel for Patent Owner
`5020 Montrose Blvd., Suite 800
`Houston, Texas 77006
`(713) 426-3923 (telephone)
`(832) 900-4941 (fax)
`wramey@rameyfirm.com
`Counsel for Patent Owner
`NETSOC, LLC
`
`5
`
`

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