Case 1:17-cv-01520-CFC-SRF Document 47 Filed 07/17/19 Page 1 of 13 PageID #: 2593
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`REALTIME ADAPTIVE STREAMING LLC,
`
`
`
`
`Plaintiff,
`
` v.
`
`HAIVISION NETWORK VIDEO INC.,
`
`
`Defendant.
`
`Case No. 17-1520-JFB-SRF
`
`
`
`
`
`July 17, 2019
`
`OF COUNSEL:
`
`Marc A. Fenster
`Brian D. Ledahl
`Reza Mirzaie
`C. Jay Chung
`RUSS, AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`(310) 826-7474
`Los Angeles, CA 90025-1031
`mfenster@raklaw.com
`bledahl@raklaw.com
`rmirzaie@raklaw.com
`jchung@raklaw.com
`
`
`
`
`
`
`
`
`PLAINTIFF REALTIME ADAPTIVE STREAMING LLC’S REPLY BRIEF IN
`SUPPORT OF ITS MOTION FOR LEAVE TO FILE AMENDED COMPLAINT
`
`
`
`BAYARD, P.A.
`
`Stephen B. Brauerman (No. 4952)
`600 N. King Street, Suite 400
`Wilmington, DE 19801
`(302) 655-5000
`sbrauerman@bayardlaw.com
`
`Attorneys for Plaintiff Realtime Adaptive
`Streaming LLC
`
`
`
` i
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`

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`Case 1:17-cv-01520-CFC-SRF Document 47 Filed 07/17/19 Page 2 of 13 PageID #: 2594
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`
`
`TABLE OF CONTENTS
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`Page(s)
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`I.
`
`REALTIME’S MOTION TO AMEND—ITS FIRST ADDRESSING PATENT
`ELIGIBILITY—IS BOTH PROCEDURALLY AND SUBSTANTIVELY PROPER ........ 1
`A. There Is No Procedural Basis to Ignore or Discount Realtime’s Amended Complaint 1
`1. Defendants’ Own Cases Make Clear There Is No “Waiver” Here. .................... 1
`2. Defendant’s “Undue Delay” Argument Has No Legal or Factual Support. ....... 2
`3. Defendants’ Contention that Realtime’s Amendment is “Highly Prejudicial”
`Defies Common Sense And Federal Circuit Caselaw ........................................ 3
`B. Realtime’s Reissue Patent Number Clarification Also Does Not Result In Undue
`Delay or Prejudice ........................................................................................................ 5
`Substantively, Realtime’s Amendments Are Anything But Futile. .............................. 5
`C.
`II. CONCLUSION .................................................................................................................... 10
`
`
`
`ii
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`Case 1:17-cv-01520-CFC-SRF Document 47 Filed 07/17/19 Page 3 of 13 PageID #: 2595
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`TABLE OF AUTHORITIES
`
`Page(s)
`
`
`
`Cases
`
`Aatrix Software, Inc. v. Green Shades Software, Inc.,
`882 F.3d 1121, 1126-28 (Fed. Cir. 2018). ...................................................................... 1, 2, 4, 7
`
`Alice Corp. Pty. Ltd. v. CLS Bank Int’l,
`134 S. Ct. 2347, 2358 (2014) ...................................................................................................... 6
`
`Berkheimer v. HP Inc.,
`890 F.3d 1369, 1372-73 (Fed. Cir. 2018) ............................................................................... 1, 8
`
`Butamax Advanced Biofuels LLC v. Gevo, Inc.,
`No. CIV. 11-54-SLR, 2012 WL 2365905, at *2 (D. Del. June 21, 2012) ................................ 10
`
`Cornell & Co., Inc. v. Occupational Safety and Health Review Commission,
`573 F.2d 820, 823 (3d Cir. 1978).............................................................................................. 10
`
`Coventry v. U.S. Steel Corp.,
`856 F.2d 514, 520 (3d Cir. 1988).............................................................................................. 10
`
`Invensas Corp. v. Renesas Elecs. Corp.,
`No. CIV.A. 11-448-GMS, 2013 WL 1776112, at *1 (D. Del. Apr. 24, 2013). .......................... 3
`
`Realtime Adaptive Streaming LLC v. Google LLC,
`Case No. 2:18-cv-03629-GW-JC, D.I. 36 (C.D. Cal. Oct. 25, 2018) ......................................... 9
`
`RingCentral, Inc. v. Dialpad, Inc.,
`18-cv-05242-JST at *16 (N.D. Cal. March 8, 2019). ................................................................. 1
`
`
`
`
`
` ii
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`

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`Case 1:17-cv-01520-CFC-SRF Document 47 Filed 07/17/19 Page 4 of 13 PageID #: 2596
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`I.
`
`REALTIME’S MOTION TO AMEND—ITS FIRST ADDRESSING PATENT
`
`ELIGIBILITY—IS BOTH PROCEDURALLY AND SUBSTANTIVELY PROPER
`
`A.
`
`There Is No Procedural Basis to Ignore or Discount Realtime’s Amended
`Complaint
`
`In their effort to have this Court avoid or ignore the substance of Realtime’s factual
`
`allegations in its Amended Complaint. Defendant presents three arguments for why Realtime’s
`
`Amendment is procedurally improper. None have merit.
`
`1.
`
`Defendants’ Own Cases Make Clear There Is No “Waiver”
`Here.
`
`
`Relying on Sincavage v. Barnhart, Defendant first argues that Realtime “waived its
`
`opportunity to seek further amendment” by supposedly not raising this issue within the period of
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`time it had to object to the Magistrate’s R&R. (D.I. 46, at 3.) But Sincavage is inapposite—and
`
`neither Sincavage nor the cropped quotes Defendant pulls out from it support their sweeping and
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`flawed position. If anything, even Sincavage compels this Court to reject Defendant’s argument.
`
`Defendant’s own cherrypicked quote from Sincavage merely states that “[t]he failure of a
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`party to object to legal conclusions may result in the lost of the right to de novo review in the
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`District Court.” Id. (emphasis added). But the “conclusion” in the R&R was not a “legal” one
`
`and also did not address the current request to amend to include Realtime’s additional factual
`
`allegations concerning patent eligibility, Realtime’s first amendment on that issue. Thus,
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`Defendant’s quote from Sincavage is inapplicable.
`
`Regardless, even if Sincavage were much more factually similar to the case and issue
`
`before this Court now, it does not support Defendant’s sweeping “waiver” rule. Even focusing
`
`on Defendant’s cropped quote, it merely states that the failure to object “may” result in the loss
`
`of “de novo” review, which does not get Defendant anywhere close to the novel “waiver” rule it
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` 1
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`

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`Case 1:17-cv-01520-CFC-SRF Document 47 Filed 07/17/19 Page 5 of 13 PageID #: 2597
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`proposes. In fact, in expressly rejecting the “waiver” argument before it, the court in Sincavage
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`held that “whether or not objections are made to the magistrate's report, the district court ‘may
`
`accept, reject, or modify, in whole or in part, the findings or recommendations made by the
`
`magistrate.’” 171 F.3d F. App’x 924, 925 (3rd Cir. 2006). While this alone contradicts
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`Defendant’s sweeping “waiver” argument, the Third Circuit went even further—and outright
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`stated that, even without any objections, it is “the better practice is for the district judge to afford
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`some level of review to dispositive legal issues raised by the report” because “[t]authority—and
`
`the responsibility—to make an informed, final determination ... remains with the judge.” Id.
`
`(citing Mathews v. Weber, 423 U.S. 261, 271 (1976). Thus, if anything, even if Sincavage were
`
`applicable, it compels a review of the magistrate judge’s reversible error in recommending that
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`Defendant’s motion be granted with prejudice.
`
`2.
`
`Defendant’s “Undue Delay” Argument Has No Legal or
`Factual Support.
`Defendant’s next contention of supposed “undue delay” suffers from similar fatal flaws.
`
`While conceding that “delay alone” is insufficient under the law, Defendant points to virtually
`
`nothing else and boldly asks this Court to find “undue delay” because “[i]n this Circuit, delay
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`‘become[s] undue when a movant has had previous opportunities to amend a complaint.” (D.I.
`
`46 at 4 (citing Cureton v. NCAA, 252 F.3d 267, 273 (3rd Cir. 2001)).)
`
`Even a cursory review of Defendant’s cited authority reveals the lengths to which it is
`
`going to stretch the law to try to have this Court improperly ignore Realtime’s meaningful and
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`detailed factual allegations. Indeed, right after the quote that Defendant’s use from Cureton, the
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`Third Circuit made clear that the “undue delay” exception to the liberal amendment rules that
`
`control Realtime’s motion are narrow—and have only been applied in cases involving multiple
`
`amendments on the same issue, over years of substantive litigation. 252 F.3d at 273 (citing cases
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`
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`2
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`Case 1:17-cv-01520-CFC-SRF Document 47 Filed 07/17/19 Page 6 of 13 PageID #: 2598
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`involving a “three year lapse”; a “second amended complaint where plaintiffs were repleading
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`facts that could have been pled earlier,” and “a [] delay[] making a motion to amend until after
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`summary judgment has been granted to the adverse party[.]”) These situations are not remotely
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`analogous to this case.
`
`But Defendant’s argument fails for another, more fundamental reason. Later Third
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`Circuit opinions have held that the Cureton exception to the “liberal amendment” rule applies
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`when the delay is inexplicable and so excessive that it resulted in a motion to amend being filed
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`after a “final or appealable order.” Mullin v. Balicki, 875 F.3d 140, 150, n. 17 (3rd Cir. 2017).
`
`The R&R is not final nor appealable. Therefore, Defendant’s legal argument for “undue delay”
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`has no merit.
`
`Finding zero support in the law, Defendant casts aspersions that “Realtime strategically
`
`chose to withhold” it factual allegations. (D.I. 46 at 4.) But Defendant’s provide no real factual
`
`support for this baseless accusation. And none can exist here. Defendants cannot point to any
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`meaningful change in circumstances or leverage of any sort between some “delay” and “undue
`
`delay”—particularly where not even a single meaningful event has taken place in this case since
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`the R&R was issued. And in any event, Defendant has no answer for the fact that the Federal
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`Circuit has even reversed a district court opinion denying a motion for leave to file “a second
`
`amendment” on the patent eligibility issue. Aatrix Software v. Green Shades Software, 882 F.3d
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`1121, 1125 (Fed. Cir. 2018).
`
`3.
`
`Defendants’ Contention that Realtime’s Amendment is
`“Highly Prejudicial” Defies Common Sense And Federal
`Circuit Caselaw
`In its final attempt to sweep Realtime’s factual allegations under the rug, Defendant tells
`
`this Court that it will suffer “undue prejudice” as a result of Realtime’s motion. (D.I. 46 at 5-6.)
`
`But the Third Circuit is clear that “[i]n order to show undue prejudice, the party opposing a
`
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`3
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`Case 1:17-cv-01520-CFC-SRF Document 47 Filed 07/17/19 Page 7 of 13 PageID #: 2599
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`motion to amend bears the burden of showing that it will be ‘unfairly disadvantaged or deprived
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`of the opportunity to present facts of evidence’ unless leave to amend is denied.” E.g., Bechtel v.
`
`Robinson, 886 F.2d 644, 652 (3rd Cir. 1989). Defendant’s own cited authority outright holds
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`that, in such cases, he Third Circuit has considered whether allowing an amendment would result
`
`in additional discovery, cost, and preparation in order to defend against new facts or new legal
`
`theories. Cureton, 252 F.3d at 273. Defendant’s meritless position does not even try to address
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`this standard, let alone meet its burden on it.
`
`To the contrary, Defendant’s argument is wholly unsupported. Defendant claims it has
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`suffered undue prejudice by “spend[ing] significant time, effort and money in defending against”
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`Realtime’s patent claims. (D.I. 46 at 5.) But there is no plausible support for this contention.
`
`Moreover, the legal standard for “undue prejudice” must only focus on actual “prejudice” after
`
`the original motion to dismiss. This case has only thus far dealt with Defendant’s own pleading
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`motions. Not one other substantive event has occurred in this case—not even a scheduling order.
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`Thus, there can be no prejudice here, let alone undue prejudice.
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`Defendant’s argument is also nonsensical. Because no events have taken place since its
`
`original motion, Defendant now resorts to claiming that it suffers undue prejudice from having to
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`even respond to a motion to amend. (D.I. 46 at 5.) But that would be true in every case, which
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`obviously would result in the narrow “undue prejudice” exception completely swallowing the
`
`liberal amendment rule.
`
`Moreover, Defendant’s claim that Realtime’s patents are facially invalid are belied by the
`
`facts and the law. Under recent Federal Circuit law, those claims are presumptively valid.
`
`Cellspin Soft, Inc. v. Fitbit, Inc., --- F.3d ---, 2019 WL 2588278, at *8-23. And here,
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`Defendant’s claim is even more implausible, as the very patent claims at issue also were already
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`4
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`Case 1:17-cv-01520-CFC-SRF Document 47 Filed 07/17/19 Page 8 of 13 PageID #: 2600
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`found not ineligible by another district court judge. In short, Defendant’s meritless argument
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`should be rejected.
`
`B.
`
`Realtime’s Reissue Patent Number Clarification Also Does Not Result In
`Undue Delay or Prejudice
`
`To get another good sense of how far Defendant stretches the facts and law on this topic,
`
`Defendant calls “undue delay” and “undue prejudice,” Defendant incredibly also argues that
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`Realtime’s amendment to simply replace the ’777 patent’s number with that of its re-issue patent
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`is both “unduly prejudicial” and the result of “undue delay.” (D.I. 46 at 16.) But the scope of the
`
`patent did not change, nor did the scope of this case. Defendant’s arguments to the contrary
`
`merely reveals its misleading suggestions as to the facts. It also reveals Defendant’s
`
`misapplication of the law. See 35 U.S.C. 252 (The surrender of the original patent shall take
`
`effect upon the issue of the reissued patent, and every reissued patent shall have the same effect
`
`and operation in law, on the trial of actions for causes thereafter arising, as if the same had been
`
`originally granted in such amended form, but in so far as the claims of the original and reissued
`
`patents are substantially identical, such surrender shall not affect any action then pending nor
`
`abate any cause of action then existing, and the reissued patent, to the extent that its claims are
`
`substantially identical with the original patent, shall constitute a continuation thereof and have
`
`effect continuously from the date of the original patent) (emphasis added).
`
`C.
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`Substantively, Realtime’s Amendments Are Anything But Futile.
`
`Defendant’s “futility” arguments are meritless. First, allegations regarding the third-party
`
`patents of Western Digital and Altera are not “futile.” On the contrary, they show that the
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`problems that Realtime’s Fallon patents solved were technological, computer-specific problems
`
`(as opposed to human problems)—i.e., the technological, computer-specific problems regarding
`
`computer capacity and a need for a more efficient compression system. This shows that the
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`5
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`Case 1:17-cv-01520-CFC-SRF Document 47 Filed 07/17/19 Page 9 of 13 PageID #: 2601
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`Fallon patents are eligible under §101. See Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 134 S. Ct.
`
`2347, 2358 (2014) (claims that “improve[] an existing technological process” or “solve a
`
`technological problem in ‘conventional industry practice’” are patent-eligible). The third-party
`
`patents are also directly relevant to the Fallon patents. Not only do these third-party patents
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`involve compression—“an area firmly rooted in computer technology” (Realtime Adaptive
`
`Streaming LLC v. Google LLC, Case No. 2:18-cv-032629-GW-JC, D.I. 36 (D.C. Cal. Oct. 25,
`
`2018))—but they also cite to other Realtime patents, including those that are related and share
`
`the same specification as the Fallon patents asserted here. For instance, U.S. Pat. No. 9,448,738
`
`of Western Digital, quoted in Realtime’s amended complaint, cites to multiple Realtime patents
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`and patent applications by inventor James Fallon, including Pat. No. 8,054,879 and Pat. App.
`
`Pub. No. 2011/0235697, which are both related to (and share the same specification as) the
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`Fallon patents asserted here. Similarly, U.S. Pat. No. 9,026,568 of Altera, quoted in Realtime’s
`
`amended complaint, also cites to multiple Realtime patents and patent application by inventor
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`James Fallon, including Pat. Nos. 6,195,024 and 6,309,424, which are both incorporated by
`
`reference into the Fallon patents asserted here. See ‘535 patent at 5:32-37. In short, the
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`statements from these third-party patents are relevant and probative of §101 eligibility.
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`Second, the allegations regarding claim construction proposals are not futile because they
`
`confirm that the Fallon patents are directed to technological, computer-specific solutions arising
`
`specifically in the realm of computer technology. For example, each of the proposed
`
`constructions confirm that the claims are computer-specific: “access profile” is a computer
`
`specific digital information that enables a computer controller to perform computer specific
`
`operations; “data profile” is also a computer specific digital information that associates other
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`computer specific operations; “asymmetric” compression is a specific subset of computer
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`6
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`Case 1:17-cv-01520-CFC-SRF Document 47 Filed 07/17/19 Page 10 of 13 PageID #: 2602
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`compression algorithm; “data block” is a digital computer data (i.e., “bits”); and “compress” is a
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`computer-specific operation that results in fewer “bits.” Indeed, a Texas court has held that
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`computer-specific nature of the claims were important considerations in ruling that other
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`Realtime patents (specifications of which are incorporated by reference into the asserted Fallon
`
`patents) are patent eligible. See Realtime Data LLC v. Actian Corp., 2016 WL 259581, *1 (E.D.
`
`Tex. Jan. 21, 2016) (“under Plaintiff’s construction [that data at issue is digital and ‘not easily
`
`recognizable to humans’], Defendants’ argument that patents are directed to an abstract idea
`
`would fail.”); see also Aatrix Software v. Green Shades Software, 882 F.3d 1121, 1125 (Fed. Cir.
`
`2018) (District court “did err when it denied leave to amend without claim construction and in
`
`the face of factual allegations, spelled out in the proposed second amended complaint, that, if
`
`accepted as true, establish that the claimed combination contains inventive components and
`
`improves the workings of the computer.”).
`
`Third, Realtime’s allegations regarding “unconventional and novel limitations” are not
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`futile. Indeed, the Federal Circuit made clear that “[t]he question of whether a claim element or
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`combination of elements is well-understood, routine and conventional to a skilled artisan in the
`
`relevant field is a question of fact.” Berkheimer v. HP Inc., 881 F.3d 1360, 1368 (Fed. Cir.
`
`2018). Moreover, while “the specification need not expressly list all the reasons why this claimed
`
`structure is unconventional” (Cellspin Soft, Inc. v. Fitbit, Inc., --- F.3d ---, 2019 WL 2588278, at
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`*8 (Fed. Cir. June 25, 2019), Realtime’s allegations actually cites and quotes the specifications
`
`supporting the unconventional and novel nature of the claim limitations. For instance, Realtime’s
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`allegations provide detailed factual support for the unconventional nature of using “throughput
`
`(bandwidth)” in selecting compression techniques and the fact that the inventors recognized the
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`novelty of “utiliz[ing] an asymmetrical algorithm” with “throughput (bandwidth),” as such a use
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`7
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`Case 1:17-cv-01520-CFC-SRF Document 47 Filed 07/17/19 Page 11 of 13 PageID #: 2603
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`may “provide an increase in the overall system performance as compared the performance that
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`would be obtained using a symmetrical algorithm.” (E.g., TAC at ¶¶ 23, 72, 121, 170, 219.) As
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`another example, Realtime’s allegations further show that using multiple compression
`
`compression algorithms in a single system is unconventional. (E.g., TAC at ¶¶ 24, 73, 122, 171,
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`220.) And as yet another example, Realtime’s allegations also show that the inventors of the
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`Fallon patents recognized the unconventional effect of using asymmetrical compression in
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`specific situations. (E.g., TAC at ¶¶ 25, 74, 123, 172, 221); see also Berkheimer v. HP Inc., 890
`
`F.3d 1369, 1373 (Fed. Cir. 2018) (per curiam) (“We cannot adopt a result-oriented approach to
`
`end patent litigation at the Rule 12(b)(6) stage that would fail to accept as true the complaint's
`
`factual allegations and construe them in the light most favorable to the plaintiff, as settled law
`
`requires.”).
`
`Defendant argues that all of these factual allegations—supported by the intrinsic
`
`evidence, with quotes and cites to the specifications—should be disregarded because they were
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`purportedly admitted in the specification to be well-known. That is false. Neither the Report and
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`Recommendation nor Defendant’s opposition cites to any specification that support the assertion
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`that the claimed combinations (involving, e.g., “asymmetric compressors,” “plurality of
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`compressors,” “compression routing … depend[] on the throughput,” and/or “access profile”)
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`were well known. In fact, the Report and Recommendation’s sole support for the assertion that
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`the patents purportedly “admit” the claims are conventional is the following sentence from the
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`Fallon patents: “It is to be understood that the systems and method described herein may be
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`implemented in various forms of hardware, software, firmware, special purpose processors, or a
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`combination thereof.” (‘535 patent at 20:1-4; see also D.I. 41 (R&R) at 20, 22.) That sentence
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`does not even mention any of the claim limitations, nor does it say anything about them being
`
`
`
`8
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`

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`Case 1:17-cv-01520-CFC-SRF Document 47 Filed 07/17/19 Page 12 of 13 PageID #: 2604
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`conventional. Indeed, virtually any computer-based inventions can be “implemented in various
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`forms of hardware, software, firmware, special purpose processors, or a combination thereof.”
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`Following such a logic, any computer-based inventions would be ineligible. That certainly is not
`
`the law.1
`
`Fourth, Realtime’s allegations regarding non-representative nature of various claims is
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`not futile, as they provide meaningful arguments regarding limitations found only in certain
`
`claims and not others. See Berkheimer, 881 F.3d at 1365 (“A claim is not representative simply
`
`because it is an independent claim. Indeed, Mr. Berkheimer advanced meaningful arguments
`
`regarding limitations found only in the dependent claims.”). Defendant’s argument regarding
`
`these allegations is not even about futility, but rather that they are legal arguments that Realtime
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`has purportedly “waived” by not including in the §101 briefing. That is false. Realtime included
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`arguments that Defendant failed to show that all claim should be treated the same. (E.g., D.I. 28
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`(Realtime’s Opp. to Mot. to Dismiss) at 18-19.) The amended allegations provide additional
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`meaningful arguments that various claims have limitations found only in certain claims. They are
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`not futile.
`
`Fifth, the allegations quoting the California court’s order holding that some of the same
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`Fallon patents at issue in this case are “tied to specific computer systems that ‘improve[]
`
`computer functionality in some way’ rather than being drawn to purely abstract concepts”
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`(Realtime Adaptive Streaming LLC v. Google LLC, Case No. 2:18-cv-032629-GW-JC, D.I. 36
`
`
`1 Haivision also cites to various other parts of the Fallon patent specifications to argue that the
`claim limitations were “admittedly known in the prior art.” See Opp. at 13, fn.15. That is false.
`As an initial matter, the Report and Recommendation does not cite to any of these portions of the
`specification. Moreover, these portions merely state that multiple compression algorithms
`(including Lempel-Ziv) were known before the Fallon patents. They do not say that anyone
`before the inventors of the Fallon patents recognized the significance and benefits of using
`multiple asymmetric compression techniques in certain circumstances and using throughput
`(bandwidth) as a parameter to compress digital data.
`
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`9
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`Case 1:17-cv-01520-CFC-SRF Document 47 Filed 07/17/19 Page 13 of 13 PageID #: 2605
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`(D.C. Cal. Oct. 25, 2018)) are not futile. On the contrary, they are factual allegations that are
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`necessarily plausible—indeed, a federal District Court found those allegations to be true. They
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`are entitled to be viewed in the light most favorable to Realtime. See Berkheimer, 890 F.3d at
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`1373 (per curiam) (“We cannot adopt a result-oriented approach to end patent litigation at the
`
`Rule 12(b)(6) stage that would fail to accept as true the complaint's factual allegations and
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`construe them in the light most favorable to the plaintiff, as settled law requires.”).
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`II.
`
`CONCLUSION
`
`For the foregoing reasons, Realtime respectfully requests that the Court grant leave for
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`Realtime to file Third Amended Complaint, set forth in Exhibit 1.
`
`
`
`
`
`July 17, 2019
`
`OF COUNSEL:
`
`Marc A. Fenster
`Brian D. Ledahl
`Reza Mirzaie
`C. Jay Chung
`RUSS, AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`(310) 826-7474
`Los Angeles, CA 90025-1031
`mfenster@raklaw.com
`bledahl@raklaw.com
`rmirzaie@raklaw.com
`jchung@raklaw.com
`
`
`
`
`
`
`
`
`
`
`BAYARD, P.A.
`
` /s/ Stephen B. Brauerman
`Stephen B. Brauerman (No. 4952)
`600 N. King Street, Suite 400
`Wilmington, DE 19801
`(302) 655-5000
`sbrauerman@bayardlaw.com
`
`Attorneys for Plaintiff Realtime Adaptive
`Streaming LLC
`
`10
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`