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`600 N. King Street ● Suite 400
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`P.O. Box 25130 ● Wilmington, DE 19801
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`Zip Code For Deliveries 19801
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` Writer’s Direct Access:
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` (302) 429-4232
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` Email: sbrauerman@bayardlaw.com
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`May 21, 2024
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`VIA CM/ECF
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`Honorable Jennifer L. Hall
`United States District Court for the District of Delaware
`844 North King Street
`Wilmington, DE 19801
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`RE: Robocast, Inc. v. YouTube, LLC, C.A. No. 22-304-JLH
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`Robocast, Inc. v. Netflix, Inc., C.A. No. 22-305-JLH
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`Dear Judge Hall:
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`Plaintiff Robocast, Inc. (“Plaintiff”) and Defendants Netflix, Inc. (“Netflix”) and YouTube,
`LLC and Google LLC (together, “Google”) (collectively, “Defendants”) respectfully submit this
`joint letter pursuant to the Court’s April 5, 2024 Oral Order (D.I. 242), directing the parties to
`provide the Court with a joint letter identifying no greater than 10 disputed claim terms to be
`construed in the above case.
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`The parties propose the following nine disputed terms for construction at a claim
`construction hearing to be set by the Court:
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` node
` show structure of nodes
` creating […] a [multidimensional] show structure of nodes
` user
` content … in an organized arrangement
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`interactively variable duration information
` advertisement content
` performing an on-line search
` accessing a … network-accessible resource
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`www.bayardlaw.com
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` Phone: (302) 655-5000
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` Fax: (302) 658-6395
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`Case 1:22-cv-00305-JLH Document 291 Filed 05/21/24 Page 2 of 2 PageID #: 14362
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`May 21, 2024
`Page 2
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`In addition, Netflix and Google each believes that, in light of the differences in the accused
`functionalities in the two cases, an additional term requires construction to reach resolution in their
`respective cases, as set forth below:
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` Netflix: plurality of accessible resources
` Google: each of said nodes
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`Robocast does not agree that any differences in the accused functionalities warrant
`expansion of the number of terms for construction from the limit of 10 set by the Court’s Oral
`Order. The parties recognize the Court’s limit of 10 and defer completely to the Court as to whether
`and when to construe these proposed tenth terms, but wanted to apprise the Court of the issue as it
`considers when to construe the disputed claim terms. Robocast, Inc. v. Netflix, Inc., C.A. No. 22-
`305-JLH, D.I. 149; Robocast, Inc. v. YouTube, LLC, C.A. No. 22-304-JLH, D.I. 122.
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`***
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`Should Your Honor have any questions or comments, the undersigned is available at the
`convenience of this Court.
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`Respectfully Submitted,
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`Counsel of Record
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`/s/ Stephen B. Brauerman
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`Stephen B. Brauerman (#4952)
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`cc:
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