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`Kelly E. Farnan
`(302) 651-7705
`farnan@rlf.com
`July 28, 2023
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`BY CM/ECF
`The Honorable Jennifer L. Hall
`United States District Court
`District of Delaware
`844 North King Street
`Wilmington, DE 19801
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`Re: Robocast, Inc. v. Netflix, Inc., C.A. No. 22-305-RGA-JLH
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`Dear Judge Hall:
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`Defendant Netflix, Inc. (“Netflix”) respectfully requests that the Court deny Plaintiff
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`Robocast, Inc.’s (“Robocast”) Motion for Teleconference Regarding Discovery Matters (D.I. 91,
`the “Motion”) on the ground that the four issues Robocast raises in the Motion are not ripe. The
`parties first met and conferred on these issues at noon today, July 28, 2023. Robocast raised the
`four issues for the first time on Monday, July 24, 2023, and yesterday, July 27, 2023. Netflix
`indicated on the meet and confer that its client was on vacation this week and that it would get
`back to Robocast with its positions. None of Netflix’s positions on the meet and confer suggested
`that the parties were “unable to resolve [the] discovery matter[s],” a prerequisite to filing the
`Motion. Judge Hall’s Rule 16 Scheduling Order – Patent – Revised Apr. 25, 2022 ¶ 8(g). Thus,
`the parties are not at an impasse on any of these issues. Further, Robocast failed to share the
`Motion with Netflix prior to filing or indicate that the four issues would be brought to the Court
`today. Netflix will be prepared to address these issues in any manner the Court deems appropriate.
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`Respectfully,
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`/s/ Kelly E. Farnan
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`Kelly E. Farnan (#4395)
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`cc: All Counsel of Record (CM/ECF)
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