`________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
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`NETFLIX, INC.,
`Petitioner,
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`v.
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`OPENTV, INC.,
`Patent Owner.
`________________
`
`IPR2014-00267
`Patent 7,409,437
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`________________
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`AFFIDAVIT OF LAURA E. MILLER IN SUPPORT OF
`PETITIONER’S SECOND MOTION FOR PRO HAC VICE ADMISSION
`
`________________
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`I, Laura E. Miller, being duly sworn and upon oath, hereby attest to the
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`following:
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`i.
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`I am a member in good standing of the Bar of California (#271713), as
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`well as the following Federal Courts:
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`a) U.S. Court of Appeals for the Ninth Circuit;
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`b) U.S. Court of Appeals for the Federal Circuit;
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`Netflix, Inc. v. OpenTV, Inc.
`IPR2014-00267
`NTFX-1011 / Page 1 of 3
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`
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`c) U.S. District Court for the Northern District of California; and
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`d) U.S. District Court for the Central District of California.
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`ii.
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`I have not been suspended or disbarred from practice before any court or
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`administrative body.
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`iii.
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`I have never had an application for admission to practice before any court
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`or administrative body denied.
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`iv. No sanction or contempt citation has been imposed against me by any
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`court or administrative body.
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`v.
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`I have read and will comply with the Office Patent Trial Practice Guide
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`and the Board’s Rules of Practice for Trials set forth in part 42 of the
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`Code of Federal Regulations.
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`vi.
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`I will be subject to the USPTO Rules of Professional Conduct set forth in
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`37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R.
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`§ 11.19(a).
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`vii.
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`I have not applied to appear Pro Hac Vice before the Office in any other
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`proceeding in the last three years.
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`viii.
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`I am an experienced litigation attorney, with experience in many
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`litigations involving patent infringement in District Courts across the
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`country, including experience with fact and expert document and
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`deposition discovery, claim construction, Markman hearings, motion
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`NTFX-1011 / Page 2 of 3
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`
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`practice, trials and hearings, and investigations before the International
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`Trade Commission.
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`ix.
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`I am counsel for Petitioner Netflix, Inc., the defendant in related on-going
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`litigations in which U.S. Patent No. 7,409,437 is and was asserted by the
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`Patent Owner. I am familiar with the subject matter at issue in this
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`proceeding as a result of my representation of Netflix, Inc. in those
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`related litigations, including the prior art that Petitioner presents in this
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`proceeding, as well as issues of claim construction.
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`Date: August 12, 2014
`
`/Laura E. Miller/
`Laura E. Miller
`DURIE TANGRI LLP
`217 Leidesdorff Street
`San Francisco, CA 94111
`Telephone: (415) 362-6666
`Fax: (415) 236-6300
`Email: LMiller@durietangri.com
`
`NTFX-1011 / Page 3 of 3