UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`
`
`LG ELECTRONICS, INC., TOSHIBA CORP.,
`VIZIO, INC., HULU, LLC,
`CISCO SYSTEMS, INC., AVAYA INC.,
`VERIZON SERVICES CORP., and VERIZON BUSNESS NETWORK
`SERVICES INC.,
`Petitioners,
`
`v.
`
`STRAIGHT PATH IP GROUP, INC.
`(FORMERLY KNOWN AS INNOVATIVE COMMUNICATIONS
`TECHNOLOGIES, INC.)
`Patent Owner
`________________
`
`Case IPR2015-002091
`Patent 6,108,704 C1
`________________
`
`
`
`PATENT OWNER’S OPPOSITION
`TO PETITIONER’S MOTION TO EXCLUDE EVIDENCE
`
`
`
`
`
` 1
`
` IPR2015-01398 and IPR2015-01406 have been joined with this
`proceeding.
`
`
`
`________________
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`
`
`LG ELECTRONICS, INC., TOSHIBA CORP.,
`VIZIO, INC., HULU, LLC,
`CISCO SYSTEMS, INC., AVAYA INC.,
`VERIZON SERVICES CORP., and VERIZON BUSNESS NETWORK
`SERVICES INC.,
`Petitioners,
`
`v.
`
`STRAIGHT PATH IP GROUP, INC.
`(FORMERLY KNOWN AS INNOVATIVE COMMUNICATIONS
`TECHNOLOGIES, INC.)
`Patent Owner
`________________
`
`Case IPR2015-002091
`Patent 6,108,704 C1
`________________
`
`
`
`PATENT OWNER’S OPPOSITION
`TO PETITIONER’S MOTION TO EXCLUDE EVIDENCE
`
`
`
`
`
` 1
`
` IPR2015-01398 and IPR2015-01406 have been joined with this
`proceeding.
`
`
`
`TABLE OF CONTENTS
`
`
`
`Page
`
`I.
`
`II.
`
`INTRODUCTION ........................................................................................... 1
`
`BACKGROUND ............................................................................................. 1
`
`III. ARGUMENT ................................................................................................... 3
`
`B.
`
`C.
`
`D.
`
`A. None of the challenged Exhibits should be excluded because
`the Board, with its administrative expertise, is in a position to
`determine and assign the appropriate weight to give to the
`evidence. ................................................................................................ 3
`The Dictionary Definitions (Exhibits 2021, 2031, 2034, 2035,
`and 2036) are relevant under Federal Rule of Evidence 401 and
`admissible under Federal Rules of Evidence 402 and 403. .................. 4
`Dr. Houh’s Testimony (Exhibit 2039) is admissible under the
`Federal Rules of Evidence. .................................................................... 6
`The Microsoft “Modifying WINS” Publication (Exhibits 2028
`and 2033) is relevant and admissible under Federal Rules of
`Evidence 703 and 807. .......................................................................... 7
`1.
`Exhibits 2028 and 2033 are admissible under Federal
`Rule of Evidence 703 because they were properly relied
`upon by an expert. ....................................................................... 7
`Petitioner has not met its burden for its irrelevance,
`authentication, and hearsay objections. ...................................... 9
`
`2.
`
`IV. CONCLUSION .............................................................................................. 11
`
`i
`
`
`
`TABLE OF AUTHORITIES
`
`
`
` Page(s)
`
`Cases
`
`505 Games, Inc.v. Babbage Holdings, Inc.,
`IPR2014-00954, Paper No. 17 (PTAB Aug. 22, 2014)… .................................... 2
`
`
`Advanced Magnetic Closures, Inc. v. Rome Fastener Corp.,
`607 F.3d 817 (Fed. Cir. 2010) .......................................................................... 1, 3
`
`Donnelly Garment Co. v. NLRB,
`123 F.2d 215 (8th Cir. 1941) ................................................................................ 3
`
`Gnosis S.p.A. v. S. Alabama Med. Sci. Found.,
`IPR2013-00118, Paper No. 64 (PTAB June 20, 2014)… .................................... 3
`
`
`Google Inc. v. Intellectual Ventures II LLC,
`IPR2014-01031, Paper No. 41 (PTAB Dec. 7, 2015)………………………..….5
`
`
`Lexington Ins. Co. v. W. Penn. Hosp.,
`423 F.3d 318 (3rd Cir. 2005) ................................................................................ 9
`
`
`LG Chem., LTD., v. Celgard, LLC,
`IPR2014-00693, Paper No. 76 (PTAB Oct. 5, 2015)… ...................................... .8
`
`
`Liberty Mutual Insurance Co. v. Progressive Casualty Insurance Co.,
`CBM2012-00002, Paper No. 66 (PTAB Jan. 23, 2014)…………………………4
`
`
`People v. Valdez,
`201 Cal. App. 4th 1429 (Cal. Ct. App. 2011) ....................................................... 9
`
`
`Sipnet EU S.R.O. v. Straight Path IP Group Inc.,
`IPR2013-00246, Paper No. 62 (PTAB Oct. 9, 2014) ....................................... …6
`
`
`Sony Computer Entertainment America LLC v. Game Controller Technology LLC,
`IPR2014-00634, Paper No. 32 (PTAB Apr. 14, 2015)………………………...3,4
`
`Vitronics Corp. v. Conceptronic, Inc.,
`90 F.3d 1576 (Fed. Cir. 1996) .............................................................................. 5
`
`ii
`
`
`
`
`
`Other Authorities
`
`37 C.F.R § 42.20(c) .................................................................................................... 1
`
`F.R.E. 401 .............................................................................................................. 4, 9
`
`F.R.E. 402 and 403 ..................................................................................................... 4
`
`F.R.E. 703 .................................................................................................................. 7
`
`F.R.E. 801(d) .............................................................................................................. 6
`
`F.R.E. 807 .................................................................................................................. 7
`
`F.R.E. 901 .................................................................................................................. 9
`
`iii
`
`
`
`Case IPR2015-00209
`Patent No. 6,108,704
`
`
`I.
`
`INTRODUCTION
`
`The Board should deny Petitioner’s Motion to Exclude Straight Path’s
`
`Exhibits 2021, 2028, 2031, 2033, 2034, 2035, 2036, and 2039 in this IPR of U.S.
`
`Patent No. 6,108,704 for at least the following reasons:
`
`(1) The entire basis for Petitioner’s motion – its argument that the
`
`Exhibits are inadmissible under the Federal Rules of Evidence—is insufficient
`
`because “[t]he Federal Rules of Evidence do not generally apply when [as here] the
`
`judge is acting as a fact-finder because a judge can presumably exclude improper
`
`inferences.”2
`
`(2) The exhibits are properly before the Board under the Federal Rules of
`
`Evidence.
`
`II. BACKGROUND
`
`As the movant, Petitioner has the burden of proof to establish that it is
`
`entitled to the requested relief. 37 C.F.R § 42.20(c). The Exhibits Petitioner seeks
`
`to exclude are the following:
`
`
`
`Exhibits 2021, 2031, 2034, 2035, and 2036, which are dictionary
`
`definitions supporting Straight Path’s proposed claim constructions.
`
`
`
` 2
`
` Advanced Magnetic Closures, Inc. v. Rome Fastener Corp., 607 F.3d 817, 831
`(Fed. Cir. 2010).
`
`1
`
`
`
`Case IPR2015-00209
`Patent No. 6,108,704
`
`
`
`
`
`Exhibit 2039 is the transcript for the deposition of Dr. Houh, the
`
`expert in co-pending IPR2014-01366, IPR2014-01367, and IPR2014-01368 (the
`
`“Cisco/Avaya/Samsung IPRs”), which relate to the same patent and references as
`
`this IPR, and which are before the same Board.
`
`
`
`Exhibits 2028 and 2033, each of which is the same substantive
`
`Microsoft document (Exhibit 2033 is Exhibit 2028 in a more readable format, as
`
`acknowledged by Petitioner’s expert Dr. Maggs, see Exhibit 2037 (Maggs Depo.)
`
`at 180:4 – 17) and describe details concerning the Microsoft Windows NT Server
`
`Version 3.5 (“WINS”) reference relied upon by Petitioner and thus evidences and
`
`confirms how one of ordinary skill in the art would understand that reference.
`
`Cisco Systems, Inc., and Avaya, Inc. are Petitioner in both this IPR and the
`
`earlier Cisco/Avaya/Samsung IPRs.3 Exhibits 2021, 2033, 2034, 2035 and 2039
`
`were previously introduced into the record in the Cisco/Avaya/Samsung IPRs with
`
`
`
` “[S]eparate companies constitute … a single Petitioner.” 505 Games, Inc. v.
`
` 3
`
`Babbage Holdings, Inc., IPR2014-00954, Paper No. 17 at 2 (PTAB Aug. 22,
`
`2014). “[T]here is but a single party filing the petition, no matter how many
`
`companies are listed as petitioner or petitioners.” Id.
`
`2
`
`
`
`Case IPR2015-00209
`Patent No. 6,108,704
`
`
`no objection by the Petitioner. Exhibits 2021, 2033, 2034, 2035 and 2039 are thus
`
`already part of the file history for the challenged ’704 Patent.
`
`III. ARGUMENT
`
`A. None of the challenged Exhibits should be excluded because the
`Board, with its administrative expertise, is in a position to
`determine and assign the appropriate weight to give to the
`evidence.
`
`Petitioner’s motion relies solely on its argument that the challenged exhibits
`
`are inadmissible under the Federal Rules of Evidence (F.R.E.). But “the Federal
`
`Rules of Evidence do not generally apply when the judge is acting as a fact-finder
`
`because a judge can presumably exclude improper inferences.” Advanced
`
`Magnetic Closures, Inc. v. Rome Fastener Corp., 607 F.3d 817, 831 (Fed. Cir.
`
`2010). Here, the Board, sitting as a non-jury tribunal with administrative expertise,
`
`is well-positioned to determine and assign appropriate weight to all evidence
`
`presented. Gnosis S.p.A. v. S. Alabama Med. Sci. Found., IPR2013-00118, Paper
`
`No. 64 at 43 (PTAB June 20, 2014); see also Donnelly Garment Co. v. NLRB, 123
`
`F.2d 215, 224 (8th Cir. 1941) (“One who is capable of ruling accurately upon the
`
`admissibility of evidence is equally capable of sifting it accurately after it has been
`
`received.”).
`
`Contrary to Petitioner’s motion, in an inter partes review, it is “the better
`
`course to have a complete record of the evidence to facilitate public access, as well
`
`3
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`
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`Case IPR2015-00209
`Patent No. 6,108,704
`
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`as appellate review.” Sony Computer Entertainment America LLC v. Game
`
`Controller Technology LLC, IPR2013-00634, Paper No. 32 at 32 (PTAB Apr. 14,
`
`2015). Indeed, “[T]here is a strong public policy for making all information filed
`
`in a non-jury, quasi-judicial administrative proceeding available to the public,
`
`especially in an inter partes review which determines the patentability of claims in
`
`an issued patent.” Liberty Mutual Insurance Co. v. Progressive Casualty Insurance
`
`Co., CBM2012-00002, Paper No. 66 at 60, 61 (PTAB Jan. 23, 2014). It is “within
`
`the Board’s discretion to assign the appropriate weight to be accorded to evidence .
`
`. . [and] it is better to have a complete record of the evidence submitted by the
`
`parties than to exclude particular pieces.” Id.
`
`Therefore, because the Board is well-positioned to determine and assign the
`
`appropriate weight to all exhibits, including Exhibits 2021, 2028, 2031, 2033,
`
`2034, 2035, 2036, and 2039, and Petitioner has not argued that it would be
`
`prejudiced by the admission of these exhibits, Straight Path respectfully requests
`
`that the Board admit these exhibits, and use its expertise and discretion to assign
`
`them the appropriate weight.
`
`B.
`
`The Dictionary Definitions (Exhibits 2021, 2031, 2034, 2035, and
`2036) are relevant under Federal Rule of Evidence 401 and
`admissible under Federal Rules of Evidence 402 and 403.
`
`4
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`
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`Case IPR2015-00209
`Patent No. 6,108,704
`
`
`
`Petitioner moves to exclude Exhibits 2021, 2031, 2034, 2035, and 2036,
`
`which are dictionary definitions supporting Straight Path’s claim constructions.
`
`Petitioner argues only that the dictionary definitions were published after the
`
`priority date and thus have no relevance to claim interpretation in this case.
`
`Petitioner misstates the law and this very Board’s own practices.
`
`Judges are free to consult dictionaries at any time in order to better
`
`understand the underlying technology. See Vitronics Corp. v. Conceptronic, Inc.,
`
`90 F.3d 1576, 1585 n.6 (Fed. Cir. 1996). Judges may also consult dictionary
`
`definitions when construing claim terms so long as the dictionary definition does
`
`not contradict any definition found in or ascertained by a reading of the patent
`
`documents. Id.
`
`Petitioner’s temporal concerns do not render the exhibits inadmissible, but
`
`rather go to the weight of the evidence. Google Inc. v. Intellectual Ventures II
`
`LLC, IPR2014-01031, Paper No. 41 at 10 (PTAB Dec. 7, 2015). This is not to
`
`suggest that the exhibits should be given little weight, only that temporal concerns
`
`raised by Petitioner go to the weight and not the admissibility. Indeed, if
`
`Petitioner’s argument had any merit, it could have and should have presented
`
`evidence that the relevant meaning of the words and phrases in question somehow
`
`changed in the time between the priority date and the publication date(s) of the
`
`5
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`Case IPR2015-00209
`Patent No. 6,108,704
`
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`dictionary definitions provided by Straight Path. Petitioner presents no such
`
`evidence; indeed, it does not even argue –with or without evidence—that the
`
`definitions changed.
`
`Contrary to Petitioner’s motion, the Board found definitions postdating the
`
`priority date highly probative in construing claims in this very patent family: in the
`
`Sipnet IPR, the Board used dictionary definitions from 2008 and 1998 to discern
`
`the plain and ordinary meaning of claim terms in Straight Path’s ’704 Patent. See
`
`Sipnet EU S.R.O. v. Straight Path IP Group Inc., IPR2013-00246, Paper No. 62 at
`
`9 n. 3, n. 4 (PTAB Oct. 9, 2014).
`
`C. Dr. Houh’s Testimony (Exhibit 2039) is admissible under the
`Federal Rules of Evidence.
`
`Petitioner’s only argument for excluding Exhibit 2039 is its hearsay
`
`objection. But Exhibit 2039 is the deposition testimony of Dr. Houh, an expert in
`
`the earlier Cisco/Avaya/Samsung IPRs concerning the same patent and prior art as
`
`this IPR, and which is before the same Board. The exhibit was introduced with no
`
`objection in that IPR and thus is already part of the file history for the challenged
`
`’704 Patent.
`
`Moreover, Petitioner’s hearsay objection is baseless. Cisco and Avaya are
`
`Petitioner in both this IPR and the earlier Cisco/Avaya/Samsung IPRs, and Dr.
`
`Houh is their own proffered expert on this very topic. See, e.g., F.R.E. 801(d)
`
`6
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`Case IPR2015-00209
`Patent No. 6,108,704
`
`
`(statement used against a party and made by a person authorized by the party to
`
`make a statement on the subject is not hearsay). Moreover, Petitioner had every
`
`opportunity to cross-examine or otherwise offer rebuttal testimony from Dr. Houh.
`
`For example, Cisco and Avaya attended Dr. Houh’s deposition in the
`
`Cisco/Avaya/Samsung IPRs and could have cross-examined him about any of the
`
`proffered testimony but they chose not to do so. See Exhibit 2039 at 4:19-21
`
`(announcing counsel “representing Cisco Systems, Inc. and Avaya, Inc.”).
`
`D. The Microsoft “Modifying WINS” Publication (Exhibits 2028 and
`2033) is relevant and admissible under Federal Rules of Evidence
`703 and 807.
`
`The Board also should reject Petitioner’s attempt to exclude the Microsoft
`
`publication titled “Modifying WINS server defaults” based on irrelevance,
`
`authentication, and hearsay objections. First, the exhibits were relied on by Straight
`
`Path’s expert, Dr. Stubblebine, and would therefore be admissible under F.R.E.
`
`703 regardless of Petitioner’s objections. Second, Petitioner’s objections are
`
`baseless.
`
`1.
`
`Exhibits 2028 and 2033 are admissible under Federal Rule
`of Evidence 703 because they were properly relied upon by
`an expert.
`
`Dr. Stubblebine relies upon Exhibit 2028 in ¶ 45 of his declaration, and
`
`Exhibit 2031 in ¶ 28 of his declaration. See Exhibit 2038 at ¶¶ 28, 45. F.R.E. 703
`
`allows the proponent of the expert opinion to disclose the evidence underlying an
`
`7
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`
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`Case IPR2015-00209
`Patent No. 6,108,704
`
`
`expert opinion to the jury if the “probative value in helping the jury evaluate the
`
`opinion substantially outweighs [its] prejudicial effect.” LG Chem., LTD., v.
`
`Celgard, LLC, IPR2014-00693, Paper No. 76 at 44-45 (PTAB Oct. 5, 2015).
`
`Petitioner has not alleged any prejudice, and these exhibits have substantial
`
`probative value.
`
`Microsoft WINS is Petitioner’s primary prior art reference in these
`
`proceedings, (see Exhibit 1003), and Exhibits 2028 and 2033 both describe how
`
`the WINS name server functions and evidence how one of ordinary skill in the art,
`
`such as Dr. Stubblebine and Petitioner’s own expert, Dr. Maggs, would understand
`
`the WINS reference. See Exhibit 2033. Indeed, the key dispute in this proceeding
`
`is whether WINS teaches determining and relying on if a computer is currently
`
`online. Exhibits 2028 and 2033 confirm that one of ordinary skill in the art would
`
`understand that the WINS reference does not teach that feature, and they are thus
`
`highly relevant to this IPR. See Exhibit 2033.
`
`Despite bearing the burden on its motion, Petitioner has not even alleged the
`
`required prejudice. Moreover, because the Board is not a lay jury, and has
`
`significant experience in evaluating expert testimony, the danger of prejudice in
`
`this proceeding is considerably lower than in a conventional district court trial. Id.
`
`8
`
`
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`Case IPR2015-00209
`Patent No. 6,108,704
`
`
`Petitioner’s irrelevance, authentication, and hearsay objections thus provide no
`
`basis for excluding these exhibits.
`
`2.
`
`Petitioner has not met its burden for its irrelevance,
`authentication, and hearsay objections.
`
`As discussed above, Exhibits 2028 and 2033 evidence and confirm that one
`
`of ordinary skill in the art would understand that Petitioner’s references do not
`
`teach determining and relying on if a computer is currently online, a key issue in
`
`this IPR. The exhibits are therefore highly relevant and admissible under Fed. R.
`
`Evid. 401. Petitioner’s only argument – that the Exhibits are irrelevant to claim
`
`construction – misses the point entirely.
`
`Petitioner’s authentication objection is likewise baseless. F.R.E. 901
`
`provides that the requirement of admissibility is satisfied by evidence sufficient to
`
`support a finding that the material in question is what its proponent claims. The
`
`burden of proof for authentication is “slight.” Lexington Ins. Co. v. W. Penn.
`
`Hosp., 423 F.3d 318, 329 (3rd Cir. 2005). Any “conflicting inferences [go to] …
`
`the document’s weight as evidence, not its admissibility.” People v. Valdez, 201
`
`Cal. App. 4th 1429, 1435 (Cal. Ct. App. 2011). A proponent’s burden is not to
`
`establish “validity or negate falsity in a categorical fashion, but rather to make a
`
`showing on which the trier of fact reasonably could conclude the proffered writing
`
`is authentic.” Id. at 1436-37.
`
`9
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`
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`Case IPR2015-00209
`Patent No. 6,108,704
`
`
`
`Petitioner’s own expert, Dr. Maggs, established the authenticity and
`
`reliability of both Exhibit 2028 and 2033. When asked “in your experience, are
`
`documents fetched from Microsoft’s URL accurate,” Dr. Maggs responded “I
`
`suppose Microsoft has – tries to make them accurate.” Exhibit 2037 at 149:22 –
`
`150:5. Also, Dr. Maggs testified that the information in the exhibits comports with
`
`the WINS reference itself. Id. at 151:17-20 (“I do believe that 5 hours was the
`
`default renewal interval for Windows NT Server.”); see also id. at 181:18-23 (“Q:
`
`Do you have any reason to doubt the accuracy of the 5-hour default for Windows
`
`NT Server 3.5?... A: It’s also listed in the WINS manual so, I – no, I don’t really
`
`have any reason to.”); id. at 182:6-15 (“Q: do you have any reason to doubt that
`
`that [information in Exhibit 2033] is correct? … A: No, not really. …I don’t have
`
`any strong doubts”). Dr. Maggs confirmed that the exhibits were reliable, and that
`
`the exhibits were consistent with the teachings of the WINS reference itself.
`
`Exhibit 2037 at 183:18-184:3. Thus, Straight Path has overcome its “slight” burden
`
`in showing that the exhibits are authentic.
`
`Dr. Maggs never seriously contested that the exhibits were authentic. The
`
`“serious doubt” petitioners refer to regarding Exhibit 2028 was nothing more than
`
`Dr. Maggs finding Exhibit 2028 confusing because of a print formatting error in
`
`the document. See Exhibit 2037 at 151:4 – 152:7 (“this document’s confusing
`
`10
`
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`Case IPR2015-00209
`Patent No. 6,108,704
`
`
`because it hasn’t actually explicitly grouped which of these hours are default and
`
`which of these hours are maximum and which are minimum.”). Recognizing the
`
`print formatting error, Straight Path stopped questioning on Exhibit 2028, and
`
`presented Dr. Maggs with Exhibit 2033, which provides the same information as
`
`Exhibit 2028, but with the proper formatting. See Exhibit 2037 at 180:4 – 17 (“So
`
`this documents looks easier for me to understand based on the formatting and so I
`
`– you may get more clear answers if you reask when I can look at this document.”)
`
`Finally, Petitioner has not met its burden of establishing that Exhibits 2028
`
`and 2033 are hearsay, inadmissible or otherwise. First, Petitioner’s argument –
`
`without any support or explanation—that the exhibits are being offered for the
`
`truth of the matter asserted is contradicted by Petitioner’s own motion, which
`
`asserted that the exhibits are being offered to support some unidentified claim
`
`constructions. Second, the Exhibits are not being offered to show the truth of the
`
`matter – how the WINS server in fact actually works—but to show how one of
`
`ordinary skill in the art would understand the teaching of the WINS reference and
`
`the name server disclosed therein.
`
`IV. CONCLUSION
`
`For the reasons stated above, Straight Path respectfully requests that the
`
`Board deny Petitioner’s motion to exclude evidence.
`
`11
`
`
`
`
`Dated: January 19, 2016
`
`
`
`
`
`
`Case IPR2015-00209
`Patent No. 6,108,704
`
`/William Meunier/
`William A. Meunier (Reg. No. 41,193)
`
`Mintz, Levin, Cohn, Ferris, Glovsky
`and Popeo, P.C.
`One Financial Center
`Boston, MA 02111
`Telephone: (617) 348-1845
`Facsimile: (617) 542-2241
`StraightPathIPRs@mintz.com
`
`
`12
`
`
`
`Case IPR2015-00209
`Patent No. 6,108,704
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I certify that a copy of Patent Owner’s Opposition to Petitioner’s Motion to
`
`Exclude Evidence is being served by electronic mail on the following counsel for
`
`the Petitioners:
`
`For LG Electronics, Inc., Verizon Services
`Corp. and Verizon Business Network
`Services Inc.
`Finnegan, LLP
`Darren M. Jiron (Reg. No. 45,777)
`Rajeev Gupta (Reg. No. 55,873)
`darren.jiron@finnegan.com
`raj.gupta@finnegan.com
`
`For Vizio, Inc.
`
`Baker & McKenzie LLP
`Kevin O’Brien (Reg. No. 30,578)
`Richard V. Wells (Reg. No. 53,757)
`Kevin.O'Brien@bakermckenzie.com
`richard.wells@bakermckenzie.com
`
`For Toshiba Corporation
`
`For CISCO Systems
`
`Dorsey & Whitney
`Clint Conner (Reg. No. 52,764)
`Paul Meiklejohn (Reg. No. 26,569)
`Jennifer Spath (Reg. No. 51,916)
`conner.clint@dorsey.com
`meiklejohn.paul@dorsey.com
`spaith.jennifer@dorsey.com
`For Avaya Inc.
`
`Fish & Richardson
`Dorothy P. Whelan (Reg. No. 33,814)
`Christopher O. Green (Reg. No. 52,964)
`whelan@fr.com
`cgreen@fr.com
`
`Wilmer Cutler Pickering hale and Dorr
`LLP
`David L. Cavanaugh (Reg. No. 36,476)
`Jason D. Kipnis (Reg. No. 40,680)
`david.cavanaugh@wilmerhale.com
`jason.kipnis@wilmerhale.com
`
`For Hulu, LLC
`
`Keker & Van Nest LLP
`Leo Lam
`Matthias Kamber
`llam@kvn.com
`mkamber@kvn.com
`HULU-SP-IPR@kvn.com
`
`
`
`
`
`13
`
`
`
`Case IPR2015-00209
`Patent No. 6,108,704
`
`/ William A. Meunier /
`William A. Meunier (Reg. No. 41,193)
`Michael C. Newman (admitted pro
`hac vice)
`Mintz, Levin, Cohn, Ferris, Glovsky
`and Popeo, P.C.
`One Financial Center
`Boston, MA 02111
`Telephone: (617) 348-1845
`Facsimile: (617) 542-2241
`StraightPathIPRs@mintz.com
`
`
`Dated: January 19, 2016
`
`
`
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