Paper 59
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________________
`
`
`TWITTER, INC.
`
`
`
`Petitioner
`
`
`v.
`
`
`VIDSTREAM, LLC
`
`Patent Owner
`
`_____________________________
`
`
`Case IPR2017-01131
`U.S. Patent No. 8,464,304
`(Claims 1, 4-5, 8-9, 11-17, 19-26, and 28-30)
`_____________________________
`
`
`PATENT OWNER VIDSTREAM LLC’s
`MOTION TO EXCLUDE EVIDENCE
`
`
`73442028.1
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________________
`
`
`TWITTER, INC.
`
`
`
`Petitioner
`
`
`v.
`
`
`VIDSTREAM, LLC
`
`Patent Owner
`
`_____________________________
`
`
`Case IPR2017-01131
`U.S. Patent No. 8,464,304
`(Claims 1, 4-5, 8-9, 11-17, 19-26, and 28-30)
`_____________________________
`
`
`PATENT OWNER VIDSTREAM LLC’s
`MOTION TO EXCLUDE EVIDENCE
`
`
`73442028.1
`
`
`
`IPR2017-01131
`U.S. Patent No. 8,464,304
`
`Patent Owner (“PO”) moves to exclude the exhibits and testimony identified
`
`below pursuant to Rule 42.64(c).
`
`A. Exhibit 1033 – Fonearena.com Nokia E50
`Petitioner identifies Ex. 1033 as a copy of a webpage. Ex. 1052, ¶ 2.
`
`Petitioner relies on Ex. 1033 at Paper 53 (“Reply”), page 9 and Ex. 1052, ¶ 12 for
`
`its content (that the Nokia E50 had certain capability). PO objected to Ex. 1033 as
`
`untimely and lacking authentication when it was introduced in Dr. Olivier’s
`
`deposition. Ex. 1051 at 95:3-7, 126:2-15. PO also objected to Ex. 1033 as hearsay
`
`and untimely in Paper 54, pages 2-3.
`
`1.
`Lack of Authentication
`Ex. 1033 is inadmissible as lacking authentication. Petitioner does not offer
`
`sufficient proof that these exhibits are what Petitioner claims that they are.
`
`Petitioner’s expert, Dr. Houh, merely states that this is a true and correct copy of a
`
`webpage at a specified URL. Ex. 1052, ¶ 2. That is irrelevant. The Board has
`
`required that “[t]o authenticate printouts from a website [where, as here, the
`
`proponent is offering the printouts to prove the website’s contents], the party
`
`proffering the evidence must produce some statement or affidavit from someone
`
`with knowledge of the website . . . for example a web master or someone else with
`
`personal knowledge would be sufficient.” Neste Oil Oyj v. REG Synthetic Fuels,
`
`LLC, IPR2013-00578, slip op. at 4 (March 12, 2015) (Paper 53) (internal quotations
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`Case IPR2017-01131
`Patent 8,464,304
`and citations omitted). Petitioner has provided no such evidence. Dr. Houh does
`
`not claim to have personal knowledge of the website, and Petitioner does not provide
`
`any other testimony by a person with such knowledge. Therefore, Ex. 1033 is not
`
`authenticated and is inadmissible. Neste Oil, IPR2013-00578, slip op. at 3-4
`
`(granting motion to exclude website printouts offered to prove the website’s contents
`
`as lacking authentication because petitioner “has not provided the testimony of any
`
`witness with personal knowledge of the websites depicted in the printouts”).
`
`2.
`Untimely For Failure to Cure Objection
`Petitioner’s attempts to authenticate Ex. 1033 are untimely. PO objected to
`
`the admissibility of Ex. 1033 when it was introduced during the deposition, as
`
`required by 37 C.F.R. § 42.64(a) (“An objection to the admissibility of deposition
`
`evidence must be made during the deposition.”). However, Petitioner failed to
`
`comply with the requirements of this rule. Section 42.64(a) requires that “[e]vidence
`
`to cure the objection must be provided during the deposition.” Id. Petitioner did not
`
`provide any evidence during the deposition to cure the lack of authentication, and
`
`any further attempts to do so are untimely.
`
`3.
`Untimely Supplemental Information
`Ex. 1033 should be excluded as an untimely submission of supplemental
`
`information. Rather than identifying Ex. 1033 for what it is, part of a new or updated
`
`obviousness combination, Petitioner instead seeks to disguise Ex. 1033 as showing
`
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`purported knowledge of a POSITA. Petitioner and its expert rely upon Ex. 1033 to
`
`purportedly demonstrate what a POSITA would have understood about mobile
`
`handsets available at the time of Lahti (Ex. 1006). See Reply at 7 (citing Ex. 1052
`
`at ¶¶7-20, which includes reference to Ex. 1033). But this is an attempt to
`
`supplement Petitioner’s grounds with knowledge that is not disclosed in Lahti. It
`
`was incumbent upon Petitioner to proffer its evidence and arguments with
`
`particularity—including evidence and arguments relating to the of level of skill in
`
`the art and exactly what (and why) Lahti purportedly disclosed to a POSITA—at the
`
`time it filed its Petition. See Intelligent Bio-Systems, Inc. v. Illumina Cambridge,
`
`Ltd., 821 F.3d 1359, 1369 (Fed. Cir. 2016) (“It is of the utmost importance that
`
`petitioners in the IPR proceedings adhere to the requirement that the initial petition
`
`identify ‘with particularity’ the ‘evidence that supports the grounds for the challenge
`
`to each claim.’” (citing 35 U.S.C. § 312(a)(3))); see also id. (“[T[he expedited nature
`
`of IPRs bring with it an obligation for petitioners to make their case in their petition
`
`to institute.”).
`
`As a result, Petitioner’s filing of Ex. 1033 with its Reply amounted to an end-
`
`run around the requirements of Rule 123(b) for late-filed supplemental information.
`
`That rule requires a party seeking to submit supplemental information more than one
`
`month after institution to first request Board authorization to file a motion to submit
`
`it. 37 C.F.R. § 42.123(b). Then, if authorized, the party’s motion must show (1)
`
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`why the information reasonably could not have been obtained earlier and (2) that
`
`consideration of the supplemental information would be in the interests of justice.
`
`Id. Petitioner requested no such authorization prior to filing Ex. 1033 with its Reply,
`
`and it did not make either such showing in its Reply. For these reasons, Ex. 1033 is
`
`an untimely submission of supplemental information and should be excluded.
`
`4. Hearsay
`Ex. 1033 includes out-of-court statements offered to prove the truth of the
`
`matter asserted: the properties of the specific phone. Reply at 9 (stating that “the E
`
`50 was capable of recording at multiple resolutions”); Ex. 1052, ¶ 12. Therefore,
`
`the statements in Ex. 1033 relied upon are inadmissible hearsay.
`
`B.
`
`Exhibit 1036 – Article entitled “Samsung Starts Selling World’s
`First 10 Megapixel Camera Phone”
`Petitioner identifies Ex. 1036 as a copy of a webpage. Ex. 1052, ¶ 2.
`
`Petitioner relies on Ex. 1036 at Reply at 13 and Ex. 1052, ¶ 15 for its content (that
`
`certain Samsung devices possessed certain functionality). PO objected to Ex. 1036
`
`as untimely and lacking authentication when it was introduced in Dr. Olivier’s
`
`deposition. Ex. 1051, 100:19-23, 126:2-15. PO also objected to Ex. 1036 as hearsay
`
`and untimely. Paper 54, pages 4-6.
`
`1.
`Lack of Authentication and No Timely Cure
`Ex. 1036 is inadmissible as lacking authentication, which was not timely
`
`cured, for the same reasons discussed above for Ex. 1033.
`
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`2.
`Untimely Supplemental Information
`Ex. 1036 is relied upon as part of a new obviousness theory in the same way
`
`as Ex. 1033 and should be excluded as an untimely submission of supplemental
`
`information for the same reasons discussed above for Ex. 1033. See also Reply at 7
`
`(citing Ex. 1052 at ¶¶7-20, which includes reference to Ex. 1036).
`
`3. Hearsay
`Ex. 1036 includes out-of-court statements offered to prove the truth of the
`
`matter asserted: the properties of the specific phones. Reply at 13 (stating that “the
`
`Samsung SCH-V770 and the Samsung SCH-B600 each could record video at 15-30
`
`fps”); Ex. 1052, ¶ 15. Therefore, the statements in Ex. 1036 relied upon are
`
`inadmissible hearsay. In addition, any date on the face of Ex. 1036 relied upon to
`
`establish a date of publication for Ex. 1036 is an out-of-court statement relied upon
`
`for the truth of the matter asserted and is therefore inadmissible hearsay.
`
`C. Exhibit 1037 – Letsgodigital.com article referencing Samsung
`SCH-V7770
`Petitioner identifies Ex. 1037 as a copy of a webpage. Ex. 1052, ¶ 2.
`
`Petitioner relies on Ex. 1037 at Reply at 13 and Ex. 1052, ¶ 15 for its content (that a
`
`certain Samsung device possessed certain functionality). PO objected to Ex. 1037
`
`as untimely and lacking authentication when it was introduced in Dr. Olivier’s
`
`deposition. Ex. 1051 at 102:16-19, 126:2-15. PO also objected to Ex. 1037 as
`
`hearsay and untimely in Paper 54, pages 6-7.
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`Patent 8,464,304
`1.
`Lack of Authentication and No Timely Cure
`Ex. 1037 is inadmissible as lacking authentication, which was not timely
`
`cured, for the same reasons discussed above for Ex. 1033.
`
`2.
`Untimely Supplemental Information
`Ex. 1037 is relied upon as part of a new obviousness theory in the same way
`
`as Ex. 1033 and should be excluded as an untimely submission of supplemental
`
`information for the same reasons discussed above for Ex. 1033. See also Reply at 7
`
`(citing Ex. 1052 at ¶¶7-20, which includes reference to Ex. 1037).
`
`3. Hearsay
`Ex. 1037 includes out-of-court statements offered to prove the truth of the
`
`matter asserted: the properties of the specific phone. Reply at 13 (stating that “the
`
`Samsung SCH-V770 … could record video at 15-30 fps”); Ex. 1052, ¶ 15.
`
`Therefore, the statements in Ex. 1037 relied upon are inadmissible hearsay. In
`
`addition, any date on the face of Ex. 1037 relied upon to establish a date of
`
`publication for Ex. 1037 is an out-of-court statement relied upon for the truth of the
`
`matter asserted and is therefore inadmissible hearsay.
`
`D. Exhibit 1043 – Class CCamera from Symbian Developer Network,
`S60 SDKs
`Petitioner identifies Ex. 1043 as a copy of a webpage. Ex. 1052, ¶ 2.
`
`Petitioner relies on Ex. 1043 at Reply at 13-14 and Ex. 1052, ¶ 14 n.6 for its content
`
`(to show versions of the Symbian operating systems (“OS”) had been released by a
`
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`certain time). PO objected to Ex. 1043 as untimely and lacking authentication when
`
`it was introduced in Dr. Olivier’s deposition. Ex. 1051 at 119:12-15, 126:2-15. PO
`
`also objected to Ex. 1043 as hearsay and untimely in Paper 54, pages 10-11.
`
`1.
`Lack of Authentication and No Timely Cure
`Ex. 1043 is inadmissible as lacking authentication, which was not timely
`
`cured, for the same reasons discussed above for Ex. 1033.
`
`2.
`Untimely Supplemental Information
`Ex. 1043 should be excluded as an untimely submission of supplemental
`
`information.
`
`Rather than identifying Ex. 1043 for what it is, part of a new or updated
`
`obviousness combination, Petitioner instead seeks to disguise Ex. 1043 as showing
`
`purported knowledge of a POSITA. In particular, Petitioner and its expert rely upon
`
`Ex. 1043 to purportedly demonstrate what a POSITA would have understood from
`
`Lahti’s passing mention of SDKs (software developer kits). See Reply at 7 (citing
`
`Ex. 1052 at ¶¶7-20, which includes reference to Ex. 1043). But this is an attempt to
`
`supplement Petitioner’s grounds with features that are nowhere disclosed in Lahti.
`
`It was incumbent upon Petitioner to proffer its evidence and arguments with
`
`particularity—including evidence and arguments relating to the level of skill in the
`
`art and exactly what (and why) Lahti purportedly disclosed to a POSITA—at the
`
`time it filed its Petition. See Intelligent Bio-Systems, 821 F.3d at 1369 (“It is of the
`
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`utmost importance that petitioners in the IPR proceedings adhere to the requirement
`
`that the initial petition identify ‘with particularity’ the ‘evidence that supports the
`
`grounds for the challenge to each claim.’” (citing 35 U.S.C. § 312(a)(3))); see also
`
`id. (“[T[he expedited nature of IPRs bring with it an obligation for petitioners to
`
`make their case in their petition to institute.”).
`
`As a result, Petitioner’s filing of Ex. 1043 with its Reply (along with Exhibits
`
`1044, 1045, 1047, and 1048) amounted to an end-run around the requirements of
`
`Rule 123(b) for late-filed supplemental information. That rule requires a party
`
`seeking to submit supplemental information more than one month after institution
`
`to first request Board authorization to file a motion to submit it. 37 C.F.R. §
`
`42.123(b). Then, if authorized, the party’s motion must show (1) why the
`
`information reasonably could not have been obtained earlier and (2) that
`
`consideration of the supplemental information would be in the interests of justice.
`
`Id. Petitioner requested no such authorization prior to filing these exhibits with its
`
`Reply, and did not make either such showing therein. For these reasons, Ex. 1043
`
`is an untimely submission of supplemental information and should be excluded.
`
`3. Hearsay
`Ex. 1043 includes out-of-court statements offered to prove the truth of the
`
`matter asserted: that certain products were on sale. Reply at 13 (alleging existence
`
`of Symbian OS by 2006) (citing Ex. 1052, ¶ 14). Thus, the statements in Ex. 1043
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`relied upon are inadmissible hearsay. In addition, any date on the face of Ex. 1043
`
`relied upon to establish a date of publication for Ex. 1043 is an out-of-court statement
`
`relied upon for the truth of the matter asserted and is thus inadmissible hearsay.
`
`E.
`Exhibit 1044 – Symbian Phones
`Petitioner identifies Ex. 1044 as a copy of a webpage. Ex. 1052, ¶ 2.
`
`Petitioner relies on Ex. 1044 at Reply page 13 for its content (that Nokia devices ran
`
`on the Symbian OS). PO objected to Ex. 1044 as untimely and lacking
`
`authentication when it was introduced in Dr. Olivier’s deposition. Ex. 1051 at 121:3-
`
`9, 126:2-15. PO also objected to Ex. 1044 as hearsay and untimely in Paper 54,
`
`pages 11-12.
`
`1.
`Lack of Authentication and No Timely Cure
`Ex. 1044 is inadmissible as lacking authentication, which was not timely
`
`cured, for the same reasons discussed above for Ex. 1033.
`
`2.
`Untimely Supplemental Information
`Ex. 1044 is relied upon as part of a new obviousness theory in the same way
`
`as Ex. 1043 and should be excluded as an untimely submission of supplemental
`
`information for the same reasons discussed above for Ex. 1043. See also Reply at
`
`13 (citing Ex. 1044).
`
`3. Hearsay
`Ex. 1044 includes out-of-court statements offered to prove the truth of the
`
`matter asserted: properties of certain phones. Reply at 13 (stating that “Nokia
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`models, as well as other leading devices ran on the Symbian OS”). Therefore, the
`
`statements in Ex. 1044 relied upon are inadmissible hearsay. In addition, any date
`
`on the face of Ex. 1044 relied upon to establish a date of publication for Ex. 1044 is
`
`an out-of-court statement relied upon for the truth of the matter asserted and is
`
`therefore inadmissible hearsay.
`
`F.
`
`Exhibit 1045 – Wire.com—“By Open Sourcing Symbian, Nokia
`Kicks off the Mobile Age”
`Petitioner identifies Ex. 1045 as a copy of a webpage. Ex. 1052, ¶ 2.
`
`Petitioner relies on Ex. 1045 at Ex. 1052, ¶ 7 n.1 for its content (the popularity of
`
`the Symbian OS). PO objected to Ex. 1045 as untimely and lacking authentication
`
`when it was introduced in Dr. Olivier’s deposition. Ex. 1051 at 122:8-14, 126:2-15.
`
`PO also objected to Ex. 1045 as hearsay and untimely in Paper 54, pages 12-13.
`
`1.
`Lack of Authentication and No Timely Cure
`Ex. 1045 is inadmissible as lacking authentication, which was not timely
`
`cured, for the same reasons discussed above for Ex. 1033.
`
`2.
`Untimely Supplemental Information
`Ex. 1045 is relied upon as part of a new obviousness theory in the same way
`
`as Ex. 1043 and should be excluded as an untimely submission of supplemental
`
`information for the same reasons discussed above for Ex. 1043. See also Reply at 7
`
`(citing Ex. 1052 at ¶¶7-20, which includes reference to Ex. 1045).
`
`3. Hearsay
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`Ex. 1045 includes out-of-court statements offered to prove the truth of the
`
`matter asserted: market conditions. Ex. 1052, ¶ 7 (stating that “Symbian had a
`
`dominant share of the smartphone operating system market in the early to mid-
`
`2000’s and maintained a large share through 2010 and 2011”). Therefore, the
`
`statements in Ex. 1045 relied upon are inadmissible hearsay. In addition, any date
`
`on the face of Ex. 1045 relied upon to establish a date of publication for Ex. 1045 is
`
`an out-of-court statement relied upon for the truth of the matter asserted and is
`
`therefore inadmissible hearsay.
`
`G. Exhibit 1047 – Symbian OS SDK v8.1 from Symbian Developer
`Library
`Petitioner identifies Ex. 1047 as a copy of a webpage (Ex. 1052, ¶ 2), and
`
`relies on Ex. 1047 at Ex. 1052, ¶ 14 n.7 for its content (the operation of an API
`
`function). PO objected to Ex. 1047 as untimely and lacking authentication when it
`
`was introduced in Dr. Olivier’s deposition. Ex. 1051 at 126:2-15, 126:18-127:4. PO
`
`also objected to Ex. 1047 as hearsay and untimely in Paper 54, pages 14-15.
`
`1.
`Lack of Authentication and No Timely Cure
`Ex. 1047 is inadmissible as lacking authentication, which was not timely
`
`cured, for the same reasons discussed above for Ex. 1033.
`
`2.
`Untimely Supplemental Information
`Ex. 1047 is relied upon as part of a new obviousness theory in the same way
`
`as Ex. 1043 and should be excluded as an untimely submission of supplemental
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`information for the same reasons discussed above for Ex. 1043. See also Reply at 7
`
`(citing Ex. 1052 at ¶¶7-20, which includes reference to Ex. 1047).
`
`3. Hearsay
`Ex. 1047 includes out-of-court statements offered to prove the truth of the
`
`matter asserted: recording procedures. Ex. 1052, ¶ 14 (“Prior to starting to record
`
`video, the developer must use the PrepareVideoCaptureL() API function7 to specify
`
`both a frame size and a frame rate at which to record.”). Therefore, the statements
`
`in Ex. 1047 relied upon are inadmissible hearsay. Any date on the face of Ex. 1047
`
`relied upon to establish a date of publication for Ex. 1047 is an out-of-court statement
`
`relied upon for the truth of the matter asserted and is therefore inadmissible hearsay.
`
`H. Exhibit 1048 – “CCamera in Multimedia ECam”
`Petitioner identifies Ex. 1048 as a copy of a webpage. Ex. 1052, ¶ 2.
`
`Petitioner relies on Ex. 1048 at Reply at pages 13-14 and Ex. 1052, ¶ 14 n.7 for its
`
`content (the operation of an API function). PO objected to Ex. 1048 as lacking
`
`authentication, hearsay, and untimely in Paper 54, pages 14-15.
`
`1.
`Lack of Authentication
`Ex. 1048 is inadmissible as lacking authentication for the same reasons
`
`discussed above for Ex. 1043.
`
`2.
`Untimely Supplemental Information
`Ex. 1048 is relied upon as part of a new obviousness theory in the same way
`
`as Ex. 1043 and should be excluded as an untimely submission of supplemental
`
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`information for the same reasons discussed above for Ex. 1043. See also Reply at 7
`
`(citing Ex. 1052 at ¶¶7-20, which includes reference to Ex. 1048) and 14 (citing Ex.
`
`1048).
`
`3. Hearsay
`Ex. 1048 includes out-of-court statements offered to prove the truth of the
`
`matter asserted: properties of certain phones. Reply at 13 (“By 2006, the Symbian
`
`OS provided mobile phones with APIs that supported a variety of multimedia
`
`functions, including video capture at varying resolutions and frame rates.”); Ex.
`
`1052, ¶ 14. Therefore, the statements in Ex. 1048 relied upon are inadmissible
`
`hearsay. In addition, any date on the face of Ex. 1048 relied upon to establish a date
`
`of publication for Ex. 1048 is an out-of-court statement relied upon for the truth of
`
`the matter asserted and is therefore inadmissible hearsay.
`
`I.
`
`Exhibit 1049 – Samsung Mobile News—“SAMSUNG Launches the
`World’s First 10 Megapixel Camera Phone”
`Petitioner identifies Ex. 1049 as a copy of a webpage. Ex. 1052, ¶ 2.
`
`Petitioner relies on Ex. 1049 at Reply at page 13 and Ex. 1052, ¶ 15 for its content
`
`(that certain Samsung devices possessed certain functionality). PO objected to Ex.
`
`1049 as lacking authentication, hearsay, and untimely in Paper 54, pages 16-18.
`
`1.
`Lack of Authentication
`Ex. 1049 is inadmissible as lacking authentication for the same reasons
`
`discussed above for Ex. 1033.
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`2.
`Untimely Supplemental Information
`Ex. 1049 is relied upon as part of a new obviousness theory in the same way
`
`as Ex. 1033 and should be excluded as an untimely submission of supplemental
`
`information for the same reasons discussed above for Ex. 1033. See also Reply at 7
`
`(citing Ex. 1052 at ¶¶7-20, which includes reference to Ex. 1049).
`
`3. Hearsay
`Ex. 1049 includes out-of-court statements offered to prove the truth of the
`
`matter asserted: properties of certain phones. Reply at 13 (stating that “the Samsung
`
`SCH-V770 and the Samsung SCH-B600 each could record video at 15-30 fps”); Ex.
`
`1052, ¶ 15. Therefore, the statements in Ex. 1049 relied upon are inadmissible
`
`hearsay. In addition, any date on the face of Ex. 1049 relied upon to establish a date
`
`of publication for Ex. 1049 is an out-of-court statement relied upon for the truth of
`
`the matter asserted and is therefore inadmissible hearsay.
`
`J.
`Exhibit 1050 – “Samsung SCH-B600 10 Megapixel Camera Phone”
`Petitioner identifies Ex. 1050 as a copy of a webpage. Ex. 1052, ¶ 2.
`
`Petitioner relies on Ex. 1050 at Reply at page 13 and Ex. 1052, ¶ 15 for its content
`
`(that certain Samsung devices possessed certain functionality). PO objected to Ex.
`
`1050 as lacking authentication, hearsay, and untimely in Paper 54, pages 18-19.
`
`1.
`Lack of Authentication
`Ex. 1050 is inadmissible as lacking authentication for the same reasons
`
`discussed above for Ex. 1033.
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`2.
`Untimely Supplemental Information
`Ex. 1050 is relied upon as part of a new obviousness theory in the same way
`
`as Ex. 1033 and should be excluded as an untimely submission of supplemental
`
`information for the same reasons discussed above for Ex. 1033. See also Reply at 7
`
`(citing Ex. 1052 at ¶¶7-20, which includes reference to Ex. 1050).
`
`3. Hearsay
`Ex. 1050 includes out-of-court statements offered to prove the truth of the
`
`matter asserted: properties of certain phones. Reply at 13 (stating that “the Samsung
`
`SCH-V770 and the Samsung SCH-B600 each could record video at 15-30 fps”); Ex.
`
`1052, ¶ 15. Therefore, the statements in Ex. 1050 relied upon are inadmissible
`
`hearsay. In addition, any date on the face of Ex. 1050 relied upon to establish a date
`
`of publication for Ex. 1050 is an out-of-court statement relied upon for the truth of
`
`the matter asserted and is therefore inadmissible hearsay.
`
`K. CONCLUSION
`For the foregoing reasons, PO requests that the indicated evidence be
`
`excluded from this proceeding.
`
`Dated: September 14, 2018
`
`Respectfully submitted,
`
`NORTON ROSE FULBRIGHT US LLP
`
`/Eagle H. Robinson/
`Eagle H. Robinson (Reg. No. 61,361)
`Lead Counsel for Patent Owner
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`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on
`
`September 14, 2018, complete copies of VidStream LLC’s Patent Owner Motion to
`
`Exclude was served on the following:
`
`
`
`
`
`
`
`
`
`Lead Counsel:
`
`Todd M. Siegel (Reg. No. 73,232)
`todd.siegel@klarquist.com
`
`Backup Counsel: Andrew M. Mason (Reg. No. 64,034)
`andrew.mason@klarquist.com
`
`Robert T. Cruzen (pro hac vice)
`rob.cruzen@klarquist.com
`
`Respectfully submitted,
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`/Eagle H. Robinson/
`Eagle H. Robinson (Reg. No. 61,361)
`
`73442028.1
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`- 16 -
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`
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