`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`HULU, LLC,
`AMAZON.COM, INC., and
`NETFLIX, INC.,
`Petitioners,
`
`v.
`
`REALTIME ADAPTIVE STREAMING LLC,
`Patent Owner.
`____________________
`
`Case IPR2018-01187
`Patent No. 9,769,477
`____________________
`
`
`DECLARATION OF KAYVAN B. NOROOZI IN SUPPORT OF
`MOTION FOR ADMISSION PRO HAC VICE
`
`
`
`
`
`
`
`
`
`
`IPR2018-01187
`DECLARATION OF KAYVAN B. NOROOZI
`I, Kayvan B. Noroozi, declare the following:
`1.
`I am an attorney at Noroozi PC. I have been practicing law
`
`since November 2010 and have been practicing in the field of patent
`
`litigation since November 2012. In that time, I have been counsel of record
`
`in numerous patent litigation matters involving a variety of technologies,
`
`including cellular telecommunications, graphical user interfaces, mobile
`
`location, computer manufacturing and assembly, computer search and
`
`indexing, semiconductor Systems-on-a-Chip, and Power over Ethernet.
`
`2.
`
`I am member in good standing of the State Bar of California,
`
`and am admitted to practice before the Eastern District of Texas and
`
`Northern District of California.
`
`3. My California State Bar Membership number is 271167.
`
`4.
`
`I have never been suspended, disbarred, sanctioned, or cited for
`
`contempt by any court or administrative body.
`
`5.
`
`I have never had a court or administrative body deny my
`
`application for admission to practice.
`
`6.
`
`I have appeared before the Patent Trial and Appeal Board in
`
`more than fifty inter partes review and covered business method
`
`proceedings involving a variety of technologies, including data compression
`
`
`
`1
`
`
`
`IPR2018-01187
`DECLARATION OF KAYVAN B. NOROOZI
`(both lossless and lossy, including video and audio), operating system
`
`booting, USB devices, and wireless communications.
`
`7.
`
`In particular, I have previously applied for admission pro hac
`
`vice before the U.S. Patent and Trademark Office in the proceedings listed
`
`below. My request for pro hac vice admission has never been opposed. It has
`
`also never been denied.
`
`
`
`
`
`Proceeding
`
`Status
`
`IPR2016-00783
`IPR2016-00972
`IPR2016-00978
`IPR2016-00980
`IPR2016-01002
`IPR2016-01370
`IPR2016-01737
`IPR2016-01738
`IPR2017-00108
`IPR2017-00167
`IPR2017-00168
`IPR2017-00176
`IPR2017-00179
`IPR2017-00557
`
`Granted
`Granted
`Granted
`Granted
`Granted
`Granted
`Granted
`Granted
`Pending when IPR terminated
`Granted
`Granted
`Granted
`Granted
`Granted
`
`2
`
`
`
`IPR2018-01187
`DECLARATION OF KAYVAN B. NOROOZI
`
`Granted
`IPR2017-00806
`Granted
`IPR2017-00808
`Pending when IPR terminated
`IPR2017-01195
`Granted
`IPR2017-01196
`Pending when IPR terminated
`IPR2017-01354
`Pending when IPR terminated
`IPR2017-01627
`Pending when IPR terminated
`IPR2017-01629
`Granted
`IPR2017-01660
`Granted
`IPR2017-01663
`Granted
`IPR2017-01664
`Pending when IPR terminated
`IPR2017-01688
`Granted
`IPR2017-01690
`Pending when IPR terminated
`IPR2017-01691
`Granted
`IPR2017-01710
`CBM2017-00061 Pending when CBM terminated
`IPR2017-02006
`Pending when IPR terminated
`IPR2017-02007
`Pending when IPR terminated
`IPR2017-02129
`Pending when IPR terminated
`IPR2017-02178
`Granted
`IPR2018-00612
`Granted
`IPR2018-00613
`Pending
`IPR2018-00614
`Granted
`IPR2018-00656
`Granted
`
`3
`
`
`
`
`
`IPR2018-01187
`DECLARATION OF KAYVAN B. NOROOZI
`
`IPR2018-00701
`IPR2018-00703
`IPR2018-00706
`IPR2018-00725
`IPR2018-00726
`IPR2018-00325
`IPR2018-00326
`IPR2018-00762
`IPR2018-00763
`IPR2018-00764
`IPR2018-00883
`IPR2018-01016
`IPR2018-01017
`IPR2018-01018
`IPR2018-01538
`IPR2018-01189
`IPR2018-01187
`
`Granted
`Pending
`Granted
`Granted
`Pending
`Granted
`Granted
`Granted
`Pending
`Granted
`Pending
`Granted
`Granted
`Granted
`Pending
`Pending
`Pending
`
`
`
`
`8.
`
`I have previously represented Realtime Data LLC, the sole
`
`owner of Realtime Adaptive Streaming LLC, in at least thirty nine inter
`
`partes review proceedings. Through those engagements, I have become
`
`extensively familiar with the company’s patent portfolio, as well as the prior
`
`art. I have also represented Realtime Adaptive Streaming in IPR2018-00883.
`
`
`
`4
`
`
`
`IPR2018-01187
`DECLARATION OF KAYVAN B. NOROOZI
`I am also familiar with the subject matter of this proceeding,
`
`9.
`
`including the patent at issue, the prior art of record, the Petition, and
`
`Petitioner’s supporting submissions. I have extensively reviewed and
`
`analyzed those materials, advised Realtime Adaptive Streaming as to their
`
`merits, and taken part in preparing Patent Owner’s Preliminary Response in
`
`this proceeding.
`
`10. Realtime Adaptive Streaming LLC has selected me to serve as
`
`its counsel in this proceeding, and this motion for pro hac vice is presented
`
`on that basis.
`
`11.
`
`I have read and will comply with the Office Patent Trial
`
`Practice Guide and the Board’s Rules of Practice for Trials set forth in part
`
`42 of title 37 of the Code of Federal Regulations.
`
`12.
`
`I understand that I will be subject to the USPTO Rules of
`
`Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and
`
`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`13.
`
`I declare that all statements made herein of my knowledge are
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`true and that all statements made on information and belief are believed to
`
`be true, and that these statements were made with knowledge that willful
`
`false statements and the like are made punishable by fine or imprisonment,
`
`or both, under Section 1001 of Title 18 of the United States Code.
`
`
`
`5
`
`
`
`IPR2018-01187
`DECLARATION OF KAYVAN B. NOROOZI
`
`
`
`Dated: October 31, 2018
`
`
`
`By: /Kayvan Noroozi/_________
`
`
`
`6
`
`
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