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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`––––––––––
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`––––––––––
`NETFLIX, INC.
`
`Petitioner,
`v.
`REALTIME ADAPTIVE STREAMING, LLC,
`Patent Owner.
`––––––––––
`Case No. IPR2018-01630
`U.S. Patent 9,769,477
`––––––––––
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`PETITIONER’S REQUEST FOR ORAL HEARING
`37 C.F.R. § 42.70
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`SMRH:4840-2296-5662.1
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`IPR2018-01630
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`Pursuant to the Board’s April 19, 2019 Scheduling Order (Paper 14), 37
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`C.F.R. § 42.70(a), and 35 U.S.C. § 316(a)(10), Petitioner respectfully requests oral
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`argument on October 14, 2019.
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`Consolidation of Oral Argument with IPR2018-01187
`This proceeding and IPR2018-01187 both challenge claims of the ’477
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`patent and rely on substantially the same prior art. The claims at issue in this
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`proceeding depend from independent claims 1 and 20 that are at issue in the 1187
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`IPR. In view of the overlap between the proceedings, Petitioner submits that a
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`consolidated oral argument with each side granted 75 minutes of argument time is
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`appropriate. The parties have met and conferred and Patent Owner does not object
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`to consolidated oral argument or the proposed time allocation.
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`Request for Oral Argument
`Petitioner requests (without any intent to waive consideration of any issue
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`not requested) one hour for the Petitioner to address the following issues at the oral
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`hearing:
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`• Ground 1: Claims 15-19, 28, and 29 are obvious in view of Imai (Ex.
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`1005) and Pauls (Ex. 1007);
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`• Ground 2: Claims 7 and 23 are obvious in view of Imai (Ex. 1005),
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`Pauls (Ex. 1007), and Dawson (Ex. 1025); and
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`SMRH:4840-2296-5662.1
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`IPR2018-01630
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`• Ground 3: Claims 8 and 24 are obvious in view of Imai (Ex. 1005)
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`and Pauls (Ex. 1007); and Lai (Ex. 1016).
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`Petitioner requests the ability to reserve a portion of its total time for
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`presenting rebuttal arguments after Patent Owner’s presentation. Petitioner
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`additionally requests that the Board provide audio-visual equipment to display
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`demonstrative exhibits, including a projector to be connected to a laptop, and a
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`document camera for displaying documents of record. In accordance with the Trial
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`Practice Guide, Fed. Reg. Vol. 77, No. 157, at 48768, Petitioner will contact the
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`Board Trial Division paralegal to discuss this request.
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`In the event that the Board sets a consolidated oral argument, Petitioner
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`requests 75 minutes of total time to address the issues identified in this request for
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`oral argument along with the issues identified in the request for oral argument that
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`is being separately filed in IPR2018-01187.
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`This Request is timely, being filed on August 22, 2019.
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`Date: August 22, 2019
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`Respectfully submitted,
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`SHEPPARD, MULLIN, RICHTER &
`HAMPTON LLP
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` /Harper Batts/
`Harper Batts (Reg. No. 56,160)
`Attorney for Petitioner
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`SMRH:4840-2296-5662.1
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`IPR2018-01630
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that on August 22, 2019, a complete copy of
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`Petitioner’s Request for Oral Argument was served via email to all parties to this
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`proceeding at the addresses indicated:
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`Joel P. N. Stonedale (Reg. No. 76,924)
`joel@noroozipc.com
`NOROOZI PC
`2245 Texas Drive, Suite 300
`Sugar Land, TX 77479
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`Kayvan Noroozi (Pro Hac Vice)
`kayvan@noroozipc.com
`James A Milkey (Pro Hac Vice)
`jim@noroozipc.com
`NOROOZI PC
`1299 Ocean Ave., Suite 450
`Santa Monica, CA 90401
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`Date: August 22, 2019
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`Neil A. Rubin (Reg. No. 67,030)
`nrubin@raklaw.com
`Kent Shum (Reg. No. 61,117)
`kshum@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Blvd., 12th Fl. Los
`Angeles, CA 90025
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` /Harper Batts/
`Harper Batts (Reg. No. 56,160)
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`SMRH:4840-2296-5662.1
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