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`UNITED STATES PATENT AND TRADEMARK OFFICE
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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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`REALTIME ADAPTIVE STREAMING LLC,
`Patent Owner.
`____________________
`
`Case IPR2018-01630
`Patent No. 9,769,477
`____________________
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`DECLARATION OF KAYVAN B. NOROOZI IN SUPPORT OF
`MOTION FOR ADMISSION PRO HAC VICE
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`IPR2018-01630
`DECLARATION OF KAYVAN B. NOROOZI
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`I, Kayvan B. Noroozi, declare the following:
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`1.
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`I am an attorney at Noroozi PC. I have been practicing law
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`since November 2010 and have been practicing in the field of patent
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`litigation since November 2012. In that time, I have been counsel of record
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`in numerous patent litigation matters involving a variety of technologies,
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`including cellular telecommunications, graphical user interfaces, mobile
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`location, computer manufacturing and assembly, computer search and
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`indexing, semiconductor Systems-on-a-Chip, and Power over Ethernet.
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`2.
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`I am member in good standing of the State Bar of California,
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`and am admitted to practice before the Eastern District of Texas and
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`Northern District of California.
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`3. My California State Bar Membership number is 271167.
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`4.
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`I have never been suspended, disbarred, sanctioned, or cited for
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`contempt by any court or administrative body.
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`5.
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`I have never had a court or administrative body deny my
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`application for admission to practice.
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`6.
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`I have appeared before the Patent Trial and Appeal Board in
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`more than fifty inter partes review and covered business method
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`proceedings involving a variety of technologies, including data compression
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`1
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`IPR2018-01630
`DECLARATION OF KAYVAN B. NOROOZI
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`(both lossless and lossy, including video and audio), operating system
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`booting, USB devices, and wireless communications.
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`7.
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`In particular, I have previously applied for admission pro hac
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`vice before the U.S. Patent and Trademark Office in the proceedings listed
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`below. My request for pro hac vice admission has never been opposed. It has
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`also never been denied.
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`Proceeding
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`Status
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`IPR2016-00783
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`IPR2016-00972
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`IPR2016-00978
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`IPR2016-00980
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`IPR2016-01002
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`IPR2016-01370
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`IPR2016-01737
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`IPR2016-01738
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`Granted
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`Granted
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`Granted
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`Granted
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`Granted
`
`Granted
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`Granted
`
`Granted
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`IPR2017-00108
`
`Pending when IPR terminated
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`IPR2017-00167
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`IPR2017-00168
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`IPR2017-00176
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`IPR2017-00179
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`IPR2017-00557
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`IPR2017-00806
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`Granted
`
`Granted
`
`Granted
`
`Granted
`
`Granted
`
`Granted
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`
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`2
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`IPR2018-01630
`DECLARATION OF KAYVAN B. NOROOZI
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`IPR2017-00808
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`Granted
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`IPR2017-01195
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`Pending when IPR terminated
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`IPR2017-01196
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`Granted
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`IPR2017-01354
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`Pending when IPR terminated
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`IPR2017-01627
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`Pending when IPR terminated
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`IPR2017-01629
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`Pending when IPR terminated
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`IPR2017-01660
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`IPR2017-01663
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`IPR2017-01664
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`Granted
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`Granted
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`Granted
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`IPR2017-01688
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`Pending when IPR terminated
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`IPR2017-01690
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`Granted
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`IPR2017-01691
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`Pending when IPR terminated
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`IPR2017-01710
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`Granted
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`CBM2017-00061 Pending when CBM terminated
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`IPR2017-02006
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`Pending when IPR terminated
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`IPR2017-02007
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`Pending when IPR terminated
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`IPR2017-02129
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`Pending when IPR terminated
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`IPR2017-02178
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`IPR2018-00612
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`IPR2018-00613
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`IPR2018-00614
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`IPR2018-00656
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`IPR2018-00701
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`Granted
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`Granted
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`Pending
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`Granted
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`Granted
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`Granted
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`3
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`IPR2018-01630
`DECLARATION OF KAYVAN B. NOROOZI
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`IPR2018-00703
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`Pending when IPR terminated
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`IPR2018-00706
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`IPR2018-00725
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`IPR2018-00726
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`IPR2018-00325
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`IPR2018-00326
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`IPR2018-00762
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`IPR2018-00763
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`IPR2018-00764
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`IPR2018-00883
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`IPR2018-01016
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`IPR2018-01017
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`IPR2018-01018
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`IPR2018-01538
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`IPR2018-01189
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`IPR2018-01187
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`IPR2018-01630
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`Granted
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`Granted
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`Pending
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`Granted
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`Granted
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`Granted
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`Pending
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`Granted
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`Granted
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`Granted
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`Granted
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`Granted
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`Pending
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`Granted
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`Granted
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`Pending
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`8.
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`I have previously represented Realtime Data LLC, the sole
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`owner of Realtime Adaptive Streaming LLC, in at least thirty nine inter
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`partes review proceedings. Through those engagements, I have become
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`extensively familiar with the company’s patent portfolio, as well as the prior
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`art. I have also represented Realtime Adaptive Streaming in IPR2018-00883.
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`IPR2018-01630
`DECLARATION OF KAYVAN B. NOROOZI
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`9.
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`I am also familiar with the subject matter of this proceeding,
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`including the patent at issue, the prior art of record, the Petition, and
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`Petitioner’s supporting submissions. I have extensively reviewed and
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`analyzed those materials, advised Realtime Adaptive Streaming as to their
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`merits, and taken part in preparing Patent Owner’s Preliminary Response in
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`this proceeding.
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`10. Realtime Adaptive Streaming LLC has selected me to serve as
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`its counsel in this proceeding, and this motion for pro hac vice is presented
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`on that basis.
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`11.
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`I have read and will comply with the Office Patent Trial
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`Practice Guide and the Board’s Rules of Practice for Trials set forth in part
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`42 of title 37 of the Code of Federal Regulations.
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`12.
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`I understand that I will be subject to the USPTO Rules of
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`Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and
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`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`13.
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`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
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`be true, and that these statements were made with knowledge that willful
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`false statements and the like are made punishable by fine or imprisonment,
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`or both, under Section 1001 of Title 18 of the United States Code.
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`5
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`IPR2018-01630
`DECLARATION OF KAYVAN B. NOROOZI
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`Dated: January 16, 2019
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`
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`By: /Kayvan Noroozi/_________
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