`Roku, Inc. v. Canon Kabushiki Kaisha
`IPR2020-00343
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`Page 1 of 4
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`Case 2:18-cv-00546-JRG Document 120 Filed 04/02/20 Page 2 of 4 PagelD #: 7156
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`the Court at the Markmanhearing that Defendants confirmedin its March 19, 2020 discovery
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`Canonseeks leave to (i) inform the Court that Roku isPo
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`2, vive tt relation,i
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`explain why Roku’s arguments before the Patent Trial and Appeals Board in inter partes review
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`proceedingson the patents in suit contradict Defendants’ claim construction arguments and are
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`directly relevant to this Court’s interpretation of the patent clams. As Canon did not have the
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`opportunity to fully brief or argue these issues previously (as Defendants had not disclosed the
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`extent of Roku’s true role in this action until after the Markman hearing), it respectfully requests
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`that the Court grant its request for leave to file the concurrently filed Supplemental Brief with
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`supporting evidence. Should the Court grant Canonleaveto file the Supplemental Brief, the
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`parties agree and Canon requests the Court also grant: (1) Defendants leaveto file a 9 page
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`response within 7 days of Canon filing the supplementalbrief, (2) Canonleaveto file a 2 page
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`reply within 3 days of Defendants filing a response, and (3) Defendants leaveto file a 2 page sur-
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`reply within 3 days of Canonfiling a reply, if any.
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`Page 2 of 4
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`Case 2:18-cv-00546-JRG Document 120 Filed 04/02/20 Page 3 of 4 PagelD #: 7157
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`DATED: March 30, 2020
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`Respectfully submitted,
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`PAUL HASTINGS LLP
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`By: /s/ Yar R. Chaikovsky
`Yar R. Chaikovsky
`yarchaikovsky@paulhastings.com
`Hiroyuki Hagiwara
`hiroyukihagiwara@paulhastings.com
`Jeffrey A. Pade
`jeffpade@paulhastings.com
`David Okano
`davidokano@paulhastings.com
`Bruce S. Yen
`bruceyen@paulhastings.com
`Kyotaro Ozawa
`kyotaroozawa@paulhastings.com
`1117 S. California Avenue
`Palo Alto, California 94304-1106
`Telephone: (650) 320-1800
`Facsimile:
`(650) 320-1900
`
`Harry L. Gillam, Jr.
`TX Bar No. 07921800
`
`GILLAM & SMITH LLP
`303 S. Washington Ave.
`Marshall, Texas 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`gil@gillamsmithlaw.com
`
`Attorneys for Plaintiff
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`Page 3 of 4
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`Case 2:18-cv-00546-JRG Document 120 Filed 04/02/20 Page 4 of 4 PagelD #: 7158
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that all counsel of record who have consented to electronic
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`service are being notified of the filing of this document via the Court’s CM/ECF system per
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`Local Rule CV-S(a). I also hereby certify that all counsel of record are being served with a copy
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`of the foregoing document by electronic mail on this 30th day of March 2020.
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`
`/s/ Harry L. Gillam, Jr.
`Harry L. Gillam, Jr.
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`Page 4 of 4
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`Page 4 of 4
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