`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SECOND DECLARATION OF JOSHUA S. WYDE
`
`GOTV STREAMING, LLC,
`PATENT OWNER.
`
`
`
`
`
`
`
`
`
`NETFLIX, INC.,
`PETITIONER,
`
`v.
`
`CASE IPR2023-00757
`PATENT 8,989,715
`
`
`
`
`
`
`
`2032
`
`
`
`
`
`I, Joshua S. Wyde, declare:
`
`¶1.
`
`I am over the age of eighteen, I am of sound mind, and I am fully
`
`competent to testify. This declaration is based upon my personal
`
`knowledge, or, if so stated, upon information and belief.
`
`¶2.
`
`I am an attorney at the law firm of Alavi Anaipakos, PLLC, and I am
`
`one of the attorneys representing the Patent Owner, GoTV Streaming, LLC,
`
`in the above captioned IPR.
`
`¶3. The statements below are subject to the following caveat: any
`
`highlighting in the exhibits was added to help the Panel locate cited
`
`sections.
`
`¶4. Exhibit 2023 is a true and correct copy of a printout of Generate, Free
`
`On-Line Dictionary of Computing, available at https://foldoc.org/generate
`
`(last updated June 15, 1995).
`
`¶5. Exhibit 2024 is a true and correct copy of a printout of Output,
`
`TechTerms.com;
`
`The
`
`Computer
`
`Dictionary,
`
`available
`
`at
`
`https://techterms.com/definition/output (last updated December 12, 2006)
`
`
`
`–1–
`
`
`
`
`
`¶6. Exhibit 2025 is a true and correct copy of a printout of From,
`
`Merriam-Webster.com Dictionary, available at https://www.merriam-
`
`webster.com/dictionary/from (last visited December 12, 2023).
`
`¶7. Exhibit 2026 is a true and correct copy a printout of the first page of
`
`Customized, Merriam-Webster.com
`
`Dictionary,
`
`available
`
`at
`
`https://www.merriam-webster.com/dictionary/customized (last visited Jan.
`
`05, 2024).
`
`¶8. Exhibit 2027 is a true and correct copy of a printout of Application-
`
`Specific,
`
`Wiktionary,
`
`available
`
`at
`
`https://en.wiktionary.org/wiki/application-specific (last visited Dec. 15,
`
`2023).
`
`¶9. Exhibit 2028 is a true and correct copy of an excerpt from a 10-K
`
`statement filed by Netflix with the Securities and Exchange Commission
`
`(Jan. 26, 2023).
`
`¶10. Exhibit 2029 is a true and correct copy of an excerpt from Netflix
`
`Women In Tech Event - UI Engineering - August 2018, Jessica Berglund,
`
`Netflix
`
`UI
`
`engineer,
`
`22:43–23:02,
`
`available
`
`at
`
`https://www.youtube.com/watch?v=YpIGejJiaBo
`
`
`
`–2–
`
`
`
`
`
`¶11. Exhibit 2030 is a true and correct copy of Ethan Kao Deposition
`
`Designations Video, GoTV Streaming, LLC v. Netflix, Inc., No. 2:22-cv-
`
`07556 (C.D. Cal. Oct. 19, 2023) (Dkt. 413-13).
`
`¶12. Exhibit 2031 is a true and correct copy of the deposition of Dr.
`
`Benjamin Bederson (Jan. 10, 2024).
`
`¶13. These statements are made with the knowledge that willful false
`
`statements are punishable by fine or imprisonment, or both, under
`
`Section 1001 of Title 18 of the United States Code.
`
`¶14. Per 28 U.S.C § 1746, I declare under penalty of perjury that the
`
`foregoing is true and correct.
`
`Executed in Houston, Texas on January 26, 2024.
`
`
`
`
`
`
`
`
`
`Joshua S. Wyde
`
`
`
`–3–
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
