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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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`GoTV Streaming, LLC,
`Patent Owner
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`Case: IPR2023-00757
`U.S. Patent No. 8,989,715
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`Filing Date: June 25, 2024
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`IPR2023-00757
`Patent No. 8,989,715
`Pursuant to 37 C.F.R. § 42.70, 35 U.S.C. § 316(a)(10), and the Board’s
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`Scheduling Order dated November 7, 2023 (Paper 12), Petitioner Netflix, Inc.
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`(“Petitioner” or “Netflix”) respectfully requests Oral Argument on issues related to
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`the patentability of Claims 1-20 of U.S. Patent No. 8,989,715 (“the ’715 patent”).
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`Request for Oral Argument
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`Petitioner wishes, without waiving consideration of any issue not specifically
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`requested, to present oral argument on the following issues:
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` Whether the challenged claims of the ’715 patent are unpatentable based on
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`the grounds raised in the Petition (Paper 2);
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` Any issues related to Patent Owner’s Preliminary Response (Paper 8), Patent
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`Owner’s Response (Paper 21), Patent Owner’s Sur-Reply (Paper 27), or the
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`Institution Decision (Paper 11);
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` Any other issues raised in the briefing pursuant to the schedule;
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` Procedural, evidentiary, or other issues raised by the parties or the Board; and
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` Any other outstanding motions and pleadings, and other issues that the Board
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`deems necessary to issue a Final Written Decision.
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`Per the Scheduling Order (Paper 12), oral argument is scheduled for August
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`6, 2024. To the extent convenient for the Board, Petitioner requests that Oral
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`Argument be held in person.
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`Petitioner proposes that the oral argument for this proceeding be consolidated
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`IPR2023-00757
`Patent No. 8,989,715
`with oral argument for IPR2023-00758, in which the patentability of Claims 1-33 of
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`U.S. Patent No. 8,478,245 are at issue, and IPR2023-00759, in which the
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`patentability of Claims 1-20, 31, and 34 of U.S. Patent No. 8,103,865 are at issue.
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`The parties’ papers in the three proceedings reveal that many disputes are common
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`to them. The same panel presides over two proceedings, and oral argument in the
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`two proceedings is scheduled for August 6, 2024. Thus, consolidation would
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`promote efficient administration of the Office. Petitioner proposes that 90 minutes
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`should be allotted to each side for the combined argument, i.e., the argument for
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`IPR2023-00757, IPR2023-00758, and IPR2023-00759. Specifically, Petitioner
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`proposes that 45 minutes per side be allotted to argument regarding IPR2023-00757
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`and IPR2023-00758, and 45 minutes per side be allotted to argument regarding
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`IPR2023-00759. Should the Board approve the combined argument, Patent Owner
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`joins in requesting the proposed time limits and allocation set forth above. Petitioner
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`requests the ability to reserve a portion of its total time for presenting rebuttal
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`arguments after Patent Owner’s presentation.
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`Petitioner also requests permission to use audio and visual equipment to
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`display demonstratives and exhibits of record. In accordance with the Trial Practice
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`Guide, Fed. Reg. Vol. 77, No. 157, at 48768, Petitioner will contact the Board Trial
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`Division paralegal to discuss this request.
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`This request is timely, being filed on June 25, 2024.
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`IPR2023-00757
`Patent No. 8,989,715
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`Dated: June 25, 2024
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`Respectfully submitted,
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`Aliza George Carrano
`Lead Counsel for Petitioner
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`IPR2023-00757
`Patent No. 8,989,715
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`CERTIFICATE OF SERVICE
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`I certify that on June 25, 2024, I caused a true and correct copy of the
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`foregoing Petitioner’s Request for Oral Argument to be served on the Patent Owner
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`via electronic mail to Patent Owner’s counsel of record below:
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`Joshua S. Wyde
`jwyde@aatriallaw.com
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`Steven T. Jugle
`sjugle@aatriallaw.com
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`IPR2023-00757@aatriallaw.com
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`Aliza George Carrano
`Lead Counsel for Petitioner
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