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`UNITED STATES PATENT AND TRADEMARK OFFICE
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`NETFLIX, INC.,
`NETFLIX, INC.,
`PETITIONER,
`PETITIONER,
`
`v.
`Vv.
`
`GOTV STREAMING, LLC,
`GOTV STREAMING,LLC,
`PATENT OWNER.
`PATENT OWNER.
`
`
`
`CASE IPR2023-00757
`CASE IPR2023-00757
`PATENT 8,989,715
`PATENT 8,989,715
`
`
`
`
`
`
`
`DECLARATION OF JOSHUA S. WYDE
`DECLARATION OF JOSHUA S. WYDE
`
`2018
`2018
`
`
`
`
`
`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. Exhibit 2001 is a true and correct copy of excerpts from CAMPBELL-
`
`KELLY ET AL., Mainframes to Smartphones: A History of the International
`
`Computer Industry (Harvard Univ. Press 2015) purchased through Amazon.
`
`¶4. Exhibit 2002 is a true and correct copy of GALAZZO, Timeline from
`
`1G to 5G: A Brief History on Cell Phones (Sept. 21, 2020), available at
`
`https://www.cengn.ca/information-centre/innovation/timeline-from-1g-to-
`
`5g-a-brief-history-on-cell-phones/.
`
`¶5. Exhibit 2003 is a true and correct copy of Cingular MEdia Mall
`
`Games and Motorola Page (March 23, 2006) captured by the Wayback
`
`Machine
`
`of
`
`the
`
`Internet
`
`Archive,
`
`available
`
`at
`
`https://web.archive.org/web/20060323054853/http://www-
`
`xl.cingularextras.com/fuel/enduser/portal/endUserHTMLDir?c1=3&dc=0
`
`
`
`–1–
`
`
`
`
`
`and
`
`https://web.archive.org/web/20060323054841/http://www-
`
`xl.cingularextras.com/fuel/enduser/portal/endUserHTMLSelectPhone?ma
`
`keName=motorola&dc=0, with an affidavit from the Records Request
`
`Processor of the Internet Archive regarding the same.
`
`¶6. Exhibit 2004 is a true and correct copy of the primary page of Suite,
`
`Definition & Meaning
`
`- Merriam-Webster,
`
`available
`
`at
`
`https://www.merriam-webster.com/dictionary/suite.
`
`¶7. Exhibit 2005 is a true and correct copy of U.S. Patent No. 7,380,205
`
`to Bezrukov et al. (filed Oct. 28, 2003) as retrieved from Google Patents.
`
`¶8. Exhibit 2006 is a true and correct copy of TUTENEL ET AL., Rule-
`
`Based Layout Solving and Its Application
`
`to Procedural Interior
`
`Generation, Netherlands Organization for Scientific Research and the
`
`Netherlands ICT Research and Innovation Authority (2009), as downloaded
`
`from Research Gate.
`
`¶9. Exhibit 2007 is a true and correct copy of excerpts from KRÖNER,
`
`Adaptive Layout of Dynamic Web Pages, Deutsches Forschungszentrum fur
`
`Künstliche Intelligenz GmH (2000) as retrieved from Google Books.
`
`¶10. Exhibit 2008 is a true and correct copy of Scheduling Order, GoTV
`
`Streaming, LLC v. Netflix, Inc., 2:22-cv-07556 (C.D. Cal. issued Feb 14,
`
`
`
`–2–
`
`
`
`
`
`2023) (Doc. 62) as taken from the Public Access to Court Electronic
`
`Records (“PACER”) system.
`
`¶11. Exhibit 2009 is a true and correct copy of Klausner Decisions re
`
`Motions to Stay Pending IPR as generated June 8, 2023 using Docket
`
`Navigator.
`
`¶12. Exhibit 2010 is a true and correct copy of Order Granting Stipulated
`
`Stay Pending IPR, Flexstent, LLC v. Abbott Labs., No. 5-18-cv-02479 (C.D.
`
`Cal. Oct. 18, 2019) (Doc.77) retrieved from PACER.
`
`¶13. Exhibit 2011 is a true and correct copy of Order Denying Renewed
`
`Stipulated Stay Pending IPR, Shenzhen Gooloo E-Commerce Co., Ltd. v.
`
`Pilot, Inc., No. 2-22-cv-02219 (C.D. Cal. Jan. 12, 2023) (Doc. 95) retrieved
`
`from PACER.
`
`¶14. Exhibit 2012 is a true and correct copy of Renewed Joint Stipulation
`
`to Stay Case Pending Resolution of Inter Partes Reviews of ’653 Patent,
`
`Shenzhen Gooloo E-Commerce Co., Ltd. v. Pilot, Inc., No. 2-22-cv-02219
`
`(C.D. Cal. Jan. 11, 2023) (Doc. 94) retrieved from PACER.
`
`¶15. Exhibit 2013 is a true and correct copy of Klausner Time to Trial in
`
`Patent Cases, generated June 8, 2023 by Docket Navigator.
`
`
`
`–3–
`
`
`
`
`
`¶16. Exhibit 2014 is a true and correct copy of U.S. District Court—
`
`Judicial Caseload Profile for Central California from Federal Court
`
`Management Statistics–Profiles
`
`(Mar. 31, 2023)
`
`retrieved
`
`from
`
`https://www.uscourts.gov.
`
`¶17. Exhibit 2015 is a true and correct copy of Order Denying Netflix’s
`
`Motions, including for Invalidity under § 101, GoTV Streaming, LLC v.
`
`Netflix, Inc., 2:22-cv-07556 (C.D. Cal. issued May 24, 2023) (Doc. 109)
`
`retrieved from PACER.
`
`¶18. Exhibit 2016 is a true and correct copy of Order re Scheduling
`
`Conference, GoTV Streaming, LLC v. Netflix, Inc., 2:22-cv-07556 (C.D.
`
`Cal. issued Feb. 13, 2023) (Doc. 61) retrieved from PACER.
`
`¶19. Exhibit 2017 is a true and correct copy of Excerpts from Redacted
`
`and De-designated Corrected Declaration of Dr. John Villasenor Regarding
`
`Invalidity of U.S. Patent Nos. 8,989,715; 8,478,245; and 8,103,865, GoTV
`
`Streaming, LLC v. Netflix, Inc., 2:22-cv-07556 (C.D. Cal. served June 23,
`
`2023) served in the district court lawsuit.
`
`¶20. 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.
`
`
`
`–4–
`
`
`
`
`
`¶21. Per 28 U.S.C § 1746, I declare under penalty of perjury that the
`
`foregoing is true and correct.
`
`Executed in Houston, Texas on August 10, 2023.
`
`
`
`
`
`
`
`
`
`
`
`Joshua S. Wyde
`
`
`
`–5–
`
`
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