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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
`Patent 8,989,715
`_______________
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`PETITIONER’S UNOPPOSED MOTION FOR ADMISSION PRO HAC
`VICE OF STEPHEN A. MARSHALL
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`IPR2023-00757
`Patent 8,989,715
`I. RELIEF REQUESTED
`Pursuant to 37 C.F.R. § 42.10, Patent Owner Netflix, Inc., (“Netflix”)
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`requests that the Board admit Stephen A. Marshall pro hac vice in this proceeding.
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`II. STATEMENT OF FACTS SHOWING GOOD CAUSE FOR THE
`BOARD TO RECOGNIZE COUNSEL PRO HAC VICE DURING
`THE PROCEEDING
`In accordance with 37 C.F.R. § 42.10(c), the Board may recognize counsel
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`pro hac vice during a proceeding upon a showing of good cause, subject to the
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`condition that lead counsel be a registered practitioner and to any other conditions
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`as the Board may impose. “[W]here lead counsel is a registered practitioner, a
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`motion to appear pro hac vice may be granted upon a showing that counsel is an
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`experienced litigation attorney and has an established familiarity with the subject
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`matter at issue in the proceeding.” § 42.10(c). The facts, supported by the attached
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`Declaration of Stephen A. Marshall in Support of Motion for Admission Pro Hac
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`Vice (Paper 16), here establish good cause for the Board to recognize Stephen A.
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`Marshall pro hac vice during this proceeding.
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`1. Lead counsel, Aliza George Carrano, is a registered practitioner.
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`2. Counsel, Stephen A. Marshall, is a Partner in the Intellectual Property Group
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`at Willkie, Farr & Gallagher, LLP, and has been in the private practice of patent
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`litigation for more than 17 years. Exhibit 1024, ¶ 8. He has an established
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`familiarity with the legal issues involved in these proceedings based on his years of
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`experience litigating patents. Id.
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`2
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`IPR2023-00757
`Patent 8,989,715
`3. Mr. Marshall is a member in good standing of the Bars of the
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`Commonwealth of Massachusetts and the District of Columbia, and is admitted to
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`the United States District Court for the Eastern District of Texas, United States
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`District Court for the Western District of Texas, United States District Court for
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`the Eastern District of Wisconsin, United States District Court for the District of
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`Massachusetts, United States Court of Appeals for the First Circuit, United States
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`Court of Appeals for the Federal Circuit, and United States Court of Federal
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`Claims. Id. at ¶ 1.
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`4. Mr. Marshall is concurrently applying to appear pro hac vice before the
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`Office in IPR2023-00758 and IPR2023-00759, and in unrelated proceedings
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`IPR2023-00628, IPR2023-00630, and IPR2023-00891. Id. at ¶ 7. He has not
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`applied to appear pro hac vice in any other proceedings before the Office in the last
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`three (3) years. Id.
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`5. Mr. Marshall is familiar with the subject matter and Petition at issue in this
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`proceeding, including the patent, its prosecution history, and the identified
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`references. Id. at ¶ 9. He represents Netflix, Inc. in the following case, which is
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`related to and involves the same patent at issue in this proceeding: GoTV
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`Streaming LLC v. Netflix, Inc., No. 2:22-cv-07556-RGK (C.D. Cal.) (filed October
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`17, 2022). Id.
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`3
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`IPR2023-00757
`Patent 8,989,715
`6. Mr. Marshall has not been suspended or disbarred from practice before any
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`court or administrative body. Id. at ¶ 2. He has never had an application for
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`admission to practice before any court or administrative body denied. Id. at ¶ 3.
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`No sanction or contempt citation has been imposed against me by any court or
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`administrative body. Id. at ¶ 4. He has read and will comply with the Office
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`Patent Trial Practice Guide and the Board’s Rules of Practice for Trials, as set forth
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`in Part 42 of 37 C.F.R. Id. at ¶ 5. He agrees to be subject to the United States
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`Patent and Trademark Office Rules of Professional Conduct set forth in 37 C.F.R.
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`§§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a). Id. at ¶
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`6.
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`III. CONCLUSION
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`For the foregoing reasons, Netflix respectfully requests that the Board admit
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`Stephen A. Marshall pro hac vice in this proceeding.
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`Dated: December 19, 2023
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`Respectfully submitted,
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` /s/ Aliza George Carrano
`Aliza George Carrano (Reg. No. 70,637)
`Indranil Mukerji (Reg. No. 46,944)
`J. Christopher Moulder (Reg. No. 70,490)
`WILLKIE FARR & GALLAGHER
`1875 K Street, N.W.
`Washington, DC 20006-1238
`Counsel for Petitioner
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`4
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`IPR2023-00757
`Patent 8,989,715
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6 the undersigned certifies that on December 19,
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`2023 a copy of the foregoing document was served by email upon the following:
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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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` /s/ Aliza George Carrano
`Aliza George Carrano
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`5
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