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UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`Paper 13
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`NETFLIX, INC.,
`
`Petitioner,
`
`v.
`
`CONVERGENT MEDIA SOLUTIONS, LLC,
`
`Patent Owner.
`
`________________
`
`
`
`INTER PARTES REVIEW OF U.S. PATENT NO. 8,640,183 B2
`Case IPR No.: IPR2016-01812
`________________
`
`
`
`JOINT MOTION OF PETITIONER AND PATENT OWNER TO FILE
`SETTLEMENT AGREEMENT AS BUSINESS CONFIDENTIAL INFORMATION
`PURSUANT TO 35 U.S.C. §317 AND 37 C.F.R. §42.74
`
`
`
`
`
`
`

`

`Case IPR2016-01812
`U.S. Patent No. 8,640,183 B2
`
`
`
`STATEMENT OF PRECISE RELIEF REQUESTED
`
`Pursuant to 35 U.S.C. § 317(b), 37 C.F.R. § 42.74(c), and the Board’s
`
`authorization provided on April 28, 2017, Petitioner Netflix, Inc. and Patent Owner
`
`Convergent Media Solutions, LLC (collectively the “Parties”) jointly request to file
`
`the Settlement Agreement between the Parties, as referenced in the Joint Motion to
`
`Terminate Proceeding, as Business Confidential Information, which shall be kept
`
`separate from the file of the involved patent. The Parties also certify that there are
`
`no collateral agreements or understandings made in connection with, or in
`
`contemplation of,
`
`the
`
`termination of
`
`the
`
`Inter Partes
`
`review. See
`
`35 U.S.C. §317(b); 37 C.F.R. § 42.74(b).
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully Submitted,
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Matthew C. Juren
`Matthew C. Juren
`
`Registration No. 68,233
`NELSON BUMGARDNER, P.C.
`3131 W. 7th Street, Suite 300
`Fort Worth, Texas 76107
`Telephone: (817) 377-9111
`Facsimile: (817) 377-3485
`matthew@nelbum.com
`Counsel for Patent Owner
`
`/s/ Chun M. Ng
`Chun M. Ng
`USPTO Reg. No. 36,878
`Perkins Coie LLP
`
`- 2 -
`
`Dated: May 1, 2017
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`1201 Third Avenue, Suite 4900
`Seattle, WA 98101-3099
`Phone: 206-359-6488
`Fax: 206-359-7488
`CNg@perkinscoie.com
`Counsel for Petitioner
`
`
`
`Case IPR2016-01812
`U.S. Patent No. 8,640,183 B2
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on May 1, 2017, a copy of the JOINT MOTION OF
`
`PETITIONER AND PATENT OWNER TO FILE SETTLEMENT AGREEMENT AS
`BUSINESS CONFIDENTIAL INFORMATION PURSUANT TO 35 U.S.C. §317 AND 37
`C.F.R. §42.74 has been served in its entirety via email on the following:
`Chun M. Ng (Reg. No. 36,878)
`Vinay P. Sathe (Reg. No. 55,595)
`Patrick J. McKeever (Reg. No. 66,019)
`Miguel J. Bombach (Reg. No. 68,636)
`Kevin E. Kantharia (Reg. No. 71,071)
`Matthew C. Bernstein (Pro Hac Vice)
`Perkins Coie LLP
`11988 El Camino Real, Suite 350
`San Diego, CA 92130
`Phone: 858-720-5700
`Fax: 858-720-5799
`Service Email: PerkinsServiceConvergentMediaIPR@perkinscoie.com
`
`
`
`
`
`
`
`
`
`
`
`Dated: May 1, 2017
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully Submitted,
`
`/s/ Matthew C. Juren
`Matthew C. Juren
`Registration No. 68,233
`Attorney for Patent Owner
`NELSON BUMGARDNER, P.C.
`
`
`
`
`
`- 3 -
`
`

`

`Case IPR2016-01812
`U.S. Patent No. 8,640,183 B2
`
`
`
`
`
`
`
`
`
`
`
`3131 W. 7th Street, Suite 300
`Fort Worth, Texas 76107
`Telephone: (817) 377-9111
`Facsimile: (817) 377-3485
`matthew@nelbum.com
`Counsel for Patent Owner
`
`
`
`
`
`
`
`
`- 4 -
`
`

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