`Patent 9,444,868 B2
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`
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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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`AFFINITY LABS OF TEXAS, LLC,
`Patent Owner
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`
`
`
`
`Case IPR2017-00122
`Patent 9,444,868 B2
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`
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`
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`PETITIONER’S REQUEST FOR ORAL ARGUMENT
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`
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`IPR2017-00122
`Patent 9,444,868 B2
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`Pursuant to 37 C.F.R. § 42.70(a) and the Board’s April 26, 2017 Scheduling
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`Order (Paper 11), Netflix hereby requests an oral argument on the issues set forth
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`below at a time set by the Board. Oral argument is presently scheduled for
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`December 21, 2017. In IPR no. IPR2016-01701, the Board has set a hearing to
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`commence at 2:00 PM Eastern Time on November 30, 2017. That trial involves
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`the same parties and patents in the same family with the same specification, and
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`some of the same prior art references. Both of these trials are in front of the same
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`panel of Administrative Patent Judges, KEVIN F. TURNER, LYNNE E.
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`PETTIGREW, and JON B. TORNQUIST. For efficiency, Petitioner, Netflix and
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`Patent Owner, Affinity Labs, have jointly requested a telephonic conference to
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`request the Board to move the hearing in the IPR2016-01701 case to occur the
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`same day as that of this case, currently on December 21, 2017.
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`Petitioner respectfully requests 45 minutes of argument time in which
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`Petitioner may present its arguments.
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`Petitioner requests that the Board provide audio/visual equipment to display
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`demonstrative exhibits and evidence of record, including the use of a projector and
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`screen for displaying documents.
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`Petitioner requests oral argument on all issues raised in the parties’ filings,
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`including but not limited to the following:
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`1
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`
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`IPR2017-00122
`Patent 9,444,868 B2
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`(1) Whether claims 1–12, 14, 15, and 17–20 are unpatentable under 35
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`U.S.C. § 103 as having been obvious over Treyz and Fuller;
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`(2) Whether claims 13 and 16 are unpatentable under 35 U.S.C. § 103 as
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`having been obvious over Treyz, Fuller, and Glaser; and
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`(3) Rebuttal to Patent Owner’s presentation on all matters.
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`
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`Date: November 14, 2017
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`Respectfully submitted,
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`
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`By: /Hector J. Ribera/
`Hector J. Ribera (Reg. No. 54,397)
`Marton Ribera Schumann & Chang LLP
`548 Market St. Suite 36117
`San Francisco, CA 94104
`Email: hector@martonribera.com
`Tel: (415) 360-2511
`
`Attorneys for Petitioner, Netflix, Inc.
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`2
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`
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`IPR2017-00122
`Patent 9,444,868 B2
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`CERTIFICATE OF SERVICE PURSUANT TO
`37 C.F.R. § 42.6
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`Pursuant to 37 CFR § 42.6(e)(4) the undersigned certifies that on November
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`14, 2017, a complete and entire copy of this Petitioner’s Request for Oral
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`Argument was provided via electronic mail, to the Patent Owner by serving the e-
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`mail addresses of record as follows:
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`
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`
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`ATTN: Ryan M. Schultz (Reg. No. 65,134)
`RSchultz@RobinsKaplan.com
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`Sui Li (Reg. No. 74,617)
`SLi@RobinsKaplan.com
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`
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`
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`Date: November 14, 2017
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`
`
`
`
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`By: /Hector J. Ribera/
`Hector J. Ribera (Reg. No. 54,397)
`Marton Ribera Schumann & Chang LLP
`548 Market St. Suite 36117
`San Francisco, CA 94104
`Email: hector@martonribera.com
`Tel: (415) 360-2511
`
`Attorneys for Petitioner, Netflix, Inc.
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`3
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`
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