UNITED STATES PATENT AND TRADEMARK OFFICE
`
`—————————————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`—————————————
`
`LIBERTY MUTUAL INSURANCE CO.
`Petitioner
`
`v.
`
`PROGRESSIVE CASUALTY INSURANCE CO.
`Patent Owner
`
`—————————————
`
`Case CBM2012-00003
`Patent 8,140,358
`
`—————————————
`
`PATENT OWNER’S MOTION TO EXCLUDE EVIDENCE
`PURSUANT TO 37 C.F.R. § 42.64(c)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`CLI-2144869v6
`
`
`
`—————————————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`—————————————
`
`LIBERTY MUTUAL INSURANCE CO.
`Petitioner
`
`v.
`
`PROGRESSIVE CASUALTY INSURANCE CO.
`Patent Owner
`
`—————————————
`
`Case CBM2012-00003
`Patent 8,140,358
`
`—————————————
`
`PATENT OWNER’S MOTION TO EXCLUDE EVIDENCE
`PURSUANT TO 37 C.F.R. § 42.64(c)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`CLI-2144869v6
`
`
`
`Pursuant to 37 C.F.R. § 42.64(c) and Notice of Stipulation of Due Dates
`
`Case CBM2012-00003
`Patent 8,140,358
`
`
`
`(Paper No. 42), Patent Owner Progressive Casualty Ins. Co. (“Progressive”),
`
`hereby moves to exclude Exhibits 1032 and 1034 filed by Liberty Mutual
`
`Insurance Co. (“Liberty”) with its Reply (Paper No. 39).
`
`I.
`
`SUMMARY OF ARGUMENT
`
`Liberty and its reply declarants have belatedly sought to introduce new prior
`
`art references, new invalidity arguments and theories, and new declarations with
`
`Liberty’s Reply in an effort to plug the holes in its original case. This is not proper
`
`rebuttal evidence, and is without justification. Liberty’s belated new evidence not
`
`only violates the Board’s rules, but it unfairly prejudices Progressive. Because
`
`Liberty delayed in submitting this improper new evidence with its Reply,
`
`Progressive has no opportunity to respond by surreply or with declarations of its
`
`own expert witnesses. The Board should grant Progressive’s motion to exclude,
`
`otherwise Liberty would be rewarded with an unfair procedural advantage
`
`resulting from shifting its theories and evidence of unpatentability at the Reply
`
`stage, in an effort to now make out a prima facie case that the Board’s rules
`
`required them to establish with their Petition.
`
`CLI-2144869v6
`
`1
`
`
`
`Case CBM2012-00003
`Patent 8,140,358
`
`
`II. LEGAL STANDARD
`A.
`Petition Must Identify All Supporting Evidence
`A petition to institute a Covered Business Method (“CBM”) Review must be
`
`accompanied by all the evidence upon which the petitioner relies in challenging
`
`patentability. See 37 C.F.R. § 42.304(b)(4),(5); 77 Fed. Reg. 48,756, 48,756-57
`
`(Aug. 14, 2012) (petition must be “accompanied by the evidence the petitioner
`
`seeks to rely upon” and “identif[y] all…supporting evidence on a claim-by-claim
`
`basis”). It must also “identify[] the specific portions of the evidence that support
`
`the challenge,” including “specify[ing] where each element of the claim is found in
`
`the prior art[.]” See 37 C.F.R. § 42.304(b)(4),(5); see also 77 Fed. Reg. at 48,757.
`
`The Board will not consider any basis for invalidity that is not specifically
`
`identified in a petition and will “resolve all vagueness and ambiguity in
`
`Petitioner’s arguments against the Petitioner.” (Paper No. 8 at 14.)
`
`B. Reply Evidence Cannot Fix Deficiencies In Prima Facie Case
`A “reply may only respond to arguments raised in the…patent owner
`
`response.” 37 C.F.R. § 42.23(b). A Petitioner is prohibited from using its reply to
`
`submit (i) new evidence necessary to make out its prima facie case, or (ii) new
`
`evidence that could have been presented in its petition. See 77 Fed. Reg. at 48,767.
`
`The Office Patent Trial Practice Guide further explains this prohibition:
`
`CLI-2144869v6
`
`2
`
`
`
`
`
`Case CBM2012-00003
`Patent 8,140,358
`
`While replies can help crystallize issues for decision, a reply that raises a
`
`new issue or belatedly presents evidence will not be considered and may be
`
`returned….Examples of indications that a new issue has been raised in a
`
`reply include new evidence necessary to make out a prima facie case for
`
`the patentability or unpatentability of an original or proposed substitute
`
`claim, and new evidence that could have been presented in a prior filing.
`
`77 Fed. Reg. at 48,767 (emphasis added). The Board has quoted and referenced
`
`this language in explaining that “a reply that raises a new issue or belatedly
`
`presents evidence will not be considered” and that “a new issue is raised if the
`
`reply includes new evidence necessary to make out a prima facie case for the
`
`unpatentability of a challenged claim.” BlackBerry Corp v. MobileMedia Ideas,
`
`LLC, No. IPR2013-00036 (JYC), Paper 40, at 2. Further, such evidence would be
`
`both irrelevant and unfairly prejudicial and therefore not admissible under F.R.E.
`
`402 and 403.
`
`C. Unreliable Testimony Improper Under F.R.E. 702
`Pursuant to Federal Evidence Rule 702, expert testimony can only be
`
`admitted if it is reliable. Rule 702 requires the Board to act as a gatekeeper for
`
`expert testimony and exclude such testimony if it is unreliable. See Daubert v.
`
`Merrell Dow Pharm., Inc., 509 U.S. 579 (1993); see also 37 C.F.R. § 42.62
`
`(Federal Rules of Evidence apply to proceedings before the Board).
`
`CLI-2144869v6
`
`3
`
`
`
`
`
`Case CBM2012-00003
`Patent 8,140,358
`
`D. Board May Exclude Or Not Consider Improper Evidence
`The Board has two options if a petitioner submits improper evidence with its
`
`reply. CBS Interactive Inc. v. Helferich Patent Licensing, LLC, No. IPR2013-
`
`00033 (JYC), Paper 79, at 3. It can exclude or decline to consider the evidence.
`
`See id. (“Should there be improper…evidence presented with a reply, the Board,
`
`exercising its discretion, may exclude the…related evidence in their entirety, or
`
`alternatively, decline to consider the…related evidence.”).
`
`III. ARGUMENT
`A. The Belatedly-Introduced O’Neil Reply Declaration
`Liberty chose not to include a declaration by O’Neil with its Petition, but
`
`instead waited to introduce her opinions in a Reply Declaration (Exhibit 1032). As
`
`demonstrated below, this belatedly-introduced Declaration includes new arguments
`
`and constitutes new evidence as to unpatentability that should have been
`
`introduced with Liberty’s Petition. It violates the prohibition on raising new issues
`
`in a reply brief, and Patent Owner timely objected. (Paper No. 40.) As such,
`
`¶¶ 26-27 of the O’Neil Reply Declaration should be excluded.
`
`1.
`
`New Issues As To Claimed “Selected Vehicle Data”
`
`In its Petition, Liberty relied on only paragraph 58 from Nakagawa as
`
`disclosing the claim limitation “selected vehicle data related to a level of safety or
`
`an insurable risk in operating a vehicle.” (See Petition at 24.) It relied on no
`
`CLI-2144869v6
`
`4
`
`
`
`
`supporting declarations as to a POSITA’s understanding of whether Nakagawa
`
`Case CBM2012-00003
`Patent 8,140,358
`
`disclosed this limitation. (Compare Petition at 24 with Petition at 25 citing
`
`Andrews’ opinion as to a POSITA’s understanding for the “database” claim
`
`limitation.)
`
`With its Reply, Liberty introduced new evidence as to a POSITA’s
`
`understanding concerning this claim limitation based on a portion of Nakagawa
`
`that was not identified in the Petition. That is, in her Reply Declaration, O’Neil
`
`quoted paragraph 65 of Nakagawa in opining that: “a POSITA would find that
`
`Nakagawa’s ‘usage data’ ‘relates to a level of safety or an insurable risk in
`
`operating a vehicle’ because it includes ‘degree of safe operation’ and ‘danger
`
`status’ that are based on determinations of ‘whether the operation and installation
`
`statuses of a vehicle are safe or dangerous.’” (O’Neil Reply Declaration at ¶ 26,
`
`paragraph 65 text underlined.)
`
`To the extent Liberty wanted to rely on paragraph 65 of Nakagawa and
`
`O’Neil’s opinions as to how a POSITA would interpret this language, it should
`
`have specifically identified this argument and evidence in its Petition, which it did
`
`not. (See supra at 2.) As such, ¶ 26 of the O’Neil Reply Declaration should be
`
`excluded.
`
`CLI-2144869v6
`
`5
`
`
`
`
`
`2.
`
`New Issues As To Claimed “Rating Factors”
`
`Case CBM2012-00003
`Patent 8,140,358
`
`In its Petition, Liberty relied on paragraph 76 from Nakagawa as disclosing
`
`the claimed “rating factors.” (See Petition at 26.) It also quoted from paragraph
`
`76, inter alia, as to “driving techniques and the level of safe driving.” (Id.; Ex.
`
`2005, ¶ 76.) Liberty did not rely on any supporting declaration as to a POSITA’s
`
`understanding of whether Nakagawa disclosed this limitation. (See Petition at 26.)
`
`Yet in her Reply Declaration, O’Neil opined that a POSITA would find that
`
`Nakagawa discloses rating factors. (See O’Neil Reply Declaration at ¶ 27.)
`
`If Liberty wanted to rely on a declaration as to how a POSITA would
`
`understand paragraph 76, it should have included this evidence with its Petition,
`
`not simply quoted the paragraph. Indeed, O’Neil admitted that if Liberty had
`
`asked her, she “would have been able to provide a declaration on the ‘358 patent
`
`back at the time of Liberty’s original petition.” (See Ex. 2015, O’Neil Tr. at 97:11-
`
`17, emphasis added.) As such, ¶ 27 of the O’Neil Reply Declaration should be
`
`excluded.
`
`Belatedly-Introduced Andrews Reply Declaration
`
`B.
`Liberty submitted a Declaration from Andrews with its Petition (Exhibit
`
`1025), in which he offered only conclusory statements as to Nakagawa, with less
`
`than one page of text addressing it. (See id. at 17.) Yet, with its Reply, Liberty
`
`submitted an Andrews Reply Declaration (Exhibit 1034) that addressed Nakagawa
`
`CLI-2144869v6
`
`6
`
`
`
`
`at length, offering a 20-page discussion and opinions on Nakagawa, which should
`
`Case CBM2012-00003
`Patent 8,140,358
`
`have been offered at the time of filing the Petition and violates the prohibition on
`
`raising new issues in a reply brief. Progressive timely objected, and ¶¶ 6, 9, 11,
`
`19-24, 26, 28, 30, and 31 of Andrews Reply Declaration should be excluded.
`
`(Paper No. 40.)
`
`1.
`
`New Issues As To Claimed “Database”
`
`In its Petition, Liberty relied on paragraphs 61 and 69 from Nakagawa and
`
`Andrews’ one-page discussion of Nakagawa in his Petition Declaration as the
`
`evidence that Nakagawa anticipated the “database” claim limitation. (See Petition
`
`at 26; Ex. 1025 at 17.) As demonstrated below, Liberty improperly introduced
`
`new invalidity arguments and evidence through the Andrews Reply Declaration at
`
`¶¶ 11, 19-24, 26, 28, 30, and 31 as to the “database” claim limitation.
`
`First, Andrews relied on different parts of Nakagawa in his Reply
`
`Declaration that were not cited in the Petition or his Petition Declaration. That is,
`
`he relied on paragraphs 67-68 and Figure 6 from Nakagawa in arguing that it
`
`discloses the “database” claim limitation. (See Andrews Reply Declaration at
`
`¶¶ 19-24, 28, and 30.) Indeed, in an apparent attempt to disguise the fact that he
`
`was relying on new portions of Nakagawa, Andrews writes, “[a]s I pointed out in
`
`my prior Declaration, for example, Nakagawa discloses that ‘the control part 22
`
`on the server side updates the “user data” recorded in memory that corresponds to
`
`CLI-2144869v6
`
`7
`
`
`
`
`the received ID.’” (See id. at ¶ 28.) Yet, this language does not appear in his
`
`Case CBM2012-00003
`Patent 8,140,358
`
`Petition Declaration, as he claims. Rather, Andrews is quoting language from
`
`paragraph 68 of Nakagawa, which was not cited in his Petition Declaration or in
`
`the Petition.
`
`Further confirming Andrews’ erroneous characterization of the subject
`
`matter addressed in his Petition Declaration, Andrews admitted that he did not
`
`opine on “user data.” (Ex. 2016, Andrews Tr. at 296:24-297:13.) He opined on
`
`“usage data” in his Petition Declaration, and he concedes that “user data” and
`
`“usage data” “are not exactly one and the same interchangeable[.]” (Id. at 296:24-
`
`297:13, 299:22-300:4, emphasis added.)
`
`Second, Andrews offered new opinions in his Reply Declaration as to how a
`
`POSITA would view Nakagawa’s disclosure concerning the “database” claim
`
`limitation. In his Petition Declaration, Andrews simply offered the conclusory
`
`statement that the “correspondence between a driver’s stored ‘usage data’ and an
`
`ID…would be understood by one skilled in the art as indicating a database.”
`
`(Andrews Petition Declaration at ¶ 36.) However, in the Andrews Reply
`
`Declaration, Liberty improperly offers numerous additional opinions as to a
`
`POSITA’s understanding of Nakagawa as follows: “[a]s explained below, a
`
`POSITA would understand Nakagawa to disclose a database;” “[a] POSITA would
`
`also find that Nakagawa’s ‘user data’ is necessarily stored in a database;” “a
`
`CLI-2144869v6
`
`8
`
`
`
`
`POSITA would understand that such data is stored in a form that maintains this
`
`Case CBM2012-00003
`Patent 8,140,358
`
`link to user ID;” “[t]his is consistent with the understanding of a POSITA;” “a
`
`POSITA would understand that ‘user data’ disclosed in Nakagawa is stored in a
`
`file that comprises ‘records;’” “a POSITA would understand Nakagawa to disclose
`
`a database comprising records;” “[t]his is common sense and certainly would have
`
`been understood by a POSITA;” “[a] POSITA would thus understand Nakagawa
`
`to disclose a database with ‘operations for searching the records;’” “a POSITA
`
`would understand Nakagawa to disclose storing the ‘user data’ in a ‘file’
`
`containing records, which necessarily allows a user to ‘retrieve, change, delete,
`
`save, or send [the stored information] to an output device,’ such as shown in the
`
`user display of Figure 6;” “for at least the reasons stated above, a POSITA would
`
`understand Nakagawa to disclose a database comprised of records with operations
`
`for searching the records and other functions.” (See Andrews Reply Declaration at
`
`¶¶ 11, 19, 22, 23, 26, 28, 30, 31 emphasis added.)
`
`Third, the new evidence in Liberty’s Reply is an attempt to fix the lack of a
`
`prima facie case. Indeed, Liberty offered no evidence with its Petition to
`
`demonstrate that the database claim limitation is inherently disclosed by
`
`Nakagawa. In his Petition Declaration, Andrews stated in conclusory fashion that
`
`“the correspondence between a driver’s stored ‘usage data’ and an ID…would be
`
`understood by one skilled in the art as indicating a database.” (Andrews Petition
`
`CLI-2144869v6
`
`9
`
`
`
`
`Declaration at ¶ 36, emphasis added.) This Petition testimony was not sufficient to
`
`Case CBM2012-00003
`Patent 8,140,358
`
`establish inherency. See Trintec Ind., Inc. v. Top-U.S.A. Corp., 295 F.3d 1292,
`
`1295 (Fed. Cir. 2002).
`
`As the Board explained in a related case:
`
`To establish inherency, that which is missing in the express description must
`
`necessarily be present and would be so recognized by one with ordinary
`
`skill in the art. Continental Can Co. v. Monsanto Co., 948 F.2d 1264, 1268
`
`(Fed. Cir. 1991). Inherency may not be established by probabilities or
`
`possibilities, and the mere fact that a certain thing may result from a given
`
`set of circumstance is not sufficient for establishing inherency. In re
`
`Oelrich, 666 F.2d 578, 581 (CCPA 1981).
`
`(CBM2013-00009, Paper No. 10, at 27, emphasis added.) Indeed, in the Institution
`
`Decision for the same patent at issue in this CBM Review, the Board addressed
`
`Andrews’ testimony and held that his “meander[ing] around the critical question of
`
`inherent disclosure” meant that “Liberty ha[d] not established…inheren[cy].” (Id.)
`
`That same description applies to the Andrews Petition Declaration in this
`
`proceeding. He meanders around the issue of inherency by simply stating that
`
`Nakagawa “indicat[es] a database.” (Andrews Petition Declaration at ¶ 36.)
`
`Moreover, Liberty improperly raised new issues with its Reply by offering
`
`numerous belated opinions by Andrews as to inherency in his Reply Declaration as
`
`CLI-2144869v6
`
`10
`
`
`
`
`follows: “Nakagawa’s ‘user data’ is necessarily stored in a database;”
`
`Case CBM2012-00003
`Patent 8,140,358
`
`“Nakagawa’s user data is necessarily stored in a database;” “‘user data’…must
`
`necessarily be stored in ‘records;’” “[t]o update such stored data keyed to a
`
`particular user, the server must necessarily ‘locate and retrieve one or more
`
`specific records from among the many records;’” “the particular data to be updated
`
`must necessarily be ‘located’ and ‘retrieved;’” “Nakagawa’s discussion of
`
`updating a particular user’s data necessarily discloses such a database;” and
`
`“Nakagawa to disclose storing the ‘user data’ in a ‘file’ containing records, which
`
`necessarily allows a user to ‘retrieve, change, delete, save, or send [the stored
`
`information] to an output device.’” (See Andrews Reply Declaration at ¶¶ 19, 21,
`
`23, 28, 30, emphasis added.)
`
`If Liberty wanted to rely on paragraphs 68-69 and Figure 6 of Nakagawa and
`
`the opinions as to a POSITA’s understanding of Nakagawa and inherency in
`
`Andrews Reply Declaration, Liberty should have specifically identified them in its
`
`Petition and had Andrews opine on them in his Petition Declaration. As such,
`
`¶¶ 11, 19-24, 26, 28, 30, and 31 of the Andrews Reply Declaration should be
`
`excluded.
`
`2.
`
`New Issues As To “Storing” And “Transmitting”
`
`In his Reply Declaration, Andrews opined that “Nakagawa discloses storing
`
`and transmitting ‘selected vehicle data,’” and he relies on paragraphs 48 and 65
`
`CLI-2144869v6
`
`11
`
`
`
`
`from Nakagawa as evidence of that disclosure. (See Andrews Reply Declaration at
`
`Case CBM2012-00003
`Patent 8,140,358
`
`¶ 5, 6, 9.) However, these portions of Nakagawa were not cited in the Petition or
`
`the Andrews Petition Declaration. Liberty’s use of these new portions of
`
`Nakagawa is an improper attempt to introduce new arguments and evidence with
`
`its Reply. (See supra at 2-3.) Indeed, Andrews admitted that if Liberty had asked
`
`him, he could have provided “additional opinions” as to Nakagawa when Liberty
`
`submitted its Petition, but he “wasn’t asked to do that.” (See Ex. 2016, Andrews
`
`Tr. at 284:17-23, emphasis added.) As such, Andrews Reply Declaration at ¶¶ 6
`
`and 9 should be excluded.
`
`C. Belatedly-Introduced Issues As To Priority
`Liberty argued in its Petition that “the claims of the ‘358 Patent are not
`
`entitled to claim priority to the applications issuing as the parent ‘134, ‘970, ‘386,
`
`or ‘598 patents.” (See Petition at 4; see also id. at 14, “claims 1, 16-17 and 19-20
`
`cannot claim priority to any application dated earlier than January 23, 2004 – the
`
`filing date of the ‘598 Patent, and claims 2-15 and 18 cannot claim priority to any
`
`application dated earlier than June 3, 2008 – the filing date of the ‘358 Patent.”)
`
`Indeed, Andrews even opined in his Petition Declaration that he “understand[s]”
`
`that the ‘358 patent “claims priority to an application filed on January 29, 1996”
`
`and that he knew that Liberty “disputes the 1996 priority date claimed by the '358
`
`Patent.” (Andrews Petition Declaration at ¶ 14.) But, neither Andrews nor O’Neil
`
`CLI-2144869v6
`
`12
`
`
`
`
`offered any declaration support for Liberty’s priority arguments with the Petition.
`
`Case CBM2012-00003
`Patent 8,140,358
`
`However, both Andrews and O’Neil offered declaration support with the Reply.
`
`(Andrews Reply Declaration at ¶¶ 43-51; O’Neil Reply Declaration at ¶¶ 22-25.)
`
`For example, Liberty argued in its Petition that “[i]ndependent claim 1’s
`
`recitation of a ‘server…configured to generate a rating factor based on the
`
`selected vehicle data stored in the database’ is an entirely new concept distinct
`
`from what those [applications’] written descriptions disclosed.” (Petition at 4,
`
`emphasis added.) Yet, Andrews waited until his Reply Declaration to offer this
`
`very same opinion that “a POSITA would not clearly conclude that the ‘650 and
`
`‘076 disclosures require that a ‘rating factor’…is calculated at the remote server.”
`
`(Andrews Reply Declaration, at ¶ 48, emphasis added.)
`
`If Liberty wanted to rely on opinions by Andrews and O’Neil as to its
`
`priority arguments, it should have had them so opine in Petition Declarations and
`
`specifically identified this evidence in the Petition. Patent Owner timely objected
`
`(Paper No. 40), and as such, ¶¶ 43-51 of the Andrews Reply Declaration and ¶¶ 22-
`
`25 of the O’Neil Reply Declaration should be excluded.
`
`IV. CONCLUSION
`For at least these reasons, Patent Owner’s Motion to Exclude should be
`
`granted.
`
`CLI-2144869v6
`
`13
`
`
`
`
`
`
`
`
`
`
`
`Case CBM2012-00003
`Patent 8,140,358
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By:
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`JONES DAY
`
`/s/Calvin P. Griffith
`Calvin P. Griffith
`Registration No. 34,831
`JONES DAY
`North Point
`901 Lakeside Avenue
`Cleveland, Ohio 44114-1190
`(216) 586-3939
`(216) 579-0212 (Fax)
`Attorney For Patent Owner
`Progressive Casualty Insurance Co.
`
`
`
`
`
`
`
`
`
`
`
`September 30, 2013
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`CLI-2144869v6
`
`14
`
`
`
`CERTIFICATE OF SERVICE
`
`I certify that a copy of the foregoing PATENT OWNER’S MOTION TO
`
`EXCLUDE EVIDENCE PURSUANT TO 37 C.F.R. § 42.64(c) was served on
`
`September 30, 2013 by causing them to be sent by email to counsel for Petitioner
`
`at the following email addresses:
`
`Steven.baughman@ropesgray.com
`Nicole.jantzi@ropesgray.com
`James.myers@ropesgray.com
`LibertyMutualPTABService@ropesgray.com
`
`
`
`/s/ John V. Biernacki
`John V. Biernacki
`Registration No. 40,511
`JONES DAY
`North Point
`901 Lakeside Avenue
`Cleveland, Ohio 44114-1190
`Attorney For Patent Owner
`Progressive Casualty Insurance Co.
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
