`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`APPLE INC.
`
`Petitioner
`
`v.
`
`SIGHTSOUND TECHNOLOGIES, LLC
`Patent Owner
`______________
`
`Case CBM2013-00020
`Patent 5,191,573
`______________
`
`Before the Honorable MICHAEL P. TIERNEY, JUSTIN T. ARBES, and
`GEORGIANNA W. BRADEN,
`Administrative Patent Judges.
`
`
`PETITIONER APPLE INC.’S RESPONSE TO
`PATENT OWNER’S MOTION FOR OBSERVATIONS ON
`CROSS-EXAMINATION
`
`
`
`
`By: Attorneys/Agents For Petitioner
`
`J. Steven Baughman, Lead Counsel
`Registration No. 47,414
`Ching-Lee Fukuda, Back-up Counsel
`Registration No. 44,334
`James R. Batchelder, Back-up Counsel
`Pro Hac Vice Granted
`
`
`
`
`
`ROPES & GRAY
`Prudential Tower
`800 Boylston Street
`Boston, Massachusetts 02199-3600
`(202) 508-4606 (Telephone)
`(617) 235-9492 (Fax)
`
`
`
`
`
`Case CBM2013-00020
`Patent 5,191,573
`
`
`TABLE OF CONTENTS
`
`
`Response To Observations Regarding CompuSonics ............................................. 1
`I.
`Response To Observations Regarding The Second Memory ................................. 2
`II.
`III. Response To Observations Regarding Non-Obviousness ..................................... 5
`IV. Response To Observations Regarding Commercial Success .................................. 6
`V.
`Response To Observations Regarding The Patented Invention .......................... 12
`VI. Response To Observations Regarding Credibility of Declaration Testimony ... 14
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`Case CBM2013-00020
`Patent 5,191,573
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`I.
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`
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`Response To Observations Regarding CompuSonics
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` Observations #1 and #2. PO first complains that Dr. John Kelly’s
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`CompuSonics opinions were not based on enough material, and then complains that
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`his CompuSonics opinions were based on too much material.
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`In Observation #1, PO implies that Mr. Stautner’s declaration should have
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`impacted Dr. Kelly’s opinions. But, as PO’s own description of the Stautner
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`Declaration (EX2121) makes clear, the Stautner Declaration is relevant only to “public
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`use” of the CompuSonics system, not the public disclosures of the CompuSonics
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`system relied upon by Dr. Kelly. PO itself summarizes the Stautner Declaration as
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`testimony “describing the shortcomings of that company’s products and business
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`plan” and “about what CompuSonics actually planned or did” (see Paper 76 at 13-14).
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`But as explained in Petitioner’s Reply at 5-6 (Paper 52 at 5-6), the CompuSonics
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`disclosures were “‘known … by others,’” under § 102(a). PO’s notion that Dr. Kelly
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`“did not have the complete record before him” misses the point, since Dr. Kelly’s
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`CompuSonics opinions relied on specific public disclosures that took place prior to
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`the critical date and were not limited to a theory that CompuSonics itself practiced the
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`challenged claims. PO’s continued attempts to shift focus—away from the
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`invalidating public disclosures relied upon by Dr. Kelly—does not and cannot
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`undercut the reliability of Dr. Kelly’s opinions. Unsurprisingly, Dr. Kelly confirmed
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`1
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`Patent 5,191,573
`that the Stautner Declaration did not change any of his opinions—testimony that
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`SightSound conspicuously ignores. EX2175 144:18-145:5.
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`Then, immediately after stating that Dr. Kelly “did not have the complete
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`record before him,” in Observation #2 PO pivots to an argument that Dr. Kelly
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`considered too much, complaining that his anticipation and obviousness opinions “have
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`always consisted of all such materials and never a subset of the whole.” Pet. Observs.
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`at 1. PO does not articulate why Dr. Kelly’s reliance on all the materials he cited, as
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`opposed to a subset of those materials, is problematic, apart from asserting without
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`explanation or support that he “applied an erroneous standard.” But as provided, for
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`example, in the declarations of Dr. Kelly and Mr. Schwartz, the exhibits relied upon
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`by Dr. Kelly publicly disclose features of the CompuSonics system and how it could
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`be used. See, e.g., EX4132 ¶¶ 49-56; EX4133 ¶ 5. These public disclosures were
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`properly the subject of Dr. Kelly’s opinions that the challenged claims were
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`anticipated and rendered obvious.
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`II. Response To Observations Regarding The Second Memory
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`Observation #3. PO complains that Dr. Kelly did not apply a construction
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`limiting “second memory” to “non-removable media.” Instead, Dr. Kelly applied a
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`“plain and ordinary meaning” construction for “second memory,” consistent with the
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`Board’s subsequent conclusion that “[a]ll other terms” in the challenged claims “are
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`given their ordinary and customary meaning.” See, e.g., EX4132 ¶ 14 (“For all
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`remaining claim terms, I have assumed their plain and ordinary meaning.”); Paper 14
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`2
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`Patent 5,191,573
`at 9 (“All other terms in claims 1, 64, and 95 are given their ordinary and customary
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`meaning and need not be further construed at this time.”). Dr. Kelly’s testimony that
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`portions of the specification are broader than the claims does not mean that he
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`misinterpreted the claims. PO’s argument that Dr. Kelly “did not properly consider
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`the specification” assumes that PO’s argument that the claims’ broad language should
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`be ignored is correct, but the Board has already concluded otherwise, as noted above.
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`Further, as explained in Petitioner’s Reply, PO’s disclaimer argument is in conflict
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`with Federal Circuit caselaw and PO’s own prior statements and positions. See Paper
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`51 at 2-3.
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`
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`Observation #4. PO cites Dr. Kelly’s testimony that the patent specifications’
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`reference to “Materials, Size, and Retrieval” pertains to inefficiencies of “hardware
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`units,” but PO neglects to provide the prior testimony, where Dr. Kelly made clear
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`that “the hardware units” he was referencing were “the hardware units of music:
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`records, tapes, and compact discs”:
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` Q. Is it correct that the ’573 patent references two issues, the
`transferability of music and inefficiencies associated with hardware units?
`Is that correct?
` THE WITNESS: No. That’s not the way I read this. This says it
`restricts the transferability of music and that results in -- the three basic
`mediums, the hardware units of music: records, tapes, and compact
`discs, greatly restricts the transferability of music, and the result of that is
`a variety of inefficiencies.
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`3
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`Patent 5,191,573
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`See EX2175 58:11-22 (objection omitted).
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`Indeed, Dr. Kelly was using PO’s own language, since this statement comes straight
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`from the patent and refers specifically to records, tapes, and compact discs. See
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`EX4101 1:17-20 (“The three basic mediums (hardware units) of music: records, tapes,
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`and compact discs, greatly restricts the transferability of music and results in a variety
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`of inefficiencies.”). These specific pieces of hardware are not notable because they
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`are “removable,” but because they are “[t]he three basic mediums (hardware units) of music”:
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`part of the traditional model for distributing music on physical media, through brick-
`
`and-mortar stores. Indeed, the patent makes this clear immediately after the
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`“materials,” “size,” and “retrieval” headings cited by PO:
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`SALES AND DISTRIBUTION: Prior to final purchase, hardware units
`need to be physically transferred from the manufacturing facility to the wholesale
`warehouse to the retail warehouse to the retail outlet, resulting in lengthy lag time
`between music creation and music marketing, as well as incurring
`unnecessary and inefficient transfer and handling costs. Additionally, tooling costs
`required for mass production of the hardware units and the material cost
`of the hardware units themselves, further drives up the cost of music to
`the end user.
`
`See EX4101 1:39-49.
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`Notably, PO fails to explain how the cited testimony undermines Dr. Kelly’s
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`opinions, and indeed, as shown above, this language and testimony does not support
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`PO’s bid to artificially limit its broad claims.
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`4
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`Patent 5,191,573
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`III. Response To Observations Regarding Non-Obviousness
`Observations #5 and #6. Jeff Robbin’s testimony regarding Petitioner’s ’242
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`patent is not relevant to obviousness of the challenged patent. Even a cursory review
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`of claim 1 of the patent application, as reproduced on p. 4 of PO’s Observations,
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`contradicts PO’s argument that Petitioner sought claims “similar” to the challenged
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`claims. For example, Apple’s claim includes the following limitations not present in
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`the claims challenged here: “the buy request being initiated by the user through a
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`single graphical user interface action by the user once an identifier for the particular
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`media item is displayed,” “the buy request including an account identifier for the
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`user,” and “the payment being processed using information previously stored in a user
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`account associated with the user.” The ’242 patent claims, as issued, included even
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`more limitations not found in any challenged claim. EX2176 at 7. Petitioner’s claims,
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`therefore, have no bearing on the disputed issues of this proceeding, and this
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`supplemental evidence PO improperly attempts to submit after its PO response
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`without the Board’s authorization is irrelevant.
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`Observation #7. PO mischaracterizes Mr. Robbin’s testimony regarding the
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`Background of the Invention section of the ’242 patent. What Mr. Robbin actually
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`testified was that he did not see “a date” or “the ‘80s” in the Summary, but that “the
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`substance of what it’s talking about is – does imply the idea that the idea of
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`distributing the music like that would be – it’s an idea that was common.” EX2176
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`111:16-21. In response to PO’s further questioning, Mr. Robbin responded: “Well, it
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`5
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`talks about music delivery or distribution over the Internet becoming popular, and the
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`idea was around – certainly much older than that….” Id. 111:23-112:3. PO at the
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`deposition improperly tried to “strike” that testimony and now selectively omits it
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`from its Observation. In addition, PO’s citations to Mr. Robbin’s testimony for the
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`proposition that Petitioner sought “similar” patent claims is wrong for the same
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`reasons discussed in Petitioner’s response to Observations #5 and #6.
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`IV. Response To Observations Regarding Commercial Success
`Observation #8. PO again selectively quotes deposition testimony, and here
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`mischaracterizes Larry Kenswil’s testimony regarding nexus to commercial success.
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`Far from “confirming” the existence of a nexus, Mr. Kenswil’s testimony contradicts
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`any nexus: “My understanding was the [challenged] patent was limited to claims
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`relating to the transmission of the file from the source to the receiver and the
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`transition and payment from the consumer back to the store. And those were
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`certainly necessary for digital sales, but certainly they were found in all previous attempts to
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`succeed in the digital business. And we had a series of failures in respect and suddenly iTunes
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`succeed. The question came up, why did they succeed when everyone else failed.” EX2174 59:8-22.
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`For the same reasons, PO’s further selective quote from Mr. Kenswil that “there are
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`people who value buying music online” does not establish any nexus to any novel
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`feature of the challenged claims. Mr. Kenswil’s declaration and additional testimony
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`establishes that the commercial success of iTMS is due to the many features of iTMS
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`and other considerations that are not found in or even related to any challenged claim.
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`6
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`Patent 5,191,573
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`See, e.g., EX4256 ¶¶ 66-98; EX2174 61:20-63:21, 68:11-24.
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`Observation #9. PO’s citations to Mr. Kenswil’s testimony regarding
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`“disaggregation” of a CD into individual songs and the ability to have one’s own
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`playlists are not relevant to the issues raised in PO’s Observation because neither
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`feature is required by the challenged claims, and thus cannot support any argument
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`for commercial success or nexus to the novel features of the challenged claims. Ormco
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`Corp. v. Align Tech, Inc., 463 F.3d 1299, 1312 (Fed. Cir. 2006) (“if the commercial
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`success is due to an unclaimed feature of device, the commercial success is
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`irrelevant”). See also In re Kao, 639 F.3d 1057, 1068 (Fed. Cir. 2011) (“Where the
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`offered secondary consideration actually results from something other than what is
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`both claimed and novel in the claim, there is no nexus to the merits of the claimed
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`invention”). Thus, PO’s perceived “benefits” of its alleged invention, which are not
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`claimed, are not relevant to a nexus analysis. Id. In addition, Mr. Kenswil was merely
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`asked in PO’s cited testimony to compare the formats of digital downloaded music
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`with CD music in general, which does not address the differences among various
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`offerings of digital download services. Mr. Kenswil’s testimony elsewhere, as well as
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`his declaration, make clear that the success of iTMS is attributable to its unique
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`features. See, e.g., EX4256 ¶¶ 93, 97. For this additional reason, PO’s Observation is
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`not relevant to nexus.
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`Observations #10, #11, #12, #16, #21, and #22. All six Observations hinge
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`on PO’s false premise that PO’s own commercial success arguments were somehow limited
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`Patent 5,191,573
`to iTMS as it existed at the time of its launch, such that (1) only features of iTMS
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`present at launch could be relevant to PO’s “co-extensive” argument (#16), and (2)
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`only differences between iTMS and the challenged claims present at the launch of
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`iTMS could be relevant (#10, #11, #12, #21, and #22). But PO’s nexus arguments
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`were explicitly not so limited. Instead, PO argued that iTMS is “currently the largest
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`music retailer in the world,” pointed out alleged market share “[a]t times since its
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`launch,” how many songs had been sold through iTMS as of February 2013, stated that
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`iTMS was the largest music retailer in the United States “[b]y 2008,” and argued that
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`iTMS drives “sales of products such as the iPod, iPad and iPhone” (notably, the iPad
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`and iPhone did not exist when iTMS was launched). See, e.g., Paper 41 at 70
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`(emphases added). In any case, PO’s Observations #10, #11, and #12 are incomplete
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`with respect to nexus because they do not identify or address the features of iTMS
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`that did exist at the time of launch. Paper 76 at 6-8. See also EX2176 114:18-115:2;
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`EX4262 ¶¶ 67-81. Further, as to Observations #21 and #22, Dr. Kelly testified that
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`his Reply Declarations, and even his report from the underlying litigation, did not
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`provide an exhaustive list of why iTMS does not practice the challenged claims. See,
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`e.g., EX2175 146:2-14. Therefore, the points mentioned by PO in Observations #21
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`and #22—a subset of the points raised by Dr. Kelly—are clearly not exhaustive as to
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`why iTMS does not practice the challenged claims.
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`Observations #11 and #17. PO argues that Mr. Kenswil and Dr. Kelly have
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`not provided enough data or done enough analysis regarding additional features of iTMS
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`Patent 5,191,573
`or of Apple’s patents, despite that PO, who bears the burden to show nexus, provided
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`no such data and did no such analysis. Kyocera Corp. and Motorola Mobility, Inc. v. Softview,
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`LLC, IPR2013-00007, Paper 51 at 32. As explained in Petitioner’s Reply at 10-11, the
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`burden of proving nexus is on PO, and PO chose to rely on an argument that iTMS is
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`“co-extensive” with the challenged claims. Yet PO chose to ignore features of iTMS
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`that are not accused of practicing the challenged claims, as well as Apple patents
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`related to such features. In addition, Mr. Kenswil provided his opinions based on his
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`25 years of experience making pertinent decisions in the music industry, in sharp
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`contrast to PO’s experts, who has had no such experience. EX4256 ¶¶ 6-15.
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`Observations #13 and #14. PO mischaracterizes Mr. Kenswil’s testimony
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`regarding Petitioner’s brand name and reputation. Mr. Kenswil’s declaration and
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`testimony make clear that his opinions are based on his personal knowledge and
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`experience in the music industry in the 2000s: “The strength of the Apple brand was
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`important. People were already associating it with digital music through the iPod, and
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`then it became an easy association with the iTunes Music Store because they
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`understood iTunes already. The label heads were impressed with Apple’s
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`understanding of how the music business is dependent upon promoting its artists and
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`how you promote the sale of music through the promotion of those artists . . . . The
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`ease of use of the software and how people – at least people who weren’t necessarily
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`all that conversant with technology or computer use were – were impressed by how
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`even they could use it. Those are examples.” EX2174 56:16-57:24. In response to a
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`Case CBM2013-00020
`Patent 5,191,573
`question about what facts or data Mr. Kenswil considered, he said: “[Apple’s]
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`established brand name. It’s a fact that Apple is a brand that’s well known to the
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`public since the launch of its initial line of personal computers many years before the
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`launch of the iTunes Music Store. Id. 62:14-23. See also id. 37:21-38:8; 61:20-62:13;
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`77:1-23. Considering the mountains of articles about Apple that exist in the media
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`since the 2000s, the mere fact that Mr. Kenswil did not review the two articles PO put
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`in front of him has no bearing on his reliable basis for his opinion. In addition, those
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`articles do not contradict Mr. Kenswil’s opinion.
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`Observation #15. PO’s citations to Mr. Kenswil’s testimony are incomplete
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`and misleading. Mr. Kenswil testified that he relied on Dr. Kelly for his analysis of
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`whether the challenged claims covered iTMS and the features of iTMS that were not
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`covered by the challenged claims. EX2174 45:19-48:5; see also EX4256 ¶¶ 19, 31, 94 n.
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`72. Thus, Mr. Kenswil’s basis for his related opinions is entirely proper.
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`Observation #18. PO also mischaracterizes Mr. Robbin’s knowledge of the
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`nine patents for which he is a named inventor. Mr. Robbin testified that he reviewed
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`the patent applications when they were prepared, and he did not remember when he
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`last reviewed the nine patents after issuance. EX2176 41:18-42:8. Contrary to PO’s
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`assertion, this testimony shows that Mr. Robbin did review the patents after issuance.
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`Thus, the cited testimony in fact establishes that Mr. Robbin did have reliable basis
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`for his testimony.
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`Case CBM2013-00020
`Patent 5,191,573
` Observation #19. PO takes issue with Dr. Kelly’s reliance on publicly
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`available information. But PO ignores that publicly available information established
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`the facts upon which Dr. Kelly relied, in addition to his own experience with iTMS,
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`and Dr. Kelly repeatedly testified that it was not necessary to consider confidential
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`information. For example, Dr. Kelly testified that he relied not only on publicly
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`available information, but also on his own use of and experience with iTMS, iTunes,
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`and iPods in arriving at his opinions. See, e.g., EX2175 13:15-23 (testifying that he
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`relied on information listed in ¶ 2 of EX4262 and “my own knowledge and
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`experience gained through years of examining iTunes and using and analyzing iPods
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`and that type of thing. Being an owner of many generations of iPods, having used
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`probably every iTunes client and so on, I would include that as what I relied on.”); see
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`also, e.g., EX2175 114:19-115:2, 116:8-12 (“[I]t wasn’t necessary to rely on Apple
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`internal information. It’s publically disclosed in these documents and can be observed by anyone
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`who cares to -- cares to see this, in actual use of the iTunes Store.”); 68:3-7 (“It was unnecessary.
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`What I laid out in my declarations does not require any source code for support.”).
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`Observation #20. PO complains that Dr. Kelly did not consider marketing
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`surveys. But Dr. Kelly did not opine on commercial success or marketing issues, and
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`had no need to consider marketing surveys or other marketing materials. Instead, Dr.
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`Kelly opined on the technical aspects of iTMS, including that iTMS does not practice
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`the challenged claims, and that iTMS includes features not accused of practicing the
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`challenged claims. See, e.g., EX4262 ¶¶ 28-63, 66-81. Tellingly, PO’s Observation #20
`11
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`does not identify any opinions of Dr. Kelly that would have required consulting
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`marketing surveys.
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`Observation #23. PO conflates the CompuSonics disclosures—evidence of
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`what the public knew—with its arguments that iTMS practices the challenged claims.
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`But PO’s correct observation that iTunes assets could be acquired without a credit
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`card does not somehow erase from the public’s knowledge CompuSonics disclosures
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`that describe, for example, using a credit card to charge purchases over the phone lines. See, e.g.,
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`EX4106 at 3 (“The retailers would then be able, in turn, to digitally transmit the music
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`to consumers who would use credit cards to charge their purchases over the phone lines.”);
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`EX4115 at 1(“all-electronic purchases”); EX4119 at 2 (“a service that would enable
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`record companies to sell direct to consumers over the telephone. Symphonies, ordered by credit
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`card, could travel digitally over phone lines into homes to be recorded by
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`Compusonics’ machine.”) (all emphases added). These public disclosures are not
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`affected by whether an iTMS asset can be acquired absent a credit card.
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`V. Response To Observations Regarding The Patented Invention
`Observations #24 and #25. PO’s citations to Mr. Robbin’s testimony about
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`Steve Jobs fails to establish any basis for PO’s allegations of copying by Petitioner.
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`There is nothing in the testimony regarding any feature of the challenged claims,
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`much less any novel feature, that is allegedly copied by Petitioner. At most, the cited
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`testimony relates to the basic idea of buying music online, an idea that has existed
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`long before PO ever approached Petitioner. EX4104 49:3-52:2, 88:16-89:9; EX4105
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`42:12-44:5; EX4136 at 109-110. Mr. Robbin’s testimony about the unauthenticated
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`YouTube video clip shown to him during deposition is limited to: “Q. Does that
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`appear to you to be Mr. Jobs? A. It does.” EX2176 87:6-7. In fact, Mr. Robbin
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`made clear that he “can’t say anything about where that clip came from or what it
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`was” nor “what that clip actually means or what the context is.” Id. 88:16-89:3. The
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`YouTube video itself mentions only the Macintosh computer, and does not even
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`reference iTMS: “It comes down to trying to expose yourself to the best things that
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`humans have done and then try to bring those things in to what you are doing. I
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`mean, Picasso had a saying. He said, Good artists copy; great artists steal. And we
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`have, you know, always been shameless about stealing great ideas. And I think part of
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`what made the Macintosh great was that the people working on it were musicians and
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`poets and artists and zoologists and historians who also happened to be the best
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`computer scientists in the world.” EX2176 87:10-23. Thus, even setting aside PO’s
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`improper attempt to use this deposition to make an unauthorized, late submission of
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`evidence it should have offered in its PO Response. The video clip itself is not
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`relevant to iTMS or the issues in this proceeding.
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`Observations #26 and #27. PO omits Mr. Weyer’s and Mr. Gavini/Mazzoni’s
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`testimony regarding why they did not pass along to others within Apple (let alone
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`those on the iTMS development project, which involved neither of them 1 )
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`SightSound’s proposal/disclosure from the February 1999 Los Angeles meeting. As
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`1 EX4258 ¶ 9; EX4257 ¶¶ 2-3.
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`Weyer explained, he was “underwhelmed” by the presentation; “They didn’t tell us
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`anything of value,” or discuss any “real technology” or anything “actionable or
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`useful,” “so there wasn’t any follow-up . . . either internally or externally”; Weyer
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`immediately told Gavini/Mazzoni that the presentation warranted no follow-up, and
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`he understood that Gavini/Mazzoni concurred. Other than that one conversation,
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`Weyer did not communicate about the meeting with anyone at Apple. EX4258 ¶¶ 3-
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`8; EX2173 33:11-34:3, 34:23-35:17, 41:20-42:7, 55:22-56:9. “This matter I thought
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`was basically over while I was down there, and I never heard anything more from it.”
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`EX2173 58:8-23.
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`Like Weyer, Gavini/Mazzoni recalls no communication about the meeting with
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`anyone at Apple; and each believes he would remember such a communication if it
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`had taken place. EX4257 ¶¶ 2-3; EX2172 30:19-24; EX2374 58:8-23.
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`Correspondingly, Mr. Robbin, who ran the iTMS development team, was not
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`aware of any SightSound-related information while iTMS was being developed, and
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`has no reason to think that anyone on his team knew such information or used it in
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`any way to build iTMS. EX4255 ¶ 8.
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`VI. Response To Observations Regarding Credibility of Declaration
`Testimony
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`Observation #28. Finally, PO mischaracterizes Mr. Kenswil’s testimony in the
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`cited passage. Mr. Kenswil properly testified that he has not read Mr. Hair’s and Mr.
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`Sander’s “depositions” as a whole. He, however, did review excerpts that relate to his
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`opinion, as properly cited in his declaration. EX4256 ¶¶ 36, 41, 44, 45, 50, 56, and 64.
`
`Further, Mr. Kenswil testified that he reviewed the declaration, including the materials
`
`that were cited (which included excerpts from the depositions of Mr. Hair and Mr.
`
`Sander), when it was prepared and reviewed the declaration again before the
`
`deposition, and found it to be accurate. EX2174 17:15-19:9. Again, PO’s observation
`
`mischaracterizes the record.
`
`April 18, 2014
`
`
`
`
`
`
`Respectfully submitted,
`
`By /J. Steven Baughman/
`J. Steven Baughman, Lead Counsel
`
`15
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`
`
`APPLE INC.
`
`Petitioner
`
`v.
`
`SIGHTSOUND TECHNOLOGIES, LLC
`Patent Owner
`______________
`
`Case CBM2013-00020
`Patent 5,191,573
`______________
`
`Before the Honorable MICHAEL P. TIERNEY, JUSTIN T. ARBES, and
`GEORGIANNA W. BRADEN,
`Administrative Patent Judges.
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that the foregoing PETITIONER APPLE INC.’S
`
`RESPONSE TO PATENT OWNER’S MOTION FOR OBSERVATIONS ON
`
`CROSS-EXAMINATION in connection with Covered Business Method Review
`
`Case CBM2013-00020 was served on this 18th day of April, 2014, by electronic mail
`
`upon Arnold & Porter LLP, counsel for Patent Owner, at david.marsh@aporter.com
`
`and kristan.lansbery@aporter.com.
`
`Dated: April 18, 2014
`
`
`
`
`
`
`
`
`
`By / Megan F. Raymond/
`Megan F. Raymond
`
`
`
`
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