`
`
`
`
`IN THE UNITED STATES PATENT & TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`salesforce.com, inc.,
`Petitioner,
`v.
`Applications In Internet Time LLC,
`Patent Owner.
`______________________
`
`
`
`Case CBM: 2014-00168
`Patent U.S. 7,356,482
`______________________
`
`PETITIONER’S REQUEST FOR REHEARING
`
`
`
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`I.
`
`RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. § 42.71(d), salesforce.com, inc. (“Salesforce”)
`
`requests rehearing of the panel’s February 2, 2015 decision (Paper 10, “Decision”)
`
`declining institution of covered business method review of U.S. Patent No.
`
`7,356,482 (“the ‘482 patent”). Salesforce respectfully submits the panel erred in
`
`concluding Salesforce had not established the ‘482 patent is a “covered business
`
`method patent” pursuant to Section 18(d)(1) of the America Invents Act (“AIA”),
`
`and in particular, erred by applying an incorrect legal standard regarding the basis
`
`for CBM subject matter jurisdiction under Section 18(d)(1). In view of the
`
`exceptional importance of this issue both to this Petition (Paper 2), and to the CBM
`
`process generally, Salesforce respectfully suggests that an expanded panel of the
`
`PTAB consider this request for rehearing. Salesforce further requests the PTAB
`
`grant this Petition, and institute CBM review of claims 1-59 of the ‘482 patent.
`
`II.
`
`SUMMARY
`
`First, the panel’s Decision misapprehended Section 18(d)(1) of the AIA in
`
`requiring that challenged claims must “expressly claim[]” a “particular relation” to
`
`financial products or services. See Decision, at 7.1 More particularly, the panel
`
`erred in interpreting Section 18(d)(1) to support a finding that AIT’s claims are
`
`ineligible for covered business method review because the “claims on their face are
`
`
`1 All emphases herein added, unless otherwise noted.
`
`04554.00001/6555380.5
`
`1
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`directed to technology ‘common in business environments across sectors’ with ‘no
`
`particular relation to the financial services sector.’” Id. Neither Section 18(d)(1),
`
`nor the relevant legislative history, nor previous decisions of the PTAB, suggest
`
`that CBM review is premised upon an analysis that the patent in question must
`
`“expressly claim[]” a “particular relation to the financial services sector.”
`
`The interpretation of Section 18(d)(1) is of exceptional importance to the
`
`present proceeding, other CBM review proceedings, and the CBM review process
`
`generally. This statute defines the very scope of the subject matter jurisdiction of
`
`the PTAB with respect to covered business method review, which Congress
`
`expressly intended be interpreted broadly. This broad view was confirmed by the
`
`Patent Office’s own stated interpretation of 37 C.F.R. § 42.301(a). See infra, at pp.
`
`5-9. Interpretations of this statute that are at odds with the express statutory
`
`language, Congressional intent, and numerous prior PTAB decisions would result
`
`in a significant lack of certainty for the public regarding the PTAB’s role in
`
`connection with such post grant review procedures. As such, Salesforce suggests
`
`that an expanded panel rehear and address the foundational interpretation issues
`
`raised in this Request for Rehearing. See Target Corp. v. Destination Maternity
`
`Corp., IPR2014-00508, Paper 28, at 3-6 (Feb. 12, 2015).
`
`Second, the Decision overlooked Salesforce’s analysis in its Petition of the
`
`claims and specification of the ‘482 patent, which established that the scope of the
`
`04554.00001/6555380.5
`
`2
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`claims, and in particular, claim 1 and 21’s limitation of “a change management
`
`layer for automatically detecting changes that affect an application” and
`
`“dynamically generating an application” explicitly cover a method or apparatus
`
`“for performing data processing or other operations used in the practice,
`
`administration, or management of a financial product or service.”
`
`III. LEGAL STANDARD
`
`A party may request rehearing of a decision by the PTAB declining
`
`institution of a trial where “the party believes the PTAB misapprehended or
`
`overlooked” matters in its decision. 37 C.F.R. § 42.71(d). When rehearing a
`
`decision on a petition to institute CBM review, the PTAB “will review the decision
`
`for an abuse of discretion.” 37 C.F.R. § 42.71(c). An abuse of discretion may be
`
`determined “if a decision is based on an erroneous interpretation of law . . . or if the
`
`decision represents an unreasonable judgment in weighing relevant factors.”
`
`Arnold Partnership v. Dudas, 362 F.3d 1338, 1340 (Fed. Cir. 2004).
`
`IV. ARGUMENT
`
`A. The Panel Applied an Erroneous Interpretation of Section
`18(d)(1) of the AIA
`
`Contrary to the panel’s Decision, neither Section 18(d)(1) nor 37 C.F.R. §
`
`42.301(a) require a petitioner to demonstrate that a patent “expressly claims” a
`
`“particular relation to the financial services sector.” Rather, Section 18(d)(1) states
`
`generally that a “covered business method patent” is “a patent that claims a method
`
`04554.00001/6555380.5
`
`3
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`or corresponding apparatus for performing data processing or other operations used
`
`in the practice, administration, or management of a financial product or service.”
`
`See also 37 C.F.R. § 42.301(a). That is, a patent is eligible for CBM review so
`
`long as it claims “a method or corresponding apparatus for performing data
`
`processing or other operations,” where that method or apparatus can be “used in the
`
`practice, administration, or management of a financial product or service.” Thus,
`
`there is no requirement of an “express” claiming of financial products or services
`
`or a relation to the financial services industry.
`
`The Decision’s interpretation of Section 18(d)(1) diverged from both this
`
`plain statutory language and from the Patent Office’s own interpretation of 37
`
`C.F.R. § 42.301(a). See Petition, at 8. In pertinent part, the Office indicated in its
`
`comments to this regulation that Section 18(d)(1) should be “interpreted broadly,”
`
`such that it would be sufficient to establish that a patent claims technology
`
`“incidental to a financial activity or complementary to a financial activity”:
`
`Comment 1: Several comments suggested that the Office interpret
`“financial product or service” broadly.
`
`Response: . . . [T]he legislative history explains that the definition of
`covered business method patent was drafted to encompass patents
`“claiming activities that are financial in nature, incidental to a
`financial activity or complementary to a financial activity.” 157
`Cong. Rec. S5432 (daily ed. Sept. 8, 2011) (statement of Sen.
`Schumer). This remark tends to support the notion that “financial
`product or service” should be interpreted broadly.
`
`
`04554.00001/6555380.5
`
`4
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`77 Fed. Reg. 157, at 48735.
`
`The Office expressly rejected the view, adopted in the panel’s Decision, that
`
`CBM review is limited to patents claiming subject matter with a “particular relation
`
`to the financial services sector”:
`
`Comment 3: One comment suggested that the Office should clarify
`that the term “financial product or service” should be limited to the
`products or services of the financial services industry. . . .
`
`Response: Such a narrow construction of the term would limit the
`scope of the definition of covered business method patents beyond
`the intent of section 18(d)(1) of the AIA. For example, the legislative
`history reveals that “[t]he plain meaning of ‘financial product or
`service’ demonstrates that section 18 is not limited to the financial
`services industry.” 157 Cong. Rec. S5432 (daily ed. Sept. 8, 2011)
`(statement of Sen. Schumer). This remark tends to support the notion
`that “financial product or service” is not limited to the products or
`services of the financial services industry.
`
`77 Fed. Reg. 157, at 48736.
`
`1.
`
`The Panel Erred in Its Interpretation of the Legislative
`History of the AIA
`
`The panel’s narrow interpretation of Section 18(d)(1) is also inconsistent
`
`with pertinent legislative history regarding the scope of CBM review. In declining
`
`to institute a trial, the panel placed undue (and inappropriate) emphasis on
`
`statements by Sen. Leahy to hold that CBM review is improper for claims which
`
`“on their face are directed to technology ‘common in business environments across
`
`sectors’ with ‘no particular relation to the financial services sector.’” Decision, at
`
`7. This overreliance is inconsistent with relevant authority on statutory
`
`04554.00001/6555380.5
`
`5
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`interpretation, the prior decisions of the PTAB, and the explicit guidance of the
`
`Federal Register.
`
`First, it is not the comments of Sen. Leahy, but the comments of the
`
`coauthors of Section 18 of the AIA, Sen. Charles Schumer and Jon Kyl, that
`
`strongly merit consideration in interpreting Section 18. Ginsburg, Feldman &
`
`Bress v. Fed. Energy Admin., 591 F.2d 717, 722 (D.C. Cir. 1978) (holding that the
`
`“interpretation [that] conforms to statements of … the principal House author of
`
`the Act … is certainly an important principle to be followed when construing the
`
`provisions of the Act.”). Indeed, the panel’s disregard of Sen. Schumer and Sen.
`
`Kyl’s comments in view of Sen. Leahy’s is inconsistent with the PTAB’s past
`
`interpretation of Section 18. See, e.g., JPMorgan Chase & Co. v. Intellectual
`
`Ventures II LLC, CBM2014-00157, Paper 8, at 13 (Jan. 14, 2015) (finding
`
`unpersuasive Patent Owner’s argument that the PTAB should adopt Sen. Leahy’s
`
`statements regarding the “financial product or service” requirement over the
`
`construction of Sen. Schumer); Apple, Inc. v. Sightsound Techs., LLC, CBM2013-
`
`00020, Paper 14, at 11 (rejecting Patent Owner’s characterization of the legislative
`
`history based on Sen. Leahy’s comments).
`
`The relevant legislative intent as expressed in the comments of Sen.
`
`Schumer, and repeatedly cited by the PTAB, confirm that CBM eligibility should
`
`extend to claims that “cover any ancillary activities related to a financial product or
`
`04554.00001/6555380.5
`
`6
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`service, including . . . customer interfaces, Web site management and functionality,
`
`transmission or management of data, [and] customer communications . . . .” 157
`
`Cong. Rec. S1365 (daily ed. March 8, 2011) (Sen. Schumer); Petition, at 8.
`
`
`
`Confirming the relevance of Sen. Schumer’s comments in interpreting
`
`Section 18, the binding regulatory guidance explicitly incorporates his definition of
`
`CBM patents (not any comments by Sen. Leahy), noting that this definition
`
`encompasses “activities that are financial in nature, incidental to a financial
`
`activity or complementary to a financial activity,” and does not require a particular
`
`relationship to “the financial services sector” as set forth in the panel’s reasoning.
`
`CBM Rules, 77 Fed. Reg. 157, at 48735–36 (quoting 157 Cong. Rec. S5432 (daily
`
`ed. Mar. 8, 2011) (statement of Sen. Schumer)).
`
`The AIA’s other coauthor, Senator Jon Kyl, in fact recognized that
`
`determining eligibility for CBM review may even require looking beyond the
`
`patent itself to determine if the patent related to a financial product or service:
`
`Given the protean nature of many business-method patents, it often
`will be unclear on the face of the patent whether it relates to a
`financial product or service. To make such a determination, the
`Office may look to how the patent has been asserted.
`
`157 Cong. Rec. S1379 (daily ed. Mar. 8, 2011) (statement of Sen. Kyl). Again, this
`
`contradicts the panel’s interpretation requiring that a CBM patent “expressly
`
`claim” a financial product or service or relation to the financial services industry.
`
`
`
`04554.00001/6555380.5
`
`7
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`2.
`
`The Panel’s Decision Regarding CBM Eligibility Conflicts
`with Previous PTAB Decisions Interpreting Section 18(d)(1)
`
`The Panel’s interpretation of Section 18(d)(1) requiring “express” claiming
`
`of a financial product or service or a “particular relation to the financial services
`
`sector” also conflicts with numerous prior PTAB decisions.2 In these decisions, the
`
`PTAB concluded that challenged claims were CBM eligible despite not
`
`“expressly” claiming financial activities or any particular relation to the financial
`
`services industry, and indeed encompassed technology “common in business
`
`environments across sectors.” The PTAB instead found eligibility in these
`
`decisions because challenged claims were directed to technology “incidental to a
`
`financial activity or complementary to a financial activity,” or otherwise
`
`encompassed “activities that are financial in nature” in accordance with a literal
`
`interpretation of Section 18(d)(1) and express legislative intent.
`
`In United States Postal Service v. Return Mail, Inc., CBM2014-00116, Paper
`
`11, at 11-12 (Oct. 16, 2014), the PTAB found subject matter eligibility for a patent
`
`related to a method for distributing encrypted data where the challenged claims did
`
`not expressly recite a relationship with or connection to financial services or
`
`products. Id. The PTAB concluded that the “subject matter is financial in nature”
`
`
`2 There is an extraordinary need for the PTAB to resolve this conflict
`between the standard set forth in the panel’s Decision and these other PTAB
`decisions, so that Petitioners and the public know which standard will be applied in
`determining CBM subject matter jurisdiction.
`
`04554.00001/6555380.5
`
`8
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`because it recites “a method for easing the administrative burden” for businesses,
`
`including those in the financial services industry. Id. at 12. The PTAB found the
`
`patent eligible for review, despite its conclusion that the patent is “applicable to
`
`any mail user” who deals with significant returned mail. Id. at 12.
`
`Likewise, in Google Inc. v. Unwired Planet, LLC, CBM2014-00005, Paper
`
`10, at 9-10 (May 9, 2014) (“Unwired Planet”), the PTAB found subject matter
`
`eligibility where the challenged patent claimed a method and system for managing
`
`location information for wireless communications devices, where none of the
`
`challenged claims expressly claimed a connection to financial service, products, or
`
`industry. Id. at 2-4. Instead, the PTAB recognized the specification’s discussion of
`
`the claimed “client application” as being possibly “associated with a service
`
`provider or a goods provider, such as a hotel, restaurant, or store.” Id. at 11. The
`
`PTAB concluded, accordingly, that “the subject matter recited in [the challenged
`
`claim] is incidental or complementary to the financial activity of service or product
`
`sales,” and therefore that subject matter eligibility had been met. Id.
`
`In CRS Advanced Techs, Inc. v. Frontline Techs, Inc., CBM2012-00005,
`
`Paper 17, at 6-8 (Jan. 23, 2013), the PTAB instituted CBM review where the
`
`claims related to a human resource management system using “substitute
`
`fulfillment,” i.e., assigning a replacement worker during a permanent worker’s
`
`absence. The challenged claims were silent as to financial products or services and
`
`04554.00001/6555380.5
`
`9
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`were instead directed to “a plurality of organizations.” Id. at 8. The PTAB
`
`nonetheless concluded that “[n]othing in the statute, its legislative history, or the
`
`rules requires that a covered business method patent include claim elements that
`
`map directly to financial products or services.” Id. The claims, the PTAB noted,
`
`“are broad enough to include substitute fulfillment for retail banks,” and are thus at
`
`least “incidental” and/or “complementary to a financial activity.” Id.
`
`Thus, the PTAB has repeatedly concluded that subject matter eligibility for
`
`CBM review is broader than the standard applied by the panel. See, e.g., Volusion
`
`Inc. v. Versata Software, Inc., CBM2013-00017, Paper 8, at 5-6 (Oct. 24, 2013)
`
`(instituting review where the claims recited a method of hierarchically representing
`
`and arranging items in a database because “a person of ordinary skill in the art
`
`would have understood” that the items displayed “may be associated with financial
`
`services”); Google Inc. v. Inventor Holdings, LLC, CBM2014-00002, Paper 16, at
`
`6-9 (Apr. 1, 2014) (instituting review where the challenged claim, silent as to
`
`financial products or services, related to a method and system for facilitating
`
`anonymous communications and exchange of identities between terminals, routed
`
`through a central controller); Experian Mktg. Solutions, Inc. v. Rpost Commc’ns
`
`Ltd., CBM 2014-00010, Paper 20, at 5-7 (Apr. 22, 2014) (finding the “financial
`
`product or service” requirement met where the claim, silent as to financial products
`
`or services, recited a method of authenticating e-mail messages using digital
`
`04554.00001/6555380.5
`
`10
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`signatures, because the specification “details that the claimed electronic messaging
`
`systems and methods” are directed to “financial, monetary, and commercial
`
`applications”); Google Inc. v. SimpleAir, Inc., CBM2014-00170, Paper 13, at 6-7
`
`(Jan. 22, 2015) (holding that the claim, which recited a method of transmitting data
`
`to selected remote locations, met the “financial product or service” requirement
`
`because the specification “contemplate[d]” using the method for managing a
`
`financial product or service.); Apple, Inc. v. Sightsound Techs., LLC, CBM2013-
`
`00020, Paper 14, at 11-15 (Oct. 8, 2013) (instituting review where the challenged
`
`patent claimed accessing downloadable content after receiving a payment because
`
`a “patent need not be used by a financial services company or involve a traditional
`
`financial services business to qualify as a covered business method patent”); Dell
`
`Inc. v. Disposition Services LLC, CBM2013-00040, Paper 7, at 7-11 (Feb. 5, 2014)
`
`(instituting review where the patent disclosed a surplus asset disassembly and
`
`disposition process because the AIA does not require a “particular relation to the
`
`financial services sector”); Hulu, LLC v. Intertainer, Inc., CBM2014-00053, Paper
`
`11, at 11-12 (June 23, 2014) (finding the “financial product or service” test met
`
`where an embodiment in the specification allowed consumers to purchase items).
`
`As the above decisions further reflect, contrary to the panel’s reasoning, the
`
`PTAB has previously based its holdings on whether a challenged patent is a
`
`covered business method patent through not just an examination of the claims, but
`
`04554.00001/6555380.5
`
`11
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`also explicitly relying on the specification or prosecution history as informing that
`
`inquiry. See, e.g., Experian, CBM 2014-0010, Paper 20, at 5, 7; Hulu, LLC,
`
`CBM2014-00053, Paper 11, at 12; Volusion, CBM2013-00017, Paper 8, at 5;
`
`Google, CBM2014-00170, Paper 13, at 6.
`
`Under the broader standard for eligibility consistently applied in these
`
`decisions, Salesforce demonstrated that, based on the claims and specification, that
`
`the technology of the ‘482 patent claims is at the least “incidental to a financial
`
`activity or complementary to a financial activity.” See infra, Section IV.B;
`
`Petition, at 8-10, 12-19. In applying a narrower standard for eligibility based on a
`
`requirement of “expressly claim[ing]” and a “particular relation” to the financial
`
`services sector, the panel erred in denying the Petition.
`
`B.
`
`The Panel Overlooked The Petition’s Discussion of The Claimed
`Change Management Layer That Manages Changes to Published
`Financial Regulations
`
`The panel did not provide further detail in its Decision as to the requirement,
`
`discussed in Section IV.A, to “expressly” claim a financial product or service.
`
`However, to the extent that the panel’s (erroneous) standard requires claims to
`
`“expressly” encompass such financial embodiments3, the panel erred by
`
`overlooking that the ‘482 patent claims expressly encompass a change management
`
`
`3 To the extent that the panel instead is requiring that challenged claims
`“expressly” recite a financial product, service or relation to the financial services
`sector, as discussed in Section IV, supra, such a standard is clearly erroneous.
`
`04554.00001/6555380.5
`
`12
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`system for managing, inter alia, changes to published financial regulations.
`
`The Petition established that the claims (including claim 1) are directed to a
`
`change management layer for monitoring and detecting changes pertinent to the
`
`operation of a business. See Petition, at 8-19. Claim 1 provides:
`
`1. A system for providing a dynamically generated application …;
`comprising: …
`
`a change management layer for automatically detecting changes that
`affect an application, each client computer further comprising a
`browser application being executed by each client computer, wherein
`a user interface and functionality for the particular application is
`distributed to the browser application and dynamically generated
`when the client computer connects to the server computer.
`
`SFDC 1001, at col. 32; see Declaration of Benjamin B. Bederson, SFDC 1012 ¶ 39
`
`(“Bederson Decl.”) (“The claims of the ‘482 Patent are directed to monitoring,
`
`detecting, and implementing changes in relevant information in the context of an
`
`application generated from information stored in a database”); see id. ¶ 41 (“Claims
`
`1, 21, and 41 each require . . . “a ‘layer’ of a server or a method step that detects
`
`changes that affect an application, and the dynamic generation or regeneration of
`
`an application and its user interface . . . .”); see also Petition, at 4 (“[T]he claims of
`
`the ‘482 Patent are broadly directed to detecting any ‘changes that effect an
`
`application,’ and then generating a user interface incorporating these changes.”) , 4
`
`(“the ‘482 Patent focuses, not on changes of any kind, but on managing changes
`
`specifically to government regulations or to ancillary business requirements related
`
`04554.00001/6555380.5
`
`13
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`to government regulations.”). Notably, the Decision itself recognized the
`
`“correspond[ence]” of the change management layer of claim 1 (i.e., one of the
`
`four layers associated with the server”) with the disclosure of the embodiment of
`
`the change management layer in Fig. 1, which “includes one or more change agents
`
`that ‘cruise the Web’; and identify and bring to the user’s attention relevant
`
`regulatory and non-regulatory changes found on the Web that may affect a user’s
`
`business.” Decision, at 7; SFDC 1001, 9:34-38.
`
`
`
`Salesforce next established, through citation to the claims, specification, and
`
`expert declaration, that this claimed change management layer can be used to
`
`manage regulatory changes affecting a business. Petition, at 13-14 (noting that the
`
`‘482 Patent describes “one integrated system that (1) provides one or more
`
`databases that contain information on operations and requirements concerning an
`
`activity or area of business; (2) monitors and evaluates the relevance of information
`
`on regulatory and non-regulatory changes that affect operations of the business
`
`and/or information management requirements . . . .”) (quoting SFDC 1001, Col.
`
`8:21-36), 18 (quoting ‘482 patent specification: “Other workers have created . . .
`
`partial solutions for tracking changes in, and compliance with, regulations and
`
`similar requirements . . .); Bederson Decl. ¶ 78.
`
`
`
`Salesforce further noted the specification’s disclosure that the claimed
`
`change management layer “monitors, responds to, and incorporates changes in,
`
`04554.00001/6555380.5
`
`14
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`federal, state and local laws, statutes, ordinances and regulations (referred to
`
`collectively herein as ‘regulations’) and changes in technology in one or more
`
`regulated areas of commercial activity.” Petition, at 9. Further, Salesforce
`
`demonstrated that these embodiments are directed towards (a) managing changes in
`
`financial and securities regulations and (b) managing other changes impacting a
`
`business’ finance department. See Petition, at 8-13.
`
`
`
`Salesforce also noted the specification expressly contemplates using the
`
`claimed change management layer in connection with regulatory change in areas
`
`that clearly encompass the financial services sector, i.e., “banking, financial and
`
`securities activities and foreign trade”:
`
`Examples of activities that are regulated by such regulations include: .
`. . banking, financial and securities activities and foreign trade . . .
`commercial trade practices . . . transportation of persons and cargo . .
`. firearms production and trade . . . mining and related activities . .
`. postal service activities . . . telecommunications . . . .
`
`See Petition, at 12; SFDC 1001, at col. 1, lines 16-41. Thus, as set forth in the
`
`Petition, the claims of the ‘482 patent all cover this change management system,
`
`which as disclosed in the specification encompasses management of regulatory
`
`changes in the financial services sector.
`
`V. CONCLUSION
`
`For the foregoing reasons, Salesforce respectfully requests rehearing and
`
`institution of covered business method review of claims 1-59 of the ‘482 patent.
`
`04554.00001/6555380.5
`
`15
`
`
`
`
`
`
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`
`
`
`
`Dated: March 4, 2015
`
`
`
`
`
`Respectfully submitted,
`
`KEVIN P.B. JOHNSON
`
`/Kevin P.B. Johnson/
`Kevin P.B. Johnson
`Registration No. 38,927
`
`04554.00001/6555380.5
`
`16
`
`
`
`
`
`
`
`CBM Review of U.S. Patent No. 7,356,482
`
`
`
`CERTIFICATE OF SERVICE
`
` I
`
` hereby certify that, on March 4, 2015, I caused a true and correct copy of
`
`the foregoing document to be served via FedEx to the below addresses:
`
`Applications in Internet Time LLC
`711 S. Carson St., Ste 4
`Carson City, NV 89701
`
`Steven C. Sereboff (Reg. No. 37,035)
`M. Kala Sarvaiya (Reg. No. 58,912)
`SoCal IP Law Group LLP
`310 N. Westlake Blvd, Ste 120
`Westlake Village, CA 91362
`
`
`
`
`/Kevin P.B. Johnson/
`Kevin P.B. Johnson
`Registration No. 38,927
`
`04554.00001/6555380.5
`
`17