UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________
`
`SAMSUNG ELECTRONICS AMERICA, INC. and
`SAMSUNG ELECTRONICS CO. LTD.,
`Petitioner
`
`and
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SMARTFLASH LLC,
`Patent Owner.
`
`_________
`
`Case CBM2014-001941
`
`Patent 8,118,221 B2
`
`_________
`
`
`
`PATENT OWNER’S REQUEST FOR REHEARING
`
`
`
`
`1 CBM2015-00117 (Patent 8,118,221 B2) was consolidated with this proceeding.
`
`
`
`_________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________
`
`SAMSUNG ELECTRONICS AMERICA, INC. and
`SAMSUNG ELECTRONICS CO. LTD.,
`Petitioner
`
`and
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SMARTFLASH LLC,
`Patent Owner.
`
`_________
`
`Case CBM2014-001941
`
`Patent 8,118,221 B2
`
`_________
`
`
`
`PATENT OWNER’S REQUEST FOR REHEARING
`
`
`
`
`1 CBM2015-00117 (Patent 8,118,221 B2) was consolidated with this proceeding.
`
`
`
`TABLE OF CONTENTS
`
`
`
`INTRODUCTION ........................................................................................... 1
`
`STATEMENT OF PRECISE RELIEF REQUESTED ................................... 2
`
`I.
`
`II.
`
`III. BACKGROUND ............................................................................................. 2
`
`IV. ARGUMENT ................................................................................................... 4
`A.
`Like the Claims in DDR Holdings, Claim 32 Is Patent Eligible
`Because It Teaches a Specific Solution to a Novel Problem Presented
`By Digital Commerce ............................................................................ 5
`B. The Challenged Claim Does Not Resemble the Claims in Alice ....... 10
`1. Claim 32 Is Directed to a Specific Device, Not an Abstract Idea
` ................................................................................................... 10
`2. Claim 32 Contains Numerous “Additional Features” That
`Demonstrate That It Does Not Cover an Abstract Idea ............ 12
`
`CONCLUSION .............................................................................................. 15
`
`
`V.
`
`
`
`i
`
`
`
`I.
`
`INTRODUCTION
`
`The Board’s final written decision in this covered business method patent
`
`review misapprehends the Federal Circuit’s and Supreme Court’s guidance on
`
`patent eligible subject matter under 35 U.S.C. § 101. Claim 32 covers a specific
`
`physical device operating within a novel content delivery system that facilitates
`
`distribution of digital content over the Internet while helping to reduce piracy—a
`
`pressing problem at the time of invention. Claim 32 contains significant and
`
`meaningful limitations which are both inventive and technological, which, when
`
`taken in ordered combination, amount to more than the idea of “conditioning and
`
`controlling access to data based on payment” and do not pre-empt the field.
`
`Furthermore, the claim improves the functioning of computers used to download,
`
`store, and access data, thereby effecting a technological improvement in the
`
`relevant field.
`
`The Board wrongly determined that this claim on a physical device actually
`
`covered an abstract idea and ignored the claim’s specific combination of hardware
`
`and software to hold that the claim contains no inventive concept. Under the
`
`Board’s analysis, any device used in an economic transaction that contains
`
`conventional components would be patent ineligible. This error is exactly what the
`
`Supreme Court cautioned against in Alice. See Alice Corp. Pty. Ltd. v. CLS Bank
`
`Int’l, 134 S. Ct. 2347, 2354 (2014) (warning against “construing this exclusionary
`
`1
`
`
`
`principle [to] swallow all of patent law”). Patent Owner respectfully requests
`
`rehearing to correct these errors. See 37 C.F.R. § 42.71(d).
`
`II.
`
`STATEMENT OF PRECISE RELIEF REQUESTED
`
`Patent Owner requests that the Board reverse its original decision
`
`(Paper 51, March 29, 2016) and hold challenged claim 32 is patent-eligible.
`
`III. BACKGROUND
`
`1.
`
`The opportunities and challenges associated with distribution of
`
`digital content over the Internet “introduces a problem that does not arise” with
`
`content that is distributed on physical media. DDR Holdings, LLC v. Hotels.com,
`
`L.P., 773 F.3d 1245, 125 (Fed. Cir. 2014). By the late 1990s, as a result of
`
`improved data compression and increasing bandwidth for Internet access, content
`
`providers, for the first time, had the ability to offer data for purchase over the
`
`Internet; at the same time, unprotected data files could be easily pirated and made
`
`available “essentially world-wide” without authorization. Ex. 1001, 1:32-33. The
`
`conventional operation of the Internet does not solve this problem: on the
`
`contrary, the Internet facilitates the distribution of data without restriction or
`
`protection. Id. 1:49-55.
`
`Content providers had faced the issue of piracy before—a CD can be copied
`
`onto a cassette tape or onto another CD and the pirated copy sold—but the problem
`
`of widespread distribution of pirated content over the Internet was unprecedented.
`
`2
`
`
`
`There had never before been a way to make free, identical, and flawless copies of
`
`physical media available to millions of people instantaneously at virtually no
`
`incremental cost. See generally Metro-Goldwyn-Mayer Studios, Inc. v. Grokster,
`
`Ltd., 545 U.S. 913, 929-30 (2005). The advent of the Internet thus gave rise to an
`
`urgent need to address the problem of data piracy.
`
`
`
`The inventor devised a data storage and access system for downloading and
`
`paying for data, described in the specification and claimed in this patent and others,
`
`comprising specific elements designed to overcome the problems inherent in
`
`making digital content available over the Internet. Ex. 1001, at 1 (Abstract).
`
`Claim 32 of the ’221 patent is directed to one aspect of that system: namely, a
`
`“data access terminal”—for example, a mobile multi-media player—for “retrieving
`
`data from a data supplier.” Id. at 28:22-25. Related patents cover other aspects of
`
`the system and interactions explained in the specification.
`
`Claim 32 requires the “data access terminal” to be coupled to a “data
`
`carrier,” and to include a “data carrier interface,” a “first interface” for
`
`“communicating with the data supplier,” a “program store,” and a “processor.”
`
`The “program store” on the device stores code that allows the machine to “read
`
`payment data from the data carrier,” “to forward the payment data to a payment
`
`validation system,” to “receive payment validation data” from that system, to
`
`“retrieve data from the data supplier,” to “write the retrieved data into the data
`
`3
`
`
`
`carrier,” to “receive at least one access rule from the data supplier” that is
`
`“responsive to the payment validation data”; and to “retrieve from the data supplier
`
`and output . . . identifier data and associated value data and use rule data.”
`
`
`
`2.
`
`The Board found the challenged claim to be patent ineligible. First,
`
`the Board found (at 9) that the challenged claim was “drawn to a patent-ineligible
`
`abstract idea,” that is, “performing the fundamental economic practice” of
`
`“conditioning and controlling access to content based upon payment.” The Board
`
`also found (at 13) that “the potentially technical elements of the claim are nothing
`
`more than ‘generic computer implementations’ and perform functions that are
`
`‘purely conventional.’” And the Board distinguished DDR Holdings because
`
`“[d]ata piracy exists in contexts other than the Internet,” “the solution provided by
`
`the challenged claim[] is not rooted in specific computer technology” and the
`
`“result does not override[] the routine and conventional use of the recited devices
`
`and functions.” Id. at 15-16.
`
`IV. ARGUMENT
`
`The Board should reverse its decision and find claim 32 directed to statutory
`
`subject matter because, in evaluating whether claim 32 complies with the
`
`requirements of § 101, the Board failed to give effect to the actual language of the
`
`claim and its specific limitations. The actual claim language, read in light of the
`
`specification, reflects a specific and concrete solution to a novel problem
`
`4
`
`
`
`associated with distribution of digital content over the Internet. Such a
`
`technological advance is patent eligible.
`
`A.
`
`Like the Claims in DDR Holdings, Claim 32 Is Patent Eligible
`Because It Teaches a Specific Solution to a Novel Problem
`Presented By Digital Commerce
`1.
`
`Claim 32 of the ’221 patent is patent eligible because it
`
`embodies one concrete aspect of a particular solution to the Internet-specific
`
`problem of digital piracy. This is not a patent that simply claims “use of the
`
`Internet” or a computer to perform an established business method. Cf.
`
`Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709, 716 (Fed. Cir. 2014). This is no
`
`digital telephone book. Cf. Final Written Decision, Paper 51 at 18-19. On the
`
`contrary, the challenged claim limitations reflect specific technical choices: a
`
`“data carrier,” coupled to a “data access terminal,” that includes functionality to
`
`send and receive “payment data” and “payment validation data” from and to the
`
`“data carrier,” and functionality to write access rules into that data carrier.
`
`That particular configuration of elements provides distinct advantages over
`
`alternatives. For example, by storing “payment data” on the data carrier – rather
`
`than (for example) requiring the user to enter payment data manually into the data
`
`access terminal with each purchase – the invention makes purchase of content
`
`convenient and ensures that payment functionality is linked to content storage. Ex.
`
`1001, 4:26-34. By transmitting payment validation data to the data access terminal
`
`5
`
`
`
`and having the terminal retrieve the digital content from the data supplier in
`
`response, the patent inventively allows the same data carrier to be compatible with
`
`independent and integrated validation systems. Id. at 8:63-9:5. By writing onto
`
`the data carrier “access rules,” the invention limits a user’s ability to make
`
`unauthorized copies and allows for different levels of access or rights to
`
`downloaded digital content. Id. at 14:65-15:4. And by storing the access rules on
`
`the data carrier rather than (for example) on the access device, the invention
`
`ensures that a portable data carrier can be used with various access terminals
`
`without losing the ability to control access to the stored data. Indeed, the basic
`
`insight reflected in the claim—that a single data carrier can store content data,
`
`payment data, and access rules and can interface with a data access terminal with
`
`functionality to (1) send, receive, read, and write this data and (2) communicate
`
`with a data supplier and a payment validation system—is itself inventive.
`
`Because claim 32 teaches specific technical solutions to one problem
`
`associated with distribution of digital content through specific organization of
`
`distinct data types, implemented on specific devices, there is no risk that the claim
`
`monopolizes “fundamental economic practice[s],” as the Board held (at 8).
`
`Consequently, there is no concern that recognizing the patent-eligibility of this
`
`claim will “impede innovation” or “improperly t[ie] up . . . building blocks of
`
`human ingenuity,” Alice, 134 S. Ct. at 2354. On the contrary, each challenged
`
`6
`
`
`
`claim teaches a “specific way” to control access to stored digital content based on
`
`payment; the claim does not attempt to “preempt every application of the idea.”
`
`DDR Holdings, 773 F.3d at 1259.
`
`2.
`
`The Board rejected Patent Owner’s reliance on DDR Holdings
`
`(at 15), holding that the challenged claim was not “rooted in computer technology
`
`in order to overcome a problem specifically arising in the realm of computer
`
`networks.”2 That is incorrect: the claim discusses specific computer functions and
`
`interactions, including with data carriers, to perform a defined series of operations.
`
`Indeed, the Board’s own summary of the ’221 patent (at 4) states:
`
`The ’221 patent describes providing portable data storage together
`with a means for conditioning access to that data upon validated
`payment. This combination allows data owners to make their data
`available over the internet without fear of data pirates.
`
`Because the Internet facilitates the “essentially world-wide” distribution of
`
`flawless, identical copies of content data, the piracy problems it creates are
`
`qualitatively different from copying physical media, which necessarily takes time,
`
`imparts imperfections, and imposes incremental costs. See Grokster, Ltd., 545
`
`U.S. at 929-30. Rather than generically claiming use of the Internet to perform an
`
`
`2 Pursuant to 37 C.F.R. § 42.71(d), the issue of whether the challenged claims were
`
`similar to those in DDR Holdings was previously addressed. See PO Resp. 12-13.
`
`7
`
`
`
`abstract business practice, the claim solves problems faced by digital content
`
`providers in the Internet Era, improving the functioning of the computer itself.3
`
`The Board also held (at 17) that the challenged claim contained
`
`limitations—unlike the claims in DDR Holdings—that were “specified at a high
`
`level of generality.” This is incorrect. The challenged claim and the specification
`
`discuss specific data stored in specific places, not mere generalities. There is
`
`“payment data” stored on the data carrier, “payment validation data” received from
`
`a payment validation system and, in response to that data, data is retrieved from a
`
`data supplier. There are “access rules” written into the carrier from that data
`
`supplier and those access rules are dependent on the payment data sent to the
`
`payment validation system. See Ex. 1001 28:31-46. Compare DDR Holdings,
`
`773 F.3d at 1249 (reciting “links,” “source page,” and “web page”). The device
`
`3 Claim 32 does not expressly recite Internet transactions; rather, the claim is
`
`directed to a data access terminal, coupled to a data carrier, and that machine’s
`
`interactions with a data supplier. However, even if not limited to the Internet, the
`
`claim “aris[es] in the realm of computer networks” because it defines an
`
`interaction between computers that solves a technological problem inherent in the
`
`conventional operation of those interactions. The claim is also directed towards an
`
`Internet-specific problem – that is, it offers a way to pay for, store, and control
`
`access to content data that is sold separately from a storage medium.
`
`8
`
`
`
`must thus transfer, receive, and act on different specific data in a particular way.
`
`The claim therefore does not “merely recite the performance of some business
`
`practice known from the pre-Internet world along with the requirement to perform
`
`it on the Internet.” DDR Holdings, LLC, 773 F.3d at 1257. By ignoring these
`
`limitations, the Board erred in holding that there were not “additional features”
`
`present in the challenged claim that made it patent-eligible.
`
`
`
` Finally, the Board held (at 13) that claim 32 could be performed by “a
`
`general-purpose computer.” But, again, this ignores the limitations of the claim,
`
`which, as explained above, requires specific configurations of distinct data types
`
`and defined interactions among system components to facilitate secure access to
`
`data stored on a data carrier. As the specification makes clear, when digital data is
`
`sent over the Internet operating in its normal, expected manner and stored by a
`
`recipient, the content data are insecure; the content owner has no means to exert
`
`further control over access. The claim provides a specific mechanism to ensure
`
`that content, once downloaded and stored, can be accessed only when the access
`
`rule, dependent on the transmitted payment data, confirms that access is
`
`authorized. Just as the claims in DDR Holdings “specif[ied] how interactions with
`
`the Internet are manipulated to yield a desired result,” 773 F.3d at 1258, so too the
`
`claim here specifies how manipulation of specific data facilitates convenient and
`
`secure provision of digital content, a result that neither the conventional Internet
`
`9
`
`
`
`nor unimproved computers can produce. The patent “improve[s] the functioning”
`
`and the functionality of digital media players, which, likewise improves the
`
`functioning of data communications networks used for digital content distribution.
`
`Alice, 134 S. Ct. at 2359.
`
`B. The Challenged Claim Does Not Resemble the Claims in Alice
`
`Claim 32 does not fit the mold of the patent-ineligible claims of Alice. It
`
`does not recite an “abstract idea” and, in any event, teaches a “combination of
`
`elements” that amounts to “significantly more” than any ineligible concept.
`
`1. Claim 32 Is Directed to a Specific Device, Not an Abstract
`Idea
`
`The Board’s determination that claim 32 was directed to an abstract idea is
`
`incorrect because it is directed to a concrete machine with specific hardware and
`
`software components and not merely to the abstract idea of controlling access to
`
`content based on payment. As the Board acknowledged (at 6) “claim 32 recites a
`
`‘machine,’ i.e., a ‘data access terminal” with defined components. It contains an
`
`interface for communicating with a data supplier, a data carrier interface, memory,
`
`and a processor. The machine runs specific software to, among other things, send
`
`payment data, receive payment validation data, and write access rules on to the
`
`10
`
`
`
`data carrier based on the validated payment data. The patent specification
`
`emphasizes that the patent is on a machine. See, e.g., Ex. 1001 at 1:20-28.4
`
`In finding this claimed machine was directed to an abstract idea, the Board
`
`apparently focused on the problem that the machine was designed to solve and
`
`treated the problem itself as the abstract idea to which the claim was directed.
`
`Specifically, the Board held (at 8) that “claim 32 is directed to performing the
`
`fundamental economic practice of controlling access to content based on
`
`payment.”5 But while the claimed machine provides a specific mechanism that can
`
`be used to control access to content based on payment, thus combatting problems
`
`of data piracy, see Ex. 1001, 1:20-2:15, that does not provide a fair description of
`
`the claim, which provides a specific solution to an aspect of the problem.
`
`There is a fundamental difference between claiming a specific device or
`
`method that can be used to accomplish an economic practice and claiming the
`
`practice itself. See Brookhill-Wilk 1, LLC v. Intuitive Surgical, Inc., 326 F.3d
`
`1215, 1223 (Fed. Cir. 2003) (“Advantages described in the body of the
`
`4 The issue of whether the claim 32 is an abstract idea was previously addressed.
`
`See 37 C.F.R. § 42.71(d); PO Resp. 11-28; see also Tr. 46:21-47:11.
`
`5 The Board identified the abstract idea without explaining its methodology, which
`
`itself merits rehearing. Cf. Avago Techs. Gen. IP (Singapore) Pte Ltd. v. Asustek
`
`Comp., Inc., No. 15-cv-04525, at 10-11 (N.D. Cal. Apr. 25, 2016).
`
`11
`
`
`
`specification, if not included in the claims, are not per se limitations . . . .”). As an
`
`example, a cash register is a physical device that is used to perform a fundamental
`
`economic practice, namely, collecting, storing, and tracking payment. A claim on
`
`a specific novel device—with specific circuit boards, keys, and cash drawers—
`
`may be patentable even though a claim on collecting and storing payment itself
`
`would not be. The Board’s decision equates a claim on a machine that may be
`
`used to perform an economic task with a claim on the economic task itself, which
`
`risks turning all devices used in commerce into abstract ideas. This is the problem
`
`that the Supreme Court warned against in Alice. 134 S. Ct. at 2354.
`
`2. Claim 32 Contains Numerous “Additional Features” That
`Demonstrate That It Does Not Cover an Abstract Idea
`
`In any event, the Board was incorrect to find that the challenged claim did
`
`not contain “additional features” to ensure that it was more than a drafting effort
`
`designed to monopolize the abstract idea. On the contrary, because the challenged
`
`claim is not limited to generic computer implementation, it contains an inventive
`
`concept sufficient to establish patent eligibility. 6
`
`Just as the claim does not purport to cover an abstract idea, it also does not
`
`“simply stat[e] an abstract idea while adding the words ‘apply it’ or ‘apply it with a
`
`
`6 The issue of whether the Claim 32 contains “additional features” was previously
`
`addressed. See 37 C.F.R. § 42.71(d); PO Resp. 8-9; 25-36.
`
`12
`
`
`
`computer.’” Versata Development Group, Inc. v. SAP America, Inc., 793 F.3d
`
`1306, 1332 (Fed. Cir. 2015). It is, of course, true that the claimed machine has
`
`several components, including computer code. But these limitations are not merely
`
`instructions to apply the idea of controlling access based on payment; the
`
`limitations specify a way in which the machine pays for, retrieves, and controls
`
`access to stored data to the user. See infra at 3, 5-6. The Board came to a different
`
`conclusion by failing to consider the various claim limitations as an ordered
`
`combination reflecting distinct technological choices and advantages.
`
`The Board held (at 11-13) that each specific limitation was a “generic”
`
`computer component such as a program store or a processor and, with respect to
`
`the claimed software limitations, that claim 32 lacked “any inventive concept …
`
`related to the way these data types are constructed or used.” But that basic
`
`methodology is flawed, because it is not proper to look at individual limitations
`
`and determine if each specified component of the machine is conventional in
`
`isolation. “[I]nventions in most, if not all, instances rely upon building blocks long
`
`since uncovered, and claimed discoveries almost of necessity will be combinations
`
`of what, in some sense, is already known.” KSR Int’l Co. v. Teleflex Inc., 550 U.S.
`
`398, 418-19 (2007). The fact that a machine uses individual well-known pieces
`
`does not mean that the particular combination of elements lacks an inventive
`
`concept. A novel cash register will likely be made of well-known circuitry or
`
`13
`
`
`
`plastics, but that does not mean that the combination is not technological. See
`
`Alice, 134 S. Ct. at 2359 (a claim may be patentable if it “effect an improvement in
`
`any other technology or technical field”).
`
`As explained, the ’221 patent claims a data access terminal used with a data
`
`carrier storing data from a data supplier, payment data, payment validation data,
`
`and access rules. This combination enables (for example) a portable “Smartflash”
`
`card to securely store downloaded content—a technological invention. See Ex.
`
`1001, 24:13-16. Nothing in the Board’s opinion supports its conclusion that this
`
`approach to data storage and access was merely conventional—which, in any
`
`event, should be a question of substantive validity, not patent eligibility.
`
`The Board acknowledged (at 18) that a combination of elements may
`
`provide an inventive concept under the Alice analysis. But in doing so, the Board
`
`not only improperly focused on a single aspect of the invention, it also drew the
`
`wrong conclusion. The Board acknowledged that the claim teaches storing “two
`
`specific types of information—content and the conditions for providing access to
`
`the content – . . . in the same place or on the same storage device.” The Board then
`
`simply pronounced itself “not persuaded” that this particular configuration of data
`
`is “an inventive concept” —no reason given.
`
`Citing two prior art patents, (Exs. 1004, 1005), the Board then asserted that
`
`this idea was known in the prior art. As an initial matter, when looking for an
`
`14
`
`
`
`“inventive concept,” § 101 requires a comparison between the claim limitations
`
`and the proposed abstract idea, not between the claim and all prior art. But, in any
`
`event, even if these isolated prior art references indicate that it was “known” to
`
`“store both content and conditions for providing access to the content” on a device,
`
`this ignores most of the challenged claim. These references hardly prove that this
`
`particular concept, if deployed as part of a novel configuration, is conventional;
`
`just as significant, the reference does not disclose the type of data storage and
`
`manipulation that the ’221 patent claims. On the contrary, both patents teach
`
`having the content owner attach usage rights as part of the content item. Ex. 1004
`
`at 4:40-41 (“Usage rights are attached to digital works . . .”); Ex. 1005, Abstract
`
`(“the owner . . . attaches usage rights to that work”). That makes it impossible to
`
`provide greater access without downloading the content again. By contrast, the
`
`’221 patent, by teaching separate storage of content data items, on the one hand,
`
`and associated use rules on the other, solves this very problem. Thus a comparison
`
`to that prior art actually confirms the patent eligibility of claim 32.
`
`
`
`V. CONCLUSION
`
`The Board should reverse its original decision and hold challenged
`
`claim 32 patent-eligible.
`
`
`
`
`
`15
`
`
`
` /
`
` Michael R. Casey /
`
`
`Michael R. Casey
`Registration No. 40,294
`Davidson Berquist Jackson & Gowdey, LLP
`8300 Greensboro Drive
`Suite 500
`McLean, VA 22102
`Telephone: (571) 765-7705
`Fax: (571) 765-7200
`Email: mcasey@dbjg.com
`Attorney for Patent Owner
`
`
`Dated: April 28, 2016
`
`
`
`
`
`16
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that this PATENT OWNER’S REQUEST
`
`FOR REHEARING in CBM2014-00194 was served, by agreement of the parties,
`
`April 28, 2016 by emailing copies to counsel for the Petitioners as follows:
`
`W. Karl Renner (renner@fr.com)
`Thomas Rozylowicz (rozylowicz@fr.com)
`CBM39843-0007CP1@fr.com
`
`J. Steven Baughman (steven.baughman@ropesgray.com)
`James R. Batchelder (james.batchelder@ropesgray.com)
`Megan Raymond (megan.raymond@ropesgray.com
`ApplePTABService-SmartFlash@ropesgray.com
`
`
` /
`
` Michael R. Casey /
`
`
`Michael R. Casey
`Registration No. 40,294
`Davidson Berquist Jackson & Gowdey, LLP
`8300 Greensboro Drive
`Suite 500
`McLean, VA 22102
`Telephone: (571) 765-7705
`Fax: (571) 765-7200
`Email: mcasey@dbjg.com
`Attorney for Patent Owner
`
`
`
`Dated: April 28, 2016
`
`
`
`17
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
