UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________
`
`APPLE INC., SAMSUNG ELECTRONICS CO. LTD, SAMSUNG
`ELECTRONICS AMERICA, INC., and GOOGLE INC.
`Petitioners,
`
`v.
`
`SMARTFLASH LLC,
`Patent Owner.
`
`_________
`
`Case CBM2015-00032
`
`Patent 8,336,772 B21
`
`_________
`
`
`
`PATENT OWNER’S REQUEST FOR REHEARING
`
`
`
`
`1 Samsung’s challenge to claim 14 of U.S. Patent No. 8,366,772 B2 (the “’772
`Patent”) in CBM 2015-00059 was consolidated with this proceeding. Paper 24, 9.
`Google’s challenge to claims 14 and 22 of the ’772 patent in CBM2015-00132 was
`consolidated with this proceeding. Paper 31, 11; Paper 38, 2-3.
`
`
`
`_________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________
`
`APPLE INC., SAMSUNG ELECTRONICS CO. LTD, SAMSUNG
`ELECTRONICS AMERICA, INC., and GOOGLE INC.
`Petitioners,
`
`v.
`
`SMARTFLASH LLC,
`Patent Owner.
`
`_________
`
`Case CBM2015-00032
`
`Patent 8,336,772 B21
`
`_________
`
`
`
`PATENT OWNER’S REQUEST FOR REHEARING
`
`
`
`
`1 Samsung’s challenge to claim 14 of U.S. Patent No. 8,366,772 B2 (the “’772
`Patent”) in CBM 2015-00059 was consolidated with this proceeding. Paper 24, 9.
`Google’s challenge to claims 14 and 22 of the ’772 patent in CBM2015-00132 was
`consolidated with this proceeding. Paper 31, 11; Paper 38, 2-3.
`
`
`
`
`
`TABLE OF CONTENTS
`
`
`I.
`STATEMENT OF PRECISE RELIEF REQUESTED ................................... 2
`BACKGROUND ............................................................................................. 2
`II.
`III. ARGUMENT ................................................................................................... 4
`Like the Claims in Enfish and DDR Holdings, the Challenged Claims
`A.
`Are Patent Eligible Because They Are Directed to a Specific Solution
`to a Novel Problem Presented by Digital Commerce ........................... 5
`The Challenged Claims Do Not Resemble Those in Alice ................. 10
`1.
`The Challenged Claims Are Directed to Specific Devices, Not
`an Abstract Idea ........................................................................ 11
`The Challenged Claims Contain “Additional Features”
`Demonstrating That They Do Not Cover an Abstract Idea ...... 13
`IV. CONCLUSION .............................................................................................. 15
`
`B.
`
`2.
`
`
`
`i
`
`
`
`
`
`
`
`The Board’s final written decision misapprehends the Federal Circuit’s and
`
`Supreme Court’s guidance on patent eligible subject matter under 35 U.S.C. § 101
`
`and overlooks the Federal Circuit’s decision in Enfish, LLC v. Microsoft Corp., No.
`
`2015-2044 (Fed. Cir. May 12, 2016). The challenged claims are directed to a
`
`novel content delivery system for distributing digital content over the Internet
`
`while reducing piracy—a pressing problem at the time of invention. Like the
`
`claims at issue in Enfish, DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245,
`
`125 (Fed. Cir. 2014), Apple, Inc. v. Mirror World Techs., LLC, Case CBM2016-
`
`00019 (Paper 12 May 26, 2016), and Google Inc. v. ContentGuard Holdings, Inc.,
`
`Case CBM2015-00040 Paper 9 (PTAB June 24, 2015), the inventions improve the
`
`functioning of computers by teaching improved devices and methods for
`
`downloading, storing, and accessing data. “[T]he focus of the claims is on the
`
`specific asserted improvement in computer capabilities” – not on an “‘abstract
`
`idea’ for which computers are invoked merely as a tool.” Enfish, slip op. at 11.
`
`Whether considered at step one or step two of the Alice inquiry, the claims’
`
`specific device elements put them squarely in the realm of patent-eligible subject
`
`matter.
`
`The Board failed to address the claim language and the specific limitations
`
`governing organization and processing of specific data types. By characterizing
`
`the “underlying concept” of the claims (at 12-13) as “conditioning and controlling
`
`
`
`1
`
`
`
`access to content based on, for example, payment … [which] is a fundamental
`
`economic practice long in existence in commerce,” the Board “describe[d] the
`
`claims at . . . a high level of abstraction and untethered from the language of the
`
`claims,” thereby “all but ensur[ing] that the exceptions to § 101 swallow the rule.”
`
`Enfish, slip op. at 9; see also Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 134 S. Ct.
`
`2347, 2354 (2014) (warning against “construing this exclusionary principle [to]
`
`swallow all of patent law”). Patent Owner respectfully requests rehearing to
`
`correct these errors. See 37 C.F.R. § 42.71(d).
`
`I.
`
`STATEMENT OF PRECISE RELIEF REQUESTED
`
`Patent Owner requests that the Board reverse its original decision (Paper 46,
`
`May 26, 2016) and hold that challenged claims 14, 19, and 22 are patent eligible.
`
`II. BACKGROUND
`
`1.
`
`Distribution of digital content over the Internet “introduces a problem
`
`that does not arise” with content distributed on physical media. DDR Holdings,
`
`LLC v. Hotels.com, L.P., 773 F.3d 1245, 125 (Fed. Cir. 2014). By the late 1990s,
`
`improved data compression and increasing bandwidth for Internet access enabled
`
`content providers, for the first time, to offer content data for purchase over the
`
`Internet; at the same time, unprotected data files could be easily pirated and made
`
`available “essentially world-wide.” Ex. 1301, 1:35-36. Conventional operation of
`
`
`
`2
`
`
`
`the Internet does not solve the problem of data piracy: on the contrary, the Internet
`
`facilitates the distribution of data without restriction or protection. Id. 1:52-58.
`
`Content providers faced piracy before—a CD can be copied onto another
`
`CD and the pirated copy sold—but the problem presented by distribution of pirated
`
`content over the Internet was unprecedented. 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
`
`Internet gave rise to an urgent need to address data piracy associated with digital
`
`content distribution over the Internet.
`
`
`
`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 problems inherent in making
`
`digital content available over the Internet and in accessing that content. Ex. 1301,
`
`at 1 (Abstract). The relevant claims of the ’772 patent are directed to two aspects
`
`of that system: a “handheld multimedia terminal” id. 27:55-28:39, and “a data
`
`access terminal for retrieving a content data item from a data supplier and
`
`providing the retrieved data item to a data carrier.” id. 28:55-29:25.
`
`Claim 14 requires the “handheld multimedia terminal,” comprising a
`
`“wireless interface”; “non-volatile memory”; a “program store”; a “processor”; a
`
`
`
`3
`
`
`
`“display”; and code to: (1) request and receive identifier data; (2) request and
`
`receive content information; (3) receive a user selection; (4) transmit payment data
`
`responsive to the user selection; (5) retrieve payment validation data; (6) and
`
`retrieve multimedia content from a data supplier responsive to the payment
`
`validation data. Ex. 1301, 27:55-28:39. Claim 19 requires similar functionality in
`
`a “data access terminal for retrieving a content data item from a data supplier.” Id.
`
`at 28:55-58. Claim 22 depends on claim 19 and adds that the terminal be
`
`“integrated with a mobile communications device and audio/video player.” Id. at
`
`29:33-35.
`
`
`
`2.
`
`The Board found the challenged claims to be patent ineligible. First,
`
`the Board found (at 11) that the challenged claims “are drawn to the abstract idea
`
`of conditioning and controlling access to content based on, for example, payment.”
`
`The Board also found “that the additional elements . . . are field of use limitations
`
`and/or generic features of a computer .” Id. at 13-14. And the Board distinguished
`
`DDR Holdings on the grounds that “data 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 19-20.
`
`III. ARGUMENT
`
`
`
`4
`
`
`
`The Board should reverse its decision in this case and find the claims
`
`directed to statutory subject matter because, in evaluating whether challenged
`
`claims 14, 19, and 22 comply with § 101, the Board failed to give effect to the
`
`actual language of the claims and their specific limitations.2 The actual claim
`
`language, read in light of the specification, reflects a specific and concrete
`
`technical solution to a novel problem associated with distribution of digital content
`
`over the Internet. Such a technological advance is patent eligible.
`
`A. Like the Claims in Enfish and DDR Holdings, the Challenged
`Claims Are Patent Eligible Because They Are Directed to a
`Specific Solution to a Novel Problem Presented by Digital
`Commerce
`
`1.
`
`The claims of the ’772 patent are patent eligible because they embody
`
`concrete aspects of a particular solution to the Internet-specific problem of digital
`
`piracy – “a specific improvement to the way computers operate.” Enfish, slip op.
`
`at 12. 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
`
`
`2 The Board disregarded the text of the claims, using nearly identical language in
`
`all the final written decisions of the covered business method reviews that concern
`
`the patents related to the ’772 patent, even though the challenged claims varied
`
`dramatically in their coverage. See, e.g., CBM2014-00192, CBM2015-00017,
`
`CBM2015-00029.
`
`
`
`5
`
`
`
`F.3d 709, 716 (Fed. Cir. 2014). This is no digital telephone book. Cf. Paper 46, at
`
`22. On the contrary, the challenged claim limitations reflect specific technical
`
`choices involving the storage, transmission, and organization of specific data types.
`
`For example, by sending payment data responsive to a user selection rather
`
`than requiring the user to enter payment data manually into the data access
`
`terminal with each purchase, the invention improves the function of user devices
`
`over prior systems that required separate submission of payment information or
`
`post-use billing. See Ex. 1301, 4:36-38. By transmitting payment validation data
`
`to the data access terminal and retrieving multimedia content responsive to that
`
`validation data, controlling access to the multimedia data in response to the
`
`validation data, the patent inventively allows the same data carrier to be compatible
`
`with independent and integrated validation systems. See id. 8:26-30. “[T]he
`
`claimed solution amounts to an inventive concept for resolving this particular
`
`Internet-centric problem.” DDR Holdings, 773 F.3d at 1259.
`
`The claims teach specific technical solutions to a problem associated with
`
`distribution of digital content through specific organization of distinct data types,
`
`implemented on a specific device. There is no risk that the patents monopolize a
`
`“fundamental economic practice,” as the Board held (at 13). The claims are not
`
`directed to any way of conditioning and controlling access to content but to
`
`specific devices and methods involving a novel organization of designated data
`
`
`
`6
`
`
`
`types. Recognizing the patent-eligibility of these claims will not “impede
`
`innovation” or “improperly t[ie] up . . . building blocks of human ingenuity.”
`
`Alice, 134 S. Ct. at 2354. On the contrary, each claim teaches a “specific way” to
`
`control access to stored digital content; the claims do 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 19),
`
`holding that the challenged claims were not “rooted in computer technology in
`
`order to overcome a problem specifically arising in the realm of computer
`
`networks.”3 That is incorrect: the claim discusses specific computer functions and
`
`interactions to perform a specific series of operations. Indeed, the Board’s own
`
`summary of the ’772 patent (at 4) states:
`
`The ’772 patent describes providing portable data storage together
`with a means for conditioning access to that data upon validated
`payment. . . . This combination of the payment validation means with
`the data storage means allows data owners to make their data
`available over the internet without fear of data pirates.
`
`The specification further explains that the purpose of the invention is to
`
`“make . . . data available . . . over the internet without fear of loss of revenue.” Ex.
`
`
`3 Pursuant to 37 C.F.R. § 42.71(d), whether the challenged claims were similar to
`
`those in DDR Holdings was previously addressed. See PO Resp. 15-27.
`
`
`
`7
`
`
`
`1301, 2:15-19. “The growing prevalence of so-called data pirates” is a problem
`
`that arises by virtue of “increasingly wide use of the internet.” Id. 1:15-17.
`
`Because the Internet facilitates “essentially world-wide” distribution of flawless,
`
`identical copies of digital content data, the data piracy problems it creates are
`
`qualitatively different from the problem of copying of physical media (videotapes,
`
`CDs, software, books), 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 abstract
`
`business practice, the claims solve problems faced by digital content providers in
`
`the Internet Era and teach “an improvement to computer functionality itself.”
`
`Enfish, slip op. at 12; Mirror Worlds, Paper 12, at 15. Another panel of the PTAB
`
`reached the same conclusion in refusing to initiate a CBM review of another patent
`
`involving digital rights management in ContentGuard. That patent claimed a
`
`method and system for transferring rights associated with an item, involving
`
`obtaining a “meta-right” specifying a right that can be created when the meta-right
`
`is exercised and determining, by a repository, whether the consumer is entitled to
`
`the right specified by the meta-right. Although it found that the claims involved no
`
`novel technological feature, the panel nevertheless held that, rather than merely
`
`reciting a “fundamental economic or longstanding commercial practice,” the
`
`claims “are directed to a particular way of creating and enforcing rights
`
`
`
`8
`
`
`
`associated with digital works that is ‘necessarily rooted in computer technology’
`
`and ‘specifically arises in the realm of computer networks.’” ContentGuard, Paper
`
`9, at 29 (emphasis added). And the panel also found that “implementation of
`
`digital rights management required by the challenged claims . . . is specific enough
`
`that it does not preempt all other ways of ensuring that an owner of a digital work
`
`can enforce the rights associate therewith.” Id. That same analysis applies here.
`
`The Board also held (at 20) that the challenged claims contained
`
`limitations—unlike the claims in DDR Holdings—that were “specified at a high
`
`level of generality.” But the challenged claims and the specification discuss a
`
`specific organization of data types to carry out transactions according to a
`
`particular scheme, not mere generalities. “Payment data,” “payment validation
`
`data” and “code responsive to payment validation data to retrieve . . . multimedia
`
`content” and are at least as specific as the claims terms in DDR Holdings. See 773
`
`F.3d at 1249 (reciting “link,” “source page,” “commerce object,” and “visually
`
`perceptible elements”).
`
`
`
` Finally, the Board held (at 17) that the claims could be performed by “a
`
`general purpose computer.” But that is generally true of software inventions, and
`
`“[s]oftware can make non-abstract improvements to computer technology just as
`
`hardware improvements can.” Enfish, slip op. at 11. These claims teach a specific
`
`scheme for validating payment, and storing payment data and content data
`
`
`
`9
`
`
`
`governing access on a terminal and using those data types to control and condition
`
`access to content data according to a specific transaction sequence. As the
`
`specification explains, when digital data is sent over the Internet operating in its
`
`normal, expected manner and stored by a recipient, the content owner has no
`
`means to exert further control over access to downloaded content. The claims
`
`provide a specific mechanism to ensure that content, once downloaded, can be
`
`accessed only in accordance with associated access control responsive to payment
`
`validation data. Just as the claims in DDR Holdings “specify how interactions with
`
`the Internet are manipulated to yield a desired result,” 773 F.3d at 1258, the claims
`
`here specify how manipulation of specific data types facilitates convenient and
`
`secure provision of digital content, a result that neither the Internet nor unimproved
`
`computers can produce. See Enfish, slip op. at 15; ContentGuard, Paper 9, at 29.
`
`The patent “improve[s] the functioning” and the functionality of data access
`
`terminals and data carriers, which likewise improves the functioning of data
`
`communications networks used for digital content distribution. Alice, 134 S. Ct. at
`
`2359.
`
`
`
`B.
`
`The Challenged Claims Do Not Resemble Those in Alice
`
`The claims do not fit the mold of the patent-ineligible claims of Alice. They
`
`do not recite an “abstract idea” and, in any event, teach a specific “combination of
`
`elements” that amounts to “significantly more” than any ineligible concept.
`
`
`
`10
`
`
`
`1.
`
`The Challenged Claims Are Directed to Specific Devices,
`Not an Abstract Idea
`
`The Board’s determination that the claims were directed to an abstract idea
`
`is incorrect because the claims are directed to a concrete machine with specific
`
`hardware and software components and not merely to the abstract idea of
`
`controlling access to content.4 As the Board acknowledged (at 9) the claims at
`
`issue “fall into the machine category” under § 101. The claims involve the use of
`
`specific software to read and transmit payment data; receive payment validation
`
`data; retrieve multimedia content data; and write it to non-volatile memory.
`
`The Board apparently focused on the problem the inventions were designed
`
`to solve and treated that problem as the abstract idea to which the claims were
`
`directed. Thus, the Board held (at 12-13) that “the underlying concept of claims
`
`14, 19, and 22 . . . is conditioning and controlling access to content based on, for
`
`example, payment. . . . [T]his is a fundamental economic practice long in
`
`existence in commerce.” But while the claims provide a specific mechanism that
`
`can be used to condition and control access to content, thus combatting problems
`
`
`4 Pursuant to 37 C.F.R. § 42.71(d), the issue of whether the claims are directed to
`
`patent eligible subject matter was previously addressed. See PO Resp. 15-34.
`
`Enfish makes clear that arguments concerning whether claims are directed to an
`
`abstract idea are also relevant to step two of the Alice framework. Slip op. 18.
`
`
`
`11
`
`
`
`of data piracy, see Ex. 1301, 1:15-42, that does not fairly describe the claims,
`
`which, as explained, provide a specific solution to an aspect of the problem of
`
`piracy of digital content distributed over the Internet. See Enfish, slip op. at 14-15;
`
`Mirror World, Paper 12 at 17; ContentGuard, Paper 9 at 29.
`
`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. As an example, all relational databases address the problem of
`
`“storing, organizing, and retrieving memory in a logical table” or “organizing
`
`information using tabular formats.” See Enfish, slip op. at 14. Nevertheless, a
`
`claim that teaches a specific way to store and organize information may be
`
`patentable even though a claim on storing and organizing data itself would not be.
`
`Compare Enfish, slip op. at 14, with In re: TLI Comm’ns LLC Patent Litig., No.
`
`2015-1372, et al., slip op. at 10 (Fed. Cir. May 17, 2016) (patent directed to
`
`“abstract idea of classifying and storing digital images in an organized manner”).
`
`The Board’s decision equates a claim on a specific way to control and condition
`
`access to content with a claim on the economic task itself, which risks turning all
`
`software into patent-ineligible abstract ideas. This is the problem that Enfish and
`
`Alice warned against. “At some level, all inventions ... embody, use, reflect, rest
`
`upon, or apply laws of nature, natural phenomena, or abstract ideas. Thus, an
`
`
`
`12
`
`
`
`invention is not rendered ineligible for patent simply because it involves an
`
`abstract concept.” Alice, 134 S. Ct. at 2354; see Enfish, slip op. at 10.
`
`2.
`
`The Challenged Claims Contain “Additional Features”
`Demonstrating That They Do Not Cover an Abstract Idea
`
`The Board was incorrect to find that the challenged claims did not contain
`
`“additional features” to ensure that they were more than a drafting effort designed
`
`to monopolize the abstract idea. On the contrary, because the challenged claims
`
`are not limited to generic computer implementation, they contain an inventive
`
`concept sufficient to establish patent eligibility.5
`
`The challenged claims do not “simply stat[e] an abstract idea while adding
`
`the words ‘apply it’ or ‘apply it with a computer.’” Versata Development Group,
`
`Inc. v. SAP America, Inc., 793 F.3d 1306, 1332 (Fed. Cir. 2015). True, the claims
`
`depend on software code. But the claims specify a way to control and condition
`
`access to content. They do not claim the general idea of controlling access to
`
`content. The Board concluded otherwise by failing to consider the various claim
`
`limitations as an ordered combination reflecting distinct technological choices and
`
`advantages. See also Enfish, slip op. at 11; Mirror World, Paper 12, at 17 (“the
`
`
`5 Pursuant to 37 C.F.R. § 42.71(d), the issue of whether the challenged claims
`
`contain “additional features” beyond an abstract idea was previously addressed.
`
`See PO Resp. 27; see also, id. at 4-9.
`
`
`
`13
`
`
`
`claims are not directed generically to organizing and storing data but instead to the
`
`particular use” of types of data).
`
`The Board held (at 17) that each specific limitation constituted a “generic
`
`computer implementation[]” and “perform functions that are ‘purely
`
`conventional.’” 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. See Mirror World, Paper 12, at 15
`
`(Petitioner’s analysis “is flawed” because it “should consider the claims as a
`
`whole”). “[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).
`
`As explained above, the ’772 patent claims a “handheld multimedia
`
`terminal” and a “data access terminal” for retrieving a content data item from a
`
`data supplier, and allowing retrieval of that data according to a novel and non-
`
`obvious organization of payment data, payment validation data, and multimedia
`
`content data. The Board’s conclusion that this approach to data storage and access
`
`was merely conventional is unsupported and incorrect. The Board acknowledged
`
`(at 21-23) that a combination of elements may provide an inventive concept and
`
`acknowledged that the claims teach storing “two specific types of information—
`
`
`
`14
`
`
`
`content and the conditions for providing access to the content – . . . in the same
`
`place or on the same storage device.” But the Board overlooked the storage of
`
`payment data, which enhances user convenience, and use of payment validation
`
`data, which reduces risk of non-payment. Instead, the Board simply stated that it
`
`was “not persuaded” that this particular configuration of data is “an inventive
`
`concept.”
`
`The Board also asserted that this idea was known in the prior art, citing U.S.
`
`Patent No. 5,629,980 (Ex. 1315). But this hardly suggests that a particular
`
`concept, deployed as part of a novel configuration, is conventional. Moreover, the
`
`reference does not disclose the data storage and manipulation that the ’772 patent
`
`claims. On the contrary, the cited art teaches having the content owner include a
`
`time bomb – which would destroy or alter the data – as part of the content item.
`
`See Ex. 1315, 10:26 (“rental products are formatted to include a time bomb”)
`
`(emphasis added). That makes it impossible to provide greater access without
`
`downloading the content again. By contrast, the ’772 patent solves this very
`
`problem by teaching separate storage of content data, on the one hand, and
`
`associated access control responsive to payment validation data on the other.
`
`Thus, a comparison to that prior art actually confirms the patent eligibility of the
`
`claims.
`
`IV. CONCLUSION
`
`
`
`15
`
`
`
`The Board should reverse its original decision and hold challenged
`
`claims 14, 19, and 22 are patent eligible.
`
` /
`
` 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: June 27, 2016
`
`
`
`
`
`
`
`16
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that this PATENT OWNER’S REQUEST
`
`FOR REHEARING in CBM2015-00032 was served today by emailing a copy to
`
`counsel for the Petitioners as follows:
`
`J. Steven Baughman (steven.baughman@ropesgray.com)
`Megan Raymond (megan.raymond@ropesgray.com)
`James R. Batchelder (james.batchelder@ropesgray.com)
`ApplePTABService-SmartFlash@ropesgray.com
`Attorneys for Petitioner Apple Inc.
`
`Raymond Nimrod (raynimrod@ quinnemanuel.com)
`QE-SF-PTAB-Service@quinnemanuel.com
`Attorneys for Petitioner Google Inc.
`
`Walter Renner &Thomas Rozylowicz (axf@fr.com)
`39843-0008CP3@fr.com
`Attorneys for Petitioners Samsung Electronics Co., Ltd. and Samsung Electronics
`America, Inc.
`
`
`
`
`
`
`
`Dated: June 27, 2016
`
` /
`
` 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
`
`17
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