Paper No.
` Filed: September 23, 2016
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`IBG LLC; INTERACTIVE BROKERS LLC;
`TRADESTATION GROUP, INC.; TRADESTATION SECURITIES, INC.;
`TRADESTATION TECHNOLOGIES, INC.; and
`IBFX, INC.
`
`Petitioners
`v.
`
` TRADING TECHNOLOGIES INTERNATIONAL, INC.
`
`Patent Owner
`_________________
`Case CBM2015-00179
`U.S. Patent 7,533,056
`_________________
`
`
`
`PATENT OWNER’S MOTION TO EXCLUDE
`UNDER 37 C.F.R. 42.64(C)
`
`
`
`
`
`
`
`
`
`
` Filed: September 23, 2016
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`IBG LLC; INTERACTIVE BROKERS LLC;
`TRADESTATION GROUP, INC.; TRADESTATION SECURITIES, INC.;
`TRADESTATION TECHNOLOGIES, INC.; and
`IBFX, INC.
`
`Petitioners
`v.
`
` TRADING TECHNOLOGIES INTERNATIONAL, INC.
`
`Patent Owner
`_________________
`Case CBM2015-00179
`U.S. Patent 7,533,056
`_________________
`
`
`
`PATENT OWNER’S MOTION TO EXCLUDE
`UNDER 37 C.F.R. 42.64(C)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`TABLE OF CONTENTS
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`I. Preliminary Statement ....................................................................................... 1
`II. Standard ............................................................................................................... 1
`III. TSE (Ex. 1003) Should Be Excluded ............................................................... 1
`A. TT Timely Objected to TSE, Which Was Relied Upon in
`Petitioners’ Petition .......................................................................................... 1
`B. TSE Has Not Been Authenticated under FRE 901 .......................... 2
`i. The 2005 Kawashima Deposition Testimony is Hearsay ............. 2
`ii. The residual hearsay exception of FRE 807 applies to both the
`2005 Kawashima deposition and Patent Owner’s evidence from district
`court litigation .............................................................................................. 3
`iii. Even if the 2005 Kawashima Deposition Testimony was
`admissible, the deposition testimony raises more doubt than it resolves. ... 6
`IV. Certain Deposition Testimony of TT’s Experts Dan Olsen (Ex. 1059) and
`Christopher Thomas (Ex. 1060) Should be Excluded .......................................... 8
`A. TT Timely Objected to the Deposition Testimony, Which Was
`Relied Upon in Petitioners’ Reply .................................................................. 8
`B. The Probative Value of the Testimony at Pages 57 and 58 of the
`Olsen Transcript is Outweighed by a Danger of Prejudice and Confusing
`the Issues under FRE 403 ................................................................................ 9
`C. The Probative Value of the Testimony at Pages 248 and 263-269
`of the Thomas Transcript is Outweighed by a Danger of Prejudice and
`Confusing the Issues under FRE 403 ...........................................................10
`
`
`
`
`
`ii
`
`
`
`
`Preliminary Statement
`
`I.
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`Pursuant to 37 C.F.R. §§ 42.64(c) and 42.61(a) and the Federal Rules of
`
`Evidence, Patent Owner Trading Technologies International, Inc. (“TT”), moves to
`
`exclude TSE (Ex. 1003), because Petitioners have failed to meet the authentication
`
`requirements of FRE 901 and because the only purportedly authenticating evidence
`
`(Ex. 1007, the transcript of a 2005 deposition of Atshushi Kawashima) is hearsay
`
`under FRE 801.
`
`In addition, TT moves to exclude certain deposition testimony of TT’s
`
`experts Dan Olsen (Ex. 1059) and Christopher Thomas (Ex. 1060) under FRE 403
`
`because its probative value is substantially outweighed by a danger of unfair
`
`prejudice and confusing the issues as the result of vague questioning.
`
`II.
`
`Standard
`
`A Motion to Exclude must (a) identify where in the record the objection was
`
`made, (b) identify where in the record the evidence sought to be excluded was
`
`relied upon by an opponent, (c) address objections to exhibits in numerical order,
`
`and (d) explain the objection. Trial Practice Guide, 77 Fed. Reg. 48,756, 48,767
`
`(Aug. 14, 2012).
`
`III. TSE (Ex. 1003) Should Be Excluded
`A. TT Timely Objected to TSE, Which Was Relied Upon in
`Petitioners’ Petition
`
`TT timely objected to Exhibit 1003 in objections filed March 9, 2016.
`
`1
`
`
`
`
`Paper 30 at 3-4. Petitioners rely upon TSE (Ex. 1003) in their Petition for some
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`instituted prior art grounds and indirectly for their 35 U.S.C. § 101 grounds via a
`
`reference to the prior art grounds. E.g., Petition, Paper 9 at 27 and 38-60.
`
`TSE Has Not Been Authenticated under FRE 901
`
`B.
`To satisfy the requirement of authenticating or identifying an item of
`
`evidence, the proponent must produce evidence sufficient to support a finding that
`
`the item is what the proponent claims it is. FRE 901(a). Petitioners have produced
`
`no such evidence to support a finding that TSE is authentic, relying solely on
`
`Exhibit 1007, the transcript of a 2005 deposition of Atshushi Kawashima, which is
`
`insufficient in multiple respects.
`
`i.
`
`The 2005 Kawashima Deposition Testimony is
`Hearsay
`
`The only evidence that even attempts to authenticate TSE is Exhibit 1007,
`
`the transcript of the 2005 Kawashima deposition. See Ex. 1010, pp. 97-99. The
`
`2005 Kawashima deposition was conducted in a district court case, not any of the
`
`CBM proceedings. Ex. 1007 at 1. As a result, the 2005 Kawashima deposition is,
`
`by definition, hearsay.
`
`FRE 801 defines hearsay as “a statement that: (1) the declarant does not
`
`make while testifying at the current trial or hearing; and (2) a party offers in
`
`evidence to prove the truth of the matter asserted in the statement.” Since
`
`2
`
`
`
`
`testimony by Mr. Kawashima in the district court case was not made “while
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`testifying at the current trial or hearing,” to the extent such testimony is used to
`
`prove the authenticity of TSE, it must be considered hearsay.
`
`ii.
`
`The residual hearsay exception of FRE 807 applies to
`both the 2005 Kawashima deposition and Patent
`Owner’s evidence from district court litigation
`
`However, just like Patent Owner’s evidence from district court litigation
`
`(e.g., Ex. 2223 (trader declarations), etc.), the 2005 Kawashima deposition
`
`transcript should not be excluded as hearsay. “Hearsay is generally inadmissible
`
`because ‘the statement is inherently untrustworthy: the declarant may not have
`
`been under oath at the time of the statement, his or her credibility cannot be
`
`evaluated at trial, and he or she cannot be cross-examined.’” United States v.
`
`Reilly, 33 F.3d 1396, 1409 (3d Cir. 1994); see also Queen v Hepburn, 11 U.S. 290
`
`(1813). These concerns are not present with respect to the 2005 Kawashima
`
`deposition transcript.
`
`Although no exception under FRE 803 or FRE 804 applies, the residual
`
`hearsay exception of FRE 807 applies to both Patent Owner’s evidence from
`
`district court litigation and the 2005 Kawashima deposition transcript because the
`
`parties in this proceeding had the opportunity to cross examine the witnesses from
`
`the district court litigation.
`
`FRE 807 requires:
`
`3
`
`
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`
`a. the statement has equivalent circumstantial guarantees of
`trustworthiness;
`b. it is offered as evidence of a material fact;
`c. it is more probative on the point for which it is offered than any
`other evidence that the proponent can obtain through reasonable
`efforts; and
`d. admitting it will best serve the purposes of these rules and the
`interests of justice.
`
`Just like Patent Owner’s evidence from district court litigation, Mr. Kawashima’s
`
`2005 deposition transcript satisfies each of these requirements.
`
`This is similar to the circumstances in the recently decided Apple v. VirnetX.,
`
`IPR2015-00811, Paper No. 44. In that case, the Board denied a motion to exclude
`
`declaration testimony from another proceeding as hearsay. Id. at 68-70.
`
`Specifically, the Board noted that “[t]he vast majority of testimony in inter partes
`
`reviews is admitted in paper form, as a declaration, instead of as live witness
`
`testimony. Thus, whether or not testimony is specifically created for a specific IPR
`
`or is created for another proceeding, if the declaration is sworn testimony and the
`
`witness is available for cross-examination, the testimony bears the same guarantees
`
`of trustworthiness.” Id. at 69-70. With this in mind, the Board found that the
`
`residual hearsay exception of FRE 807 applied to the declaration testimony. Id.
`
`at 69.
`
`4
`
`
`
`
`Likewise, here, both Patent Owner’s evidence from district court litigation
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`and the Kawashima 2005 deposition transcript are sworn testimony regarding
`
`material facts. Indeed, both are from district court litigation, where they were
`
`subject to the Federal Rules of Evidence, just like in this proceeding, and thus have
`
`equivalent circumstantial guarantees of trustworthiness.
`
`Patent Owner’s evidence from district court litigation differs from the
`
`Kawashima 2005 deposition transcript only in that Patent Owner exerted greater
`
`efforts to obtain better evidence than Petitioners. Patent Owner attempted to bring
`
`in alternative evidence through depositions in this proceeding but such efforts were
`
`opposed by Petitioner and denied by the Board. See Paper No. 54 at 2-5. Admitting
`
`Patent Owner’s evidence from district court litigation thus serves the interests of
`
`justice and does not undermine the rule on hearsay, because Patent Owner was
`
`precluded from accessing other evidence after exerting reasonable efforts and
`
`Petitioners were not prejudiced because they could have deposed Patent Owner’s
`
`witnesses here if they wanted to.
`
`In contrast, Petitioners did not make reasonable efforts to obtain new
`
`nonhearsay evidence authenticating TSE. Instead, Petitioners fought against Patent
`
`Owner’s efforts to obtain new nonhearsay evidence by opposing Patent Owner’s
`
`request to depose Mr. Kawashima in these proceedings. See Paper No. 39 (Board
`
`deciding it is Petitioner’s responsibility to secure availability of Kawashima).
`
`5
`
`
`
`
`Although Patent Owner was eventually able to depose Mr. Kawashima in
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`these proceedings, that does not differentiate the Kawashima 2005 deposition
`
`transcript from Patent Owner’s evidence from district court litigation. Petitioners
`
`could have likewise deposed the witnesses on which Patent Owner relies here but
`
`simply chose not to do so.
`
`Accordingly, Patent Owner’s evidence from district court litigation and the
`
`2005 Kawashima deposition transcript should stand or fall together. To the extent
`
`the Board excludes any of Patent Owner’s evidence from district court litigation,
`
`which it should not, the Board should likewise exclude the 2005 Kawashima
`
`deposition transcript.1
`
`iii.
`
`Even if the 2005 Kawashima Deposition Testimony
`was admissible, the deposition testimony raises more
`doubt than it resolves.
`
`Rather than supporting a finding under FRE 901(a) that TSE is what
`
`Petitioners claim it is, the 2005 Kawashima deposition transcript ultimately raises
`
`additional doubts as to the authenticity of the document.
`
`
`1 TT timely objected to Exhibit 1007, the 2005 Kawashima deposition
`
`transcript, in objections filed March 21, 2016. Paper 30 at 2. Petitioners rely upon
`
`the 2005 Kawashima deposition transcript in their Petition to establish that TSE is
`
`prior art. E.g., Petition, Paper 9 at 21-22.
`
`6
`
`
`
`
`For example, in the deposition, Mr. Kawashima draws a conclusion about
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`the authenticity of TSE, a document of hundreds of pages, based on the perceived
`
`absence of a mark in “looking briefly through” the document. Specifically, he
`
`testified:
`
`Q Is this entire document, this document identified as Defendant’s
`Exhibit 179, from August 24 of 1998?
` A Yes.
`Q How do you know?
`
`
` Because when we replace sections there is a mark indicating a
`correction at the bottom of the page. And just looking briefly through
`this document, I didn’t see that mark and therefore I thought that was
`the original date.
` Ex. 1007, pp. 97-98.
`
` A
`
`Further, when asked how one would know if a distributed manual were the
`
`same as a particular copy, Mr. Kawashima merely makes the conclusory assertion
`
`that a comparison would reveal whether a distributed copy were the same, without
`
`any detail as to how such a comparison would be carried out how what level of
`
`scrutiny might be required. Specifically, he testified:
`
`Q Is there any way to tell that the manual that was distributed is the
`same as Defendant's Exhibit 179?
`A If you were to compare this with the distributed manual you would
`be able to tell.
`
`7
`
`
`
`
`Ex. 1007, p. 99.
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`Finally Mr. Kawashima’s testimony cannot be relied upon as to
`
`authentication because he is not a disinterested witness. As noted in Patent
`
`Owner’s Response, Kawashima’s employer—the Tokyo Stock Exchange—
`
`challenged TT’s Japanese counterpart to U.S. Patent No. 6,766,304, which was
`
`asserted in the litigation in which Kawashima previously testified. Paper No. 77 at
`
`40-41. Moreover, at his deposition in the current proceeding, when Mr.
`
`Kawashima was asked if he was attending voluntarily, he answered that he was
`
`present at the direction of the Tokyo Stock Exchange. Exhibit 2163, p. 9. Further,
`
`he acknowledged that he “did a practice run or went through anticipated questions
`
`that might come out” with Petitioners counsel Lori Gordon and Natalie Morgan.
`
`Id. at pp 11-12.
`
`In view of the above, Petitioners have not produced evidence sufficient to
`
`support a finding that TSE is what Petitioners claim it is. TSE should thus be
`
`excluded.
`
`IV. Certain Deposition Testimony of TT’s Experts Dan Olsen (Ex. 1059)
`and Christopher Thomas (Ex. 1060) Should be Excluded
`A. TT Timely Objected to the Deposition Testimony, Which Was
`Relied Upon in Petitioners’ Reply
`
`TT timely objected to Exhibit 1059 during the deposition. Ex. 1059 at 57-58.
`
`TT also timely objected to Exhibit 1060 during the deposition. Ex. 1060 at 393-
`
`8
`
`
`
`
`397. Petitioners rely upon pages 57 and 58 of the Olsen deposition transcript (Ex.
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`1059) and pages 248 and 263-269 of the Thomas deposition transcript (Ex. 1060)
`
`in their Reply for their 35 U.S.C. § 101 grounds. Reply, Paper 110 at 5.
`
`B.
`
`The Probative Value of the Testimony at Pages 57 and 58 of the
`Olsen Transcript is Outweighed by a Danger of Prejudice and
`Confusing the Issues under FRE 403
`
`The answers at page 57 and 58 were in response to vague and ambiguous
`
`questions yielding irrelevant testimony that Petitioners are using in a confusing and
`
`misleading manner to imply that the claimed inventions do not improve computers.
`
`18 Q. Okay. Does the GUI in Figure 3 make
`19 the computer run faster?
`20 A. That's not the improvement claimed.
`21 Q. I'm asking. That's the question I'm
`22 asking.
`1 A. It does not.
`2 Q. Does it allow the computer to use less
`3 energy?
`4 MS. KURCZ: Objection, form.
`5 BY MR. SOKOHL:
`6 Q. Does the GUI in Figure 3 allow the
`7 computer to use less energy?
`8 A. That is not one of the claimed
`9 improvements, no.
`10 Q. Does the GUI in Figure 3 make the
`11 computer more efficient relative to the network?
`
`9
`
`
`
`
`12 A. That's not one of the claimed
`13 improvements, no.
`Ex. 1059 at 57:18-58:13. Rather than admitting the claimed inventions do not
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`improve computers, Mr. Olsen was simply stating what was not explicitly recited
`
`by the claims. The probative value of this testimony is thus substantially
`
`outweighed by a danger of unfair prejudice and confusing the issues as the result of
`
`vague questioning. Accordingly, it should be excluded under FRE 403.
`
`C. The Probative Value of the Testimony at Pages 248 and 263-269
`of the Thomas Transcript is Outweighed by a Danger of Prejudice
`and Confusing the Issues under FRE 403
`
`The answers at page 248 and 263-269 were in response to vague and
`
`ambiguous questions yielding irrelevant testimony that Petitioners are using in a
`
`confusing and misleading manner to imply that the claimed inventions do not
`
`improve computers.
`
`15 Q. It does have to do with the patent.
`16 Does Claim 1 recite a GUI? What
`17 does Claim 1 recite? If you're going to just
`18 repeat the claim, that's fine. But do you have a
`19 generalization for what Claim 1 recites?
`20 A. A GUI tool.
`21 Q. Okay. Does the GUI tool of Claim 1
`22 cause the recited computer from Claim 1 to process
`1 data faster than a Figure 2 type GUI tool?
`2 MR. GANNON: Object to the form,
`
`10
`
`
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`
`3 scope.
`4 THE WITNESS: This isn't about
`5 processing data. There's nothing claiming
`6 processing data.
`7 BY MR. SOKOHL:
`8 Q. Okay. Does it make the computer more
`9 efficient?
`10 A. There's nothing claiming to make the
`11 computer -- well, first of all, you have to define
`12 what making the computer more efficient is.
`13 Q. Well, does it make it more
`14 efficient -- does it make the computer more
`15 efficient in any way?
`16 MR. GANNON: Object to the form.
`17 BY MR. SOKOHL:
`18 Q. Does the GUI tool of Claim 1 make the
`19 computer more efficient in any way?
`20 MR. GANNON: Object to the form.
`21 THE WITNESS: The elements of Claim 1
`22 do not relate to making the computer more
`1 efficient. That's not what is described in all of
`2 the elements of Claim 1.
`3 BY MR. SOKOHL:
`4 Q. Does the GUI tool of Claim 1 make the
`5 computer more reliable?
`6 MR. GANNON: Object to the form.
`
`11
`
`
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`
`7 THE WITNESS: Again, my answer is
`8 going to be similar.
`9 The elements of Claim 1 have
`10 nothing to do with making a computer more
`11 reliable. The elements of Claim 1 claim a new
`12 type of GUI tool that has previously not been
`13 described.
`14 BY MR. SOKOHL:
`15 Q. Okay. Does the computer in Claim 1
`16 include a memory, if you know?
`17 MR. GANNON: Object to the form,
`18 scope.
`19 THE WITNESS: It doesn't relate,
`20 again, for the same reason my answer is going to
`21 be that the claims, the elements of Claim 1 do not
`22 relate to the memory of a computer, and they
`1 relate, they describe the structure, makeup, and
`2 function of a GUI tool.
`3 BY MR. SOKOHL:
`4 Q. If I was to ask you whether or not the
`5 GUI tool of Claim 1 made a memory as part of a
`6 computer more efficient or reliable or processed
`7 data faster, would your answer be the same as it
`8 was for the computer generically?
`9 MR. GANNON: Object to the form.
`10 THE WITNESS: It would be the same.
`
`12
`
`
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`
`11 BY MR. SOKOHL:
`12 Q. If I was to ask you the same question
`13 regarding processing data faster, more reliably,
`14 or more efficiently with regard to a processor
`15 that makes up a computer, would the answer be the
`16 same?
`17 MR. GANNON: Object to the form.
`18 THE WITNESS: Yes. In relation to
`19 what you're just saying?
`20 BY MR. SOKOHL:
`21 Q. Uh-huh.
`22 A. Yes.
`1 Q. Does the GUI tool of Claim 1 cause the
`2 computer to display the data to the screen faster
`3 than conventional GUI tools?
`4 MR. GANNON: Object to the form,
`5 scope.
`6 THE WITNESS: Again, my answer is
`7 going to be the elements of Claim 1 have nothing
`8 to do with displaying data on a screen faster or
`9 anything like that. They describe the structure,
`10 makeup, and function of a GUI tool.
`11 BY MR. SOKOHL:
`12 Q. Does the GUI tool of Claim 1 cause the
`13 user's input device to operate any faster than
`14 conventional GUIs?
`
`13
`
`
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`
`15 MR. GANNON: Object to the form,
`16 scope.
`17 THE WITNESS: Could you just repeat
`18 that, please?
`19 BY MR. SOKOHL:
`20 Q. Sure. Does the GUI tool of Claim 1
`21 cause the user's input device to operate faster
`22 than conventional GUIs?
`1 MR. GANNON: Object to the form,
`2 scope.
`3 MR. SOKOHL: I'm going to restate that
`4 question.
`5 BY MR. SOKOHL:
`6 Q. Does the GUI tool of Claim 1 cause the
`7 user's input device to operate any faster than a
`8 user's input devices used with conventional GUIs?
`9 A. And, again, the elements of Claim 1
`10 and Claim 1 itself or any other claims are not
`11 directed to the input devices or anything else
`12 like that. They describe the structure, makeup,
`13 and function of a GUI tool.
`14 Q. Does the GUI tool of Claim 1 cause the
`15 recited computer to communicate with the
`16 electronic exchange any faster than conventional
`17 GUI tools?
`18 MR. GANNON: Object to the form,
`
`14
`
`
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`
`19 scope.
`20 THE WITNESS: Again, the elements of
`21 Claim 1 do not cause the network -- it's nothing
`22 to do with the network elements of the computer,
`1 anything to do with that. They specifically
`2 describe the structure, makeup, and function of a
`3 GUI tool.
`4 BY MR. SOKOHL:
`5 Q. Other than the way that the data is
`6 displayed in the GUI tool of Claim 1, how else is
`7 it functionally different from conventional
`8 devices?
`9 MR. GANNON: Object to the form,
`10 foundation.
`11 THE WITNESS: In exactly the way as
`12 described in Claim 1. You're talking about Claim
`13 1; correct?
`Ex. 1060 at 263:155-269:13; see also Ex. 1060 at 247:17-249:2.. Rather than
`
`admitting the claimed inventions do not improve computers, Mr. Thomas was
`
`simply stating what was not explicitly recited by the claims. The probative value of
`
`this testimony is thus substantially outweighed by a danger of unfair prejudice and
`
`confusing the issues as the result of vague questioning. Accordingly, it should be
`
`excluded under FRE 403.
`
`Dated: September 23, 2016
`
`
`
`By: /Joshua L. Goldberg/ (Reg. No. 59,369)
`
`15
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`CBM2015-00179
`U.S. Patent 7,533, 056
`
`The undersigned hereby certifies that a copy of the foregoing PATENT
`
`
`
`OWNER’S MOTION TO EXCLUDE UNDER 37 C.F.R. 42.64(C) was served
`
`on September 23, 2016, via email directed to counsel of record for the Petitioner at
`
`the following:
`
`Robert Sokohl
`rsokohl-PTAB@skgf.com
`
`Lori Gordon
`lgordon-PTAB@skgf.com
`
`Richard Bemben
`rbemben-PTAB@skgf.com
`
`John C. Phillips
`CBM41919-0007CP1@fr.com
`
`PTAB@skgf.com
`
`
`
`
`
`
`Dated: September 23, 2016
`
`
`
`
`
`
`
`/Valencia Daniel/
`Valencia Daniel
`Litigation Legal Assistant
`
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`
`
`16
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
