Emsley, Rachel
`
`From:
`Sent:
`To:
`Cc:
`
`Subject:
`
`Rob Sokohl <RSOKOHL@skgf.com>
`Friday, June 3, 2016 8:41 PM
`Steve Borsand (TT)
`Emsley, Rachel; Arner, Erika; Lori Gordon; Richard M. Bemben; PTAB Account;
`gannon@mbhb.com; sigmond@mbhb.com; tt-patent-cbm@tradingtechnologies.com;
`Trading-Tech-CBM; Adam Kessel; John Phillips; Healey@fr.com
`Re: Meet/Confer to Discuss Discovery from TradeStation
`
`Counsel, we are in receipt of your email. We are reviewing and will get back to you with our availability for a
`meet and confer on your various contentions and demands.
`
`
`
`Rob
`
`Sent from my iPhone
`
`On Jun 3, 2016, at 1:32 PM, Steve Borsand (TT) <steve.borsand@tradingtechnologies.com> wrote:
`
`Counsel,
`
`
`Following our telephone call yesterday, we sent a preliminary list of documents (reattached here
`for your convenience). Based on some recently produced documents, TT may be supplementing
`this list. TS recently produced the listed documents in the litigation, and they are highly relevant
`to these proceedings. We believe these documents should have been produced in these
`proceedings as relevant information that is inconsistent with TS's obviousness grounds and
`characterizations of TT’s inventions. At a minimum, we believe they should be produced as
`additional discovery. These are documents that were generated by TS and came out of TS's own
`files.
`
`
`TS has labeled many of these documents as confidential under the district court protective
`order. While TT does not necessarily agree with this designation, TS should immediately
`produce the documents in an appropriate manner in these proceedings. Importantly, both TS
`counsel in these proceedings and others with obligations under Rule 42.51(iii) are aware of these
`documents.
`
`
`To give just one example of these documents that is not marked confidential, TS0111352
`appears to be part of a manual describing TS's Matrix product (its first commercial embodiment
`of the claimed invention at issue in the CBMs) when it was released around 2003: "The Matrix
`window provides users with an exciting new view of the market including an innovative
`graphical display of market depth and trade activity for a given instrument along with lightning
`fast order execution with its one-click trading capability. This combination allows for
`unprecedented market feel and efficiency for the frequent trader." Many of the other documents
`on the attached list contain equally, if not more relevant, statements that contradict TS’s
`obviousness positions and characterizations of TT’s inventions. For example, some documents
`provide similar praise, discuss extensive usage of TS’s trading GUI that implements the claimed
`invention, reflect requests by customers to expand use of the invention to other platforms, etc.
`We also believe that these documents contain statements in conflict with Petitioner's claim
`construction positions.
`
`
`1
`
`Page 1 of 13
`
`TRADING TECH EXHIBIT 2399
`IBG ET AL. v. TRADING TECH
`CBM2015-00182
`
`

`
`As we discussed, we have not completed our review of the recent partial production of
`documents from TS, and there are many other documents that are being improperly withheld by
`TS (for example, because they reference a customer).
`
`
`TT is entitled to the production of all such discovery in the CBM proceedings, both in the form
`of documents and testimony. At a high level, this discovery would provide information
`supporting TT's position that the claimed invention went against the conventional wisdom of the
`state of the mind of a POSITA at the time of the invention and objective indicia of non-
`obviousness (including failure of others, long felt need, copying (direct or indirect), commercial
`success, praise, etc). Relevant documents also include (i) documents showing the functionality of
`GUI order entry tools at TS prior to the introduction of TS’s Matrix, (ii) documents describing
`the interfaces as GUIs or UIs for providing data entry functionality and as providing functional
`advantages or improved performance, and (iii) documents describing the products embodying the
`claimed invention as addressing technical problems with technical solutions (as opposed to
`merely addressing aesthetics). To be clear, information learned from the TS and IB depositions
`on these topics is also relevant and should be usable in these proceedings. Currently, the TS
`depositions (both of Mr. Bartleman) are scheduled for June 8 and 9 and the IB deposition of Mr.
`Galik is scheduled for June 13. Also, to be clear, relevant documents do not need to be worded
`exactly like the ones on TT's preliminary list.
`
`
`Even if not considered routine discovery, this evidence exists and the Bloomberg factors are met.
`
`
`TT requests the following:
`1. Prompt compliance with Rule 42.51(iii) by the parties’ production in the PTAB proceedings of
`the documents in the attached list (and any supplemental list provided by TT in the next several
`days), and any additional relevant documents from Petitioners’ files:
`(a) supporting TT's position that the claimed combination went against the conventional wisdom
`of a POSITA at the time of the invention;
`(b) supporting existence of objective indicia of non-obviousness when viewed from Patent
`Owner's perspective;
`(c) describing products TT alleges embody the claimed invention as addressing technical
`problems with technical solutions;
`(d) describing the interfaces as GUIs or UIs for providing data entry functionality, as providing
`functional advantages, or improved performance;
`(e) describing terms in conflict with Petitiioner's claim term positions; and
`(f) the transcripts of the TS and IB depositions scheduled on June 8, 9 and 13.
`2. Prompt notification to corporate officers, and persons involved in the preparation or filing of
`the PTAB papers of their duty under Rule 42.52 (iii) so that they may provide any additional
`similar documents from their files.
`
`
`Division of labor between counsel or the district court protective order and how TS chooses to
`apply that protective order to its own documents do not insulate TS and its PTAB counsel from
`its obligations in the PTAB. The Board specifically extended the deadline for Patent Owner’s
`Responses to allow for the discovery to progress through June 10, 2016 in the litigation--
`including the expected document production. Thus, the Board has also assumed that to the extent
`that helpful information was produced in the litigation, that Patent Owner could use such
`information in the PTAB. If the Petitioners do not agree to produce all of the materials requested
`above in the PTAB proceedings, TT will contact the Board to order compliance with Rule
`42.51(iii), or in the alternative, order the production of relevant documents and testimony as
`Additional Discovery.
`
`
`2
`
`Page 2 of 13
`
`

`
`Please let us know your availability for a phone call to discuss this either today or Monday.
`
`Thanks,
`
`Steve
`
`---------------------------------------------------------------------
`Steven F. Borsand
`Executive Vice President, Intellectual Property
`Trading Technologies, Inc.
`ph: +1.312.476.1018
`fax: +1.312.476.1182
`steve.borsand@tradingtechnologies.com
`----------------------------------------------------------------------
`
`
`On Thu, Jun 2, 2016 at 4:15 PM, Emsley, Rachel <Rachel.Emsley@finnegan.com> wrote:
`
`
`
`Rob,
`
`We do appreciate that we are not far apart on these issues. But, we simply cannot agree to a
`cutoff on the deposition duration. As we’ve said, we have no intent to question Mr. Kawashima
`outside the scope we’ve discussed, but our experience with the translated deposition is that it
`may not be as contained as we ALL want it to be. On the deadline: June 28 gives us only 2
`additional days, and if we are going to the Board with these two remaining issues, we will
`request an extension to July 1st. TT should not be prejudiced by Petitioners’ delay in securing a
`deposition of Mr. Kawashima.
`
`We are available for a Board call, if necessary, on Monday from 10:30 am eastern (9:30 am
`central) to 5 pm eastern (4 pm central).
`
`Regards,
`Rachel
`
`
`
`
`
`Rachel L. Emsley | Attorney at Law | Finnegan, Henderson, Farabow, Garrett & Dunner, L.L.P. | Two Seaport Lane, Boston
`MA 02210-2001 | Tel: 617.646.1624 | Fax: 202-408-4400| Email: rachel.emsley@finnegan.com | Web: www.finnegan.com
`
`NOTICE: This e-mail is sent by a law firm and may contain information that is confidential, protected, or privileged. If you are
`not the intended recipient, please delete the email and any attachments and notify us immediately.
`
`
`
`
`
`From: Rob Sokohl [mailto:RSOKOHL@skgf.com]
`Sent: Thursday, June 2, 2016 2:06 PM
`To: Emsley, Rachel
`Cc: Arner, Erika; Lori Gordon; Richard M. Bemben; PTAB Account; gannon@mbhb.com;
`sigmond@mbhb.com; tt-patent-cbm@tradingtechnologies.com; Trading-Tech-CBM; Adam Kessel; John
`Phillips
`Subject: RE: Kawashima Deposition
`
`3
`
`Page 3 of 13
`
`

`
`
`
`
`
`Rachel, I've thought about your email a bit further. We are not that far apart on these issues. So,
`in the spirit of cooperation, perhaps we can agree to 5.5 hours for the deposition and a reply date
`of June 28th. We then do not see a need for a call with the Board.
`
`
`
`
`
`Let us know as soon as possible. Otherwise, we will send an email to the Board for a call
`tomorrow and/or Monday (please provide availability).
`
`
`
`
`
`Rob
`
`
`
`
`
`From: Emsley, Rachel [mailto:Rachel.Emsley@finnegan.com]
`Sent: Wednesday, June 01, 2016 4:35 PM
`To: Rob Sokohl
`Cc: Arner, Erika; Lori Gordon; Richard M. Bemben; PTAB Account; gannon@mbhb.com;
`sigmond@mbhb.com; tt-patent-cbm@tradingtechnologies.com; Trading-Tech-CBM; Adam Kessel; John
`Phillips
`Subject: RE: Kawashima Deposition
`
`
`
`
`
`Counsel,
`
`
`
`
`
`Thank you for the call this morning. As discussed, this email details TT’s positions.
`
`
`
`
`
`Scope
`
`- TT agrees that the testimony is a cross examination, and therefore limited to the scope of the
`original testimony (per 37 CFR 42.53(d)(5)(ii)), and to credibility/bias as would be the case for
`any witness. Our understanding is that Petitioners rely on Mr. Kawashima’s testimony to allege
`that the TSE document constitutes prior art. As such, TT intends to ask questions related to this
`topic (and credibility/bias), and not to topics outside that scope. By way of example, as Rob
`mentioned on the call, and we agree, that questions “about the technical details” of the TSE
`document, or the “meaning” of the substance of the TSE document would not fall within the
`scope of this deposition. And, as Steve mentioned and Petitioners appeared to agree, questions
`about “who” the document was allegedly made available to would be within the scope.
`
`
`
`
`
`Time
`
`4
`
`Page 4 of 13
`
`

`
`- TT does not intend to exceed the scope as outlined above; nor does TT expect that Mr.
`Kawashima’s deposition would extend to the full 7-hours. However, we cannot agree to an
`absolute cutoff because we do anticipate likely discussion with the translators. As Steve
`mentioned, last time Mr. Kawashima was deposed the translation issues slowed the questioning
`down considerably and even to one question in 15 minutes. Furthermore, TT is concerned that
`given Petitioners’ request that this deposition be admissible across all existing CBM proceedings
`(and several not-yet filed proceedings), that TT will be prejudiced by any agreement to an
`absolute cutoff in deposition time. As the scope is truly limited in this cross examination, as
`outlined above, TT does not believe that restriction on the time beyond the Board’s general rule
`is necessary.
`
`
`
`
`
`Applicability of Mr. Kawshima’s testimony
`
`- Petitioners have asked that this deposition be admissible across all existing CBM proceedings
`(and several not-yet-filed proceedings--at least two coming in the next couple of weeks,
`specifically). To the extent that Mr. Kawashima’s testimony is relied upon in the same way, for
`the same purpose, in the not-yet-filed proceedings, TT agrees to its applicability and
`admissibility in those proceedings. This agreement is with the understanding that TT will use its
`best efforts to minimize the duration of Mr. Kawashima’s deposition, but that the parties will
`allow for the 7-hours if necessary to fully explore TT’s questions within the scope as outlined
`above.
`
`
`
`
`
`Deadline extensions
`
`- As explained on the call, TT’s counsel and TT are essentially unavailable during the week
`of June 20, and TT has thus requested that the deadline be extended to July 1, which would
`effectuate a one-week extension in reality for our team. We can agree to an extension of one
`week for Petitioners’ reply to September 9. A two week extension for Petitioners, however,
`would not be feasible without moving Due Dates 4-7, as that would leave only one week for
`Observations across all of the proceedings, and we do not yet know whether Petitioners will put
`forth declarants in their Replies.
`
`
`
`
`
`We are available for a Board call on Thursday afternoon from 2-5 pm (eastern), Friday morning
`9am-noon (eastern), or Friday afternoon from 3-5 pm (eastern).
`
`
`
`
`
`Thanks,
`
`Rachel
`
`
`
`
`
`From: Rob Sokohl [mailto:RSOKOHL@skgf.com]
`Sent: Tuesday, May 31, 2016 9:44 PM
`
`5
`
`Page 5 of 13
`
`

`
`To: Emsley, Rachel
`Cc: Arner, Erika; Lori Gordon; Richard M. Bemben; PTAB Account; gannon@mbhb.com;
`sigmond@mbhb.com; tt-patent-cbm@tradingtechnologies.com; Trading-Tech-CBM; Adam Kessel; John
`Phillips
`Subject: Re: Kawashima Deposition
`
`
`
`
`
`Thank you for confirming June 17th works for the deposition of Mr. Kawashima.
`
`
`
`
`
`We agree to extend the deadline for your reply until June 24th. We propose September 9th for
`our response, which leaves ample time in regard to the other due dates. There is no reason to
`request that the Board move the hearing date. We are hopeful we can agree on this straight
`forward scheduling matter.
`
`
`
`
`
`Let's have a meet and confer tomorrow at 11:30. Let's use the following dial-in:
`
`
`
`
`
`1-866-876-6756
`
`Conference code: 7728677
`
`
`
`
`
`We will discuss your other issue with our clients and get back to you in due course. We will not
`be prepared to discuss that issue with you tomorrow.
`
`
`
`
`
`Rob
`
`
`
`
`
`Sent from my iPhone
`
`
`On May 31, 2016, at 8:43 PM, Emsley, Rachel <Rachel.Emsley@finnegan.com> wrote:
`
`Rob -
`
`We are available for a meet/confer tomorrow from 10-12 Eastern. Please circulate
`a dial in number. A Board call on Thursday afternoon also works, but our
`preference would be to seek a call for Friday morning.
`
`We are available on June 17 for Mr. Kawashima's deposition. The scope will be
`governed by the Board’s rules on cross-examination (37 CFR 42.53(d)(5)(ii)), and
`
`6
`
`Page 6 of 13
`
`

`
`should include TSE’s bias. Because of overlapping due dates in these and other
`proceedings, the due date should be July 1st. We cannot extend Petitioners’
`deadline further than September 2, 2016, unless the Board will move the Hearing
`Deadline and allow appropriate time for Due Dates 4-7.
`
`In addition, we would like to discuss the following discovery issues with all TS
`counsel of record in each of the CBM proceedings on the phone. First, it’s our
`understanding that Petitioners have been producing documents recently pursuant
`to Judge Kendall's order and in advance of the John Bartleman deposition. Will
`petitioners agree to reproduce the documents it has been producing in the district
`court in the PTAB proceedings? If we cannot reach agreement, TT will raise this
`issue with the Board. The limited number of documents produced so far has
`proved to be highly relevant. For example, we have been informed that
`TS0111352 (which is not market confidential) states at the time of the Matrix
`windows first release (TS's first product embodying the claimed invention) that
`"the Matrix window provides users with an exciting new view of the market
`including an innovative graphical display of market depth and trade activity for a
`given instrument along with lightning fast order execution with its one-click
`trading capability. This combination allows for unprecedented market feel and
`efficiency for the frequent trader." We also understand that there are even more
`relevant documents in the limited documents produced so far that have been
`marked as confidential. TS should not be allowed to avoid production of this
`material based on the protective order. Second, we understand that TS’s counsel
`has objected to the production of certain documents in the district court litigation
`so that the production that has been occurring has been very limited. For
`example, we understand that TS has refused to produce emails that reflect
`customer interactions. TT believes that these documents contain highly relevant
`information relating to non-obviousness, and asks that all of these types of
`documents be produced to TT in the PTAB proceedings. We plan to raise this
`issue with the Board as well if TS refuses to do so.
`
`
`
`
`
`Thanks,
`
`Rachel
`
`
`
`
`
`From: Rob Sokohl [mailto:RSOKOHL@skgf.com]
`Sent: Tuesday, May 31, 2016 3:32 PM
`To: Arner, Erika <erika.arner@finnegan.com>; Emsley, Rachel
`<Rachel.Emsley@finnegan.com>
`Cc: Lori Gordon <LGORDON@skgf.com>; Richard M. Bemben
`<RBEMBEN@skgf.com>; PTAB Account <PTAB@skgf.com>;
`gannon@mbhb.com; sigmond@mbhb.com; tt-patent-
`cbm@tradingtechnologies.com; Trading-Tech-CBM <Trading-Tech-
`CBM@finnegan.com>; Adam Kessel <Kessel@fr.com>; John Phillips
`<phillips@fr.com>
`Subject: RE: Kawashima Deposition
`
`7
`
`Page 7 of 13
`
`

`
`
`
`
`
`
`
`Erika, thank you for your email. Please send our well wishes to Steve for a full
`discovery.
`
`
`
`
`
`However, we need to meet and confer on a number of issues, including the points
`raised in my email last week, as soon as possible. We also need your availability
`for a conference call with the Board tomorrow (anytime) or Thursday afternoon
`should our meet and confer not be fruitful.
`
`
`
`
`
`Mr. Kawashima is available for deposition on June 17th. The deposition will be
`held in either California or Hawaii. Due to the inconvenience to Mr. Kawishima,
`we are permitting him to decide the exact location to minimize any further impact
`to him.
`
`
`
`
`
`We recognize that his will require a further extension to the due date for TT's
`reply. We therefore propose to extend TT's POR due date by one week and make
`a commensurate change to our due date.
`
`
`
`
`
`We look forward to hearing from you later today about a meet and confer. Please
`also confirm that June 17th works since Mr. Kawashima needs to make his travel
`plans immediately.
`
`
`
`
`
`Rob
`
`
`
`
`
`
`
`From: Arner, Erika [mailto:erika.arner@finnegan.com]
`Sent: Tuesday, May 31, 2016 9:51 AM
`To: Rob Sokohl; Emsley, Rachel
`Cc: Lori Gordon; Richard M. Bemben; PTAB Account; gannon@mbhb.com;
`sigmond@mbhb.com; tt-patent-cbm@tradingtechnologies.com; Trading-Tech-CBM;
`Adam Kessel; John Phillips
`Subject: RE: Kawashima Deposition
`
`
`
`8
`
`Page 8 of 13
`
`

`
`Rob,
`
`We will get back to you as soon as possible with our availability for a meet and
`confer. TT’s counsel, Mr. Borsand, has been dealing with some medical issues
`and is hopefully able to get an MRI today. Thank you for your patience.
`
`Regards,
`
`Erika
`
`
`
`
`
`Erika H. Arner
`Attorney at Law
`Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
`11955 Freedom Drive, Reston, VA, 20190
`571.203.2754 | fax 202.408.4400 | erika.arner@finnegan.com| Bio
`Finnegan AIA Blog | www.finnegan.com | PTAB Guidebook
`
`<image001.jpg>
`
`
`
`
`
`
`
`
`
`From: Rob Sokohl [mailto:RSOKOHL@skgf.com]
`Sent: Friday, May 27, 2016 8:57 PM
`To: Emsley, Rachel
`Cc: Lori Gordon; Richard M. Bemben; PTAB Account; gannon@mbhb.com;
`sigmond@mbhb.com; tt-patent-cbm@tradingtechnologies.com; Trading-Tech-CBM;
`Adam Kessel; John Phillips
`Subject: Re: Kawashima Deposition
`
`
`
`
`
`Rachel, are you available for a meet and confer on Tuesday to discuss our
`proposal? We would also like to know your availability for a call with the Board
`on Wednesday.
`
`
`
`
`
`Rob
`
`Sent from my iPhone
`
`
`On May 27, 2016, at 5:36 PM, Emsley, Rachel <Rachel.Emsley@finnegan.com>
`wrote:
`
`Rob,
`
`9
`
`Page 9 of 13
`
`

`
`
`
`
`
`We would prefer that Mr. Kawashima be made available in the
`continental United States. If you could please provide us with Mr.
`Kawashima’s counsel’s contact information, we would like to
`communicate directly to discuss the location of the deposition and
`also the scope of his deposition to avoid any misunderstandings.
`
`
`
`
`
`We cannot agree to a 4-hour deposition. While we respect that Mr.
`Kawashima is a third-party witness, his testimony is central to a
`key issue and will be subject to translation and check-translation.
`The rules allow at least for a seven hour deposition for Mr.
`Kawashima’s testimony, and we cannot agree to less given the
`challenges this deposition will pose.
`
`
`
`
`
`Thanks,
`Rachel
`
`
`
`
`Rachel L. Emsley
`Attorney at Law
`Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
`Two Seaport Lane
`
`Boston, MA 02210-2001
`617.646.1624 | fax: 202.408.4400 | rachel.emsley@finnegan.com |
`www.finnegan.com
`
`NOTICE: This e-mail is sent by a law firm and may contain information
`that is confidential, protected, or privileged. If you are not the intended
`recipient, please delete the email and any attachments and notify us
`immediately.
`
`
`
`
`
`
`
`From: Rob Sokohl [mailto:RSOKOHL@skgf.com]
`Sent: Thursday, May 26, 2016 1:44 PM
`To: Emsley, Rachel; Lori Gordon; Richard M. Bemben; PTAB Account
`Cc: gannon@mbhb.com; sigmond@mbhb.com; tt-patent-
`cbm@tradingtechnologies.com; Trading-Tech-CBM
`Subject: RE: Kawashima Deposition
`
`
`
`
`
`Counsel,
`
`10
`
`Page 10 of 13
`
`

`
`
`We wanted to let you know that TSE is reconsidering whether to
`make Mr. Kawashima available for deposition. We will likely be
`able to confirm their decision early next week. In the meantime,
`we wanted to discuss the scope of the potential deposition and
`logistics.
`
`Given the limited use of his deposition testimony, we propose that
`the deposition be limited to two issues: public availability of the
`TSE Operation Guide and Mr. Kawashima's alleged bias. We also
`propose limiting the deposition to 4 hours. Mr. Kawashima is a
`third party and we do not believe he should be significantly
`inconvenienced.
`
`
`
`
`
`We also propose that this deposition be admissible in all pending
`or to be filed CBMs (whether instituted or not). There is simply no
`reason to take Mr. Kawashima's deposition more than once.
`
`The location of the deposition is still uncertain, but two possible
`locations are Hong Kong or Guam. We will confirm the date and
`location early next week once we hear back from TSE.
`
`Please let us know if you are agreeable to the terms outlined
`above. Please let us know by COB tomorrow. If you are not, we
`intend to reach out to the Board for relief when we receive
`confirmation of Mr. Kawashima availability.
`
`Rob
`
`
`
`
`
`From: Rob Sokohl
`Sent: Wednesday, May 04, 2016 3:08 PM
`To: 'Emsley, Rachel'; Lori Gordon; Richard M. Bemben; PTAB Account
`Cc: gannon@mbhb.com; sigmond@mbhb.com; tt-patent-
`cbm@tradingtechnologies.com; Trading-Tech-CBM
`Subject: RE: Kawashima Deposition
`
`
`
`
`
`Rachel, as we have previously indicated, Mr. Kawashima has
`informed us he is unwilling to voluntarily be deposed in the United
`States or Japan. Further, Mr. Kawashima is a third party witness
`and is not under our control. Nevertheless we have made another
`inquiry as to whether he will agree to be deposed.
`
`
`
`
`
`Rob
`
`11
`
`Page 11 of 13
`
`

`
`
`
`
`
`
`
`From: Emsley, Rachel [mailto:Rachel.Emsley@finnegan.com]
`Sent: Monday, April 25, 2016 9:54 PM
`To: Rob Sokohl; Lori Gordon; Richard M. Bemben; PTAB Account
`Cc: gannon@mbhb.com; sigmond@mbhb.com; tt-patent-
`cbm@tradingtechnologies.com; Trading-Tech-CBM
`Subject: Kawashima Deposition
`
`
`
`
`
`Counsel,
`
`
`
`
`
`The Board’s Order (Paper 39, CBM2015-00179; Paper 34,
`CBM2015-00181; Paper 25, CBM2015-00182) makes clear that
`Petitioners must produce Mr. Kawashima for cross-examination,
`and Patent Owner notes that its request to depose Mr. Kawashima
`from March 22, 2016, remains outstanding. As the dates in our
`original request have passed, we note that Patent Owner has
`availability from May 10-13 and May 18-20 for the deposition of
`Mr. Kawashima.
`
`
`
`
`
`Regards,
`Rachel
`
`
`
`
`
`Rachel L. Emsley
`Attorney at Law
`Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
`Two Seaport Lane
`
`Boston, MA 02210-2001
`617.646.1624 | fax: 202.408.4400 | Rachel.Emsley@finnegan.com |
`www.finnegan.com
`
`
`
`This e-mail message is intended only for individual(s) to whom it is addressed and may contain
`information that is privileged, confidential, proprietary, or otherwise exempt from disclosure under
`applicable law. If you believe you have received this message in error, please advise the sender
`by return e-mail and delete it from your mailbox. Thank you.
`
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`<PrelimTSdoclist.docx>
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