Paper No. __
`Paper Filed: September 12, 2013
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SCHRADER—BRIDGEPORT INTERNATIONAL, INC; and
`SCHRADER ELECTRONICS, INC.
`Petitioner
`
`V.
`
`CONTINENTAL AUTOMOTIVE SYSTEMS US, INC.
`Patent Owner
`
`Case IPR2013-00014
`
`Patent No. 6,998,973
`
`PETITIONER’S REPLY TO RESPONSE OF PATENT OWNER-
`
`
`Paper Filed: September 12, 2013
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SCHRADER—BRIDGEPORT INTERNATIONAL, INC; and
`SCHRADER ELECTRONICS, INC.
`Petitioner
`
`V.
`
`CONTINENTAL AUTOMOTIVE SYSTEMS US, INC.
`Patent Owner
`
`Case IPR2013-00014
`
`Patent No. 6,998,973
`
`PETITIONER’S REPLY TO RESPONSE OF PATENT OWNER-
`
`
`
`TABLE OF CONTENTS
`
`TABLE OF AUTHORITIES ................................................................................. ii
`
`I.
`
`11.
`
`INTRODUCTION.......... '............................................................................... 1
`
`Claims 1-5 and 7-11 of the ’973 patent are primafacie obvious in view of
`Derbyshire, Bailie, and Bowers ............................... 2
`
`III. Patent Owner presented arguments that misunderstand the teachings of
`the prior art and are irrelevant .................................................................... 5
`
`A. The focus on “critical data” is irrelevant to the primafacz'e case of
`obviousness ...................................................................................................... 6
`
`B. The combination of Derbyshire, Bailie, and Bowers would reduce the
`occurrence of “non-critical”_ data clashing ...................................................... 7
`
`IV.
`
`Patent Owner misapplied the law of teaching away and analogous art 11
`
`A. Derbyshire does not teach away from the combination with Bowers ........... 11
`
`' B. Derbyshire and Bowers are analogous art due to Bailie ............................... 12
`
`C. Bailie expressly teaches benefits of imprecise components.......................... 14
`
`D. Claims 3 and 8 are obvious in View of Derbyshire, Bailie, and Bowers ....... 14
`
`V.
`
`CONCLUSION ...............y............................................................................. 15
`
`
`
`TABLE OF AUTHORITIES
`
`Cases
`
`In re Aller, 220 F.2d 454 (CCPA 1955) ............' ...................................................... 1 5
`
`In re Piaseckz', 745 F.2d 1468 (Fed. Cir. 1984) ........................................... '. ............. 1
`
`In re Sullivan, 498 F.3d 1345 (Fed. Cir. 2007) ......................................................... 1
`
`Strata/lax, Inc. v. Aeroquip Corp, 713 F.2d 1530 (Fed. Cir. 1983) .......................... 1
`
`ii
`
`
`
`I.
`
`INTRODUCTION
`
`As set forth in the Petition for Inter Partes Review, claims 1—5 and: 7-11 of
`
`US 6,998,973 (“the ’973 patent”) are prima facie obvious in View of the combined
`
`teachings of _US 6,271,748 (“Derbyshire”), US 6,486,773 (“Bailie”), and US
`5,883,582 (“Bowers”).
`Paper
`1 at 23-24. Once the prima facie case of
`
`obviousness was established, the burden shifted to Patent Owner to rebut the prima
`facie case. See In re Piasecki, 745 F.2d 1468, 1472 (Fed. Cir. 1984)(“After a
`primafacz'e case of obviousness has been established, the bUrden of going forward
`
`shifts to the applicant”), and In re Sullivan, 498 F.3d 1345, 1351 (Fed. Cir.
`
`2007)(“[W]hen a prima facie case is made, the burden shifts to the applicant to
`
`come forward with evidence and/or argument supporting patentability.” Citation
`
`omitted.)
`
`V Notable in Patent Owner’s response to the decision by the Patent Trial and
`
`Appeal Board (“Board”) instituting this inter partes review (“the Decision”) was
`
`the total lack of evidence of any Objective indicia of non—obviousness, also referred
`
`to as secondary considerations. As the courts have held, “evidence of secondary
`
`considerations may often be the most probative and cOgent evidence in the
`
`record.” Strata/16x, Inc. v. Aeroquz‘p Corp, 713 F.2d 1530, 1538 (Fed. Cir. 1983).
`
`In this case, h0wever, Patent Owner failed to point to any evidence showing
`
`
`
`commercial success, long—felt but unresolved need, failure of others, copying, or
`
`other objective indicia of non-obviousness.
`
`Without the need to balance any evidence of secondary c0nsiderations, the
`
`issue remaining in this case is simple and straight-forward: under a preponderance
`
`of evidence standard, is there a primafacz'e case of obviousness for claims 1-5 and
`
`7=ll of the ’973 patent in view of Derbyshire, Bailie, and Bowers? The answer is
`
`a resounding yes.
`
`As discussed in more detail below, Patent Owner’s assertions that there is no
`
`prima facie case of obviousness are unavailing. Patent Owner’s arguments are
`
`based on misunderstandings of the prior art and the law. I
`
`II.
`
`Claims 1-5 and 7—11 of the ’973 patent are primafacie obvious in View of
`Derbyshire, Bailie, and Bowers
`
`Independent claim 1 of the ’973 patent recites:
`
`1. A data transmission method for a tire-pressure monitoring
`system (10) of a vehicle, said data being transmitted by wheel units
`(12) to a central computer (13) located in the vehicle, said method
`comprising:
`a data transmission phase in parking mode, over a first period;
`
`and
`
`a data transmission phase in running mode, over a second
`period shorter than the first period; said method being characterized in
`that:
`
`a natural time lag between various internal clocks with which
`each wheel unit (12) is equipped is used to prevent collisions between
`transmissions from the various wheel units of one and the same
`
`vehicle.
`
`
`
`’973 patent, Exhibit 1001 at col. 4, 11. 7-19. Each and every element recited in
`
`claim 1 is taught by the combined teachings of Derbyshire, Bailie, and Bowers.
`
`I
`
`First, Derbyshire teaches the basic components of a tire pressure monitoring
`
`system with the claimed “parking mode” and “running mode” “data transmission
`
`phase[s]” as well as the preamble of claim 1. See, e.g., Derbyshire, Exhibit 1003
`
`at FIGS. 6(1) and 6(II) and col. 7, ll. 40=56. Bailie similarly teaches a tire pressure
`
`monitoring system with the very same features of claim 1.1 See, e.g.,lBailie,
`
`Exhibit 1006, at col. 6, 11. 10-41.
`
`Indeed, there is no dispute that- the method of
`
`data transmission. in a tire pressure monitoring system as recited in the preamble
`
`and first two clauses of claim 1 are known in the art. Paper 12 at 5. The
`
`Background section of the ’973 patent even admits all this subject matter to be
`
`known in the prior art.
`
`’973 patent, Exhibit 1001 at col. 1, 11. 29-49 (discussing
`
`parking and running modes with longer and shorter transmission intervals,
`
`respectively).
`
`Indeed, claim 1 even uses a Jepson style “characterized in-that”
`
`clause before reciting the allegedly novel “natural time lag” feature.
`
`1 In this respect, even though Derbyshire is the base reference in the ground of
`
`invalidity as specified in the Decision, Bailie provides the exact same teaching as
`
`Derbyshire for a tire pressure monitoring system that operates in at least two
`
`distinct modes to transmit data.
`
`
`
`Second, Bailie recognizes the problem of clashing data from different. tire
`
`pressure sensors at the receiver in a tire pressure monitoring system. Bailie,
`
`Exhibit 1006 at col. 1,, 11. 28-29. For that reason, Bailie teaches the need for an
`
`anti—collision feature in a tire pressure monitoring system to prevent the clashing of
`
`data at a receiver.
`
`Id. at col. 1, 11. 48-51. Bailie discloses different. approaches to
`
`meeting this need, including one using imprecise components in the sensor that
`
`trigger the transmission periods (i.e., roll switches that have a natural spread of g-
`
`force triggering so that transmission clashing is reduced). Id. at col. 6, 11. 42—58.
`
`Third, Bowers teaches the use of imprecise RC clock circuits with large
`
`tolerances as
`
`timing circuits
`
`for
`
`systems having multiple radio frequency
`
`transmiSsions in order to avoid or minimize the likelihood of simultaneous
`
`transmissions. Bowers, Exhibit 1005 at col. 8, 11. 17-37.
`
`Thus, a person having ordinary skill in the art, having read Bailie as teaching
`
`the desirability of collision avoidance and the use of, imprecise components as a
`
`way of doing so, would have been led to modify the tire pressure monitoring
`
`system of the known type, as taught by Derbyshire and Bailie, with the imprecise
`
`RC clock circuits having large tolerances, as taught by Bowers, in order to avoid or
`
`minimize the problem of simultaneous transmissions in a tire pressure monitoring
`
`system. The law is clear that where the prior art both discloses the elements of a
`
`claimed invention and provides motivation to combine those elements, the claims
`
`
`
`are obvious and invalid, Accordingly, claim liof the ’973 patent is prima facie
`
`unpatentable as being obvious in view of Derbyshire, Bailie, and Bowers.
`
`Dependent claims 2—5 and 7-lI of the ’973 patent recite additional limitations that
`
`are likewise disclosed by the combined teachings of Derbyshire, Bailie, and
`
`Bowers, and therefore are likewise obvious and invalid. See Paper 1 at 23-24.
`
`This Board acknowledged Schrader’s position and instituted this inter‘partes
`
`review on that ground:
`
`“[I]t is apparent that Schrader relies on Derbyshire as disclosing the
`majority of the features required by claims 1-5 and 7-11, coupled with
`Bailie’s recognition in the art that reducing data collisions is a desired
`outcome, and further coupled with Bowers’ teachings as to particular
`involved clock precision levels which accomplish the desired data
`collision avoidance.
`'
`‘
`
`After a thorough review of the record, and foregoing reasons, we
`conclude that Schrader has demonstrated a reasonable likelihood of
`prevailing in its obviousness ground of unpatentability of claims 1—5
`and 7—11 based on the combined teachings of Derbyshire, Bailie, and
`Bowers.”
`
`Paper 12 at 16-17 and 19.
`
`III. Patent Owner presented arguments that misunderstand the teachings of
`the prior art and are irrelevant
`
`The crux of Patent Owner’s argument that a primafacz‘e case. of obviousness
`
`has not been established centered on what Patent Owner characterized as
`
`Derbyshire’s alleged treatment of “critical” and “non-critical” data. Paper 19 at 6-
`
`7.
`
`Indeed, Patent Owner devoted over 21 pages in the response to arguments
`
`
`
`focused on this distinction between “critical” and. “non-critical” data.
`
`This
`
`distinction in data type, however, is an artificial distinction that is irrelevant to the
`
`obviousness analysis.
`
`The claim language itself makes no such distinction
`
`between types of data being transmitted and merely refers to transmissions of data
`
`in general — not any particular type.
`
`A.
`
`The focus on “critical data” is irrelevant to the primafacie case of
`obviousness
`
`Patent Owner argued that “Derbyshire goes to great lengths to ensure that
`
`data, and particularly ‘critical data’ (i.e., data related to a change in tire pressure
`
`and/or temperature indicating a problematic tire) is received by a receiver unit.”
`Paper 19 at 8. According to Patth Owner, Derbyshire ensures that “critical data”
`
`would be received in the Derbyshire system because such data are transmitted
`
`three times.
`
`Id. at 9. This argument misses the mark and has no bearing on the
`
`obviousness of the claims at issue.
`
`i
`
`As recognized by Patent Owner, 'the occurrence of an event that would cause
`
`the transmission of “critical” data “is a purely random event based upon abnormal
`
`conditions sensed by the TPM.” Id. at 16.
`
`In other words, Patent Owner defines
`
`the so-called “critical” data as data sent during a rapid or dramatic drop in tire
`
`pressure. There is no dispute that data clashing, as taught by Bailie, would likely
`
`not be an issue in such conditions. The chances of multiple tires having a drastic
`
`
`
`failure causing rapid pressure loss, such as multiple simultaneous blown tires,
`
`would be minimal.
`
`Rather, this category of drastic failure is simply a third mode of operation in
`
`addition to the “parking mode” and “running mode” as disclosed by Derbyshire
`
`and recited in claim 1.
`
`Indeed, other tire pressure monitoring systems, including
`
`the one taught in Bailie, recognized that drastic failures can occur.
`
`'See Bailie,
`
`Exhibit 1006, col. 2, ll. 41-44 (“The receiving unit 14 receives RF signals form the
`
`transmitters 12 and provides a warning to the operator of the vehicle V when the
`
`indicated tire pressure of any of the tires is outside a predetermined range”)
`
`Accordingly, Patent Owner’s assertion that Derbyshire’s treatment of
`
`“critical” data means that there would be no enhancement in Derbyshire’s system
`
`from the use of Bowers’ timer circuit is without merit. This alleged “critical data” ‘
`
`is data transmitted during serious pressure loss conditions, and has nothing to do
`
`with the periodic types of transmissions where clashing is likely to occur.
`
`B.
`
`The combination of Derbyshire, Bailie, and Bowers would reduce
`the occurrence of “non-critical” data clashing
`
`Patent Owner then argued that “lnlon-critical data will also be received in
`
`Derbyshire and there would be no enhancement from use of the Bowers timer
`
`circuit.” Paper 19 at 19, emphasis in original. “Non-critical data” was defined by
`
`Patent Owner as “periodic and mundane transmissions of update or communication
`
`maintenance”.
`
`Id.
`
`at 8. What was defined as “periodic and mundane
`
`
`
`transmissions” are simply the type of data that any tire pressure monitoring system,
`
`such as the ones disclosed in Derbyshire and Bailie, are intended to monitor on a
`
`routine basis.
`
`It is this type of “periodic and mundane transmissions” that Bailie
`
`recognized would be at risk of clashing.
`
`Indeed, the Derbyshire devices have the
`
`exact same time intervals between the periodic transmissions of such data that
`
`'
`
`create the risk of collision with which Bailie is concerned.
`
`Patent Owner’s assertions with respect to the “non—critical” data miss the
`
`mark on two accounts. First, Patent Owner contended that the timer circuit of
`
`Bowers would not improve Derbyshire’s performance because “[e]ach wheel unit
`
`in Derbyshire will inevitably have a different absolute start time for its two-second
`
`timer circuit 26 as compared to the start times for the timer circuits in other wheel
`
`units.” Id. at 19. Patent Owner then goes to great lengths to explain how “each
`
`wheel unit’s transmissions will be non—aligned with the transmissions of other
`
`wheel units because of the randomness of when the timer circuit 26 in each wheel
`
`unit is activated (i.e., powered up).” Id. at 24. This assertion is yet another red
`
`herring argument.
`The purpose of the timer 26 in Derbyshire, which could be a two second
`
`timer, is to output a wake—up signal to the microprocessor. Derbyshire, Exhibit
`1003 at col. 7, 11. 62-65. The wake—up timer 26 does not control the timing of the
`
`transmission of data as asserted by Patent Owner. Rather, transmission of data is
`
`
`
`based off an internal clock that allows Derbyshire’s system to transmit data every
`
`60 minutes while in a “parking mode” or every 10 minutes while in a “running
`
`mode.” Id. at Figure 6(1) and (II), Reference Nos. 60 and 75. Derbyshire discloses
`
`such an internal system clock, separate from the timer,
`in the tire monitoring
`system. Id. at Figure 2 (“System Clock. 300 kHz”). The use of a reference clock to
`
`control the timing of the data transmissions was also disclosed by Bailie. Bailie,
`
`Exhibit 1006 at col. 5, 11'. 46-48. The internal clock must be timing the intervals
`
`between such events at all times, even when the processor is in sleep mode before
`being woken up by timer 26. This is evidenced, for example, by the fact that the
`
`first thing the processor does after receiving the wake—up signal is to check if the
`
`centrifugal detector has signaled vehicle motion in the last twenty minutes, and if
`
`so checking to see if a measurement has been taken in the last five minutes. Id. at
`
`col. 7,
`
`l. 60 — col. 9,
`
`l. 13. Similar queries are then made for the most recent
`
`transmission depending on the mode (parking or running).
`Id. Contrary to Patent
`Owner’s assertion, it is of no consequence what the absolute start time is for each
`individual two-second timer 26 since the timers have no part in the timing of the
`
`data transmission and merely trigger the processor to wake-up and query whether
`
`
`
`certain events have happened,
`
`including whether certain time intervals have
`
`elapsed since the last time it was woken up. 2
`
`Second, Patent Owner argued that “[r]eplacing Derbyshire’s two-second
`
`'timer 26 with Bowers’ timer may actually serve to increase collisions for non—
`
`critical data.
`
`9’
`
`Paper 19 at 19. Patent Owner then provided a diagram showing
`
`how the data would occasionally collide. As explained above,
`
`the timer in
`
`Derbyshire does not control the timing of data transmission. Another flaw in this
`
`assertion is that Patent Owner mistakenly equates the imprecise tolerance as taught
`
`by Bowers with variable timing. As clearly taught by Bowers, “[e]ach tag is
`
`constructed such that electrical components within each tag include predetermined
`
`manufacturing tolerances, such that although the length of the non-transmission
`
`interval is fixed for each tag, the non—transmission interval varies between tags at
`
`2 Patent Owner’s argument also seems to imply that the time intervals used would
`
`be measured from the time the battery is installed in a given sensor. Paper 19 at
`
`19—23. That makes no sense, as then the time measurement periods in
`
`Derbyshire would be stated in accumulated periods of time, rather than in
`
`intervals like 10 minutes or 60 minutes. Clearly, Derbyshire’s reference to these
`
`time intervals means those intervals are being used and clocked, not some
`
`accumulated amount of time since the battery was installed.
`
`10
`
`
`
`least within the. prescribed tolerances.” Bowers, Exhibit 1005 at col. 4, 11. 7-12.
`
`Accordingly, there is no support for Patent Owner’s argument that Bowers’ timers
`
`are “variable timers” that could “actually increase the odds of non-critical data
`
`collisions (with other non-critical data).” Paper 19 at 25.
`
`Regardless, the Patent Owner’s focus on alleged deficiencies in Derbyshire
`
`studiously avOids the fact that Bailie teaches the same claim limitations anyways,
`
`along with the recognition of the collision issue and the desirability of using
`
`imprecise components to reduce such collisions. That is, even though what the
`
`Patent Owner has argued about Derbyshire is both technically and legally
`
`incorrect, it is of no moment because the Patent Owner fails to rebut the same
`
`teachings that are found in Bailie.
`
`IV.
`
`Patent Owner misapplied the law of teaching away and analogous art
`
`Having attempted to argue against the prima facie case of obviousness with
`
`misunderstandings of the prior art, Patent Owner then proposed other arguments
`
`that are based on misapplicatiOns of the law.
`
`A.
`
`Derbyshire does not teach away from the combination with
`Bowers
`
`Patent Owner alleged that “in order to achieve higher reliability rates,
`
`Derbyshire teaches that only ‘close tolerance components’ should be used, even if
`
`such components are more expenSive.” Paper 19 at 29. Thus, according to Patent
`
`11
`
`
`
`Owner, Derbyshire taught away from the high tolerance components taught by
`
`Bowers. Id. at 29. This is incorrect.
`
`I
`
`Derbyshire does not teach that only “close tolerance components” should be
`
`used. Rather, Derbyshire states that “[i]n some applications it is necessary that the
`
`data be acquired with high reliability,” in which case, expensive, close tolerance
`
`components may be used. Exhibit 1003 at col. 19, 11. 22-23. This hardly serves as
`
`a teaching away from the wider tolerance components taught byBowers.
`
`In fact,
`
`the cited passage of Derbyshire also recognized the costs of such components as
`
`being an issue.
`
`So, Derbyshire cannot be characterized as suggesting close
`
`tolerance components should be used to the exclusion of other options.
`
`Moreover, even if Derbyshire were read as alleged by the Patent Owner,
`
`I Bailie itself teaches all the limitations 'of the claims except the use of imprecise
`
`clocks with lag, just like Derbyshire. And Bailie further includes the recognition
`of transmission colliSion issues and the use of imprecise components to reduce
`
`those issues. So, focusing on alleged “close tolerance components” in Derbyshire
`
`does nothing to rebut the prima facie case and misdirects the analysis because it
`
`fails to address the teachings in Bailie.
`
`B.
`
`Derbyshire and Bowers are analogous art due to Bailie
`
`Patent Owner again attempted to argue against combining Derbyshire and
`
`B0wers because they are allegedly from “non-analogous” art fields. This was the
`
`12
`
`
`
`same argument presented in Patent Owner’s preliminary response (Paper 11 at 32-.
`
`37), which the Board dismissed‘in the Decision (Paper 12 at 17—18).
`
`. As made clear in the Decision, “[a] reference is analogous art if it is either;
`
`(1) in the field of the inventor’s endeavor, 0r (2) is reasonably pertinent to the
`particular problem with which the inventor was concerned.” Paper 12 at 17,
`
`emphasis in original, citation omitted. As discussed above, Bowers teaches the use
`
`of RC clock circuits with large tolerances in a system having multiple radio
`
`frequency transmissions
`
`in order
`
`to avoid or minimize the likelihood of
`
`simultaneous transmissions. This is the exact problem that Bailie recognized
`
`would be present in a tire pressure monitoring system. Moreover, Bailie teaches
`
`the benefit of using imprecise components in its system to reduce transmission
`
`collisions, and this suggests consultation of a reference like Bowers that uses
`
`imprecise components for the exact same reason. That is, while normally RFID
`
`transmitters may not necessarily be analogous art to tire pressure sensors for all
`purposes, here the teachings of Bailie suggest a collision problem and the use of
`
`imprecise components to resolve it, which leads one to consult usage of thersame
`
`type of approach in Bowers.
`
`Patent Owner provided no new arguments that Bowers is in a non-analogous
`
`art field as Derbyshire. Accordingly, Patent Owner’s argument on this point
`
`should be dismissed.
`
`13
`
`
`
`'C.
`
`Bailie expressly teaches benefits of imprecise components
`
`Patent Owner’s argument that “Bailie demands a vetted approach while the
`
`Bowers approach must practically be u'nvetted” in essence is saying that Bailie
`
`teaches away from the Bowers’ approach. Paper 19 at 33.
`
`,
`
`Contrary to Patent Owner’s assertion, Bailie teaches the benefits of using
`
`imprecise components in the tire pressure sensors to help avoid transmission ,
`
`collisions. Bailie expressly taught that the roll switches used to trigger the start of
`
`the driving mode and the parking mode should have a natural spread in order to
`
`decrease “the likelihood of clashing or word collision at the receiver.” Bailie,
`
`Exhibit 1006, col. 6,
`
`11. 42—58. Thus, Bailie describes a means of naturally
`
`avoiding, clashing or transmission overlap by taking advantage of the natural
`
`imprecision in the roll switches of the various sensor wheel units. The fact that
`
`one embodiment of Bailie patent is devoted to a more precise, vetted approach
`
`built into the sensor processor does not negate the fact that it teaches the imprecise
`
`r011 switches as having the same benefit as well.
`
`D.
`
`Claims 3 and 8 are obvious in View of Derbyshire, Bailie, and
`Bowers
`
`Patent Owner again mischaracterized the teaching of Bowers to allege that
`
`“Bowers demands wider tolerance values than 20%, not less.” Paper 19 at 37,
`
`emphasis in original. Nowhere does Bowers “demand” tolerance values greater
`
`than 20%. Rather, Bowers taught
`
`that components having a predetermined
`
`l4
`
`
`
`
`tolerance level, “such as a +/—20% tolerance”, would decrease the chance of data
`
`clashing. Bowers, Exhibit 1005 at col. 8, 11. 19-28 (underlining added).
`
`Further, claims ‘3 and 8 recite. an arbitrary number for the amount of
`
`imprecision of the RC—type oscillator (i.e. “about +/- 15%”). Where the general
`
`conditions of a claim are disclosed in the prior art, discovering the “optimum
`. range” involves only routine skill in the art. In re Aller, 220 F.2d 454, 456 (CCPA
`
`1955). Moreover, Patent Owner has offered no evidence to rebut the prima facie
`
`case, such as evidence that the particular 15% value achieves unexpected results.
`
`Accordingly, claims 3 and 8 are likewise obvious.
`
`V.
`
`CONCLUSION
`
`For the foregoing reasons, the Petitioner respectfully requests that claims 1-5
`
`and 7—11 ofthe ’973 patent be canceled.
`
`V
`
`'
`
`_ Respectfully submitted,
`
`PILLSBURY WINTHROP SHAW
`
`TTMAN L
`
` Dated: September 12, 2013
`
` Reg.N 43,560
`Tel. No. 703.770.7538
`
`FaXNo. 703.770.7901
`
`PO. Box 10500
`
`McLean, VA 22102
`(703) 770-7900
`
`15
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true copy ofthe PETITIONER’S REPLY TO
`
`RESPONSE OF PATENT OWNER was served in their entirety by EXPRESS
`
`MAIL® this 13th day of September, 2013 on the attorney of record of Continental
`
`Automotive Systems US, Inc., owner of the subject patent, as indicated below:
`
`Timothy R. Baumann
`Steven G. Parmelee
`
`Fitch Even Tabin & Flannery, LLP
`120 South LaSalle Street
`
`Suite 1600
`
`Chicago, Illinois 60603
`
`A courtesy copy of the same was also emailed to tbaumanngQfitchevencom
`
`and sgparmgagfitchevencom, as requested by the patent owner.
`
`Dated: September 12, 2013
`
`Fax No. 703.770.7901
`
`13.0. Box 10500
`
`.
`
`McLean, VA 22102
`(703) 770—7900
`
`
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
