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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`MICROSTRATEGY, INC.
`Petitioner
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`v.
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`ZILLOW, INC.
`Patent Owner
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`Case IPR2013-00034
`Patent 7,970,674
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`PETITIONER’S REPLY TO
`PATENT OWNER RESPONSE TO PETITION
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`Case IPR2013-00034
`Attorney Docket No: 30693-0090IP1
`TABLE OF CONTENTS
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`I.
`II.
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`Page
`INTRODUCTION .................................................................................................... 1
`INDEPENDENT CLAIMS 2 AND 15 ......................................................................... 2
`A. The Patent Owner Incorrectly Applies Claim Scope Disavowal ............................. 2
`B. The Term “Automatic Valuation” Does Not Require an “Automated Valuation
`Model” ............................................................................................................. 5
`C. Even If the Claims Require An AVM, Dugan And Kim Describe Systems that Would
`Be Classified as AVMs By One of Ordinary Skill ................................................. 9
`D. The Dugan and Kim Systems Do Not Require Appraiser Oversight .................... 12
`III. DEPENDENT CLAIMS 8, 12 TO 14, 27, 30, 34, AND 38 .......................................... 14
`IV. CONCLUSION...................................................................................................... 15
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`Case IPR2013-00034
`Attorney Docket No: 30693-0090IP1
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`LIST OF EXHIBITS
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`Uniform Standards of Professional Appraisal Practice
`and Advisory Opinions 2005 Edition, Appraisal
`Standards Board, The Appraisal Foundation, Effective
`January 1, 2005
`(Reserved)
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`(Reserved)
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`(Reserved)
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`USPAP Q&A, The Appraisal Foundation, Vol. 9, No. 6,
`June 2007
`Standard on Automated Valuation Models (AVMs),
`International Association of Assessing Officers,
`Approved September 2003
`RMBS: Guidelines for the Use of Automated Valuation
`Models for U.K. RMBS, September 26, 2005
`real-info.com, “What is an AVM?” December 22, 2005
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`MICROSTRATEGY 1014
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`MICROSTRATEGY 1015
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`MICROSTRATEGY 1016
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`MICROSTRATEGY 1017
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`MICROSTRATEGY 1018
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`MICROSTRATEGY 1019
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`MICROSTRATEGY 1020
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`MICROSTRATEGY 1021
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`MICROSTRATEGY 1022
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`Deposition of John A. Kilpatrick, Ph.D., August 8, 2013
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`MICROSTRATEGY 1023
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`Declaration of Dr. Richard Borst
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`Case IPR2013-00034
`Attorney Docket No: 30693-0090IP1
`TABLE OF AUTHORITIES
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`Cases
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`Advanced Fiber Techs. Trust v. J&L Fiber Servs., Inc., 674 F.3d 1365 (Fed. Cir. 2012)
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`Omega Eng'g, Inc. v. Raytek Corp., 334 F.3d 1314 (Fed. Cir. 2003)
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`In re Am. Acad. Sci. Tech Ctr., 367 F.3d 1359 (Fed.Cir.2004)
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`Teleflex, Inc. v. Ficosa N. Am. Corp., 299 F.3d 1313 (Fed.Cir.2002)
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`Chef America, Inc. v. Lamb-Weston, Inc., 358 F.3d 1371 (Fed. Cir. 2004)
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`In re American Academy of Science Tech Center, 367 F.3d 1359 (Fed. Cir. 2004)
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`Case IPR2013-00034
`Attorney Docket No: 30693-0090IP1
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`I.
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`INTRODUCTION
`The Patent Owner’s Response filed on June 14, 2013 presents several arguments
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`through which the following positions are advanced in an attempt to distinguish independent
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`claims 2 and 15 from Dugan and Kim: (1) the term “automatic valuation,” as recited in
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`independent claims 2 and 15, requires the implementation of an Automated Valuation Model
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`(AVM); and (2) Dugan and Kim describe “appraisal systems,” which are exclusively used by
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`appraisers and which produce an output that is different than the output of an AVM.
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`Relatedly, the Patent Owner’s Response also attempts to narrow the scope of various claim
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`terms through claim scope disavowal.
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`To support these arguments, the Patent Owner introduces, for the first time, the
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`concept of an “Automated Valuation Model.” It is clear from the prior art submitted by the
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`Patent Owner during original prosecution that the Patent Owner was aware of the term
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`“Automated Valuation Model.” See Ex. 1001, p. 2 (listing at least two references submitted
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`by the Patent Owner of which the subject is AVM technology). Nonetheless, the term
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`“Automated Valuation Model” was not included anywhere in the specification or claims of
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`the ʼ674 patent, nor was this term (or the term, “automatic valuation”) ever mentioned by the
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`Patent Owner during the original prosecution of the ʼ674 patent to describe the Patent
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`Owner’s invention. Yet, Patent Owner anchors its response in the misguided view that the
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`term is within and required by the claims at issue. It is not.
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`Patent Owner’s attempt to not incorporate this language into claims 2 and 15 of the
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`ʼ674 patent through amendment is not appropriate, nor is the evidence in support of this
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`position credible To this latter point, Petitioner herewith submits a declaration by Dr.
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`Richard Borst, which responds to assertions made by Patent Owner and Dr. Kilpatrick by
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`demonstrating the unreasonableness of reading the claim term “automatic valuation” as
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`requiring a different term of art, namely “Automated Valuation Model,” and which also
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`responds to inaccurate descriptions of the prior art that were introduced by Dr. Kilpatrick
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`and relied upon by Patent Owner. Dr. Borst demonstrates that AVM technology is
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`incorporated in Dugan and Kim, making them applicable even if the claims were somehow
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`read to require the “Automated Valuation Model” term of art. Based on the following
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`arguments and Dr. Borst’s Declaration, Petitioner respectfully requests that the Patent Trial
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`and Appeal Board find claims 2, 5-17, and 26-40 unpatentable based on the grounds
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`instituted as part of this IPR.
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`II.
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`INDEPENDENT CLAIMS 2 AND 15
`A.
`The Patent Owner Incorrectly Applies Claim Scope Disavowal
`At two different points, the Patent Owner’s Response inappropriately seeks to
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`narrow the scope of independent claim terms through present disclaimer/disavowal. In
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`doing so, the Patent Owner’s Response either misinterprets or misapplies the legal principle
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`of claim scope disavowal.
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`In the first instance, at page 19, the Patent Owner’s Response argues:
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`Patent Owner respectfully submits that any proper construction of [“user
`knowledgeable about the distinguished home”], must be limited to the owner
`of a home, or someone with equivalent knowledge, because Patent Owner
`has made a clear and unambiguous disavowal of any broader construction,
`or, if not deemed to have previously done so, at the very least herein
`expressly disclaims any construction that is broader than "the owner or a
`person with equivalent knowledge to the owner.”
`Patent Owner’s Response, p. 19 (emphasis added).
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`Similarly, in the second instance, the Patent Owner’s Response argues: “To the
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`extent that the Board does not recognize this ordinary meaning [of “automatic valuation”],
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`however, Patent Owner hereby expressly disclaims any claim scope that would encompass
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`computerized tools used by appraisers to perform appraisals.” Patent Owner Response, p.
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`20 (emphasis added).
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`In supporting its application of claim scope disavowal, the Patent Owner’s Response
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`cites to case law. However, the Patent Owner fails to note that each of the cited cases
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`deals with interpretation of claim terms during litigation, not during proceedings at the U.S.
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`Patent and Trademark Office, which afford Patent Owners an opportunity to amend claims
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`and which therefore approach claim interpretation differently. See Patent Owner’s
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`Response, p. 18. Specifically, in AFT Trust, the Federal Circuit considered the implications
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`of a clear and unambiguous disavowal of claim scope on how the claims should be
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`construed by the district court; AFT Trust does not therefore support the use of disavowal
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`during ongoing proceedings before the U.S. Patent and Trademark Office to narrow claim
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`scope under the broadest reasonable interpretation applicable during those same
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`proceedings. See Advanced Fiber Techs. Trust v. J&L Fiber Servs., Inc., 674 F.3d 1365,
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`1372-73 (Fed. Cir. 2012).
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`In fact, the Omega Engineering Court, to which the Patent Owner’s Response
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`directly cites, recognizes that the doctrine of prosecution disclaimer was originally created to
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`“preclud[e] patentees from recapturing through claim interpretation specific meanings
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`disclaimed during prosecution.” Omega Eng'g, Inc. v. Raytek Corp., 334 F.3d 1314, 1323
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`(Fed. Cir. 2003). While a patent applicant may act as his or her own lexicographer, the
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`Court requires that the patent applicant “demonstrate an intent to deviate from the ordinary
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`and accustomed meaning of a claim term by including in the specification expressions of
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`manifest exclusion or restriction, representing a clear disavowal of claim scope.” In re Am.
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`Acad. Sci. Tech Ctr., 367 F.3d 1359, 1365 (Fed.Cir.2004) (quoting Teleflex, Inc. v. Ficosa
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`N. Am. Corp., 299 F.3d 1313, 1325 (Fed.Cir.2002)) (emphasis added).
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`Under the broadest reasonable interpretation standard, disclaimer in the manner
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`attempted by the Patent Owner is simply inappropriate and it should not be permitted as an
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`alternative to amendments clearly afforded by procedure. Quite the opposite, an applicant
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`should be required to tune their claims, through amendment, to reflect desired scope, and
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`thus, to allow the claims themselves to achieve a broadest reasonable interpretation that is
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`precise. To this point, “[c]onstruing claims broadly during prosecution is not unfair to the
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`applicant (or, in this case, the patentee), because the applicant has the opportunity to
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`amend the claims to obtain more precise claim coverage.” Am. Acad. Sci., 367 F.3d at
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`1364.
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`In this IPR, the Patent Owner had an opportunity to amend the claims to include
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`clear language that reflects the interpretations that the Patent Owner is now attempting to
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`achieve through an ex post facto disavowal of claim scope. Therefore, Petitioner
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`respectfully requests that Patent Owner’s attempt to disavow claim scope be rejected.
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`B.
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`The Term “Automatic Valuation” Does Not Require an “Automated Valuation
`Model”
`Patent Owner’s Response suggests that the words “automatic valuation” necessarily
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`require the use of an Automated Valuation Model (AVM), even when subject to their
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`broadest reasonable interpretation. Petitioner disagrees.
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`Petitioner’s view is informed by well-established legal principals. Ordinarily, in the
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`absence of an indication that their use in a particular context changes their meaning,
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`English words whose meaning is clear and unquestionable are construed to mean exactly
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`what they say. See Chef America, Inc. v. Lamb-Weston, Inc., 358 F.3d 1371, 1372 (Fed.
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`Cir. 2004). Indeed, as long as the specification is not inconsistent, the claims must be
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`interpreted during examination as broadly as their terms reasonably allow. See In re
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`American Academy of Science Tech Center, 367 F.3d 1359, 1369 (Fed. Cir. 2004).
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`As previously mentioned, the term of art “Automated Valuation Model” was not
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`included anywhere in the specification of the ʼ674 patent, nor was it ever before mentioned
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`by the Patent Owner during the original prosecution of the ʼ674 patent to describe the
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`Patent Owner’s invention, much less the term “automatic valuation.” The specification only
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`recites the term “automatic valuation” in each of its title, background section, and the claims.
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`In doing so, the ʼ674 patent provides no clear definition for this term, leading those of skill to
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`apply the term’s ordinary meaning. Moreover, the ʼ674 patent does not use the term
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`“automatic valuation” in a context that would lead one of ordinary skill in the art to limit that
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`term beyond the ordinary meaning of its constituent words, nor to otherwise establish that
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`those words require the features of an AVM. See Ex. 1023, ¶ 16.
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`Yet, while Dr. Kilpatrick attempts to establish (through his declaration and deposition
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`testimony) that “automatic valuation” is “synonymous with automated valuation model or
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`AVM,” he is never able to refer to any specific intrinsic or extrinsic evidence in support of
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`this theory; rather, when asked for the same, Dr. Kilpatrick simply references the entirety of
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`the ʼ674 patent without citing to specific intrinsic or extrinsic evidence. Ex. 1022, 63:20-21.
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`To this point, Dr. Kilpatrick admits that his comparison of the ʼ674 patent with the Dugan
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`and Kim references involved consideration of the ʼ674 patent “holistically” without being
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`“specifically focused on the claims.” Ex. 1022, 60:13-21; see also Ex. 1013, ¶ 19 (“My
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`report does not address every detail of the claims, but assesses broadly whether Dugan
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`discloses the thrust of the ʼ674 invention.”). Moreover, Dr. Kilpatrick asserts that his
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`declaration relies “on how a person of ordinary skill in the art, in 2006, would have
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`understood the ʼ674 invention,” but his cross-examination testimony sets forth at least two
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`different definitions of such a person that he considered in preparing his declaration. See
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`Ex. 1022, 45:24 to 47:1 (“a person who is familiar with AVMs and familiar with real estate
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`appraisal”), 47:20 to 49:10 (clarifying this familiarity as “something that at least approaches
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`Ph.D.-level statistical knowledge, training and experience, plus an intense amount of
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`experience, understanding, and expertise in real estate appraisal”), 213:19 to 214:8 (on re-
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`direct, changing this earlier definition to “[r]eal estate appraisers who had a working
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`knowledge and ability of the use of automated valuation model, or for that matter, any real
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`estate professional”).
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`Without a clear definition in the specification, the term “automatic valuation” must be
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`“construed to mean exactly what [it] say[s].” Chef America, Inc., 358 F.3d at 1372.
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`Considering its use within the claims and within the context of the ʼ674 patent itself, one of
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`ordinary skill in the art would understand the broadest reasonable interpretation of the term
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`“automatic valuation” to be “a calculation of a value of a distinguished property or home
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`performed without human intervention.” Ex. 1023, ¶18.
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`Under this proper interpretation, Dugan and Kim both clearly describe an “automatic
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`valuation.” Dugan describes a system that determines a valuation for a property. See Ex.
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`1003, 8:32-34. In particular, the system described by Dugan either allows its operator to
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`select a number of comparable properties or automatically suggests “comparable properties
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`based upon preferences of the subject property, such as location, facilities, or other
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`information.” Ex. 1003, 7:60-65. “If the operator is satisfied with the comparable properties
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`selected, the system will proceed to determine an appraised value” for the subject property.
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`Ex. 1003, 8:32-34 (emphasis added).
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`Therefore, Dugan clearly describes that “the system” calculates the valuation of the
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`subject property and does not describe that any human intervention is necessary for the
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`system to perform this calculation. One of ordinary skill in the art would understand Dugan
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`to describe a computer system that calculates a value of a distinguished property or home
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`performed without human intervention. See Ex. 1023, ¶ 21.
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`Similarly, Kim describes operations 1400 of an exemplary appraiser valuation engine
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`that includes “[a]n estimating operation 1416 [that] ranks the comparable properties relative
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`to the subject property and estimates a subject property value based on the comparable
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`property characteristics.” Ex. 1004, ¶ 0093. In other words, Kim describes an estimating
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`operation performed by a valuation engine that resides on a web server or client computer.
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`Ex. 1004, ¶ 0032. Kim does not describe that any human intervention is necessary for the
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`valuation engine to estimate a subject property value. One of ordinary skill in the art would
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`understand Kim to describe a computer system that calculates a value of a distinguished
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`property or home performed without human intervention. See Ex. 1023, ¶ [22].
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`Therefore, contrary to the arguments of the Patent Owner’s Response, Dugan and
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`Kim describe “automatic valuations.” In fact, the Patent Owner’s Response admits that the
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`prior art describes valuations that “may be automatically calculated by a ‘system’.” Patent
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`Owner’s Response, p. 21.
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`C.
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`Even If the Claims Require An AVM, Dugan And Kim Describe Systems that
`Would Be Classified as AVMs By One of Ordinary Skill
`Through its proposed construction of “automatic valuation,” the Patent Owner’s
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`Response attempts to import alleged features of AVMs into the claim language in order to
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`distinguish Dugan and Kim. For example, Dr. Kilpatrick testified that, through implicit
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`inclusion of an AVM, the claims necessarily require the use of a regression model. See Ex.
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`1022, 78:1-5. By lacking a regression model, Dr. Kilpatrick declares that Dugan and Kim
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`are distinguishable from claims 2 and 15. See Ex. 1013, ¶¶ 45-46, 48. Similarly, again
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`through implicit inclusion of an AVM, Dr. Kilpatrick declared that the valuation recited in
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`claims 2 and 15 is necessarily different than the “appraisal value” described by Dugan and
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`Kim. However, as will be explained in greater detail below, AVMs do not require regression
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`models and the output of an AVM is indistinguishable from the output of the Dugan and Kim
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`systems. In fact, one of ordinary skill in the art would have understood Dugan and Kim to
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`describe systems that could be classified as AVMs.
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`Dr. Kilpatrick contends in his deposition that AVMs have a laundry list of
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`characteristics, but his opinion defies logic and it is therefore unsurprisingly unsupported by
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`any authority. See, e.g., Ex. 1013, ¶¶ 26, 37-38; see also Ex. 1022, 22:4 to 23:5, 63:24 to
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`68:16, 75:7-12, 79:24 to 82:10. For example, Dr. Kilpatrick declares that “[t]he
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`distinguishing feature of the AVM is the use of computer algorithms to generate values in a
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`statistical fashion based on a large data set of sales, without any need for an appraiser to
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`identify comparable properties.” Ex. 1013, ¶ 37. However, this definition of an AVM, along
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`with the various definitions Dr. Kilpatrick set forth during his cross-examination, find no
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`support beyond his own naked advancement of them. See, e.g., Ex. 1022, 64:5 to 68:16.
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`As demonstrated below, under the weight of authority, these opinions cannot stand.
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`Both the Uniform Standards of Professional Appraisal Practice (USPAP) and the
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`“Standard on Automated Valuation Models” approved and published by the International
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`Association of Assessing Officers (hereinafter the “IAAO Standard”) define AVMs much
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`broader than Dr. Kilpatrick. Indeed, Dr. Kilpatrick cited to these same (or similar authorities)
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`in his declaration. Ex. 1013, ¶¶ 20, 38, 42; n. 1, 5. Moreover, Dr. Kilpatrick testified that he
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`either adheres or makes reference to these standards in performing his professional work.
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`See Ex. 1022, 8:10 to 9:7, 10:10-21.
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`Advisory Opinion 18 of the USPAP defines an AVM as “a computer software
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`program that analyzes data using an automated process.” Ex. 1014, 178:15. Advisory
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`Opinion 18 goes on to describe that “AVMs may use regression, adaptive estimation, neural
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`network, expert reasoning, and artificial intelligence programs.” Ex. 1014, 178:15-17. In
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`other words, contrary to Dr. Kilpatrick’s declaration and testimony, the USPAP recognizes
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`that AVMs do not necessarily require a regression model.
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`In his cross-examination, Dr. Kilpatrick countered Advisory Opinion 18 by noting that
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`“[b]y 2006, it was grossly out of date.” Ex. 1022, 123:24. However, the most current
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`release of the USPAP still contains Advisory Opinion 18. See USPAP, pp. A-42 to A-43.
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`Moreover, the IAAO Standard, which wasn’t published until 2003, defines AVMs equally as
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`broad as the USPAP. Specifically, the IAAO Standard recognizes that any one of
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`regression, adaptive estimation, or neural networks is an appropriate calibration technique
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`for AVMs.
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`Furthermore, the IAAO Standard specifies a “distinguishing feature” of AVMs that is
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`different than the “distinguishing feature” offered by Dr. Kilpatrick. Specifically, the IAAO
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`Standard states that “[t]he distinguishing feature of an AVM is that it is a market appraisal
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`produced through mathematical modeling.” Ex. 1019, p. 5 (emphasis added). One of
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`ordinary skill in the art would understand Dugan and Kim to describe computer systems that
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`generate market appraisals produced through mathematical modeling. See Ex. 1023, ¶¶
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`27-28. Therefore, Dugan and Kim meet the definition of an AVM set forth in the IAAO
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`Standard. See id.
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`The Patent Owner’s Response also tries to draw a distinction between an AVM-
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`based valuation that it alleges is required by independent claims 2 and 15 and the
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`“appraisals” generated by the Dugan and Kim systems. However, one of ordinary skill in
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`the art would recognize that all three of these systems “produce estimates of market value.”
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`Ex. 1023, ¶ 30. The use of the word “appraisal” in Dugan and Kim is consistent with the use
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`of that term by the IAAO Standard to describe the output of an AVM. See id.; Ex. 1019, p.
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`5. In other words, the outputs of the Dugan and Kim systems are the same in nature as the
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`output of the system described in the ʼ674 patent, regardless of whether claims 2 and 15
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`specifically require an AVM. See Ex. 1023, ¶¶ 30-31.
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`The Dugan and Kim Systems Do Not Require Appraiser Oversight
`D.
`The Patent Owner’s Response also argues that Dugan and Kim do not describe or
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`suggest claims 2 and 15 because the systems described by Dugan and Kim “require
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`‘appraiser’ oversight.” Patent Owner’s Response, pp. 22, 26-28. The Kilpatrick Declaration
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`argues that “an appraiser must control the appraisal process” and “oversee all aspects of
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`the appraisal, and would not simply allow the seller to revise data sets unilaterally.” Ex.
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`1013, ¶ 31. However, these arguments are undermined by both the Dugan and Kim
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`references themselves, as well as Dr. Kilpatrick’s own testimony.
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`Specifically, Dugan describes its system in terms of use by an “operator.” See 1003,
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`7:41 to 9:30. Though Dugan describes that an “appraiser” is one example of an “operator,”
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`Dugan’s use of these two terms distinctly requires that the term “operator” be interpreted to
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`encompass actors other than just appraisers. Similarly, Kim describes its system in terms
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`of use by a “user.” See Kim, ¶¶ 0032-0033, 0042. As with Dugan’s reference to an
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`appraiser being just one example of an operator, Kim specifically acknowledges that
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`“appraisers” are merely an example of the users that may access its system. See Kim, ¶
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`0042.
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`During his cross-examination, Dr. Kilpatrick acknowledged these facts.
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`Contradicting the position set forth in their Patent Owner’s Response, Dr. Kilpatrick said that
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`both sellers and buyers could use the Dugan and Kim systems. See Ex. 1022, 152:22 to
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`153:8, 156:3 to 157:4. Specifically, in response to a question of whether “sellers could use
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`the system of Dugan,” Dr. Kilpatrick said “sure,” though he attempted to place this use in the
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`context of appraising a single property, as opposed to a mass appraisal. Ex. 1022, 152:22.
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`When similarly asked whether “[s]ellers could use the system of Kim,” Dr. Kilpatrick
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`responded: “Sellers, interested people. If you want to know what your neighbor's property is
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`worth, you could appraise your property and use Kim to assist you in that appraisal.” Ex.
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`1022, 156:21-25.
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`Dugan and Kim clearly do not limit use of their systems to appraisers, as argued in
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`the Patent Owner’s Response. Moreover, the statements of Dr. Kilpatrick during cross-
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`examination clearly support the “Decision – Institution of Inter Partes Review” in its
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`conclusion that “it would have been obvious to substitute a seller for the buyer and
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`appraiser who inputs information in Dugan, because it would make the appraisal more
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`accurate, for example, by allowing the seller to fix errors, and thus make the appraisal more
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`trustworthy and reliable to all parties, especially the seller.” Paper 17, p. 17.
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`III. DEPENDENT CLAIMS 8, 12 TO 14, 27, 30, 34, AND 38
`The Patent Owner’s Response presents various arguments why the prior art cited in
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`the Petition does not describe or suggest the limitations of dependent claims 8, 12 to 14, 27,
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`30, 34, and 38. See Patent Owner’s Response, pp. 28-38. Notably, the Patent Owner’s
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`Response does not cite to any new extrinsic evidence to support their arguments for these
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`dependent claims. Moreover, the arguments regarding dependent claims 8, 13, 14, and 30
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`rely primarily upon the arguments made with regard to independent claims 2 and 15, which
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`Petitioner addresses above.
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`The Petitioner submits that the arguments made in the Patent Owner’s Response
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`with regard to claims 8, 12 to 14, 27, 30, 34, and 38 do not overcome the rejections of these
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`claims that were set forth in the Petition. Accordingly, for at the reasons set forth in the
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`Petition, the Patent Trials and Appeals Board should find claims 8, 12 to 14, 27, 30, 34, and
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`38 unpatentable based on the prior art cited in the Petition.
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`14
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`Case IPR2013-00034
`Attorney Docket No: 30693-0090IP1
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`IV. CONCLUSION
`For at least the foregoing reasons, Petitioner respectfully requests that the Patent
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`Trials and Appeals Board find claims 2, 5-17, and 26-40 unpatentable based on the grounds
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`instituted as part of this IPR.
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`The absence of comments in reply to a specific assertion made by the Patent Owner
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`does not signify agreement with or concession of that assertion. In addition, because the
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`arguments made above may not be exhaustive, there may be reasons for unpatentability of
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`any or all pending claims (or other claims) that have not been expressed. Finally, nothing in
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`these comments should be construed as an intent to concede any issue with regard to any
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`claim, except as specifically stated in these comments.
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`Please apply any fees or any credits to Deposit Account No. 06-1050.
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`August 26, 2013
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`Date:
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`Customer Number 26171
`Fish & Richardson P.C.
`Telephone: (612) 337-2508
`Facsimile: (612) 288-9696
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`Respectfully submitted,
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`/Karl Renner/
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`W. Karl Renner, Reg. No. 41,265
`Attorney for Petitioner
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`15
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR §§ 42.6(e)(4)(i) et seq. and 42.105(b), the undersigned certifies
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`that on August 26, 2013, a complete and entire copy of this Petitioner’s Reply to
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`Patent Owner Response to Petition and all supporting exhibits were provided via
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`email to the Patent Owner by serving the email correspondence addresses of record
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`as follows:
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`Steven D. Lawrenz
`Ramsey M. Al-Salam
`Perkins Coie LLP
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101
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`Email: slawrenz@perkinscoie.com
`Email: ralsalam@perkinscoie.com
`Email: patentprocurement@perkinscoie.com
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`/Edward G. Faeth/
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`Edward G. Faeth
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(202) 626-6420
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`
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