IPR2014-00039 (U.S. Patent No. 6,628,314)
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`Petitioner Reply
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`Paper No. 33
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
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`MICROSOFT CORPORATION AND GOOGLE INC.
`Petitioner,
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`v.
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`B.E. TECHNOLOGY, LLC,
`Patent Owner
`_________________________
`
`Case IPR2014-00039
`Patent No. 6,628,314 B1
`________________________
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`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE
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`Petitioner Reply
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`Paper No. 33
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`MICROSOFT CORPORATION AND GOOGLE INC.
`Petitioner,
`
`v.
`
`B.E. TECHNOLOGY, LLC,
`Patent Owner
`_________________________
`
`Case IPR2014-00039
`Patent No. 6,628,314 B1
`________________________
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`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE
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`IPR2014-00039 (U.S. Patent No. 6,628,314)
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`Petitioner Reply
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`TABLE OF CONTENTS
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`I.
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`Guyot Anticipates Claims 11-15 and 17-19 of the ’314 Patent .................. 1
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`A. Guyot Discloses a Method of Providing Demographically-
`Targeted Advertising to a Computer User ....................................... 1
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`1.
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`2.
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`3.
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`Guyot Discloses Acquiring Demographic Information and
`Using that Information to Target Advertising to Users ........ 1
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`Patent Owner’s Expert Admits that Guyot Collects
`Demographic Information ........................................................ 2
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`Patent Owner Misunderstands the Test for Anticipation ..... 4
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`B. Guyot Discloses Transferring a Copy of the Software In Response
`to a Download Request By the User .................................................. 5
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`C. Guyot Teaches Providing a Unique Identifier to the Computer .. 10
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`II. Claims 20-22 Are Obvious Based on Guyot in View of RFC 1635 ......... 13
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`III. Guyot Anticipates and/or Renders Obvious Claims 12-22 ...................... 14
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`IV. The PTO Acted Within Its Rule-Making Authority ................................ 15
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`V. Conclusion .................................................................................................... 15
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`IPR2014-00039 (U.S. Patent No. 6,628,314)
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`Petitioner Reply
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`I.
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`Guyot Anticipates Claims 11-15 and 17-19 of the ’314 Patent
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`The Board correctly found claims 11-15 and 17-19 of the ’314 patent
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`anticipated by Guyot. Decision at 10-13. In response, Patent Owner argues Guyot
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`does not show (i) collection of “demographic information”; (ii) transfer of software
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`in response to a download request by the user, or (iii) providing a unique identifier
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`to the computer. Each argument relies on limitations not found in the claims, and
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`conflicts with or disregards evidence in the record. The Board should maintain its
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`determination that claims 11-15 and 17-19 are unpatentable.
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`A. Guyot Discloses a Method of Providing Demographically-
`Targeted Advertising to a Computer User
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`The Board correctly found that Guyot shows “a method of providing
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`demographically-targeted advertising” and “acquiring demographic information
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`about the user” per claim 11 of the ’314 patent. Decision at 10-11. In response,
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`Patent Owner does not dispute that Guyot teaches processes that collect
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`information and use that information to deliver targeted ads. Instead, Patent Owner
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`contends “demographic information is neither explicitly nor inherently disclosed in
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`Guyot.” Response at 10-15. The evidence refutes Patent Owner’s contentions.
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`1. Guyot Discloses Acquiring Demographic Information and
`Using that Information to Target Advertising to Users
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`The Board correctly found Guyot shows collection and use of demographic
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`information. Decision at 11-12. Guyot shows a user profile being generated using
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`-1-
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`IPR2014-00039 (U.S. Patent No. 6,628,314)
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`Petitioner Reply
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`answers to a questionnaire presented to the user. Ex. 1006 (Guyot) at 3:61-65;
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`Petition at 28-29; Ex. 1003 at ¶¶ 76-81, 266, 273-274, 300-301; Ex. 1028 at ¶¶ 6-
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`12. The ’314 patent acknowledges this web-based questionnaire technique was
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`commonly used to collect demographic information. Ex. 1001 at 2:29-34 (“Perhaps
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`the most common way to acquire demographic data regarding users via the Internet
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`is to request the information using a form written in html (HyperText Markup
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`Language) and provided to the user over the World-Wide Web (WWW) using http
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`(HyperText Transfer Protocol).”). Dr. Houh explained a person of ordinary skill in
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`the art would have read this description in Guyot as describing a process that
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`collects “demographic information” within the meaning of the claims—i.e.,
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`“collected characteristic information about a user.” Ex. 1027 at 189:10-192:5,
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`208:3-12, 209:17-210:15; Ex. 1003 at ¶¶ 266, 273-274, 300-301; see also Ex. 1028
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`at ¶¶ 6-16. This is because, for example, the information collected by the user
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`profile questionnaire is used to establish and update the user’s personal profile,
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`which the server uses to direct targeted advertising to the user. Id.; Ex. 1006
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`(Guyot) at 3:61-65; Ex. 1003 at ¶¶ 273-275, 278; Ex. 1028 at ¶ 9; see also id. at ¶¶
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`6-12.
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`2.
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`Patent Owner’s Expert Admits that Guyot Collects
`Demographic Information
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`Patent Owner’s Expert, Mr. Goldstein, conceded at his deposition that Guyot
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`describes collection of demographic information within the Board’s construction.
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`IPR2014-00039 (U.S. Patent No. 6,628,314)
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`Petitioner Reply
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`For example, he agreed that information documenting certain types of web
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`browsing activity – such as visiting a particular site on a repeated basis over a
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`defined period – is demographic information. For example, when asked if a
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`hypothetical web browsing history documenting that a user visited the CNN
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`website every day over a 30-day period at 9 am each day could be “demographic
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`information,” Mr. Goldstein stated:
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`Q. And so in this browsing history, there’s no user
`identifying information that accompanies it, right, in my
`hypothetical?
`A. That’s correct.
`Q. So then under the board’s definition, it would be
`demographic information as they’ve defined it?
`A. Yes, it would be.
`Ex. 2015 at 54:5-54:23 (emphasis added). It is undisputed that Guyot shows
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`collection of web-browsing information from the user’s computer, sending this
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`information to the server as part of the Subscriber Statistics, and using it to update
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`the user’s profile, which, in turn, is used to direct targeted advertisements. Ex.
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`1006 (Guyot) at 2:36-4; Ex. 275, 278, 290-291. Indeed, Patent Owner admits this
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`type of admittedly demographic information would be collected by the Guyot
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`questionnaire. Response at 13 (“The questionnaire might ask the server to identify
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`preferred websites. Indeed, Guyot teaches that ‘the server utilizes [information on
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`Internet sites that the subscriber has accessed over a predetermined period of time]
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`3
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`IPR2014-00039 (U.S. Patent No. 6,628,314)
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`Petitioner Reply
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`to further define the subscriber’s personal profile.’ Ex. 1006, Col. 4:19-23”). Guyot
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`thus describes a process in which demographic information is collected from a
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`user, and is used to define or update a user’s personal profile, which is used to
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`direct targeted advertising. Ex. 1003 at ¶¶ 275, 278, 290-291; Ex. 1028 at ¶¶ 13-
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`14.
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`3.
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`Patent Owner Misunderstands the Test for Anticipation
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`Patent Owner’s theory that Guyot does not show collection of “demographic
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`information” rests on a mistaken understanding of the law of anticipation.
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`Response at 10-11. An anticipatory reference need not duplicate word-for-word
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`what is in the claims. Instead, anticipation may be found “when a claimed
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`limitation is . . . implicit in the relevant reference.” Standard Havens Products, Inc.
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`v. Gencor Indus., Inc., 953 F.2d 1360, 1369 (Fed. Cir. 1991) (emphasis added).
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`Moreover, what an anticipatory reference teaches must be analyzed from the
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`perspective of a person of ordinary skill. To anticipate, “[t]here must be no
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`difference between the claimed invention and the reference disclosure, as viewed
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`by a person of ordinary skill in the field of the invention.” Smith & Nephew v.
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`Convatec Tech., IPR2013-00102, Paper 87 at 14-15 (PTAB May 19, 2014). When
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`considering what a reference discloses, “it is proper to take into account not only
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`specific teachings of the reference but also the inferences which one skilled in the
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`art would reasonably be expected to draw therefrom.” Denso Corp. and Clarion
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`IPR2014-00039 (U.S. Patent No. 6,628,314)
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`Petitioner Reply
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`Co. v. Beacon Navigation, IPR2013-00026, Paper 34 at 19-20 (PTAB March 14,
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`2014) (emphasis added)(internal citations omitted).
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`Petitioner presented evidence from Dr. Houh establishing that a person of
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`ordinary skill would have interpreted the disclosure in Guyot as describing a
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`process that collects demographic information via a web-based questionnaire
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`technique shown in Guyot. Ex. 1003 at ¶¶ 266, 273-274, 300-301. Dr. Houh
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`explained this technique was a well-known and widely-used technique for
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`capturing demographic information, Ex. 1003 at ¶¶ 76-81, and is consistent with
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`how the ’314 patent illustrates collection of demographic information, Ex. 1001 at
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`2:29-34. Mr. Goldstein agreed that user questionnaires presented via web pages
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`were a well-known and commonly used technique for collecting demographic
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`information. Ex. 2015 at 40:23-41:10. Thus, substantial evidence supports the
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`Board’s determination that Guyot discloses collection of “demographic
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`information” pursuant to the claims of the ’314 patent. Ex. 1003 at ¶¶ 76-81, 266,
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`273-274, 300-301; Ex. 1028 at ¶¶ 6-16.
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`B. Guyot Discloses Transferring a Copy of the Software In Response
`to a Download Request By the User
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`The Board found that Guyot discloses operations that satisfy the requirement
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`in claim 11 of “transferring a copy of said software to the computer in response to
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`a download request by the user.” Decision at 11. As the Board observed, “Guyot
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`discloses that a client application is provided to the subscriber’s computer.”
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`IPR2014-00039 (U.S. Patent No. 6,628,314)
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`Petitioner Reply
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`Decision at 11. Patent owner does not dispute this finding. The Board also
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`observed that Guyot shows that a user can manually connect to the server, and
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`when it does, that action will prompt downloading of updated client software. Id.
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`Thus, the Board correctly found that Guyot discloses two examples of transferring
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`software to the user’s computer in response to a download request by the user. Id.
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`Patent Owner does not dispute that Guyot states that software is downloaded
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`in response to a user’s action, either to enable the initial installation of the software
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`or during an updating process triggered by the user’s action to manually connect to
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`the server. Response at 16-22. Instead, Patent Owner contends the second way of
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`downloading software (i.e., for "updated" software) does not meet the claim
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`language because Patent Owner believes the intention of the user when they take
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`the actions that cause downloading of the software must be considered (i.e., what
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`the user believes at the time the user takes the actions that cause downloading of
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`the software). This putative distinction is illusory and legally irrelevant.
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`Initially, Guyot shows that a client application is provided to a user’s
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`computer over a distributed information network, such as the Internet. Ex. 1006
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`(Guyot) at 1:58-60. As Dr. Houh explains, this means that a user will necessarily
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`make a download request of the server to transfer (i.e., “download”) the software
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`to the user’s computer– this is simply how Internet-based communications work.
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`Ex. 1028 at ¶ 27. This process was (and remains) an extremely common and well-
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`IPR2014-00039 (U.S. Patent No. 6,628,314)
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`Petitioner Reply
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`known technique for acquiring new software. Id.
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`Dr. Houh also explains that Guyot shows a process where a user manually
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`connects to the server, and in response to that action, the server downloads an
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`updated version of the software to the user’s computer. Ex. 1003 at ¶¶ 285-292;
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`Ex. 1006 (Guyot) at 6:44-56; Ex. 1028 at ¶¶ 17-26. Specifically, Guyot shows that
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`a user can manually connect to the server by clicking a “connection” button. Ex.
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`1006 (Guyot) at 6:43-46, 7:25-26 (“At step S400, the control system determines if
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`the connection button 550 has been selected by the subscriber”); Fig. 5 (S400).
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`When this is done, the client application uploads data to the server for further
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`refinement of the user’s personal profile and triggers a process on the server
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`(LOCSOFT) that causes downloading of the latest version of the client application
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`software if the user’s software is not the most current version. Ex. 1028 at ¶¶ 21-
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`22; Ex. 1006 (Guyot) at 1:66-2:1, 8:25-50, Figs. 6A and 7 (describing
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`“LOCSOFT” routine); Ex. 1003 at ¶¶ 288, 291-292. And, importantly, Guyot
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`shows providing “the URL address of the updated version of the client application
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`software” to enable downloading of the updated software. Ex. 1006 (Guyot) at
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`4:24-27; Ex. 1003 at ¶ 276; Ex. 1028 at ¶ 21. An URL is plainly a "download
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`request" – clicking it sends a request to a server to download the file specified in
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`the URL. Ex. 1028 at ¶ 21. Thus, a person of ordinary skill would have read Guyot
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`as showing two different examples of transferring software in response to a
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`IPR2014-00039 (U.S. Patent No. 6,628,314)
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`Petitioner Reply
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`download request by a user. Ex. 1028 at ¶¶ 17-27.
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`Patent Owner and its expert simply ignore the first example. As to the
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`second, Patent Owner asserts that “the subscriber understands only the subscriber
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`statistics need to be uploaded and the advertisement queue needs to be updated, but
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`the subscriber has no information that would cause him or her to perceive even the
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`potential that a new version of the software will be downloaded.” Response 22.
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`Patent Owner’s observations rest on a flawed understanding of the law of
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`anticipation, and are factually incorrect.
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`Initially, neither Patent Owner nor its expert dispute that a user’s request to
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`manually connect to the server will cause the downloading of software to the user’s
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`computer. Response at 19; see Ex. 2015 at 95:22-96:1 (Q. [U]nder the operation of
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`Guyot, the connection to the server will cause downloading the software, correct?
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`A. It could cause downloading of software, yes). Instead, Patent Owner contends
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`the user needs to be “conscious of the request and purposefully make[] the
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`request.” Patent Owner’s response should be disregarded for three reasons.
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`First, the language of the ’314 patent claims forecloses Patent Owner’s
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`theory. The claims state simply “transferring a copy of said software to the
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`computer in response to a download request by the user.” A “download request”
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`according to the claims is what causes downloading of the software to the user’s
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`computer. Ex. 1028 at ¶¶ 19-20. A “download request,” however, necessarily
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`IPR2014-00039 (U.S. Patent No. 6,628,314)
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`Petitioner Reply
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`involves sending data from a user’s computer based on a user’s “request,” which is
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`received by and triggers actions by the server (e.g., downloading of the updated
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`software). Id. Importantly, both experts agree this is described in Guyot (e.g.,
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`clicking the “connection button” is an action taken by the user that causes the
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`user’s computer to send a request to the server, which responds by providing an
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`URL enabling downloading of updated software to the user’s computer). Compare
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`Ex. 1027 (Dr. Houh) at 203:8-204:14 with Ex. 2015 (Mr. Goldstein) at 95:4-96:1;
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`see also Ex. 1028 at ¶¶ 18-22; see also Ex. 1003 at ¶ 273.
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`Second, Patent Owner’s putative distinction is an attempt to read an
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`improper limitation into the claims. This should be rejected because the mental
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`state of a user is not entitled to any patentable weight. 1 Indeed, the Federal Circuit
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`has held that the subjective intentions of an individual purportedly practicing the
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`invention are irrelevant. See, e.g., Amazon.com, Inc. v. Barnesandnoble.com, Inc.,
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`239 F.3d 1343, 1352-53 (Fed. Cir. 2001)(rejecting construction of a claim term
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`1 Q. [Mr. Kushan] You’re not addressing the scenario in this definition of the -- a
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`request being in the form of a message sent by a user’s computer to the server;
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`right? A. [Mr. Goldstein] No. I’m defining a “request” as an action by the user to
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`request software. Q. So that turns, then, on somewhat of the intent of the user
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`in making the request? A. Yes, that is correct. Ex. 1015 at 56:19-57:2.
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`IPR2014-00039 (U.S. Patent No. 6,628,314)
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`Petitioner Reply
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`because it would “inject[] subjective notions into the infringement analysis” and
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`observing “[w]e are not prepared to assign a meaning to a patent claim that
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`depends on the state of mind of the accused infringer.”)(emphasis added).
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`Finally, Patent Owner’s contentions about a user’s lack of awareness of the
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`consequences of its actions are simply incorrect. Patent Owner presents a
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`hypothetical that posits a user will be unaware of the consequences of clicking the
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`connection button in the Guyot system. Response at 21-22. Even if this
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`hypothetical is accepted, it would be true only until the user observed the updating
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`of the client application software occur in response to clicking the manual
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`“connection” button. Ex. 1028 at ¶¶ 23-26. Every subsequent time the user clicked
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`that button, he or she would be aware that doing so will result in downloading of
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`an updated version of the software if one is available. Id. Thus, even under Patent
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`Owner’s hypothetical, a user will acquire the necessary awareness that establishing
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`a manual connection to the server will cause downloading of the software over
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`time. Patent Owner’s hypothetical, thus, is irrelevant and readily dismissed. Id.
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`C. Guyot Teaches Providing a Unique Identifier to the Computer
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`The Board correctly found that Guyot discloses “periodically acquiring said
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`unique identifier and said computer usage information recorded by said software
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`from the computer via said computer network” and “associating said computer
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`usage information with said demographic information using said unique
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`IPR2014-00039 (U.S. Patent No. 6,628,314)
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`Petitioner Reply
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`identifier.” Decision at 13. The Board’s determination is supported by undisputed
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`evidence, and should be maintained.
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`As Dr. Houh explained, Ex. 1003 at ¶¶ 275, 278, 291, Guyot shows that the
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`client application on the user’s computer periodically collects “Subscriber
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`Statistics” data comprising computer usage information, and sends that data to the
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`server over a network connection. Ex. 1006 (Guyot) at 1:66-2:1, 4:15-23, 5:19-24.
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`The Subscriber Statistics are used by the server to update the subscriber’s personal
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`profile, which includes the subscriber’s demographic information. Ex. 1006
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`(Guyot) at 3:57-65; 4:21-23; Ex. 1003 at ¶¶ 266, 273-275, 278. The server in
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`Guyot thus associates computer usage information with demographic information
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`associated with each individual subscriber. To be able to do this, the information
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`collected from each user must be uniquely identified, which Guyot explains is done
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`by including information that is unique to each subscriber. Ex. 1003 at ¶¶ 313; see
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`also Ex. 1006 (Guyot) at 3:57-61 (“The Subscriber Data preferably includes, for
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`reach subscriber, the subscriber’s identification information, a password assigned
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`to the subscriber, and a personal profile of the subscriber that is used to target
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`specific advertisements to the subscriber.”) Thus, Guyot clearly shows providing a
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`unique identifier to the user’s computer in the form of Subscriber Data, and using
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`this “unique identifier” to associate information sent by the user’s computer to the
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`server. Ex. 1003 at ¶¶ 313; Ex. 1028 at ¶¶ 28-34. Additionally, Guyot expressly
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`IPR2014-00039 (U.S. Patent No. 6,628,314)
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`Petitioner Reply
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`states that a “unique proprietary identifier” being provided to each user’s computer
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`system. Ex. 1001 at 3:21-22 (“each of the subscriber system 300 having a unique
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`proprietary identifier.”). Ex. 1003 at ¶¶ 312.
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`Patent Owner first responds that Guyot does not show sending a “unique
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`identifier” from the server to the subscriber computer. Response at 23-24. Once
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`again, Patent Owner improperly reads a non-existent limitation into its claims –
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`there is no requirement in the claims that the unique identifier be sent by the server
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`to the user’s computer – it simply states “providing a unique identifier to the
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`computer.” More importantly, Patent Owner only disputes that one of the two
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`unique identifiers shown in Guyot meets this claim element – it does not dispute
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`the other (the “Subscriber Data”) is sent and stored on the user’s computer. Id.
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`Next, Patent Owner argues that, in one hypothetical configuration (i.e.,
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`where one computer is used by multiple users), Guyot does not meet the “unique
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`identifier” element of the claims. Initially, as its own expert confirmed, this
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`hypothetical configuration is nowhere described in Guyot. Ex. 2015 at 92:17-20
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`(Q. Now, Guyot doesn’t actually say that the computer the user is using has to
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`support multiple user accounts; right? A. That’s correct.); see generally Ex. 2015 at
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`90:10 to 93:19. Thus, under Patent Owner’s own reasoning, a “single user per
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`computer” implementation (i.e., the one actually described in Guyot) does meet the
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`“unique identifier” element of the claims. Ex. 1028 at ¶¶ 28-30.
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`Finally, Patent Owner contends the “unique identifier” must be anonymous,
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`Response at 25. This again seeks to improperly read a non-existent limitation into
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`the claims, which must be rejected. Vibrant Media, Inc. v. G.E. Co., IPR2013-
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`00170, Paper 56 at 5 (PTAB June 26, 2014).
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`II. Claims 20-22 Are Obvious Based on Guyot in View of RFC 1635
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`The Board found that Guyot in view of RFC 1635 (describing the
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`anonymous FTP technique) would have rendered claims 20 to 22 of the ’314 patent
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`obvious to a person of ordinary skill. Decision at 16-19. Patent Owner first
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`responds that Petitioner did not provide a detailed explanation why the claims were
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`obvious. This is simply incorrect – Petitioner and its expert explained that
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`capturing demographic information as a condition of providing download access to
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`a file was a well known technique in client/server systems, which was illustrated
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`by the anonymous FTP technique described in RFC 1635. Petition at 37-42; Ex.
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`1003 at ¶¶ 59-68, 368-385. This technique is the precise concept that Patent Owner
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`contends was not known in the prior art and which differentiates its claimed
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`process from that in Guyot. Patent Owner also contends there was no “motivation
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`to combine” this anonymous FTP technique with Guyot, in part, because Patent
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`Owner believed the combination of the anonymous FTP technique with the Guyot
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`scheme would render it “inoperable.” Response at 3.
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`The latter theory was refuted by Patent Owner’s own witness, who freely
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`IPR2014-00039 (U.S. Patent No. 6,628,314)
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`admitted it would have been trivial to alter the Guyot scheme to use the
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`anonymous FTP technique to provide download access for the Guyot software. Ex.
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`2015 at 80:9-18(“Q. All right. So if I wanted to provide access to a user to an
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`installation program I had on my server via a Web page, I could serve up a Web
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`page with a link that was an FTP link pointing to the installation program I’m
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`asking them to download; right? A. Correct. Q. All right. And that wouldn’t
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`require any special skill to create that kind of a link? A. No, it would not.”)
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`(emphasis added). Patent Owner’s arguments also ignore the undisputed testimony
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`of Dr. Houh, who explained “[p]rompting a user for certain information before
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`providing a user download access to a server would have been an obvious design
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`choice based on knowledge of this broadly-used technique before 1998.” Ex. 1003
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`at ¶ 365, 368, 371. And, while not legally required under KSR Int’l Co. v. Teleflex,
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`Inc., 550 U.S. 398 (2007), the person of ordinary skill would have found a specific
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`motivation within RFC 1635 to implement this obvious design choice in other
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`client/server systems, such as those used in Guyot. Id. The Board’s finding of
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`obviousness thus is fully supported by the record.
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`III. Guyot Anticipates and/or Renders Obvious Claims 12-22
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`The Board found the evidence presented by the Petition sufficient to show:
`
`(i) claims 12-14 and 16-19 of the ’314 patent anticipated by Guyot (Decision at
`
`13); (ii) claim 15 of the ’314 patent obvious based on Guyot in view of Robinson.
`
`
`
`14
`
`
`
`IPR2014-00039 (U.S. Patent No. 6,628,314)
`
`Petitioner Reply
`
`Decision at 15-16, and (iii) claims 20-22 obvious based on Guyot in view of RFC
`
`1635. Patent Owner does not advance any arguments regarding any of these claims
`
`distinct from its arguments regarding claim 11. Response at 26. Because the
`
`findings of unpatentability of claim 11 were proper and supported by substantial
`
`evidence, the Board’s finding that Guyot anticipates claims 12-14 and 16-19, that
`
`Guyot in view of Robinson renders obvious claim 15, and that Guyot in view of
`
`RFC 1635 renders obvious claims 20-22 were also proper.
`
`IV. The PTO Acted Within Its Rule-Making Authority
`
`Patent Owner contends use of the “‘broadest reasonable construction’ rule
`
`exceeded the PTO’s rule-making authority.” Response at 28-30. Patent Owner is
`
`incorrect – the Office was well within its statutory and rulemaking authority to
`
`promulgate Rule 42.100(b) and follow it in this proceeding. See SAP Am., Inc. v.
`
`Versata Dev. Grp., Inc., CBM2012-00001, Paper 70 at 6-19 (PTAB June 11,
`
`2013). Moreover, Patent Owner identifies no consequence of the Board using this
`
`different standard.
`
`V. Conclusion
`
`The Board should maintain its determination that claims 11-22 of the ’314
`
`Patent are unpatentable, and should cancel these claims.
`
`
`
`
`
`
`
`15
`
`
`
`IPR2014-00039 (U.S. Patent No. 6,628,314)
`
`Petitioner Reply
`
`Dated: Sept 24, 2014
`
`
`
`
`
`
`
`Respectfully Submitted,
`
`/Jeffrey P. Kushan/
`Jeffrey P. Kushan
`Registration No. 43,401
`Sidley Austin LLP
`1501 K Street NW
`Washington, DC 20005
`jkushan@sidley.com
`
`
`
`16
`
`
`
`IPR2014-00039 (U.S. Patent No. 6,628,314)
`
`Petitioner Reply
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 24th day of September, 2014, a copy of the
`
`foregoing has been served in its entirety by e-mail on the following counsel of
`
`record for Patent Owner:
`
`Jason S. Angell
`Robert E. Freitas
`Freitas Tseng & Kaufman LLP
`jangell@ftklaw.com
`rfreitas@ftklaw.com
`
`
`Dated:
`
`September 24, 2014
`
`Respectfully submitted,
`
`/Jeffrey P. Kushan/
`Jeffrey P. Kushan
`Reg. No. 43,401
`Sidley Austin LLP
`1501 K Street NW
`Washington, DC 20005
`jkushan@sidley.com
`Attorney for Petitioner
`
`-1-
`
`
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