`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`PATENT TRIAL AND APPEAL BOARD
`____________________
`
`FACEBOOK, INC.,
`Petitioner
`
`v.
`
`B. E. TECHNOLOGY LLC
`Patent Owner
`
`_______________________
`
`Case No. IPR2014‐00052
`Patent No. 6,628,314
`
`
`____________________________________________________________
`
`
`
`
`
`PETITIONER’S OPPOSITION TO PATENT OWNER’S
`CONTINGENT MOTION TO AMEND
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`TABLE OF CONTENTS
`
`
`Page(s)
`
`
`I.
`II.
`III.
`
`IV.
`
`
`
`
`
`
`
`INTRODUCTION ............................................................................................. 1
`BACKGROUND ............................................................................................... 1
`THE PATENT OWNER FAILED TO CARRY ITS BURDEN TO
`DEMONSTRATE PATENTABILITY OF ITS PROPOSED SUBSTITUTE
`CLAIMS .......................................................................................................... 2
`A.
`The patent owner failed to distinguish over the closest prior art ...... 2
`1.
`Apte renders the proposed claims obvious .............................. 4
`2.
`Barrett also renders the proposed claims obvious ................... 8
`3.
`The patent owner’s motion fails to show that its
`proposed substitute claims are patentable under the
`Graham factors ....................................................................... 11
`The proposed substitute claims fail under 35 U.S.C. § 101 .............. 11
`B.
`The patent owner’s substitute claims are indefinite ........................ 13
`C.
`CONCLUSION .............................................................................................. 15
`
`
`
`
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`I.
`
`INTRODUCTION
`
`The patent owner has failed to carry its burden of showing that its
`
`proposed substitute claims in its Contingent Motion to Amend are patentable.
`
`Those proposed claims are obvious in light of the prior art of record in this IPR,
`
`combined with the Apte and Barrett references discussed in more detail below.
`
`The proposed substitute claims also fail to recite patent‐eligible subject
`
`matter and are indefinite. And the patent owner’s motion should also be rejected
`
`because it fails to apply the correct legal standard, does not address the proper
`
`factors, and pays only lip service to the closest prior art of record.
`
`II.
`
`BACKGROUND
`
`On October 9, 2013, Facebook filed two petitions for inter partes review of
`
`claims 11–13, 15, 18, and 20 of the ’314 patent (IPR2014‐00052 and IPR2014‐
`
`00053). The Board instituted inter partes review in IPR2014‐00052 on all
`
`petitioned claims as obvious over U.S. Patent No. 5,809,242 (Ex. 1103) (“Shaw”) in
`
`view of Melissa Dun et al., Privacy and Profiling on the Web (June 1, 1997) (Ex.
`
`1105) (“W3C”). In IPR2014‐00053, the Board instituted inter partes review on all
`
`petitioned claims as obvious over U.S. Patent No. 5,933,811 (Ex. 1003) (“Angles”)
`
`in view of Shaw (Ex. 1004).
`
`
`
`1
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`III.
`
`THE PATENT OWNER FAILED TO CARRY ITS BURDEN TO DEMONSTRATE
`PATENTABILITY OF ITS PROPOSED SUBSTITUTE CLAIMS
`
`In a motion to amend, the patent owner must address the patentability of
`
`its proposed substitute claims. (IPR2013‐00191, paper 70 at 55.) The Board has
`
`made clear that with respect to obviousness, “the patent owner should present
`
`and discuss facts which are pertinent to the first three underlying factual inquiries
`
`of Graham, 383 U.S. at 17–18: (1) the scope and content of the prior art, (2)
`
`differences between the claimed subject matter and the prior art, and (3) the
`
`level of ordinary skill in the art, with special focus on the new claim features
`
`added by the proposed substitute claims.” Id. at 55–56. “Some discussion and
`
`analysis should be made about the specific technical disclosure of the closest
`
`prior art as to each particular feature, and the level of ordinary skill in the art, in
`
`terms of ordinary creativity and the basic skill set of a person of ordinary skill in
`
`the art, regarding the feature.” Id. at 56. But the patent owner failed to address
`
`Graham’s factual inquiries and, as shown below, its proposed substitute claims
`
`are not patentably distinguishable over the prior art.
`
`A.
`
`The patent owner failed to distinguish over the closest prior art
`
`Proposed substitute claim 23 adds two limitations to claim 11: (1) a
`
`
`
`2
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`limitation requiring that computer usage information is collected from “user’s
`
`interactions with . . . at least one other program,” and (2) a limitation that
`
`advertising is selected using “real‐time and other computer usage information.”
`
`The patent owner asserts that no prior art reference discloses these limitations,
`
`but it is mistaken.
`
`It was widely known prior to the earliest priority date of the ’314 patent
`
`that targeted advertising was more effective when it was based on multiple
`
`sources of information about a user and timely presented. (Second Sherwood
`
`Decl., Ex. 1145, ¶¶ 12, 20, 24.) The prior art not only recognized this fact, but
`
`expressly relied upon in describing the same two features recited in patent
`
`owner’s proposed substitution. (Id.) As a result, the patent owner’s substitute
`
`claims are unpatentable and obvious.
`
`As discussed in detail below and supported by the Second Declaration of
`
`Robert J. Sherwood, U.S. Patent No. 7,225,142 to Apte and U.S. Patent No.
`
`6,490,584 to Barrett each render the proposed substitute claims obvious when
`
`viewed in light of Shaw and W3C or Angles and Shaw. (Id. ¶¶ 5‐7.) BE’s amended
`
`claim 23 adds nothing but minor implementation details that persons of ordinary
`
`skill in the art would have viewed as known options for inclusion in a targeted
`
`
`
`3
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`advertising system. (Id.)
`
`1.
`
`Apte renders the proposed claims obvious
`
`U.S. Patent No. 7,225,142 to Apte renders the proposed substitute claims
`
`obvious in combination with either (a) Shaw and W3C (IPR2014‐00052) or (b)
`
`Angles and Shaw (IPR2014‐00053). Because Apte issued from an application filed
`
`on August 1, 1996, it qualifies as prior art under 35 U.S.C. § 102(e) (pre‐AIA).
`
`Although the patent owner discussed Apte in its Contingent Motion to Amend, it
`
`failed to acknowledge the full scope of Apte’s disclosure or adequately distinguish
`
`over its teachings.
`
`Apte discloses a targeted advertising system that collects computer usage
`
`information from “user’s interactions with . . . at least one other program” in the
`
`form of “advertising software [that] operates as an overlay to a conventional,
`
`known browser, such as the Netscape browser, dividing the user’s client
`
`computer display into an advertising area and a browser area.” (Apte, Ex. 2012,
`
`at 3:36–40; Second Sherwood Decl., Ex. 1145, ¶¶ 15‐19.)
`
`The patent owner incorrectly identifies the browser disclosed by Apte as
`
`the software program that displays the advertising content. But Apte actually
`
`discloses “advertising software” separate from the browser that performs the
`
`
`
`4
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`advertising display. (Id. ¶¶ 15‐16.) As Apte explains, “[t]he browser area retains
`
`the original functionality of the underlying browser and operates independently
`
`of the advertising area, except that certain buttons (e.g., control buttons and
`
`electronic transaction buttons) in the advertising area cause pages to load and
`
`display in the browser area when selected.” (Apte, Ex. 2012, 3:51–55; 5:29‐34.)
`
`Apte also discloses that computer usage information is collected about
`
`users’ interactions with the browser and the advertising software. (Apte, Ex.
`
`2012, 9:2‐6 (“The content control window 47 includes a list of topics. . . . When
`
`one or more topics are selected by the user, they are highlighted, and
`
`advertisements pertinent to the highlighted topics appear in the display area.”);
`
`9:14‐17 (“The present invention advantageously provides the capability of
`
`selecting advertisements to show to the user based upon the content of the
`
`pages viewed by the user in the browser area.”); 9:58‐65 (“In one embodiment, a
`
`file is maintained comprising the name of a user, a list of electronic coupons
`
`clipped by that user, and the date on which each electronic coupon is clipped, and
`
`whether or not each coupon has been redeemed. This information is used to
`
`target advertisements to the user . . .”).)
`
`Apte also discloses that advertising is selected using “real‐time and other
`
`
`
`5
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`computer usage information.” In particular, Apte discloses that “the present
`
`invention can make choices about which advertisements to display to the user
`
`that are responsive to the user’s current viewing habits.” (Apte, Ex. 2012, 6:60–64
`
`(emphasis added).) Apte provides an example in which the system selects ads for
`
`camping gear in response to real‐time information indicating that the user is
`
`currently viewing pages about outdoor activities. (Id., Col. 6:64‐7:8.) Apte
`
`emphasizes the benefit of this type of real‐time information by noting that “[t]his
`
`dynamic targeting capability is in part due to the capability of the present
`
`invention to operate with a browser such that the progression of advertisements
`
`in no way interferes with the independent operation of the browser.” (Id., 6:64‐
`
`7:8 (emphasis added); Second Sherwood Decl., Ex. 1145, ¶¶ 10, 12, 21.)
`
`Apte demonstrates that the patent owner’s proposed substitute claims
`
`recite nothing but minor implementation details that were well‐known to persons
`
`of ordinary skill in the art. Modifying claim 11 to recite two additional well‐known
`
`and obvious method steps is inadequate to make the proposed substitute claims
`
`patentable over the prior art. (Id. ¶¶ 8‐22.)
`
`
`
`6
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`
`a.
`
`It would have been obvious to combine Apte with (a)
`Shaw and W3C or (b) Angles and Shaw
`
`Apte renders the proposed substitute claims obvious in light of Shaw and
`
`W3C or Angles and Shaw. As explained in the accompanying Second Sherwood
`
`Declaration, one of ordinary skill in the art would have regarded the references as
`
`analogous systems and would have had ample motivation to combine. (Id., ¶¶
`
`11‐13, 19‐22.) It would have been obvious to a person of ordinary skill in the art
`
`to augment Shaw and W3C, or Angles and Shaw, by collecting information from
`
`multiple computer programs because it was known that additional information
`
`enabled more successful targeting. (Id., ¶¶ 20, 24.) It would also have been
`
`obvious to utilize “real‐time” computer usage information to inform the selection
`
`of advertisements because each of Shaw, Angles, and Apte teach that approach.
`
`(Apte, Ex. 2012, 6:64‐7:1; Shaw, Ex. 1103, 13:48‐54; Angles, Ex. 1134, 20:2‐7;
`
`Second Sherwood Decl., Ex. 1145, ¶¶ 9, 10, 12, 33, 34‐36.)
`
`Furthermore, combining Apte with Angles and W3C or Angles and Shaw
`
`would have predictably resulted in targeted advertising systems with the
`
`additional ability to record computer usage information about user interactions
`
`with the advertisement displaying software and at least one other program—
`
`
`
`7
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`which persons of ordinary skill would have appreciated would enable even better
`
`targeting of advertisements. (Id., ¶¶ 14‐22.)
`
`2.
`
`Barrett also renders the proposed claims obvious
`
`U.S. Patent No. 6,490,584 to Barrett also renders the proposed substitute
`
`claims obvious. Barrett, entitled “User Centered Push Methods and System” is a
`
`system that “monitors user activity to build a dynamic model representing
`
`probable user interests” and uses that model to push information to the user.
`
`(Barrett, Ex. 1143, Abstract.) Because Barrett issued from an application filed on
`
`November 26, 1997, it is prior art under 35 U.S.C. § 102(e) (pre‐AIA). Barrett was
`
`not discussed or mentioned in the patent owner’s Contingent Motion to Amend.
`
`The system in Barrett “is based upon the idea that people and their
`
`interests are dynamic, and therefore that the information which a user deems
`
`relevant constantly changes because his interests change. Therefore, building and
`
`maintaining a reliable, useful user model requires data from numerous sources.
`
`What the user is currently browsing, for instance, or topics which he has recently
`
`written about or read (in a document, an e‐mail, or a new posting), applications
`
`he uses, as well as keyboard and mouse activity are all valuable sources of user
`
`model information.” (Barrett, Ex. 1143, 2:45‐54 (emphasis added).)
`
`
`
`8
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`
`Barrett attempts to capture this idea in a straightforward way–by obtaining
`
`as much information as possible about user interactions with the computer, and
`
`using that information to select content to be delivered (“pushed”) to that user.
`
`Barrett discloses “[t]he system user 12 (hereafter ‘user 12’) interacts with user‐
`
`invoked system applications 14, 16, 18, e.g., via a keyboard, a pointing device, and
`
`a display monitor (not shown). The interactions, 13, 15, 17, between the user 12
`
`and the system applications 14, 16, 18 are monitored 19 by one or more observer
`
`agents 20.” (Id. at 4:29–36.)
`
`As these excerpts demonstrate, Barrett comprehensively tracks users’
`
`interactions with all aspects of their computers in “real‐time” and pushes
`
`information to them based on the tracking. (Id. at 13:11–29.) Barrett does not
`
`specifically teach pushing advertising to computer users, but rather, is capable of
`
`pushing any kind of digital content. (Second Sherwood Decl., Ex. 1145, ¶ 28.)
`
`Barrett makes clear that that any type of digital information can be pushed to
`
`users based on dynamically‐created user profiles. (Barrett, Ex. 1143, 3:1‐5
`
`(“Another specific embodiment of the invention defines a system for determining
`
`what information is relevant to a user’s changing interests, locating such
`
`information, and pushing the information to a client triggered on the changes in
`
`
`
`9
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`user interests.”), 11:40‐42 (“The information source 28 (FIG. 1) is any storage
`
`including a searchable database located outside a specific lookup agent, including
`
`multiple information sources.”).) It was known, in fact, that push technologies
`
`such as those described in Barrett could be used to deliver advertisements.
`
`(Second Sherwood Decl., Ex. 1145, ¶¶ 28, 29.)
`
`a.
`
`It would have been obvious to combine Barrett with
`Shaw and W3C or Angles and Shaw
`
`Barrett renders the proposed substitute claims obvious in combination with
`
`Shaw and W3C or Angles and Shaw. (Second Sherwood Decl., Ex. 1145, ¶¶ 23‐29.)
`
`It would have been obvious to combine the teachings of Barrett with Shaw and
`
`W3C or Angles and Shaw to improve the quality of targeted advertisements
`
`served in each system. (Id.) Barrett specifically teaches, as noted above, that
`
`“people and their interests are dynamic,” and that data from “numerous sources”
`
`is useful in selecting relevant content. (Barrett, Ex. 1143, 2:45‐50.) A person of
`
`ordinary skill in the art would have recognized that collecting data from numerous
`
`sources would improve the efficacy of the targeted advertising systems, and that
`
`the references are technologically combinable. (Second Sherwood Decl., Ex.
`
`1145, ¶¶ 30‐38.) As explained previously, both and Angles and Shaw disclose
`
`
`
`10
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`collecting usage information in “real‐time” and using that information to target
`
`advertisements, so combining Barrett with either Angles and Shaw, or Shaw and
`
`W3C would result in a system that included every limitation recited in claim 23.
`
`3.
`
`The patent owner’s motion fails to show that its proposed
`substitute claims are patentable under the Graham factors
`
`The patent owner failed to show patentability in the context of the Graham
`
`factors for two additional reasons: the patent owner did not address the level of
`
`ordinary skill in the art or construe the new terms in its substitute claims.
`
`(IPR2013‐00419 paper 32 at 4 (“there should be a discussion of the ordinary skill
`
`in the art, with particular focus on the feature added to provide the basis of
`
`patentable distinction”); IPR2013‐00191 paper 70 at 50 (“Without a reasonable
`
`construction of the new claim features . . . [the] motion does not provide
`
`adequate information for [the Board] to determine . . . patentability.”).) These
`
`failures of proof provide a further reason to deny the patent owner’s motion.
`
`B.
`
`The proposed substitute claims fail under 35 U.S.C. § 101
`
`The patent owner’s proposed substitute claims also fail to claim patent‐
`
`eligible subject matter under 35 U.S.C. § 101. In Alice Corporation Pty. Ltd. v. CLS
`
`Bank International, 134 S.Ct. 2347 (2014), the Supreme Court clarified that the
`
`
`
`11
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`test for patent eligibility articulated in Mayo Collaborative Services v. Prometheus
`
`Laboratories, Inc., 132 S.Ct. 1289 (2012), is the standard for determining whether
`
`patent claims are directed to patent‐ineligible concepts: “First, we determine
`
`whether the claims at issue are directed to one of those patent‐ineligible
`
`concepts.” Alice Corp., 134 S.Ct. 2355. Second, if the claim is drawn to an abstract
`
`idea, “we consider the elements of each claim both individually and ‘as an
`
`ordered combination’ to determine whether the additional elements ‘transform
`
`the nature of the claim’ into a patent‐eligible application.” Id. When a claim is
`
`drawn to an abstract idea, “merely requiring generic computer implementation
`
`fails to transform that abstract idea into a patent‐eligible invention.” Id.
`
`The patent owner’s substitute claims are ineligible under § 101 because
`
`they are directed to the abstract idea of improving advertising results by showing
`
`people advertising for products and services they are interested in purchasing. It
`
`is a “fundamental” concept, “long prevalent in our system of commerce” that
`
`advertising works best when advertisements are tailored to the audience. Id. at
`
`2350; Ex. 1111 at 24–25. The proposed substitute claims amount to nothing more
`
`than a “mere instruction to implement [that] abstract idea on a computer.” Alice,
`
`134 S.Ct. at 2359.
`
`
`
`12
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`
`When the generic steps associated with computer implementation are
`
`removed from the patent owner’s substitute claims, they recite nothing more
`
`than: (1) acquiring demographic information, (2) acquiring additional information
`
`about the person’s activities, (3) associating the demographic information with
`
`information about the person’s activities, (4) selecting advertising in real‐time
`
`based on the person’s activities, and (5) presenting the advertisement to the user
`
`while the activity is ongoing. For decades, salespeople have practiced this
`
`“invention” each time a person walks into a store—by noticing a person’s gender
`
`and dress and targeting sales in light of those observations, coupled with
`
`recognition of the items about which the shopper has expressed interest.
`
`The patent owner’s proposed substitute claims merely attempt to cover
`
`this process when performed using a computer. Id. Because the patent owner’s
`
`proposed substitute claims cover ineligible subject matter under 35 U.S.C. § 101,
`
`and preempt age‐old forms of advertising, they should be rejected.
`
`C.
`
`The patent owner’s substitute claims are indefinite
`
`The patent owner’s proposed substitute claims are also indefinite under 35
`
`U.S.C. § 112(b). In Nautilus, Inc. v. Biosig Instruments, Inc., the Supreme Court
`
`recently held that “a patent is invalid for indefiniteness if its claims, read in light
`
`
`
`13
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`of the specification delineating the patent, and the prosecution history, fail to
`
`inform, with reasonable certainty, those skilled in the art about the scope of the
`
`invention.” 134 S.Ct. 2120, 2124 (2014). The Federal Circuit has subsequently
`
`interpreted Nautilus to require that patent claims “provide objective boundaries
`
`for those of skill in the art.” Interval Licensing LLC v. AOL, Inc., 2014 WL 4435871,
`
`*5 (Fed. Cir. Sept. 10, 2014). The substitute claims fail to satisfy this standard.
`
`a.
`
`“real‐time” is indefinite
`
`The patent owner added the term “real‐time” in claim 23 but did not
`
`construe it, and although “real‐time” appears five times in the specification, it is
`
`never defined. (’314, Ex. 1101, Abstract; 3:31; 6:3; 16:27; 16:50.) “Real‐time” is
`
`indefinite because it is facially subjective and neither the specification nor claims
`
`of the ‘314 patent provide any objective boundary for measuring the scope of the
`
`phrase. Interval Licensing, 2014 WL 4435871 at *7 (holding that “unobtrusive
`
`manner” was indefinite and explaining that the term was facially subjective and
`
`that the specification failed to provide an objective boundary for its meaning).1
`
`
`1 The Interval Licensing decision made its indefiniteness determination on
`
`intrinsic evidence; expert testimony was not required. 2014 WL 4435871 at *4
`
`
`
`14
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`Absent additional guidance, a person of ordinary skill in the art would not know
`
`whether “real‐time” means instantly, within several seconds, several minutes,
`
`during the same session, or some other period of time.
`
`IV.
`
`CONCLUSION
`
`For the foregoing reasons, BE failed to the establish patentability of its
`
`proposed substitute claims, so its Motion to Amend should be denied.
`
`Date: September 24, 2014
`
`/ Heidi L. Keefe /
`Heidi L. Keefe
`Reg. No. 40,673
`
`
`
`
`
`COOLEY LLP
`ATTN: Heidi L. Keefe
`Patent Docketing
`1299 Pennsylvania Ave. NW, Suite 700
`Washington, D.C. 20004
`Tel: (650) 843‐5001
`Fax: (650) 849‐7400
`
`
`
`
`
`
`n.6. Although the precise boundaries of the term “real‐time” are indefinite, for
`
`purposes of assessing obviousness, the Petitioner has made its best guess that the
`
`broadest reasonable construction of this term would be satisfied by something
`
`that takes place during the same communication session.
`
`
`
`15
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Inter Partes Review of U.S. Patent No.
`6,628,314
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify, pursuant to 37 CFR section 42.6, that a complete
`
`copy of the attached PETITIONER’S OPPOSITION TO PATENT OWNER’S
`CONTINGENT MOTION TO AMEND, including all exhibits and related documents,
`is being served electronically on the 24th day of September, 2014, the same day
`as the filing of the above‐identified document in the United States Patent and
`Trademark Office/Patent Trial and Appeal Board, upon the patent owner’s
`counsel of record as follows:
`
`Jason S. Angell
`Freitas Angell & Weinberg LLP
`350 Marine Parkway, Suite 200
`Redwood Shores, CA 94065
`BEIPRFTK@ftklaw.com
`
`
`/ Heidi L. Keefe /
`Heidi L. Keefe
`Reg. No. 40,673
`
`
`
`COOLEY LLP
`ATTN: Heidi L. Keefe
`Patent Docketing
`1299 Pennsylvania Ave. NW, Suite 700
`Washington, D.C. 20004
`Tel: (650) 843‐5001
`Fax: (650) 849‐7400
`
`
`
`
`110573235 v1
`
`
`
`16
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
