Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`
`
`IPR2014‐00053
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`PATENT TRIAL AND APPEAL BOARD
`____________________
`
`FACEBOOK, INC.,
`Petitioner
`
`v.
`
`B. E. TECHNOLOGY LLC
`Patent Owner
`
`_______________________
`
`Case No. IPR2014‐00053
`Patent No. 6,628,314
`
`
`____________________________________________________________
`
`
`
`
`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE
`
`
`
`
`(309101‐2064)
`
`
`
`IPR2014‐00053
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`PATENT TRIAL AND APPEAL BOARD
`____________________
`
`FACEBOOK, INC.,
`Petitioner
`
`v.
`
`B. E. TECHNOLOGY LLC
`Patent Owner
`
`_______________________
`
`Case No. IPR2014‐00053
`Patent No. 6,628,314
`
`
`____________________________________________________________
`
`
`
`
`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`
`
`IPR2014‐00053
`
`TABLE OF CONTENTS
`
`Page
`
`INTRODUCTION ............................................................................................. 1
`ANGLES DISCLOSES EVERY LIMITATION OF CLAIM 11. ................................. 2
`A.
`Angles Discloses Recording Computer Usage Information ................. 3
`B.
`Angles Discloses Periodically Requesting Advertising Content ........... 4
`ALL CHALLENGED CLAIMS ARE OBVIOUS OVER ANGLES IN VIEW OF
`SHAW ............................................................................................................ 5
`A.
`Angles Does Not Require a Continuous Internet Connection ............. 5
`B.
`The Patent Owner Presents No Evidence Refuting the Strong
`Motivations to Combine Angles with Shaw Set Forth in the
`Petition ............................................................................................... 9
`THE PATENT OWNER’S “BROADEST REASONABLE INTERPRETATION”
`ARGUMENTS ARE NOT RELEVANT TO THIS PETITION ................................. 12
`CONCLUSION .............................................................................................. 13
`
`
`I.
`II.
`
`III.
`
`IV.
`
`V.
`
`
`
`i
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`
`
`IPR2014‐00053
`
`TABLE OF AUTHORITIES
`
`
`Page(s)
`
`Cases
`
`KSR International Co. v. Teleflex Inc.,
`550 U.S. 398 (2007) ........................................................................................... 12
`
`Perfect Web Techs., Inc. v. InfoUSA, Inc.,
`587 F.3d 1324 (Fed. Cir. 2009) .......................................................................... 12
`
`Phillips v. AWH Corp.,
`415 F.3d 1303 (Fed. Cir. 2005) (en banc) .......................................................... 13
`
`SAP America, Inc. v. Versata Develop. Group, Inc.,
` CBM2012‐00001, Paper 70 (June 11, 2013) ..................................................... 13
`
`Statutes
`
`35 U.S.C. § 103(a) ..................................................................................................... 1
`
`Other Authorities
`
`37 C.F.R. § 42.23(a) .................................................................................................. 5
`
`37 C.F.R. § 42.65(a) ................................................................................................ 11
`
`
`
`
`
`
`
`
`
`ii
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`I.
`
`INTRODUCTION
`
`
`
`IPR2014‐00053
`
`The Board instituted inter partes review of claims 11‐13, 15, 18 and 20
`
`based on obviousness over Angles [Ex. 1003] in view of Shaw [Ex. 1004]. The
`
`patent owner’s response (“Response”) does not dispute key elements of the
`
`Petition. The patent owner does not dispute that Angles and Shaw qualify as
`
`prior art to the ’314 patent and does not challenge any aspect of the Board’s
`
`claim constructions as set forth in the Decision instituting inter partes review. The
`
`patent owner also does not dispute that Angles and Shaw disclose every
`
`limitation of claims 11‐13, 15, 18 and 20.
`
`The patent owner instead rests its entire response on the assertion that
`
`Angles cannot properly be combined with Shaw under 35 U.S.C. § 103(a). The
`
`patent owner, relying on a sparse and conclusory expert declaration lacking any
`
`analysis or citation to evidence, asserts that Angles and Shaw disclose
`
`“completely different types of systems” that operate in different ways. But this
`
`argument ignores key teachings of Angles, and is unaccompanied by any evidence
`
`or reasoned argument from the patent owner. Because the patent owner has
`
`offered no serious rebuttal to the obviousness of claims 11‐13, 15, 18 and 20 over
`
`Angles in view of Shaw, the Board should find them unpatentable.
`
`
`
`1
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`II.
`
`ANGLES DISCLOSES EVERY LIMITATION OF CLAIM 11.
`
`
`
`IPR2014‐00053
`
`The patent owner’s response begins from the inaccurate premise that the
`
`Petitioner conceded that Angles fails to disclose two limitations of claim 11 –
`
`software that “records computer usage information” and “periodically requests
`
`additional advertising content,” as recited
`
`in claims 11d(ii) and 11d(iii),
`
`respectively. (Response at 5‐6, 9.)1 But the Petitioner made no such concession.
`
`As demonstrated below, the Petitioner specifically argued that Angles discloses
`
`these two limitations – because it does.
`
`The Response does not address these two limitations or provide any
`
`explanation as to why Angles allegedly fails to disclose them. In fact, the patent
`
`owner specifically instructed its expert, Mr. Goldstein, to “assume that [the
`
`disputed limitations] of claim 11 are not disclosed by Angles.” (Goldstein Decl.,
`
`Ex. 2001, at 10 (¶ 24).) The Board should therefore accept Petitioner’s
`
`
`1 As noted in the text, the patent owner does not dispute that these two
`
`limitations are disclosed in Shaw, and does not dispute that the combination of
`
`Angles and Shaw disclose all limitations of claims 11‐13, 15, 18 and 20.
`
`Accordingly, even if the Board were to conclude that these two limitations are
`
`missing from Angles, the challenged claims should still be found unpatentable.
`
`
`
`2
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`uncontroverted showing as to limitations 11(d)(ii) and 11(d)(iii) and find them
`
`IPR2014‐00053
`
`
`
`disclosed in Angles for the reasons set forth in the Petition.
`
`A.
`
`Angles Discloses Recording Computer Usage Information
`
`Angles discloses downloaded software that records computer usage
`
`information, as recited in claim 11d(ii). (Petition at 39‐40.) As explained in the
`
`Petition, when the user clicks a customized advertisement 30 in Angles, the
`
`downloaded consumer control module 42 software running on the user’s
`
`computer sends a message to the server indicating that the user has selected the
`
`advertisement. (Petition at 39‐40.) In order for the software to send such a
`
`message, it must store computer usage information reflecting the user’s
`
`selection – even if that storage is in random access memory and short‐lived.
`
`The Petitioner never conceded that Angles lacks the step of recording
`
`computer usage information. The Petition instead argued that if the word
`
`“recording” in claim 11d(ii) was narrowly interpreted to require persistent (rather
`
`than temporary) storage of computer usage information, Shaw discloses the
`
`claimed recording under this narrower interpretation. (See Petition at 40 (“To the
`
`extent storage of computer usage information in a persistent manner is deemed
`
`to be a requirement of ‘recording’ as recited in limitation 11d(ii), any such
`
`requirement is disclosed in Shaw.”).) The patent owner does not contend that
`
`
`
`3
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`claim 11 requires any such persistent storage, and nor is there any basis for
`
`IPR2014‐00053
`
`
`
`importing such a requirement into the claim as noted earlier. Angles therefore
`
`discloses recording computer usage information as recited in claim 11.
`
`B.
`
`Angles Discloses Periodically Requesting Advertising Content
`
`Angles also discloses downloaded software that periodically requests
`
`additional advertising content, as recited in claim 11d(iii). (Petition at 43‐44.) In
`
`particular, Angles discloses that “if a consumer views a particular electronic page
`
`32 for more than a minute, the advertising module 52 can send a new customized
`
`advertisement.” (Petition at 44 (quoting Angles, Ex. 1003, Col. 20:14‐17).) Mr.
`
`Sherwood explained, in his declaration accompanying the Petition, that the
`
`standard HTTP protocol used in Angles is a stateless protocol in which each
`
`communication includes at least a request from the consumer computer, and a
`
`response by the server. (Sherwood Decl., Ex. 1007, ¶¶ 37‐38.) One of ordinary
`
`skill in the art, therefore, would have understood that the periodic sending of a
`
`new customized advertisement by the advertising module 52 in Angles occurs in
`
`response to a request from the consumer computer. (Id. ¶¶ 38‐40.) Angles
`
`therefore discloses periodically requesting additional advertising content.
`
`Although the Petition also argued that Shaw discloses the step of
`
`periodically requesting additional advertising content, it made clear that Angles
`
`
`
`4
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`discloses this step as well. (See Petition at 43 (after discussion of Shaw: “Angles
`
`IPR2014‐00053
`
`
`
`also discloses periodically requesting additional advertising content.”).) The
`
`patent owner does not address, let alone challenge, any of the Petitioner’s
`
`arguments or Mr. Sherwood’s testimony about this limitation. See 37 C.F.R. §
`
`42.23(a) (“Any material fact not specifically denied may be considered
`
`admitted.”). The Board should therefore accept Petitioner’s uncontroverted
`
`evidence and find that Angles discloses periodic requesting of additional
`
`advertising content. Angles therefore discloses all limitations of claim 11.
`
`III.
`
`ALL CHALLENGED CLAIMS ARE OBVIOUS OVER ANGLES IN VIEW OF SHAW
`
`The patent owner presents an exceedingly narrow challenge to a finding of
`
`obviousness based on the combination of Angles and Shaw. Critically, the patent
`
`owner does not dispute that Angles and Shaw collectively disclose all limitations
`
`of claims 11‐13, 15, 18 and 20. (Response at 5‐11.) The patent owner instead
`
`argues that a person of ordinary skill in the art would not have found the two
`
`references combinable. The patent owner’s arguments are without merit.
`
`A.
`
`Angles Does Not Require a Continuous Internet Connection
`
`The patent owner primarily contends that a person of ordinary skill in the
`
`art would not have combined Angles and Shaw because, according to the patent
`
`owner, “Angles is a communication system that requires continuously being
`
`
`
`5
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`connected to the Internet to operate properly.” (Goldstein DEcl., Ex. 2001, ¶ 27;
`
`IPR2014‐00053
`
`
`
`Response at 9, 11.) The patent owner contends that this renders Angles
`
`completely different from Shaw, a system in which the user’s computer is “mostly
`
`disconnected” from the network. (Goldstein Decl., Ex. 2001, ¶¶ 27‐29.)
`
`The patent owner’s attempt to avoid the combination of Angles and Shaw
`
`appears to depend entirely on this assumption, i.e. that Angles requires the user
`
`computer to have a continuous connection to the Internet. (Response at 9‐11;
`
`Goldstein Decl., Ex. 2001, ¶¶ 27‐32.) But the patent owner and its expert cite no
`
`evidence and point to nothing in Angles to support it.
`
`Angles makes clear that its advertising system does not require a
`
`continuous Internet connection. Angles explains that its system supports “a wide
`
`range of interactive communication mediums,” including telephone modem
`
`systems in which the user must specifically connect to an Internet service
`
`provider prior to accessing information. (Angles, Ex. 1003, Col. 9:27‐29, 9:61‐64.)
`
`In particular, Angles explains that home personal computer (PC) users connect to
`
`the Internet using dial‐up connections
`
`in which “an attached modem
`
`is
`
`automatically instructed to dial the telephone number associated with the local
`
`Internet host server.” (Id. Col. 1:45‐50.) “When a consumer desires to access
`
`information available on the Internet 33 via an Internet provider 34,” according to
`
`
`
`6
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Angles, “the consumer initiates a connection with the Internet provider 34 from
`
`IPR2014‐00053
`
`
`
`his or her consumer computer 12.” (Id., Col. 9:61‐64.) Angles further explains
`
`that “[i]n the preferred embodiment, the consumer computer 12
`
`is a
`
`conventional computer which is equipped with a conventional modem.” (Id., Col.
`
`10:23‐25.) Angles therefore clearly discloses the ability to work with “dial‐up”
`
`configurations in which the consumer computer is connected to the Internet only
`
`when such a connection is required – and not continuously.
`
`Angles further discloses that its advertising system can be used with well‐
`
`known Internet service providers such as “American [sic; America] On‐Line,
`
`Microsoft Network, Prodigy, CompuServe, and Network Intensive, to name a
`
`few.” (Id., Col. 9:39‐41.) As Mr. Sherwood explained in his declaration
`
`accompanying the Petition and in his deposition, these services were specifically
`
`designed for users who did not have a continuous network connection.
`
`(Sherwood Decl., Ex. 1007, ¶¶ 32‐34; Sherwood Depo., Ex. 2003, at 213:18‐219:5.)
`
`They instead required users to connect using a “dial‐up” modem connection over
`
`a voice telephone line. (Sherwood Decl., Ex. 1007, ¶¶ 20, 32‐33.) Some of these
`
`on‐line services even charged customers based on the amount of time they were
`
`connected to the network, making a continuous connection economically
`
`infeasible for some customers. (Id. ¶ 33.)
`
`
`
`7
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`
`
`
`IPR2014‐00053
`
`The fact that the system of Angles can support Internet providers such as
`
`America Online (AOL) further undermines the patent owner’s assumption that
`
`Angles requires a continuous Internet connection. (Angles, Ex. 1003, Col. 9:39‐
`
`41.) The AOL service mentioned in Angles was specifically designed to prevent a
`
`consumer’s computer from being continuously connected to the Internet. For
`
`example, the AOL service automatically disconnected the user from the network if
`
`the user’s computer was idle for a period of time. (See Curt Degenhart et al., AOL
`
`In a Nutshell (O’Reilly ed. 1998), Ex. 1034, 380.) AOL also offered a feature called
`
`“FlashSessions” or “Automatic AOL” in which the user could instruct its computer
`
`to automatically connect to the AOL service at a late hour – such as late at night
`
`when the network was less congested – and perform a number of automatic
`
`operations such as sending and receiving e‐mails and posts, downloading files,
`
`and performing other tasks. (Id. at 334‐36.) The user could then read the
`
`downloaded information “offline” the next day. (Id. at 334.) These features
`
`confirm that AOL, a service fully contemplated by the system of Angles, supported
`
`dial‐up users that were not continuously connected to the Internet.
`
`The patent owner’s premise that the two references disclose “completely
`
`different types of systems” (Response at 8) depends entirely on the false
`
`assumption that Angles requires a continuous connection to the Internet.
`
`
`
`8
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`(Goldstein Decl., Ex. 2001, ¶¶ 27‐32.) Because Angles expressly contemplates a
`
`IPR2014‐00053
`
`
`
`dial‐up environment with an intermittent connection — precisely the same
`
`environment in which Shaw was designed to operate – the patent owner’s
`
`arguments must be rejected.
`
`B.
`
`The Patent Owner Presents No Evidence Refuting the Strong
`Motivations to Combine Angles with Shaw Set Forth in the Petition
`
`Mr. Sherwood’s declaration that accompanied the Petition provided a
`
`thorough and detailed explanation as to why a person of ordinary skill in the art
`
`would have found it obvious to combine Angles and Shaw. (See Petition at 41‐43;
`
`Sherwood Decl., Ex. 1007, ¶¶ 54‐56, 63‐69.) Among other things, Mr. Sherwood
`
`explained that Shaw disclosed a technique for providing advertising in an on‐line
`
`system that did not require a consistent connection between a user’s computer
`
`and the Internet. (Id. ¶¶ 64‐66.) He explained that Shaw would have improved
`
`the advertising system of Angles by allowing the consumer computer in Angles to
`
`collect and store computer usage locally rather than immediately upload it to the
`
`server. This would have allowed the consumer computer to defer connection to
`
`the Internet until a later time when bandwidth usage was lower and costs were
`
`potentially reduced. (Id. ¶ 65; see also Sherwood Depo., Ex. 2003, 215:18‐216:18
`
`(“Q: What is the advantage that's achieved by combining Shaw and Angles? A:
`
`
`
`9
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Well, one of the top‐level advantages, of course, is a reduced cost.”); see also id.
`
`IPR2014‐00053
`
`
`
`at 218:7‐23.)
`
`Mr. Sherwood also pointed out that Shaw contains express statements
`
`touting cost‐reduction benefits that would have motivated a person of skill in the
`
`art to adapt its teachings to the system of Angles. (Sherwood Decl., Ex. 1007, ¶
`
`66; see also Shaw, Ex. 1004, Col. 4:62‐66 (“One such advantage is that
`
`communication costs and hardware requirements are substantially lower than for
`
`‘fully‐connected’ on‐line service.”), 23:56‐59 (“Thus, the system operates in a
`
`‘batch’ mode. This, of course, keeps the costs associated with maintaining a
`
`communications link, i.e., connect or line charges, low.”).) These benefits would
`
`have been particularly important to Internet users in the mid‐1990s who
`
`frequently endured slow and
`
`inconsistent dial‐up
`
`Internet connections.
`
`(Sherwood Decl., Ex. 1007, ¶ 64.)
`
`An Angles‐Shaw combination could also have displayed ads faster to the
`
`user because, as recognized in Angles, ads could be stored and retrieved from on
`
`the consumer computer’s local storage, which is much faster than a network
`
`connection. (Id. at ¶ 60 (quoting Angles, Ex. 1003, Col. 12:2‐7).) Even the patent
`
`owner admits
`
`this benefit.
`
`
`
`(See Response, 10
`
`(“Storage of some
`
`advertisements . . . on the consumer computer would provide for faster access to
`
`
`
`10
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`the stored advertisements . . .”). This would have provided a critical improvement
`
`IPR2014‐00053
`
`
`
`considering the slow Internet connections in the 1990s. (Sherwood Depo., Ex.
`
`2003, 218:24‐219:5.) The ability to save time and money would have provided
`
`motivators for a person of ordinary skill to adapt the batch mode teachings of
`
`Shaw to the advertising system of Angles.
`
`The patent owner and its expert make no attempt to rebut or even address
`
`the detailed explanations provided by the Petitioner and Mr. Sherwood. The sole
`
`mention of Mr. Sherwood in the Goldstein Declaration, for example, appears in a
`
`paragraph in which Mr. Goldstein identifies the materials he reviewed in
`
`connection with his engagement. (Goldstein Decl., Ex. 2001, ¶ 19.)2
`
`The patent owner instead presents a series of arguments that have no
`
`factual or legal basis. The patent owner argues, for example, that Angles and
`
`Shaw cannot be combined because Angles discloses “no problem to solve, and no
`
`
`2 The portions of the Goldstein Declaration cited in the Response consist entirely
`
`of conclusory statements unsupported by analysis or citation to evidence.
`
`(Goldstein Decl., Ex. 2001, ¶¶ 26‐33.) The Board should give no weight to them.
`
`See 37 C.F.R. § 42.65(a) (“Expert testimony that does not disclose the underlying
`
`facts or data on which the opinion is based is entitled to little or no weight.”).
`
`
`
`11
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`reason to change or complicate the Angles system.” (Response at 10; Goldstein
`
`IPR2014‐00053
`
`
`
`Decl., Ex. 2001, ¶ 31 (“Nothing in Angles identifies any problem that would be
`
`solved by changes of either type.”).) This argument is based on a fundamental
`
`misunderstanding of the law of obviousness under KSR International Co. v.
`
`Teleflex Inc., 550 U.S. 398 (2007). There is no requirement that a prior art
`
`reference acknowledge some kind of deficiency or problem as a prerequisite to its
`
`use in combination with another reference to establish obviousness. An
`
`obviousness analysis “may include recourse to logic, judgment, and common
`
`sense available to the person of ordinary skill that do not necessarily require
`
`explication in any reference or expert opinion.” Perfect Web Techs., Inc. v.
`
`InfoUSA, Inc., 587 F.3d 1324, 1329 (Fed. Cir. 2009).
`
`The evidence set forth above and in the Petition shows that it would have
`
`been obvious to a person having ordinary skill in the art to combine Angles and
`
`Shaw. Accordingly, the Board should find that all challenged claims are
`
`unpatentable as obvious in light of Angles and Shaw.
`
`IV.
`
`THE PATENT OWNER’S “BROADEST REASONABLE
`ARGUMENTS ARE NOT RELEVANT TO THIS PETITION
`
`INTERPRETATION”
`
`The patent owner asserts that the Board’s application of the broadest
`
`reasonable interpretation (“BRI”) standard for construing claims exceeds the
`
`
`
`12
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`PTO’s rule‐making authority. (Response at 12‐13.) The Board already rejected
`
`IPR2014‐00053
`
`
`
`this argument in SAP America, Inc. v. Versata Develop. Group, Inc., CBM2012‐
`
`00001, Paper 70, 19 (June 11, 2013) (“[T]he broadest reasonable interpretation
`
`standard is the one correct standard for post grant reviews.”). No further
`
`discussion is warranted here.
`
`The patent owner has failed to show that the claim construction standard
`
`applied by the Board would have any impact in this proceeding. The patent
`
`owner did not specifically address any claim construction issues in its Response
`
`and did not, for example, show that the Board would interpret any claim
`
`differently if it employed the standards applicable to district court litigation under
`
`Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (en banc). The Board
`
`therefore need not reach this issue because even if the patent owner’s legal
`
`argument about the BRI standard had merit, it would have no impact on the
`
`outcome of the trial.
`
`V.
`
`CONCLUSION
`
`For the reasons set forth above, and based on the Petition and all of the
`
`evidence of record, claims 11‐13, 15, 18, and 20 of the ’314 patent are
`
`unpatentable as obvious in view of Angles and Shaw. Accordingly, all of the
`
`challenged claims should be cancelled.
`
`
`
`13
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`Date: September 24, 2014
`
`
`
`IPR2014‐00053
`
`/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
`
`
`
`
`
`
`
`
`14
`
`
`
`
`
`Attorney Docket No. FABO‐027/00US
`(309101‐2064)
`
`
`
`
`IPR2014‐00053
`
`CERTIFICATE OF SERVICE
`
`
`I hereby certify, pursuant to 37 CFR section 42.6, that a complete copy of
`
`the attached PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE, 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
`
`
`
`
`
`
`
`15
`
`
`
`
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
