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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`APPLE INC.,
`TWITTER, INC., AND YELP INC.,
`Petitioners
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`v.
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`EVOLUTIONARY INTELLIGENCE LLC
`Patent Owner.
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`____________________
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`Inter Partes Review No. IPR2014-00086
`Inter Partes Review No. IPR2014-008121
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`____________________
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`Petitioners’ Reply
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`1 Per the Board’s Order (Paper 16 at 4), Petitioner Apple identifies this as a
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`consolidated filing.
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`Table of Contents
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`I. Gibbs Discloses the Claimed “Plurality of Containers” .................................... 1
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`A. Gibbs Shows Each Map Display Contains a Collection of Instantiated
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`Transport, Map, and Report Objects ............................................................... 3
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`B. Gibbs’ Collection of Instantiated Objects is a “Container” ........................... 6
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`C. Gibbs Discloses a “Plurality of Containers” .................................................. 7
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`II. Gibbs Discloses the Claimed “Plurality of Registers” ...................................... 8
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`A. “First Register for Storing a Unique Container Identifier” ........................... 8
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`B. “Acquire Register” For Adding “a Register from Other Containers or
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`Add[ing] a Container from Other Containers” ..............................................11
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`C.
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`“Active Space Register” ..............................................................................12
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`D. “Passive Space Register” .............................................................................13
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`E.
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`“Neutral Space Register” .............................................................................14
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`The Board correctly found the “specific types of objects, programs, routines,
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`and architecture disclosed in Gibbs meet the limitations of” claims 2-12, 14, and 16
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`of the ’536 patent. Paper 8 (“Dec.”) at 21, 26. In its Response, Patent Owner
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`seeks to cloud the record by incorrectly portraying Petitioners’ arguments, the
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`testimony of Petitioners’ expert Henry Houh, Ph.D., the scope of the ’536 claims,2
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`and the Gibbs reference (Ex. 1006). The Board should dismiss Patent Owner’s
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`arguments, and maintain its finding that Gibbs anticipates the challenged claims.
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`I.
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`Gibbs Discloses the Claimed “Plurality of Containers”
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`The Board correctly found Gibbs discloses the “plurality of containers” of
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`claims 2 and 16. Dec. at 21 (“Gibbs’ overall train management system receives,
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`transmits, and manipulates information, as per the limiting preamble of claim 2.”).
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`This rested on substantial evidence presented in the Petition; namely, that Gibbs
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`shows the claimed “container” via its description of a collection of transport, map,
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`and report objects that are instantiated and used to display maps and reports to
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`users. See Pet. at 18-19 (the map and report objects have “instructions and routines
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`[that] are used to gather information from the various transport objects . . . to
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`generate and modify maps and reports”), 15 (the “transport objects interact with
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`the map and report objects to display information relating to the physical
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`2 Patent Owner explicitly advances new claim constructions for two of the
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`“registers” in the ’536 claims. Those are addressed in the analysis of Gibbs below.
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`equipment and facilities that the transport objects represent.”); Ex. 1003 at ¶¶ 122
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`(same), 109 (the “system [] uses objects to display and transmit information to the
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`user, such as through maps and reports.”) (emphases added); see id. at ¶¶ 86-98.
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`Rather than dispute this in its Response, Patent Owner attacks a straw-man:
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`Dr. Houh’s use of the label “TMR subsystem” during his deposition as a shorthand
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`for the architecture and objects in Gibbs that anticipate the claims. See Paper 20
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`(“Resp.”) at 30-35. While Dr. Houh agreed to use this label as a courtesy to Patent
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`Owner’s counsel, he repeatedly and consistently explained the “instances of items
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`from the transport object library, the map object library and report object library”
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`in Gibbs correspond to the “container” of the claims. E.g., Ex. 1008 at 98:21-
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`103:1, 95:15-96:1, 63:8-68:22. Dr. Houh’s deposition testimony reinforces that the
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`displayed maps and reports of Gibbs, created through interactions between the
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`transport, map, and report objects, anticipate the claims. E.g., Pet. at 12-13, 15, 18.
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`Patent Owner also contends the individual objects in Gibbs cannot be a
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`“container.” Resp. at 24-30, 37. Patent Owner raised this same argument in its
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`Preliminary Response (Paper 6 at 31-32); it remains unpersuasive. See Dec. at 21
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`(“Gibbs’ disclosure of objects describes the claimed ‘container.’” (emphasis
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`added)). Patent Owner also advances three theories why it believes Gibbs does not
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`disclose a “container” that includes the transport, map, and reports objects: (1) that
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`Gibbs does not describe a “TMR subsystem,” (Resp. at 30-38), (2) even if the
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`“TMR subsystem” did exist, it is not a “container,” (id. at 38-40), and, finally, (3)
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`even if Gibbs does disclose a container, it does not disclose a “plurality of
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`containers,” (id. at 55-56). All three theories must be rejected.
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`A. Gibbs Shows Each Map Display Contains a Collection of
`Instantiated Transport, Map, and Report Objects
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`Patent Owner argues that because Gibbs itself does not use the term “TMR
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`subsystem” and does not otherwise coin a term for the collection of instantiated
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`objects in its system, the disclosure of these objects by Gibbs can only be
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`“inherent.” Resp. at 10-11, 35-40. This disclosure is not “inherent.” It is explicit.
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`Patent Owner simply ignores the explanations in the Petition and Dr. Houh’s
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`original declaration that detail how Gibbs describes this element – it shows
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`instantiated transport, map, and report objects interacting to create maps and
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`reports for display to a user. Ex. 1003 at ¶¶ 89-90, 94, 96-97; Pet. at 15, 18-19, 23;
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`Ex. 1009 at ¶¶ 5-16.
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`As Dr. Houh explained, Figure 8a of Gibbs depicts the display of maps and
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`reports generated by its system, which, in turn, contain the transport objects that
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`are within the selected geographic boundaries and meet the other selected criteria.
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`Ex. 1003 at ¶ 94; see id. at ¶¶ 89-100, 108-09; Ex. 1006 at Fig. 8a, 20:2-5
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`(generated display shows map objects), 20:5-16 (transport objects), 20:17-21 &
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`20:30-40 (report objects); Pet. at 15 (the map object “determine[s] which transport
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`objects are within the selected map area”), 18. In Figure 9b, Gibbs shows how the
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`map and report objects maintain collections of transport objects within the selected
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`boundaries and can iterate through each object in the collection to monitor its
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`status. Ex. 1003 at ¶¶ 102-04; Ex. 1006 at Fig. 9b, 22:23-55; Ex. 1009 at ¶¶ 42-46.
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`Patent Owner’s expert, Dr. Green, admitted as much at his deposition. Ex. 2009 at
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`223:8-225:7, 228:16-229:11, 232:12-17, 234:6-236:9. Thus, Gibbs explicitly
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`shows instances of the transport, map, and report objects being collected into a
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`“logically defined data enclosure” used to depict the maps and reports to a user.
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`Ex. 1009 at ¶¶ 32-46; see Ex. 1006 at Figs. 9a-9c, 21:49-65, 22:2-12.
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`Patent Owner next argues Gibbs’ collection of objects cannot be considered
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`part of a single enclosure (i.e., a container) because several passages in Gibbs
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`describe each type of object as a “discrete entity.” Resp. at 25-28, 38 (citing Ex.
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`1006 at 7:24-27, 8:48-52). But Patent Owner ignores the full meaning of the cited
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`passages, which explain the objects are “treated by the processing unit 48 as
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`discrete entities within an object-oriented programming structure as
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`conventionally known in the art.” Ex. 1003 at ¶¶ 78, 89 (emphasis added) (citing
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`Ex. 1006 at 7:24-27). Gibbs’ disclosure that its system treats these “discrete
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`entities” as part of a “structure” would be understood by one of skill as meaning
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`they would be instantiated as part of a logical data structure in an operating system.
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`Ex. 1009 at ¶¶ 11, 33-37. This is how Gibbs’ “object oriented” architecture works
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`– it combines those objects (i.e., transport, map, and report) into a structure which
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`is used to provide “varying levels of real-time perspective on an operating railroad
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`system,” such as “a ‘system-wide’ view needed by executives” and an
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`“individualized and detailed report needed by . . . a train master or a dispatcher.”
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`Ex. 1003 at ¶ 69 (quoting Ex. 1006 at 3:65-4:10); Ex. 1009 at ¶¶ 33-37. This
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`compound “object” created by combining the transport, map, and report objects in
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`varying manners to give users access to real-time data about the train system is
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`plainly a “container.” Ex. 1009 at ¶¶ 33-37, 42-48; see Ex. 1001 at 3:28-34.
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`Patent Owner also misunderstands the law – anticipation exists “when a
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`claimed limitation is . . . implicit in the relevant reference.” Standard Havens
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`Products, Inc. v. Gencor Indus., Inc., 953 F.2d 1360, 1369 (Fed. Cir. 1991)
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`(emphasis added). Moreover, what an anticipatory reference teaches must be
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`analyzed from the perspective of a person of ordinary skill. Smith & Nephew v.
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`Convatec Tech., IPR2013-00102, Paper 87 at 14-15 (May 19, 2014). Thus, “it is
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`proper to take into account not only specific teachings of the reference but also the
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`inferences which one skilled in the art would reasonably be expected to draw
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`therefrom.” Denso Corp. v. Beacon Navigation, IPR2013-00026, Paper 34 at 19-
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`20 (Mar. 14, 2014) (emphasis added). Dr. Houh explained what a person of skill
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`would infer from Gibbs, essentially without dispute. Ex. 1003 at ¶¶ 69-106; see,
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`e.g., Ex. 2006 at ¶¶ 80-84 (Dr. Green agreeing Gibbs includes a plurality of TWS
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`stations), 98-100 (attributes of transport objects), 107-12 (map and report objects
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`request, receive, and retain data from transport objects), 116 (maps and reports are
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`nested), 119 (train consist report shows an idealized picture of train cars on a map).
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`B. Gibbs’ Collection of Instantiated Objects is a “Container”
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`Patent Owner asserts Gibbs’ collection of objects cannot be the claimed
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`“container” because the objects are not “nestable containers that include the logical
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`description of another container.” Resp. at 38-40. This argument is inconsistent
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`with the Board’s construction and the ’536 patent itself. Ex. 1009 at ¶¶ 18-31.
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`Throughout the specification, “containers” are described as being able to
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`encapsulate another container or “sets of containers.” Ex. 1003 at ¶ 54 (citing Ex.
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`1001 at 8:64-9:2); see Ex. 1001 at 12:13-27, Fig. 3A, 3B; Ex. 2009 at 43:4-17,
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`36:2-38:10. Likewise, the ’536 specification states “Any container may include (n)
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`other containers, to infinity.” Ex. 1001 at 12:45-46. Although one way of
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`encapsulating another container is by “includ[ing] the logical description of [the]
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`container,” nothing in the claim language limits encapsulation of other containers
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`to this embodiment, as the Board found. Ex. 1009 at ¶¶ 26-31; Dec. at 7-9, 21.
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`Patent Owner’s restricted definition is also inconsistent with Dr. Green’s
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`understanding of the claimed “container.” Dr. Green explained that one way to
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`“logically define” an enclosure was “through a software mechanism.” Ex. 2006 at
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`¶ 35; Ex. 2009 at 27:21-28:4, 56:18-22; see id. at 57:20-58:11 (e.g., a web browser
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`rendering an HTML page), 50:4-16. Gibbs plainly shows a software mechanism –
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`software running on each TWS workstation creates instances of transport, map,
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`and report objects and processes them to generate depictions of those objects for a
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`user. Ex. 1003 at ¶¶ 71-72, 78, 88, 89; see id. at ¶¶ 90-104, 108-09; Ex. 1006 at
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`Figs. 2-3, 8a, 9b, 5:52-6:43, 22:23-55. Gibbs explains the objects are created in an
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`object-oriented programming structure, and are instantiated and used by executing
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`software. Ex. 1003 at ¶¶ 78, 88-89; Ex. 1006 at 8:44-53, 9:27-31.
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`Gibbs also shows “containers” even under Patent Owner’s new theory that
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`“containers” must include “the logical description” of other containers. As
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`explained in § II.B, during generation of a map for display to a user, each map and
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`report acquires the unique ID of each transport object within its boundaries, and,
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`as Dr. Green admitted, each unique ID is a “logical description” of the transport
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`object. See Ex. 2009 at 191:15-193:1, 28:5-29:22, 33:20-34:4, 37:11-15, 47:16-
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`49:16 (a URL is a logical reference), 57:20-58:11; Ex. 1009 at ¶¶ 42-48, 62.
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`C. Gibbs Discloses a “Plurality of Containers”
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`The Board found that “Gibbs’ overall train management system receives,
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`transmits, and manipulates information, as per the limiting preamble of claim 2.”
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`Dec. at 21 (emphasis added). Patent Owner responds that Gibbs does not disclose
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`“a plurality of containers” because a TWS station generates one set of maps and
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`reports at a time. Resp. at 56. But Patent Owner ignores, for example, that Gibbs
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`expressly describes an “overall train management system,” which discloses a
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`network of concurrently operating TWS workstations, each having software
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`allowing a user to generate various maps and reports. Ex. 1003 at ¶¶ 69-72 (citing,
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`e.g., Ex. 1006 at Fig. 2); Ex. 1009 at ¶ 48; see Ex. 1006 at 12:49-50 (generating “a
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`variety of maps in response to [user-selected] criteria”); Ex. 2009 at 181:4-182:2
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`(Fig. 2 shows multiple TWS stations). Gibbs discloses a plurality of containers
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`even under Patent Owner’s rationale, and thus, the Board correctly found that
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`Gibbs discloses a “plurality of containers” as specified in the preamble.
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`II. Gibbs Discloses the Claimed “Plurality of Registers”
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`Patent Owner challenges that Gibbs discloses a “plurality of registers” by
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`again focusing on each individual object in isolation, arguing that none has all the
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`“registers” in the claims. Resp. at 26. These arguments again ignore the claims
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`and mischaracterize Gibbs. Patent Owner also asserts that Gibbs does not disclose
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`that the instances of the transport, map, and report objects used to display
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`information to a user include “a first register for storing a unique container
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`identification value,” an “acquire register,” and the active/passive/neutral space
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`registers.3 Resp. at 41-56. These arguments must be rejected.
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`A.
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`“First Register for Storing a Unique Container Identifier”
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`The Board did not construe the term “a first register for storing a unique
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`3 Patent Owner “denies” the Board’s constructions of “container,” “gateway,” and
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`“register” but provides no basis to dispute those findings. Resp. at 4, 15 n.3.
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`container identification value” in its institution decision. For the first time in its
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`Response, Patent Owner now proposes a construction for this term – “a first
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`register for storing a value that uniquely identifies the given container.” Resp. at
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`16-19 (emphasis added), 41-42. Patent Owner’s attempt to incorporate unrecited
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`limitations into the claims should be rejected.
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`The claim language is clear – it recites a register for storing “a unique
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`container identification value” without reference to any particular container. This
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`limitation is satisfied by a value that uniquely identifies any container. While a
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`“unique container identification value” can identify the container that includes the
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`register, no language in the claim requires this – the claims use the indefinite
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`article “a”, not a term or phrase with an antecedent basis such as “the” or “said.”
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`This language stands in stark contrast to the language used to describe every other
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`“register” in claims 2 and 16 – each explicitly specifies “the container” (e.g.: “a
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`second register . . . governing interactions of the container . . .”; “an active space
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`register for identifying space in which the container will act . . .”; and an “acquire
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`register for controlling whether the container . . . .” (emphasis added)).
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`Patent Owner next argues the unique container identifier must refer to “the
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`given container” because the specification discloses an example of an “identity
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`register.” Resp. at 16-17. But even Dr. Green acknowledged the “identity
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`register” was just one example of a “first” register. Ex. 2009 at 113:1-22, 107:2-
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`110:22; see id. at 66:11-22. And the specification shows other examples, such as
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`registers that store identifiers of the contents of the container as opposed the
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`container itself. Ex. 1009 at ¶¶ 61-62; e.g., Ex. 1001 at 15:32-34 (describing “a
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`content key register [] identifying the container contents . . .”). Patent Owner next
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`asserts the first register must specify “the given container” because the original
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`claims specified “exchanging identification information.” Resp. at 17. The
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`original claims are irrelevant – even Dr. Green admitted they do not correspond to
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`the issued claims. Ex. 2009 at 131:1-10, 132:20-135:11. In addition, opaque
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`prosecution disclaimers cannot change the plain meaning of clear claim language
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`under the broadest reasonable construction standard used in these proceedings.
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`The Board correctly found that Gibbs shows each transport object’s unique
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`identifier is “a unique container identification value” because it uniquely identifies
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`the transport object. This is supported by undisputed evidence. Ex. 1003 at ¶¶ 81-
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`85; Ex. 2009 at 192:3-4 (“My understanding is that Gibbs discloses that transport
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`objects have unique IDs.”). Each transport object also is a “container” because
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`each is a logically defined data enclosure that encapsulates digital content. Ex.
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`1009 at ¶¶ 40-41; Ex. 2009 at 161:16-162:9, 164:8-18. When generating a map,
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`the unique IDs of the transport objects within the selected boundaries are loaded
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`into the map and report objects. Ex. 1003 at ¶¶ 86, 90, 97, 102, 113, 118, 159-61.
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`Thus, the collection of instantiated transport, map, and report objects displayed to a
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`user comprise “a first register for storing a unique container identifier.”
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`B.
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`“Acquire Register” For Adding “a Register from Other
`Containers or Add[ing] a Container from Other Containers”
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`The Board correctly found Gibbs discloses an “acquire register.” Dec. at 26
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`(“the formation of a map . . . is an act of controlling the object itself and adding to
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`itself a value or code associated with another object, i.e., a register.” (emphasis
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`added)). Patent Owner disagrees because it believes the instantiated transport,
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`map, and report objects displayed to a user is not a “container.” Resp. at 55-56.
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`Gibbs shows that to generate an output display (e.g., Figures 8a & 8b), the
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`software builds the selected maps and reports (i.e., a “container”) out of individual
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`transport, map, and report objects. Ex. 1003 at ¶¶ 159-61; see § I.A-B, above.
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`Thus, the output displayed to a user is a composite object, built from individual
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`objects. Ex. 1003 at ¶¶ 90, 97; Ex. 1006 at Fig. 9a-9c, 8:53-63, 9:31-40, 21:55-65,
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`22:2-12. Each of the transport, map, and report objects is a type of “container”;
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`each is a logically defined data enclosure that encapsulates digital content. Ex.
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`1009 at ¶¶ 40-41; Ex. 1003 at ¶¶ 77-79, 159-60; Ex. 2009 at 161:16-162:9, 164:8-
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`18. The collection of instantiated transport, map, and report objects is also a
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`container as it encapsulates other containers. Ex. 1001 at 8:64-9:2 (“The
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`information container 100 is a logically defined data enclosure which encapsulates
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`. . . any system component or process, or other containers or sets of containers.”).
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`Gibbs also shows that to build the maps and reports displayed to a user, each
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`map and report object will determine which transport objects meet the selected
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`criteria (e.g., are within the selected geographic boundaries), and each will collect
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`and store data (e.g., unique IDs, locational attributes, etc.) from the relevant
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`transport objects. Ex. 1003 at ¶¶ 159-61, ¶ 90 (citing Ex. 1006 at 8:53-63), ¶¶ 91-
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`92, 101-06; Ex. 1006 at Fig. 9a-9c, 9:31-40, 21:55-65, 22:2-12; see Pet. at 23, 18-
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`19; Dec. at 19 (“Gibbs discloses that map objects obtain and retain data items from
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`the transport objects.”). Thus, the map object “obtains and retains” data (i.e.,
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`registers) from each transport object (i.e., by adding a register from another
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`container). Ex. 1003 at ¶¶ 90, 97, 159-61; Ex. 2009 at 228:16-229:11 (Dr. Green
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`agreeing the map object adds data from transport objects). The map object also
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`acquires each transport object’s unique ID, which is a “logical description” of the
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`object, and encapsulates the objects themselves (i.e., another container). See Ex.
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`2009 at 191:15-193:1; see id. at 47:16-22, 49:3-16 (a URL is a logical reference),
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`57:20-58:11, 28:5-29:22. Thus, building the maps and reports for display to a user
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`shows an “acquire register.”
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`C.
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`“Active Space Register”
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`The Board found the warning criteria and the map boundaries in Gibbs each
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`was an active space register. Dec. at 19-20. In response, Patent Owner argues that
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`Gibbs does not show use of warning criteria to monitor space data (e.g., a train’s
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`location). Resp. at 43-48. But Gibbs unequivocally states warning criteria can be
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`used to monitor “any selected map or report data item” (Ex. 1003 at ¶ 106; Ex.
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`1006 at 12:36-41, 22:13-55), that map objects depicts train objects, and that the
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`map obtains and retains the location of each train. Ex. 1003 at ¶¶ 90-92, 102-06.
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`Each train’s location is a “data item” on a map that can be monitored, and if the
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`train deviates from its expected course, the map object will act on the system and
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`display by generating an alert displayed or signaled to a user. Id. at ¶¶ 125-28; Ex.
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`1009 at ¶¶ 49-54; Ex. 2009 at 190:10-191:9, 84:20-85:9, 87:5-9.
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`Patent Owner also asserts the map object does not “continuously monitor”
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`transport objects within the boundaries. Resp. at 47-48. But Gibbs shows that,
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`when generating a map, a user will enter the map boundaries, and the map object
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`then will act on each transport object within the boundaries to collect data from
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`those objects. Ex. 1009 at ¶¶ 32-34; Ex. 1003 at ¶¶ 90, 128; Ex. 2009 at 202:1-16,
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`218:22-222:3, 223:8-228:8. The Gibbs maps also show “real time data,” and Dr.
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`Green agreed a person of ordinary skill logically would configure Gibbs to provide
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`updates. Ex. 2009 at 239:19-241:4; Ex. 1003 at ¶ 101 (quoting Ex. 1006 at 4:18-
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`24). The Board thus correctly found Gibbs discloses an active space register.
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`D.
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`“Passive Space Register”
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`The Board correctly found the zoom increment in Gibbs to be a passive
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`space register. Dec. at 19-20, 22-23. Patent Owner disagrees, asserting a user can
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`zoom “irrespective of where the map object is or where the portion of the
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`transportation network it represents is.” Resp. at 48-49. Patent Owner’s theory is
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`irrelevant. First, Dr. Green agreed a relative location is data about space. Ex. 2009
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`at 82:12-83:22, 88:2-13, 208:2-11. The zoom increment defines the map’s zoom
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`boundaries relative to the original boundaries, and thus, is data about space. Id.;
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`Ex. 1003 at ¶¶ 133-37. It also defines space in which the objects will be acted
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`upon – when a user changes the zoom increment, the CMO will instruct the map
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`and report objects to regenerate, causing each to collect data from the transport
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`objects within the new boundaries and changing which objects are added to a map
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`and displayed. Ex. 1003 at ¶¶ 133-34; Ex. 2009 at 208:9-212:19, 215:22-216:15,
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`238:11-239:3. Thus, the zoom increment plainly specifies the space in which the
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`objects will be acted upon, which is a “passive space register” of the claims.
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`E.
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`“Neutral Space Register”
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`The Board correctly found the reports in Gibbs to be a neutral space register.
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`Decision at 20, 23. Patent Owner disagrees, asserting: (a) the reports do not show
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`interactions among transport objects and (b) even if they did, the location of the
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`transport objects does not identify space where the interaction may occur. Resp. at
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`50-54. Patent Owner again improperly focuses on the transport objects in isolation
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`– it ignores that Gibbs shows interactions among transport, map, and report
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`objects to generate a report. Gibbs also shows that to generate a train consist
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`report, a user first selects a particular train on a map. Ex. 1003 at ¶ 98 (citing Ex.
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`14
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`IPR2014-00086 & -00812
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`1006 at 16:53-17:4). The data about the train is passed to the report object, which
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`requests and receives data from the relevant train and car objects. Id. The report
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`object then uses the data from the train and cars to depict those objects on the map.
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`Id. Gibbs shows this same process for the terminal delay report, where selecting
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`the report will cause the map object to replace the terminal marker with a pie chart.
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`Ex. 2009 at 78:7-80:2, 172:3-15, 237:12-238:3, 241:22-245:13; Ex. 1003 at ¶¶ 99-
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`106. The location of each transport object thus specifies a point where various
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`objects may interact, making the terminal delay report a “neutral space register.”
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`Patent Owner also challenges the Board’s analysis, arguing the Board
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`“substitute[ed] the phrase ‘may act’ for the phrase . . . ‘may interact’” in its
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`analysis of Gibbs. Resp. at 20-21. But Gibbs shows interactions between objects
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`(e.g., the report object requests data from the train and car objects, and then those
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`objects send data back to the report object). See e.g., Ex. 1003 at ¶ 97 (citing Ex.
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`1006 at 9:31-40); Ex. 1009 at ¶¶ 63-65. Dr. Green’s testimony also shows this
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`supposed distinction is illusory, stating first “the word ‘interaction’ implies a two-
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`way flow of actions,” (Ex. 2009 at 154:7-16), but later stating interaction meant
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`only “the possibility that communications could go in either direction,” (id. at
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`156:15-157:6 (emphasis added), 158:18-21). Gibbs satisfies either construction.
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`The Board should maintain its finding that Gibbs anticipates claims 2-12, 14
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`and 16, as that finding is supported by substantial evidence.
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`15
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`IPR2014-00086 & -00812
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`Dated: October 27, 2014
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`Respectfully Submitted,
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`/Jeffrey P. Kushan/
`Jeffrey P. Kushan
`Registration No. 43,401
`Sidley Austin LLP
`1501 K Street NW
`Washington, DC 20005
`jkushan@sidley.com
`(202) 736-8914
`Attorney for Petitioner Apple
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`Certificate of Service
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`I hereby certify that on this 27th day of October, 2014, a copy of this
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`Petitioner’s Reply has been served in its entirety by email on the following counsel
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`of record for Patent Owner and Petitioners Yelp and Twitter:
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`Patent Owner:
`Anthony Patek
`Gutride Safier LLP
`835 Douglass Street
`San Francisco, CA 94114
`anthony@gutridesafier.com
`pto@gutridesafier.com
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`Todd Kennedy
`Gutride Safier LLP
`835 Douglass Street
`San Francisco, CA 94114
`todd@guttridesafier.com
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`Petitioners Yelp and Twitter
`Vaibhav P. Kadaba
`Kilpatrick Townsend & Stockton LLP
`1100 Peachtree Street NE, Suite 2800
`Atlanta, GA 30309-4528
`wkadaba@kilpatricktownsend.com
`rartuz@kilpatricktownsend.com
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`Dated: October 27, 2014
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`Respectfully submitted,
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`/Jeffrey P. Kushan/
`Jeffrey P. Kushan
`Attorney for Petitioner Apple