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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` ____________
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`RELOADED GAMES, INC.
`Petitioner
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`v.
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`PARALLEL NETWORKS LLC
`Patent Owner
`____________
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`Case No. IPR2014-00136
`Patent 7,188,145
` ____________
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`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE
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`PURSUANT TO 37 C.F.R. § 42.120
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`IPR2014-00136
`U.S. Patent No. 7,188,145
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`TABLE OF CONTENTS
`TABLE OF CONTENTS ................................................................................... 2
`I. INTRODUCTION ......................................................................................... 1
`II. SMITH IN VIEW OF INOHARA RENDERS CLAIMS 1, 2-4, 6, 7, 10, 16-18,
`20, 21, 24, 35 AND 36 OBVIOUS ..................................................................... 1
`A. SMITH IN VIEW OF INOHARA TEACH “ALLOWING A CLIENT TO JOIN THE CACHE
`COMMUNITY” (CLAIM 1) .............................................................................................. 1
`1. Inohara’s Disclosed Server Group is a “Community” ................................................. 2
`2. Inohara’s Disclosed Server Group “Allows” a Client to Join a Community ................ 6
`3. The Combination of Smith and Inohara Teach Allowing and Denying Entry of
`Servers to a Proxy Server Array (i.e., Community) .................................................... 9
`4. The Record Evidence Supports that Smith and Inohara are Properly Combined to
`Render Claim 1 Obvious ....................................................................................... 11
`III. SMITH IN VIEW OF INOHARA RENDERS CLAIMS 29-34 AND 36
`OBVIOUS ..................................................................................................... 12
`IV. CONCLUSION ........................................................................................... 13
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`INTRODUCTION
`Taking a similar tactic to its response in the related proceeding (IPR2014-00139),
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`IPR2014-00136
`U.S. Patent No. 7,188,145
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`I.
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`PO is improperly attempting to create limitations through the terms “allowing” and
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`“community” that are not found in the claims or required by the Board’s construction.
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`The PO strains the Board’s constructions to avoid the prior art. A proper application of
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`the Board’s claim construction – rendered according to the broadest reasonable
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`interpretation standard – to the combination of Smith and Inohara confirms that the
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`Challenged Claims are obvious.
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`II.
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`SMITH IN VIEW OF INOHARA RENDERS CLAIMS 1, 2-4, 6, 7, 10, 15,
`16-18, 20, 21, 24, 35 AND 36 OBVIOUS1
`A.
`Smith in view of Inohara Teach “Allowing a Client to Join the Cache
`Community” (Claim 1)
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` 1
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`While the Board instituted the present proceeding on dependent claims 2-4, 6,
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`7, 10, 16-18, 20, 21 and 24, it expressly found that Inohara teaches “allowing” or
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`“allow” as claimed by independent claims 1 and 15, which were not instituted because
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`it was not specifically requested by Petitioner. Petitioner respectfully requests that the
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`Board exercise its discretion in any final decision to cancel independent claims 1 and
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`15. First, in the event that the Board invalidates claims 2 and 16, it will necessarily
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`have found that all limitations of the independent claims are present in the prior art.
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`Second, PO will not be prejudiced by such a finding because the “allowing” and
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`“allow” limitations of claims 1 and 15 are the premise of PO’s entire argument.
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`1
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`PO’s response on the combination of Smith in view of Inohara is somewhat
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`confusing. It appears that PO contends that Inohara does not teach a “community”
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`under PO’s strained interpretation of that term, and because of that strained
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`interpretation does not teach “allowing.” This is confusing because PO does not
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`dispute that Smith teaches a “community.” And, the Board has already found that
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`Inohara teaches “allowing” as required by claim 1. Paper 15 [Institution Decision] at
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`30.
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`Nonetheless, PO appears to be melding the two concepts into a single concept
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`by testing Inohara against the entire phrase “allowing a client to join the cache
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`community.” This is a meritless argument by PO. A proper application of the
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`Board’s constructions of “allowing” and “community,” demonstrates that Inohara
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`meets PO’s challenge head-on.
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`1.
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`Inohara’s Disclosed Server Group is a “Community”
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`In its Decision to Institute, the Board construed “community” to mean “similarity
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`or identity” or “sharing, participation, and fellowship.” Paper 15 [Institution Decision] at
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`13. The Board also correctly found that Inohara’s disclosed server group is a
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`“community” and rejected PO’s contention that Inohara’s server group is not a “group
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`of peers that cooperate to cache data.” Id. at 28-31. Now, PO argues that the
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`“community” of Inohara is “a single distributed cache hierarchy” rather than the
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`individual server groups and, therefore, a server is not “allowed” to join the
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`“community” because it cannot be denied entry to the hierarchy, only to a server group.
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`Paper 23 [PO Response] at 4-18.
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`The individual server groups of Inohara are each a “community” under the
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`Board’s construction. Namely, Inohara discloses that “[o]ne [server] group includes a
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`MAX servers or members (MAX: a fixed number) at the largest.” Ex. 1007, Inohara at
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`7:47-49. Each member of a server group participates in that group and in order to
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`become a member of a group, the server that “wants to newly participate in a group”
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`issues a “group participation message 300.” Ex. 1007, Inohara at 8:1-2 (emphasis added).
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`The leader of the group determines whether a “server [is] permitted to participate in a
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`group.” Id. at 8:24-26 (emphasis added); also 10:51-11:17. Once part of the group, each
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`member of the group has a common similarity or identity and “participates” in that
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`group. Namely, each member’s “group table” has the same list of a leader server ID and
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`group member IDs, i.e., the servers of a group have “similarity” in their group tables and
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`share information with other servers in the group. Id. at Fig. 2, 10:19-30, 7:59-61; see also
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`id. at 11:32-37 (“In subsequent step 519, a group update message 320 having the server
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`ID of the server 10 stored in new leader server ID 321 is transmitted to the new server
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`ID 301 and a group update message having the new server ID 301 stored in new leader
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`server ID 321 is transmitted to the new server ID’s 3011, 30111, ….”). On the other hand,
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`when a server is not permitted to join a group, “a new group is formed.” Id. at 11:8-19.
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`To suggest that a first group of servers (e.g., servers 2321, 23211, etc. in Inohara), which
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`have the same group leader (e.g., server 232), are not “participating” in a “community,”
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`to which a second group of servers (e.g., servers 301, 3011, 30111, etc.) are denied the
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`opportunity to join, is not consistent with the broadest reasonable interpretation of a
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`“community.” Each server group of Inohara is a community because the members of
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`each server group have similarity or identity and each server group is established for the
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`purpose of “sharing, participation, and fellowship.”
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`Further, Inohara discloses that a cache directory is updated and shared among
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`members of the group. Id. at 15:19-21 (“In order to update the cache directory 108 of the
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`group, the server 10 acquiring the new information transmits a host URL message 370 to
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`members of the group.”)(emphasis added); also id. at 18:24-27. Inohara also discloses a
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`process for making sure that all copies of cached information in a group are not
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`“revoked” at the same time. Id. at 17:49-55. Nowhere, however, does Inohara disclose
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`that the cache directories are shared among members of other groups in the hierarchy. In
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`terms of retrieving shared content, there is no appreciable difference between the
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`“community” in the preferred embodiment of the ‘145 Patent and Inohara. Compare Ex.
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`1001, ‘145 Patent at 14:20-32 (determining whether requested content is available within
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`the “community” by searching a location table) with Ex. 1007, Inohara at 14:53-15:24
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`(determining whether requested content is available within the group, i.e., “community,”
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`by searching a cache directory).
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`Neither the ‘145 Patent nor the Board’s construction preclude a situation where a
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`member of one community cannot also be a member of a hierarchy of communities.
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`Tellingly, Patent Owner does not cite to the intrinsic record to support its position. In
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`fact, the ‘145 Patent is lacking any disclosure limiting clients to only being a member of a
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`single community. Rather, the ‘145 Patent discloses that a community “may be formed
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`by dynamically seeking out other active instances of cache module” where “based on a
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`set of performance heuristics, clients 12 are bonded together under favorable
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`conditions.” Ex. 1001, ‘145 Patent at 13:22-26.
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`Nor does the Board’s construction of “community” require membership only in a
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`single community. Using PO’s example (see Paper 23 [PO Response] at 16-17), a house in
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`a subdivision/neighborhood may be a member of the subdivision/neighborhood
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`community, such that the house has similarity or identity with other houses in that
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`subdivision/neighborhood. The house may also be a member of the broader city-wide
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`community, such that the house has similarity or identity with other houses in that city.
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`The city may be a member of the broader county-wide community, and so on. Thus, the
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`broadest reasonable construction – or any reasonable construction – of “community” is
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`not limited as PO suggests.
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`Further, although Inohara contemplates a hierarchy of groups, where each
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`member of the group is aware of other proximate server groups by virtue of information
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`stored in a “group table,” Inohara also discloses that, on startup, servers initially form
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`“one group.” Ex. 1007, Inohara at 9:17-41. Contrary to PO’s numerous and lengthy
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`5
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`assertions, Inohara expressly discloses a situation where there is only one group in the
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`hierarchy, and prior to reaching the maximum number of members for the initial group,
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`each server that attempts to join the group will be “allowed” entry, with a possibility of
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`being “denied.” Id. In this scenario, the initial server group can be seen as a “cache
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`community” even under PO’s overly narrow interpretation, “because it would [] provide
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`access to all requests for cached content.” Paper 23 [PO Response at 16].
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`Finally, PO relies on its expert, Dr. Mitchell Thornton, to support its
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`interpretation of Inohara. However, Dr. Thornton’s report is notable for a few
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`reasons. First, he does not at any point acknowledge the Board’s construction of
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`“allowing” or “community.” Failing to even recognize the Board’s construction, he
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`does not state why Inohara does not meet the Board’s construction. Second, Dr.
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`Thornton does not specifically reference any portion of the ‘145 Patent. Dr.
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`Thornton’s opinions are entirely irrelevant to the issue of whether the server groups
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`of Inohara have “similarity or identity” and “[s]haring, participation, and fellowship.”
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`He simply did not discuss these actual constructions.
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`The Board should, once again, reject PO’s attempt to inject an inappropriate
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`limitation into the term “community.” Under the broadest reasonable construction,
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`Inohara, and Smith for that matter, teach a “community.”
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`2.
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`Inohara’s Disclosed Server Group “Allows” a Client to Join a
`Community
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`In its Decision to Institute, the Board construed “allow” and “allowing” as
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`meaning “to permit the presence of.” Paper 15 [Institution Decision] at 14. The
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`Board correctly found that Inohara’s disclosed server groups “permit the presence of”
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`new servers in the group. Id. at 30. PO contends that, in Inohara, “even if an
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`individual server group could be construed as a cache community, there is no
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`mechanism in Inohara to deny entry to a new server into such a group.” See Paper 23
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`[PO Response] at 19. The Board has already properly rejected this same argument.
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`Paper 15 [Institution Decision] at 30.
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`PO appears to contend that “allowing a client to join the community” as
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`recited in claim 1 also requires “denying” a client attempting to join the community.
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`As the Board already determined, “[i]f the sum of the number of old members and
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`new members in Inohara is smaller than MAX, Inohara would permit the presence of
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`the server requesting to join.” Paper 15 [Institution Decision] at 30. When the leader
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`of a group determines that the group is at maximum capacity, instead of allowing a
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`new client to join the group, the client requesting to participate in the group must
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`form a new group. Ex. 1007, Inohara at 11:18-37; see also id. at 11:39-42 (“[I]t becomes
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`possible to make hierarchization corresponding to a dynamic increase in the number
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`of servers while the maximum number of members in each group is kept equal to or
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`smaller than MAX.”). Not allowing a client into the group is denying its ability to
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`join.
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` The
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`‘145 Patent discloses the nearly
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`identical process. Namely, the
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`determination of whether to allow a new client to join an existing community may be
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`based on “whether the addition of client 404 would exceed the maximum number of
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`members 412 that may be in community 402.” Ex. 1001, ‘145 Patent at 20:53-55.
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`Where a client is denied entry, the client “nominates itself as a master” and “creates a
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`new cache community.” Id. at 24:23-40; see also id. at 13:33-36 (“If no communities 100
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`are found or found communities 100 do not allow cache module 26, then cache
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`module 26 may attempt to start its own cache community.”), Fig. 9.
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`The caching architecture of Inohara is not nearly as different, as Patent Owner
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`would have this Panel believe, from the architecture described by the ‘145 Patent. In
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`the ‘145 Patent, one or more cache servers include an “administration module” that
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`stores a list of communities that are close to the one or more cache servers “in terms
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`of network distance,” and may impose an upper and/or a lower limit on the network
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`distance from the server that may be listed. Ex. 1001, ‘145 Patent at 19:33-20:10.
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`Similar to the “master” and “members” of a community, the one or more cache
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`servers are nothing more than a general-purpose computer programmed to perform
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`certain functions. Id. As discussed above, when a server is “denied” entry into one
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`community, it may form its own community, which will be listed on the community
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`list of one or more cache servers. Id. at 24:23-45. Accordingly, the caching architecture
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`of the ‘145 Patent includes a hierarchy of communities organized based on network
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`distance. Similarly, Inohara discloses that each server in the hierarchy includes a
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`“group table” with a list of proximate servers and a “server status table” with a
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`8
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`measured communication speed to each proximate server. Ex. 1007, Inohara at 7:31-
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`64, 19:33-20:19. A new server determines which group to join based on the measured
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`communication speed (i.e., network distance). Id. at 10:13-19. As previously discussed,
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`when the leader of a group determines that the group is at maximum capacity, instead
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`of allowing a new client to join the group, the client requesting to participate in the
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`group must form a new group. Ex. 1007, Inohara at 11:18-37. In both the ‘145 Patent
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`and Inohara a server that is denied entry into a specific group/community still
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`participates in the overall “caching architecture.”
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`Finally, Patent Owner’s contention that a communication denying entrance
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`into the server group is a requirement of claim 1 (Paper 23 [PO Response] at 19
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`(“There is no communication sent in Inohara to a new server indicating that entrance
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`to the server group has been denied.”) is clearly controverted by the express
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`disclosures of ‘145 Patent. Ex. 1001, ‘145 Patent at 25:10-13 (“If client 404 is not
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`allowed to join community 402, then the … join request is ignored by master 410”);
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`see also id. at 21:22-27. Inohara teaches “allowing” a client to join a “community.”
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`3.
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`The Combination of Smith and Inohara Teach Allowing and
`Denying Entry of Servers to a Proxy Server Array (i.e.,
`Community)
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`Looking now to the combination of Smith and Inohara, PO does not dispute
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`that the proxy server array of Smith is a cache “community” within the meaning of
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`claim 1, as construed by the Board. Smith discloses a distributed data caching scheme
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`utilizing an array of proxy servers (i.e., community). Ex. 1006, Smith at 1:5-15; Fig. 2.
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`Smith also teaches sharing array membership information between proxy servers in
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`the array so that all proxy servers know where object data resides. Id. at 4:31-36. A
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`membership list is updated upon allowing the addition or removal of members to the
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`array. Id. at 4:67-5:6, 18:49-53. When a proxy server is added or removed, all of the
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`remaining proxy servers will be assigned fewer or additional data objects to store in
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`their local cache. Id. at 12:50-62. PO argues, “[i]nstead of including any discussion on
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`how a proxy server is admitted into the described proxy server array, Smith simply
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`describes a new proxy server as having been added to the array.” See Paper 23 [PO
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`Response] at 4 (citing Ex. 1006, Smith at 18:54-55). Again, this argument is confusing
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`because the instituted grounds rely on Inohara for teaching a specific mechanism for
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`“allowing” a new server in a server group, not Smith.
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`Like Smith and the ‘145 Patent, Inohara describes a distributed caching
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`infrastructure and recognizes that rapid growth of internet usage has created increased
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`response times for users. Ex. 1007, Inohara at Abstract, 3:4-15; Ex. 1006, Smith at 2:18-
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`24. As with Smith, Inohara allows for the addition of servers to form a group of
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`servers and the groups, in turn, make up the large-scale cache. Ex. 1007, Inohara at
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`9:16-10:36. Inohara expressly discloses permitting the presence of or “allowing” a
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`server to join a server group. Specifically, Inohara discloses that the group “leader”
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`receives a group participation message and determines whether to permit the presence
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`of a server in the group based on whether the group has reached a maximum number
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`of members. See, e.g., id. at 10:38-11:3, 8:1-18, 8:25-27. Inohara’s disclosure of
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`determining whether to permit the presence of a client in a community based on
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`whether the sum of the old and new members is smaller than a maximum number
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`(“MAX”) is expressly contemplated by the ‘145 patent. Compare Ex. 1007, Inohara at
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`10:60-66 with Ex. 1001, ‘145 Patent at 20:53-55.
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`As noted by the Board, “Smith describes that ‘many different implementations
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`may be envisioned by those skilled in the art that will allow a proxy server to be added
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`to the proxy server array.’” See Paper 15 [Institution Decision] at 24 (citing Ex. 1006,
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`Smith at 18:51-53). Inohara discloses one such implementation and teaches that it
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`would be useful to allow cache servers the ability to search for and join cache groups
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`so as to increase the effectiveness of the caching scheme. Ex. 1007, Inohara at 3:48-58.
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`Inohara’s “allowing” is combined with Smith’s “community” to satisfy the Challenged
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`Claims.
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`4.
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`The Record Evidence Supports that Smith and Inohara are
`Properly Combined to Render Claim 1 Obvious
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`In a last-ditch attempt to rescue some of its claims, PO argues that “a forced
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`combination with Smith renders Inohara inoperative and therefore Inohara and Smith
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`are non-combinable.” Paper 23 [PO Response] at 22. PO’s assertion is an offshoot of
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`PO’s overly narrow claim interpretations and reading of Inohara which, as discussed
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`above, should be rejected. It should also be rejected because PO fails to recognize
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`that it is the “community” of Smith that is being modified in the proposed
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`combination, not the “community” of Inohara. On the actual proposed combination,
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`the record is clear. A person having ordinary skill in the art would have recognized
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`that the distributed caching scheme described in Smith could have been combined
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`with Inohara to include the function of allowing proxy servers the ability to search for
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`and join existing proxy server arrays (i.e., communities). Ex. 1002, Danzig Declaration,
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`at ¶ 17. Adding the software capabilities for transmitting group participation
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`messages, determining whether the addition of a new server would cause the group to
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`exceed the maximum number of members, and permitting the new server to join the
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`group based on that determination as described in Inohara to the distributed caching
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`system of Smith is well within the capabilities of one of skill in the art. Id. Upon
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`reading the disclosure of Inohara, a skilled artisan would have recognized that such a
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`modification would increase the effectiveness and performance of the system
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`described in Smith due to the resulting large-scale cache that extends over a plurality
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`of servers. Id. Therefore, the evidence of record demonstrates that one of ordinary
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`skill in the art would have been motivated to combine the various teachings of Smith
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`and Inohara to arrive at the purported invention of claim 1.
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`III. SMITH IN VIEW OF INOHARA RENDERS CLAIMS 29-34 AND 36
`OBVIOUS
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`Continuing with its misconstruction of “community,” PO asserts that Smith in
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`view of Inohara does not teach claims 29-34 and 36. Paper 23 [PO Response] at 26-
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`12
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`28. PO argues that Inohara does not teach a list of communities because it only
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`involves a single community and further argues that a server group is assigned, and
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`not selected, by the server requesting to join. This flawed reasoning is discussed
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`above and will not be repeated here. PO additionally argues that a server is “assigned”
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`to a group and, therefore, does not meet the “selecting” limitation. This too is
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`incorrect. As noted in the Petition, a joining server in Inohara sends a group
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`participation message to “the most proximate server in a group of servers.” Ex. 1007,
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`Inohara at 10:13-17; see also id. at claim 2 (“a processing for which said first computer
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`selects a second computer in said table”). The most proximate server is determined as
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`the server with the maximum value of the division of throughput by latency. Id. This
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`is not a random assignment of a server; rather, it is a calculated decision of which
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`server group to join. The process for selecting the most proximate server is akin to
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`the ‘145 Patent’s preferred embodiment for determining the “best fit” community
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`based on the roundtrip transmission time. Compare Ex. 1001, ‘145 Patent at 23:54-62,
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`19:58-20:7 with Ex. 1007, Inohara at 10:13-17. Therefore, Inohara clearly teaches the
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`“selecting” limitation. As PO does not raise any other issues with respect to these
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`claims, the Board should affirm its initial finding and invalidate claims 29-34 and 36.
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`IV. CONCLUSION
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`Based on the foregoing, the Board should invalidate claims 1-4, 6, 7, 10, 15-18,
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`20, 21, 24 and 29-36 of the ‘145 Patent as obvious over Smith in view of Inohara.
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`Date: October 31, 2014
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`Respectfully submitted,
`ERISE IP, P.A.
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`BY: /Eric A. Buresh
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`Eric A. Buresh, Reg. No. 50,394
`Mark C. Lang, Reg. No. 55,356
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`P: (913) 777-5600
`F: (913) 777-5601
`eric.buresh@eriseip.com
`mark.lang@eriseip.com
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`ATTORNEYS FOR PETITIONERS
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`14
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`IPR2014-00136
`U.S. Patent No. 7,188,145
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`CERTIFICATE OF SERVICE ON PATENT OWNER
`UNDER 37 C.F.R. § 42.105(a)
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`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(b), the undersigned certifies that on
`October 31, 2014, a complete and entire copy of Petitioner’s Reply was served by
`electronic mail to Counsel for Patent Owner at the e-mail addresses identified below:
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`Darren Collins
`Robert Hilton
`Aaron Pickell
`McGuire Woods
`2000 McKinney Ave., Suite 1400
`Dallas, TX 75201
`dwcollins@mcguirewoods.com
`rhilton@mcguirewoods.com
`apickell@mcguirewoods.com
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`Respectfully submitted,
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`BY:
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`ERISE IP, P.A.
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` /Eric A. Buresh/
`Eric A. Buresh, Reg. No. 50,394
`Mark C. Lang, Reg. No. 55,356
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`P: (913) 777-5600
`F: (913) 777-5601
`eric.buresh@eriseip.com
`mark.lang@eriseip.com
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`ATTORNEYS FOR PETITIONER