IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`ENZYMOTEC LTD.,
`Petitioner
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`v.
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`NEPTUNE TECHNOLOGIES AND BIORESSOURCES INC.,
`Patent Owner
`
`IPR2014-00586
`
`MOTION FOR JOINDER UNDER 35 U.S.C. § 315(c) AND
`37 C.F.R. §§ 42.22 AND 42.122(b)
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ENZYMOTEC LTD.,
`Petitioner
`
`v.
`
`NEPTUNE TECHNOLOGIES AND BIORESSOURCES INC.,
`Patent Owner
`
`IPR2014-00586
`
`MOTION FOR JOINDER UNDER 35 U.S.C. § 315(c) AND
`37 C.F.R. §§ 42.22 AND 42.122(b)
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`I.
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`STATEMENT OF THE PRECISE RELIEF REQUESTED
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`Pursuant to 35 U.S.C. § 315(c) and 37 C.F.R. § 42.122(b), Enzymotec Ltd.
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`respectfully submits this Motion for Joinder, together with a Petition for Inter
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`Partes Review of U.S. Patent No. 8,278,351, Petition IPR2014-00586 (the
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`“Enzymotec IPR”). Enzymotec requests joinder of the Enzymotec IPR with Aker
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`Biomarine AS v. Neptune Technologies and Bioressources, Inc., Case IPR2014-
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`00003 (the “Aker IPR”). The Aker IPR was instituted on March 24, 2014, and it
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`likewise concerns U.S. Patent No. 8,278,351 (the “’351 patent”).
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`In the Aker IPR, the Board instituted trial on claims 1-6, 9, 12, 13, 19-
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`29, 32, 35, 36, and 42-46 of the ’351 patent. (Institution of Inter Partes
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`Review, Aker IPR, Paper No. 22 at p. 2 (March 24, 2014).) The Enzymotec
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`IPR seeks institution of inter partes review of additional claims of the ’351
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`patent, namely claims 47-52, 55, 58, 59, and 65-69.1 As will be shown
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`below, these claims are virtually identical to the claims at issue in the Aker
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`IPR, with the sole exception of minor differences in the preamble language.
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`Because the differences in the claims at issue in the Aker and Enzymotec
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`1 On April 4, 2014, Enzymotec filed another petition for IPR on
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`the ’351 patent (directed to the same claims at issue in Aker’s IPR, i.e.,
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`claims 1-6, 9, 12, 13, 19-29, 32, 35, 36, and 42-46), together with a motion
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`for joinder with Aker’s IPR. See IPR2014-00556.
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`
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`1
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`
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`IPRs are so minor, the identical prior art, grounds of unpatentability, and
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`expert declarations that are the subject of Aker’s IPR are at issue in
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`Enzymotec’s IPR.
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`Joinder of the Enzymotec IPR to the Aker IPR is appropriate. The
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`Enzymotec IPR will not introduce new issues, prior art, or expert
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`declarations. In addition, Enzymotec is willing to cooperate with Aker to
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`streamline discovery and briefing. Joinder will therefore promote the
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`efficient resolution of the question of validity of a patent in a single
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`proceeding, and will not prejudice the parties to the Aker IPR. Absent
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`joinder, Enzymotec will be prejudiced because its petition is time-barred, and
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`its interests may not be adequately represented in the Aker IPR.
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`II. MATERIAL FACTS
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`Neptune Technologies and Bioressources, Inc. (“Neptune” or “Patent
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`Owner”) owns the ’351 patent. On October 2, 2012, Neptune sued Enzymotec in
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`district court for alleged infringement of this patent. (Neptune et al. v. Enzymotec
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`et al., D. Del., 1:12cv1253.) On January 29, 2013, Neptune filed a complaint
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`with the International Trade Commission against Enzymotec and others alleging
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`violation of 19 U.S.C. § 1337 by importation into the U.S. of articles that
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`allegedly infringe the ’351 patent. (ITC Investigation No. 337-TA-887, the “ITC
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`Investigation.”) On May 13, 2013, the district court case against Enzymotec was
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`2
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`stayed pending resolution of the ITC Investigation. On December 16, 2014, the
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`ITC Investigation was stayed, pending Neptune and Enzymotec’s efforts to
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`conclude a settlement agreement.
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`On March 24, 2014, the Board instituted Aker’s IPR on claims 1, 3-6, 9,
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`12, 13, 19-24, 26-29, 32, 35, 36, and 42-46 of the ’351 patent, on the ground of
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`anticipation by WO 00/23546 to Beaudoin (“Beaudoin I”). (Institution of Inter
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`Partes Review, Aker IPR, Paper No. 22 at pp. 8-16 (March 24, 2014).) The
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`Board also instituted inter partes review of these same claims, plus claims 2 and
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`25, on the ground of obviousness over Fricke et al., Lipid, Sterol, and Fatty Acid
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`Composition of Antarctic Krill, LIPIDS, Vol. 19, No. 11, pp. 821-827 (“Fricke”),
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`Bergelson, Lipid Biochemical Preparations, Elsevier/North-Holland Biomedical
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`Press (“Bergelson”), JP Pat. App. Pub. Hei 8-231391 (“Yasawa”), Bio and High
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`Technology Announcement (“Itano”), and WHO News and Activities, Nutritional
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`Value of Antarctic Krill (“the WHO Bulletin”). (Id. at pp. 21-27.)
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`Enzymotec’s IPR seeks institution of trial with respect to claims 47-52, 55,
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`58, 59, and 65-69 of the ’351 patent on the same two grounds at issue in Aker’s
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`IPR, namely: (1) anticipation by Beaudoin I; and (2) obviousness over Fricke,
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`Bergelson, Yasawa, Itano, and the WHO Bulletin. (Petition for Inter Partes
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`Review of U.S. Patent 8,278,351, Petition IPR2014-00586.)
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`3
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`
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`III. STATEMENT OF REASONS FOR THE RELIEF REQUESTED
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`The Leahy-Smith America Invents Act permits joinder of like review
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`proceedings, e.g. an inter partes review may be joined with another inter partes
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`review. 37 C.F.R. § 42.122(a). The Board has discretion to join parties to an
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`existing inter partes review. 35 U.S.C. § 315(c). In deciding whether to exercise
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`its discretion, the Board considers factors including: (1) the movant’s reasons
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`why joinder is appropriate; (2) whether the new petition presents any new
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`grounds of unpatentability; (3) what impact (if any) joinder would have on the
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`trial schedule for the existing review; and (4) how briefing and discovery may be
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`simplified. Dell Inc. v. Network-1 Security Solutions, Inc., Decision on Motion
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`for Joinder, IPR2013-00385, Paper No. 17 at 4 (July 29, 2013).
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`A. Enzymotec’s Motion For Joinder is Timely
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`The instant Petition and this Motion for Joinder are timely under 35 U.S.C.
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`§ 315(c) and 37 C.F.R. § 42.122(b). While, as a general proposition, inter partes
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`review may not be instituted more than one year after the date on which a petitioner
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`is served with a complaint alleging infringement of the patent-at-issue (35 U.S.C. §
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`315(b)), the one year period does not apply when a petition for inter partes review
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`is accompanied by a motion for joinder filed within one month of institution of the
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`inter partes review for which joinder is requested. 37 C.F.R. § 42.122(b). This
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`Motion for Joinder and the accompanying Petition are timely, as they are submitted
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`4
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`within one month of the March 24, 2014 institution of the Aker IPR.
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`B. Joinder is Appropriate
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`Joinder is appropriate because Enzymotec will be unduly prejudiced if
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`joinder is denied. As noted above, Enzymotec remains a party in the ITC
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`Investigation and district court case concerning the ’351 patent. The ITC
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`Investigation was stayed pending the parties’ efforts to conclude a settlement
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`agreement, but to date the parties have been unable to reach settlement.
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`Accordingly the stay will be lifted on April 14, 2014, and the hearing will be held
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`beginning April 28, 2014. (Order No. 43, Setting Amended Procedural
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`Schedule, ITC Investigation 337-TA-877.)
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`At this stage, in order to challenge Neptune’s claims in an inter partes
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`review, the only option available to Enzymotec is to file its petition and
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`simultaneously request joinder to Aker’s IPR pursuant to 37 C.F.R. § 42.122(b).
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`Therefore, absent joinder, Enzymotec’s petition for inter partes review would
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`be barred. Enzymotec would be prejudiced if the Board refuses joinder, as its
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`interests may not be adequately represented in the Aker IPR.
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`In contrast, neither Aker nor Neptune would suffer prejudice if the Board
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`permits joinder. Enzymotec’s Petition is limited to claims that mirror the claims
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`at issue in Aker’s IPR, and it presents the same two grounds of unpatentability
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`on which the Aker IPR was instituted. Specifically, Aker’s IPR is directed to a
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`5
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`total of 28 claims, which can be categorized into two related groups:
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`Group 1 consists of independent claim 1 and dependent claims 2-6, 9, 12,
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`13, and 19-23. Claim 1’s preamble recites a “krill extract,” and the remainder of
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`claim 1, as well as the dependent claims in Group 1, are directed to certain
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`features of the krill extract.
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`Group 2 consists of independent claim 24 and dependent claims 25-29,
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`32, 35, 36, and 42-46. Claim 24’s preamble recites a “capsule, tablet, solution,
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`syrup, or suspension comprising a krill extract.” The remaining limitations are
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`identical to the limitations of the Group I claims.
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`Likewise, the claims at issue in Enzymotec’s IPR differ from those in
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`Group 1 and Group 2 based only on certain words in the preamble. Whereas the
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`claims at issue in Group 1 are directed to a “krill extract,” and those in Group 2
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`are directed to a “capsule, tablet, solution, syrup or suspension comprising a krill
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`extract,” those at issue in the Enzymotec IPR are directed to a “food, beverage,
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`energy bar, or nutritional supplement comprising a krill extract.” Claim 47 is
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`the only independent claim included in Enzymotec’s IPR. Other than
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`differences in the words in the preamble, the limitations of independent claim 47
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`are identical to those of independent claims 1 and 24. And the dependent claims
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`at issue in the Enzymotec IPR contain the identical substantive limitations to
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`those in the Aker IPR. The table below shows the identity of the claims:
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`
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`6
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`
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`Group 1 claims at
`issue in Aker’s IPR
`1. A krill extract
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`Group 2 claims at
`issue in Aker’s IPR
`24. A capsule, tablet,
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`Claims at issue in
`Enzymotec’s IPR
`47. A food, beverage,
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`comprising:
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`solution, syrup, or
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`energy bar, or
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` a
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`suspension comprising
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`nutritional supplement
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`a krill extract
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`comprising:
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`comprising a krill
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`extract comprising:
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` phospholipid of the
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`a phospholipid of the
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`a phospholipid of the
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`general formula (I),
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`formula (I),
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`formula (I),
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`wherein R1 and R2,
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`wherein R1 and R2,
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`wherein R1 and R2,
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`each together with the
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`each together with the
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`each together with the
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`respective carboxyl
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`respective carboxyl
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`respective carboxyl
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`groups to which each
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`groups to which each
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`groups to which each
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`is attached, each
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`is attached, each
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`is attached, each
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`independently
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`represents a
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`independently
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`represents a
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`independently
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`represents a
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`docosahexaenoic acid
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`docosahexaenoic acid
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`docosahexaenoic acid
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`7
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`(DHA) or an
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`(DHA) or an
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`(DHA) or an
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`eicosapentanoic acid
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`eicosapentaenoic acid
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`eicosapentaenoic acid
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`(EPA) residue, and X
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`(EPA) residue, and X
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`(EPA) residue, and X
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`is --CH2CH2NH3, --
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`is --CH2CH2NH3, --
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`is --CH2CH2NH3, --
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`CH2CH2N(CH3)3, or
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`CH2CH2N(CH3)3, or
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`CH2CH2N(CH3)3, or
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`and wherein the extract
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`and wherein the extract
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`and wherein the extract
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`is suitable for human
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`is suitable for human
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`is suitable for human
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`consumption.
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`2. The extract
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`consumption.
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`consumption.
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`25. The extract
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`48. The extract
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`according to claim 1,
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`according to claim 24,
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`according to claim 47,
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`wherein the extract has
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`wherein the extract has
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`wherein the extract has
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`a total phospholipid
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`a total phospholipid
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`a total phospholipid
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`concentration in an
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`concentration in an
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`concentration in an
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`amount of about 40%
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`amount of about 40%
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`amount of about 40%
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`w/w, wherein about
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`w/w, wherein about
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`w/w, wherein about
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`represents ± 10%.
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`represents ± 10%.
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`represents ± 10%.
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`3. The extract
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`26. The extract
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`49. The extract
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`8
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`
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`according to claim 1,
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`according to claim 24,
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`according to claim 47,
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`wherein the extract has
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`wherein the extract has
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`wherein the extract has
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`a total phospholipid
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`a total phospholipid
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`a total phospholipid
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`concentration in an
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`concentration in an
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`concentration in an
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`amount of about 45%
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`amount of about 45%
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`amount of about 45%
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`w/w, wherein about
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`w/w, wherein about
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`w/w, wherein about
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`represents ± 20%.
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`represents ± 20%.
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`represents ± 20%.
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`4. The extract
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`27. The formulation
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`50. The nutraceutical
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`according to claim 1,
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`according to claim 24,
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`composition of claim
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`further comprising
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`further comprising
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`47, wherein the extract
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`
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`
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`further comprises
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`an additional lipid,
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`an additional lipid,
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`an additional lipid,
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`wherein the additional
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`wherein the additional
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`wherein the additional
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`lipid is selected from
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`lipid is selected from
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`lipid is selected from
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`the group consisting of
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`the group consisting of
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`the group consisting of
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`monoglycerides,
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`monoglycerides,
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`monoglycerides,
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`triglycerides,
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`triglycerides,
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`triglycerides,
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`cholesterols, mixtures
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`cholesterols, mixtures
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`cholesterols, mixtures
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`thereof, and free fatty
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`thereof, and free fatty
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`thereof, and free fatty
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`acids.
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`acids.
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`acids.
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`9
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`5. The extract
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`28. The formulation
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`51. The nutraceutical
`
`according to claim 1,
`
`according to claim 24,
`
`composition of claim
`
`
`
`
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`47,
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`wherein the extract has
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`wherein the extract has
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`wherein the extract has
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`a concentration of free
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`a concentration of free
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`a concentration of free
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`fatty acids of about 5%
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`fatty acids of about 5%
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`fatty acids of about 5%
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`w/w of the lipids in the
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`w/w of the lipids in the
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`w/w of the lipids in the
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`extract.
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`extract.
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`extract.
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`6. The extract
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`29. The formulation
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`52. The nutraceutical
`
`according to claim 1,
`
`according to claim 24,
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`composition of claim
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`wherein the extract
`
`wherein the extract
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`47, wherein
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`further comprises
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`further comprises
`
`
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`polyunsaturated fatty
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`polyunsaturated fatty
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`polyunsaturated fatty
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`acids which comprise
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`acids which comprise
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`acids comprise at least
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`at least 15% w/w of
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`at least 15% w/w of
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`15% w/w of the lipids
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`the lipids in the
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`the lipids in the
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`in the extract.
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`extract.
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`extract.
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`9. The extract
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`32. The formulation
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`55. The nutraceutical
`
`according to claims 6,
`
`according to claim 29,
`
`composition of claim
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`7, or 8, wherein the
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`30, or 31, wherein the
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`52, 53, or 54, wherein
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`10
`
`
`
`
`
`
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`polyunsaturated fatty
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`polyunsaturated fatty
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`the polyunsaturated
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`acids are omega-3 fatty
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`acids are omega-3 fatty
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`fatty acids are omega-3
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`acids.
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`acids.
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`fatty acids.
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`12. The extract
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`35. The formulation
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`58. The nutraceutical
`
`according to claim 1,
`
`according to claim 24,
`
`composition of claim
`
`
`
`
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`47, wherein the extract
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`further comprising a
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`further comprising a
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`further comprises a
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`metal.
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`metal.
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`metal.
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`13. The extract
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`36. The formulation
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`59. The nutraceutical
`
`according to claim 12,
`
`according to claim 35,
`
`composition of claim
`
`
`
`
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`58,
`
`wherein the metal is
`
`wherein the metal is
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`wherein the metal is
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`zinc, selenium or a
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`zinc, selenium or a
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`zinc, selenium or a
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`mixture thereof.
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`mixture thereof.
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`mixture thereof.
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`19. The extract of
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`42. The formulation of
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`65. The nutraceutical
`
`claim 1,
`
`
`
`claim 24,
`
`composition of claim
`
`
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`47,
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`wherein one of R1 and
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`wherein one of R1 and
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`wherein one of R1 and
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`R2 is EPA and the
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`R2 is EPA and the
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`R2 is EPA and the
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`other is DHA.
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`other is DHA.
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`other is DHA.
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`11
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`
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`
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`20. The extract of
`
`43. The formulation of
`
`66. The nutraceutical
`
`claim 1,
`
`
`
`claim 24,
`
`composition of claim
`
`
`
`47,
`
`wherein R1 and R2 is
`
`wherein R1 and R2 is
`
`wherein R1 and R2 is
`
`EPA.
`
`EPA.
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`EPA.
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`21. The extract of
`
`44. The formulation of
`
`67. The nutraceutical
`
`claim 1,
`
`
`
`claim 24,
`
`composition of claim
`
`
`
`47,
`
`wherein R1 and R2 is
`
`wherein R1 and R2 is
`
`wherein R1 and R2 is
`
`DHA.
`
`DHA.
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`DHA.
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`22. The extract of
`
`45. The formulation of
`
`68. The nutraceutical
`
`claim 1,
`
`
`
`claim 24,
`
`composition of claim
`
`
`
`47, wherein the extract
`
`further comprising an
`
`further comprising an
`
`further comprises an
`
`antioxidant.
`
`antioxidant.
`
`antioxidant.
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`12
`
`
`
`
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`23. The extract of
`
`46. The formulation of
`
`69. The nutraceutical
`
`claim 22,
`
`claim 45,
`
`composition of claim
`
`
`
`
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`68,
`
`wherein the
`
`wherein the
`
`wherein the
`
`antioxidant is selected
`
`antioxidant is selected
`
`antioxidant is selected
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`from the group
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`from the group
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`from the group
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`consisting of vitamin
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`consisting of vitamin
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`consisting of vitamin
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`A, vitamin E,
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`A, vitamin E,
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`A, vitamin E,
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`carotenoid, beta-
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`carotenoid, beta-
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`carotenoid, beta-
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`carotene, astaxanthin,
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`carotene, astaxanthin,
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`carotene, astaxanthin,
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`canthaxanthin,
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`canthaxanthin,
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`canthaxanthin,
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`flavonoids, and
`
`flavonoids, and
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`flavonoids, and
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`mixtures thereof.
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`mixtures thereof.
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`mixtures thereof.
`
`Enzymotec’s IPR includes the identical obviousness and anticipation grounds
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`for the mirror-image claims that are at issue in Aker’s IPR. Enzymotec’s IPR is
`
`supported by the identical prior art and prior art combinations and the identical
`
`expert declarations that Aker relied on in its petition. Enzymotec’s IPR additionally
`
`asserts that claim 48 is also anticipated by Beaudoin I—a ground that the Board did
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`not adopt for mirror-image claims 2 and 25 in Aker’s IPR—but this argument is
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`based on the same evidence already of record in the Aker IPR. The differences in
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`13
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`
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`the preambles of the claims in the Enzymotec and Aker IPRs are minor and do not
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`require citation to anything other than the prior art already at issue in Aker’s IPR.
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`Thus substantive issues in the Aker IPR would not be unduly complicated by joining
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`Enzymotec’s IPR because the joinder does not introduce any new prior art, expert
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`declarations, or grounds of unpatentability. Accordingly, Enzymotec respectfully
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`submits that the Patent Owner would not need substantial time to complete its
`
`Preliminary Patent Owner’s Response, should it choose to file one.2
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`Accordingly Enzymotec believes that joinder would have little, if any,
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`impact on the trial schedule set in Aker’s IPR, and will require substantially no
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`additional time or cost on the Patentee’s part. Given that Aker and Enzymotec will
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`be addressing the same prior art and same bases for rejection using the same
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`experts, Enzymotec envisions virtually no differences in positions. Because the
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`experts are the same, no additional depositions are needed, and Enzymotec is
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`In fact, Neptune’s Patent Owner Preliminary Response to Aker’s IPR
`2
`
`already addressed the claims at issue in Enzymotec’s IPR, because Aker originally
`
`filed its IPR against claims 1-94 of the ’351 patent. (See Petition for Inter Partes
`
`Review, Aker IPR (Oct. 1, 2013); Patent Owner Preliminary Response, Aker IPR
`
`(Jan. 2, 2014).) Aker and Neptune later filed a joint motion to limit the claims at
`
`issue. (Joint Motion to Limit Petition, Aker IPR (Jan. 30, 2014).)
`
`
`
`14
`
`
`
`
`
`willing to have Aker take the lead at depositions, with Enzymotec asking limited,
`
`supplemental questions (if any). Further, Enzymotec will seek to cooperate with
`
`Aker to simplify briefing and discovery whenever possible, and is amenable to
`
`consolidated filings. Conducting the proceedings in this manner should minimize
`
`cost, complication, and delay, and should not unduly affect the Board’s ability to
`
`issue its final determination within the statutorily-defined time limit.
`
`IV. CONCLUSION
`
`For the foregoing reasons, Enzymotec respectfully requests that the Board
`
`institute its Petition for Inter Partes Review of U.S. Patent 8,278,351 (IPR2014-
`
`00586) and join this proceeding with Aker Biomarine AS v. Neptune
`
`Technologies and Bioressources, Inc. (IPR2014-00003). Although it is believed
`
`that no fee is required for this Motion, the Commissioner is authorized to charge
`
`any fees to Deposit Account No. 11-0600.
`
`Dated: April 11, 2014
`
`
`
`
`
`Respectfully submitted,
`/Elizabeth J. Holland/
`Elizabeth J. Holland (Reg. No. 47,657)
`Cynthia Lambert Hardman (Reg. No.
`53,179)
`KENYON & KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel: (212) 425-7200
`Fax: (212) 425-5288
`Counsel for Enzymotec Ltd.
`
`15
`
`
`
`CERTIFICATION OF SERVICE
`
`The undersigned hereby certifies that “MOTION FOR JOINDER UNDER
`
`35 U.S.C. 315(c) AND 37 C.F.R. §§ 42.22 AND 42.122,” was served in its
`
`entirety by Federal Express overnight service, Tracking No. 798522007078, on
`
`this 11th day of April 2014 on the following:
`
`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Avenue,
`NW Suite 700
`Washington, DC 20004
`
`Patent owner’s correspondence
`address of record for U.S. Patent
`8,278,351
`
`Dated: April 11, 2014
`
`/Cynthia Lambert Hardman/
`Elizabeth J. Holland (Reg. No. 47,657)
`Cynthia Lambert Hardman (Reg. No.
`53,179)
`KENYON & KENYON LLP
`One Broadway
`New York, NY 10004
`Tel: (212) 425-7200
`Fax: (212) 425-5288
`
`Counsel for Petitioner Enzymotec Ltd.
`
`16
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