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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` ____________
`
`FORD MOTOR CO., AMERICAN HONDA MOTOR CO. INC., BMW OF
`NORTH AMERICA LLC, AND NISSAN NORTH AMERICA INC.,
`Petitioner
`
`v.
`
`VEHICLE OPERATION TECHNOLOGIES, LLC
`Patent Owner
`
`____________
`
`Case No. IPR2014-00600
`Patent No. 7,145,442
` ____________
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` PETITIONERS’ REPLY BRIEF
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`TABLE OF CONTENTS
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`TABLE OF CONTENTS .................................................................................... i
`UPDATED APPENDIX OF EXHIBITS ......................................................... II
`I. INTRODUCTION ......................................................................................... 1
`II. CLAIM CONSTRUCTION ......................................................................... 2
`A. “GENERATING FROM SAID DATA SIGNAL A COMMAND” (CLAIM 36) ...................... 2
`III. ANTICIPATION AND/OR OBVIOUSNESS OF CHALLENGED
`CLAIMS .............................................................................................................. 5
`A. ISHIKAWA ANTICIPATES AND/OR RENDERS OBVIOUS CLAIMS 36-40 ...................... 6
`B. KROPP ANTICIPATES AND/OR RENDERS OBVIOUS CLAIMS 36-40 ......................... 10
`C. EVANS ANTICIPATES AND/OR RENDERS OBVIOUS CLAIMS 36-40 ......................... 13
`D. KROPP IN VIEW OF ISHIKAWA RENDERS CLAIMS 36-40 OBVIOUS ......................... 14
`E. KROPP IN VIEW OF CROMBEZ RENDERS CLAIMS 36-40 OBVIOUS .......................... 15
`IV. CONCLUSION .......................................................................................... 15
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`UPDATED APPENDIX OF EXHIBITS
`Exhibit 1001 U.S. Patent No. 7,145,442 to Yu Hei Sunny Wai
`Exhibit 1002 Certified Translation of Japanese Application Publication No. H5-
`227369, entitled “Electric Automobile Air-Conditioning Device,” filed
`by Hiroshi Ishikawa, et al. on September 23, 1993 and published on
`March 28, 1995 (“Ishikawa”), which is available as prior art under 35
`U.S.C. §102(b)
`Exhibit 1003 Certified Translation of German Patent Publication No. DE 101 38
`750, entitled “An automobile computer system and method for
`identification and visualization of energy consumption in a vehicle,”
`filed by Michaela Kropp on July 30, 2001 and published on February
`27, 2003 (“Kropp”), which is available as prior art under 35 U.S.C.
`§102(a)
`Exhibit 1004 U.S. Patent No. 6,480,106 to Crombez et al. (“Crombez”) entitled,
`“Rate of Consumption Gauge with Variable Rate of Consumption
`Limits,” filed on May 17, 2001, claiming priority to a provision
`application 60/254,423, filed on Dec, 11, 2000, and issued on
`November 12, 2002 (“Crombez”), which is available as prior art under
`35 U.S.C. §102(e)
`Exhibit 1005 Expert Declaration of Ralph Wilhelm, Jr., Ph.D.
`
`Exhibit 1006 U.S. Patent No. 5,534,759 to Evans et al. (“Evans”) entitled, “Electric
`Vehicle Monitoring System,” filed on May 19, 1995, and issued on
`July 9, 1996 (“Evans”), which is available as prior art under 35 U.S.C.
`§102(b)
`Exhibit 1007 File History of U.S. Patent No. 7,145,442
`Exhibit 1008 Complaint in Vehicle Operation Technologies, LLC v. American Honda
`Motor Co. Inc., Case No. 1:13-cv-00537 (D. Del.)
`Exhibit 1009 Complaint in Vehicle Operation Technologies, LLC v. BMW of North
`America, LLC, Case No. 1:13-cv-00538 (D. Del.)
`Exhibit 1010 Complaint in Vehicle Operation Technologies, LLC v. Ford Motor Company,
`Case No. 1:13-cv-00539 (D. Del.)
`Exhibit 1011 Complaint in Vehicle Operation Technologies, LLC v. Nissan North America
`Inc., Case No. 1:13-cv-00541 (D. Del.)
`Exhibit 1012 Rule 11 Memorandum Opinion (Case 1:13-cv-00539-RGA, D. I. No.
`61)
`Exhibit 1013 Order (Case 1:13-cv-00539-RGA, D. I. No. 62)
`Exhibit 1014 Transcript of September 29, 2014 Teleconference
`Exhibit 1015 Supplemental Expert Declaration of Ralph Wilhelm, Jr., Ph.D.
`Exhibit 1016 Transcript of Deposition of Michael P. Nranian (April 7, 2015)
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` ii
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`I.
`
`INTRODUCTION
`
`
`
`In an attempt to avoid the prior art references in this proceeding, Patent Owner
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`(“PO”) advances and applies an overly narrow construction of the limitation “generating
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`from said data signal a command” to make essentially the same arguments that the Board
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`found unpersuasive in its Institution Decision. Not only does PO’s interpretation lack
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`any basis in the specification, its expert’s opinions regarding the interpretation are
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`nothing more than a nearly verbatim copy and paste of PO’s brief and are wholly
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`unsupported by any intrinsic or extrinsic evidence.1 Further, in relying on a claim
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`limitation directed towards the step of converting data signals into information that can
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`be displayed, PO relies on what the ‘442 patent itself admits “would be obvious to one
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`skilled in the art for such applications.” ‘442 Patent at 13:30-33. Applying the proper
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`constructions – in view of the specification – to the prior art reveals that claims 36-40 are
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`anticipated and rendered obvious as set forth in the Petition and as discussed below.
`
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`1 Importantly, PO’s expert, Mr. Nranian, for purposes of his opinions, applied an
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`incorrect date of invention of August 16, 2000, which is more than three years before
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`the ‘442 patent’s filing date (and earliest priority date) of October 14, 2003. Ex. 2017
`
`at ¶ 23. Mr. Nranian confirmed during his deposition that he did, indeed, apply the
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`August 16, 2000 date. Ex. 1016 at 40:15-44:9.
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`-1-
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`II. CLAIM CONSTRUCTION
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`
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`In the context of an IPR proceeding, claims are to receive the “broadest
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`reasonable construction in light of the specification of the patent in which it appears.”
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`37 C.F.R. § 42.100(b). PO violates this basic tenet of claim construction by ignoring
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`the specification’s description of the Challenged Claims. Specifically, while PO
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`contends that “generating from said data signal a command” should be construed as
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`“generating an instruction for operation of a processor, including a ‘CPU’ or ‘display
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`CPU,’ based on said data signal,” it ignores the prior art that includes this exact
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`teaching in the exact manner as it is described by the ‘442 patent.
`
`A.
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`“generating from said data signal a command” (Claim 36)
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`This is the only claim limitation proposed for construction by PO. The parties
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`agree that this limitation is not discussed in the ‘442 patent other than in the claims.
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`The term “command” was construed by the Board “to embrace instructions
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`(hardware, software, and firmware) and triggers typically associated with the operation
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`of a processor, including a ‘CPU’ and a ‘display CPU.’”2 Inst. Dec. [Paper 19] at 8-9.
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`PO and its expert take issue with the Board’s construction and propose that this
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`2 The Board also construed the “transforming” based on the command “to embrace
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`any kind of processor-based or circuit-based changing of data or signals from one
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`form to another, including from one voltage to another, or otherwise adapting data or
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`signals to be used by another component or system.” Id. at 9.
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`limitation should be construed as “generating an instruction for operation of a
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`processor, including a ‘CPU’ or ‘display CPU,’ based on said data signal.” PO Resp.
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`[Paper 31] at 16. Thus, the only substantive difference is that the Board’s construction
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`expressly includes “(hardware, software, and firmware),” as well as “triggers.”
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`First, PO cannot point to anything in the specification that requires that a
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`“command” be limited to software. Indeed, the ‘442 patent never mentions the term
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`“command” outside of claim 36. See PO Resp. [Paper 31] at 16; Ex. 1005 [Wilhelm
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`Decl.] at ¶32; Ex. 2017 [Nranian Decl.] ¶87. Nor does PO’s expert rely on the
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`specification at all in rendering his construction or in criticizing the Board’s
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`construction as “overly broad.” Ex. 2017 [Nranian Decl.] at ¶¶81-90. Rather, PO’s
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`expert chides the Board for not considering “intrinsic or extrinsic evidence,” but then
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`bases his “construction” on nothing more than conclusory, self-serving statements
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`that are not based on intrinsic or extrinsic evidence. Id. at ¶¶86, 87. In view of this,
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`the best place to determine the meaning of the claims is the claims themselves and the
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`specification.
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`As recognized by the Board, the ‘442 patent only describes one embodiment
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`relating to these claims and it is a very general and broad description. Inst. Dec. at 8.
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`In this embodiment, an input data signal is received by a processing device that
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`processes the data signal according to one or more instructions and provides a display
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`signal to a display based on the processing. Ex. 1001, ‘442 patent at 11:62-12:11; see
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`also Ex. 1005, Wilhelm Decl. at ¶32 (“[T]he ‘442 Patent only describes a data signal
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`being generated by a sensor that is then sent out to and processed by a CPU that
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`generates a display signal.”); Ex. 2017, Nranian Decl. at ¶54 (“Thus, a signal output by
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`any of the power consuming components is processed by the A/D converter (57) and
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`then this information is processed by scalar processing module (72) and the image
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`generation module (81).”). In other words, the instructions for operation of a
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`processor are generated and executed upon receiving a data signal. Therefore, this
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`description, at least, should be within the broadest reasonable interpretation of claim
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`36. See e.g., Johns Hopkins Univ. v. CellPro, Inc., 152 F.3d 1342, 1355 (Fed. Cir. 1998) (“A
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`patent claim should be construed to encompass at least one disclosed embodiment in
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`the written description portion of the patent specification.”). Further, there is no
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`distinction in the ‘442 patent between how those instructions are maintained or
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`generated. Therefore, the Board should maintain its construction and application of
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`that construction to the prior art.
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`In an effort to improperly narrow the scope of this construction, PO and it’s
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`expert assert that there must be a dependency between a “command” and the “data
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`signal” and contend that the Board’s equating a “command” to hardware or firmware
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`instructions is overly broad. PO Resp. at 15-16; Ex. 2017, Nranian Decl. at ¶¶85, 86.
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`However, the Board’s construction clearly requires a dependency between a data
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`signal and the instructions because the instructions (whether contained in the form of
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`hardware, software or firmware) are not generated/invoked unless a data signal is
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`received. Thus, there is clearly a relationship between the two.
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`In addition, there is nothing in the ‘442 patent that would limit the
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`“instructions” to only software. While PO attempts to use the preamble to limit the
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`construction in this manner (see PO Resp. at 15-16, 25-28), there is no basis in the
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`claims or the specification for such a narrow construction. All that is required by
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`claim 36 is a “medium storing instructions” that “if executed” performs the steps of
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`claim 36. There is no doubt that hardware, such as a circuit containing logic to
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`implement various instructions or a circuit programmed in a specific manner, is a
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`“medium storing instructions” that if executed can perform various functions and
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`steps, including those required by claim 36. Ex. 1015, Wilhelm Suppl. Decl. at ¶4.
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`Because the Board’s construction is consistent with the scope of the only
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`described embodiment,
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`it
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`is presumptively within
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`the broadest reasonable
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`interpretation of the claim. And as demonstrated below, application of either the
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`Board’s construction and even PO’s construction to the prior art renders the
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`Challenged Claims anticipated and obvious.
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`III. ANTICIPATION AND OBVIOUSNESS OF CHALLENGED CLAIMS
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`At the outset, Petitioners note that PO has not presented any evidence or
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`reasoning to uphold the validity of any of the Challenged Claims if the Board’s
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`construction is maintained. Rather, all of PO’s arguments are based on a different
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`-5-
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`construction of “generating from said data signal a command” than the Board
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`adopted. Therefore, to the extent that the Board does not substantively alter its
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`construction, claims 36-40 should be canceled. In the event that the Board alters its
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`construction or considers PO’s arguments relevant in any respect to its own
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`construction, Petitioners submit the following.
`
`A.
`
`Ishikawa anticipates and renders obvious claims 36-40
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`There is no disagreement that Ishikawa discloses that “[a] program for
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`calculating the power consumption is installed in the air conditioner ECU.” PO Resp.
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`at 21 (citing Ex. 1002, Ishikawa at ¶0016). In view of either PO’s or the Board’s claim
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`construction, there is little doubt that the ECU and its associated “program” are
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`sufficient to anticipate claim 36’s requirement of “generating from said data signal a
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`command,” in addition to the other limitations. See Corr. Pet. at 8-23.
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`PO, however, contends that Ishikawa does not disclose that a “command be
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`generated from the data signal” or “what the generated command is … or how a
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`command is utilized in conjunction with the data signal to generate the display
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`information.” PO Resp. at 27-28. However, it is clear that Ishikawa discloses that its
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`“program for calculating power consumption” (i.e., medium storing instructions) is
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`executed if the ECU receives data signals from the air conditioner inverter. Ex. 1002,
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`Ishikawa at ¶¶0015, 0016. If the signals are received, the instructions in the program of
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`the ECU are invoked to perform the steps of calculating the power consumption
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`based on the data signals and displaying the power consumption based on the
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`operation of those instructions. Id. at ¶0016.
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`PO additionally contends that Ishikawa does not disclose a “medium storing
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`instructions,” as
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`recited
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`in
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`the preamble, because
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`it also describes a
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`“calculation/controlling circuit.” PO Resp. at 25-26. This is a misunderstanding of
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`claim 36 and Ishikawa. For example, even if Ishikawa’s ECU were limited to a
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`“circuit,” there is no doubt that such a circuit can be programmed to include
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`instructions that perform a desired function, including the steps recited in Ishikawa
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`and claim 36. See Ex. 1015, Wilhelm Suppl. Decl. at ¶6; see also Ex. 2017, Nranian Decl. at
`
`¶99. Thus, such a “circuit” would undoubtedly constitute a “medium storing
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`instructions” – nothing more is required by the preamble.
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`PO would additionally have the Board believe that the air conditioner ECU is
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`just a “circuit” solely dedicated to calculating power consumption. PO Resp. at 28
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`(“there is no disclosure that the ECU is anything more than a dedicated task device”).
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`Regardless of whether this inquiry is even relevant to applying Ishikawa to the claims,3
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`it is a gross mischaracterization. For example, the air conditioner ECU performs
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`3 Under PO’s same logic, the “display CPU” and “vehicle CPU” in the ‘442 Patent
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`could, of course, similarly be characterized as dedicated to their respective tasks of
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`controlling a display and controlling vehicle functions.
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`numerous other functions, including controlling the electric compressor for the air
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`conditioning system. Id. at ¶0015. A person of ordinary skill in the art would also
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`understand from Figure 1 that the air conditioner ECU also controls numerous other
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`components of the air conditioning system, including the blower motor 132, the
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`various dampers (141, 142, 143, 131, 154), etc. Id. at Fig. 1; Ex. 1015, Wilhelm Suppl.
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`Decl. at ¶16. Thus, the ECU is not only dedicated to displaying information, but also
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`controlling vehicle components.
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`Even under Patent Owner’s narrowing construction and its argument that “an
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`instruction based processor” is required, this requirement is met because Ishikawa’s
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`ECU 300 would be understood by a person of ordinary skill in the art to have a
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`microprocessor with instructions stored thereon. Ex. 1015, Wilhelm Suppl. Decl. at ¶¶7-
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`15. Patent Owner’s Response argues that “one of ordinary skill in the art would know
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`that the ECU [300] is not an instruction based processor,” and cites to its expert, Mr.
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`Nranian. PO Resp. at 27 (citing Ex. 2017 at ¶ 99). But Mr. Nranian never asserts in
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`his declaration that ECU 300 is not an instruction based processor or that a person of
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`ordinary skill in the art would not understand it as such. See Ex. 2017 at ¶ 99. Instead,
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`Mr. Nranian merely implies that he believes there is at least some theoretical
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`possibility that it might not be by suggesting that a Field Programmable Gate Array
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`(FPGA) might be used and might not be an instruction based processing circuit. Id.
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`Notably, Mr. Nranian never actually opines that he believes ECU 300 is an FPGA or
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`that a person of ordinary skill in the art would understand it to be. Id. Nor does he
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`provide any reasoning suggesting that a person of ordinary skill in the art would
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`understand from Ishikawa’s disclosure that ECU 300 is an FPGA. Id. He does not
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`make such assertions, because it is inconceivable that a person of ordinary skill in the
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`art would have understood Ishikawa, which was filed in 1993, to have been teaching
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`that ECU 300 is an FPGA. Ex. 1015, Wilhelm Suppl. Decl. at ¶¶8-14. Indeed, non-
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`microprocessor FPGA circuits were not being used for automotive ECUs in 1993,
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`they were not even introduced in automotive applications until the late 1990s or early
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`2000s and they are really not used even today by the industry. Id. at ¶¶10, 11. As
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`explained by Dr. Wilhelm in great detail, a person of ordinary skill in the art would
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`have had no doubt from Ishikawa’s disclosure and the context of the automotive
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`industry in 1993 that ECU 300 uses a microprocessor and would not have understood
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`it to be using an FPGA. Id. at ¶¶7-15. Claims 36-40, therefore, are anticipated by
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`Ishikawa.
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`Finally, even if one were to assume that some distinction can be drawn between
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`Ishikawa’s ECU 300 and an “instruction based processor of a CPU type” (assuming
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`such is, indeed required), then such a modification (i.e., using a traditional
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`microprocessor) would have been exceedingly obvious to a person of ordinary skill in
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`the art. Ex. 1015, Wilhelm Suppl. Decl. at ¶¶17-18; Ex. 1005 at ¶59. Indeed, the ‘442
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`patent itself admits that it was not intending to introduce new technology used for
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`turning data signals into displayable information. Instead, it used “existing
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`technologies for the display of information regarding the performance of a vehicle to
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`the operator” (3:16-19), which were “old” (3:30-33). Ex. 1001. And the “algorithms
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`needed to convert given signals to meaningful display quantities” were “obvious to
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`one skilled in the art for such applications.” (13:30-33). Claims 36-40, therefore, are
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`also obvious over Ishikawa alone.
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`In view of the foregoing, claims 36-40 should be canceled.
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`B.
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`Kropp anticipates and renders obvious claims 36-40
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`PO does not dispute that Kropp discloses an instruction-based processing
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`device. (See Ex. 1028, Nranian Dep. Tr. at 133:17-23). Rather, PO manufactures the
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`argument that because the energy capture device of Kropp “continuously” captures
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`supplied energy of the consumers “[t]here is no command or any instruction disclosed
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`that is ‘generated’ ‘from’ such pulled data.” PO Resp. at 34. This and the other
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`arguments presented by PO and its expert, under their construction, are contrived and
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`highly flawed for a number of reasons.
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`First, Kropp clearly describes receiving data, performing one or more
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`calculations based on the received data according to instructions contained in a
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`program and displaying the result of the calculations on a screen. Ex. 1003, Kropp at
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`¶0036. Specifically, Kropp teaches that an energy capturing device collects and passes
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`consumers’ supplied energy on to the “assessment device” of a computer, which also
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`includes a microprocessor and other standard PC components. Ex. 1003, Kropp at
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`¶¶0036, 0025. The assessment device of the computer calculates the power use of the
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`consumer, which is then converted to “equivalent fuel use.” Id. This data is then
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`presented on a screen only if a user has chosen for this information to be displayed.
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`Id. Thus, no calculations and conversions are performed and no display occurs unless
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`the computer receives one or more data signals from the consumers. Therefore,
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`execution of the calculations in the computer, via its associated microprocessor, are
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`dependent on receiving one or more signals from the individual consumers.
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`Moreover, the calculation performed by the computer is dependent on what
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`signals are received. For example, depending on the function selected, the computer
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`may receive different data signals—if the user selects the “range function,” then it will
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`receive signals from sensors 22 and 24 in addition to data received from the individual
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`consumers 41-44. Id. at ¶0038. In this case, the computer must generate an instruction
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`to perform a calculation different than if only data from the individual consumers
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`were received as a different output is displayed (e.g., fuel consumption of consumer
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`versus range gained if consumer is turned off). Id. at Figs. 2, 3.
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`Second, and of questionable relevance to the present analysis, the computer of
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`Kropp is not a single-task device. See Ex. 2017, Nranian Decl. at ¶104. For example, in
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`addition to performing the various power consumption and range calculations
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`described above, the computer of Kropp also controls various components in a
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`vehicle such as a navigation system and an internet communication system. Ex. 1003,
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`Kropp at ¶¶0028, 0029. For example, the computer can also determine the closest
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`service station based on the calculations or automatically turn individual consumers
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`off. Id. at ¶¶0041, 0042. Indeed, the computer is the “heart” of the vehicle computer
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`system. Id. at ¶0025. Because the computer of Kropp is performing numerous
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`functions based on different types of received data, the signals must be generating an
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`instruction for operation of the microprocessor to perform the required calculations
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`according to a program and generating display data from that in a selected format. In
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`other words, the signals are generating a command to perform a specific calculation
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`and this is occurring sequentially upon receipt of new data. Ex. 1015, Wilhelm Suppl.
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`Decl. at ¶¶20-21.
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`Finally, PO’s argument regarding Kropp “continuously” capturing/pulling data
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`and “continuously” calculating power consumption is purely subjective, because it
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`begs the question of how infrequent these processes must be to satisfy PO’s self-
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`serving construction of the “generating” and “transforming” limitations. As PO
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`acknowledges and a person of ordinary skill would understand, data must be
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`“sampl[ed]” discretely, and thus the collecting of the data and the calculation of power
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`consumption is occurring at discrete intervals, not truly “continuously.” Ex. 1015,
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`Wilhelm Suppl. Decl. at ¶¶20-21. PO apparently contends the time intervals are too
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`small. But the ‘442 patent and claims impose no requirement as to how slowly or how
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`quickly these steps must be performed. Therefore, Kropp anticipates claims 36-40.
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`Further, even if one were to assume that PO’s “continuously” argument somehow
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`distinguishes Kropp from the claimed “generating” limitation, a person of ordinary
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`skill in the art would have nonetheless readily bridged any such gap, and it would,
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`therefore have been obvious. Id. at ¶22. In view of the foregoing, claims 36-40 should
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`be canceled.
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`C.
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`Evans anticipates and renders obvious claims 36-40
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`PO again relies on its faulty interpretation of “generating … a command” and
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`“transforming … based on the command.” PO Resp. at 42. And similar to Kropp,
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`PO’s primary complaint is that Evans “merely collects” and “stores and reports the
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`data[.]” Id. As discussed in detail above, the proper construction of the claims do not
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`require anything more than receiving data signals, processing the data signals
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`according to instructions and transforming the data signals into a display signal based
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`on the instructions. Somewhat incredulously, in the discussion of Evans, PO and its
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`expert both acknowledge that “[a]ll that is illustrated in Evans is a processor for
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`collecting data, i.e., sensing data, and processing it in accordance with a sequence of
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`instructions, which sequence of instructions are executed in accordance with the
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`program that is running on the microprocessor.” PO Resp. at 43; same Ex. 2017,
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`Nranian Decl. at ¶107. But this teaching clearly anticipates any construction,
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`including PO’s construction, of “generating from a data signal a command.” It is
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`unclear as to what more PO and its expert believe is required or what would ever be
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`within the scope of the claims in their view. With respect to the sequence of
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`instructions that are executed in accordance with the program running on the
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`microprocessor, PO argues that the instructions “are defined by the program and are
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`not defined or generated by data signals.” PO Resp. at 55. If PO is contending that
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`the microprocessor must be creating brand new instructions on its own (i.e., re-coding
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`itself) as opposed to executing instructions based on the received data, then PO’s
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`argument is utterly incredible. The ‘442 patent speaks nothing of artificial intelligence
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`or machine learning and it would be utterly unreasonable to construe the claim
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`language in such a manner. Evans discloses a processor that receives data that is
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`processed according to instructions contained in a program running on the
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`microprocessor, which is the same way that these steps are described in the ‘442
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`specification. As further set forth in the Petition, claims 36-40 are anticipated and
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`rendered obvious by Evans. See Corr. Pet. at 35-41.
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`D. Kropp in view of Ishikawa renders claims 36-40 obvious
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`PO does not identify any rationale for its argument with respect to this
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`combination other than to rely on its previous arguments as to the references
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`individually. Thus, to the extent Ishikawa or Kropp do not anticipate claims 36-40
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`alone, the combination of the two references cures any deficiency as set forth in the
`
`Petition. Corr. Pet. [Paper 5] at 48-51.
`
`-14-
`
`

`

`E.
`
`Kropp in view of Crombez renders claims 36-40 obvious
`
`
`
`PO does not identify any rationale for its argument with respect to this
`
`combination other than to rely on its previous arguments as to the references
`
`individually. Thus, to the extent Kropp does not anticipate claims 36-40 alone, the
`
`combination of Kropp in view of Crombez cures any deficiency as set forth in the
`
`Petition. Corr. Pet. [Paper 5] at 51-57.
`
`IV. CONCLUSION
`
`For the forgoing reasons, Petitioners respectfully submit that claims 36-40 be
`
`canceled.
`
`
`
`
`
`April 23, 2015
`
`
`
`Lionel M. Lavenue
`Reg. No. 46,859
`
`Respectfully submitted,
`
`By: /s/Eric A. Buresh
`
`Eric A. Buresh
`Reg. No. 50,394
`Jason R. Mudd
`Reg. No. 57,700
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`Telephone: (913) 777-5600
`Facsimile: (913) 777-5601
`eric.buresh@eriseip.com
`jason.mudd@eriseip.com
`
`Counsel for Petitioner Ford Motor Company
`
`Joshua L. Goldberg
`Reg. No. 59,369
`-15-
`
`

`

`FINNEGAN, HENDERSON,
`FARABOW, GARRETT &
`DUNNER, LLP
`11955 Freedom Drive
`Reston, VA 20190
`Telephone: (571) 203-2750
`Facsimile: (202) 408-4400
`lionel.lavenue@finnegan.com
`
`Counsel for Petitioner BMW of North
`America, LLC
`
`
`
`
`
`
`
`
`
`FINNEGAN, HENDERSON,
`FARABOW, GARRETT & DUNNER,
`LLP
`901 New York Avenue, NW
`Washington, DC 20001
`Telephone: (202) 408-6092
`Facsimile: (202) 408-4400
`joshua.goldberg@finnegan.com
`
`Counsel for Petitioner BMW of North America,
`LLC
`
`
`
`-16-
`
`

`

`CERTIFICATE OF SERVICE
`
`
`
`The undersigned certifies that a copy of the attached PETITIONER’S REPLY
`
`was sent via electronic mail on April 23, 2015, to the following:
`
`Greg Howison
`Registration No. 30,646
`HOWISON & ARNOTT
`5420 LBJ Freeway, Suite 660
`Dallas, Texas 75240
`GHowison@dalpat.com
`
`James Arnott
`Reg. No. 70,458
`BUETHER JOE & CARPENTER, LLC
`1700 Pacific Avenue, Suite 4750
`Dallas, Texas 75201
`BJC-VOT@BJCIPLaw.com
`
`
`
`
`Date: April 23, 2015
`
`
`By:
`
`
`
`
`
`/s/ Eric A. Buresh
`Eric A. Buresh
`Reg. No. 50,394
`Jason R. Mudd
`Reg. No. 57,700
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`Telephone: (913) 777-5600
`Facsimile: (913) 777-5601
`
`Counsel for Petitioner Ford Motor Company
`
`
`
`
`
`