Filed on behalf of UUSI, LLC
`
`By: Monte L. Falcoff (mlfalcofnghdpeomI
`Hemant M. Keskar (hkeskarthdpeomI
`HARNESS, DICKEY & PIERCE, P.L.C.
`
`5445 Corporate Drive, Ste. 200
`Troy, MI 48098
`Telephone: (248) 641—1600
`Facsimile: (248) 641—0270
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`WEBASTO ROOF SYSTEMS, INC.
`Petitioner
`
`V.
`
`UUSI, LLC
`Patent Owner
`
`Case IPR2014—00650
`
`Patent 7,579,802
`
`PATENT OWNER’S RESPONSE TO PETITIONER’S MOTION FOR
`
`JOINDER
`
`
`
`
`
`
`By: Monte L. Falcoff (mlfalcofnghdpeomI
`Hemant M. Keskar (hkeskarthdpeomI
`HARNESS, DICKEY & PIERCE, P.L.C.
`
`5445 Corporate Drive, Ste. 200
`Troy, MI 48098
`Telephone: (248) 641—1600
`Facsimile: (248) 641—0270
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`WEBASTO ROOF SYSTEMS, INC.
`Petitioner
`
`V.
`
`UUSI, LLC
`Patent Owner
`
`Case IPR2014—00650
`
`Patent 7,579,802
`
`PATENT OWNER’S RESPONSE TO PETITIONER’S MOTION FOR
`
`JOINDER
`
`
`
`
`
`
`Case IPR2014-00650
`
`Patent 7,579,802
`
`I.
`
`INTRODUCTION ................................................................... 3
`
`II.
`
`PARTIAL JOINDER ACCEPTABLE
`
`IF CERTAIN CONDITIONS ARE IMPOSED TO REDUCE HARM .............. 4
`
`III.
`
`REASONS FOR DENYING JOINDER
`
`ABSENT UUSl’S PROPOSED CONDITIONS ...................................... 5
`
`1.
`
`WEBASTO’S GROUND A AND
`
`BROSE’S GROUND 5 ARE NOT “THE SAME” ........ 5
`
`2.
`
`WEBASTO SEEKS TO ADD
`
`DIFFERENT CLAIMS TO BROSE IPR .................... 7
`
`3.
`
`WEBASTO SEEKS TO ADD
`
`NEW GROUND TO BROSE IPR ......................... 1O
`
`4.
`
`JOINDER WILL NOT CREATE EFFICIENCIES
`
`AND WILL PREJUDICE UUSI ............................ 11
`
`5.
`
`WEBASTO’S DELAY TACTICS
`
`SHOULD NOT BE REWARDED .......................... 13
`
`6.
`
`DENYING JOINDER
`
`WILL NOT HARM WEBASTO ............................. 14
`
`IV.
`
`UUSI RECOMMENDS SETTING A COMMON DATE
`
`FOR ORAL ARGUMENTS ............................................................. 14
`
`V.
`
`CONCLUSION ................................................................... 15
`
`Page 2 Of 17
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`Case IPR2014-00650
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`Patent 7,579,802
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`I.
`
`INTRODUCTION
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`Petitioner Webasto Roof Systems, Inc. (“Webasto”) seeks to join Ground A
`
`of its IPR2014-0065O (“Webasto IPR”), which alleges that Claims 1, 6—9, and 15-
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`16 of US. Patent No. 7,579,802 (“the ’802 patent”) are obvious over Itoh and
`
`Kinzl, with Ground 5 of IPR2014-004l7 filed by Brose et al. (“Brose IPR”), which
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`alleges that the Claims 1, 6—9, and 14 are obvious over Itoh, Kinzl, and ordinary
`
`skill in the art. Webasto IPR, Paper 11 at 2. In addition to requesting joinder of
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`different Claims 15 and 16, Webasto also requests adding Ground B of its IPR,
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`which alleges that Claim 11 is obvious over Itoh, Kinzl, and Jones, as a different
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`ground including different prior art to the Brose IPR. Id.
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`Patent Owner UUSI, LLC (“UUSI”) will agree to Webasto’s proposed
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`joinderM if the Patent Trial and Appeal Board (“Board”) orders UUSI’s
`
`proposed conditions as set forth below, which will create efficiencies with minimal
`
`harm to all parties and the Board. If the Board does not order UUSI’s conditions
`
`then UUSI opposes joinder since, without these conditions, joinder will not reduce
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`the burden on the Board and UUSI, and will harm UUSI. If the Board does not
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`order UUSI’s conditions then, in lieu ofjoinder, UUSI requests the Board to set a
`
`common date for oral arguments for the Brose IPR and, if instituted, the Webasto
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`IPR for the ‘802 patent in addition to Brose IPR2014—004l6 and Webasto
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`IPR2014-00648, if instituted, for US. Patent No. 8,217,612 (“the ’612 patent”).
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`Page 3 of 17
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`Patent 7,579,802
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`II.
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`PARTIAL JOINDER ACCEPTABLE IF CERTAIN CONDITIONS ARE
`
`IMPOSED To REDUCE HARM
`
`UUSI opposes adding Webasto’s Ground B to the Brose IPR because this
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`ground involves a totally different claim, Claim 11, and a different prior art
`
`reference, Jones, that are not asserted in the Brose IPR. UUSI, however, will agree
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`to joinder of Webasto’s Ground A with Brose’s Ground 5 if the Board orders the
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`following procedural conditions:
`
`(1) Both petitioners must speak with a “single voice” for Claims 1 and 6—9 of
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`Brose’s Ground 5 and Webasto’s Ground A throughout all of the IPR proceedings
`
`including depositions, reply briefs, and the oral arguments. In other words, Brose
`
`will take the lead, and Webasto cannot file any supplemental briefs, ask deposition
`
`questions, or the like for Claims 1 and 6—9 of this proposed Ground A.
`
`(2) Webasto’s expert’s Declaration must be stricken and ignored with regard
`
`to Claims 1 and 6—9 of Webasto’s Ground A and the facts and conclusions
`
`regarding the combination of the Itoh and Kinzl references discussed therein.
`
`Furthermore, if Webasto’s expert testifies during his deposition on the combination
`
`of the Itoh and Kinzl references (such as when it additionally combines the Jones
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`reference for Claim ll) then such testimony cannot be used in support of Claims 1
`
`and 6-9 of Brose’s Ground 5 or Webasto’s Ground A.
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`Page 4 of 17
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`Patent 7,579,802
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`(3) No evidence Of ordinary skill in the art or the like presented in or
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`attached to the IPR Petition or expert’s Declaration solely filed by Webasto can be
`
`used in support of Claims 1 and 6—9 of Brose’s Ground 5 and Webasto’s Ground
`
`A. This causes these proposed grounds to be identical and not alternate in nature.
`
`(4) The proposed claim constructions asserted by Webasto regarding Claims
`
`1 and 6—9 be ignored such that only the Brose ones shall be proffered on behalf of
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`both Petitioners (without UUSI admitting to the correctness or incorrectness of
`
`either of these claim constructions at this time).
`
`If the Board orders the preceding conditions then UUSI agrees to the partial
`
`joinder of Webasto’s Ground A with Brose’s Ground 5. If the preceding conditions
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`are not ordered then UUSI opposes the joinder in its entirety for the following
`
`reasons since UUSI will be disadvantageously harmed.
`
`III.
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`REASONS FOR DENYING JOINDER ABSENT UUSI’S PROPOSED
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`CONDITIONS
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`1. WEBASTo’S GROUND A AND BROSE’S GROUND 5 ARE NOT
`
`“THE SAME”
`
`Citing IPR2013-00629 (“Smith IPR”), Webasto contends that its and
`
`Brose’s invalidation positions for Claims 1 and 6—9, which are common in these
`
`grounds, are “the same” and therefore these grounds should be joined. Webasto
`
`IPR, Paper 11 at 7. Webasto’s contention, however, is meritless because the facts
`
`of the Smith IPR are inapposite, and the grounds Webasto seeks to join are not “the
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`Page 5 of 17
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`Patent 7,579,802
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`same.” Specifically, Webasto’s reliance on the Smith IPR is misplaced because all
`
`parties in the Smith IPR including the Patent Owner jointly moved to join a later-
`
`filed IPR with the earlier—filed Smith IPR since the grounds sought to be joined in
`
`the two IPRs were identical. Further, all parties agreed to a single deposition of
`
`Patent Owner’s expert, agreed to maintain the schedule of the earlier—filed Smith
`
`IPR, and agreed to terminate the later—filed IPR. Smith IPR, Paper 18 at 2—5.
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`In contrast, the parties in the Webasto and Brose lPRs have neither moved
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`jointly for joinder nor reached any agreements similar to those reached in Smith
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`IPR. Indeed, UUSI opposes joinder absent the UUSI-proposed conditions. Further,
`
`the parties have not yet agreed to maintain the schedule of the earlier-filed Brose
`
`IPR. Therefore, the Smith IPR does not support Webasto’s proposition for joinder,
`
`and Webasto’s motion for joinder should be denied.
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`Additionally, the grounds sought to be joined here are facially not “the
`
`same” because the claims in these grounds are not the same: the Brose IPR does
`
`not challenge Claims 15 and 16 that are challenged in Webasto IPR, and the
`
`Webasto IPR does not challenge Claim 14 that is challenged in the Brose IPR.
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`Accordingly, joining these grounds will in fact add different Claims 15 and 16 to
`
`the Brose IPR.
`
`Moreover, although Claims 1 and 6—9 are common in these grounds, Brose
`
`and Webasto’s invalidity positions for these claims in these grounds are not “the
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`Page 6 of 17
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`Patent 7,579,802
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`same.” Specifically, Brose’s Ground 5 alleges obviousness over Itoh, Kinzl, and
`
`ordinary skill in the art as interpreted by Brose’s expert MacCarley. Brose IPR,
`
`Paper 6 at 49. Further, Brose’s Ground 5 relies on its Ground 1, which alleges
`
`obviousness over Itoh and ordinary skill in the art as interpreted by Brose’s expert
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`MacCarley. Id. at 49—56 and 28—29. In contrast, Webasto’s Ground A alleges
`
`obviousness over only Itoh and Kinzl and does not rely on ordinary skill in the art.
`
`
`Thus UUSI Will be burdened With the need to take the deposition of Webasto’s
`
`expert on its different Ground A. Furthermore, Webasto desires to submit a
`
`supplemental reply brie_f,_exgrt testimony, and oral a_rguments on their differences.
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`Therefore, these grounds are not “the same” even with respect to the common
`
`claims 1 and 6—9 and should not be joined.
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`2.
`
`WEBASTO SEEKS TO ADD DIFFERENT CLAIMS To BROSE IPR
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`As mentioned above, since Brose IPR does not challenge Claims 15 and 16,
`
`joining Webasto’s Ground A challenging Claims 15 and 16 With Brose’s Ground 5
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`will in fact add different Claims 15 and 16 to Brose IPR. Webasto advances several
`
`arguments to support these additions. Each argument fails as follows.
`
`i.
`
`Webasto ’s reliance on Enzymotec [PR is misplaced
`
`First, Webasto relies on 1PR2014-005 56 (“Enzymotec IPR”) to propose
`
`joinder of Claims 15 —16 because the prior art in its Ground A is allegedly the same
`
`as that in Brose’s Ground 5. Webasto IPR, Paper 11 at 7. Webasto’s reliance on
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`Page 7 of 17
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`Patent 7,579,802
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`Enzymotec IPR is misplaced because the Board granted joinder in Enzymotec IPR
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`for entirely different reasons that are not present in the Webasto and Brose IPRs:
`
`petitioners stipulated cooperation and agreed to use the same experts; petitioner
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`Aker of the earlier—filed IPR agreed to lead the joined proceedings; and petitioner
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`Enzymotec would have been prejudiced without joinder since its IPR was time
`
`barred. Enzymotec IPR, Paper 19 at 2, 3, and 5. Here, Webasto and Brose have not
`
`stipulated to anything. Nor has Brose indicated that it will lead the joined
`
`proceedings for these additional claims. Nor will Webasto be prejudiced without
`
`joinder since its IPR petition is timely. Therefore, Webasto’s reliance on
`
`Enzymotec IPR is misplaced.
`
`In contrast, see IPR2013-003 86 (“Network—1 IPR”), where the Board denied
`
`joinder since joinder would have added new claims and new expert’s declaration
`
`and deposition, and would have raised new unpatentability analysis and substantive
`
`issues. Network—1 IPR, Paper 16 at 2 and 7. As in the Network-1 IPR, adding
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`different Claims 15 and 16 currently not before the Board in the Brose IPR, which
`
`already includes a pile of seven grounds, is tantamount to adding a new ground,
`
`and will in fact raise new unpatentability analysis and substantive issues. Further,
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`Webasto has clarified that ifjoinder is permitted, its expert “Dr. Toliat would []
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`address the additional grounds raised by WRSI’S petition with respect to claim[s]
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`15 and 16.” Webasto IPR, Paper 11 at 12.
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`Page 8 of 17
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`Patent 7,579,802
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`ii.
`
`Claim 15 is not similar to Claim 7
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`Second, Webasto argues that joinder of Claims 15 and 16 is appropriate
`
`because its “arguments” against Claim 15 are similar to its arguments against
`
`Claim 7, which is also challenged in the Brose IPR. Id. at 8. This argument is
`
`irrelevant since Claim 15 is admittedly not the same as Claim 7 (Id. at 8), and what
`
`matters is whether Webasto’s arguments against Claim 15 are similar to Brose’s
`
`arguments against Claim 7, which they are not. Additionally, they are unlikely to
`
`be the same since Webasto wants to use its expert to address issues regarding
`
`Claim 15 while Brose’s expert will address issues regarding claim 7. Id. at 12.
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`Indeed, Webasto’s apparent argument that the differences between Claims 15 and
`
`7 are insignificant enough to permit joinder is inconsistent with its intent to use its
`
`expert’s opinion for Claim 15, which implies that the differences are significant
`
`enough to require separate expert opinion. Webasto can’t have it both ways.
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`iii.
`
`UUSI will address Claims 15 and 16 in its Response
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`Third, Webasto argues that UUSI “raised no arguments specific to Claims
`
`15 or 16” in the Preliminary Response and therefore “there is no reason to expect
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`that Claims 15—16 will present any significant new issues.” Id. at 8. UUSI is not
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`aware of any rules that bar it from presenting new arguments in its Response
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`simply because it did not do so in its Preliminary Response, which is optimal and
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`not intended to include all argument and evidence of the Patent Owner.
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`Page 9 of 17
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`3. WEBASTO SEEKS TO ADD NEW GROUND To BROSE IPR
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`Furthermore, since Brose IPR does not challenge Claim ll, adding Webasto
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`IPRs Ground B alleging invalidity of Claim 11 over different prior art to Brose IPR
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`will in fact add new prior art (Jones) and a new ground to a plethora of invalidity
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`grounds already pending in the Brose IPR, which fithher militates against joinder
`
`in light of the Board’s holding in the Network-l IPR. Since joinder would add a
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`different claim (Claim 11), a different ground (Ground B), different prior art
`
`(Jones), and different expert testimony (Webasto’s expert’s opinion on Claim 11),
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`the Board should deny joinder as it did for similar reasons in the Network—l IPR.
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`Nonetheless, to support joinder of Claim 11, Webasto relies on IPR2014—
`
`00541 (“Wintek IPR”), which involved partially overlapping prior art in
`
`proceedings sought to be joined. Id. at 8. Webasto’s reliance on the Wintek IPR is
`
`misplaced since the Board granted joinder in the Wintek IPR for entirely different
`
`reasons that are not present in the Webasto and Brose IPRs: each IPR involved the
`
`same parties; Patent Owner TPK did not oppose joinder; and the parties jointly
`
`requested revised scheduling and agreed to follow the scheduling set forth in the
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`earlier-filed IPR. Wintek IPR, Paper 14 at 2 and 3. Here, Webasto and Brose are
`
`different parties; UUSI opposes joinder; and the parties have not yet agreed to
`
`follow any jointly revised scheduling. Therefore, joinder should be denied.
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`Page 10 of 17
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`4.
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`JOINDER WILL NOT CREATE EFFICIENCIES AND WILL
`
`PREJUDICE UUSI
`
`i.
`
`Joined claims must be reanalyzed in Webasto ’s grounds C—E
`
`Webasto argues that joinder of these grounds Will be “more efficient and
`
`economical.” Webasto IPR, Paper ll at 9. Since Webasto’s Grounds C—E also
`
`involve Claims 11, 15 , and 16 sought to be joined here, joining Grounds A and B
`
`including these claims with the Brose IPR Will not relieve the Board from
`
`determining validity of these claims again in the Webasto IPR. Instead, the Board
`
`Will be best able to adjudicate the validity of these claims in all of the alleged
`
`grounds in a single lPR, namely the Webasto IPR, instead of splitting the
`
`adjudication into two IPRs via joinder.
`
`ii.
`
`Joinder will increase the burden on the Board
`
`lfjoinder is granted, the Board Will be burdened with construing the joined
`
`claims in the Brose IPR, in addition to construing numerous other claims in the
`
`seven grounds already pending in the Brose IPR. Also, analyzing the additional
`
`Jones reference will further increase the Board’s burden.
`
`iii.
`
`Joinder will require the Board to deal with two experts in Brose [PR
`
`The board’s already burdensome task of analyzing seven grounds in Brose
`
`IPR will be further complicated by the fact that Webasto wants to use its expert’s
`
`opinion on issues regarding Claims 11, 15, and 16 ifjoined. Id. at 12. While
`
`Webasto offers to Withdraw portions of its expert’s declaration on grounds
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`Page 11 ofl7
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`addressed by Brose’s expert, Webasto’s concession is not meaningful and will not
`
`create efficiencies for the Board and UUSI because the Board and UUSI will still
`
`be burdened with evaluating Webasto’s expert’s opinions rendered in Webasto’s
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`grounds C-E involving the same claims and the same prior art. UUSI will still have
`
`to depose Webasto’s expert to address these grounds, which will revive those
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`portions of the expert’s declaration that Webasto offers to withdraw, and the Board
`
`will similarly have to consider those portions of the deposition and declaration
`
`again in Webasto IPR. Accordingly, Webasto’s offer will not alleviate these
`
`burdens that will be incident on the Board and UUSI, and joinder will not create
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`efficiencies for the Board and UUSI.
`
`iv.
`
`Joinder will prejudice UUS]
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`Ifjoinder is granted, Webasto suggests that there is “ample room” (12
`
`weeks) in the Brose IPR schedule to move back initial deadlines. Id. at 8. If,
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`however, the Board denies joinder, institutes the Webasto IPR, and issues a
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`schedule for Webasto IPR, since Webasto’s IPR was filed 16 weeks after Brose’s,
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`UUSI will get an additional four weeks’ time to properly defend Webasto’s assault
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`on its patent. Accordingly, granting joinder and moving back deadlines in Brose
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`IPR will not reduce harm to UUSI, particularly since UUSI will have to deal with
`
`two experts in the Brose IPR, and joinder should therefore be denied.
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`Page 12 of 17
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`Additionally, since Brose intends to file supplemental information related to
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`the alleged claim construction issues in its IPR, UUSI reasonably believes that
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`joinder will further increase the burden on the Board and prejudice to UUSI if the
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`alleged claim construction issues inevitably spill over and taint the analysis of the
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`joined claims. Joinder should therefore be denied.
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`5. WEBASTO’S DELAY TACTICS SHOULD NOT BE REWARDED
`
`Webasto had nearly 10 months after being sued on April 16, 2013 and
`
`before Brose filed its IPR on February 7, 2014 within which to consider whether to
`
`join the Brose IPR. Both Petitioners had acted in concert on many procedural
`
`matters during the lawsuits and therefore presumably knew that they both intended
`
`to file the present IPRs. But Webasto apparently made a tactical decision to wait on
`
`filing its IPR. Further, when Webasto filed its IPR on April 16, 2014, Webasto
`
`knew the grounds Brose alleged in its IPR for nearly 10 weeks after Brose filed its
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`IPR. Webasto could have moved for joinder concurrently when it filed its IPR or
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`soon thereafter. But Webasto did not do so. Instead, Webasto again tactically
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`waited until after UUSI filed preliminary responses to both the Brose and Webasto
`
`IPRs for both ‘612 and ‘802 patents and until after the Board instituted the Brose
`
`IPRs for both ‘612 and ‘802 patents, and then moved for joinder on August 29,
`
`2014. Thus, Webasto moved for joinder after waiting well over six months after
`
`the filing of Brose IPR and four months after the filing of its IPR. While Webasto’s
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`Page 13 of17
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`joinder petition is not barred, its tactically delayed request for joinder due to its
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`apparently repetitive wait-and-see strategy undermines its credibility to fairly argue
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`that joinder does not prejudice UUSI and that the Board should adjust the schedule
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`already in place for the Brose IPR to accommodate Webasto’s strategically delayed
`
`joinder request. UUSI will be unfairly harmed if it must depose Webasto’s expert
`
`and respond to the different Ground B halfway through UUSI’s response period.
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`Thus, equity requires that joinder be denied absent the UUSI—proposed conditions.
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`6.
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`DENYING JOINDER WILL NOT HARM WEBASTO
`
`While UUSI will be harmed and prejudiced as explained above ifjoinder is
`
`granted, Webasto Will not be harmed or prejudiced ifj oinder is denied and if its
`
`IPR is instituted because Webasto will incur no additional burden ifj oinder is
`
`denied. Therefore, the Board should not hesitate in denying joinder.
`
`IV. UUSI RECOMMENDS SETTING A COMMON DATE FOR ORAL
`
`ARGUMENTS
`
`In lieu ofjoinder, UUSI requests the Board to set a common date for oral
`
`arguments for the Brose lPRs and, if instituted, Webasto IPRS for the ‘612 and
`
`‘802 patents. Since UUSI will not amend any claims in any of these IPRs (since
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`the patents in dispute have or will soon expire) and as long as the common hearing
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`date does not shorten response/reply timing for any party, UUSI believes the
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`Page 14 of 17
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`
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`common hearing date Will provide’defmite efficiency benefits to the Board and all
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`the parties.1
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`Case IPR2014—00650
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`Patent 7,579,802
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`V.
`
`CONCLUSION
`
`For the reasons set forth above, UUSI respectfully requests the Board to (i)
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`order UUSl’s conditions and grant Webasto’s motion for joinder mpg}: (joining
`
`only Claims 1 and 6-9 of Webasto’s Ground A with Brose’s Ground 5), (ii) order
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`UUSI’S conditions and grant Webasto’s motion for joinder Mt (joining only
`
`Webasto’s Ground A with Brose’s Ground 5), (iii) deny Webasto’s motion for
`
`joinder if it does not order UUSI’s conditions, or (iv) deny Webasto’s motion for
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`joinder and order a common hearing date for all the IPRS instituted for the ‘802
`
`and ‘612 patents.
`
`
`
`Reg. No. 61,776
`Attorneys for Patent Owner UUSI
`
`1 UUSI does not request a common hearing date for Webasto’s IPR2014—00649 for
`US. Patent No. 7,548,037 (“the ’037 patent”), if trial is instituted, since Webasto
`has asserted a considerable quantity of different references and the claims of the
`‘037 patent are very different than those of the ‘802 and ‘612 patents.
`
`Page 15 of 17
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6(E)(4)
`
`It is hereby certified that today, q £93 [2014, a copy of the foregoing doc-
`
`ument was served via electronic mail upon the following:
`
`Timothy J. Rousseau (Reg. No. 59,454)
`Charles H. Sanders (Reg. No. 47,053)
`
`csanders@goodwinmocter.com
`trousseau@go_odwir_i_procter.corn
`GOODWIN PROCTER LLP
`GOODWIN PROCTER LLP
`Exchange Place
`The New York Times Building
`53 State Street
`620 Eighth Avenue
`Boston, MA 02109
`New York, New York 10018
`Telephone: (617) 570-1315
`Telephone: (212) 813—8000
`Fax: (617) 801—8804
`Fax: (212) 355-3333
`
`Phong T. Dinh (Reg. No. 67,475)
`(pdinthgoodwinprocter.com)
`GOODWIN PROCTER LLP
`
`901 New York Avenue, NW
`
`Washington, DC. 22201
`Telephone: (202) 346-4320
`Fax: (202) 346-4444
`Attorneys ofRecordfor Webasto RoofSystems, Inc.
`
`Craig D. Leavell
`Craig.leavell@kirkland.com
`KIRKLAND & ELLIS LLP
`
`Alyse Wu
`alyse.wu@kirkland.com
`KIRKLAND & ELLIS LLP
`
`300 North LaSalle
`
`Chicago, IL 60654.
`Phone: 312-862-2105
`
`300 North LaSalle
`
`Chicago, IL 60654
`Phone: 312—862—3340
`
`Fax: 312—862—2200
`Fax: 312—862—2200
`Attorneys ofRecordfor Brose North America, Inc. and Brose Fahrzeugteile GmbH
`& Co KG, Hallstadt
`
`Page 16 of 17
`
`
`
`Case IPR2014—00650
`
`Patent 7,579,802
`
`
`
`/
`
`Monte L. F alcoff
`
`Reg. No. 37,617
`Hemant M. Keskar
`
`Reg. No. 61,776
`Attorneys for Patent Owner UUSI
`
`Dated:
`
`C?
`
`/5‘
`
`By:
`
`1889449614
`
`Page 17 of 17
`
`
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