`Patent 7,537,370
`Filed on behalf of Innovative Display Technologies, LLC
`By:
`Justin B. Kimble (jkimble@bcpc-law.com)
`
`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
`
`Bragalone Conroy PC
`
`2200 Ross Ave.
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`Suite 4500 – West
`
`Dallas, TX 75201
`
`Tel: 214.785.6670
`
`Fax: 214.786.6680
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`LG DISPLAY CO., LTD.,
`Petitioner,
`v.
`INNOVATIVE DISPLAY TECHNOLOGIES, LLC,
`Patent Owner
`
`
`Case IPR2014-01096
`U.S. Patent No. 7,537,370
`
`
`
`
`PATENT OWNER’S RESPONSE
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`
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`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
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`
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`1
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`Case IPR2014-01096
`Patent 7,537,370
`I.
`INTRODUCTION
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`Patent Owner Innovative Display Technologies, LLC, (“IDT” or “Patent
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`Owner”) hereby files this response (“Response”) to the Corrected Petition (Paper 4)
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`(the “Petition”) for Inter Partes Review of U.S. Patent No. 7,537,370 (the “’370
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`patent”) in IPR2014-01096 filed by LG Display Co., Ltd. (“LGD” or “Petitioner”).
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`The Petitioner’s challenge to the ’370 patent claims should be rejected
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`because the prior art lacks several material claim limitations. Even if one of skill in
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`the art would have combined the references as Petitioner suggests – the combination
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`would not yield the claimed invention.
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`A. Instituted Grounds
`The instant inter partes review was instituted on two grounds of alleged
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`invalidity– a 103(a) obviousness ground based solely on Pristash for claims 15 and
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`27, and a 103(a) obviousness ground based on the combination of Kobayashi and
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`Pristash. For the following reasons discussed in more detail below, these grounds
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`does not demonstrate by a preponderance of the evidence that claims 15 or 27 of the
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`’370 patent are invalid.
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`
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`Even if it were proper to combine Kobayashi and Pristash, neither reference,
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`either separately or in combination arrive at the claimed invention as discussed
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`below.
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`Patent 7,537,370
`B. The ’370 Patent
`The ’370 patent relates generally, to “light emitting panel assemblies”
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`including a transparent panel member for efficiently conducting light, and
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`controlling the light conducted by the panel member to be emitted from one or more
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`light output areas along its length. (’370 patent, Ex. 1001, Col. 1, ll. 19-29; Werner
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`Decl., Ex. 2005 at ¶ 28.)
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`Although light emitting panel assemblies were known, the ’370 patent relates
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`to different light emitting panel assembly configurations that provide for better
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`control of the light output from the panel assemblies and for more efficient utilization
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`of light, which results in greater light output from the panel assemblies. (’370 patent,
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`col. 1, ll. 19-29; Werner Decl. at ¶ 29.)
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`The Petition attempts to characterize the ’370 patent as merely describing
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`“several different light emitting panel assembly configurations which allegedly
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`provide for better control of light output from the panel assembly and for more
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`‘efficient’ utilization of light, thereby resulting in greater light output from the panel
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`assembly.” (Corrected Petition (“Petition”), Paper 4 at 6.) The Petition alleges that
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`the claimed light emitting panel assemblies would have been obvious under 35
`
`U.S.C. § 103 over Pristash (U.S. Patent No. 5,005,108 (“Pristash”), Ex. 1006) and
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`obvious under 35 U.S.C. § 103 over Kobayashi (U.S. Pat. No. 5,408,388
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`Patent 7,537,370
`(“Kobayashi”), Ex. 1008) in view of Pristash. (Petition, Paper 4 at 9; Werner Decl.
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`at ¶ 30.)
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`However, the Petition fails to demonstrate (1) that the combination of these
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`references would have been obvious to a person of ordinary skill in the art at the
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`time of invention and (2) that the modifications and combinations suggested would
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`result in the light emitting panel assemblies disclosed by the ’370 patent. (Werner
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`Decl. at ¶ 31.) Moreover, the Petition improperly relies on impermissible hindsight
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`in an effort to re-create the novel light emitting panel assemblies disclosed by the
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`’370 patent. (Id.)
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`Further, for each ground initiated, the Petition relies primarily on the Pristash
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`reference that was both disclosed to the Examiner and that the Examiner expressly
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`considered during the prosecution of the ’370 patent. (See List of References Cited
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`by Applicant and Considered by Examiner 03-23-2009, ’370 File History, Ex. 1002
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`at LGD_000095; Werner Decl. at ¶ 32.) After having considered this reference, the
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`Examiner chose to allow the claims of the ’370 patent. The ’370 patent issued from
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`U.S. Application No. 11/548,330, which was filed on October 11, 2006 and claims
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`a priority date of June 27, 1995.
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`C. The Prior Art in the Petition
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`Pristash
`Pristash describes a thin panel illuminator that includes a solid transparent
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`panel member having one or more deformed output regions. (Pristash, Ex. 1006,
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`Abstract.) The arrangement causes light entering the panel to be emitted along its
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`length. (Id.)
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`.
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`
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`Pristash Figure 1 above shows an exemplary panel. Petitioner analogized
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`Pristash’s “transition device” (reference number 5) as the claimed “transition
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`region.” (Petition at 13, 21).
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` Kobayashi
`U.S. Patent No. 5,408,388 to 2. Kobayashi (Exhibit 1008) (“Kobayashi”)
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`Titled “Planar illuminating device” describes a planar illuminating device that uses
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`“two sources of light each arranged adjacent to one of the side edges of the plate, a
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`reflector arranged behind the plate rear face and reflecting rays of light from the
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`Patent 7,537,370
`plate to the front face of the plate, a light diffuser arranged in front of the plate and
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`diffusing rays of light from the plate. The device comprises a reflecting finish
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`applied directly to the rear face of the plate.” (Kobayashi, Abstract.)
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`D. Claim Construction
`For inter partes reviews, claim terms are given their broadest reasonable
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`construction in light of the specification as it would be interpreted by one of ordinary
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`skill in the art. Additionally, the words of the claim must be given their plain
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`meaning that is consistent with the specification. The plain meaning of a term means
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`the ordinary and customary meaning given to the term by those of ordinary skill in
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`the art at the time of the invention. The ordinary and customary meaning of a term
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`may be evidenced by a variety of sources, including the words of the claims
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`themselves, the specification, drawings, and prior art.
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`a. “Deformities”
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`For the purposes of institution, the Board construes the term “deformities” to
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`include “any change in the shape or geometry of a surface and/or coating or surface
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`treatment that causes a portion of light to be emitted.” (Institution Decision, Paper
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`11 at 4, 12, 18.) The positions in this Response stand in light of that construction
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`and in light of the Board’s constructions upon institution. This Response does not
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`take a position on claim construction at this point. Patent Owner however, reserves
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`the right to propose its own construction of any and all claim terms for which an
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`issue arises in this IPR.
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`Patent Owner notifies the Board that the district court in Innovative Display
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`Technologies v. Acer, Inc. et al., No. 2:13-cv-522 (E.D. Tex. 2013) (Dkt. No. 101)
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`(“Claim Construction Order”) (Ex. 2002) has ruled on constructions of terms in this
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`patent, including entering an agreed construction of “deformities” that Petitioner
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`adopts in its Petition. (Petition at 7; Ex. 2002 at 58.)
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`E. Level of Ordinary Skill in the Art
`The Board did not make a determination of the level of ordinary skill in the
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`art it its institution decision. The broadest reasonable construction of the claims is
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`determined based on how the challenged patent would be read by a person of
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`“ordinary skill in the art.” The factors such as the education level of those working
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`in the field, the sophistication of the technology, the types of problems encountered
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`in the art, the prior art solutions to those problems, and the speed at which
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`innovations are made may help establish the level of skill in the art.
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`Patent Owner and its expert, Kenneth Werner rely on the following definition
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`of a person of ordinary skill in the art: “a person of ordinary skill in the art of the
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`patents would hold an undergraduate degree in physics, material science, electrical
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`engineering, or mathematics and have one or both of the following: (1) three or more
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`years of work experience in a field related to optical technology; or (2) a graduate
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`degree in a field related to optical technology.” (Werner Decl. at ¶ 36.)
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`II. ARGUMENT
`A. Claims 15 and 27 in View of Pristash
`The Petition fails to show that Pristash teaches and/or renders obvious each
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`and every limitation of the Asserted Claims of the ’370 Patent. (Werner Decl. at ¶
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`38.) Specifically, the Petition does not show that Pristash discloses “the panel
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`member has a transition region between the at least one input edge and the patterns
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`of light extracting deformities to allow the light from the at least one light source to
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`mix and spread,” and “at least one side of the transition region contains optical
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`elements for reflecting or refracting light from the at least one light source.” (Werner
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`Decl. at ¶ 38.) These limitations are required by independent claim 27 of the ’370
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`Patent. (Werner Decl. at ¶ 38.)
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`The Petition alleges that Pristash teaches “a transition device … for converting
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`light and is positioned between input edge 10 and deformities on panel 2…”
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`(Petition at p. 13). The claim chart identifies transition device 5 as allegedly meeting
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`this limitation. (Id. at 21; Werner Decl. at ¶ 39.) Both the argument in the Petition
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`and in its chart miss a crucial point of this limitation: “the panel member has a
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`transition region . . . to allow the light from the at least one light source to mix and
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`spread.” (Werner Decl. at ¶ 39.) That means that the transition region must be part
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`of the panel member such that the light can mix and spread. (Werner Decl. at ¶ 39.)
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`Here, Petitioner fails to show or explain how the alleged Pristash transition
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`device would mix the light. (Petition at 21; Werner Decl. at ¶ 39.) Further, the
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`analogized transition region does not have “optical elements for reflecting or
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`refracting light from the at least one light source.” (Werner Decl. at ¶ 39.) The
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`Petition does not show that Pristash discloses optical elements for reflecting or
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`refracting light in its “transition device.” (Werner Decl. at ¶ 39.)
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`Dr. Escuti focuses on language in Pristash that claims that its transition device
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`“spreads the light evenly across such surfaces.” But he completely ignores the claim
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`requirement that the transition region “mix and spread” as required in claim 27.
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`(Escuti Decl. at ¶¶ 109-111; Werner Decl. at ¶ 39.) Additionally, the Petition does
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`not show that Pristash discloses that its “transition region” “contains optical
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`elements for reflecting or refracting light from the at least one light source.” (Werner
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`Decl. at ¶ 39.) Instead Dr. Escuti cites Pristash Fig. 19 reproduced below “with a
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`lens 141 at the input surface 142 shaped to spread the light evenly across its output
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`surface 143.” (Id. at ¶ 112; Werner Decl. at ¶ 39.)
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`But claim 27 recites “at least one side of the transition region contains optical
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`elements for reflecting or refracting light from the at least one light source.” The
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`Petition alleges that Pristash teaches “a transition device … which can have lens 141
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`at input surface 143 …” (Petition at p. 13, emphasis added; Werner Decl. at ¶ 39.)
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`But this allegation is deficient as the Petition entirely disregards the plain claim
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`language of having “optical elements” – in the plural. (Werner Decl. at ¶ 39.)
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`Further, the Petition does not show that Pristash discloses the “pattern of light
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`extracting deformities on or in the at least one side has at least two different types of
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`light extracting deformities and at least one of the types of deformities on or in the
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`at least one side varies along at least one of the length and width of the panel
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`member” that is required in both claims 15 and 27. (Werner Decl. at ¶ 40.)
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`Neither the Petition nor Dr. Escuti provide evidence that these limitations are
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`met by Pristash other than citing the statement above: “both of the light emitting
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`panels 40 and 49 shown in FIGS. 5 and 6 may have prismatic surfaces on both the
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`top and bottom surfaces rather than on just one surface as shown.” (Pristash, 4:66-
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`5:5; Werner Decl. at ¶ 41.) From that lone statement, Dr. Escuti concludes that “[t]he
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`disruptions of Pristash are a pattern of light extracting deformities that may be
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`formed on both the front and back sides of the light emitting panels” and that “[t]hese
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`deformities cause light to be emitted from the panel member in a predetermined
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`output distribution.” (Escuti decl., Ex. 1004 at ¶¶ 77-78; Werner Decl. at ¶ 41.) Those
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`are simply conclusory statements. (Werner Decl. at ¶ 41.)
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`As the Board recognized in its institution decision denying claims 1 and 13,
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`Pristash is “insufficient to establish a disclosure or suggestion” “of having different
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`deformities on both sides of the panel.” (Decision, Paper 11, at 7.) Likewise,
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`Petitioner has not shown that Pristash is sufficient to establish different deformities
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`on or in the at least one side of the panel. (Werner Decl. at ¶ 42.) Petitioner argues
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`that the “roughened surfaces” are the different “type” of deformity that varies.
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`For independent Claim 15, the additional limitations, Pristash discloses
`one side having prismatic cuts and roughened surfaces with the
`roughened surfaces varying. Ex. 1006, Fig. 6; see also Escuti Decl.,
`¶¶115-123. For independent Claim 27, the additional limitations,
`deformities on one side are disclosed as discussed for claim 1, different
`types of deformities are discussed for claim 15, and the transition region
`limitations are disclosed as discussed for Claim 13. See Escuti Decl.,
`¶¶125-133. (Petition at 13.)
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`Dr. Escuti states that “Pristash discloses ‘where the pattern of light extracting
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`deformities on or in the at least one side has at least two different types of light
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`extracting deformities and at least one of the types of deformities on or in the at least
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`one side varies along at least one of the length and width of the panel member.’”
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`(Escuti Decl., Ex. 1004 at ¶ 121.) But Pristash merely discloses that the deformities
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`may generally be of any desired shape. (Pristash, 4:49-54; Werner Decl. at ¶ 43.)
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`The Petition does not explain why that statement can be read to mean that different
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`types of deformities could be used on or in the at least one side. Indeed claim 15
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`dictates that the different types of deformities need to be shown to be used on one
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`side at the same time (“where the pattern of light extracting deformities on or in the
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`at least one side has at least two different types of light extracting deformities”). To
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`argue that this limitation is met by Pristash, the Petition and Dr. Escuti simply draw
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`a conclusion based on assumptions and conjecture. (Werner Decl. at ¶ 43.)
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`The Petition also does not show that Pristash discloses that “the panel member
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`has a transition region between the at least one input edge and the patterns of light
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`extracting deformities to allow the light from the at least one light source to mix and
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`spread,” as recited by Claim 27. (Werner Decl. at ¶ 45.) Because the light emitting
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`panel 2 disclosed by Pristash does not have a transition region between the input
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`edge (4) of the panel member and the patterns of light extracting deformities, this
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`limitation is not disclosed. (Werner Decl. at ¶¶ 45, 46.)
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`Pristash discloses a “transition device 5 which is used to make the transition
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`from the light source 3 target shape to the light emitting panel input edge 4 shape as
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`shown.” (Pristash, 2:65-3:4.) Thus, element 5 cannot be the claimed transition region
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`because it is not “between the at least one input edge and the patterns of light
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`extracting deformities.” (Werner Decl. at ¶ 46.) Instead, the alleged transition region
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`5 comes first, then followed by light emitting panel input edge 4, then followed by
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`the alleged deformities (see Fig. 1 below). (Werner Decl. at ¶ 46.)
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`Dr. Escuti does not even analyze the transition regions of Pristash against this
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`positional requirement of the claims. (Werner Decl. at ¶ 47.) And, accordingly, Dr.
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`Escuti’s conclusory arguments fail. (Werner Decl. at ¶ 47.)
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`B. Claims 15 and 27 over Kobayashi in View of Pristash
`The Petition fails to show that Kobayashi teaches and/or renders obvious each
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`and every limitation of the instituted claims of the ’370 Patent that are likewise
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`absent in Pristash as shown above. (Werner Decl. at ¶ 48.) Specifically, the Petition
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`never argues that Kobayashi discloses the following limitation: “where the pattern
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`of light extracting deformities on or in the at least one side has at least two different
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`types of light extracting deformities and at least one of the types of deformities on
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`or in the at least one side varies along at least one of the length and width of the
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`panel member” as required by claims 15 and 27. (Werner Decl. at ¶ 48.) Instead,
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`Petitioner relies on Pristash to show this limitation with identical arguments as
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`above. (See Petition at 53-56; Werner Decl. at ¶ 48.) For the reasons explained
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`above, the Petition does not show that Pristash discloses, teaches, or suggests this
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`limitation, and therefore does not show that the combination of Pristash and
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`Kobayashi discloses this limitation. (Werner Decl. at ¶ 48.)
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`Additionally, like for Pristash, the Petition does not show that Kobayashi
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`teaches or suggest “the panel member has a transition region between the at least
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`one input edge and the patterns of light extracting deformities to allow the light from
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`the at least one light source to mix and spread,” as recited by Claim 27. The Petition
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`does not discuss Kobayashi as showing any portion of light transmitting plate 2 that
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`is between the at least one input edge and the pattern of light extracting deformities.
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`(Werner Decl. at ¶ 49.) Notably the Petition does not cite to any support from
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`Kobayashi to establish disclosure of a transition region. (See Petition at 47 (“A
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`transition region is not explicitly disclosed in Kobayashi.”); Werner Decl. at ¶ 49.)
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`Instead, Petitioner relies on Pristash. (Id.) As claimed, the transition region needs to
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`be between the at least one input edge and the pattern of light extracting deformities.
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`(Werner Decl. at ¶ 49.) The Petition does not show that Kobayashi discloses a
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`transition region meeting these requirements. (Werner Decl. at ¶ 49.) And thus,
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`neither Kobayashi alone nor the combination of Kobayashi with Pristash are
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`described in the Petition as disclosing a transition region as recited by Claim 27.
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`(Werner Decl. at ¶ 49.)
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`C. Real Party in Interest
`The Petitioner of this Request is LG Display Co., Ltd. (Petition at 1.). The
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`Petition also lists LG Display America, Inc. as a real party-in-interest. (Id.). The
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`Petition, however, omits two other real parties-in-interest: LG Electronics Inc. and
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`LG Electronics U.S.A., Inc. We know LG Electronics Inc. is a real party-in-interest
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`because it owns 37.9% of Petitioner and because it has admitted to being a related
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`party to Petitioner. (See Ex. 2003 at 75 and 109 (Excerpt of LG Electronics
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`Consolidated Financial Statements, December 31, 2013 and 2012).) We know that
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`LG Electronics U.S.A., Inc. is a real party-in-interest because it is 100% owned by
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`LG Electronics, Inc. (Id. at 16).
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`We also know that LG Electronics Inc. is a real party-in-interest because the
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`same attorneys that filed this IPR request represent LG Electronics Inc. in a lawsuit
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`that involves this patent: Delaware Display Group LLC et al. v. LG Electronics, Inc.,
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`LG Electronics U.S.A., Inc., LG Display Co., Ltd., and LG Display America, Inc.,
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`Case No. 1:13-cv-02109 (D. Del., filed December 31, 2013) (the “Delaware
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`lawsuit”). In the Delaware lawsuit, Robert G. Pluta has appeared for LG Electronics
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`Inc. (See Ex. 2004, Docket Report for Delaware Case). Mr. Pluta is also primary
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`attorney on this Petition. Furthermore, Jamie B. Beaber also represents LG
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`Electronics Inc. in the Delaware lawsuit (Id.), and he has appeared pro hac vice in
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`this IPR proceeding.
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`These facts show that both LG Electronics Inc. and LG Electronics U.S.A.,
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`Inc. are in sufficient control of these proceedings to be considered real parties-in-
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`interest.
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`Both have the “actual measure of control or opportunity to control that might
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`reasonably be expected between two formal coparties.” (IPR2013-00609, Zoll
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`Lifecor Corp. v. Phillips Elec. N. America Corp., Paper No. 15 at p. 11.)
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`Accordingly, this Petition does not meet the requirements of 35 U.S.C. 312(a).
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`Unlike a clerical issue such as using the incorrect font in a petition, the effect of
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`failure to name real parties-in-interest may give rise to arguments that the unnamed
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`parties are free to operate without the estoppel restrictions of 35 U.S.C. 315(e).
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`III. STATEMENT OF MATERIAL FACTS IN DISPUTE
`Petitioner did not submit a statement of material facts in its petition for inter
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`partes review. Accordingly, the Patent Owner cannot properly submit, as required
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`by 37 C.F.R. § 42.23, a statement of material facts in dispute. Out of an abundance
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`of caution, however, Patent Owner identifies the following disputed material facts:
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`Patent Owner disagrees with Petitioner’s characterization of Admitted Prior Art and
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`contends that Petitioner has not made a sufficient showing for and Admitted Prior
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`Art as qualifying under any of the provisions of 35 U.S.C. § 102.
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`IV. STATEMENT OF PRECISE RELIEF REQUESTED
`Pursuant to 35 U.S.C. § 316 and 37 C.F.R. § 42.120, Patent Owner requests
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`that the Board confirm the validity of claims 15 and 27 of the ’370 patent.
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`Specifically, Patent Owner requests that the Board find that Claims 15 and 27 of the
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`’370 Patent are not obvious under 35 U.S.C. § 103(a) by Pristash or by Kobayashi
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`in view of Pristash.
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`V. CONCLUSION
`This Response shows that the grounds proposed in the Petition does not
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`invalidate the initiated claims of the ’370 patent. For those reasons, Patent Owner
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`requests that the Board hold that the Petition has not proven invalidity of claims 15
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`and 27 of the ’370 Patent.
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`Dated: April 6, 2015
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`Respectfully submitted,
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`Justin B. Kimble
`Attorney for Patent Owner
`Registration No. 58,591
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that document was served via electronic mail
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`on April 6, 2015, to Petitioner via counsel, Robert Pluta, at the email addresses
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`rpluta@mayerbrown.com, bpaul@mayerbrown.com, astreff@mayerbrown.com,
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`alam@mayerbrown.com,
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`jbeaber@mayerbrown.com,
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`and
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`DDGIPR@mayerbrown.com, pursuant to Petitioner’s consent in its revised
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`mandatory notice.
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`Justin B. Kimble
`Attorney for Patent Owner
`Registration No. 58,591
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
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`18
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