IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`Applicant:
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`Case No.:
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`
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`Filing Date:
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`Arling, et. al
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`IPR2014-01146
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`
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`09/29/2009
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`
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`Patent No.:
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`8,243,207
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`
`
`Universal Remote Control, Inc.
`
`v.
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`
`
`
`
`
`Universal Electronics, Inc.
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`
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`Trial Paralegal: Amy Kattula
`
`Attny Doc.: 059489.144400
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`System and Method
`For Activity Based
`Configuration of an
`Entertainment System
`
`MOTION FOR ADDITIONAL DISCOVERY
`PURSUANT TO 37 C.F.R. § 42.51(b)(2)(i)
`
`Title:
`
`
`
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`Certificate of Filing: I hereby certify that this correspondence is being electronically filed with the USPTO on this
`5th day of March 2015.
`
`
`
`
`
`
`
`By:
`
`/s/ Sambath Meas
`Sambath Meas
`
`
`
`
`
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`
`

`

`
`
`
`Ex. 2002
`
`
`Ex. 2003
`
`
`Ex. 2004
`
`EXHIBIT LIST
`
`
`Ex. 2001 Mohawk Resources Ltd. V. Vehicle Service Group, LLC, Case
`IPR2014-00464, Paper 10 (Aug. 29, 2014)
`
`Edmund Optics, Inc. v. Semrock, Inc., Case IPR2014-00583, Paper 9
`(P.T.A.B. Sept. 19, 2014)
`
`3D-Matrix, Ltd. v. Menicon Co., Case IPR2014-00398, Paper No. 11
`(P.T.A.B. Aug. 1, 2014)
`
`Eizo Corp. v. Barco N.V., IPR2014-00358, Paper 11 (P.T.A.B. July
`23, 2014)
`
`
`Ex. 2005 Moses Lake Indus., Inc. v. Enthone, Inc., IPR2014-00243, Paper 6
`(P.T.A.B. June 18, 2014)
`
`
`Ex. 2006 Moses Lake Indus., Inc. v. Enthone, Inc., IPR2014-00246, Paper 6
`(P.T.A.B. June 18, 2014)
`
`
`Ex. 2007
`
`
`Ex. 2008
`
`
`Ex. 2010
`
`eBay, Inc. v. Paid, Inc., CBM2014-00125, Paper 15 (P.T.A.B. Sept.
`30, 2014)
`
`Synopsis v. Mentor Graphics Corp., IPR2012-00042, Paper No. 16
`(P.T.A.B. Feb. 22, 2013)
`
`
`Ex. 2009 Dominion Dealer Solutions, LLC v. AutoAlert, Inc., IPR2013-00222,
`Paper No. 12 (P.T.A.B. Aug. 12, 2013)
`
`SAS Institute, Inc. v. ComplementSoft, LLC, IPR2013-00581, Paper
`No. 15 (P.T.A.B. Dec. 30, 2013)
`
`
`Ex. 2011 Heart Failure Techs., LLC v. CardioKinetix, Inc., IPR2013-00183,
`Paper No. 12 (P.T.A.B. July 31, 2013)
`
`
`Ex. 2012-2016 INTENTIONALLY SKIPPED
`
`Ex. 2017
`
`Trial Transcript from Universal Electronics, Inc. v. Universal Remote
`Control, Inc., No. 8:12-cv-00329-AG-JPR (C.D. Cal.), Dkt. No. 398-1
`
`
`
`ii
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`IPR2014-01146
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`Ex. 2018 Universal Remote Control, Inc.’s (“URC’s”) Initial Disclosures from
`Universal Electronics, Inc. v. Universal Remote Control, Inc., No.
`8:12-cv-00329-AG-JPR (C.D. Cal.)
`
`
`Ex. 2019 URC’s Response to UEI’s Interrogatory at No. 6 from Universal
`Electronics, Inc. v. Universal Remote Control, Inc., No. 8:12-cv-
`00329-AG-JPR (C.D. Cal.)
`
`
`Ex. 2020 Ohsung Website Printout, available at
`http://www.ohsungec.com/02_affli/02_foreign/06.aspx.
`
`
`Ex. 2021 URC’s Amended Initial Disclosures from Universal Electronics, Inc.
`v. Universal Remote Control, Inc., No. 8:12-cv-00329-AG-JPR (C.D.
`Cal.)
`
`
`Ex. 2022 Defendant Ohsung Electronics, USA, Inc.’s Answer to Second
`Amended Complaint, Dkt. No. 76, from Universal Electronics Inc., v.
`Universal Remote Control, Inc., Ohsung Electronics Co., Ltd., and
`Ohsung Electronics U.S.A., Inc., Case No. SACV 13-00984 AG
`(JPRx) (C.D. Cal.)
`
`
`Ex. 2023
`
`LinkedIn Profile of Jak You, available at
`https://www.linkedin.com/pub/jak-you/92/8a5/6b.
`
`09/05/2013 M. Hurley Email to L. Kenneally
`
`
`Ex. 2024
`
`Ex. 2025 Amended Notice of 30(b)(6) Deposition to URC from Universal
`Electronics, Inc. v. Universal Remote Control, Inc., No. 8:12-cv-
`00329-AG-JPR (C.D. Cal.)
`
`
`Ex. 2026
`
`
`Ex. 2027
`
`Joint Stipulation Staying Action Pending Petitions for Inter Partes
`Review of All Asserted Claims, Dkt. No. 87 from Universal
`Electronics Inc., v. Universal Remote Control, Inc., Ohsung
`Electronics Co., Ltd., and Ohsung Electronics U.S.A., Inc., Case No.
`SACV 13-00984 AG (JPRx) (C.D. Cal.)
`
`Joint Statement of the Parties Pursuant to Order Staying Action (ECF
`No. 88) and Joint Request to Continue Status Conference, Dkt. No.
`102 from Universal Electronics Inc., v. Universal Remote Control,
`
`iii
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`IPR2014-01146
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`Inc., Ohsung Electronics Co., Ltd., and Ohsung Electronics U.S.A.,
`Inc., Case No. SACV 13-00984 AG (JPRx) (C.D. Cal.)
`
`
`Ex. 2028 URC NY Secretary of State, Division of Corporations, Entity
`Information Website Printout
`
`iv
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`U.S. Patent No. 8,243,207
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`PATENT OWNER’S MOTION FOR ADDITIONAL DISCOVERY
`PURSUANT TO 37 C.F.R. § 42.51(b)(2)(i)
`
`Universal Electronics Inc. (“UEI”) respectfully moves the Board for an order
`
`granting UEI permission to obtain additional discovery from Universal Remote
`
`Control, Inc. (“URC”) relating to URC’s failure to identify all real parties-in-
`
`interest. URC did not identify Ohsung Electronics Co., Ltd., and/or Ohsung
`
`Electronics U.S.A., Inc. (collectively “Ohsung”) as real parties-in-interest. UEI
`
`has identified evidence supporting its contention that Ohsung may be a real party-
`
`in-interest subject to the mandatory disclosure provision of 35 U.S.C. § 312(a)(2).
`
`URC and Ohsung share office space, at least one key remote control executive, and
`
`legal counsel in a related federal district court litigation. Moreover, URC’s CEO’s
`
`trial testimony suggests that Ohsung has previously paid certain of URC’s legal
`
`fees. In the interest of justice, it is necessary that the Board permit UEI to take
`
`limited discovery to explore the full extent to which Ohsung may be a real party-
`
`in-interest in this proceeding.
`
` UEI has filed this Motion for Additional Discovery under 37 C.F.R.
`
`§ 42.51(b)(2)(i) in response to the Board’s March 3, 2015, Order Authorizing
`
`Motion for Additional Discovery. (Paper 12.) UEI timely filed the instant motion
`
`in accordance with the Board’s March 5, 2015, deadline. (Id. at 3.) UEI sought a
`
`meet and confer with URC’s counsel, in accordance with the Board’s
`
`recommendation. (Id.) URC’s counsel offered to permit UEI’s counsel to view
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`1
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`U.S. Patent No. 8,243,207
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`the discovery gathered in a prior UEI v. URC litigation in lieu of responding to
`
`UEI’s discovery requests. UEI declined that offer because UEI would not expect
`
`to find information responsive to its discovery requests in the materials produced
`
`in that prior litigation. Ohsung was not a named defendant in that prior litigation
`
`and different patents were at issue than are at issue in the current proceedings
`
`between UEI and URC. For those reasons, among others, the real party in interest
`
`question raised here was neither litigated nor resolved in that prior litigation.
`
`I.
`
`FACTUAL BACKGROUND
`
`The Petition identifies a single real party in interest, Universal Remote
`
`Control, Inc. (Petition at 1.) URC acknowledges that UEI sued URC and Ohsung
`
`in the currently pending federal court litigation involving the patent at issue in this
`
`Proceeding. (Id. (Universal Electronics Inc., v. Universal Remote Control, Inc.,
`
`Ohsung Electronics Co., Ltd., and Ohsung Electronics U.S.A., Inc., Case No.
`
`SACV 13-00984 AG (JPRx) (C.D. Cal.) (“UEI Litigation II”)).)
`
`According to URC’s CEO, Chang Park, URC and Ohsung have a “very
`
`close relationship.” (Exhibit 2017, Trial Transcript from Universal Electronics,
`
`Inc. v. Universal Remote Control, Inc., No. 8:12-cv-00329-AG-JPR (“UEI
`
`Litigation I”), Dkt. No. 398-1, at 596:22-24.) This very close relationship goes
`
`beyond a simple supplier relationship. First, a key remote control executive
`
`identifies himself as both an Ohsung and URC employee, depending upon the
`
`2
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`U.S. Patent No. 8,243,207
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`circumstances in which questions regarding his employment status arise. Second,
`
`Ohsung represents to the public that URC’s office space is Ohsung’s US office and
`
`refers to URC as a “Foreign Affiliate.” Third, URC and Ohsung share legal
`
`counsel.
`
`At the outset, there is no dispute that Ohsung supplies all of URC’s remote
`
`control products. (Id. at 1791:17-22.) Mr. Jak You is the “primary liaison
`
`between URC and Ohsung for all product development.” (Id. at 708:6-13.) Mr.
`
`You appears to have been an employee of both URC and Ohsung. As of July 16,
`
`2012, URC represented that Mr. Jak You was URC’s director of engineering.
`
`(Exhibit 2018, UEI Litigation I, URC’s Initial Disclosures at 9; see also Exhibit
`
`2019, URC’s Response to UEI’s Interrogatory at No. 6 (identifying Jak You as an
`
`URC employee).) URC listed Mr. You’s contact information as: Jak You;
`
`Universal Remote Control, Inc.; 500 Mamaroneck Ave.; Harrison, NY 10528.
`
`(Id. (emphasis added).) Ohsung’s website refers to URC as its “Foreign Affiliate”
`
`and represents that URC’s Harrison, New York office is Ohsung’s US office.
`
`(Exhibit 2020, Ohsung Website Printout; Exhibit 2028, URC NY Secretary of
`
`State, Division of Corporations, Entity Information Website Printout.) Mr. You
`
`currently has an email address with a “universalremote.com” extension. (Id.)
`
`In July 2013, however, URC amended its Initial Disclosures, noting that
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`“Mr. You is Ohsung Electronics USA’s contact in the New York office.” (Exhibit
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`3
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`U.S. Patent No. 8,243,207
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`2021, UEI I Litigation, URC’s Amended Initial Disclosures at 9.) URC amended
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`Mr. You’s contact information to reflect that he now worked for Ohsung out of the
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`very same office that URC had previously referred to as its own office in Harrison,
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`New York: Jak H. You; Ohsung Electronics USA.; 500 Mamaroneck Ave.; Suite
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`502; Harrison, NY 10528. (Id.(emphasis added); Exhibit 2028.) In UEI Litigation
`
`II, Ohsung admitted “that it has one employee who works at 500 Mamaroneck
`
`Avenue, Harrison, New York 10528” and that “it has not made monetary rental
`
`payments for this one employee’s use of the facilities at this address.” (Exhibit
`
`2022, UEI II, Defendant Ohsung Electronics, USA, Inc.’s Answer to Second
`
`Amended Complaint, Dkt. No. 76 at ¶ 24.) Confusingly, Mr. You’s LinkedIn
`
`profile identifies himself as “VP at Universal Remote Control.” (Exhibit 2023, Jak
`
`You LinkedIn profile.)
`
`
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`Mr. You testified in UEI Litigation I as follows:
`
`Q. Question: In fact, you introduced yourself as the director of
`engineering for URC; is that correct, sir?
`
`
`A. Yes. Usually when I meet with customers from Korea I use URC
`business card. However, when I meet with U.S. customers -- when I
`meet with U.S. customers in the U.S. -- sorry. Strike that. When I
`meet with URC customers in the U.S., then I use Ohsung Electronics
`U.S.A. business card.
`
`
`(Exhibit 2017 at 1794:13-20.) Lest there be any doubt regarding the closeness of
`
`the relationship between Ohsung and URC vis-à-vis at least Mr. You, URC
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`designated Mr. You as its 30(b)(6) witness in UEI Litigation I. (Exhibit 2024,
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`4
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`U.S. Patent No. 8,243,207
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`09/05/2013 M. Hurley Email to L. Kenneally; Exhibit 2025, Amended Notice of
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`30(b)(6) deposition from UEI Litigation I.)
`
`
`
`The closeness of the relationship between URC and Ohsung extends beyond
`
`Mr. You. URC and Ohsung also share legal counsel. On July 7, 2014, URC and
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`Ohsung signed a joint stipulation (along with UEI) in UEI Litigation II agreeing to
`
`stay the action pending the outcome of this proceeding (among the other IPRs
`
`relating to the other patents at issue in UEI Litigation II). (Exhibit 2026, UEI
`
`Litigation II, Joint Stipulation Staying Action Pending Petitions for Inter Partes
`
`Review of All Asserted Claims, Dkt. No. 87.) Peter H. Kang of Sidley Austin LLP
`
`signed on behalf of Ohsung. (Id. at 4.) Douglas A. Miro of Ostrolenk Faber LLP
`
`signed on behalf of URC. (Id. at 3.) Mr. Kang is also listed as counsel for URC.
`
`Messrs. Miro and Kang are counsel for URC in this Proceeding . (Petition at 3.)
`
`
`
`The parties in UEI Litigation II subsequently filed a joint statement relating
`
`to this and the other related IPR proceedings concerning the same patents at issue
`
`in UEI Litigation II. (Exhibit 2027, UEI Litigation II, Joint Statement of the
`
`Parties Pursuant to Order Staying Action (ECF No. 88) and Joint Request to
`
`Continue Status Conference, Dkt. No. 102.) Whereas Mr. Kang had only
`
`previously signed pleadings on behalf of Ohsung, he signed this joint statement on
`
`behalf of both URC and Ohsung. (Id. at 5.)
`
`5
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`U.S. Patent No. 8,243,207
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`URC’s relationship with Ohsung is perhaps best exemplified by the trial
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`testimony of URC’s CEO, Chang Park, regarding whether Ohsung pays the legal
`
`fees associated with URC’s legal battles with UEI:
`
`Q. And, sir, isn’t it correct that the Ohsung has paid your company’s
`legal fees; is that correct?
`A. No, they haven’t paid any legal fee in this case.
`
`(Exhibit 2017 at 597:4-6 (emphasis added).) Naturally, Mr. Park’s answer begs the
`
`question: Has Ohsung paid URC’s legal fees in any other case or proceeding? But
`
`UEI never had the opportunity to ask that question at the UEI Litigation I trial
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`because the court would not permit UEI to impeach Mr. Park with documentary
`
`evidence purportedly relating to that issue. (Id. at 597:7-600:17.) UEI needs
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`discovery regarding the financial relationship between URC and Ohsung vis-à-vis
`
`this, the other related IPR proceedings, and UEI Litigation II to determine whether
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`Ohsung is a real party-in-interest.
`
`II. ARGUMENT
`
`Discovery is available for “what is …necessary in the interest of justice.” 35
`
`U.S.C. § 316(a)(5); 37 C.F.R. § 42.51(b)(2). Garmin Int’l, Inc. v. Cuozzo Speed
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`Techs. LLC, IPR2012-00001, Paper 26 (PTAB Mar. 5, 2013) (“Garmin”), sets
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`forth the relevant factors to assess whether requested discovery meets that
`
`standard. According to Garmin, the following five factors guide the analysis:
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`6
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`IPR2014-01146
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`U.S. Patent No. 8,243,207
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`1. More Than A Possibility And Mere Allegation -- The mere possibility
`of finding something useful, and mere allegation that something useful
`will be found, are insufficient to demonstrate that the requested discovery
`is necessary in the interest of justice. The party requesting discovery
`should already be in possession of evidence tending to show beyond
`speculation that in fact something useful will be uncovered.
`
`2. Litigation Positions And Underlying Basis -- Asking for the other
`party’s litigation positions and the underlying basis for those positions is
`not necessary in the interest of justice. The Board has established rules
`for the presentation of arguments and evidence. There is a proper time
`and place for each party to make its presentation. A party may not
`attempt to alter the Board’s trial procedures under the pretext of
`discovery.
`
`3. Ability To Generate Equivalent Information By Other Means –
`Information a party can reasonably figure out or assemble without a
`discovery request would not be in the interest of justice to have produced
`by the other party. In that connection, the Board would want to know the
`ability of the requesting party to generate the requested information
`without need of discovery.
`
`4. Easily Understandable Instructions -- The questions should be easily
`understandable. For example, ten pages of complex instructions for
`answering questions is prima facie unclear. Such instructions are counter-
`productive and tend to undermine the responder’s ability to answer
`efficiently, accurately, and confidently.
`
`5. Requests Not Overly Burdensome To Answer -- The requests must not
`be overly burdensome to answer, given the expedited nature of Inter
`Partes Review. The burden includes financial burden, burden on human
`resources, and burden on meeting the time schedule of Inter Partes
`Review. Requests should be sensible and responsibly tailored according
`to a genuine need.
`
`Garmin, Paper 26 at 6.
`
`Each of UEI’s discovery requests complies with the Garmin factors. None
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`of the requested discovery relates to URC’s litigation positions or underlying
`
`7
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`U.S. Patent No. 8,243,207
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`bases. Likewise, none of the requested discovery, which seeks information
`
`regarding (presumably) non-public financial arrangements between Ohsung and
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`URC as well as their personnel information, can be obtained by any other means.
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`Moreover, each of the discovery requests is easily understandable, does not require
`
`consideration of any instructions for a response, and permits URC to efficiently
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`respond. Thus, Garmin Factors 2, 3, and 4 favor granting UEI discovery.
`
`With respect to Garmin Factors 1 and 5 UEI states the following:
`
`UEI Production Request No. 1: Documents and things regarding any money
`or consideration paid or to be paid by Ohsung to URC or URC’s legal counsel
`for the Petition or this Proceeding, and agreements regarding any such money
`or consideration paid or to be paid by Ohsung to URC or URC’s legal counsel
`for the Petition or this Proceeding.
`
`UEI Production Request No. 2: Documents and things regarding any money
`or consideration paid or to be paid by Ohsung to URC or URC’s legal counsel
`for Universal Electronics Inc., v. Universal Remote Control, Inc., Ohsung
`Electronics Co., Ltd., and Ohsung Electronics U.S.A., Inc., Case No. SACV
`13-00984 AG (JPRx) (C.D. Cal.) (the “Litigation”), and agreements regarding
`any such money or consideration paid or to be paid by Ohsung to URC or
`URC’s legal counsel for the Litigation.
`
`UEI Interrogatory No. 1: Identify any money or consideration paid or to be
`paid by Ohsung to URC or URC’s legal counsel for the Petition or this
`Proceeding, by the payment date and the amount paid.
`
`UEI Interrogatory No. 2: Identify any money or consideration paid or to be
`paid by Ohsung to URC or URC’s legal counsel for the Litigation, by the
`payment date and the amount paid.
`
` Garmin Factor 1: UEI possesses evidence tending to show beyond
`
`speculation that evidence that Ohsung is a real party-in-interest will be uncovered
`
`8
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`IPR2014-01146
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`U.S. Patent No. 8,243,207
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`in response to UEI Production Request Nos. 1 and 2 and UEI Interrogatory Nos. 1
`
`and 2. The shared employees and resources pertaining to Ohsung and URC’s
`
`remote control operations, e.g., Mr. You (URC’s 30(b)(6) witness in UEI
`
`Litigation I), shared office space which both URC and Ohsung hold out as their
`
`own, shared legal counsel in UEI Litigation II, etc., confirms beyond mere
`
`speculation that there is a relationship between Ohsung and URC that goes beyond
`
`an ordinary co-defendant or supplier relationship. Indeed, Ohsung and URC have
`
`taken identical legal positions with respect to the stay entered in UEI Litigation II
`
`as a result of this and the other related IPR Proceedings. This evidence suggests
`
`that Ohsung may exert control over this Proceeding by paying for UEI Litigation II
`
`or this Proceeding, similar to how URC has done for Ohsung for other expenses.
`
`The fiscal relationship between URC and Ohsung in UEI Litigation II is germane
`
`to whether Ohsung is a real party-in-interest here because the statutory estoppel
`
`effect of this Proceeding will impact Ohsung’s litigation strategy in UEI Litigation
`
`II. Accordingly, Garmin Factor 1 supports granting UEI discovery.
`
`
`
`Garmin Factor 5: These discovery requests are not overly burdensome to
`
`answer. These requests seek discovery only regarding the extent Ohsung is paying
`
`for this Proceeding and the extent Ohsung is paying for UEI Litigation II. UEI has
`
`not peppered its discovery requests with the overused “including but not limited
`
`9
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`IPR2014-01146
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`U.S. Patent No. 8,243,207
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`to” and other such modifiers that are the hallmark of a fishing expedition.
`
`Accordingly, Garmin Factor 5 supports granting UEI discovery.
`
`UEI Production Request No. 3: Documents and things regarding Mr. Jak
`You’s, or any other person’s, dual-status as an employee of URC and Ohsung.
`
`UEI Interrogatory No. 3: Identify any person who has been an employee of
`both URC and Ohsung, concurrently or separately, and for each identified
`person, please also provide the company name, title, job function, and time
`period for each position held for each such employee.
`
`Garmin Factor 1: UEI possesses evidence tending to show beyond
`
`speculation that evidence that Ohsung is a real party-in-interest will be uncovered
`
`in response to UEI Production Request No. 3 and UEI Interrogatory No. 3. The
`
`facts relating to Mr. You confirms beyond mere speculation that there is
`
`relationship between Ohsung and URC that goes beyond an ordinary supplier
`
`relationship. That URC and Ohsung share Mr. You as an employee suggests that
`
`(i) there may be other employees that have a dual-employment relationship and
`
`hence (ii) the companies’ ties go much deeper than a supplier relationship.
`
`Accordingly, Garmin Factor 1 supports granting UEI discovery.
`
`
`
`Garmin Factor 5: These discovery requests are not overly burdensome to
`
`answer. The requests seek discovery only regarding whether additional
`
`employees, other than Mr. You, have worked for both URC and Ohsung. As
`
`before, UEI has not riddled its requests with overly inclusive modifiers.
`
`Accordingly, Garmin Factor 5 supports granting UEI discovery.
`
`10
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`IPR2014-01146
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`U.S. Patent No. 8,243,207
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`
`
`Respectfully Submitted,
`GREENBERG TRAURIG, LLP
`
`
`
`
`
`
`
` /Eric J. Maiers/
`
`
`By: Eric J. Maiers, Reg. No. 59,614
`James J. Lukas, Reg. No. 59,114
`Matthew J. Levinstein, Pro Hac Vice
`Rob R. Harmer, Reg. No. 68,048
`77 West Wacker Drive, Suite 3100
`Chicago, Illinois 60601
`(312) 456-8400
`
`
`Date: March 5, 2015
`
`
`
`
`
`
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`11
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`
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`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on the below date, I caused the
`
`foregoing to be served upon the following counsel of record via electronic mail
`
`(with counsel’s agreement):
`
`Douglas A. Miro
`Ostrolenk Faber LLP
`1180 Avenue of the Americas New
`York, NY 10036
`Telephone: (212) 596-0500
`Facsimile: (212) 382-0888
`dmiro@ostrolenk.com
`
`Peter H. Kang, Reg. No. 40,350
`Theodore W. Chandler, Reg. No. 50,319
`Ferenc Pazmandi, Reg. No. 66,216
`Sidley Austin LLP
`1001 Page Mill Rd.
`Building One
`Palo Alto, CA 94304
`Telephone: (650) 565-7000
`Facsimile: (65) 565-7100
`pkang@sidley.com
`tchandler@sidley.com
`fpazmandi@sidley.com
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`March 5, 2015
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` /s/ Sambath Meas
`Sambath Meas
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`Date:
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