UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`
`
`ORACLE CORPORATION and NETAPP INC.,
`Petitioners,
`v.
`CROSSROADS SYSTEMS, INC.
`Patent Owner.
`____________
`Case IPR2014-01207
`Patent No. 7,051,147
`____________
`
`
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`PATENT OWNER’S REPLY IN SUPPORT OF ITS MOTION TO
`EXCLUDE EVIDENCE CITED BY PETITIONERS
`
`
`
`
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`
`
`ORACLE CORPORATION and NETAPP INC.,
`Petitioners,
`v.
`CROSSROADS SYSTEMS, INC.
`Patent Owner.
`____________
`Case IPR2014-01207
`Patent No. 7,051,147
`____________
`
`
`
`PATENT OWNER’S REPLY IN SUPPORT OF ITS MOTION TO
`EXCLUDE EVIDENCE CITED BY PETITIONERS
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`Patent Owner respectfully submits this Reply in support of its Motion to
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`Exclude (Paper 61, “Motion” or Mot.”).
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`A. Ex 1218: Levy Testimony-Objection 1 (56:19-57:24): Patent Owner objected to
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`Petitioners’ citation to Ex.1218 at 56:19-57:24 (Paper 45 (“Reply”) at 3) for the
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`proposition that “a host channel ID (a Fibre Channel ID in the CRD combined system)
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`is sufficient to identify the host” as such is directly contrary to Dr. Levy’s prior
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`testimony. Mot. at 1, 4-5. Petitioners now attempt to distance themselves from that
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`contrary testimony, arguing that Dr. Levy was testifying about “a different combined
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`system in which there were multiple FC devices on a single channel” not a system that
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`has a single host on a channel. Paper 66 (“Opp.”) at 3-4. This is simply not correct.
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`Dr. Levy was distinguishing channel identifiers from host identifiers while discussing
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`the example in ¶ 70 of his IPR2014-01226 Declaration—an example in which there
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`was one host per channel. Ex. 1232, 125:22-126:19; IPR2014-01226, Ex. 2027 at
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`¶ 70. Thus, Petitioners’ attempt to distinguish Dr. Levy’s prior testimony fails.
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`Moreover, Petitioners ignore the fact that in the present case Dr. Levy testified
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`that “on the host side of the map, all that’s required in the map is an identifier
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`sufficient to distinguish between multiple hosts on the first transport medium. So a
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`fibre channel ID of some kind would be one example of something that could
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`distinguish between such hosts” in context of a system “where there is only a single
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`host device on a fibre channel.” Ex. 1218, 57:10-24 (emphasis added). Thus,
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`Petitioners’ assertion that Dr. Levy conceded that a host channel ID is sufficient to
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`1
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`identify the host is also directly contradicted by Dr. Levy’s testimony in the present
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`case with respect to a one host per channel system. See also Mot. at 5 (citing Ex.
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`1218, 54:5-16, 67:22-68:8, 92:14-20, 93:9-15, 94:15-22).
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`Petitioners also argue that “fibre channel ID” is not ambiguous because the ’147
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`Patent describes “fiber channel identifiers.” Opp. at 2-3 (referring to identifiers for
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`“Fibre Channel devices”). Petitioners however use their term “fibre channel ID” in an
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`entirely different way from the “fibre channel identifiers” they refer to in the
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`specification. Id. at 4 (referring to identifiers for channels). See Reply at 3; Ex.
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`1001,8:1-2. That Petitioners cannot agree on one definition demonstrates the
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`ambiguity of “fibre channel ID.” Petitioners’ arguments that “fibre channel ID” is not
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`vague based on context and Dr. Levy’s understanding (Opp. at 2-3) were previously
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`addressed in the Motion. See Mot. at 3-4.
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`Accordingly, Patent Owner respectfully requests that the objections in the
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`Motion be sustained or that the Board consider additional portions of the record under
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`FRE 106, as requested in the Motion. See Zhongshan Broad Ocean Motor Co., Ltd.,
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`et al. v. Nidec Motor Corp., IPR2014-01121, Paper 42 at 3 (Sept. 10, 2015) (citing
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`FRE 106).
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`B. Ex 1218: Levy Testimony-Objection 2 (93:20-96:4): Petitioners attempt to
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`address Patent Owner’s objection with respect to the use of “for routing purposes” by
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`arguing that the phrase was clarified. Opp. at 5. However, Patent Owner would point
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`out that Petitioners’ clarification does not support the initial proposition for which the
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`objectionable testimony was cited in the Reply. That is, Dr. Levy does not say that a
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`host interface ID identifies the host, only that “responding on that interface would be
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`responding to the correct host.” Ex. 1218, 95:5-6.
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`Turning to Petitioners’ assertions with respect to Ex. 1218, 95:13-22,
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`Petitioners do not actually address Patent Owner’s objections to this testimony, but
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`simply assert that the “witness did not have any difficulty in responding to the
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`question.” Opp. at 5. The issue is not whether the deponent had difficulty in answering
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`the question but, rather, whether the questions are vague (Mot. at 8-9) and, further,
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`whether Petitioners mischaracterized Dr. Levy’s testimony (Mot. at 9-11), neither of
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`which is addressed by Petitioners. In any case, Dr. Levy explicitly denied the very
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`statement that Petitioners claim he supports. Ex. 1218, 92:17-20 (Dr. Levy explaining
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`that “the host interface ID does not identify the host”). See also Mot. at 9-10 (citing
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`Ex. 1218, 92:8-20; 93:9-15, 94:15-22, 95:7-12). As such, Patent Owner respectfully
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`requests that the objection to the testimony at Ex. 1218, 93:20-96:4 be sustained or
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`additional testimony considered under FRE 106, as requested in the Motion.
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`C. Ex 1220: Middleton Testimony: Petitioners’ Opposition simply reiterates
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`Petitioners’ mischaracterizations of Middleton’s testimony from the Reply. While Mr.
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`Middleton agreed that he could not “testify as to any specific technical reason” (54:6-
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`9), he provided multiple reasons Crossroads could not test its software. See e.g., Ex.
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`1220, 106:13-107:15. Mr. Middleton repeatedly confirmed that Crossroads could not
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`have tested the access controls, under any conditions, until Verrazano was complete.
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`3
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`See Mot. at 11 (citing Ex. 1220, 52:3-12, 106:13-107:15, 108:5-15, 113:7-14, 115:14-
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`17). The testimony should be excluded for the reasons set forth in the Motion at 11-
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`12.
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`D. Ex. 1009, 1224, 1225, 1226: In response to these objections, Petitioners note that
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`a district court’s claim construction order or an expert declaration regarding claim
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`construction may be relevant to the broadest reasonable interpretation. Opp. at 10.
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`This argument is inapposite because exhibits 1009, 1224, 1225, and 1226 are neither.
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`Exhibits 1009, 1224 and 1225 are preliminary infringement statements and should be
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`excluded for the reasons set forth in the Motion at 12-14.
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`Further, with respect to Exhibit 1226, Petitioners have completely failed to
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`establish the relevance of the user guide for the ProtecTIER software from Diligent
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`Technologies (not Overland). Instead, Petitioners unhelpfully “note” that Patent
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`Owner did not contest “that the accused Overland 9500D actually operated in the
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`manner described.” Opp. at 7. Disregarding the fact that there is no competent
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`evidence to actually contest (or that Patent Owner even has a mechanism for
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`contesting, as Petitioners chose not to provide an expert declaration), the real issue is
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`the relevance of this software guide. How this software (never referenced in the
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`preliminary infringement contentions) may have operated is simply irrelevant; and,
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`thus, Exhibit 1226 should be excluded for the reasons set forth in the Motion at 12-14.
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`E. Ex. 1008: Petitioners cite Metrics, Inc. v. Senju Pharm, for the proposition that “a
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`party may cure an objection to the certificate of translation by serving supplemental
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`4
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`evidence.” Opp. at 11-12 (citing Metrics, Inc. v. Senju Pharm, IPR2014-01041, Paper
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`19 at 19-20) (PTAB Feb. 19, 2015). This is incorrect. Metrics merely lays out the
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`objection procedure, but notes that the issue would ultimately be resolved at the Final
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`Written Decision. Id. at 20. Metrics settled before the Board actually ruled on whether
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`the party could cure the objection. Metrics, IPR2014-01041, Paper 39.
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`Petitioners try to divert attention from their noncompliance by attempting to
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`shift the burden to Patent Owner, claiming that Patent Owner failed to show prejudice
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`or inaccuracies in the translation. Opp. at 6. This overlooks that “Petitioner has not
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`demonstrated an extraordinary situation such that wavier of a rule is justified.” See
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`Square, Inc. v REM Holdings 3, LLC, IPR2014-00312, Paper 58 at 36 (PTAB Jul. 7,
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`2015). In fact, the Board has found that situations like the present case do not warrant
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`a waiver of the rules. According to the Board, compliance with 37 C.F.R. § 42.63(b) is
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`mandatory and requires that an affidavit of translation be filed with the petition.
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`Zhongshan, IPR2014-01121, Paper 25 at 5 (PTAB Feb. 24, 2015). “The distinction
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`between correction of an already filed, but defective, attesting affidavit and an attempt
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`to file a new later-obtained attesting affidavit is fundamental.” Id. at 5. As in
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`Zhongshan, the Board should exclude Petitioners’ late acquired affidavit (Ex. 1238).
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`Id.; see also id. at 7 (“[W]e are not persuaded that waiving the requirement under §
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`42.63(b) would be a prudent exercise of our discretion under these facts.”).
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`Respectfully submitted,
`SPRINKLE IP LAW GROUP
`
` John L. Adair /
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` /
`
`John L. Adair
`Reg. No. 48,828
`Counsel for Patent Owner
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`Dated: October 13, 2015
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`1301 W. 25th Street
`Suite 408
`Austin, Texas 78705
`Tel. (512) 637-9220
`Fax. (512) 371-9088
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`6
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`PATENT OWNER’S EXHIBIT LIST
`IPR2014-01207
`
`
`
`
`2001
`
`2003
`
`2004
`
`2002
`
`Exhibit No. Description
`
`U.S. Patent No. 5,941,972 (the “’972 patent”)
`
`District Court Order (denying motion for summary judgment of
`invalidity based on Kikuchi), Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., C.A. No. 00-cv-00217-SS (W.D.
`Tex. Aug. 30, 2001)
`
`Final Judgment, Crossroads Systems, (Texas), Inc. v. Chaparral
`Network Storage, Inc., C.A. No. 00-cv-00217-SS (W.D. Tex. Oct.
`11, 2001)
`
`Markman Order, Crossroads Systems, (Texas), Inc. v. Chaparral
`Network Storage, Inc., C.A. No. 00-cv-00217-SS (W.D. Tex. Jul.
`27, 2000) & Crossroads Systems, (Texas), Inc. v. Pathlight
`Technology, Inc., C.A. No. 00-cv-00248-SS (W.D. Tex. Jul. 27,
`2000)
`
`Markman Order, Crossroads Systems (Texas), Inc. v. Dot Hill
`Systems Corp., C.A. No. 03-cv-00754-SS (W.D. Tex. Nov. 4, 2005)
`
`Report and Recommendation of Special Master re: Claim
`Construction, Crossroads Systems (Texas), Inc. v. Dot Hill Systems
`Corp., C.A. No. 03-cv-00754-SS (W.D. Tex. Jan. 21, 2005)
`
`Markman Order, Crossroads Systems, Inc. v. 3Par, Inc., C.A. No.
`10-cv-00652-SS (W.D. Tex. Nov. 8, 2011)
`
`Report and Recommendation of Special Master re: Claim
`Construction, Crossroads Systems, Inc. v. 3Par, Inc., C.A. No. 10-
`cv-00652-SS (W.D. Tex. Aug. 10, 2011)
`
`Joint Claim Construction Chart submitted in Pending Litigation in
`Western District of Texas by Crossroads and Petitioners
`
`Declaration of Janice Pampell
`
`
`2005
`
`2006
`
`2007
`
`2008
`
`2009
`
`2010
`
`
`
`
`
`
`
`2011
`
`2012
`
`2013
`
`2014
`
`Exhibit No. Description
`
`CRD-5500, RAID DISK ARRAY CONTROLLER Product Insert,
`pp. 1-5
`
`Excerpt from File History of Reexamination Control No.
`90/001,125 (U.S. Patent No. 6,425,035)
`
`Claim Chart Comparing MaxStrat Gen5 S-Series XL to ‘035 Patent
`Claims, Exhibit 10 to July 19, 2004 Ex Parte Reexamination
`Request in Reexamination Control No. 90/001,125
`
`Claim Chart Comparing U.S. Patent No. 6,219,771 (Kikuchi) to
`‘035 Patent Claims, excerpted from Exhibit 22 to July 19, 2004 Ex
`Parte Reexamination Request in Reexamination Control No.
`90/001,125
`
`Claim Chart Comparing U.S. Patent No. 6,073,209 (Bergsten) to
`‘035 Patent Claims, excerpted from Exhibit 22 to July 19, 2004 Ex
`Parte Reexamination Request in Reexamination Control No.
`90/001,125
`
`Hewlett Packard, TACHYON HPFC-5000 User’s Manual, May
`1996
`
`CMD Technology, CRD-5500 RAID Controller Brochure, May
`1999
`
`[Reserved]
`
`Declaration of John Levy, Ph.D., IPR2014-01226 (April 20, 2015)
`
`2015
`
`2016
`
`2017
`
`2018-2026
`
`2027
`
`2028
`
`2029
`
`2030-31
`
`[Reserved]
`
`October 6, 2014 Markman Hearing Transcript
`Crossroads Sys., Inc. v. Multiple Defendants
`(co-pending litigation in W.D. Tex.)
`
`[Reserved]
`
`
`
`
`
`
`
`
`2032
`
`2033
`
`2034
`
`2035
`
`2036
`
`2037
`
`Exhibit No. Description
`
`Defendants’ Joint Claim Construction Brief
`(co-pending litigation, W. D. Tex.)
`
`July 31, 2014 Declaration of Randy Katz regarding Claim
`Construction (including exhibits)
`(co-pending litigation, W.D. Tex.).
`
`Special Master’s Recommended Constructions
`(co-pending litigation, W.D. Tex.)
`
`Crossroads Industry Awards
`
`Sept. 7, 2012 Strongbox Engineering Excellence Award
`Announcement
`
`Small Computer System Interface-2, ANSI X3.131-1994
`
`Randy H. Katz, High Performance Network and Channel-Based
`Storage, Proceedings of the IEEE, Vol. 80, No. 8, August 1992
`
`[Reserved]
`
`Tree Illustration with annotations from Jeffrey Chase, Ph.D.
`(unfiled, referenced in April 3, 2015 Chase Deposition)
`
`Table Illustration, hand drawn by Scott Crocker
`(unfiled, referenced in April 3, 2015 Chase Deposition)
`
`Figure 2 of Hirai (Ex. 1008 at 6) with annotations
` by Jeffrey Chase, Ph.D.
`(unfiled, referenced in April 4, 2015 Chase Deposition)
`
`Declaration of Brian Bianchi (April 20, 2015)
`
`Exhibit A to Declaration of Brian Bianchi
`Confidential Protective Order Material
`
`
`2038
`
`2039
`
`2040
`
`2041
`
`2042
`
`2043
`
`2044
`
`
`
`
`
`
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`2045
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`2046
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`2047
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`2049
`
`2050
`
`2051
`
`2052
`
`2048
`
`Exhibit No. Description
`
`Exhibit B to Declaration of Brian Bianchi
`Confidential Protective Order Material
`
`Exhibit C to Declaration of Brian Bianchi
`
`SCSI 3 Architecture Model, ANSI X3.270-1996
`
`NFS: Network File System Version 3 Protocol Specification, Sun
`Microsystems, February 16, 1994
`
`Declaration of Jennifer Ray Crane (April 16, 2015)
`
`Exhibit A to Declaration of Jennifer Ray Crane
`Confidential Protective Order Material
`
`Appendix B to Declaration of Jennifer Ray Crane
`
`Appendix C to Declaration of Jennifer Ray Crane
`Confidential Protective Order Material
`
`Declaration of John Levy, Ph.D.
`
`Deposition of Jeffrey S. Chase, Ph.D., Cisco Sys., Inc. v. Crossroads
`Sys., Inc., IPR2014-01197, -01207, -01209,
`Vol. I, pp. 1-225 (PTAB April 3, 2015)
`
`Deposition Jeffrey S. Chase, Ph.D., Cisco Sys., Inc. v. Crossroads
`Sys., Inc., IPR2014-01197, -01207, -01209,
`Vol. II, pp. 226-432 (PTAB April 4, 2015)
`
`Andrew S. Tanenbaum, Modern Operating Systems (3rd ed. 2008)
`Chaps 4-5
`
`Andrew S. Tanenbaum, Modern Operating Systems (1st ed. 1992),
`Chaps 1, 4, and 7
`
`
`2053
`
`2054
`
`2055
`
`2056
`
`2057
`
`
`
`
`
`
`
`2058
`
`2059
`
`2060
`
`Exhibit No. Description
`
`M. Satyanarayanan, Integrating Security in Large Distributed
`System, ACM Transactions on Computer Systems, Vol. 7, No. 3,
`August 1989, at 247
`
`The Open Group, Protocols for Interworking: XNFS, Version 3W
`(1998)
`
`Deposition of Randy Katz, Ph.D., Crossroads Sys., Inc. v. Multiple
`Defendants
`(co-pending litigation in W.D. Tex. August 9, 2014)
`
`SCSI-3 Block Commands (SBC), ANSI NCITS 306-1998
`
`2061
`
`2062
`
`2063
`
`2064
`
`2065
`
`Fibre Channel Protocol for SCSI (FCP), ANSI X3.269-1996
`
`SCSI-3 Primary Commands (SPC), ANSI X3.301-1997
`
`Fibre Channel Physical and Signaling Interface (FC-PH) revision
`4.3, ANSI working draft, proposed June 1, 1994
`
`September 5, 2014 Stipulated Definitions of Claim Terms (co-
`pending litigation, W.D. Tex.)
`
`[Reserved]
`2066-2299
`
`
`2300 May 28, 1997 Fax from Geoffrey Hoese to Anthony Peterman
`(Plaintiff’s Exhibit 7 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS
`(W.D. Tex. 2001)
`
`Excerpts from Transcript of Trial in Crossroads Systems, (Texas),
`Inc. v. Chaparral Network Storage, Inc., Docket No. A 00-CA-217
`SS (W.D. Tex. 2001)
`
`Excerpts from Deposition of Geoff Hoese, August 6, 2001, taken in
`Crossroads Systems, (Texas), Inc. v. Chaparral Network Storage,
`Inc., Docket No. A 00-CA-217 SS (W.D. Tex. 2001)
`
`
`2301
`
`2302
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`2303
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`2304
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`2305
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`2306
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`2307
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`Exhibit No. Description
`
`July 11, 1997 Letter and Draft Patent Application from Mr. Anthony
`Peterman (Baker & Botts LLP) to Mr. Geoffrey Hoese (Plaintiff’s
`Exhibit 266 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS
`(W.D. Tex. 2001)
`
`Excerpts from Deposition of Anthony Peterman, Nov. 14, 2000,
`taken in Crossroads Systems, (Texas), Inc. v. Chaparral Network
`Storage, Inc., Docket No. A 00-CA-217 SS (W.D. Tex. 2001)
`
`Declaration of John Middleton
`
`Excerpts from Deposition of Geoff Hoese, Sept. 18-19, 2000, taken
`in Crossroads Systems, (Texas), Inc. v. Chaparral Network Storage,
`Inc., Docket No. A 00-CA-217 SS (W.D. Tex. 2001).
`
`Verrazano FC-SCSI Bridge Product Overview Presentation, June
`19, 1996
`(Plaintiff’s Exhibit 4 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS
`(W.D. Tex. 2001)
`
`Verrazano Software Development, Sept. 10, 1996
`(Plaintiff’s Exhibit 5 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS
`(W.D. Tex. 2001)
`
`Verrazano: System Structure Drawings, Document Number
`DS04100, Jan. 22, 1997
`(Plaintiff’s Exhibit 6 in Trial of Crossroads Systems, (Texas), Inc. v.
`Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS
`(W.D. Tex. 2001)
`
`Excerpts from Deposition of Jeffry Russell, Sept. 26, 2000, taken in
`Crossroads Systems, (Texas), Inc. v. Chaparral Network Storage,
`Inc., Docket No. A 00-CA-217 SS (W.D. Tex. 2001).
`
`Conception and Reduction to Practice Timeline (Demonstrative)
`
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`2311
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`2308
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`2309
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`2310
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`
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`2312
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`2313
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`2314
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`2315
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`2317
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`Exhibit No. Description
`
`Verrazano Bare Board Drawings (latest revisions Sept. 3, 1997)
`CRDS 50579
`
`Engineering/Lab Notebook of Geoff Hoese
`(Plaintiff’s Exhibit 263 in Trial of Crossroads Systems, (Texas), Inc.
`v. Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS
`(W.D. Tex. 2001)
`(Exhibit 12 to Deposition of Geoff Hoese, Sept. 19, 2000, taken in
`Crossroads Systems, (Texas), Inc. v. Chaparral Network Storage,
`Inc., Docket No. A 00-CA-217 SS (W.D. Tex. 2001)).
`
`Verrazano Enclosure Specification, Revision 2.1, June 5, 1997
`(Plaintiff’s Exhibit 264 in Trial of Crossroads Systems, (Texas), Inc.
`v. Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS
`(W.D. Tex. 2001)
`
`[Reserved]
`
`CP4x00 Product Specification (Preliminary)
`(Plaintiff’s Exhibit 267 in Trial of Crossroads Systems, (Texas), Inc.
`v. Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS
`(W.D. Tex. 2001)
`(Exhibit 10 to Deposition of Jeffry Russell, Sept. 26, 2000, taken in
`Crossroads Systems, (Texas), Inc. v. Chaparral Network Storage,
`Inc., Docket No. A 00-CA-217 SS (W.D. Tex. 2001)).
`
`Verrazano Hardware Architecture, Revision 1.0, Aug. 25, 1997
`(Plaintiff’s Exhibit 268 in Trial of Crossroads Systems, (Texas), Inc.
`v. Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS
`(W.D. Tex. 2001)
`(Exhibit 2 to Deposition of Jeffry Russell, Sept. 26, 2000, taken in
`Crossroads Systems, (Texas), Inc. v. Chaparral Network Storage,
`Inc., Docket No. A 00-CA-217 SS (W.D. Tex. 2001)).
`
`2316
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`
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`2318
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`Verrazano: System Structure Drawings, Document Number
`DS04100, Sept. 3, 1997
`
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`2319
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`2320
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`2321
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`2322
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`Exhibit No. Description
`
`Verrazano Software Architecture, Revision 1.1, Aug. 27, 1997
`
`Verrazano Programmable Device Instructions, Version 1.1, Sept. 5,
`1997
`
`Verrazano Component List and Insertion List Report, Sept. 29, 1997
`
`Engineering/Lab Notebook of Geoff Hoese
`(Plaintiff’s Exhibit 274 in Trial of Crossroads Systems, (Texas), Inc.
`v. Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS
`(W.D. Tex. 2001)
`(Exhibit 14 to Deposition of Geoff Hoese, Sept. 19, 2000, taken in
`Crossroads Systems, (Texas), Inc. v. Chaparral Network Storage,
`Inc., Docket No. A 00-CA-217 SS (W.D. Tex. 2001)).
`
`December 31, 1997 Letter and Patent Application from Mr. William
`Hulsey (Baker & Botts LLP) to Mr. Dale Quisenberry
`
`(Plaintiff’s Exhibit 275 in Trial of Crossroads Systems, (Texas), Inc.
`v. Chaparral Network Storage, Inc., Docket No. A 00-CA-217 SS
`(W.D. Tex. 2001)
`Declaration of Brian Bianchi (May 26, 2015)
`
`2325-2349 [RESERVED]
`
`2323
`
`2324
`
`2350
`
`Declaration of John Middleton (June 8, 2015)
`
`2351
`
`Declaration of Brian Bianchi (June 16, 2015)
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
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`The undersigned certifies service of a copy of Patent Owner’s Reply in
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`Support of its Motion to Exclude and Exhibit 2027 on October 13, 2015 on counsel
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`for Petitioners by e-mail (pursuant to agreement) at the below e-mail addresses:
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`Greg Gardella
`cpdocketgardella@oblon.com
`Scott McKeown
`cpdocketmckeown@oblon.com
`Oblon Spivak
`1940 Duke Street
`Alexandria, VA 22314
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`By:
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` /John L. Adair /
`John L. Adair
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