Petitioner Microsoft’s Reply
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`Paper No. 34
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MICROSOFT CORPORATION
`Petitioner,
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`v.
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`BISCOTTI INC.
`Patent Owner
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`Patent No. 8,144,182
`Issued: March 27, 2012
`Filed: September 16, 2009
`Inventors: Matthew B. Shoemake and Nadeem Ahmed
`Title: REAL TIME VIDEO COMMUNICATIONS SYSTEM
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`___________________
`Case IPR2014-01457
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`PETITIONER MICROSOFT’S REPLY
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`________________________
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`Paper No. 34
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`MICROSOFT CORPORATION
`Petitioner,
`
`v.
`
`BISCOTTI INC.
`Patent Owner
`
`Patent No. 8,144,182
`Issued: March 27, 2012
`Filed: September 16, 2009
`Inventors: Matthew B. Shoemake and Nadeem Ahmed
`Title: REAL TIME VIDEO COMMUNICATIONS SYSTEM
`
`___________________
`Case IPR2014-01457
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`PETITIONER MICROSOFT’S REPLY
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`________________________
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`Petitioner Microsoft’s Reply
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`I.
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`Kenoyer Discloses All the Elements of Claim 6
`A. Kenoyer Discloses the Claimed Input Interfaces
`Claim 6 requires audio and video input interfaces “to receive” input from a set
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`top box (“STB”). Ex. 1001 at 32:64-67. It does not require interfaces “typically”
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`used to connect a STB, as Patent Owner suggests. See Resp., 10, 14. Kenoyer
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`discloses a codec with multiple audio and video interfaces that can connect to a
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`STB, teaches connecting an STB to the codec and, in Figure 5, shows multiple
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`audio and video input interfaces through which such a connection may be made.
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`Pet., 14; Ex. 1003 ¶¶95, 234; Ex. 1006, Fig. 5, 8:56-9:34.1 Despite Patent Owner’s
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`suggestion otherwise, Kenoyer’s disclosure of the codec’s functionality in one
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`paragraph and the codec’s interfaces in another is sufficient to satisfy the claim. Ex
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`parte Luck, 28 U.S.P.Q.2d 1875-76.
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`Patent Owner ignores that claim 6 requires only an “interface” (Resp., 13), i.e.,
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`“the point at which a connection is made between two elements so that they can
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`1 Kenoyer also discloses other input interfaces for the codec that are capable of
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`receiving audio and video from a STB. Pet., 11; Ex. 1003 ¶81; Ex. 1006, 9:29-34;
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`Ex. 1052 (Houh Reply Dec.), ¶12, 30, 39; Ex. 1050 (July 30, 2015, Bovik Dep.
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`Tr.), 32:3-21. Kenoyer also discloses “coupl[ing]” the codec to the STB. Pet., 13-
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`14, citing Ex. 1006, 10:25-30; 1:65-2:1. Kenoyer then describes multiple video and
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`audio interfaces for that coupling. Ex. 1006, 11:2-4; Fig. 7b.
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`Petitioner Microsoft’s Reply
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`work with each other or exchange information.” Ex. 1005 (Microsoft Computer
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`Dict.), at 279-80; Ex. 1050 (July 30, 2015 Bovik Dep. Tr.), 56:1 – 57:6. When
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`Kenoyer discloses “coupling” (i.e., connecting) the STB and the codec, it discloses
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`an “interface” – i.e., a point at which those devices can connect.
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`Patent Owner also focuses improperly on one embodiment to argue that Fig. 5
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`shows interfaces from the codec to a computer, not to a STB (Resp., 10), ignoring
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`that Kenoyer also teaches connecting the codec to a STB. Pet. 13-14; Ex. 1006,
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`1:65-2:1, 10:25-28. Indeed, Patent Owner implicitly concedes the VGA port of Fig.
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`5 can connect to a STB, by arguing only that VGA “is not ordinarily used for
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`transmission of a cable or satellite signal.” Resp., 10, also 14; Ex. 2011 ¶81. The
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`evidence shows STBs with VGA outputs that could interface with Kenoyer’s
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`“VGA In.” See Ex. 1052, ¶25-29; Ex. 1055, ¶ 5; Ex. 1055, 6:51-61; Ex. 1046 at 7,
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`9, 11; Ex. 1047 at 15, 21; Ex. 2017 at 42; Ex. 1033 at 63; Ex. 1050, 79:2-9.
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`Patent Owner also argues that Kenoyer “fails to identify whether the ‘pass-
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`through’ content consists of both audio and video, or only one of the two.” Resp.,
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`13; see also id. at 15. But the “regular programming/games” disclosed in Kenoyer
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`includes both audio and video. Ex. 1052, ¶32, 42; Ex. 1006, 11:2-4 (STB with
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`audio and video output interfaces); see also Ex. 1009 at 2 (TV with audio and
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`video inputs for STB); Ex. 2018 at 11 (same); Ex. 2017 at 14 (same); Ex. 1033
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`(Briere) at 73 (“you also need some separate cables to carry the audio signals that
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`2
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`Petitioner Microsoft’s Reply
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`correspond with your TV video”). Indeed, Biscotti’s expert agrees that
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`“programming” includes both video and audio. See, e.g., Ex. 1050, 14:2-21
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`(video); id., 15:3-16 (audio).
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`In addition, the claim requires just an audio “interface,” and Fig. 5 shows audio
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`input interfaces, including “microphone-in 513” and “alternate input 315.” Ex.
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`1003, ¶235. And Kenoyer describes the STB as both coupled to the codec and
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`having “audio ports (e.g., audio ports 713a-b ).” Ex. 1006, 11:3-4. Kenoyer also
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`explains that in some embodiments the audio interfaces of its codec are “Radio
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`Corporation of America (RCA) (L+C+R analog) input,” Ex. 1006, 12:62-66; see
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`Ex. 1003, ¶81, which is a typical audio input interface, see Ex. 1052, ¶39; Ex.
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`1050, 39:4-12, 114:4-8, and one which the ’182 patent explicitly says can be an
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`audio input interface, see Ex. 1001, 10:24-26; id., 10:41-47.
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`B. Kenoyer Discloses The Claimed Audio Output Interface
`Claim 6 requires “an audio output interface to provide audio output to an audio
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`receiver”. The claim does not require an audio receiver, as Patent Owner suggests,
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`but instead requires only an interface to an audio receiver, and Kenoyer discloses
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`several, including a headphone jack, Ex. 1006 at Fig. 5; Ex. 1052, ¶44, 48, and a
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`“RCA output,” Ex. 1003 ¶81; Ex. 1006, 12:67-13:3; Ex. 1052, ¶44, 49.
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`Patent Owner also mistakenly interprets an “audio receiver” as a home theater
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`“stereo receiver.” Resp., 16. That definition is inconsistent with the ’182 patent,
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`3
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`Petitioner Microsoft’s Reply
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`where an audio receiver is alternatively described as internal to a display, Ex.
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`1001, 10:59-64, & claim 17.2 This, under the broadest reasonable interpretation
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`consistent with the specification, the claim requires an interface to something that
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`receives audio–an “audio receiver,” such as the speaker port and RCA output
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`disclosed by Kenoyer. Pet., 15; Houh Tr. at 148:19-25.
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`In any event, the headphone jack of Kenoyer’s Fig. 5 is a common audio
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`interface to a stereo receiver. Ex. 1052, ¶48; Ex. 1048 at 16, 23 (receiver with
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`headphone jack for input); Ex. 1056, 1:34-38; Ex. 1057, ¶ 5 (headphone jack input
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`in car audio receivers). The “RCA output” of Kenoyer’s codec is also a typical
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`interface to a stereo receiver, Ex. 1003 ¶ 81; Ex. 1052, ¶49, and one which the ’182
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`patent explicitly says can be an audio output interface, Ex. 1001, 10:24-27.
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`C. Kenoyer Discloses The Claimed Storage Medium
`Claim 6 also requires a “storage medium” having encoded thereon certain
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`computer instructions, Ex. 1001, 33:9-25, which Kenoyer discloses through its
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`description of functionality and its later statement that “[e]mbodiments of a subset
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`or all (and portions or [sic] all) of the above may be implemented by program
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`2 Biscotti incorrectly argues that Dr. Houh’s deposition testimony limits this term
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`to home theater stereo receivers because that interpretation is inconsistent with the
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`‘182 patent’s specification.
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`4
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`Petitioner Microsoft’s Reply
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`instructions stored in a memory medium or carrier medium and executed by a
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`processor.” Ex. 1006, 15:21-24; Pet. at 17-19. Patent Owner contends this passage
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`refers only to a few of the immediately preceding paragraphs, and not to the earlier
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`described functionality of Kenoyer. Resp., 18-19. The passage, however, literally
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`refers to the entire disclosure by using the phrase “a subset or all … of the above.”
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`See Ex. 1052, ¶53; Ex. 1006, 15:21-24. Indeed, the same column later notes that
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`“[f]urther modifications and alternative embodiments of various aspects of the
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`invention may be apparent to those skilled in the art in view of this description.”
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`Ex. 1006, 15:55-57. The statement that “further” modifications of aspects of “the
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`invention” confirms that the earlier passage in column 15 refers to the disclosure as
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`a whole, not just to the top of column 15. Patent Owner also contends that a
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`“handle for carrying the videoconferencing system or a fan for cooling its
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`components” could be the disclosed instructions. Resp., 20. But the average artisan
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`would know that a “handle” or “fan” would not be implemented in program
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`instructions and Kenoyer’s statement is not fairly interpreted to mean that such
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`ordinary structures would be implemented in computer instructions. Ex. 1052, ¶57,
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`Ex. 1050 223:22 – 227:17. 3
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`3 Patent Owner repeats this argument for some dependent claims with
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`“instructions” elements, Resp., 25-27, 31, 37 and is wrong with respect to those
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`5
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`Petitioner Microsoft’s Reply
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`D. Kenoyer Discloses The Claimed Instructions For Encoding And
`Transmitting
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`Kenoyer discloses both using (1) the Internet Protocol (IP) to encode and
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`transmit data and (2) transmitting the encoded audio and video. Ex. 1006, Fig. 5,
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`4:17-27, 8:10-15, 9:27-28, 15:8-20; Ex. 1003, ¶¶246-47. Specifically, Kenoyer’s
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`description of the codec using an IP interface discloses encoding into packets for
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`transmission. Pet., 18-19; Ex. 1006 at Ex. 1006, Fig. 5, 8:10-14, 8:56-9:34, 9:27-
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`28; Ex. 1050, 144:4 – 148:2. And Kenoyer discloses transmitting audio and video,
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`which it previously disclosed as encoded using IP. Pet. at 19; Ex. 1003, ¶246-47;
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`Ex. 1006, 15:11-12. Kenoyer need not disclose both within one paragraph to
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`satisfy the claim, Ex parte Luck, 28 U.S.P.Q.2d 1875-76, and Petitioner is not
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`solely relying on inherency as Patent Owner suggests.
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`Patent Owner argues that Kenoyer discloses networks that might not use IP
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`(Resp., 23), which is irrelevant because Kenoyer specifically discloses
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`embodiments that use IP rather than these alternate network types. Ex. 1003 ¶246;
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`Ex. 1050, 144:10-20, 145:4-21. Patent Owner also argues that the “IP link [is]
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`connected to a computer system 355, and not to the codec 309” (Resp., 22),
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`ignoring that the IP link can connect the codec directly to a network. Ex. 1006,
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`claims for the same reasons demonstrated here. Kenoyer teaches implementing all
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`codec-related functionality as instructions. See Ex. 1006 at 15:21-24.
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`6
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`Petitioner Microsoft’s Reply
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`8:11-15. Patent Owner further contends that “Kenoyer only discloses that ‘signals
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`may be sent/received through a network connection 351,’ without disclosing which
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`signals are transmitted by IP.” Resp., 23. But Kenoyer teaches processing and
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`sending audio and video signals over the network connection: “the local video and
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`audio may be processed in codec 309 for transmission to a remote conference site,”
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`Ex. 1006, 15:11-14; see also Fig. 22; 5:55-64; Ex. 1006, 8:10-14, which it
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`elsewhere explains uses IP in some embodiments, Ex. 1006, 8:10-15; Ex. 1003,
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`¶246.
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`II. Claim 24
`Patent Owner says Kenoyer does not disclose the “receiv[ing]” in claim 24.
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`But as explained above for claim 6, Kenoyer discloses several “video input
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`interface[s]” to receive video input and also discloses that the codec acts as a
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`“pass-through” for a STB, which describes receiving STB video. Ex. 1003, ¶81,
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`234-35; Ex. 1006, 1:65-2:1, 10:25-28 .
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`III. Claims 25, 26, and 28
`Patent Owner argues that Kenoyer does not disclose a “consolidated output
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`stream,” as required by claim 25 and its dependents, citing H.239 “dual streaming”
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`as an alternative explanation of Kenoyer’s disclosure of a shared screen in the
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`context of “regular programming/games”. Resp., 27-28. Patent Owner
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`misunderstands H.239 dual streaming, which allows multiple streams between
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`7
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`Petitioner Microsoft’s Reply
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`networked video conferencing endpoints; Patent Owner identifies no evidence that
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`it has any role with regard to the output stream to the display. See, e.g., Ex. 1052, ¶
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`94-96; Ex. 1050 151:12-19. Confirming this, Kenoyer discloses “dual streaming”
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`is “for sharing PC content during a videoconference,” Ex. 1006, 13:4-6, not the
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`“programming/games” described with respect to sharing the screen. Kenoyer also
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`discloses putting both videos on the same screen at the same time, necessarily
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`making them part of the same output stream. See Ex. 1006, 10:28-30; See, e.g., Ex.
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`1052, ¶97. Thus, displaying the “regular programming/games” and remote video at
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`the same time (Ex. 1006, 10:28-30) necessarily uses a consolidated output stream.4
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`IV. Claims 29 and 31
`Patent Owner contends that displaying incoming streams in their native
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`resolution would be “without allocation” and therefore not satisfy claim 29. Resp.,
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`32. “Allocation,” however, refers to assigning certain pixels in the output stream to
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`the incoming streams, which occurs at any resolution. Ex. 1001, 23:6-9; Ex. 1052,
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`¶101. The ’182 patent explains that allocation occurs even if no scaling, cropping,
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`or down-sampling occurs – i.e., using the video’s native resolution. Ex. 1001, 23:2-
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`5; Ex. 1052, ¶101. Consequently, displaying both “regular programming” and the
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`4 Patent Owner repeats this argument for multiple dependent claims, see Resp., 32,
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`38, and the argument fails for the same reason as for claims 25, 26, and 28.
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`8
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`Petitioner Microsoft’s Reply
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`remote video at the same time, as disclosed in Kenoyer, necessarily requires
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`allocating – i.e., assigning – the pixels making up the display, as claimed. Ex.
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`1003, ¶318, 324; Ex. 1001, Ex. 1001, 23:6-9, 23:2-5.
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`V. Claim 36
`Patent Owner argues that Kenoyer does not disclose a user setting the
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`resolution as required by claim 36, (Resp., 38-39), but the Board instituted trial on
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`this claim based on Kenoyer combined with Briere (Ex. 1033), see Paper 9 at 31.
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`Patent Owner also asserts that Kenoyer and Briere (Ex. 1033) cannot be
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`combined because Briere “does not, on its face, relate to videoconferencing.”
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`Resp., 39. But Briere does relate to, or is at least reasonably pertinent to, the field
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`of video communications, which is the field of endeavor of both the ’182 patent
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`and Kenoyer. See Ex. 1001 at 1:31-33; Ex. 1006 at 1:21-24. Indeed, Briere
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`expressly teaches the use of video communications on a PC, Ex. 1033 at 211-226,
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`and video conferencing in particular on a PC, id. at 213-15. See also Ex. 1050,
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`165:2-11, 166:3-23. As the Petition explains, one of skill would combine the two
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`references because Briere discloses functionality (e.g., setting of output resolution)
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`that would be useful in the system of Kenoyer. Pet., 54-55; Ex. 1033, 120. Such a
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`combination would thus be merely the combination of known techniques according
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`to known methods to achieve a predictable result.
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`Patent Owner also argues that changing the operating system resolution “would
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`9
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`Petitioner Microsoft’s Reply
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`not necessarily have any effect on the resolution that program chose to apply to a
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`given output.” Resp., 39. Briere discloses having the user set the output resolution
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`to the display by telling the operating system what resolution to use for the actual
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`output to the monitor – i.e., the “consolidated output stream.” Ex. 1033 at 120
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`(“This tab lets you select the display size in pixels which are individual points of
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`light in your display. … This slider lets you select the number of pixels displayed
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`on your monitor.”). Nothing in Briere indicates, as Patent Owner argues, that a
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`program can use a different output resolution. See, e.g., Ex. 1052, ¶105-09. Patent
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`Owner also argues “[c]hanging the resolution of the monitor or operating system
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`would … defeat the purpose of specifically requesting the proper resolution from
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`other endpoints in the system.” Resp., 39-40. That is incorrect. Kenoyer describes
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`sending a video conferencing stream to multiple endpoints, some of which may
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`have different resolution capabilities, thereby necessitating resampling, and
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`making it impossible for an endpoint to send a stream appropriate for all recipients.
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`Ex. 1006, 4:28-31; also Ex. 1010, 4:51-62; See, e.g., Ex. 1052, ¶111. Moreover,
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`Briere explains that a user would want to configure the output resolution for
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`ergonomic reasons. See Ex. 1033 at 120.
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`VI. Claim 37
`Patent Owner contends that Kenoyer does not incorporate Ex. 1010 by
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`reference. Resp., 33. But in Hariri v. Lee, 656 F.3d 1331, 1334 (Fed. Cir. 2011) the
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`10
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`Petitioner Microsoft’s Reply
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`Federal Circuit found that the words “[t]he disclosures of the two applications are
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`hereby incorporate[d] by reference” “unequivocal[ly]” incorporated the entire
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`disclosures of the cited references. Id. at 1335. Kenoyer is even more specific in
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`expressly incorporating references in their “entirety.” See Ex. 1006, 3:40-61.
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`Patent Owner’s reliance on an unpublished district court opinion that preceded
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`Hariri, is therefore misplaced, particularly since on appeal of that decision the
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`Federal Circuit explicitly stated it was not addressing incorporation. Skinmedica,
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`Inc. v. Histogen Inc., 727 F.3d 1187, 1207 n. 13 (Fed. Cir. 2013).
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`Patent Owner also contends that the portion of Ex. 1010 cited in the Petition
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`(4:63-5:3) does not disclose the claimed resampling of claim 37 because it
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`“indicates that images are displayed at the same resolution they were sent.” Resp.,
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`34. Not so. The cited passage explains how low resolution video is handled on a
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`high resolution system, or vice versa, requiring resampling. Pet., 30. Indeed, that
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`conclusion is confirmed by the immediately preceding sentence in Ex. 1010, which
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`explains that: “If a video conferencing system can only display a resolution less
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`than the resolution provided by other video conferencing systems, the video
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`conferencing system with the lower supported display resolution may display the
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`other video conferencing system signals at its lower supported display resolution
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`without forcing the other video conferencing systems to display a lower
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`resolution.” Ex. 1010, 4:56-62. Ex. 1010 explains that this resolution change is
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`11
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`Petitioner Microsoft’s Reply
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`performed by scaling the video. See, e.g., Ex. 1010, 6:53-67; Ex. 1052, ¶¶114-121.
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`Further confirming this understanding, Ex. 1010 expressly discloses resampling the
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`received remote video stream. Ex. 1010, 6:53-67; see Ex. 1003, ¶ 102; See, e.g.,
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`Ex. 1052, ¶120. Scaling low resolution video to display it on the higher resolution
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`display is the claimed resampling. Ex. 1052, ¶116.
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`With regard to Section 103, Patent Owner argues that “resampling can be
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`computationally expensive” (Resp., 36), even though it does not argue teaching
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`away or that one of skill could not implement such a predictable variation.
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`Kenoyer already discloses resampling (Ex. 1010, 6:53-67), so Kenoyer already
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`accepts the need to perform resampling computations. The issue is thus whether it
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`would have been obvious for the system of Kenoyer, which included resampling
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`functionality, to resample the remote video stream, not whether it would have
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`“computationally expensive” to do so. Indeed, Kenoyer discloses having both TV
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`and video conferencing on the same screen, see, e.g., Ex. 1006, 10:28-30, which
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`requires making both video streams fit on the screen through resampling. And the
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`incorporated Exhibit 1010 states: "the first and second video conferencing signals
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`may be composited at an MCU or locally at the video conferencing system. The
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`video may not be scaled before being sent to the second video conferencing
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`system,” necessitating resampling on receipt. Ex. 1010 at 5:60-64; See, e.g., Ex.
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`1052, ¶123. The average artisan reading Kenoyer would therefore understand that
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`12
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`Petitioner Microsoft’s Reply
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`the “computational expense” of resampling already provided for in the design of
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`Kenoyer, and thus there was no reason to avoid such functionality.
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`Finally, Patent Owner again argues that the codec could negotiate a different
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`resolution from a remote codec to avoid resampling. But Petitioner does not rely
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`on inherency because Kenoyer discloses resampling the remote video stream. Ex.
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`1010, 6:53-67. And negotiating would not negate the need for resampling when the
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`same stream goes to multiple endpoints. Ex. 1006, 4:28-31; also Ex. 1010, 4:51-
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`62; see, e.g., Ex. 1052, ¶123.
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`VII. Secondary Indicia
`A.
`Patent Owner Misstates When Petitioner Must Respond to Its
`Secondary Indicia Arguments
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`The Board has rejected Patent Owner’s argument that Petitioner must address
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`purported evidence of secondary indicia in the Petition. See, e.g., Resp., 48.
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`Petroleum Geo-Servs. v. Western Geco L.L.C., IPR2014-01475, Paper 18 at 27-28
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`(PTAB Mar. 17, 2015); Sega of America, Inc., et al. v. Uniloc USA, Inc., et al.,
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`IPR2014-01453, Paper 11 at 20 (PTAB Mar. 10, 2015). The Board has also stated
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`Omron case cited by Patent Owner does not stand for that proposition. See, e.g.,
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`Owens Corning v. CertainTeed Corp., IPR2014-01403, Paper 10 at 16 (PTAB
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`Mar. 9, 2015). Petitioner may therefore rebut Patent Owner’s secondary
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`considerations arguments. See, e.g., Owens Corning, IPR2014-01403, paper 10 at
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`16; Chums, Inc., IPR2014-01240, paper 10 at 7-8.
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`13
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`Petitioner Microsoft’s Reply
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`B.
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`Patent Owner Fails to Show The Required Nexus
`1.
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`Patent Owner Fails to Show That Xbox One Falls Within
`Claim 36 and/or 37
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`This IPR instituted under Section 103 on only two claims, claims 36 and 37.
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`Patent Owner contends that claim 36 covers Xbox One but ignores claim 37
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`completely. Resp., 43. Patent Owner fails to show that Xbox One practices each
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`element of the claims from which claim 36 depends, instead just baldly asserting
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`that Xbox One contains the “instructions for” elements of its ultimate parent claim
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`6 and ignoring the intervening parent claims 24 and 25. Resp., 42-44. Patent owner
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`has thus failed to show Xbox One bears any relationship to claims 36 and 37 that
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`could support a finding of secondary considerations of non-obviousness.
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`2.
`Patent Owner’s commercial success contention also fails because it identified
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`Patent Owner’s Commercial Success Argument Fails
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`no evidence comparing Xbox One sales to its overall market, In re Applied
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`Materials, Inc., 692 F.3d 1289, 1300 (Fed. Cir. 2012); that Xbox One’s
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`commercial success relates to the features allegedly corresponding to claims 36
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`and 37, Demaco Corp. v. F. Von Langsdorff Licensing Ltd., 851 F. 2d 1387, 1392
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`(Fed. Cir. 1988); or that “the asserted commercial success of the product [is] due to
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`the merits of the claimed invention beyond what was readily available in the prior
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`art.” J.T. Eaton & Co. v. Atlantic Paste & Glue Co., 106 F.3d 1563, 1571 (Fed.
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`Cir. 1997). See Resp., 44-46.
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`14
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`Petitioner Microsoft’s Reply
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`3.
`Patent Owner also identifies no nexus between the alleged copying and the
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`Patent Owner’s Copying Argument Fails
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`allegedly novel elements in claims 36 and 37. MotivePower, Inc. v. Cutsforth, Inc.,
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`IPR2013-00274, paper 31 at 30 (PTAB Oct. 30, 2014). Patent Owner does not
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`even identify what functionality it (wrongly) asserts Petitioner copied, much less
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`demonstrate that such functionality has a nexus to the allegedly novel elements of
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`claims 36 and 37. See id. Indeed, Patent Owner never shows that its commercial
`
`products contain any elements of claims 36 and 37 (or any claim). See Resp., 46-
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`47. Consequently, no evidence shows any copying of any patented functionality.5
`
`Dated: August 19, 2015
`
`
`
`
`
`Respectfully Submitted,
`
`
`/Joseph Micallef/
`Joseph A. Micallef
`Registration No. 39,772
`Sidley Austin LLP
`1501 K Street NW
`Washington, DC 20005
`
`
`
`
`
`5 Moreover, allowing the user to set the display resolution, which Patent Owner
`
`accuses of satisfying claim 36, was in the older Xbox 360 and thus long pre-dates
`
`any contact between Petitioner and Patent Owner. See Ex. 1061 at 108-09.
`
`
`
`15
`
`
`
`Petitioner Microsoft’s Reply
`
`
`
`PETITIONER MICROSOFT’S REPLY
`
`
`
`Attachment A:
`
`Proof of Service of the Reply
`
`
`
`16
`
`
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`
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`Petitioner Microsoft’s Reply
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 19th day of August 2015, a copy of this Reply,
`
`including all attachments, appendices and exhibits, has been served in its entirety
`
`by E-mail on the following counsel of record for patent owner:
`
`Amanda Hollis
`Kirkland & Ellis LLP
`300 North LaSalle
`Chicago, IL 60654
`amanda.hollis@kirkland.com
`
`Adam Alper
`Kirkland & Ellis LLP
`555 California Street
`San Francisco, CA 94104
`adam.alper@kirkland.com
`
`Michael W. De Vries
`Kirkland & Ellis LLP
`333 South Hope Street
`Los Angeles, CA 90071
`michael.devries@kirkland.com
`
`
`Dated:
`
`August 19, 2015
`
`
`
`
`
`
`
`17
`
`Respectfully submitted,
`
`
`/Joseph Micallef/
`Joseph A. Micallef
`Registration No. 39,772
`Sidley Austin LLP
`1501 K Street NW
`Washington, DC 20005
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