UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`RF CONTROLS, LLC,
`Petitioner
`
`v.
`
`A-1 PACKAGING SOLUTIONS, INC.,
`Patent Owner
`
`_______________
`
`Patent 8,690,057
`Issue Date: April 8, 2014
`
`Title: RADIO FREQUENCY IDENTIFICATION SYSTEM FOR TRACKING
`AND MANAGING MATERIALS IN A MANUFACTURING PROCESS
`_______________
`
`Cases: IPR2014-01536
`IPR2015-00119
`_______________
`
`PATENT OWNER RESPONSE
`UNDER 37 C.F.R. § 42.120
`
`Pursuant to 37 C.F.R. § 42.120, please consider the following Patent Owner
`
`Response to the Decision of Institution of Inter Partes Review 37 C.F.R. § 42.108,
`
`issued March 30, 2015, for IPR2014-01536, and the Decision of Institution of Inter
`
`Partes Review 37 C.F.R. § 42.108, issued April 29,2015, for IPR2015-00119, in
`
`the above-identified matter.
`
`
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`RF CONTROLS, LLC,
`Petitioner
`
`v.
`
`A-1 PACKAGING SOLUTIONS, INC.,
`Patent Owner
`
`_______________
`
`Patent 8,690,057
`Issue Date: April 8, 2014
`
`Title: RADIO FREQUENCY IDENTIFICATION SYSTEM FOR TRACKING
`AND MANAGING MATERIALS IN A MANUFACTURING PROCESS
`_______________
`
`Cases: IPR2014-01536
`IPR2015-00119
`_______________
`
`PATENT OWNER RESPONSE
`UNDER 37 C.F.R. § 42.120
`
`Pursuant to 37 C.F.R. § 42.120, please consider the following Patent Owner
`
`Response to the Decision of Institution of Inter Partes Review 37 C.F.R. § 42.108,
`
`issued March 30, 2015, for IPR2014-01536, and the Decision of Institution of Inter
`
`Partes Review 37 C.F.R. § 42.108, issued April 29,2015, for IPR2015-00119, in
`
`the above-identified matter.
`
`
`
`TABLE OF CONTENTS
`
`I.
`
`Introduction ..................................................................................................1
`
`A.
`
`B.
`
`Statement of Relief Requested...........................................................1
`
`Grounds for Review ...........................................................................1
`
`II.
`
`Legal Authority.............................................................................................2
`
`A.
`
`B.
`
`C.
`
`D.
`
`Burden of Proof..................................................................................2
`
`Anticipation........................................................................................2
`
`A Limitation is Not Intended Use if Closely Tied to Structure
`in the Claim and Therefore Entitled to Patentable Weight................3
`
`Limitations Reciting Unobvious Functions are not Merely
`Descriptive and Therefore Entitled to Patentable Weight .................4
`
`III.
`
`Claims 1, 17, and 27 are not Anticipated by Hofer/Bloy.............................4
`
`A.
`
`“Inventory tracking” and “inventory item information”
`limitations should be entitled to patentable weight............................4
`
`1.
`
`2.
`
`The “inventory tracking” aspects of the claims are
`more than intended use; they are closely tied to
`structure giving them patentable weight..................................6
`
`The “inventory item information” limitations are more
`than descriptive; they provide an unobvious functional
`relationship giving them patentable weight.............................9
`
`B.
`
`Hofer/Bloy does not include an enabling disclosure for
`applying RFID tags in the application of inventory
`management .....................................................................................11
`
`IV.
`
`Conclusion..................................................................................................13
`
`i
`
`
`
`TABLE OF AUTHORITIES
`
`CASES
`Elan Pharm., Inc. v. Mayo Found. For Med. Educ. & Research, 346 F.3d
`1051 (Fed. Cir. 2003).................................................................................2, 11
`
`Impax Labs. Inc. v. Aventis Pharm, Inc., 468 F.3d 1366 (Fed. Cir. 2006)..........3, 11
`
`In re Hoeksema, 399 F.2d 269 (CCPA 1968)............................................................2
`
`In re Lowry, 32 F.3d 1579 (Fed. Cir. 1994)...............................................................4
`
`In re Ngai, 367 F.3d 1336 (Fed. Cir. 2004)...............................................................4
`
`K-2 Corp. v. Solomon S.A. et al, 191 F.3d 1356 (Fed. Cir. 1999).............................3
`
`Richardson v. Suzuki Motor Co., 868 F.2d 1226 (Fed. Cir. 1989)............................2
`
`Typhoon Touch Technologies, Inc. v. Dell, Inc., 659 F.3d 1376 (Fed. Cir.
`2011) ................................................................................................................3
`
`Verdegaal Bros. v. Union Oil Co. of California, 814 F.2d 628 (Fed. Cir.
`1987) ................................................................................................................2
`
`STATUTES
`
`35 U.S.C. § 316..........................................................................................................2
`
`OTHER AUTHORITIES
`
`MPEP § 2121 .............................................................................................................2
`
`MPEP § 2122 .............................................................................................................3
`
`ii
`
`
`
`I.
`
`Introduction
`
`Patent Owner A-1 Packaging, Inc. (hereinafter “Patent Owner”) respectfully
`
`submits its Response under 35 U.S.C. §§311–319 and 37 C.F.R. §42.120.
`
`It is
`
`timely filed by June 26, 2015 (the deadline listed in the IPR2014-01536
`
`Scheduling Order entered on March 3, 2015 ).
`
`A.
`
`Statement of Relief Requested
`
`Pursuant to 35 U.S.C. §316, Patent Owner respectfully requests that the
`
`Patent Trial And Appeal Board (“the Board”) find that originally issued claims 1,
`
`17, and 27 of U.S. Patent No. 8,690,057 (“the ‘057 Patent,” Exh. 1001) are not
`
`invalid and, specifically, that these claims are patentable in view of the grounds
`
`under consideration.
`
`B.
`
`Grounds for Review
`The present inter partes review is a consolidation of IPR2014-01536 and
`
`IPR2015-00119. The Board instituted the present consolidated inter partes review
`
`on the following grounds:
`
`(1)
`
`(2)
`
`Independent claim 1 as anticipated by Hofer/Bloy (Exh. 1008)
`(IPR2014-01536); and
`Independent claims 17 and 27 as anticipated by Hofer/Bloy (IPR2015-
`00119).
`
`1
`
`
`
`II.
`
`Legal Authority
`
`A.
`
`Burden of Proof
`In an inter partes review, “the petitioner shall have the burden of proving a
`
`proposition of unpatentability by a preponderance of the evidence.” 35 U.S.C. §
`
`316(e) (2011).
`
`B.
`
`Anticipation
`
`To invalidate a patent as anticipated, a petitioner must demonstrate that
`
`“each and every element as set forth in the claim is found, either expressly or
`
`inherently described, in a single prior art reference.” Verdegaal Bros. v. Union Oil
`
`Co. of California, 814 F.2d 628, 631 (Fed. Cir. 1987). “The identical invention
`
`must be shown in as complete detail as is contained in the . . . claim.” Richardson
`
`v. Suzuki Motor Co., 868 F.2d 1226, 1236 (Fed. Cir. 1989).
`
`To determine the amount of a prior art disclosure necessary to find a
`
`patented invention ‘not novel’ or ‘anticipated,’ the test is whether a reference
`
`contains an ‘enabling disclosure’... .”
`
`In re Hoeksema, 399 F.2d 269 (CCPA
`
`1968). Merely reciting the subject matter is insufficient if it cannot be produced
`
`without undue experimentation. Elan Pharm., Inc. v. Mayo Found. For Med.
`
`Educ. & Research, 346 F.3d 1051, 1054 (Fed. Cir. 2003); see also MPEP § 2121.
`
`A prior art reference provides an enabling disclosure and thus anticipates a claimed
`
`invention if the reference describes the claimed invention in sufficient detail to
`
`enable a person of ordinary skill in the art to carry out the claimed invention. See
`
`2
`
`
`
`Impax Labs. Inc. v. Aventis Pharm, Inc., 468 F.3d 1366, 1383 (Fed. Cir. 2006); see
`
`also MPEP § 2122.
`
`C.
`
`A Limitation is Not Intended Use if Closely Tied to Structure in
`the Claim and Therefore Entitled to Patentable Weight
`
`Functional language is given patentable weight when sufficiently tied to
`
`structure recited in the claim. See Typhoon Touch Technologies, Inc. v. Dell, Inc.,
`
`659 F.3d 1376, 1380 (Fed. Cir. 2011) (holding that functional language associated
`
`with structure required to perform the function is entitled to patentable weight); see
`
`also IPR 2014-00392 (“[i]n order to modify the drive signal to maintain oscillation,
`
`the control
`
`system must have appropriate structure (e.g., a programmed
`
`microprocessor) to achieve the claimed function”); see also K-2 Corp. v. Solomon
`
`S.A. et al, 191 F.3d 1356, 1363 (Fed. Cir. 1999) (“the functional language tells us
`
`something about the structural requirements of the attachment between the bootie
`
`and the base”).
`
`Claim terms that limit the claimed invention functionally, and that describe
`
`the intended use of an invention through defining characteristics are also entitled to
`
`patentable weight. See IPR2013-00312 (Doc. 26 at 13-14) (“first information” and
`
`“second information” entitled to patentable weight because they are related
`
`functionally to “an electronic communication”); see also IPR 2013-00252 (Doc. 12
`
`at 11) (“for providing continuous decompressed video data to an output” entitled to
`
`patentable weight because continuous output is fundamental to the invention).
`
`3
`
`
`
`D.
`
`Limitations Reciting Unobvious Functions are not Merely
`Descriptive and Therefore Entitled to Patentable Weight
`
`While purely descriptive language is not entitled to patentable weight,
`
`descriptive limitations that define a functional, distinctive characteristic of the
`
`invention are.
`
`See IPR2013-00595 (Doc. 14 at 20-21) (bar code processing
`
`module actually describes distinctive characteristics of the invention, rather than
`
`simply describing a type of module); see also In re Lowry, 32 F.3d 1579, 1582–83
`
`(Fed. Cir. 1994) (data structures and information entitled to patentable weight
`
`because “information” was linked to the physical structure, memory, stating that
`
`the claimed information in “[the patentee’s] claims define functional characteristics
`
`of the memory”); In re Ngai, 367 F.3d 1336, 1338 (Fed. Cir. 2004).
`
`III. Claims 1, 17, and 27 are not Anticipated by Hofer/Bloy
`
`Several of the inventory tracking and inventory item information limitations
`
`defining the invention should be given patentable weight, and Hofer/Bloy does not
`
`provide an enabling disclosure for those limitations of claims 1, 17, or 27.
`
`A.
`
`“Inventory tracking” and “inventory item information”
`limitations should be entitled to patentable weight
`
`The Board preliminarily gave patentable weight to the computer operations
`
`regarding the tracking and access systems recited in the independent claims, but
`
`found that “the inventory tracking aspect of those limitations is an intended use in
`
`the claim.” See Decision of IPR 2014-01536 (Doc. 10 at 13) and Decision of IPR
`
`2015-00119 (Doc. 10 at 13).
`
`Similarly,
`
`the Board preliminarily found that
`
`4
`
`
`
`“‘inventory item identification information defining the identity of the inventory
`
`item, and an indication of the current physical location of the inventory item is
`
`non-functional descriptive material related to the RFID tag which lacks patentable
`
`weight.’” See Decision of IPR 2015-00119 (Doc. 10 at 13-14).
`
`Patent Owner respectfully disagrees. Even assuming that the “inventory
`
`tracking” limitations recite an intended use, these limitations are closely tied to
`
`structure in the claims, entitling them to patentable weight. And the “inventory
`
`item information” limitations are important functional
`
`limitations, more than
`
`merely descriptive. Collectively, these “inventory” aspects of the claims impart
`
`meaningful limitations on the invention, differentiating it from RFID tracking
`
`systems that do not manage inventory.
`
`Tracking inventory, according to claims 1, 17, and 27 of the ‘057 patent,
`
`requires not only tracking the location of an RFID tag, but also tracking
`
`information about the items the RFID tags represent. For example, a store security
`
`system may sound an alarm when an article of clothing with an RFID tag exits the
`
`store. But this system knows nothing of the particular article of clothing. The
`
`inventory tracking system of claims 1, 17, and 27, on the other hand, not only
`
`tracks the location of the items, but also manages information about the inventory,
`
`like what it is, or how long it has been on the shelf.
`
`5
`
`
`
`1.
`
`The “inventory tracking” aspects of the claims are more
`than intended use; they are closely tied to structure giving
`them patentable weight
`
`The Board preliminarily found that the “inventory tracking” aspects of the
`
`claims recite only an intended use. But the inventory aspect of the claims is much
`
`more than that. The “inventory tracking” limitations describe aspects of tracking
`
`that are particular to inventory (as opposed to tracking other things) and,
`
`importantly, those limitations are intertwined with multiple structural components
`
`of
`
`the claims, and the functions of
`
`those structural components—such as
`
`“memory” (which stores inventory tracking information), the “access system”
`
`(which accesses the inventory tracking information), and the “tracking system”
`
`(which updates the inventory information in memory).
`
`These functions,
`
`collectively, describe part of what makes an inventory tracking system different:
`
`that it tracks not only the location of an RFID tag, but the identity/quantity/etc. of
`
`the items the RFID tag represents.
`
`For example, in IPR2014-00392, the Board gave patentable weight to a
`
`claim limitation directed to a control system, “operable to modify the drive signal
`
`and thereby maintain oscillation of the flowtube,” holding that the phrase “thereby
`
`maintain oscillation of the flowtube” required that the control system have the
`
`appropriate structure to modify the drive signal and achieve the claimed function.
`
`Id. at 9. And, this IPR decision is directly supported by the Federal Circuit’s
`
`6
`
`
`
`Typhoon decision discussed above.
`
`In the present case, applying this law means
`
`that Patent Owner’s tracking system limitations describe functions of claimed
`
`structure:
`
`the memory,
`
`the access system, and the tracking system, and are
`
`therefore entitled to patentable weight.
`
`Specifically, independent claim 1 recites an inventory tracking system that
`
`includes “a memory for storing … inventory item information defining the identity
`
`of the inventory item,” and “an access system that accesses the memory and
`
`provides at least a subset of the inventory item information for one or more of the
`
`inventory items to a user.” Independent claim 1 further specifies that “the tracking
`
`system updates the indication of the current physical location of at least one
`
`particular inventory item .
`
`.
`
`. based on the indication of the current physical
`
`location of the one or more detected radio frequency tags for at the least one
`
`particular inventory item as produced by the detection controller.” ‘057 Patent,
`
`Claim 1.1
`
`Just as a control system requires an appropriate structure to maintain
`
`oscillation in a flowtube, the memory, access system, and detection controller have
`
`an associated physical
`
`structure to facilitate updating of
`
`inventory item
`
`information. Inventory item information stored in the memory includes data that is
`
`1 This claim language is also repeated in independent method claims 17 and 27 for
`
`the operations of “storing,” “updating,” and “accessing” data from memory.
`
`7
`
`
`
`written and rewritten to reflect physical
`
`locations of, and other necessary
`
`information about, the inventory.
`
`The inventory tracking limitations, therefore, are inextricably linked to the
`
`structure of the “memory,” the “access system,” and the “tracking system.” The
`
`memory stores the inventory item information2, the access system accesses the
`
`inventory item information from the memory3, and the tracking system updates the
`
`inventory item information accessible in the memory4.
`
`These inventory tracking features are not merely an intended use of an RFID
`
`tracking system, but are functional limitations describing interoperability between
`
`the memory, access system, and tracking system structures. These limitations, in
`
`other words, describe how an RFID inventory tracking system works differently
`
`2 See ‘057 Patent, 17:13-19, “the processor 25 may run a tracking controller using
`
`and/or including the memory 26. . .which may, in turn, store inventory and
`
`manufacturing item information.”
`
`3 See ‘057 Patent, 17:16-18:2, “an access system that enables a user to access the
`
`location information for the RFID tags as stored in the database 28.”
`
`4 See ‘057 Patent, 19:54-59, “[t]he command system 12 may then use these RFID
`
`records (the locations of which are being constantly updated by the RFID detection
`
`and tracking system) to perform various process, inventory and shipping
`
`management or control functions”
`
`8
`
`
`
`from non-inventory RFID tracking systems. See In re Lowry, 32 F.3d 1579, 1583–
`
`84 (“[m]ore than mere abstraction … the data structures provide tangible benefits:
`
`data stored in accordance with the claimed data structures are more easily
`
`accessed, stored, and erased…The Board is not at
`
`liberty to ignore such
`
`limitations”).
`
`2.
`
`The “inventory item information” limitations are more than
`descriptive; they provide an unobvious functional
`relationship giving them patentable weight
`
`The Board found that “‘inventory item identification information” that
`
`defines (1) the physical location of the inventory item, and (2) its identity, “is non-
`
`functional descriptive material related to the RFID tag which lacks patentable
`
`weight.” See Decision of IPR 2014-01536 (Doc. 10 at 13). But only the first of
`
`the two pieces of information associated with “inventory item identification
`
`information” is describing the RFID tag—the physical location.
`
`The second piece of information—“the identity of the inventory item”—has
`
`nothing to do with the RFID tag. Rather, the “identity of the inventory item” is an
`
`important limitation that defines the invention of inventory tracking over other
`
`kinds of RFID tracking. In an inventory tracking system, it is not enough to simply
`
`know the physical location of the RFID tag. The system must also know the
`
`identity of the goods the RFID tag represents. Because these terms have important
`
`9
`
`
`
`functional limitations, they are more than merely descriptive and should be given
`
`patentable weight.
`
`In IPR2013-00595, the Board gave patentable weight to a limitation reciting
`
`information (i.e. bar code symbols) in a bar code processing module because that
`
`information limited the invention in a way other information did not:
`
`to identify representations of bar code symbols, distinct
`from other types of descriptive material that may exist in
`collected image data, requires identification of the bar
`code symbol patterns and discrimination among other
`types of information. As such, the limitation sufficiently
`defines a functional distinction for us to afford the
`limitation patentable weight.
`
`Id. at 21 (emphasis added). Likewise, the “inventory item information” of claims
`
`1, 17, and 27 limits the RFID tracking system to a system in which not only the
`
`location of the RFID tag is tracked, but information about what that RFID tag
`
`represents is stored, accessed, and updated. Additionally, if this language is
`
`ignored as merely descriptive, other limitations in the claim become confused and
`
`unworkable. For example,
`
`the “access system” limitation must “access[] the
`
`10
`
`
`
`memory” and provide “a subset of the [].” If “inventory item information” is not
`
`limiting, then what subset is the access system providing?5
`
`B.
`
`Hofer/Bloy does not include an enabling disclosure for applying
`RFID tags in the application of inventory management
`
`The Board determined that “Hofer (with Bloy) is directed at least in part to
`
`inventory management.” See Decision of IPR 2014-01536 (Doc. 10 at 12-13). But
`
`to anticipate the independent claims, Hofer/Bloy (Exh. 1008) must be more than
`
`that. The test is whether Hofer/Bloy provides an enabling disclosure of Patent
`
`Owner’s inventory management system as recited in the claims. Elan Pharm, 346
`
`F.3d 1051, 1054 (Fed. Cir. 2003). It does not.
`
`Hofer/Bloy does not describe any features of inventory management using
`
`RFID tags, let alone describe them in sufficient detail to enable a person of
`
`ordinary skill in the art to carry out the claimed invention. See Impax Labs. Inc.,
`
`468 F.3d 1366, 1383 (Fed. Cir. 2006). Rather, Hofer/Bloy provides, in just one
`
`sentence, a passing reference to “inventory control.” That sentence states, “[t]he
`
`invention provides direction and velocity tracking, useful for example to identify
`
`movement of targets into areas where additional actions may be desired, such as
`
`5 Again, this claim language is repeated in independent method claims 17 and 27
`
`for the operations of “storing,” “updating,” and “accessing” data from memory.
`
`11
`
`
`
`user access, process control, inventory control and/or theft prevention.” Exh.
`
`1008, 23-24 (Bloy at 21-22).
`
`In other words, Hofer/Bloy’s one sentence only generally recites that an
`
`RFID tracking system may provide direction and velocity tracking. But this is just
`
`a generic function. Most, if not all, systems using RFIDs may provide direction
`
`and velocity tracking simply by monitoring the location of RFID tags over time.
`
`As mentioned above, retailers often use security systems to track stock items with
`
`RFID tags by sounding an alarm if a tag leaves the store. But these security
`
`systems reveal nothing about the item itself.
`
`At best, it is this kind of basic RFID tracking system that Hofer/Bloy
`
`describes because it says nothing about implementing an RFID system to track
`
`inventory.
`
`The ‘057 Patent claims,
`
`read together with the ‘057 Patent
`
`specification, do. For example, independent claim 1 of the ‘057 Patent recites
`
`limitations that provide for tracking an RFID’s tag’s whereabouts, but claim 1 also
`
`requires “provid[ing] at least a subset of the inventory item information for one or
`
`more of the inventory items to a user.”
`
`In other words, the claims differentiate between simply locating RFID tags,
`
`a feature of all basic RFID systems, and the specific inventory tracking application
`
`that requires providing and managing a subset of inventory information, i.e.
`
`information about the very things (inventory items) the RFID is tracking. The ‘057
`
`12
`
`
`
`Patent claims a system that identifies not only where a crate is located in the
`
`warehouse, but also that the crate contains apples (or even the age of the apples,
`
`the type of apples, etc.). Hofer/Bloy says nothing about this latter feature, also
`
`known as “inventory item information.” Without knowing information about the
`
`inventory in addition to the physical locations of the inventory itself, a user
`
`attempting to manage inventory with the Hofer/Bloy system is left with a
`
`disorganized pool of tag locations and no link between the tags and what they are
`
`attached to.
`
`While Hofer/Bloy makes a generic statement about identifying RFID tag
`
`movement “where additional actions may be desired,” it goes no further in
`
`explaining what
`
`those “additional actions” may be, or how such “additional
`
`actions” might be related to inventory management.
`
`The language of independent claims 17 and 27 also similarly recites steps
`
`specific to inventory management using RFID tags with operations like “storing,”
`
`“updating,” and “accessing” inventory item information from a memory.
`
`IV. Conclusion
`
`RF Controls, LLC has failed to satisfy its burden of proof, and claims 1, 17,
`
`and 27 are not unpatentable based on the grounds at issue in this consolidated inter
`
`partes review. Hofer/Bloy does not include an enabling disclosure regarding the
`
`inventory management functions, and therefore Hofer/Bloy does not anticipate
`
`13
`
`
`
`claims 1, 17, and 27. Furthermore, the inventory tracking and inventory item
`
`identification features recited in the claims are functional and do not recite an
`
`intended use or non-functional descriptive material, and thus are entitled to
`
`patentable weight.
`
`The Patent Trial and Appeal Board is hereby authorized to charge any fees
`
`associated with the Inter Partes Review No. 2014-01536 of U.S. Patent No.
`
`8,690,057 to Deposit Account No. 13-2855, under Order No. 31440/10014.
`
`Customer No. 04743
`
`Respectfully submitted,
`
`/Roger A. Heppermann #37,641/
`Roger A. Heppermann (Reg. No. 37,641)
`Lead Counsel for Patent Owner
`
`Benjamin T. Horton
`Back-up Counsel for Patent Owner
`
`Shawn M. Buchanan (Reg. No. 65,064)
`Back-up Counsel for Patent Owner
`
`MARSHALL, GERSTEIN & BORUN LLP
`6300 Willis Tower
`233 South Wacker Drive
`Chicago, Illinois 60606-6357
`Telephone: (312) 474-6300
`Docket@marshallip.com
`
`14
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6 and agreement of the parties, I hereby certify
`
`that a copy of the foregoing PATENT OWNER RESPONSE, was served on the
`
`date indicated below, by electronic mail upon the following:
`
`Michael Hickey
`LEWIS RICE LLC
`ATTN: BOX IP DEPT.
`600 WASHINGTON, SUITE 2500
`ST. LOUIS, MO 63101
`T. 314.444.7630
`mhickey@lewisrice.com
`
`June 26, 2015
`
`Kirk A. Damman
`LEWIS RICE LLC
`ATTN: BOX IP DEPT.
`600 WASHINGTON, SUITE 2500
`ST. LOUIS, MO 63101
`T. 314.444.7783
`kdamman@lewisrice.com
`
`Benjamin B. Siders
`LEWIS RICE LLC
`ATTN: BOX IP DEPT.
`600 WASHINGTON, SUITE 2500
`ST. LOUIS, MO 63101
`T. 314.444.7805
`bsiders@lewisrice.com
`
`/Roger A. Heppermann #37,641/
`Roger A. Heppermann
`MARSHALL, GERSTEIN & BORUN LLP
`
`15
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