`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`MAKO SURGICAL CORP.,
`Petitioner
`
`v.
`
`BLUE BELT TECHNOLOGIES, INC. and
`CARNEGIE MELLON UNIVERSITY,
`Exclusive Licensee and Patent Owner.
`_____________________
`
`
`
`IPR2015-00630
`
`U.S. Patent No. 6,205,411 B1
`
`_____________________
`
`REPLY TO PETIONTER’S OPPOSITION TO MOTION TO AMEND
`
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`TABLE OF CONTENTS
`
`Page
`
`I.
`
`II.
`
`Introduction ...................................................................................................... 1
`
`DiGioia is not prior art against proposed substitute claims 18–34. ................ 1
`
`(a) Dr. Jaramaz describes facts establishing that the inventive entities of
`
`DiGioia and of the ’411 Patent are identical. ............................................... 1
`
`(b) Mr. Kischell is not an inventor of the subject matter Pet’r relies
`
`upon from DiGioia. ...................................................................................... 4
`
`III.
`
`Proposed claims 18–34 are patentable over DiGioia II, Chao, Taylor
`and O’Toole. .................................................................................................... 5
`
`(a) DiGioia II does not render obvious the Simulating limitations. .................. 6
`
`(b) Chao does not render obvious the Calculating and the Determining
`
`limitations. .................................................................................................... 9
`
`(c) Taylor does not render obvious proposed claims 18–34. ........................... 10
`
`IV. Conclusion and Relief Requested .................................................................. 12
`
`V.
`
`Exhibit List for Inter Partes Review of U.S. Pat. No. 6,205,411 ................. 13
`
`
`
`i
`
`
`
`TABLE OF AUTHORITIES
`
`Page(s)
`
`Cases
`Amgen Inc. v. Hoechst Marion Roussel, Inc.,
`314 F.3d 1313 (Fed. Cir. 2003) ............................................................................ 9
`
`Ashland Oil, Inc. v. Delta Resins & Refractories, Inc.,
`776 F.2d 281 (Fed. Cir. 1985) ............................................................................ 10
`
`Beckman Instruments, Inc. v. LKB Produckter AB,
`892 F.2d 1547 (Fed. Cir. 1989) ............................................................................ 8
`
`Corning Inc. v. DSM IP Assets B.V.,
`IPR2013-00052, Paper 88 (PTAB May 1, 2014) ............................................... 10
`
`Geo M. Martin Co. v. Alliance Mach. Sys. Int’l, LLC,
`618 F.3d 1294 (Fed. Cir. 2010) ............................................................................ 8
`
`Riverwood Int’l Corp. v. R.A. Jones & Co.,
`324 F.3d 1346 (Fed. Cir. 2003) ............................................................................ 4
`
`
`
`
`
`ii
`
`
`
`
`
`
`
`GLOSSARY OF ABBREVIATIONS
`
`
`
`Description
`U.S. Patent No. 6,205,411, provided as Ex. 1001
`E.Y.S. Chao et al., “Simulation and Animation of
`Musculoskeletal Joint System,” Transactions of the
`ASME, Vol. 115, pp. 562-568, Nov. 1993, provided as Ex.
`1007.
`Declaration of Dr. Kevin Cleary, provided as Ex. 2003.
`
`A.M. DiGioia et al., “HipNav: Pre-operative Planning and
`Intraoperative Navigational Guidance for Acetabular
`Implant Placement in Total Hip Replacement Surgery,”
`2nd CAOS Symposium, 1996, provided as Ex. 1005.
`Anthony M. DiGioia III et al., “An Integrated Approach to
`Medical Robotics and Computer Assisted Surgery in
`Orthopaedics,” Proc. 1st Int’l Symposium on Medical
`Robotics and Computer Assisted Surgery, pp. 106-111,
`1995, provided as Ex. 1006.
`Declaration of Robert D. Howe, provided as Ex. 1004.
`
`Deposition Transcript of Dr. Robert Howe, provided as
`Ex. 2006.
`Declaration of Dr. Branislav Jaramaz, provided as Ex.
`2002.
`Deposition Transcript of Dr. Branislav Jaramaz – Filed
`Under Seal, provided as Ex. 1011.
`Declaration of Eric R. Kischell, provided as Ex. 1013
`
`Motion to Amend, Paper No. 12 (Nov. 10, 2015).
`Petitioner’s Opposition, Paper No. 25 (Feb. 19, 2016).
`R.V. O’Toole III et al., “Towards More Capable and Less
`Invasive Robotic Surgery in Orthopaedics,” Computer
`
`iii
`
`Shorthand
`’411 Patent
`Chao
`
`Cleary Decl.
`
`DiGioia
`
`DiGioia II
`
`Howe Decl.
`
`Howe Dep.
`
`Jaramaz Decl.
`
`Jaramaz Dep.
`
`Kischell Decl.
`
`MTA
`Opp.
`O’Toole
`
`
`
`
`
`
`
`
`
`Vision, Virtual Reality and Robotics in Medicine Lecture
`Notes in Computer Science, Vol. 905, pp. 123-130, 1995,
`provided as Ex. 1008.
`Petitioner Mako Surgical Corp.
`Patent Owner Carnegie Mellon University and Exclusive
`Licensee Blue Belt Technologies, Inc.
`Russell H. Taylor et al., An Image-Directed Robotic
`System for Precise Orthopaedic Surgery, IEEE
`Transactions on Robotics and Automation, Vol. 10, No. 3,
`June 1994, provided as Ex. 1009.
`
`iv
`
`Pet’r
`PO
`
`Taylor
`
`
`
`
`
`
`
`
`
`I.
`
`Introduction
`
`Pet’r fails to rebut the patentability arguments in the MTA for two main
`
`reasons. First, Dr. Branislav Jaramaz’s undisputed declaration testimony shows
`
`that DiGioia is not prior art because Eric Kischell did not invent the subject matter
`
`from DiGioia Pet’r alleges to invalidate the claims. Second, Pet’r’s arguments that
`
`DiGioia II, Chao, Taylor, and/or O’Toole render proposed claims 18–34 obvious
`
`are unsupported and fail to account for explicitly recited claim limitations.
`
`II. DiGioia is not prior art against proposed substitute claims 18–34.
`Testimony from ’411 Patent inventor Dr. Jaramaz established that DiGioia is
`
`not prior art because the inventive entities of the portions of DiGioia relied upon
`
`by Pet’r and the ’411 Patent are identical. MTA at 7–11. Pet’r attempts to attack
`
`that testimony by mischaracterizing Dr. Jaramaz’s deposition testimony and by
`
`introducing testimony from a DiGioia co-author named Eric Kischell. Opp. at 2–9.
`
`Neither of those arguments have merit.
`
`(a) Dr. Jaramaz describes facts establishing that the inventive entities of
`DiGioia and of the ’411 Patent are identical.
`
`Dr. Jaramaz established that the inventors of the ’411 Patent also “invented”
`
`the subject matter Pet’r relies upon from DiGioia. Jaramaz Decl., ¶¶ 5–17. Pet’r’s
`
`Kischell Declaration fails to dispute Dr. Jaramaz’s testimony.
`
`Pet’r’s argument that Dr. Jaramaz did not have the “factual knowledge”
`
`1
`
`
`
`
`
`
`
`needed to establish that the inventive entities of DiGioia and the ’411 Patent are
`
`identical is not supported by the testimony. Opp. at 3–4 (citing Jaramaz Dep. at
`
`25:14–26:5). While Dr. Jaramaz does not remember who among a group of eight
`
`people decided to omit Dr. Kanade as an author of DiGioia, Dr. Jaramaz explained
`
`all facts relevant to the inquiry: the team decided to omit Dr. Kanade because he
`
`was not, at the time DiGioia was published, involved in day-to-day research.
`
`Jaramaz Decl., ¶ 11. This is a fact, undisputed by Mr. Kischell. And, Pet’r cites
`
`no law that requires pinpointing who made the decision to omit Dr. Kanade.
`
`Pet’r’s argument that Dr. Jaramaz got the publication date of DiGioia wrong
`
`and thus his memory regarding other facts must be disregarded is based on a false
`
`premise. Opp. at 7–8; Jaramaz Decl., ¶ 8. Dr. Jaramaz did not offer incorrect
`
`declaration testimony about the date DiGioia was published. It was published in
`
`1996—not 1995. Indeed, Pet’r listed DiGioia in the Petition as being published in
`
`1996—but now appears to be trying to argue that it was first presented at the First
`
`Computer Aided Orthopedic Surgery (CAOS) Symposium, in November 1995, not
`
`at the Second CAOS Symposium, which occurred in November 1996. See Opp. at
`
`7–8. Pet’r is wrong for at least three reasons.
`
`First, DiGioia includes three citations to materials published after the First
`
`Symposium in 1995. See DiGioia at 7–8 (citations [3], [5], and [6]). Citations [5]
`
`
`
`2
`
`
`
`
`
`and [6] are to a book titled Reconstructive Surgery of Joints, the earliest
`
`publication of which was December 29, 1995. Screenshot of Product Details on
`
`Amazon.com, provided as Ex. 2010; screenshot of Bibliographic Information on
`
`Google Books, provided as Ex. 2011. As Dr. Jaramaz explained, he could not have
`
`cited these materials before they were published. Jaramaz Dep. at 56:25–57:24.
`
`DiGioia must have been published after December 29, 1995.
`
`Second, the title of DiGioia is almost identical to the presentation Dr.
`
`DiGioia gave at the Second Symposium in 1996. Compare DiGioia (title) to Ex.
`
`2009 (presentation by Dr. DiGioia with the title: “HipNav: Navigational guidance
`
`for acetabular implant placement in THR [Total Hip Replacement]”). The title of
`
`Dr. DiGioia’s presentation at the First Symposium is “Computer assisted planners
`
`and execution systems for total hip replacement surgery” (Ex. 1020)—with no
`
`mention of HipNav at all. Dr. Jaramaz thus testified that the DiGioia paper was
`
`presented at the 1996 conference. Jaramaz Dep. at 57:25–60:17.
`
`Third, Mr. Kischell’s testimony indicates that DiGioia was presented at the
`
`Second Symposium. Mr. Kischell lists DiGioia as being published in the
`
`proceedings of the Second CAOS Symposium in November 1996. Kischell Decl.,
`
`¶ 5. Mr. Kischell also testifies that he “began working for Carnegie Mellon
`
`University (‘CMU’) in July of 1995” and that he “reviewed the draft [of DiGioia]
`
`
`
`3
`
`
`
`
`
`and provided further input and revisions before it was published.” Kischell Decl.,
`
`¶¶ 4, 11. Considering that articles must typically be submitted for publication
`
`weeks before a symposium or conference, Mr. Kischell’s testimony is consistent
`
`with DiGioia being published in November 1996.
`
`Pet’r argues that DiGioia was presented at the First Symposium, citing a
`
`“pdf” version of DiGioia marked as having been presented at the First Symposium
`
`(Ex. 1019), a webpage listing Dr. Jaramaz’s publications, which links to the “pdf”
`
`version (Ex. 1018), and a paper that cites to the “pdf” version of DiGioia (Ex.
`
`1021). Opp. at 7. But as Dr. Jaramaz explained in his deposition, he did not write
`
`or otherwise create the “pdf” version, the webpage, or the citation in the paper, and
`
`believes the dates on these documents are erroneous. Jaramaz Dep. at 60:18–
`
`63:12.
`
`(b) Mr. Kischell is not an inventor of the subject matter Pet’r relies
`upon from DiGioia.
`
`Next, Pet’r argues that Mr. Kischell is an inventor on DiGioia that was
`
`omitted from the ’411 Patent. But that conclusion is not supported by Mr.
`
`Kischell’s testimony. The relevant question is whether Mr. Kischell contributed to
`
`and/or invented aspects of DiGioia paper that Pet’r relied on in its invalidity
`
`analysis. Riverwood Int’l Corp. v. R.A. Jones & Co., 324 F.3d 1346, 1356 (Fed.
`
`Cir. 2003) (the question in determining whether a prior art publication is by
`
`
`
`4
`
`
`
`
`
`another is “whether the portions of the reference relied on as prior art, and the
`
`subject matter of the claims in question, represent the work of a common inventive
`
`entity.”). Mr. Kischell’s testimony clearly establishes that he did not work on the
`
`features or functions described in DiGioia that Pet’r is now relying on. Instead, he
`
`worked only on (1) “integrat[ing] the intra-operative tracking and guidance system
`
`into a graphical user interface that would allow the surgeon to place the implant in
`
`the optimal location”; and (2) “developing software to perform clean-up of image
`
`contours for 3D object reconstruction.” Kischell Decl., ¶¶ 7, 9. Pet’r does not
`
`even argue that either of these contributions is described in DiGioia—for good
`
`reason as these contributions are absent. Instead Pet’r asserts that Mr. Kischell is
`
`“part of the inventive entity of the system included in DiGioia.” Opp. at 5
`
`(emphasis added). But Pet’r’s prior art arguments are not based on the HipNav
`
`system—they are based on specific passages from the DiGioia reference and Mr.
`
`Kischell’s omission of any claim to have worked on the systems described in the
`
`passages relied on by Pet’r in DiGioia confirms Dr. Jaramaz’s testimony. Mr.
`
`Kischell did not invent any subject matter from DiGioia used in Pet’r’s invalidity
`
`analysis related to the ’411 Patent claims at issue here.
`
`III. Proposed claims 18–34 are patentable over DiGioia II, Chao, Taylor and
`O’Toole.
`
`
`
`
`
`The proposed substitute independent claims are patentable over the art of
`
`5
`
`
`
`
`
`record because that art does not disclose or render obvious the “Simulating,”
`
`“Calculating,” and “Determining” limitations of proposed claims 18–34 (the full
`
`text of each is provided at MTA pages 15, 18–23). Pet’r contends that DiGioia II,
`
`Chao, and Taylor teach and/or render these limitations obvious without providing
`
`any additional testimony from its expert declarant.1 Pet’r’s arguments are incorrect
`
`because they do not account for explicit limitations of claims 18–34, particularly
`
`the requirement of a “three dimensional geometric model of the hip joint” and a
`
`“three dimensional component model of the artificial implant.”
`
`(a) DiGioia II does not render obvious the Simulating limitations.
`Relying on Figs. 1 and 2—tellingly without the support of its expert Dr.
`
`Howe—Pet’r argues that DiGioia II discloses a “biomechanical system” that
`
`teaches the Simulating limitations. Opp. at 14–15. But DiGioia II does not
`
`disclose the Simulating limitations, and indeed cannot disclose these limitations
`
`because the authors had not yet developed the requisite “three dimensional
`
`
`
` 1 Pet’r also relies on O’Toole to argue that claims 18–34 would have been
`
`obvious, but does not rely on O’Toole for the Simulating, Calculating, or
`
`Determining limitations. See Opp. at 19–23.
`
`
`
`6
`
`
`
`
`
`models” of the hip joint or the acetabular cup. Fig. 1 of DiGioia II is a proposal for
`
`an integrated approach, not a “biomechanical system” as Pet’r alleges. Fig. 1 is
`
`described in the section of DiGioia II titled “Proposed Integrated Approach” and
`
`illustrates the component technologies that the authors proposed to be integrated
`
`for “the potential of computer assisted surgery to be fully realized in orthopaedics.”
`
`DiGioia II at 107. Indeed, DiGioia II does not caption Fig. 1 as a “biomechanical
`
`system,” but rather “Component technologies combine to improve surgical
`
`technique.” DiGioia II at 108. Section 4 of DiGioia, titled “Current Work,”
`
`explains progress that the authors had made, stating that the authors “are
`
`developing full three-dimensional models (of both the femur and acetabulum)
`
`based upon CT scan data.” DiGioia II at 110. Thus, the authors had not yet
`
`developed a “three dimensional model geometric model of the hip joint,” as recited
`
`in claims 18, 27, and 34, and thus could not have simulated movement of the hip
`
`joint with the artificial component in a test position “using the geometric model of
`
`the hip joint,” as required by the Simulating limitations.
`
`Pet’r’s reliance on Fig. 2 of DiGioia II is similarly problematic. Fig. 2
`
`shows an “[a]xisymmetric model of the insertion of a cementless acetabular cup
`
`into a prepared acetabular cavity.” DiGioia II at 109. But Pet’r does not establish
`
`that this axisymmetric model is a “three dimensional geometric model,” as
`
`
`
`7
`
`
`
`
`
`required by the Simulating limitations. DiGioia II indicates the opposite as it states
`
`that axisymmetric models “idealize the geometry of the implant and the bone by
`
`assuming symmetry.” DiGioia II at 109. Claims 18, 27, and 34, on the other hand,
`
`require the “three dimensional geometric model of the hip joint” to be generated
`
`based on “skeletal data,” not on ideal, symmetric characteristics of a hip joint.
`
`Pet’r argues that DiGioia II nonetheless renders the Simulating limitations
`
`obvious because inoperative devices still constitute prior art. Opp. at 15. But this
`
`rule does not free Pet’r from having to establish that the prior art teaches or renders
`
`obvious all of the limitations of the claims. The two cases that Pet’r cites in the
`
`Opp. at 15 illustrate this flaw in Pet’r’s argument. In Geo M. Martin Co. v.
`
`Alliance Mach. Sys. Int’l, LLC, the Federal Circuit explained:
`
`To be clear, prior art must teach a person of ordinary skill to
`make an apparatus that works for its intended purpose. Beckman
`Instruments, 892 F.2d at 1551. If the [prior art] machine did not do so
`on its own, [the accused infringer] would have needed to establish that
`a person of ordinary skill would have nonetheless been able to make a
`working apparatus. In this case, however, the record shows that the
`[prior art] machine did work, insofar as it was able to do what the
`[the claim] required . . . . The [prior art] machine simply did not work
`at ‘production speed.’ As discussed, however, the claims do not
`require a threshold throughput or commercial speed.
`
`
`
`8
`
`
`
`
`
`618 F.3d 1294, 1303 (Fed. Cir. 2010) (emphasis added) (citing Beckman
`
`Instruments, Inc. v. LKB Produckter AB, 892 F.2d 1547, 1551 (Fed. Cir. 1989)) .
`
`In contrast, DiGioia II does not disclose what the claims require, i.e., the
`
`Simulating limitations. And in Amgen Inc. v. Hoechst Marion Roussel, Inc., the
`
`Federal Circuit explained that a reference qualifies as prior art “for whatever is
`
`disclosed therein.” 314 F.3d 1313, 1357 (Fed. Cir. 2003). But DiGioia II does not
`
`disclose the Simulating limitations. Thus, DiGioia II does not teach or render
`
`obvious the Simulating limitations.
`
`(b) Chao does not render obvious the Calculating and the Determining
`limitations.
`
`
`
`Pet’r also incorrectly asserts that a single sentence in Chao’s “Selection and
`
`planning in total joint replacement” section renders obvious the Calculating and
`
`Determining limitations. Opp. at 16 (citing Chao at 5). The sentence only relates
`
`to simulation of joint pressure and motion; it does not teach one of ordinary skill in
`
`the art how to calculate “a range of motion” based on simulation using a “three
`
`dimensional geometric model of the hip joint” and a “three component model of
`
`the artificial implant,” as required by the Calculating limitations. Chao’s
`
`simulation of joint pressure and motion is based on a Rigid Body Spring Model
`
`(RBSM), but Pet’r provides no indication that an RBSM is a “three dimensional
`
`
`
`9
`
`
`
`
`
`geometric model” of the hip joint, nor does Pet’r point to any disclosure in Chao
`
`describing a “three dimensional component model of the artificial implant.”
`
`
`
`Pet’r’s arguments should further be rejected because they lack the rational
`
`underpinning needed to support an obviousness conclusion. Pet’r relies on ¶ 50 of
`
`the Howe Decl. to support its obviousness analysis. Opp. at 17. But ¶ 50 repeats
`
`the Opp.’s conclusory assertions nearly verbatim, and thus should be not be
`
`entitled to any weight. Corning Inc. v. DSM IP Assets B.V., IPR2013-00052, Paper
`
`88 at 21 (PTAB May 1, 2014) (“One’s expertise, even though draped with a
`
`skilled-artisan veil, does not entitle a naked opinion to much weight.”) (citing
`
`Ashland Oil, Inc. v. Delta Resins & Refractories, Inc., 776 F.2d 281, 294 (Fed. Cir.
`
`1985)).
`
`(c) Taylor does not render obvious proposed claims 18–34.
`As explained in the MTA, Taylor does not render proposed claims 18–34
`
`
`
`obvious because it assumes that the surgeon will provide the implant location, and
`
`thus there was no reason to modify Taylor’s system to allow for pre-operative
`
`simulation. MTA at 15–16 (citing Cleary Decl., ¶ 58). Yet Pet’r contends—
`
`tellingly again without the support of its expert Dr. Howe—that such a
`
`modification would have been obvious. Specifically, on page 18 of the Opp., Pet’r
`
`asserts:
`
`
`
`10
`
`
`
`Similarly here, the system in Taylor could be modified to suggest
`several possible locations for implantation, like the semiautonomous
`SpineAssist tool, and that would still leave the surgeon in control
`while satisfying the requirement of the ’411 patent that the pre-
`operative planning system allow for pre-operative simulation.
`
`But Pet’r does not establish that the SpineAssist tool was prior art as of the
`
`
`
`
`
`priority date of the ’411 Patent. Although PO’s expert Dr. Cleary cited the
`
`SpineAssist tool in his Declaration, he did not concede that it was prior art. To the
`
`contrary, Dr. Cleary cited the SpineAssist tool as an example of “commercial pre-
`
`operative planning tools [that] remain semiautonomous to this day.” Cleary Decl.,
`
`¶ 46 (emphasis added). Moreover, Pet’r does not provide any evidence to support
`
`its claim that Taylor could have been modified to “suggest several possible
`
`locations for implantation.” Opp. at 18. Pet’r’s vague allegations do not explain
`
`what components of Taylor would be modified and what, if any, disclosure in
`
`Taylor indicates that those modifications would have been feasible. Accordingly,
`
`proposed substitute claims 18, 27, and 34 would not have been obvious over
`
`Taylor.
`
`
`
`
`
`
`
`11
`
`
`
`
`
`IV. Conclusion and Relief Requested
`For the reasons provided in the MTA as well as those provided above, PO
`
`respectfully requests that the Board grant the Motion to Amend in the event that it
`
`finds claims 1–17 of the ’411 Patent unpatentable.
`
`Dated: February 24, 2016
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`By: /Brian M. Buroker/
`
`
`
`Brian M. Buroker (Reg. No. 39,125)
`
`
`12
`
`
`
`
`
`V. Exhibit List for Inter Partes Review of U.S. Pat. No. 6,205,411
`
`Exhibit Description
`
`Exhibit #
`
`Robert D. Howe & Yoky Matsuoka, Robotics for Surgery, Annu.
`Rev. Biomed Eng., 212–40, 220 (1999) (“Robotics for Surgery”)
`Declaration of Dr. Branislav Jaramaz (“Jaramaz Decl.”)
`Declaration of Dr. Kevin Cleary (“Cleary Decl.”)
`U.S. Patent No. 5,880,976 (“the ’976 Patent”)
`U.S. Patent No. 6,002,859 (“the ’859 Patent”)
`Deposition Transcript of Dr. Robert Howe (“Howe Depo.”)
`’411 Patent Original Specification (“the ’411 Original Spec.”)
`’976 Patent Original Specification (“the ’976 Original Spec.”)
`2nd CAOS Symposium Final Program, November 7–9, 1996
`Reconstructive Surgery of the Joints – Amazon Screenshot
`Reconstructive Surgery of the Joints – Google Books Screenshot
`
`
`
`2001
`
`2002
`2003
`2004
`2005
`2006
`2007
`2008
`2009
`2010
`2011
`
`
`
`13
`
`
`
`
`
`
`
`CERFITICATE OF SERVICE
`
`The undersigned certifies service pursuant to 37 C.F.R. § 42.6(e) of a copy
`
`of this Reply to Petitioner’s Opposition to Motion to Amend by electronic mail on
`
`February 24, 2016 on the counsel of record of the Petitioner:
`
`Matthew I. Kreeger, mkreeger@mofo.com
`
`Walter Wu, wwu@mofo.com
`
`
`
`Dated: February 24, 2016
`
`By: /Brian M. Buroker/
`
`
`
`Brian M. Buroker (Reg. No. 39,125)
`GIBSON, DUNN & CRUTCHER LLP
`1050 Connecticut Avenue, N.W.
`Washington, DC 20036-5306
`Telephone: 202.955.8500
`Facsimile: 202.467.0539
`bburoker@gibsondunn.com