UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_______________
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`LG DISPLAY CO., LTD.
`Petitioner
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`v.
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`SURPASS TECH INNOVATION LLC
`Patent Owner
`_______________
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`Case: IPR2015-00885
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`Patent 7,202,843
`_______________
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`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE TO
`PETITION
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`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_______________
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`LG DISPLAY CO., LTD.
`Petitioner
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`v.
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`SURPASS TECH INNOVATION LLC
`Patent Owner
`_______________
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`Case: IPR2015-00885
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`Patent 7,202,843
`_______________
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`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE TO
`PETITION
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`TABLE OF CONTENTS
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`Page
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`INTRODUCTION .......................................................................................... 1
`I.
`II. ARGUMENT .................................................................................................. 2
`A.
`Claim 4 does not require overdriving ................................................... 4
`B.
`Even if claim 4 requires overdriving, Lee still anticipates claims
`4, 8, and 9 ........................................................................................... 11
`III. CONCLUSION ............................................................................................. 18
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`Petitioner’s Reply to Patent Owner’s Response
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`I.
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`INTRODUCTION
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`In its September 8, 2015 Decision, the Board correctly found there was a
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`reasonable likelihood Petitioner would prevail in establishing that claims 4, 8, and
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`9 of the ’843 patent are unpatentable.1 Paper 9, Decision at 12. Patent Owner’s
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`(“Surpass”) Response fails to rebut, or even address, Petitioner’s arguments.
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`Instead, Surpass mischaracterizes Petitioner’s positions and the opinions and
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`testimony of its expert, Dr. Richard Zech. Surpass also proffers an overly narrow
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`interpretation of independent claim 4, which ironically only serves to bolster
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`Petitioner’s position that claims 4, 8, and 9 are anticipated by the Lee reference.
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`Surpass’s Response boils down to two arguments: (1) claim 4 requires
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`“overdriving,” and (2)
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`the Lee reference must disclose overshooting or
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`undershooting in each subframe to satisfy all limitations of claim 4. The first
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`argument is belied by the plain language of the claims. Claim 4 does not recite
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`“overdriving.” Claim 1 (not at issue in this proceeding) does. It is axiomatic that
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`each patent claim is presumed to have a different scope. See Versa Corp. v. Ag-
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`1 On February 26, 2016, the Board issued a final decision in IPR2015-00021,
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`holding that claims 4, 8, and 9 of the ’843 patent are unpatentable as anticipated by
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`U.S. Patent Application Publication No. 2004/0196229 (“Ham”). Sharp Corp., et
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`al. v. Surpass Tech Innovation LLC, Case IPR2015-00021, Paper 44.
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`1
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`Petitioner’s Reply to Patent Owner’s Response
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`Bag Int'l Ltd., 392 F.3d 1325, 1329 (Fed. Cir. 2004). And Surpass has failed to
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`proffer any reasonable argument or evidence for overcoming this presumption.
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`This argument is further inconsistent with the Board’s final decision in IPR2015-
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`00021, holding that claim 4 does not require “overdriving.” Sharp Corp., et al. v.
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`Surpass Tech Innovation LLC, Case IPR2015-00021, Paper 44 at 11.
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`The second argument is predicated on a complete mischaracterization of
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`Petitioner’s arguments, as well as a betrayal of the ’843 patent’s explicit definition
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`for “overdriving,” which Surpass’s own expert has endorsed. Even accepting all of
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`Surpass’s flawed and unsupported arguments, a plain review of the record to date
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`and the arguments and evidence presented herein shows that claims 4, 8, and 9 are
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`anticipated by Lee.
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`In view of the foregoing, and the arguments and evidence set forth below,
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`Petitioner respectfully requests that the Board find the challenged claims
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`unpatentable on the instituted ground.
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`II. ARGUMENT
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`As a preliminary matter, Surpass and its expert concede that Lee discloses
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`the rudimentary limitations of claim 4, namely:
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`a plurality of scan lines;
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`2
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` plurality of data lines; and
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` a
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`a plurality of pixels, each pixel being connected to a corresponding scan line
`and a corresponding data line, and each pixel comprising a liquid crystal
`device and a switching device connected to the corresponding scan line, the
`corresponding data line, and the liquid crystal device, and
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`receiving continuously a plurality of frame data;
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`Ex. 1001, ’843 Patent, Claim 4. Nor do Surpass or its expert challenge whether Lee
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`discloses the additional limitations of claims 8 and 9:
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`8. The method of claim 4 further comprising: applying a scan line voltage to
`the switch device of the pixel via the scan line connected to the pixel in
`order to have the data impulses be applied to the liquid crystal device of the
`pixel.
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`9. The method of claim 4 wherein each frame data comprises a plurality of
`pixel data, and each pixel data corresponds to a pixel.
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`Id. at Claims 8 and 9. Instead, Surpass focuses on the latter two limitations of
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`claim 4:
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`generating a plurality of data impulses for each pixel within every frame
`period according to the frame data, and
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`applying the data impulses to the liquid crystal device of one of the pixels
`within one frame period via the data line connected to the pixel in order to
`control a transmission rate of the liquid crystal device of the pixel.
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`3
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`Id. at Claim 4. Specifically, Surpass appears to argue both limitations require the
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`performance of “overdriving,” and are thus not disclosed by Lee. This argument is
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`unsupported by the claims, specification, and conflicts with controlling case law. It
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`is also inconsistent with this Board’s final decision in IPR2015-00021. Sharp v.
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`Surpass, Case IPR2015-00021, Paper 44 at 11.
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`A. Claim 4 does not require overdriving
`As an initial matter, claim 4 does not recite “overdriving.” Yet, Surpass
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`contends that the broadest reasonable construction of claim 4 requires narrowing
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`the plain language of the claim to require “overdriving”—a term or concept that is
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`not recited in the claim. In its criticism of Petitioner’s analysis of claim 4, allegedly
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`for “provid[ing] no meaningful analysis of the Shen specification,” Surpass
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`conveniently ignores the other claims. Response at 18-19. As Surpass is well
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`aware, claims 1-3 all explicitly require the performance of “overdriving”:
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`a blur clear converter for receiving frame data every frame period, each
`frame data comprising a plurality of pixel data and each pixel data
`corresponding to a pixel, the blur clear converter delaying current frame data
`to generate delayed frame data and generating a plurality of overdriven
`pixel data within every frame period for each pixel;
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` a
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` source driver for generating a plurality of data impulses to each pixel
`according to the plurality of overdriven pixel data generated by the blur
`clear converter and applying the data impulses to the liquid crystal device of
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`4
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`Petitioner’s Reply to Patent Owner’s Response
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`the pixel via the scan line connected to the pixel within one frame period in
`order to control transmission rate of the liquid crystal device; an
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`Ex. 1001, ’843 Patent at Claim 1 (emphases added).
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`a processing circuit for generating the plurality of overdriven pixel data
`according to the pixel data and the pixel data delayed by the first image
`memory;
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` second image memory for storing the overdriven pixel data;
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` a
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` a
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` memory controller for controlling the second image memory according to
`the multiplied signal to output the plurality of overdriven pixel data to any
`pixel so that the source driver generates the data impulses to each pixel
`within one frame period according to the overdriven pixel data output by the
`second image memory.
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`Id. at Claim 2 (emphasis added).
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`a processing circuit for generating the plurality of overdriven pixel data
`according to the pixel data delayed and output by the second image memory
`and the third image memory; and
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` a
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` comparing circuit for comparing the pixel data delayed by the second
`image memory with the pixel data delayed by the third image memory in
`order to determine data values of the overdriven pixel data generated by the
`processing circuit.
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`5
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`Id. at Claim 3 (emphases added). There is a presumption that different patent
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`claims have different scopes. See Curtiss-Wright Flow Control Corp. v. Velan,
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`Inc., 438 F.3d 1374, 1380 (Fed. Cir. 2006) (“Beyond the independent/dependent
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`claim scenario, this court has characterized claim differentiation more generally,
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`i.e., as the ‘presumption that each claim in a patent has a different scope.’”)
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`(citations omitted). This applies to independent claims 1 and 4, which share several
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`limitations, with the obvious exception of “overdriving” or “overdriven pixel
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`data.” See Versa Corp. v. Ag-Bag Int'l Ltd., 392 F.3d 1325, 1330 (Fed. Cir. 2004)
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`(“The difference in meaning and scope between claims is presumed to be
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`significant ‘to the extent that the absence of such difference in meaning and scope
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`would make a claim superfluous.’”) (citations omitted). Surpass has provided no
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`evidence whatsoever as to why or how this presumption is overcome.
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`Instead, Surpass argues that the term “to control a transmission rate of the
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`liquid crystal device of the pixel” is synonymous with “overdriving.” See Ex. 2017
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`at 13. This argument is not supported by the ’843 patent, nor is it consistent with
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`how a person of ordinary skill in the art would interpret “to control a transmission
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`rate” in view of the claims and specification. Ex. 1015, Supp. Dec. at ¶ 5. First,
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`claim 1 also contains the “to control a transmission rate” limitation. Reading
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`“overdriving” into this limitation—when “overdriving” is already explicitly
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`required by claim 1—would render it superfluous. See Ex. 1015, Supp. Dec. at ¶ 5.
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`6
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`See also Case IPR2015-00021, Paper 44 at 11. Second, the ’843 patent defines
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`“overdriving” to mean “applying a higher or a lower data impulse to the pixel
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`electrode to accelerate the speed of the liquid crystal molecules, so that the pixel
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`can reach the predetermined gray level in a predetermined frame period.” Ex. 1001
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`at 2:2-7. Surpass’s expert, Mr. William Bohannon, noted this definition in his
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`declaration (see Ex. 2017 at 13) and further stated he agreed with it during
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`deposition:
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`Q:
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`So you accept this as a definition of overdriving?
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`A: Yes.
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`Is this consistent with your understanding of overdriving before
`Q:
`reading the ’843 Patent?
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`A: Yes.
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`Ex. 1014, Bohannon Dep. Trans at 33:25-34:6. Notably, this definition does not
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`appear in claim 4, nor does any similar language (much less the word,
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`“overdriving”). Nor does the specification contain any disclosure equating
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`“controlling a transmission rate” with “overdriving.” See Ex. 1015, Supp. Dec. at ¶
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`6. To the contrary, the specification describes controlling the operation of the pixel
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`without referencing overdriving in several instances. See id. at ¶ 7. For example, at
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`column 1, lines 27-31, the ’843 patent states: “Generally when driving an LCD, a
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`driving circuit receives a plurality of frame data and then generates corresponding
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`7
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`data impulses, scan voltages, and timing singles, according to the frame data, in
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`order to control pixel operation of the LCD.” (Emphasis added). Similarly, at
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`column 3, lines 43-47, the ’843 patent states: “The switching device 38 is
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`connected to the corresponding scan line 32 and the corresponding data line 34,
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`and the source driver 18 and the gate driver 20 control the operation of each pixel
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`36 via the scan line 32 and the data line 34.” (Emphasis added).
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`In both instances, the control of the pixel’s operation is described without
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`overdriving. As Petitioner’s expert has confirmed, one of ordinary skill in the art
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`would understand that controlling the “operation” of the pixel (as per the
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`specification) refers to the amount of light passing through the pixel—i.e., the
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`transmission. Ex. 1015, Supp. Dec. at ¶ 8. One of ordinary skill in the art would
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`also appreciate that there is a direct correlation between the voltage applied to the
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`pixel and the amount of light that passes through it. Id. Mr. Bohannon conceded
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`this point during deposition:
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`So I think you said…that transmission denotes the amount of light
`Q:
`that passes through the liquid crystal?
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`A: Yes I’ve measured it extensively…
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`Ex. 1014, Bohannon Dep. Trans. at 21:23-22:3.
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`8
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`So there are some scenarios that you can conceive of where the
`Q:
`transmissivity is changed as a result of the application of more than one data
`impulse in a single frame?
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`A: But the transmissivity is changed whenever you apply a voltage…
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`Id. at 51:12-17.
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`Q: …what that percentage value is referring to, the amount of light that’s
`passing through? So in your example of 10 percent, would that be 10 percent
`transmission through the pixel?
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`A: Yes.
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`Q: And then there is a direct correlation between the transmission and
`the voltage; is that accurate?
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`A: Yes. I’m sorry I didn’t wait for you to finish.
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`Q:
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`I was finished. So that’s correct?
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`A: Yes.
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`Q:
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`That would be a direct correlation, I assume?
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`A: Yes, that’s correct. The manufacturers or the people developing the
`LCD will generally put out a curve called the VT curve, which is voltage
`versus transmission.
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`Id. at 14:22-15:16 (emphases added).
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`Thus, one of ordinary skill in the art would understand that “control[ling] a
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`transmission rate” of a pixel merely refers to the application of a voltage. See Ex.
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`9
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`Petitioner’s Reply to Patent Owner’s Response
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`1015, Supp. Dec. at ¶ 9. Accepting Surpass and Mr. Bohannon’s reasoning, the
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`application of any data impulse is sufficient to qualify as the overdriven signal.
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`The absurdity of Surpass’s argument is plain on its face:
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`By way of Shen’s disclosure, a person of ordinary skill in the art would
`understand that the application of a target voltage impulse without
`overdriving causes the liquid crystal molecules to react without controlling
`the transmission rate, as reflected by curve C1.
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`Response at 25 (emphasis). Surpass essentially argues that applying a voltage to a
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`pixel—which would necessarily change
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`the
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`transmission rate—would not
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`constitute control of the transmission rate. This argument is belied by Figure 2 of
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`the ’843 patent (which is admitted prior art):
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`Ex. 1001 at Fig. 2. See also Ex. 1015, Supp. Dec. at ¶ 9. Regarding this figure, the
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`specification states:
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`Petitioner’s Reply to Patent Owner’s Response
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`Two curves C1, C2 are measured when the driving circuit changes the
`transmission rate from T1 to T2 beginning at frame period N. The curve C1
`shows the transmission rate of a pixel not overdriven corresponding to the
`frames, and the curve C2 shows the transmission rate of the pixel
`overdriven corresponding to the frames.
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`Id. at 1:27-31 (emphasis added). Both curves (C1 and C2) show the transmission
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`rate changing—regardless of whether the data impulse is overdriven. See Ex. 1015,
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`Supp. Dec. at ¶ 9. In other words, the mere application of the voltage results in a
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`change of the transmission rate; overdriving is not necessary.
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`Surpass simply has not provided any justification for why “controlling a
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`transmission rate” and “overdriving” are synonymous, or otherwise why claim 4
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`requires overdriving. Nor has Surpass explained how the broadest reasonable
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`construction of “to control a transmission rate” should be limited to overdriving.
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`Surpass improperly seeks to import limitations from the specification into the
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`claim to narrow its scope—for the obvious purpose of avoiding prior art. As
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`explained below, however, this effort is futile.
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`B.
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`Even if claim 4 requires overdriving, Lee still anticipates claims 4,
`8, and 9
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`Even accepting Surpass’s unsupported argument that claim 4 requires
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`overdriving, Lee still anticipates the challenged claims. As a preliminary matter, if
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`“overdriving” means nothing more than “controlling” the transmission rate (as
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`Surpass contends), then Lee necessarily anticipates claim 4. As Dr. Zech explained
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`during deposition, Figure 12 of Lee depicts the application of a voltage at the
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`beginning of the first subframe, and another (negative) voltage in the second
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`subframe (to drive the transmission rate down to the target value). See Ex. 2007 at
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`125:19-126:5 (emphasis added); see also Ex. 1010 at LGD_000600 (Lee, Fig. 12).
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`Thus, Surpass’s misguided attempt to shoehorn “overdriving” into claim 4 only
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`reinforces Petitioner’s argument that the overshoot and rollback shown in Lee’s
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`Figure 12 (and corresponding disclosure) satisfies the last two limitations of claim
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`4. Unable to rebut this reasoning, Surpass attempts to distort and mischaracterize
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`Petitioner’s arguments, as well as those of Petitioner’s expert, Dr. Zech. A plain
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`review of the record shows that Surpass has failed to offer a credible rebuttal to
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`any of Petitioner’s arguments.
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`To be clear, the Petition (and supporting declarations of Dr. Zech)
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`unequivocally contend that the overshoot and rollback occurring respectively in the
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`first and second subframes of Lee’s Figure 12 meet the “generating a plurality of
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`[overdriven] impulses for each pixel within every frame” limitation of claim 4 (to
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`the extent “overdriving” is required by the claim). See, e.g., Petition at 26, 28, 29-
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`39; Ex. 1015, Supp. Dec. at ¶ 13. As Dr. Zech explained during deposition (and
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`again in his supplemental declaration submitted herewith), the overshooting and
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`undershooting described in Lee are the result of overdriving. See Ex. 2007 at Ex.
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`12
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`Petitioner’s Reply to Patent Owner’s Response
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`2007 at 94:5-6, 95:1-3; Ex. 1015, Supp. Dec. at ¶ 13. In other words, and as
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`elaborated upon in Dr. Zech’s supplemental declaration, “overdriving” (i.e.,
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`applying a “higher or lower data impulse”) is necessary to achieve the overshoot
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`depicted in the first subframe of Figure 12. See Ex. 1015, Supp. Dec. at ¶ 13. As
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`for the second subframe, no overshooting/undershooting is required—only a
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`subsequent higher or lower data impulse. And such an impulse is depicted in the
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`second subframe, in view of the rollback shown. Dr. Zech explained this
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`relationship fully in his deposition:
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`Whatever signal process that you have tells you how much you have
`overshot and tells you how much you must roll back…When you look at the
`end of N plus, you are looking at a voltage there, that’s a maximum voltage
`that you put on the pixel. Not good. You don’t want to be there. You want to
`be at T2. So you need to apply a negative voltage to bring that back down
`and that what he means by rolling back.
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`Ex. 2007 at 125:19-126:5 (emphasis added).
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`Incapable of
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`rebutting Petitioner’s analysis, Surpass deliberately
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`mischaracterizes Petitioner’s arguments, and claims there are ambiguities or
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`omissions where there are none. By way of example, at the beginning of its
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`“Argument” section, Surpass disingenuously summarizes Petitioner’s position as
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`follows:
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`13
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`Petitioner’s Reply to Patent Owner’s Response
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`In characterizing the disclosure of Lee, Petitioner suggests that Lee divides a
`frame into at least two sub frames, and applies “an overshoot or undershoot
`driving” in both sub frames. That is not how Lee operates.
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`Response at 28-29 (emphasis added). This is nothing more than a straw man. As
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`per above, Petitioner’s primary position is that the overshoot/rollback process
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`depicted in Lee’s Figure 12 (and corresponding disclosure) satisfies the generating
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`and applying a plurality of overdriven data impulses limitation of claim 4 (to the
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`extent overdriving is required by the claim).2
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`Similarly, Surpass argues the table included in LG Display’s Petition and Dr.
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`Zech’s declaration, comparing related relevant terms from the ’843 patent and Lee,
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`somehow constitutes an admission that Lee does not disclose overdriving in the
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`second subframe (n-). See Response at 29. Again, this argument is belied by the
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`several instances (including those discussed above) where Petitioner has explained
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`the precise relationship between Lee’s overshooting/undershooting and rollback,
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`and the ’843 patent’s overdriving. Such an argument also erroneously presumes
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`that overdriving requires overshooting/undershooting. Using this flawed (and
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`unsupported) logic, Surpass argues that overshooting/undershooting must occur in
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`2 Petitioner’s expert, Dr. Zech, explained in his deposition that in practice
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`some undershooting would occur in the second subframe of Lee’s Figure 12, but
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`this is not the primary basis for Dr. Zech’s conclusion that Lee anticipates claim 4.
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`each subframe in order for Lee to disclose a plurality of overdriven data impulses
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`in a single frame. See id. 28-29. This position is inconsistent with the record to
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`date. It is the application of a higher or lower data impulse in each of the subframes
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`that meets the ’843 patent’s “overdriving” requirement—not the overshooting per
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`se (though the two are obviously related). The overshooting in the first subframe is
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`merely a result of the overdriving in the first subframe (i.e., the application of a
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`higher voltage). Undershooting/overshooting need not occur in the second
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`subframe, or in the first subframe for that matter.
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`Surpass’s position is also inconsistent with the ’843 patent itself, including
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`the very clear definition of “overdriving” provided at column 2, lines 2-7, as well
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`as Figure 6:
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`Ex. 1001, ’843 Patent at Fig. 6. As per above, the transmission rate does not
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`exceed the target, T2. The goal (as per the “Background” section of the patent) is
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`Petitioner’s Reply to Patent Owner’s Response
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`simply to reach T2 before the end of the second subframe (n+3) of frame N+1. The
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`patent says nothing about exceeding T2.
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`Even accepting Surpass’s erroneous premise that overshooting is required in
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`each subframe, Lee still anticipates claim 4 of the ’843 patent. As Dr. Zech
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`explains in the supplemental declaration, a person of ordinary skill in the art would
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`understand that in practice undershooting would likely occur in the second
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`subframe. See Ex. 1015, Supp. Dec. at ¶ 17. As per Dr. Zech’s deposition, Lee’s
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`figures depict ideal representations of the transmission of the pixel. Dr. Zech also
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`explained that reaching (and stopping) at a particular target value would be
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`extremely difficult. See Ex. 2007 at 109:20-110:6 (“What [Lee] is simply saying is
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`I put too much voltage on the pixel, now I got to correct the overvoltage…and
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`even with underdriving…he gets some undershot.”); Ex. 1015, Supp. Dec. at ¶ 17.
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`Thus, one of ordinary skill in the art would recognize that employing the Lee
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`system in practice would result in some undershooting in the second subframe (i.e.,
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`this would be an inherent result). Indeed, Dr. Zech stated the same with respect to
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`Figure 6 of the ’843 patent. Id. Consistent with its pattern of distorting the record,
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`Surpass mischaracterizes Dr. Zech’s testimony on this point, claiming he somehow
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`“disparage[d]” the Lee reference. See Response at 6. To the contrary, Dr. Zech
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`lauded Lee for its comprehensiveness: “I think the Lee work is outstanding, it’s
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`Petitioner’s Reply to Patent Owner’s Response
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`
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`one of the best patent applications…that I have seen, he clearly understands what
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`he’s doing.” Ex. 2007 at 42:19-43:2.
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`
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`Lastly, Surpass erroneously contends that Lee, Figure 12, does not show the
`
`application of specific voltages. As a preliminary matter, Lee’s Figure 12 is
`
`directly analogous to Figure 6 of the ’843 patent—both relate the amount of light
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`passing through the pixel (transmission) to the frame or subframe. See Ex. 1015,
`
`Supp. Dec. at ¶ 18. In the context of both patents, as per the other figures and
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`corresponding disclosures, it is the application of voltages that cause these changes
`
`in transmission or transmission rate. Id. Moreover, Mr. Bohannon conceded during
`
`deposition that there is a correlation between transmission or transmission rate and
`
`voltage—a direct correlation. See Ex. 1014, Bohannon Dep. Trans. at 14:22-15:16.
`
`Mr. Bohannon also conceded this point in his discussion of the rollback that occurs
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`in the second subframe (n+) of Lee, Figure 12: “a signal is applied that returns the
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`pixel transmission rate to the target value.” Ex. 2017 at 16 (emphasis added). To be
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`clear, Mr. Bohannon is correct in this assessment. As Dr. Zech explained in his
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`deposition, a negative voltage (lower data impulse) is required to achieve the
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`rollback depicted in the second subframe. Ex. 2007 at 125:19-126:5. During
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`deposition, Mr. Bohannon suggested that turning the higher voltage off or down
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`might also be an option. But doing so would not ensure that the target transmission
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`is reached before the end of the frame (which is the goal in Lee). See Ex. 1015,
`
`17
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`
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`Petitioner’s Reply to Patent Owner’s Response
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`Supp. Dec. at ¶ 20. The rollback requires a “lower” signal, which is consistent with
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`the definition of overdriving provided in the ’843 patent—which Mr. Bohannon
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`has endorsed.
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`
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`Thus Mr. Bohannon has effectively admitted that Lee, Figure 12, depicts the
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`application of two distinct voltages (higher and lower, respectively) in the first and
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`second subframes. The application of these higher and lower signals necessarily
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`meets the ’843 patent’s definition of overdriving (presuming for the sake of
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`argument that claim 4 requires “overdriving,” which it does not).
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`III. Conclusion
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`For at least the above reasons, the Board should cancel claims 4, 8, and 9 of
`
`the ’843 patent as being anticipated by Lee.
`
`
`
`Respectfully submitted,
`
`/Robert G Pluta Reg No 50970/
`Robert G. Pluta
`Registration No. 50,970
`William J. Barrow
`Registration No. 62,813
`Amanda K. Streff
`Registration No. 65,224
`Jamie B. Beaber (motion for pro hac
`vice to be filed)
`
`
`18
`
`
`
`Dated:
`
`March 1, 2016
`
`
`
`
`
`
`
`Petitioner’s Reply to Patent Owner’s Response
`
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`
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`CERTIFICATE OF SERVICE
`
`I hereby
`
`certify
`
`that on March 1, 2016,
`
`a
`
`copy of
`
`the
`
`attached PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE TO
`
`PETITION has been served by electronic mail to the attorneys of record in the co-
`
`pending litigation, at the following addresses:
`
`
`
`Wayne M. Helge (Reg. No. 56,905)
`Donald L. Jackson (Reg. No. 41,090)
`Michael R. Casey (Reg. No. 40,294)
`Davidson Berquist Jackson & Gowdey L.L.P.
`8300 Greensboro Drive, Suite 500
`McLean, VA 22102
`Telephone: 571-765-7700
`Fax: 571-765-7200
`Email: whelge@dbjg.com
`Email: djackson@dbjg.com
`Email: mcasey@dbjg.com
`
`
`Date: March 1, 2016
`
`
`
`
`
`Respectfully submitted,
`
`By:/Robert G Pluta Reg No 50970/
`Robert G. Pluta
`Registration No. 50,970
`Mayer Brown LLP
`71 S. Wacker Drive
`Chicago, IL 60606
`Telephone: 312-701-8641
`Facsimile: 312-701-7711
`
`Counsel for LG Display America, Inc.
`
`19
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