UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`VOLKSWAGEN GROUP OF AMERICA, INC.,
`Petitioner,
`v.
`SIGNAL IP, INC.,
`Patent Owner.
`____________
`Case IPR2015-01088
`Patent 5,954,775
`____________
`
`PATENT OWNER’S PRELIMINARY RESPONSE
`
`
`
`
`
`
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`VOLKSWAGEN GROUP OF AMERICA, INC.,
`Petitioner,
`v.
`SIGNAL IP, INC.,
`Patent Owner.
`____________
`Case IPR2015-01088
`Patent 5,954,775
`____________
`
`PATENT OWNER’S PRELIMINARY RESPONSE
`
`
`
`
`
`
`
`TABLE OF CONTENTS
`
`. Overview of the ‘775 Patent. ...................................................................... 1
`
`. Argument. ................................................................................................. 10
`
`A. Claim 6 is Not Obvious in View of Jurgen and Waggener. ................. 10
`
`B. Claim 6 is Patentable Over Jurgen and Mosch. .................................... 14
`
`C. Petitioner Fails to Identify any Reasons for Institution of Trial on
`Multiple, Redundant Grounds. .................................................................. 17
`
`. Conclusion. ............................................................................................... 19
`
`
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`!
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`! 4
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`! 2
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`! 3
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`1. Introduction. ................................................................................................ 1
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`!
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`ii!
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`
`
`TABLE OF AUTHORITIES
`
`
`
`CASES
`CFMT, Inc. v. Yieldup Int’l. Corp.,
`349 F.3d 1333 (Fed. Cir. 2003) ........................................................... 13, 17
`
`!I
`
`llumina, Inc. v. Trustees of Columbia Univ.,
`IPR2012-00006 (P.T.A.B. May 10, 2013) .......................................... 18, 19
`
`SR Int’l Co. v. Teleflex Inc.,
`550 U.S. 398 (2007) .................................................................................. 13
`
`!K
`
`! S
`
`! R
`
`TATUTES
`35 U.S.C. § 314(a) .......................................................................................... 1
`
`EGULATIONS
`37 C.F.R. § 42.108(c)...................................................................................... 1
`
`
`
`!
`
`iii!
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`
`
`1. Introduction.
`
`Petitioner challenges the patentability of claim 6 of U.S. Patent
`
`5,954,775 (the “’775 Patent”). The Patent Trial and Appeal Board (“PTAB”
`
`or “Board”) should not institute inter partes review of the ‘775 Patent
`
`because Petitioner has not met its burden to show a reasonable likelihood
`
`that claim 6 of the ‘775 Patent is unpatentable.1
`
`
`
`2. Overview of the ‘775 Patent.
`The ‘775 Patent discloses a dual rate communication protocol to
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`improve the communication of seat occupant presence and position
`
`information to a control unit of a supplemental inflatable restraint (SIR)
`
`system.2 Claim 6 is the sole claim challenged in the instant petition and
`
`reads:
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`6. A method of accommodating communication of first
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`1 35 U.S.C. § 314(a) (An inter partes review may be instituted only if “the
`
`information presented in the petition . . . and any response . . . shows that
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`there is a reasonable likelihood that the petitioner would prevail with respect
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`to at least 1 of the claims challenged in the petition.”); 37 C.F.R. §
`
`42.108(c).
`
`2 Ex. 1001 at Abstract; 2:20-24, 38-45.
`
`1!
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`!
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`
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`and second types of data at first and second message
`rates over a common communication link comprising the
`steps of:
`establishing a message rate interval on the
`common communication link;
`devoting a portion of each message rate interval to
`the first type of data and reserving a remaining portion of
`each message rate interval for the second type of data;
`providing the first type of data at a first message
`rate sufficient to form a complete message within the
`devoted portion of each message rate interval;
`providing the second type of data at a second
`message rate sufficient to form only a fragment of a
`complete message in the remaining portion of each
`message rate interval, thereby requiring a plurality of
`consecutive message rate intervals to form a complete
`message of the second type of data; and
`transmitting at least one of the first and second
`types of data in the respective portions of each message
`rate interval.3
`
`In order to understand this claimed method, it is helpful to review the
`
`teachings provided in the specification.
`
`The specification explains that, for various reasons, it is desirable to
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
`!
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`3 Id. at 6:24-45.
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`2!
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`
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`transmit different types of information, such as seat occupant presence
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`information and position information, from seat sensors to a SRI system
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`controller.4 However, because occupant presence information changes only
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`relatively slowly, that presence information need only be updated relatively
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`infrequently. On the other hand, the occupant positon information may be
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`subject to near continual and rapid changes and so should be updated at
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`much faster intervals.5 The claimed invention allows both types of
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`information, i.e., that requiring relative fast updates and that requiring
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`relative slow updates, to be transmitted at corresponding high and low
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`bandwidths over the same communication link.6 This is shown in Figure 1 of
`
`the ‘775 Patent, which is reproduced below.
`
`In the above illustration, an electronic control unit (ECU) (10) is
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`
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`4 Id. at 2:21-24.
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`5 Id. at 1:52-62.
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`6 Id. at 2:21-23; 3:36-50.
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`!
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`3!
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`coupled to air bags (12), and an occupant presence and position sensing
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`(OPPS) device (18) is used to determine both the presence and position of a
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`seat occupant.7 Information from the OPPS device is encoded as digital data
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`and transmitted over a communication link (26) to the ECU, which
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`determines whether to deploy an air bag.8 The OPPS device transmits both
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`presence and position data concerning the set occupant,9 however, the
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`presence data need only be (and is) updated slowly, while the position data
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`must be (and is) updated frequently and rapidly.10 Both data types are
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`transmitted (at their required bandwidths) over the single communication
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`link.11 Thus, the communication of the two different types of data (presence
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`and position) constitute different component protocols—a low message rate
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`protocol for the presence data and a high message rate protocol for the
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`position data—within a combined protocol.12
`
`Each component protocol is based on a corresponding fundamental
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`7 Id. at 3:20-27.
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`8 Id. at 3:31-35.
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`9 Id. at 3:26-31.
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`10 Id. at 3:36-37.
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`11 Id. at 3:37-38
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`12 Id. at 3:38-42.
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`!
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`4!
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`time interval (FTI)—a low rate FTI (LFTI) for the occupant presence
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`component, and a high rate FTI (HFTI) for the occupant position
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`component.13 Each respective fundamental time interval is “the shortest
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`meaningful time interval for that protocol.”14 The ratio of the LFTI to the
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`HFTI allows at least one complete high rate message to be contained within
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`one LFTI. At the same time there is sufficient time remaining within the
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`LFTI to determine its state unambiguously.
`
`This relationship is illustrated in Figure 2 of the ‘775 Patent.15 As
`
`depicted, within a given
`
`low rate FTI, there are
`
`multiple high rate FTIs,
`
`providing sufficient
`
`bandwidth to contain at
`
`least one complete high
`
`rate FTI (i.e., occupant position) message.16 By way of example, if the LFTI
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`is 50 ms and the HFTI is 500 µs (i.e., 0.5 ms), then a high rate message
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`13 Id. at 3:36-46.
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`14 Id. at 2:46-47.
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`15 Id. at 3:47-51.
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`16 Id. at 3:57-60.
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`!
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`5!
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`using 54 FTIs would require 27 ms and fit within the LTFI without
`
`ambiguity.17 The remainder of the LFTI would be available for a portion of
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`the low rate message.18
`
`Figure 4 of the ‘775 Patent (below) provides an example of the low rate
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`message (i.e., the occupant presence message). The low rate message
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`requires “two to four LFTIS or 100 ms to 200 ms.”19
`
`The highlighted excerpt of Figure 4 below illustrates an individual LFTI.
`
`
`
`
`
`
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`17 Id. at 4:11-17.
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`18 Id. at 4:11-16.
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`19 Id. at 4:43-44.
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`!
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`6!
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`The complete low rate message includes the information in the following
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`table:20
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`
`
`Figure 4 thus depicts a low rate message specifying a rear facing infant seat
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`(1 low and 2 high FTIs).21
`
`The high rate message “is more complex,” and is shown in Figure 5 of
`
`the ‘775 Patent (reproduced below).22 There is a start of message (SOM)
`
`symbol comprising a low pulse and a high pulse, a 3-bit tag (TAG)
`
`identifying the type of data to follow, 8 bits of data “representing the
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`20 Id. at 4:30-42.
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`21 Id. at 4:43-45.
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`22 Id. at 4:49-50.
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`!
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`7!
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`
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`information identified by the tag, e.g., the distance between the driver and
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`the steering column,” a parity bit, and an end of message (EOM) symbol
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`comprising a single pulse.23 As shown, “[a] value of 0 is represented by a
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`pulse one FTI wide and a value of 1 is denoted by a pulse of either polarity
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`two FTI wide.”24
`
`Returning then to claim 6, the recited method includes “establishing a
`
`message rate interval on the common communication link” and “devoting a
`
`portion of each message rate interval to the first type of data and reserving a
`
`remaining portion of each message rate interval for the second type of data”
`
`such that it is possible “to form a complete message within the devoted
`
`portion of each message rate interval.”25 As illustrated above in the example
`
`shown in Figure 2, within a given LFTI, there are multiple high rate FTIs,
`
`providing sufficient bandwidth to contain at least one complete high rate FTI
`
`message.26 Indeed, Figure 2 shows that the “period reserved to the high rate
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`message . . . is somewhat shorter than the LFTI.”27 This period “consists of
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`23 Id. at 4:49-60.
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`24 Id. at 4:22-24.
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`25 Id. at 6:26-36.
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`26 Id. at 3:57-60.
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`27 Id. at 3:55-56.
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`!
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`8!
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`
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`many HFTI intervals affording sufficient bandwidth to contain at least one
`
`complete occupant position message.”28
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`The remainder of the LFTI is available for a portion of the low rate
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`message.29 Indeed, “[t]he ratio of the LFTI to the HFTI [is] great enough to
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`allow at [least] one complete high rate message to be contained within a
`
`single LFTI and leave sufficient time remaining within the LFTI that its state
`
`can be determined without ambiguity.”30 Claim 6 highlights this feature by
`
`specifying that the “second type of data” is provided “at a second message
`
`rate sufficient to form only a fragment of a complete message in the
`
`remaining portion of each message rate interval, thereby requiring a plurality
`
`of consecutive message rate intervals to form a complete message of the
`
`second type of data.”31 Thus, as recited in the claim, the “first and second
`
`types of data” are transmitted “in the respective portions of each message
`
`rate interval.”32 This claim language indicates that the “message rate
`
`interval” is an interval of time for messages, to be apportioned as expressly
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`28 Id. at 3:52-60.
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`29 Id. at 4:11-16.
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`30 Id. at 3:47-51.
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`31 Id. at 6:37-42.
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`32 Id. at 6:43-45.
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`!
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`9!
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`called for in the claim.
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`
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`3. Argument.
`A. Claim 6 is Not Obvious in View of Jurgen and Waggener.
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`Petitioner contends that claim 6 is obvious in view of the combined
`
`teachings of Jurgen and Waggener.33 In particular, Petitioner alleges that,
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`“The combination of Jurgen and Waggener also teaches ‘providing the first
`
`type of data at a first message rate sufficient to form a complete message
`
`within the devoted portion of each message rate interval.’”34 To this end,
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`Waggener is cited as describing a so-called “complete” set of data D1 – D8
`
`that is transmitted within each minor frame of a multiplex.35 Missing from
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`Petitioner’s analysis, however, is any explanation of why a set of data D1 –
`
`D8 should be considered a “complete message,” as required by the
`
`challenged claim.
`
`Claim 6 of the ‘775 Patent specifically recites “providing the first type
`
`of data at a first message rate sufficient to form a complete message within
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`33 Pet. at 11 et seq.
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`34 Id. at 18-19.
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`35 Id. at 19.
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`!
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`10!
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`the devoted portion of each message rate interval.”36 As explained in the
`
`specification, within a given LFTI, there are multiple high rate FTIs,
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`providing sufficient bandwidth to contain at least one complete high rate FTI
`
`message.37 For example, the LFTI period “consists of many HFTI intervals
`
`affording sufficient bandwidth to contain at least one complete occupant
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`position message.”38 The occupant position message is known to be
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`complete because it originates with a start of message (SOM) indication and
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`concludes with an end of message (EOM) indication.39 While this is only an
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`example of a complete message at a first message rate as recited in claim 6,
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`it nevertheless appraises a person of ordinary skill in the art that a “complete
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`message” is one that includes all constituent elements for a message of that
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`data type.
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`In contrast, Waggener’s description of an irregular multiplex (relied
`
`upon by Petitioner) indicates only that it is an array structure that includes a
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`mixture of data sources with differing rates.40 In the example shown in
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`36 Ex. 1001 at 6:34-36 (emphasis added).
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`37 Id. at 3:57-60.
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`38 Id. at 3:52-60 (emphasis added).
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`39 Id. at 4:48-60.
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`40 Ex. 1009 at 110.
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`!
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`11!
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`Waggener’s Fig. 4.4, information from data channels D1 – D8 is included in
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`each minor frame. However, there is no indication, indeed not even a
`
`suggestion, that this information provides a “complete message” (i.e., one
`
`having all the constituent parts) of D-channel data. Nor would inclusion of a
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`sync marker as described by Waggener indicate same because the sync
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`marker is used only to indicate the boundaries of a frame,41 not the content
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`of messages contained therein.
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`Petitioner presumes that Waggener’s description of a minor frame in
`
`the context of Fig. 4.4 somehow includes a “complete” set of D data.42 Even
`
`assuming this to be true, however, Petitioner has not explained why a person
`
`of ordinary skill in the art would consider a complete set of D data to be a
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`“complete message” as required by claim 6. Petitioner’s declarant states that
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`since all eight D time slots are transmitted in each minor frame, it constitutes
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`a “complete message,”43 however, this is a conclusion and not an
`
`explanation. Petitioner’s declarant cites nothing in Waggener that would
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`support such a conclusion and nowhere does he compare the attributes of a
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`“complete message” as specified in the ‘775 Patent with any teachings of
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`41 Id. at 109.
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`42 Pet. at 19.
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`43 Ex. 1002 at ¶ 13.
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`!
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`12!
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`
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`Waggener. Indeed, conspicuously absent from the declaration is any
`
`construction of the terms of claim 6 from the standpoint of the person of
`
`ordinary skill in the art.
`
`A claim is unpatentable under 35 U.S.C. § 103(a) only if the
`
`differences between the subject matter sought to be patented and the prior art
`
`are such that the subject matter as a whole would have been obvious at the
`
`time the invention was made to a person having ordinary skill in the art to
`
`which said subject matter pertains.44 At a minimum, this requires a
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`suggestion of all limitations in a claim.45 Here, this requirement is not met
`
`because the combination of Jurgen and Waggener does not suggest
`
`“providing the first type of data at a first message rate sufficient to form a
`
`complete message within the devoted portion of each message rate
`
`interval,”46 as required by claim 6 and Petitioner has not demonstrated
`
`otherwise. Petitioner relies on Jurgen for teaching “a single network
`
`architecture” and multiplexed systems47 and Waggener that is relied upon for
`
`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`44 KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 418 (2007).
`
`45 CFMT, Inc. v. Yieldup Int’l. Corp., 349 F.3d 1333, 1342 (Fed. Cir. 2003)
`
`citing In re Royka, 490 F.2d 981, 985 (CCPA 1974).
`
`46 Ex. 1001 at 6:34-36 (emphasis added).
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`47 Pet. at 15.
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`!
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`13!
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`
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`purportedly teaching devoting a portion of each message rate interval to the
`
`first type of data and reserving a remaining portion of each message rate
`
`interval for the second type of data; and providing the first type of data at a
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`first message rate sufficient to form a complete message within the devoted
`
`portion of each message rate interval.”48 As demonstrated above, this is not
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`so; hence, even if the teachings of Waggener were combined with those of
`
`Jurgen concerning a single network architecture, one would still not arrive at
`
`the subject matter recited in claim 6. Accordingly, no inter partes review
`
`should be instituted on this proposed ground.
`
`
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`B. Claim 6 is Patentable Over Jurgen and Mosch.
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`In its second proposed ground for institution of trial, Petitioner alleges
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`that claim 6 is obvious in view of the combined teachings of Jurgen and
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`Mosch.49 A careful analysis of Mosch, however, undercuts this argument.
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`Accordingly, no inter partes review should be instituted on this proposed
`
`ground.
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`According to Petitioner, Mosch teaches that,
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`14!
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`48 Id. at 17-19.
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`49 Pet. at 30 et seq.
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`
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`After the low-frequency signal has been sampled in the
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`quiet interval TQ between packets, this value is held by
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`Sample and Hold circuit SH1 and converted to an
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`equivalent differential current (I COMP of FIG. 2) which
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`is subtracted from the received input signal during the
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`subsequent high-speed data packet intervals (e.g., T1, T2
`
`of FIG. 3).50
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`Petitioner contends that the cited passage indicates that a low-frequency
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`signal is transmitted in a reserved portion of a message rate interval, as
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`required by claim 6.51 This is not so.
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`
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` According to Mosch, a digital burst-mode packet data receiver
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`receives high-speed burst-mode packet data signals combined with lower
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`frequency data signals.52 In between the high-speed burst mode data packets,
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`which are separated by a quiet interval TQ to ensure the packets do not
`
`interfere with one another,53 the receiver samples the received signal to
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`50 Id. at 37, citing Ex. 1010 at 5:42-48.
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`51 Id.
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`52 Ex. 1010 at 2:16-19.
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`53 Id. at 6:12-16.
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`!
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`15!
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`
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`determine whether a low frequency signal is present.54 The value of any
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`detected low frequency signal is retained by a sample and hold circuit.55 This
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`value is later subtracted from the received signal during subsequent high-
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`speed data packet intervals.56
`
`
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`The need to subtract the value of the low frequency signal is evident
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`because Mosch indicates the high and low frequency signals are, in fact,
`
`superimposed on an optical bus.57 That is, the high and low frequency
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`signals are each present on the optical bus with one another so that in order
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`to ensure the value of the high frequency signal is determined correctly, the
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`value of the low frequency signal (determined by sampling same during TQ)
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`is subtracted.58 No such subtraction would be needed if the low frequency
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`signal were restricted to a reserved portion of a message rate interval in
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`which no high frequency message were being transmitted.
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`54 Id. at 5:21-41.
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`55 Id. at 5:42-48.
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`56 Id.
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`57 Id. at 2:30-33.
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`58 Id. at 5:42-48.
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`!
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`16!
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`
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`Jurgen is cited for teaching “a single network architecture” and
`
`multiplexed systems,59 while Mosch is relied upon for purportedly teaching
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`“devoting a portion of each message rate interval to the first type of data and
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`reserving a remaining portion of each message rate interval for the second
`
`type of data,” as recited in claim 6.60 As demonstrated above, however, this
`
`is not so. Mosch describes superimposing low and high frequency data
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`signals on an optical bus.61 Accordingly, the combination of Jurgen and
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`Mosch fail to suggest all of the elements of the challenged claim and,
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`accordingly, the challenged claim is not obvious in view of the cited
`
`references.62 Hence, no inter partes review should be instituted on this
`
`proposed ground.
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`
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`C. Petitioner Fails to Identify any Reasons for Institution of Trial
`on Multiple, Redundant Grounds.
`
`In addition to the substantive reasons for refusing to institute trial on
`
`the proposed grounds, the Board should further refuse to do so because
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`59 Pet. at 34-35.
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`60 Id. at 37.
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`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
`61 Ex. 1010 at 2:30-33.!
`!
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`62 CFMT, Inc., 349 F.3d at 1342.
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`17!
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`
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`Petitioner has not adequately explained why these multiple, redundant bases
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`for institution of trial are necessary. The Board has made clear that in order
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`to ensure “the just, speedy, and inexpensive resolution of every proceeding,”
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`it will not institute inter partes review proceedings on cumulative grounds.63
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`Indeed, the Board has remarked that “[C]onsidering multiple rejections for
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`the same unpatentability issue would unnecessarily consume the time and
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`resources of all parties involved.”64
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`To avoid dismissal of a proposed ground of unpatentability, a
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`petitioner must “provide a meaningful distinction between the different,
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`redundant rejections.”65 Where multiple references have been cited for the
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`same facts, it is not be enough for a petitioner to argue that the cited
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`references are not identical, or to “speculate[] that in certain publications an
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`element may be more clearly set forth in one publication rather than
`
`another.”66 Rather, a petitioner must provide an adequate explanation as to
`
`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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`the differences between the references and “how this difference would
`
`63 Illumina, Inc. v. Trustees of Columbia Univ., IPR2012-00006, Paper 43 at
`
`11-12 (P.T.A.B. May 10, 2013) citing 37 C.F.R § 42.1(b).
`
`64 Id. at 12.
`
`65 Id.
`
`66 Id.
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`!
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`18!
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`
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`impact the unpatentability challenge.”67 Here, Petitioner has set forth no
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`such explanation or rationale.
`
`Nothing in Petitioner’s analysis of claim 6 or the construction of the
`
`terms thereof suggests that consideration of some of the proposed grounds of
`
`institution rather than others would be determinative of any outcome. For
`
`example, Petitioner has not set forth alternative constructions of the claim
`
`under alternative theories of patentability. Instead, all Petitioner has done is
`
`to propose parallel sets of rejections using different references, but without
`
`any different substantive analysis of the teachings of the cited reference.
`
`Accordingly, the Board should decline to institute trial on all of the grounds
`
`proposed by Petitioner, as considering these multiple grounds for the same
`
`unpatentability issues would unnecessarily consume the time and resources
`
`of all parties involved.
`
`
`
`4. Conclusion.
`For at least the foregoing reasons, no inter partes review should be
`
`instituted on the identified grounds. Further, as this is Patent Owner’s
`
`Preliminary Response, it is not a comprehensive rebuttal to all arguments
`
`!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
`!
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`67 Id.
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`19!
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`
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`raised by the Petition. If a trial is instituted, Patent Owner reserves the right
`
`to contest the Petition on all grounds permitted under the applicable rules.
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`Moreover, nothing herein should be construed as a concession or admission
`
`by Patent Owner as to any fact or argument proffered in the Petition
`
`
`
`Respectfully submitted,
`
`/Tarek N. Fahmi/
`Tarek N. Fahmi
`Reg. No. 41,402
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`Dated: August 4, 2015
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`Ascenda Law Group, PC
`333 W San Carlos St., Suite 200
`San Jose, CA 95110
`Tel: 866-877-4883
`Email: tarek.fahmi@ascendalaw.com
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`20!
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a copy of the foregoing
`PATENT OWNER’S PRELIMINARY RESPONSE
`was served on August 4, 2015, by filing this document though the Patent
`Review Processing System as well as by delivering a copy via email directed
`to the attorneys of record for the Petitioner at the following address:
`Michael J. Lennon
`Clifford A. Ulrich
`Michelle Carniaux
`Kenyon & Kenyon LLP
`One Broadway
`New York NY 10004
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`ptab@kenyon.com
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`The parties have agreed to electronic service in this proceeding.
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`Respectfully submitted,
`/Tarek N. Fahmi/
`Dated: August 4, 2015
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`Tarek N. Fahmi
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`Reg. No. 41,402
`Ascenda Law Group, PC
`333 W San Carlos St., Suite 200
`San Jose, CA 95110
`Tel: 866-877-4883
`Email: patents@ascendalaw.com
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