UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`
`
`UMICORE AG & CO. KG,
`
`Petitioner,
`
`v.
`
`BASF CORPORATION
`
`Patent Owner.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`IPR2015-01125
`U.S. Patent 7,601,662
`
`
`
`PATENT OWNER’S OPPOSITION TO
`PETITIONER’S MOTION TO EXCLUDE
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`
`
`UMICORE AG & CO. KG,
`
`Petitioner,
`
`v.
`
`BASF CORPORATION
`
`Patent Owner.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`IPR2015-01125
`U.S. Patent 7,601,662
`
`
`
`PATENT OWNER’S OPPOSITION TO
`PETITIONER’S MOTION TO EXCLUDE
`
`
`
`
`
`
`
`
`
`
`
`Patent Owner respectfully submits this opposition to Petitioner’s motion to
`
`exclude. As explained below, Petitioner’s objections on hearsay and relevance
`
`grounds are entirely unfounded, and should be rejected. Furthermore, Petitioner’s
`
`argument that the obviousness analysis in this case should be conducted without
`
`recognition of the properties of the claimed CuCHA zeolite catalyst is entirely
`
`inconsistent with Federal Circuit precedent. Petitioner’s motion to exclude should
`
`be denied in its entirety.
`
`I. MOTION TO EXCLUDE PARAGRAPHS OF TSAPATSIS
`DECLARATION
`A. Tsapatsis Declaration, ¶ 28
`Petitioner moves to exclude ¶ 28 of the Tsapatsis Declaration (Ex. 2018),
`
`
`
`which cites ¶ 4 of the Declaration of Dr. Ahmad Moini (Ex. 2003) from the inter
`
`partes reexamination history of the 662 Patent. Petitioner incorrectly contends that
`
`¶ 4 of the Moini declaration is irrelevant and that the un-cross examined testimony
`
`of Dr. Moini is unreliable.
`
`
`
`First, Dr. Tsapatsis cites the Moini declaration to rebut the unsupported
`
`assertions by Petitioner’s expert, Dr. Lercher, that the technology at issue in this
`
`case is predictable, and that it was simply a matter of routine optimization to arrive
`
`at the claimed invention. The undisputed fact that the inventors of the 662 Patent
`
`performed broad experimentation before arriving at the claimed invention is
`
`clearly relevant to whether the technology at issue is complex and unpredictable.
`
`
`
`
`
`
`
`Furthermore, Dr. Tsapatsis’ opinion is not based solely on ¶ 4 of the Moini
`
`declaration. Instead, Dr. Tsapatsis cites substantial evidence to support his opinion
`
`that the relevant technology is complex and unpredictable. See Ex. 2018 at ¶¶ 28,
`
`56-75, 151-167, 172.
`
`
`
`Petitioner is also wrong that there is no evidence in the record indicating that
`
`the screening of 900 zeolite materials and 12 different structure types was directed
`
`to problems solved by the 662 Patent. Dr. Moini’s declaration explicitly states that
`
`the screening was done “to provide a material for selective catalytic reduction that
`
`would have two main properties: (1) excellent NOx conversion over a wide
`
`temperature range…and (2) hydrothermal stability…” Ex. 2003 at ¶ 3.
`
`
`
`Second, Petitioner’s argument that the “uncross-examined declaration” is not
`
`the type of information on which an expert would ordinarily rely is wholly without
`
`merit. There is no rule that an expert can only rely on testimony that has been
`
`subject to cross-examination. See FRE 703. And even if there were such a
`
`requirement, the only reason Dr. Moini was not cross-examined was because
`
`Petitioner voluntarily decided not to proceed with the deposition that had been
`
`scheduled for April 27, 2016.
`
`Tsapatsis Declaration, ¶ 174
`
`B.
`Petitioner moves to exclude ¶ 174 of the Tsapatsis Declaration, which cites
`
`
`
`to the Second Declaration of Dr. Moini (Ex. 2011). This Second Moini declaration
`
`
`
`3
`
`
`
`
`
`is also part of the 662 reexamination history and includes testimony regarding
`
`testing of zeolite catalysts. Petitioner argues that the testing should be disregarded
`
`because the natural chabazite samples tested by Dr. Moini were not from the same
`
`source as the natural chabazite samples discussed in the Dedecek prior art
`
`reference. Petitioner, however, offers no evidentiary rule for excluding either ¶
`
`174 of the Tsapatsis declaration or the Second Moini declaration. Dr. Moini
`
`explicitly noted in his declaration that the natural chabazite discussed in Dedecek
`
`was from North Korea, and therefore, not available to him. Ex. 2011 at ¶ 5. He
`
`instead utilized a comparable natural chabazite from Bowie, Arizona. Id.
`
`
`
`Petitioner’s expert, Dr. Lercher, and Patent Owner’s expert, Dr. Tsapatsis,
`
`each reviewed the Second Moini declaration and neither offered any opinion that
`
`the testing was insufficient, improper, or otherwise unreliable. Ex. 2018 at ¶ 174;
`
`Ex. 2027 at 84:22-25. In fact, Dr. Lercher’s 120-page declaration is entirely silent
`
`about the testing performed by Dr. Moini. Ex. 1108. Petitioner offers no reasoned
`
`explanation for why the use of the sample from Bowie, Arizona renders the testing
`
`unreliable.
`
`
`
`Petitioner also argues that ¶ 25 of the Second Moini declaration includes
`
`hearsay, and on this basis, requests that ¶ 174 of the Tsapatsis declaration be
`
`excluded (even though it does not cite ¶ 25 of the Second Moini declaration). In ¶
`
`25, Dr. Moini explains where certain samples came from, how the samples were
`
`
`
`4
`
`
`
`
`
`prepared, the parameters of the samples, and the results of the testing. Ex. 2011 at
`
`¶ 25. This is not hearsay, and Petitioner certainly has no argument that Dr. Moini
`
`was not competent to testify about these facts based on his personal knowledge.
`
`FRE 602. Moreover, even assuming ¶ 25 of the Second Moini declaration includes
`
`hearsay, that is not a sufficient basis on which to exclude ¶ 174 of the Tsapatsis
`
`Declaration. FRE 703.
`
`C. Tsapatsis Declaration, ¶ 48
`Petitioner moves to exclude ¶ 48 of the Tsapatsis declaration because it cites
`
`
`
`to the Second Ravindran declaration (Ex. 2004), which is part of the 662 inter
`
`partes reexamination history. The Second Ravindran declaration includes Mr.
`
`Ravindran’s testimony that BASF sent a sample to Ford, Ford tested the sample,
`
`and published the results in a paper (Ex. 2002). As is clear from the declaration,
`
`these facts were known to Mr. Ravindran, and Petitioner, having elected not to
`
`cross-examine Mr. Ravindran, has no argument that Mr. Ravindran did not have
`
`personal knowledge of these facts.
`
`
`
`Petitioner also contests the Second Ravindran declaration on the grounds
`
`that an email from Ford Motor Company referenced in ¶ 8 of declaration was not
`
`attached to the declaration. The omission of this email from the Second Ravindran
`
`declaration does not warrant exclusion of ¶ 48 of the Tsaptasis declaration. First,
`
`Petitioner has not moved to exclude ¶ 8 of the Ravindran declaration from the
`
`
`
`5
`
`
`
`
`
`record. Second, even if ¶ 8 of the Ravindran declaration were not admissible
`
`evidence, it would still be permissible for Dr. Tsapatsis to rely on this paragraph of
`
`the Ravindran declaration for purposes of determining the nature of the material
`
`that was tested in the Ford paper. The Ravindran testimony is clearly probative of
`
`whether the material tested by Ford, and described as “remarkable” in the Ford
`
`Paper, falls within the scope of the 662 claims, and Petitioner has not identified
`
`any prejudicial effect to admitting the testimony. FRE 703 (“…if the facts or data
`
`would otherwise be inadmissible, the proponent of the opinion may disclose them
`
`to the jury only if their probative value in helping the jury evaluate the opinion
`
`substantially outweighs their prejudicial effect.”).
`
`D. Tsapatsis Declaration, ¶ 79
`Petitioner moves to exclude ¶ 79 of the Tsapatsis declaration because it cites
`
`
`
`to the Zones declaration (Ex. 2009), which is part of the 662 inter partes
`
`reexamination history. Dr. Tsapatsis cites to ¶ 8 of the Zones declaration as
`
`supporting his opinion that the phrase “catalyzing the reduction of the oxides of
`
`nitrogen” encompasses a number of different reactions. Even assuming the Zones
`
`declaration is inadmissible does not mean that ¶ 8 of the Tsapatsis declaration
`
`should be excluded. FRE 703. Furthermore, it is undisputed that the phrase
`
`“catalyzing the reduction of the oxides of nitrogen” encompasses a number of
`
`different reactions. Petitioner’s expert, Dr. Lercher, agreed at his deposition that
`
`
`
`6
`
`
`
`
`
`the phrase encompasses a number of different reactions exactly as stated in ¶ 8 of
`
`the Zones Declaration. Ex. 2027 at 37:19-38:22.
`
`Tsapatsis Declaration, ¶ 170
`
`E.
`Petitioner moves to exclude ¶ 170 of the Tsapatsis declaration because it
`
`
`
`cites to the Roth declaration (Ex. 2001), which is part of the 662 inter partes
`
`reexamination history. Dr. Tsapatsis’ declaration notes that Dr. Roth submitted a
`
`declaration in which he discusses skepticism expressed by the Department of
`
`Energy. Experts are permitted to base their opinions on the testimony of others,
`
`and there is no requirement that the testimony relied on be admissible. FRE 703.
`
`Furthermore, Petitioner has not moved to exclude the Roth declaration, which is
`
`separately cited at pages 40-41 of Patent Owner’s Response (Paper No. 25).
`
`II. MOTION TO EXCLUDE OPINIONS REGARDING PROPERTIES
`OF THE CLAIMED MATERIAL
`
`
`
`Petitioner moves to exclude paragraphs ¶¶ 54-55, 62-71, and 168-177 of the
`
`Tsapatsis declaration on the basis that they focus on “irrelevant and unclaimed
`
`catalyst features.” Petitioner is essentially requesting that the Board consider the
`
`issue of obviousness of the claimed CuCHA zeolite catalyst without reference to
`
`the properties exhibited by the claimed CuCHA catalyst. As explained below, as
`
`well as in Patent Owner’s Response to the Petition, Paper No. 25, at pp. 13-15,
`
`Petitioner’s argument is contrary to the law.
`
`
`
`
`
`First, Petitioner states that the “none of the ‘662 patent claims at issue in this
`
`7
`
`
`
`
`
`IPR require either ‘low temperature SCR activity’ or ‘improved hydrothermal
`
`durability.’” This argument misses the mark. The claims are directed to an
`
`aluminosilicate CuCHA catalyst having a SAR within various ranges (15-150, 15-
`
`100, 25-40, or 30) and a Cu/Al ratio within various ranges (0.25-1, 0.30-0.50,
`
`0.40), and used for the selective catalytic reduction of NOx in the presence of NH3
`
`(“NH3-SCR of NOx”). As explained by Dr. Tsapatsis, a zeolite catalyst having
`
`these parameters has been shown to exhibit certain NOx conversion percentages.
`
`Ex. 2018, ¶¶ 48-49 (discussing NOx conversion percentages disclosed in third party
`
`research papers), ¶¶ 54-55 (discussing NOx conversion percentages disclosed in the
`
`662 Patent), ¶¶ 147-150 (discussing NOx conversion percentages shown by Dr.
`
`Schutze). These properties must be considered in the evaluation of obviousness of
`
`the claimed CuCHA zeolite catalyst. Otsuka Pharm. Co. v. Sandoz, Inc., 678 F.3d
`
`1280, 1292 (Fed. Cir. 2012) (internal citations omitted) (“In determining whether a
`
`chemist would have selected a prior art compound as a lead, the analysis is guided
`
`by evidence of the compound's pertinent properties. Such properties may include
`
`positive attributes such as activity and potency, adverse effects such as toxicity,
`
`and other relevant characteristics in evidence. Absent a reason or motivation based
`
`on such prior art evidence, mere structural similarity between a prior art compound
`
`and the claimed compound does not inform the lead compound selection.”);
`
`Sanofi-Synthelabo v. Apotex, Inc., 550 F.3d 1075, 1086 (Fed. Cir. 2008) (“For
`
`
`
`8
`
`
`
`
`
`chemical compounds, the structure of the compound and its properties are
`
`inseparable considerations in the obviousness determination.”); In re Papesch, 315
`
`F.2d 381, 391 (CCPA 1963) (“From the standpoint of patent law, a compound and
`
`all of its properties are inseparable; they are one and the same thing.”); see also
`
`United States v. Adams, 383 U.S. 39, 48-49 (1966).
`
`
`
`Second, Petitioner also points out in its motion that not all CuCHA catalysts
`
`that fall within the claimed ranges perform equally. Specifically, Petitioner makes
`
`much of the fact that Example 1 in the 662 Patent, while falling within the scope of
`
`claim 1, does not perform as well as Examples 2 and 3 in the 662 Patent.
`
`However, the issue at hand is not how the claimed invention compares to itself, but
`
`how the claimed invention compares to the prior art. As explained by Dr.
`
`Tsapatsis, and not contested by Petitioner’s expert, Example 1 of the 662 Patent
`
`exhibits significantly better aged NOx conversion performance in comparison to
`
`the prior art Cu-Beta sample. Ex. 2018 at ¶¶ 54-55. Moreover, there is clear
`
`evidence that the claimed CuCHA catalyst produces unexpected results in
`
`comparison to the prior art. Patent Owner’s Response, Paper No. 25, at pp. 42-45.
`
`
`
`Finally, Petitioner cites Tyco Healthcare Grp. v. Mut. Pharm. Co., 642 F.3d
`
`1370 (Fed. Cir. 2011) for the proposition that the NOx conversion performance of
`
`the claimed CuCHA catalyst is irrelevant to the question of obviousness. The
`
`claim at issue in Tyco Healthcare was directed to a capsule including temazepam,
`
`
`
`9
`
`
`
`
`
`but did not specify an intended use for the capsule. The only distinction between
`
`the claimed capsule and the main prior art Restoril® capsules was a lower amount
`
`of temazepam, which was disclosed in other prior art. In the present case, the
`
`claims of the 662 Patent specify an intended use—NH3-SCR of NOx. Moreover, in
`
`the present case and unlike the Tyco Healthcare case (i) there is no evidence in the
`
`prior art of general efficacy of a CHA zeolite for the NH3-SCR of NOx; (ii) there is
`
`prior art that teaches away from the use of a CHA zeolite for such a reaction; and
`
`(iii) there is evidence of unexpected results. Tyco Healthcare, 642 F.3d at 1373
`
`(“[The] presumption [of obviousness] is rebuttable either by a showing that the
`
`prior art taught away from the invention or by a showing of new and unexpected
`
`results relative to the prior art.”). First, as explained by Dr. Tsapatsis, none of the
`
`prior art references in the grounds presented by Petitioner discuss the NOx
`
`conversion performance of a CHA zeolite used for the NH3-SCR of NOx. Ex. 2018
`
`at ¶¶ 72-74, 80, 85, 90, 97. Second, as also explained by Dr. Tsapatsis, the only
`
`prior art reference that discusses the performance of a CHA zeolite for the NH3-
`
`SCR of NOx explicitly teaches away from using a CHA zeolite. Ex. 2018 at ¶¶ 75,
`
`173. Finally, there is firm evidence of unexpected results. The well-known
`
`problem of hydrothermal stability of zeolite catalysts was documented in the prior
`
`art beginning as early as 1995 and as late as 2008. Ex. 2018 at ¶ 66-70. It is
`
`undisputed that the claimed CuCHA catalyst solved this problem, and that the NOx
`
`
`
`10
`
`
`
`
`
`conversion performance exhibited by the CuCHA catalyst would not have been
`
`expected in view of the closest prior art. Ex. 2018 at ¶¶ 48, 49, 63, 172-174.
`
`III. MOTION TO EXCLUDE ANALYSIS OF DR. SCHUTZE’S DATA
`
`Petitioner moves to exclude ¶¶ 147-150 of the Tsapatsis declaration. These
`
`paragraphs directly rebut the erroneous conclusions that were drawn by
`
`Petitioner’s expert, Dr. Lercher, using the data in the Schutze declaration (Ex.
`
`1115). Specifically, Dr. Lercher concluded, based solely on the Schutze data, that
`
`the claimed SAR and Cu/Al ratios lacked criticality. Dr. Tsapatsis reviewed the
`
`same data, and presented a clear analysis showing the exact opposite. Petitioner,
`
`now realizing the clear error in their own expert’s analysis, asks the Board to
`
`exclude the reasoned analysis of Dr. Tsapatsis as unreliable because it “is based on
`
`isolated testing points.” Petitioner’s motion to exclude has no merit.
`
`
`
`First, with respect to the Cu/Al ratio, Dr. Tsapatsis graphed the Schutze data
`
`for both the SAR 30 fresh and aged samples, to show how the lower Cu/Al
`
`boundary of 0.25 has criticality. Ex. 2018 at ¶¶ 147-150. The criticality of the
`
`boundary is clear from the figures themselves and the supporting explanation by
`
`Dr. Tsapatsis. Id. In addition, the graphs also refute the argument by Dr. Lercher
`
`that adjusting Cu/Al ratio produces a linear, predictable increase in NOx conversion
`
`performance.
`
`
`
`11
`
`
`
`
`
`
`
`
`The same is true for the SAR lower boundary of 15. The graph and
`
`
`
`supporting explanation by Dr. Tsapatsis plainly show that the SAR 15 boundary
`
`has criticality. Ex. 2018 at ¶¶ 147-
`
`150. And likewise, the analysis by
`
`Dr. Tsapatsis also shows that
`
`increasing SAR does not produce a
`
`linear, predictable improvement in
`
`NOx conversion performance after
`
`hydrothermal aging as Dr. Lercher
`
`wrongly concluded.
`
`IV. MOTION TO EXCLUDE PARAGRAPH ¶ 11 OF MOINI
`DECLARATION (EX. 2019)
`
`
`
`Petitioner moves to exclude ¶ 11 of the Moini Declaration (Ex. 2019). In
`
`this paragraph, Dr. Moini discusses the commercial CuCHA catalyst sold by Patent
`
`Owner. Dr. Moini explains that the CuCHA catalyst is sold on a substrate (either a
`
`
`
`12
`
`
`
`
`
`flow-through substrate or a wall flow filter), that the catalyst is specifically made
`
`for use in the NH3-SCR of NOx in the exhaust treatment system of a diesel engine,
`
`and that customers purchase the CuCHA catalyst because of properties of the
`
`CuCHA material coated on the substrate. Petitioner argues that Dr. Moini lacks
`
`personal knowledge, the statement regarding customers is hearsay, and the
`
`testimony is irrelevant. Petitioner is incorrect on all counts.
`
`
`
`First, Dr. Moini’s declaration specifically states that he is a Senior Expert
`
`and Research Fellow at BASF, a named inventor of the 662 Patent, and that he is
`
`familiar with the product specification for the CuCHA zeolite catalyst that is
`
`commercially sold by BASF. He further notes in his declaration that the final
`
`CuCHA catalyst product that is sold to customers is made according to the product
`
`specification. Thus, there is clear foundation that Dr. Moini has personal
`
`knowledge regarding the specification and manufacture of the commercial CuCHA
`
`zeolite catalyst. There is also foundation establishing that Dr. Moini is qualified to
`
`offer testimony as to why BASF customers purchase the CuCHA zeolite catalyst.
`
`In addition to being a Senior Expert and Research Fellow at BASF and a named
`
`inventor of the 662 Patent, Dr. Moini has been involved in catalyst research for
`
`more than twenty years, and is a named inventor on 30 U.S. patents, some of which
`
`pertain to zeolites for use as automotive catalysts. Ex. 2011 at ¶¶ 1-2.
`
`
`
`13
`
`
`
`
`
`
`
` Second, Dr. Moini is not relaying any statements by BASF customers, and
`
`therefore, his statement regarding why customers purchase the BASF product is
`
`not hearsay. As explained above, Dr. Moini is clearly qualified to offer testimony
`
`as to why customers would purchase the CuCHA catalyst given his extensive
`
`knowledge and experience with zeolite catalysts.
`
`
`
`Finally, Dr. Moini’s testimony has relevance to the issue of whether there is
`
`a nexus between the commercial success of the product and the claimed CuCHA
`
`catalyst. Dr. Moini’s testimony and Dr. Tsapatsis’ testimony demonstrate that the
`
`product sold by BASF falls within the scope of the claims of the 662 Patent. Ex.
`
`2018 at ¶¶ 175-177. Furthermore, Dr. Moini’s testimony shows that the
`
`commercial success of the product is due to the properties of the CuCHA material
`
`(and not, for example, due to the nature of the substrate).
`
`V. MOTION TO EXCLUDE PARAGRAPH ¶ 7 OF SCHMIDT
`DECLARATION (EX. 2034)
`
`
`
`Petitioner moves to exclude ¶ 7 of the Schmidt declaration (Ex. 2034) on the
`
`grounds of relevance and hearsay. The testimony by Ms. Schmidt about the level
`
`of BASF sales was based on her personal knowledge of data that is maintained in
`
`various databases at BASF. This testimony is not hearsay. Furthermore, if
`
`Petitioner’s objection to the evidence is based on its belief that it was denied the
`
`ability to inspect the databases underlying Ms. Schmidt’s testimony, the objection
`
`has been waived. Patent Owner received Ms. Schmidt’s declaration on February
`
`
`
`14
`
`
`
`
`
`12, 2016, and did not seek discovery of the underlying databases, nor would
`
`inspection of such databases fall within the scope of “routine discovery” under 37
`
`C.F.R. § 42.51(b). Any belated desire to inspect the databases is not a basis on
`
`which to exclude Ms. Schmidt’s testimony.
`
`
`
`Petitioner also contends that the testimony should be excluded on the
`
`grounds of relevance because Ms. Schmidt was instructed not to testify regarding
`
`the market share split between BASF and its licensee, Johnson Matthey. As is
`
`clear from the deposition transcript, Ms. Schmidt could not testify to that split
`
`without violating confidentiality provisions of the license agreement between
`
`BASF and Johnson Matthey. Ex. 1120 at 22:1-24:16. Thus, Petitioner’s objection
`
`based on relevance is improper. Ms. Schmidt’s testimony about the total market
`
`share for CuCHA catalysts is clearly relevant to the issue of commercial success.
`
`FRE 401. In addition, Petitioner is incorrect that Patent Owner has not provided
`
`any information from which to determine whether Johnson Matthey makes a
`
`CuCHA catalyst that falls within the scope of the 662 claims. Patent Owner has
`
`produced evidence that Johnson Matthey is a licensee of the 662 Patent and
`
`provided the combined CuCHA total market share owned by Patent Owner and its
`
`licensee, Johnson Matthey.
`
`
`
`For the reasons stated above, respectfully requests that Petitioner’s motion to
`
`exclude should be denied in its entirety.
`
`
`
`15
`
`
`
`Respectfully submitted,
`
` /
`
` Anish R. Desai /
`Brian E. Ferguson (Reg No. 36,801)
`Anish R. Desai (Reg. No. 73,760)
`Weil, Gotshal & Manges LLP
`1300 Eye Street NW, Suite 900
`Washington, DC 20005
`T: 202-682-7000
`brian.ferguson@weil.com
`anish.desai@weil.com
`
`16
`
`
`
`Dated: July 5, 2016
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on July 5, 2016 the foregoing
`
`PATENT OWNER’S OPPOSITION TO PETITIONER’S MOTION TO
`
`EXCLUDE was served via electronic mail, upon the following:
`
`Elizabeth Gardner
`Richard L. DeLucia
`K. Patrick Herman
`A. Anthony Pfeffer
`Orrick, Herrington & Sutcliffe LLP
`51 West 52nd Street
`New York, NY 10019-6142
`egardner@orrick.com
`rdelucia@orrick.com
`pherman@orrick.com
` apfeffer@orrick.com
`
`/ Timothy J. Andersen / c
`Timothy J. Andersen
`Case Manager
`Weil, Gotshal & Manges LLP
`1300 Eye Street NW, Suite 900
`Washington, DC 20005
`T: 202-682-7075
`timothy.andersen@weil.com
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
