throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., AND APPLE INC.,
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`Petitioners
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`v.
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`IXI IP, LLC
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`Patent Owner
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`Case IPR2015-01444
`Patent 7,039,033
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`PETITIONERS OPPOSITION TO MOTION TO EXCLUDE
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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
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` 
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`TABLE OF CONTENTS
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`INTRODUCTION ...................................................................................................... 1
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`EXHIBITS 1002, 1014, AND 1015 SHOULD BE EXCLUDED ............................. 2
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`EXHIBITS 1016 AND 1017 ARE PROPER REPLY EVIDENCE .......................... 3
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`EXHIBIT 1016 MEETS FRE 901 ............................................................................. 6
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`DATE INFORMATION IS ADMISSIBLE............................................................... 8
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`EXHIBITS 1016 AND 1017 ARE RELEVANT ....................................................... 9
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`CONCLUSION ........................................................................................................ 11 
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`i
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`EXHIBIT-1001
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`EXHIBIT-1002
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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`EXHIBIT LIST
`U.S. Patent No. 7,039,033 to Haller et al. (“’033 Patent”)
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`S. M. Bellovin et al., Network Firewalls, Network
`Firewalls, IEEE Communications Magazine, Vol. 32,
`Issue 9, pp. 50-57, 1999 (“Bellovin”)
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`EXHIBIT-1003
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`Declaration of Dr. Sayfe Kiaei
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`EXHIBIT-1004
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`Curriculum Vitae of Dr. Sayfe Kiaei
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`EXHIBIT-1005
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`PCT. Publication No. WO 01/76154 A2 to Marchand
`(“Marchand PCT”)
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`EXHIBIT-1006
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`U.S. Patent Application No. 09/541,529 to Marchand
`(“Marchand Priority”)
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`EXHIBIT-1007
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`Handley et al., Request For Comments 2543 SIP: Session
`Initiation Protocol, The Internet Society, March, 1999
`(“RFC 2543”)
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`EXHIBIT-1008
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`U.S. Patent No. 6,836,474 to Larsson (“Larsson”)
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`EXHIBIT-1009
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`K. Arnold et al., The JINITM Specification, Addison-
`Wesley, June 1, 1999 (“JINI Spec.”)
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`EXHIBIT-1010
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`U.S. Patent No. 6,560,642 to Nurmann (“Nurmann”)
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`EXHIBIT-1011
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`U.S. Patent No. 6,771,635 to Vilander (“Vilander”)
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`EXHIBIT-1012
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`Claim Chart from IXI’s Infringement Contentions of U.S.
`Patent No. 7,039,033 in 14-cv-4428 (April 9, 2015)
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`EXHIBIT-1013
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`Claim Chart from IXI’s Infringement Contentions of U.S.
`Patent No. 7,039,033 in 14-cv-4355 (March 27, 2015)
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`ii 
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`EXHIBIT-1014
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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`R. Droms, Request for Comments 2131 Dynamic Host
`Configuration Protocol, The Internet Society, March,
`1997 (“RFC 2131”)
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`EXHIBIT-1015
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`U.S. Patent No. 6,622,017 to Hoffman (“Hoffman”)
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`EXHIBIT-1016
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`J. Newmarch, A Programmer’s Guide to Jini Technology,
`Apress, 2000 (“Newmarch”)
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`EXHIBIT-1017
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`U.S. Patent No. 5,963,908 to Chadha (“Chadha”)
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`EXHIBIT-1018
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`EXHIBIT-1019
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`Deposition Transcript of Dr. Mandayam, IPR2015-01443,
`May 18, 2016
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`Deposition Transcript of Dr. Mandayam, IPR2015-01444,
`May 19, 2016
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`EXHIBIT-1020
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`Declaration of Jessica Coral Sheldon-Hess
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`iii 
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`

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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`TABLE OF AUTHORITIES
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`Case Law
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`Belden Inc. v. Berk-Tek LLC, Appeal Nos. 2014-1575, -1576, Slip Op. 20-29 (Fed.
`Cir. Nov. 5, 2015) ........................................................................................ 4,6
`
`Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579, 587 (1993) ......................... 1,9
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`Fin. Co. of Am. v. BankAmerica Corp., 493 F. Supp. 895, 900-01 (D. Md. 1980) .. 6
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`Peabody Coal Co. v. McCandless, 255 F.3d 465, 469 (7th Cir. 2001) ................. 1,9
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`Prime Ins. Syndicate, Inc. v. Damaso, 471 F. Supp. 2d 1087, 1093 (D. Nev. 2007) 6
`
`Decisions of the Patent Trial and Appeal Board
`
`Liberty Mutual Ins. v. Progressive Casualty Ins., CBM2012-00002, Paper 66, pp.
`60-61 (PTAB Jan. 23, 2014) ........................................................................ 1,9
`
`SAP America, Inc. v. Lakshmi Arunachalam, Case IPR2013-00195, slip op. at 22
`(PTAB Sept. 18, 2014) (Paper 60)) ................................................................ 7
`
`Vibrant Media, Inc., Petitioner, IPR2013-00170, Final Decision, p. 31 (PTAB June
`26, 2014) ...................................................................................................... 3,9
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`Rules and Regulations
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`37 C.F.R. § 42.123(b) ................................................................................................ 3
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`37 C.F.R. §42.62 ....................................................................................................... 3
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`37 C.F.R. §42.20 ....................................................................................................... 1
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`37 C.F.R. §42.64 ....................................................................................................... 2
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`FRE 401 .................................................................................................................. 1,2
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`FRE 402 .................................................................................................................. 1,2
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`iv 
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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`FRE 403 ..................................................................................................................... 2
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`FRE 803(6) ................................................................................................................ 8
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`FRE 803(18) .............................................................................................................. 8
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`FRE 901 .................................................................................................................. 6,8
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`FRE 901(b)(4) ........................................................................................................ 6,7
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`v 
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`
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`INTRODUCTION
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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
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`Patent Owner, IXI IP, LLC (“IXI”), filed a motion to exclude Exhibits 1002
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`and 1014-1017 on August 3, 2016. IXI, however, fails to adequately explain why
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`these exhibits are inadmissible, merely asserting inadmissibility and improperly
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`shifting the burden to Petitioners to explain why these exhibits are admissible. IXI,
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`as the moving party, bears the burden to show entitlement to the relief requested by
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`the motion to exclude. 37 C.F.R. § 42.20. IXI has not done so.
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`Indeed, relevant evidence is generally admissible. See FRE 402. “Evidence is
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`relevant if: (a) it has any tendency to make a fact more or less probable than it would
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`be without the evidence; and (b) the fact is of consequence in determining the action.
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`FRE 401. “The Rule’s basic standard of relevance thus is a liberal one.” Daubert v.
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`Merrell Dow Pharm., Inc., 509 U.S. 579, 587 (1993). Administrative agencies
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`further relax the rules of evidence as administrative judges have the skill to handle
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`evidence that may mislead a jury. See Peabody Coal Co. v. McCandless, 255 F.3d
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`465, 469 (7th Cir. 2001). With this in mind, the PTAB favors inclusion. See, e.g.,
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`Liberty Mutual Ins. v. Progressive Casualty Ins., CBM2012-00002, Paper 66, pp.
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`60-61 (PTAB Jan. 23, 2014) (“It is better to have a complete record of the evidence
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`submitted by the parties than to exclude particular pieces.”). As discussed in more
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` 
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`1
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`

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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`detail below, each of Exhibits 1002 and 1014-1017 is relevant to this proceeding and
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`admissible.
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`In accordance with 37 C.F.R. §42.64, Petitioners’ opposition addresses “the
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`objections in the record in order,” starting with the objections to Exhibit 1002. For
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`the reasons discussed below, Patent Owner’s Motion to Exclude should be denied.
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`EXHIBITS 1002, 1014, AND 1015 SHOULD BE EXCLUDED
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`In the Motion to Exclude, IXI argues that “Exhibits 1002, 1014, and 1015 are
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`not relevant under FRE 401 and 402” and “should be excluded under FRE 403 as
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`highly prejudicial.” Motion to Exclude, 10-11. IXI’s sole argument focuses on the
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`lack of citation to Exhibits 1002, 1014, and 1015 in the Petition or Petitioners’
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`Reply. See Motion to Exclude, 10-11.
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`Exhibits 1002, 1014, and 1015, however, were all relied upon and discussed in
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`Dr. Kiaei’s Declaration. Ex. 1003, ¶¶ 35, 36, 42, and 60. For instance, Exhibit 1002
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`was cited at paragraph 60 of Dr. Kiaei’s Declaration to corroborate Dr. Kiaei’s
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`testimony that “a firewall was a well-known network security software component
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`that controls access and data transfer from or to an external network.” Id., ¶ 60.
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`Exhibit 1014 was cited at paragraph 42 of Dr. Kiaei’s Declaration to corroborate Dr.
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`Kiaei’s testimony that “DHCP is known in the art as a framework to allocate IP
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`addresses for network devices.” Id., ¶ 42. Exhibit 1015 was cited at paragraphs 35
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`and 36 of Dr. Kiaei’s Declaration to corroborate Dr. Kiaei’s testimony that “it was
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` 
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`2
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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`known at the time of the Critical Date of the ’033 Patent, that a mobile phone, such
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`as Marchand’s mobile phone 33, would include a processor coupled to a storage
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`device to ‘control all operations’ of the mobile phone including the storing and
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`execution of various code or software components on the mobile phone.” Id., ¶¶ 35
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`and 36. And, each of these paragraphs of Dr. Kiaei’s declaration was cited in the
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`Petition. See, e.g., Petition, 16, 38, 45-47, 56, and 58. Thus, Exhibits 1002, 1014,
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`and 1015 corroborate and add credibility to testimony provided by Dr. Kiaei that was
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`relied upon in the Petition. For at least these reasons, Exhibits 1002, 1014, and 1015
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`are relevant to this proceeding and not prejudicial.
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`EXHIBITS 1016 AND 1017 ARE PROPER REPLY EVIDENCE
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`In the Motion to Exclude, IXI argues that Exhibits 1016 and 1017 are
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`inadmissible pursuant to 37 C.F.R. § 42.123(b). Motion to Exclude, 2. As an initial
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`matter, Petitioners note that “the Federal Rules of Evidence shall apply to a
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`proceeding.” 37 C.F.R. §42.62. The rule on supplemental information, 37 C.F.R. §
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`42.123(b), is not a Federal Rule of Evidence. As a consequence, a motion to exclude
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`is not a proper mechanism for these challenges. See Vibrant Media, Inc., Petitioner,
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`IPR2013-00170, Final Decision, p. 31 (PTAB June 26, 2014) (“A motion to exclude
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`is not a mechanism to argue that a reply contains new arguments or relies on
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`evidence necessary to make out a prima facie case”).
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`3
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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`Moreover, Exhibits 1016 and 1017 are proper reply evidence. As confirmed
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`by the Federal Circuit, evidence submitted with a Petitioner’s Reply is permitted to
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`respond to arguments made in a Patent Owner Response. Belden Inc. v. Berk-Tek
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`LLC, Appeal Nos. 2014-1575, -1576, Slip Op. 20-29 (Fed. Cir. Nov. 5, 2015). Here,
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`Exhibits 1016 and 1017 properly respond to and refute arguments made by IXI and
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`its expert, Dr. Mandayam.
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`In the Patent Owner Response, IXI took the position that a “person skilled in
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`the art would appreciate that the JINI LUS 46 must be located on the master device
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`of the Bluetooth piconet.” Patent Owner Response, 28 and 34 (emphasis added).
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`IXI’s expert, Dr. Mandayam, also testified that “the JINI LUS can only be located
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`on the master device of the Bluetooth piconet.” Ex. 2301, ¶ 55 (emphasis added).
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`Notably, neither IXI nor Dr. Mandayam cited any authority corroborating this
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`testimony. As a consequence, Petitioners investigated this issue and located Exhibit
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`1016, which contradicts Dr. Mandayam’s testimony. As explained in Petitioners’
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`Reply, Exhibit 1016 confirms that “a network may have more than one LUS” and
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`“implementing multiple JINI LUSs is particularly useful in ad-hoc networks, such as
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`Marchand’s, since the network topology is variable and the network 30 is
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`heterogeneous with devices expected to join and leave at various times.” Petitioners’
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`Reply, 7. Because Exhibit 1016 confirms that multiple LUSs are possible in an ad-
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`hoc Bluetooth network, at least one of the multiple LUSs resides on a slave device,
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` 
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`4
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`

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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`as an ad-hoc Bluetooth network includes a single master device. Thus, Exhibit 1016
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`responds to IXI’s contention that a JINI LUS must be located on a master device,
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`proving that IXI and Dr. Mandayam were incorrect. Rather than leave the record
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`with incorrect and uncorroborated testimony, Petitioners’ appropriately submitted
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`Exhibit 1016 to impeach Dr. Mandayam’s testimony and to clarify the record by
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`showing that a LUS may be located on a slave device.
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`Exhibit 1016 also responds to IXI’s contention that “Marchand’s and the JINI
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`Spec’s disclosure of a joining device publishing its proxy object to the LUS does not
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`imply a ‘plug and play software component.’” Patent Owner Response, 50. Indeed,
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`Exhibit 1016 confirms that “Jini is the name for a distributed computing
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`environment that can offer ‘network plug and work.’” Ex. 1016, 1 (emphasis
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`added). Thus, as discussed in Petitioners’ Reply, Exhibit 1016 responds to IXI’s
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`Patent Owner Response and confirms that Marchand’s JINI technology is plug and
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`play. Petitioners’ Reply, 24.
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`As for Exhibit 1017, IXI’s Patent Owner Response contends that “Marchand
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`does not teach that any device has the ability to access a webpage, let alone through
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`the mobile gateway.” Patent Owner Response, 45. In response, Petitioners point to
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`Marchand’s laptop 31 and cite Exhibit 1017 to demonstrate that “[a] well-known
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`functionality of a laptop includes webpage access for browsing the Internet” and
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`“[a]ccessing the Internet is well-known to include webpage access.” Petitioners’
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` 
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`5
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`

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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`Reply, 21. Thus, Exhibit 1017 responds to IXI’s Patent Owner Response and re-
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`confirms the positions already taken at pages 33 and 34 of the Petition.
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`For the above reasons, Exhibits 1016 and 1017 appropriately respond to IXI’s
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`arguments and confirm the prima facie case set forth in the Petition. See Belden
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`Inc., Appeal Nos. 2014-1575, -1576, Slip Op. 23-24 (Fed. Cir. Nov. 5, 2015).
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`EXHIBIT 1016 MEETS FRE 901
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`IXI argues that Exhibit 1016 is not authenticated. IXI, however, has
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`submitted nothing—e.g., evidence of tampering or alteration—to suggest that the
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`documents are anything but what they facially purport to be. Thus, IXI’s
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`unsupported challenge to the authenticity of Exhibit 1016 is not sufficient reason to
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`exclude. See Fin. Co. of Am. v. BankAmerica Corp., 493 F. Supp. 895, 900-01 (D.
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`Md. 1980) (where defendants attacked plaintiff’s failure to comply with the methods
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`of authentication set out in FRE 901, but did not challenge the authenticity of the
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`documents, the court held defendants’ failure to challenge the documents’
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`authenticity provides whatever extrinsic evidence of authenticity that might be
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`required); see also Prime Ins. Syndicate, Inc. v. Damaso, 471 F. Supp. 2d 1087, 1093
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`(D. Nev. 2007) (“[T]he Court will consider Prime’s exhibits [under FRE] 901(b)(4)
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`because Defendants neither challenge the authenticity of any of Prime’s exhibits nor
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`the facts contained therein, and because the exhibits’ appearance and contents
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`support authentication.”).
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` 
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`6
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`

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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`Regardless, under the FRE, Exhibit 1016 is self-authenticating. FRE
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`901(b)(4) states that “the appearance, contents, substance, internal patterns, or other
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`distinctive characteristics of the item, taken together with all the circumstances”
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`satisfies the authentication requirement. Exhibit 1016 is distinctive under the
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`circumstances.
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`Specifically, Exhibit 1016 is a book entitled “A Programmer’s Guide to
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`JINITM Technology,” by Jan Newmarch. Exhibit 1016 bears various trademarks,
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`publisher information, an ISBN number, a copyright notice, and date information.
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`Ex. 1016, 1-3. For these reasons, Exhibit 1016 is self-authenticating under FRE
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`901(b)(4). See SAP America, Inc. v. Lakshmi Arunachalam, Case IPR2013-00195,
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`slip op. at 22 (PTAB Sept. 18, 2014) (Paper 60)) (“Patent Owner points to
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`circumstantial evidence, including dates, websites, trademarks, copyright notices,
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`and URL links. … While the circumstantial evidence is thin, given the technical
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`nature of the documents, this panel can assess their authenticity and assign them
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`appropriate weight.”).
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`Moreover, IXI completely ignores Petitioners’ supplemental evidence. IXI
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`merely states that “Petitioner’s supplemental evidence served on July 13, 2016 also
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`fails to provide any evidence showing the authenticity of Exhibit 1016.” Motion to
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`Exclude, 6. This is inaccurate. Petitioners’ supplemental evidence includes a
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`librarian declaration that establishes authenticity and publication of Exhibit 1016.
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` 
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`7
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`

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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`See Ex. 1020 (Sheldon-Hess Declaration), ¶¶ 8-10. The librarian declaration
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`confirms that “Exhibit 1016 is an authentic copy of the book entitled ‘A
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`Programmer’s Guide to JINITM Technology’” and George Mason University’s
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`holding of the book was available “as of January 31, 2001.” Id. In this regard, the
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`librarian declaration confirms the 2000 copyright date listed in Exhibit 1016 and
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`establishes that Exhibit 1016 was publicly available by the relevant time frame. Id.
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`For the reasons discussed above, Exhibit 1016 should not be excluded under
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`FRE 901.
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`DATE INFORMATION IS ADMISSIBLE
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`IXI contends that date information appearing on Exhibit 1016 “constitutes
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`inadmissible hearsay.” Motion to Exclude, 6. IXI’s analysis, however, fails to
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`account for the supplemental evidence that was served on IXI and confirms the date
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`information appearing on Exhibit 1016 and is not hearsay. See Ex. 1020 (Sheldon-
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`Hess Declaration), ¶¶ 9-10. Also, based on the librarian declaration, the date
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`information included in Exhibit 1016 qualifies as information in a learned treatise,
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`periodical, or pamphlet under FRE 803(18). Moreover, the MARC records that were
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`relied upon in the librarian declaration (and that were provided as supplemental
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`evidence) qualify as business records under FRE 803(6). For these reasons, the date
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`information included in Exhibit 1016 should not be excluded as inadmissible
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`hearsay.
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` 
`
`8
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`

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`
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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`
`EXHIBITS 1016 AND 1017 ARE RELEVANT
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`In contesting the relevance of Exhibits 1016 and 1017, IXI first argues that
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`these exhibits “improperly raise[] new issues.” Motion to Exclude, 7. As an initial
`
`matter, the argument has no bearing on whether the evidence meets the standard of
`
`relevance under the FRE. In fact, a motion to exclude is not a proper motion to
`
`pursue these types of arguments. See Vibrant Media, Inc., Petitioner, IPR2013-
`
`00170, Final Decision, p. 31 (PTAB June 26, 2014) (“A motion to exclude is not a
`
`mechanism to argue that a reply contains new arguments or relies on evidence
`
`necessary to make out a prima facie case”).
`
`As to relevance under the FRE, the “Rule’s basic standard of relevance … is a
`
`liberal one.” Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579, 587 (1993). In
`
`fact, administrative agencies, like the PTAB, relax the rules of evidence because
`
`administrative judges have the skill to handle evidence that may mislead a jury. See
`
`Peabody Coal Co. v. McCandless, 255 F.3d 465, 469 (7th Cir. 2001). With this in
`
`mind, the PTAB favors inclusion. See, e.g., Liberty Mutual Ins. v. Progressive
`
`Casualty Ins., CBM2012-00002, Paper 66, pp. 60-61 (PTAB Jan. 23, 2014) (“It is
`
`better to have a complete record of the evidence submitted by the parties than to
`
`exclude particular pieces.”). With this background, Exhibits 1016 and 1017 are
`
`relevant to this proceeding and IXI’s conclusory arguments on relevance fail.
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` 
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`9
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`

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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`Regarding Exhibit 1016, IXI contends that “Petitioner provides no explanation
`
`regarding how or why this reference demonstrates that Marchand’s JINI technology
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`is plug and play.” Motion to Exclude, 8. This is simply untrue. As discussed above,
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`Exhibit 1016 confirms that “Jini is the name for a distributed computing
`
`environment that can offer ‘network plug and work.’” Ex. 1016, 1 (emphasis
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`added). Thus, as discussed in Petitioners’ Reply, Exhibit 1016 confirms that
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`Marchand’s JINI technology is plug and play. Petitioners’ Reply, 24. In this regard,
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`Petitioners’ Reply explains how Exhibit 1016 demonstrates that Marchand’s JINI
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`technology is plug and play. As such, Exhibit 1016 is relevant to IXI’s arguments
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`and confirms the prima facie case set forth in the Petition.
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`IXI also contends that Exhibit 1016’s description “that JINI technology
`
`supports multiple LUSs … is irrelevant to the claims of the ’033 Patent and the
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`alleged prior art.” Motion to Exclude, 8. However, as discussed above, because
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`Exhibit 1016 confirms that multiple LUSs are possible in an ad-hoc Bluetooth
`
`network, at least one of the multiple LUSs necessarily resides on a slave device, as
`
`an ad-hoc Bluetooth network includes a single master device. Thus, Exhibit 1016
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`responds to IXI’s contention that a JINI LUS must be located on a master device,
`
`proving that IXI and Dr. Mandayam were incorrect in concluding that a LUS must
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`be located on a master device in a Bluetooth network.
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`10
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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`Regarding Exhibit 1017, IXI contends that “Petitioner’s conclusory statements
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`fail to establish how Exhibit 1017 demonstrates this functionality and how it relates
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`to the claims of the ’033 Patent or the alleged prior art.” Motion to Exclude, 9.
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`Again, this is simply not true.
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`As discussed above, IXI’s Patent Owner Response contends that “Marchand
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`does not teach that any device has the ability to access a webpage, let alone through
`
`the mobile gateway.” Patent Owner Response, 45. In response, Petitioners point to
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`Marchand’s laptop 31 and cite Exhibit 1017 to demonstrate that “[a] well-known
`
`functionality of a laptop includes webpage access for browsing the Internet” and
`
`“[a]ccessing the Internet is well-known to include webpage access.” Petitioners’
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`Reply, 21. Thus, Exhibit 1017 responds to IXI’s Patent Owner Response and re-
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`confirms the positions already taken at pages 33 and 34 of the Petition. As such,
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`Exhibit 1016 is relevant to IXI’s arguments and confirms the prima facie case set
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`forth in the Petition.
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`For the reasons discussed above, Exhibits 1016 and 1017 are relevant to this
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`proceeding and should not be excluded.
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`CONCLUSION
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`For the above reasons, Petitioners submit that Exhibits 1002 and 1014-1017
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`should be allowed entry into the proceeding, and Patent Owner’s Motion to Exclude
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`these exhibits should not be granted.
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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`Respectfully submitted,
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`
`
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`
`
`/Jeremy J. Monaldo/
`W. Karl Renner, Reg. No. 41,265
`Jeremy J. Monaldo, Reg. No. 58,680
`Fish & Richardson P.C.
`P.O. Box 1022
`Minneapolis, MN 55440-1022
`T: 202-626-6376
`F: 202-783-2331
`
`Attorneys for Petitioners
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`Dated: August 17, 2016
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`Case IPR2015-01444
`Attorney Docket No: 00035-0004IP1
`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR §§ 42.6(e)(1) and 42.6(e)(4)(iii), the undersigned certifies
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`that on August 17, 2016, a complete and entire copy of this Petitioners Opposition to
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`Motion to Exclude was provided via email to the Patent Owner by serving the email
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`correspondence addresses of record as follows:
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`Andy H. Chan
`Pepper Hamilton LLP
`333 Twin Dolphin Drive, Suite 400
`Redwood City, CA 94065
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`George S. Haight
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
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`Email: chana@pepperlaw.com
`Email: haightg@pepperlaw.com
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`/Diana Bradley/
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`Diana Bradley
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(858) 678-5667
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