UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`VOLKSWAGEN GROUP OF AMERICA, INC.
`
`Petitioner
`
`v.
`
`JOAO CONTROL & MONITORING SYSTEMS, LLC
`
`Patent Owner
`
`Patent No. 7,397,363
`Issue Date: July 8, 2008
`Title: CONTROL AND/OR MONITORING
`APPARATUS AND METHOD
`
`__________________________________________________________________
`
`PETITIONER’S REPLY
`
`Case No. IPR2015-01612
`__________________________________________________________________
`
`
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`VOLKSWAGEN GROUP OF AMERICA, INC.
`
`Petitioner
`
`v.
`
`JOAO CONTROL & MONITORING SYSTEMS, LLC
`
`Patent Owner
`
`Patent No. 7,397,363
`Issue Date: July 8, 2008
`Title: CONTROL AND/OR MONITORING
`APPARATUS AND METHOD
`
`__________________________________________________________________
`
`PETITIONER’S REPLY
`
`Case No. IPR2015-01612
`__________________________________________________________________
`
`
`
`
`
`
`TABLE OF CONTENTS
`
`I.
`
`INTRODUCTION ......................................................................................... 1
`
`II. CLAIM CONSTRUCTION .......................................................................... 2
`
`A.
`
`“First Signal” and “Second Signal” Need Not Be Construed ......... 2
`
`III. CLAIMS 68, 69, 72, 74, 77, AND 80 ARE INVALID................................. 4
`
`A. Claims 68, 69, 74, 77, and 80 are Anticipated by Spaur .................. 4
`
`1.
`
`2.
`
`Spaur describes a chain of three devices for monitoring a
`vehicle system/component ........................................................ 5
`
`Spaur describes dependent claims 69, 74, 77, and 80 .......... 10
`
`B.
`
`Claim 72 is Obvious in View of Spaur ............................................. 12
`
`1.
`
`Using a wireless device, cellular telephone, or personal
`digital assistant as the communication device ould have
`been obvious ............................................................................. 12
`
`IV. CONCLUSION ............................................................................................ 14
`
`
`
`i
`
`
`
`LISTING OF EXHIBITS
`
`U.S. Patent No. 7, 397,363 to Joao
`
`U.S. Patent No. 6,072,402 to Kniffin
`
`U.S. Patent No. 5,070,320 to Ramono
`
`U.S. Patent No. 5,732,074 to Spaur
`
`U.S. Patent No. 5,081,667 to Drori
`
`Declaration of Scott Andrews
`
`Supplement to the Remarks for the Amendment Filed on
`October 24, 2007
`
`Response to Office Action, June 1, 2015
`
`August 18, 2015 Memorandum Opinion and Order
`Regarding Claim Construction in Joao Control &
`Monitoring Systems, LLC v. Protect America, Inc., Case
`No. 1:14-cv-134 (W.D. Tex.)
`
`March 23, 2016 Memorandum Opinion and Order in
`Joao Control & Monitoring Systems, LLC v. Telular
`Corp., Case No. 1:14-cv-09852 (N.D. Ill.)
`
`June 10, 2016 Opinion and Order (1) Granting In Part
`and Denying In Part Defendant FCA US LLC’S Motion
`for Summary Judgment on Invalidity and
`Noninfringement (Dkt. 59) and (2) Denying as Moot
`Plaintiff Joao Control & Monitoring Systems, LLC’S
`Motion for Summary Judgment of Infringement of U.S.
`Patent No. 7,397,363 by UConnect Access (Dkt. 57) in
`Joao Control & Monitoring Systems, LLC v. Chrysler
`Group LLC, Case No. 4:13-cv-13957
`
`ii
`
`Exhibit 1001
`
`Exhibit 1002
`
`Exhibit 1003
`
`Exhibit 1004
`
`Exhibit 1005
`
`Exhibit 1006
`
`Exhibit 1007
`
`
`Exhibit 1008
`
`Exhibit 1009
`
`
`Exhibit 1010
`
`
`Exhibit 1011
`
`
`
`
`
`
`
`I.
`
`INTRODUCTION
`
`This Petitioner’s Reply is responsive to the Patent Owner’s Response to
`
`Petition for Inter Partes Review Under 37 C.F.R. § 42.107 (the “Response”).
`
`As set forth in the Petition, the claims of U.S. Patent No. 7,397,363 (the
`
`“’363 patent”) are invalid in view of the prior art cited therein, including U.S.
`
`Patent No. 5,732,074 (Ex. 1004, “Spaur”). Despite the Patent Owner’s (“Joao”)
`
`assertions that the ’363 patent describes a “novel and unconventional system,” and
`
`claims “a specially assembled and programmed distributed control and monitoring
`
`system for vehicles” (Response, at 2), the ’363 patent merely claims a conventional
`
`chain of signals among three devices. As set forth in the Petition, the claimed
`
`systems are disclosed by the cited prior art and were well known before the earliest
`
`effective filing date of the ’363 patent, such that the challenged claims are invalid
`
`and should be canceled.
`
`In its Response, Joao argues that Spaur fails to describe a second processing
`
`device that receives a first signal from a first processing device, and that generates
`
`and transmits a second signal to a communication device. As described in the
`
`Petition, and below, Spaur describes the second processing device claimed by the
`
`’363 patent, so that the challenged claims are unpatentable, and should be
`
`canceled.
`
`1
`
`
`
`II. CLAIM CONSTRUCTION
`A.
`“First Signal” and “Second Signal” Need Not Be Construed
`
`The terms “first signal” and “second signal” should be given their ordinary
`
`and customary meaning, as would be understood by a person of ordinary skill in
`
`the art, at the time of the alleged invention, considering the claim language, the
`
`specification, and the prosecution history. Phillips v. AWH Corp., 415 F.3d 1303,
`
`1312, 1327 (Fed. Cir. 2005). In this case, the specification and prosecution history
`
`do not provide any special definition of the terms “first signal” and “second
`
`signal.” Nor does Joao assert otherwise.
`
`Instead, Joao asserts that the claim terms “first signal” and “second signal”
`
`require construction, that “first signal” is “a signal sent by a first device,” and that
`
`“second signal” is “a signal sent by a second device.” Response, at 9. Joao does not
`
`explain why these terms are not entitled to their ordinary and customary meaning
`
`according to Phillips, nor does Joao refer to any intrinsic evidence to support its
`
`proposed constructions. Joao relies only on a claim construction decision from
`
`Joao Control & Monitoring Systems, LLC v Chrysler Group LLC, Case No. 13-cv-
`
`13957 (E.D. Mich.). Response at 9.
`
`Joao’s reliance on this district court decision is misplaced. First, Joao
`
`incorrectly states that the Michigan court “construed the terms ‘first signal,’
`
`‘second signal,’ and ‘third signal.’” The Michigan court expressly did not construe
`
`2
`
`
`
`these terms. Ex. 2003, at 23 (“After considering the claim term and the claims as a
`
`whole, the Court finds that the terms ‘first signal,’ second signal,’ and ‘third
`
`signal’ do not need to be construed, at least at this time, because the claim
`
`language is clear.”), and at 25 (“Accordingly, the Court will not rewrite or redefine
`
`claim terms which are otherwise clear to preserve the validity of the claims or
`
`defeat an anticipated invalidity argument.”). Second, the portion of that court’s
`
`opinion on which Joao relies only notes that the parties in that case agreed on the
`
`meaning of the terms; the court did not construe the terms accordingly. Id.
`
`The claim language is clear on its face, so that no construction is necessary.
`
`Joao’s narrow proposed constructions are both contradictory and redundant of the
`
`remaining claim language. Claim 68 recites “the first processing device at least one
`
`of generates a first signal and transmits a first signal to a second processing
`
`device,” and “the second processing device at least one of generates a second
`
`signal and transmits a second signal to a communication device.” As stated in the
`
`Petition (see p. 16), during the original examination of the ’363 patent, Joao
`
`asserted in the November 23, 2007 supplemental paper that “at least one of … and
`
`…” means “only one item from the list, or any combination of items in the list.”
`
`Ex. 1007, at 2-3. That is, by Joao’s own statement, claim 68 requires that the first
`
`processing device perform one of three functions:
`
`(i)
`
`generate a first signal; or
`
`3
`
`
`
`(ii)
`
`transmit the first signal; or
`
`(iii) generate and transmit the first signal.
`
`Yet, Joao’s proposed construction would contradict this claim language, because it
`
`would eliminate function (i), in which the first processing device generates, but is
`
`not necessarily required to transmit, the first signal. Joao’s proposed construction is
`
`also redundant of this claim language, because the claim already describes
`
`functions (ii) and (iii) in which the first processing device transmits the first signal.
`
`These claim terms are unambiguous, no construction of these terms is
`
`necessary. As the Michigan court noted, the Board should not “rewrite or redefine
`
`claim terms which are otherwise clear to preserve the validity of the claims or
`
`defeat an anticipated invalidity argument.” Ex. 2003, at 23.
`
`III. CLAIMS 68, 69, 72, 74, 77, AND 80 ARE INVALID
`A. Claims 68, 69, 74, 77, and 80 are Anticipated by Spaur
`
`Joao states that it “disagrees with the Petitioner’s interpretation of
`
`‘processing device’ that would allow the CDPD network modem 76 of Spaur to
`
`serve as the ‘second processing device’ of claim 68.” Response, at 10. According
`
`to Joao, the CDPD network modem 76 cannot be a “processing device” because it
`
`is “merely a component of a communication system or communication network.”
`
`Id. However, during prosecution of the ’363 patent, Joao submitted to the USPTO
`
`4
`
`
`
`“Supplemental to the Remarks for the Amendment Filed on October 24, 2007”
`
`(Ex. 1007), in which the following definition of “processing device” was provided:
`
`“Processing device” means “a device or a computer, or that part of a
`device or a computer, which performs an operation, an action, or a
`function, or which performs a number of operations, actions, or
`functions.”
`Spaur describes the operations, actions, or functions of the CDPD network
`
`modem 76 as, for example, “prepar[ing] the information in a conventionally
`
`acceptable manner for transmission and communication with a cellular phone 80
`
`which is contained in the vehicle” (Spaur, 7:40-47), “packetize[ing] the data
`
`message so that it can be properly transmitted over the airlink” (Spaur, 12:51-54),
`
`and “collect[ing] such data … and subsequently pass[ing] the vehicle data to the
`
`Internet” (Spaur, 14:19-25). Thus, despite Joao’s arguments to the contrary, the
`
`CDPD network modem 76 constitutes a “processing device” according to Joao’s
`
`definition as presented in Ex. 1007.
`
`1.
`
`Spaur describes a chain of three devices for monitoring a
`vehicle system/component
`
`Joao’s Response contends that “Spaur fails to disclose the ‘A to B to C’
`
`system of claim 68.” Response, at 10-19. As explained in the Petition (see pp. 47–
`
`49), Spaur describes monitoring data from vehicle devices 50, including “GPS
`
`(global positioning system), dead reckoning sensors, facsimile machine, PDA
`
`(personal digital assistant), laptop computer, printer, display unit, modem, CD-
`
`5
`
`
`
`ROM unit, storage device, medical conditioning sensors, vehicle condition sensors,
`
`vehicle cargo sensors, airbag sensor and general alarm sensors related to unlocking
`
`the vehicle or unwanted intrusion into the vehicle,” and transmitting that data to a
`
`remote site. Spaur, 3:30-39, 4:24-29, 8:49-53, 9:62-10:9. Examples include
`
`“monitoring of vehicle locations and status” and “vehicle parameter monitoring for
`
`maintaining the vehicle such as checking engine conditions including possibility of
`
`overheating and operating mileage (odometer reading).” 9:3-12. Controller 30 may
`
`also transmit notifications to the one or more stations when a particular event
`
`occurs, such as a sensor measuring a particular value. Spaur, 12:18-30; Ex. 1006, ¶
`
`33. The data is transmitted by wireless device 18 over an airlink, to the CDPD
`
`network modem 76, over the Internet 68, to the computer terminal 60. Spaur, 7:13-
`
`47; Fig. 2; Ex. 1006, ¶ 34.
`
`Specifically, Spaur describes that a second processing device automatically
`
`receives the first signal, and sends a second signal to a communication device,
`
`located remote from the second processing device, via, on, or over, the Internet
`
`and/or the World Wide Web, and the communication device automatically receives
`
`the second signal and provides information regarding the event. Spaur describes
`
`that data obtained by the controller 30 may be transmitted to at least one remote
`
`station, for analysis. Spaur, 4:24-29. The data is transmitted from controller 30 (the
`
`first processing device) via cellular phone 80 to the CDPD network modem (the
`
`6
`
`
`
`second processing device), and it is then transmitted over Internet 68 to computer
`
`terminal 60 (the communication device). Spaur, 7:13-47; see also 4:14-16, 4:26-29;
`
`Figs. 1, 2; Ex. 1006, ¶¶ 34-35.
`
`Joao argues that Spaur describes additional devices in the chain of
`
`communication between the controller 30 and the computer terminal 60. Joao
`
`points to the various devices that Spaur describes in the chain of communication—
`
`phone interface 84, CDPD network modem 82, cellular phone 80, CDPD network
`
`modem 76, and modem 64—and concludes that Spaur describes an “A to B to C to
`
`D to E to F to G” system, and not an “A to B to C” system as purportedly claimed
`
`by the ’363 patent.1 Response at 11–17. Joao’s argument requires an interpretation
`
`of the challenged claims in which the second processing device can only receive a
`
`signal transmitted directly from the first processing device, and the communication
`
`device can only receive a signal transmitted directly from the second processing
`
`device, with no devices in between.
`
`As discussed above, this interpretation of the claims is not supported by the
`
`claim language, the specification, or the prosecution history. The challenged claims
`
`1
`Claim 68 uses the transitional phrase, “comprising,” which is inclusive or
`
`open-ended and does not exclude additional, unrecited elements or method steps.
`
`See, M.P.E.P. § 2111.03 (citing Mars Inc. v. H.J. Heinz Co., 377 F.3d 1369, 1376
`
`(Fed. Cir. 2004)).
`
`7
`
`
`
`do not exclude the system described by Spaur, in which controller 30 uses cellular
`
`phone 80 to transmit data. The data is transmitted from controller 30 (the first
`
`processing device) via cellular phone 80 to the CDPD network modem 76 (the
`
`second processing device), and it is then transmitted over Internet 68 to computer
`
`terminal 60 (the communication device). Spaur, 7:13-47; see also 4:14-16, 4:26-
`
`29; Figs. 1, 2; Ex. 1006, ¶¶ 34-35. That Spaur describes the use of transmission and
`
`interface devices (e.g., wireless device 18, transfer protocol modem 20, and
`
`interface 22, or cellular phone 80, vehicle CDPD network modem 82, and phone
`
`interface 84) does not change the ultimate conclusion about Spaur’s disclosure:
`
`that “the controller 30 is able to prepare information for sending to a remote station
`
`10,” over a remote modem using the Internet. Spaur, 7:13-47; Figs. 1, 2.
`
`According to Joao’s Response, claim 68 “requires that the ‘second
`
`processing device’ receive a first signal sent from the claims ‘first processing
`
`device.’” Response, at 11. However, Joao’s Response mischaracterizes claim 68.
`
`For example, claim 68 states that the first processing device generates a first signal
`
`and/or transmits a first signal to a second processing device (“wherein the first
`
`processing device at least one of generates a first signal and transmits a first signal
`
`to a second processing device”). There is no requirement in claim 68 that the first
`
`signal is sent to the second processing device by the first processing device: the
`
`first processing device may merely generate the first signal. Furthermore, claim 68
`
`8
`
`
`
`merely states that that the second processing device automatically receives the first
`
`signal (“wherein the second processing device automatically receives the first
`
`signal”), without specifying that the first signal is received by the second
`
`processing device from the first processing device. In other words, the first
`
`processing device may generate the first signal (but not transmit it to the second
`
`processing device), and the second processing device may receive the first signal
`
`from an intermediate device located between the first and second processing
`
`devices, and still fall within the scope of claim 68.
`
`Similarly, Joao’s Response states that claim 68 “requires that the
`
`‘communication device’ receives a ‘second signal’ from the second processing
`
`device.” Response, at 12. Joao’s Response again mischaracterizes claim 68. For
`
`example, claim 68 states that the second processing device generates a second
`
`signal and/or transmits a second signal to a communication device (“wherein the
`
`second processing device at least one of generates a second signal and transmits a
`
`second signal to a communication device”). There is no requirement in claim 69
`
`that the second signal is sent to the communication device by the second
`
`processing device: the second processing device may merely generate the second
`
`signal. Furthermore, claim 68 merely states that the second signal is transmitted to
`
`the communication device, without specifying that the communication device
`
`receives the second signal from the second processing device. Indeed, claim 68
`
`9
`
`
`
`states that the second signal is transmitted to the communication device “via, on, or
`
`over, at least on [sic] of the Internet and the World Wide Web,” which could entail
`
`additional processing or communication devices located in between the second
`
`processing device and the communication device.
`
`Spaur describes dependent claims 69, 74, 77, and 80
`
`2.
`As to claim 69, Spaur describes the use of software executable programs to
`
`obtain data or other information associated with vehicle devices. Spaur, 3:30-39,
`
`3:66-4:5. Further, Spaur describes web server 102 being programmed to provide a
`
`notification when a particular event occurs, such as when a vehicle reaches a
`
`location, or when a sensor measures a particular value. Spaur, 12:18-30; Ex. 1006,
`
`¶ 36. Spaur therefore discloses the additional limitations of, and, consequently
`
`anticipates, claim 69. Joao argues that Spaur does not disclose an intelligent agent,
`
`software agent, or mobile agent. Response, at 17. Claim 69, however, does not
`
`require an intelligent agent, software agent, or mobile agent, because claim 69
`
`further recites that the apparatus may, in the alternative, be programmed for
`
`automatic activation or automatic operation. Joao does not address this aspect of
`
`claim 69, nor does Joao address Spaur’s disclosure of software programming for
`
`obtaining data, or providing notifications. Spaur, 3:30-39, 3:66-4:5, 12:18-30; Ex.
`
`1006, ¶ 36.
`
`10
`
`
`
`As to claim 74, Spaur describes a system for reporting data from a vehicle
`
`control to remote stations. As described by Spaur, a program memory stores
`
`executable programs used to obtain data “associated with the vehicle devices.”
`
`Spaur, 3:30-36, see also 8:49-53. Exemplary applications include “monitoring of
`
`vehicle locations and status,” and “vehicle parameter monitoring for maintaining
`
`the vehicle such as checking engine conditions including possibility of overheating
`
`and operating mileage (odometer reading).” Spaur, 9:3-12. The data may then be
`
`transmitted to a remote station for analysis. Spaur, 4:24-29. The vehicle devices
`
`may include “common vehicle parts or components” (7:5-10) and a variety of
`
`vehicle sensors (9:62-10:9). Ex. 1006, ¶ 37. Spaur therefore discloses the
`
`additional limitations of, and, consequently anticipates, claim 74. Joao’s lone
`
`argument as to claim 74 is that “Spaur does not even contain the word
`
`‘diagnostic.’” Response, at 19. Joao does not address the actual disclosure of
`
`Spaur, which, as discussed above and in the Petition, includes applications for
`
`monitoring vehicle status or engine conditions, such as overheating and operating
`
`mileage. Spaur, 9:3-12. Spaur need not literally use the word “diagnostic” to
`
`describe a diagnostic signal.
`
`The only argument made by Joao relating to claims 77 and 80 is that claims
`
`77 and 80 are patentable based on their dependency from claim 68. Response, at
`
`17. As set forth in the Petition (see pp. 50-52, 56-58), Spaur discloses the
`
`11
`
`
`
`additional limitations of claims 77 and 80, such that claims 77 and 80 are
`
`anticipated in view of Spaur.
`
`B. Claim 72 is Obvious in View of Spaur
`
`1.
`
`Using a wireless device, cellular telephone, or personal
`digital assistant as the communication device ould have
`been obvious
`
`As explained in the Petition (see pp. 59–60), providing Spaur’s computer
`
`terminal 60 as a wireless device, a cellular telephone, or a personal digital assistant
`
`would have been obvious to a person of ordinary skill in the art at the time of the
`
`effective filing date of the ’363 patent. Such communication devices were well
`
`known before the filing of the ’363 patent. See, e.g., Kniffin, Ex. 1002. For
`
`example, Spaur describes a “wireless device” contained in the vehicle for
`
`transmitting and receiving information over an air link (6:3-5), and further
`
`describes that such devices may be among vehicle devices 50 (e.g., at 10:1-9,
`
`describing a PDA or laptop computer).2 Using a wireless device, a cellular
`
`telephone, or a personal digital assistant as the communication device in the system
`
`described by Spaur would have been well within the understanding of a person of
`
`ordinary skill in the art at the time the alleged invention of claim 72 was made, and
`
`
`2
`See also, Kniffin at 2:32-35, which refers to a cellular telephone 22, which is
`
`both a “wireless device” and “a cellular telephone” as claimed in claim 72.
`
`12
`
`
`
`it would have been obvious to do so, to allow the user to operate the system from a
`
`mobile device. Ex. 1006, ¶ 40.
`
`Joao asserts that “Mr. Andrews could not support this position during cross-
`
`examination.” Response at 19-20. First, Joao does not address the statements made
`
`in the Petition about the obviousness of claim 72, leaving the Petition unrebutted.
`
`Second, Mr. Andrews testified, by declaration, that such wireless devices, cellular
`
`telephones, and personal digital assistants were well-known as of the filing of the
`
`’363 patent, and that the use of a mobile device would have been obvious. Ex.
`
`1006, ¶ 40.3 Then, during his cross examination, Mr. Andrews testified that people
`
`“could certainly contact using a cellular telephone contact, an Internet gateway,
`
`and obtain information from devices on the Internet via an Internet gateway.” Ex.
`
`2004, 45:16-19. Joao has no basis for its statement that Mr. Andrews could not
`
`support this position during cross-examination.
`
`Joao’s argument, that “cellular telephones were not typically used with the
`
`Internet in 1996” (Response at 20), does not address the question of whether a
`
`person of ordinary skill in the art at the time of the alleged invention would have
`
`found it obvious to use a wireless device, cellular telephone, or personal digital
`
`assistant for the computer terminal of Spaur. Joao refers to a New York Times
`
`3
`Counsel for Joao chose not to cross-examine Mr. Andrews about his
`
`declaration testimony on this point.
`
`13
`
`
`
`article (Ex. 2005), describing the AT&T Pocketnet cellular phone as “[a]iming to
`
`make it easier to connect wirelessly to the Internet.” Joao refers to a quote from
`
`that article, stating that the AT&T phone was “too expensive to be a mass market
`
`product.” Response at 20. Joao does not include the remainder of the quote, which
`
`shows that the technology was well-known, and even popular: the quote continues,
`
`“[b]ut there are 35 million people who are willing to carry a cellular phone, so this
`
`is no longer a technology question.” Joao’s own evidence points to the conclusion
`
`that the use of a wireless device, cellular telephone, or personal digital assistant for
`
`the computer terminal of Spaur would have been obvious.
`
`IV. CONCLUSION
`
`As set forth in the Petition, claims 68, 69, 72, 74, 77, and 80 of the ’363
`
`patent are invalid in view of the prior art. For the reasons set forth in the Petition,
`
`and herein, Petitioner, Volkswagen Group of America, Inc., respectfully requests
`
`the cancellation of claims 68, 69, 72, 74, 77, and 80 of the ’363 patent.
`
`
`
`
`
`
`/Clifford A. Ulrich/
`Clifford A. Ulrich (Reg. No. 42,194)
`
`Dated: August 8, 2016
`
`
`
`
`
`Michael J. Lennon (Reg. No. 26,562) Lead Counsel
`Clifford A. Ulrich (Reg. No. 42,194) Backup Counsel
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004
`
`
`
`
`
`
`
`14
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`
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`
`
`CERTIFICATE OF WORD COUNT
`
`The foregoing Petitioner’s Reply complies with the type-volume limitations
`
`of 37 C.F.R. § 42.24(c)(1). Excluding the items listed in 37 C.F.R. § 42.24(c) as
`
`not included in the word count, and using the word count of the word-processing
`
`system used to prepare the paper (Microsoft Word), the petition contains 3,341
`
`words.
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`
`
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`
`
`
`
`
`
`
`
`Michael J. Lennon (Reg. No. 26,562) Lead Counsel
`Clifford A. Ulrich (Reg. No. 42,194) Backup Counsel
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004
`Tel:
`
`212.425.7200
`Fax:
`
`212.425.5288
`Email:
`mlennon@kenyon.com
`culrich@kenyon.com
`
`
`
`
`
`
`
`
`/Clifford A. Ulrich/
`Clifford A. Ulrich (Reg. No. 42,194)
`
`
`
`15
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`
`
`CERTIFICATE OF SERVICE
`
`The foregoing Petitioner’s Reply was served on August 8, 2016, via email
`
`
`
`upon the following:
`
`Raymond A. Joao, Reg. No. 35,907
`rayjoao@optonline.net
`René A. Vazquez, Reg. No. 38,647
`rvazquez@sinergialaw.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Clifford A. Ulrich/
`Clifford A. Ulrich (Reg. No. 42,194)
`
`
`
`
`
`
`
`Michael J. Lennon (Reg. No. 26,562) Lead Counsel
`Clifford A. Ulrich (Reg. No. 42,194) Backup Counsel
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004
`Tel:
`
`212.425.7200
`Fax:
`
`212.425.5288
`Email:
`mlennon@kenyon.com
`culrich@kenyon.com
`
`
`
`16
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