By: Christopher Frerking (chris@ntknet.com)
`
`Reg. No. 42,557
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`LAM RESEARCH CORP.,
`Petitioner
`
`v.
`
`DANIEL L. FLAMM,
`
`Patent Owner
`
`CASE IPR2015-01767
`U.S. Patent No. 6,017,221
`
`
`
`PATENT OWNER’S PRELIMINARY RESPONSE
`UNDER 37 C.F.R. § 42.107
`
`
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`Reg. No. 42,557
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`LAM RESEARCH CORP.,
`Petitioner
`
`v.
`
`DANIEL L. FLAMM,
`
`Patent Owner
`
`CASE IPR2015-01767
`U.S. Patent No. 6,017,221
`
`
`
`PATENT OWNER’S PRELIMINARY RESPONSE
`UNDER 37 C.F.R. § 42.107
`
`
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`
`Introduction …………………………………………………………………1
`
`A. Horizontal Redundancy……………………………………………………...2
`
`TABLE OF CONTENTS
`
`TABLE OF CONTENTS …………………………………………………………...i
`
`TABLE OF AUTHORITIES…………………………………………………….....ii
`
`I.
`
`II. Overview of the ‘221 Patent………………………………………………....1
`
`III. The Petitioner Fails To Satisfy Its Burden…………………………………..2
`
`
`
`
`
`
`B. Lieberman……………………………………………………………………3
`
`C. Dible…………………………………………………………………………8
`
`D. Dependent Claims………………………………………………………….12
`
`IV. Conclusion………………………………………………………………….13
`
`CERTIFICATE OF SERVICE……………………………………………………14
`
`
`
`i
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`
`TABLE OF AUTHORITIES
`
`
`Statutes Page(s)
`
`35 U.S.C. § 103…………………………………………………………………….8
`
`37 C.F.R. § 42.107………………………………………………………………….1
`
`Cases Page(s)
`
`Hartness Int’l Inc. v. Simplimatic Eng. Co.,
`819 F.2d 1100 (Fed. Cir. 1987)…………………………………………………...13
`
`Kimberly Clark Corp. v. Johnson & Johnson,
`745 F.2d 1437 (Fed. Cir. 1984)…………………………………………………...13
`
`Liberty Mutual Ins. Co. v. Progressive Cas. Ins. Co.,
`CBM2012-0003, Paper No. 7 at 2 (P.T.A.B. Nov. 26, 2012)…………………….13
`
`
`
`ii
`
`
`
`
`
`
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`Daniel L. Flamm, Sc.D., the sole inventor and owner of the U.S. Patent No.
`
`
`
`6,017,221 (“the ‘221 patent”), through his counsel, submits this preliminary
`
`response pursuant to 37 C.F.R. § 42.107 and asks that the Patent Trial and Appeals
`
`Board decline to institute inter partes review on the instant petition because the
`
`petition fails to show a reasonable likelihood that any claim is unpatentable.
`
`I.
`
`
`
`Introduction
`
`Lam makes two invalidity contentions for the single independent claim of
`
`the ‘221 patent; anticipation via either of the Lieberman references (Ex’s 1002 and
`
`1012) and obviousness via either of the Lieberman references in view of the Dible
`
`patent (Ex. 1003). As will be demonstrated, neither ground supports inter partes
`
`review.
`
`II. Overview of the ‘221Patent
`
`
`The problems that Dr. Flamm was addressing in making the invention of the
`
`‘221 patent were reduction, elimination, and/or control of ion bombardment or ion
`
`flux to semiconductor device surfaces being processed in inductively coupled
`
`plasmas, while maintaining desired etching selectivity. (Ex. 1001 at 2:7-:16.)
`
`Conventional ion assisted plasma etching, however, often requires
`control and maintenance of ion flux intensity and uniformity within
`selected process limits and within selected process energy ranges.
`Control and maintenance of ion flux intensity and uniformity are often
`difficult to achieve using conventional techniques. For instance,
`capacitive coupling between high voltage selections of the coil and the
`
`
`
`1
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`
`plasma discharge often cause high and uncontrollable plasma
`potentials relative to ground.
`(Id. at 2:64-3:2.)
`
`The specification discusses at length the “conventional techniques,”
`
`including “shields, baffles, large separation distances between the plasma source
`
`and the chamber.” (Id. at 2:17-:19; see also generally id. at 1:44-4:57.) The
`
`specification also discusses the many drawbacks of these conventional techniques.
`
`(Id. at 1:44-4:57.)
`
`Dr. Flamm’s solution, as reflected in claim 1 of the patent, was to balance
`
`the phase and anti-phase portions of capacitive currents coupled from the inductive
`
`coupling structure using a wave adjustment circuit. Instead of suppressing the
`
`charged species, as conventional techniques had done via blockage or distance, Dr.
`
`Flamm went to the source of the ion flux problem and reduced or eliminated the
`
`undesired capacitive ion current flux.
`
`III. The Petitioner Fails To Satisfy Its Burden
`A. Horizontal Redundancy
`At the threshold, Lam relies on multiple prior art references to satisfy several
`
`claims elements in the petition. For example, Lam cites to the Lieberman
`
`references (Ex’s 1002 and 1012) and to Dible (Ex. 1003) for each and every
`
`element of claims 1, 5, and 6 on Ground 2. (Pet. at 39-42, 44-45.) Lam also cites
`
`
`
`2
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`
`to multiple prior art references for claim 2 on Ground 3 (Pet. at 50.)
`
`The assertion of “multiple grounds, which are presented in a redundant
`
`manner by a petitioner who makes no meaningful distinction between them, are
`
`contrary to the regulatory and statutory mandates, and therefore are not all entitled
`
`to consideration.” Liberty Mutual Ins. Co. v. Progressive Cas. Ins. Co.,
`
`CBM2012-0003, Paper No. 7 at 2 (P.T.A.B. Nov. 26, 2012). Petitioners must
`
`“explain why one reference more closely satisfies the claim limitation at issue in
`
`some respects than another reference and vice versa.” Id. at 3.
`
`The Board should reject Lam’s attempt to invalidate the claims of the ‘221
`
`patent by relying on multiple pieces of prior art to attack the same claim elements
`
`without the required explanation of the relative merits of each instance where
`
`multiple prior art references relate to a single claim element.
`
`Lieberman
`B.
`In this Petition, Lam relies heavily on two iterations of Lieberman (Exs.
`
`1002 and 1012), which Lam concedes are essentially identical in content with
`
`minor variations that do not affect the invalidity analysis. (Pet. at 5, n.3.)
`
`Lam contends that Lieberman anticipates claim 1 of the ‘221 patent. The
`
`portion of Lieberman that Lam relies on consists of a single paragraph:
`
`Similar to helicon antennas, inductive coils can be driven by a 13.56
`MHz, 50 ohm rf supply through a TI matching network. The coil can
`
`
`
`3
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`
`be driven push-pull using a balanced transformer, which places a
`virtual ground in the middle of the coil and reduces the maximum
`coil-to-plasma voltage by a factor of two. This reduces the undesired
`capacitively coupled rf current flowing from coil to plasma by a factor
`of two. An electrostatic shield placed between the coil and the plasma
`can further reduce the capacitive coupling if desired, while allowing
`the inductive field to couple unhindered to the plasma.
`(Ex. 1002 at 23 (original pagination); Ex. 1012 at 52-53.)
`
`There are four elements of claim 1 that are not taught by this passage from
`
`Lieberman, specifically the elements denominated by Lam as [1.], [1.d], [1.e], and
`
`[1.f].
`
`Element [1.] “A process for fabricating a product using a plasma source”
`Lieberman does not teach any process for fabricating a product; instead,
`
`Lieberman teaches only miscellaneous equipment that might be adaptable for such
`
`use. This absence becomes apparent in reading Lam’s inapposite quotations and
`
`citations in portion [1.] of its claim chart.
`
`Element [1.d] “in which a phase portion and an anti-phase portion of capacitive
`currents coupled from the inductive coupling structure are
`selectively balanced;”
`Nothing in Lieberman teaches selectively balancing a phase and an anti-
`
`phase portion of capacitive currents from an inductive coupling structure.
`
`Lieberman essentially concedes that the capacitive currents are not balanced when
`
`he teaches that the maximum coil-to-plasma voltage is reduced by a factor of two,
`
`which in turn: “reduces the undesired capacitively coupled rf current flowing from
`4
`
`
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`coil to plasma by a factor of two.” (Ex. 1002 at 23; Ex. 1012 at 53 (emphasis
`
`added).) The balancing of the phase and anti-phase—as taught in the ‘221
`
`patent—results in not simply a reduction by a factor of two, but substantially
`
`eliminates capacitively coupled power:
`
`But in all of these above embodiments, the phase and anti-phase
`potentials substantially cancel each other,
`thereby providing
`substantially no capacitively coupled power from the plasma source to
`the chamber bodies.
`(Ex 1001 at 9:2-:6; see also Ex. 1001 at 6:32-:41, 6:44-:51, 6:54-:65, 8:49-:52.
`
`17:9-:13.)
`
`Lieberman further confirms that he has not balanced the phase and anti-
`
`phase portions of the capacitive currents when he teaches using a shield to further
`
`reduce capacitive coupling:
`
`An electrostatic shield placed between the coil and the plasma can
`further reduce the capacitive coupling if desired, while allowing the
`inductive field to couple unhindered to the plasma.
`(Ex. 1002 at 23; Ex. 1012 at 53.) Lieberman explicitly recognizes that his initial
`
`approach—“The coil can be driven push-pull using a balanced transformer”—
`
`does not solve the capacitive coupling problem, so he reverts to the very prior art
`
`that Dr. Flamm found wanting. (Ex. 1001 at 2:17-:51; 3:14-:52.) Additionally, a
`
`“balanced transformer” taught by Lieberman has nothing to do with a “selectively
`
`balanced” phase portion and an anti-phase portion of capacitive currents coupled
`
`
`
`5
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`form the inductive coupling structure in the manner claimed. The term “balanced”
`
`in Lieberman is meaningless in the context of the claimed invention. Accordingly,
`
`Lieberman is plagued with the limitations of the prior art, which Dr. Flamm’s
`
`invention has overcome for the fabrication of a product.
`
`Lieberman also teaches that an antenna coil can be driven through a
`
`balanced transformer so that the antenna coil is isolated from ground to reduce the
`
`maximum antenna-plasma voltage by a factor of two, and thereby also reducing an
`
`undesired capacitive current by a factor of two. (Ex. 1002 at 23; Ex. 1012 at 53.)
`
`This reduction by a factor of two (i.e., 50%) is a far cry from the fruits of Dr.
`
`Flamm’s claim 1: that the net capacitive current can be reduced to ZERO because
`
`an anti-phase and phase portion can mutually cancel. (Ex 1001 at 9:2-:6; see also
`
`Ex. 1001 at 6:32-:41, 6:44-:51, 6:54-:65, 8:49-:52. 17:9-:13.) The phase and anti-
`
`phase are referenced to ground, not isolated from ground. (See e.g., id. at Fig’s 1,
`
`2A-C, 3-5A, & 6.) Accordingly, Lieberman teaches away from the solutions
`
`provided by the ‘221 patent.
`
`Element [1.e] “wherein said inductive coupling structure is adjusted using a wave
`adjustment circuit,”
`Lieberman does not teach any wave adjustment circuit because, as noted
`
`above, the power is isolated from ground in Lieberman.
`
`Element [1.f] “said wave adjustment circuit adjusting the phase portion and the
`
`
`
`6
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`
`anti-phase portion of the capacitively coupled currents.”
`In addition to not teaching any wave adjustment circuit or any adjusting of a
`
`phase and anti-phase portion of capacitively coupled current, Lieberman does not
`
`teach any selective adjustment of phase and antiphase, or that phase and anti-phase
`
`exist. Wave adjustment circuits can be adjusted to provide substantially zero
`
`(ground) AC voltage at least at one point on the coil. If the coil is not referenced to
`
`ground at some point, currents may not cancel because there can be different and
`
`asymmetric coupling from the plasma to various points on the applicator coil.1
`
`Lieberman teaches a virtual ground in the middle of the applicator coil but
`
`provides no means or method to effectuate one. By contrast, the ‘221 patent
`
`teaches relative phase and anti-phase currents that emanate from an applicator coil.
`
`Since Lieberman’s balanced transformer and his applicator coil are both isolated
`
`from ground (Ex. 1012 at 42), the voltages at various points on that coil will
`
`depend on the plasma density, plasma mode, and details of plasma coupling to the
`
`coil. Accordingly, the Lieberman configuration would not effectuate mutually
`
`cancelling capacitive currents in a controlled manner because the distribution of
`
`voltage along a floating coil depends on the proximate and distal plasma density
`
`distribution, and plasma currents to the chuck and various reactor walls.
`
`1 The balanced transformer winding disclosed in Lieberman is not an applicator
`coil; rather, it is a floating source of voltage used to “drive” an applicator coil.
`7
`
`
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`Lieberman teaches nothing about how to make a balanced transformer that can
`
`isolate and power a plasma at high frequency or how to position connections of a
`
`balanced transformer to an applicator coil.
`
`Thus, Lam has failed to demonstrate that any claims of the ‘221 patent are
`
`anticipated by Lieberman.
`
`C. Dible
`For Ground 2, Lam asserts that Lieberman in view of Dible renders claim 1
`
`of the ‘221 patent obvious under 35 U.S.C. § 103. (Pet. at 33.)
`
`At the threshold, it is curious that while asserting that Lieberman anticipates
`
`claim 1 (Pet. at 21-32), Lam makes no attempt to explain what is missing in
`
`Lieberman that requires Dible to reach obviousness. This is horizontal redundancy
`
`taken to the second power. Not only is there a failure to comply with the
`
`requirement that a petitioner must “explain why one reference more closely
`
`satisfies the claim limitation at issue in some respects than another reference and
`
`vice versa,” Liberty Mutual Ins. Co. v. Progressive Cas. Ins. Co., CBM2012-0003,
`
`Paper No. 7 at 2,3 (P.T.A.B. Nov. 26, 2012), there is a total absence of even a
`
`suggestion as to what Lam thinks might be missing from Lieberman that requires
`
`bringing in Dible.
`
`Despite that failing, Dible does not fill the gaps left by Lieberman. The ‘221
`
`
`
`8
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`patent balances the phase portion and the anti-phase portion of the capacitive
`
`currents from an inductive coupling structure using a wave adjustment circuit to
`
`adjust the inductive coupling structure in order to reduce or eliminate capacitively
`
`coupled power from the plasma source to chamber bodies. (See, e.g., Ex. 1001 at
`
`9:2-:6.) Dible teaches nothing about adjusting any inductive coupling structure in
`
`order to reduce or eliminate capacitively coupled power, adjusting phase and
`
`antiphase portions of capacitive currents from an inductive coupling structure, or
`
`any other such thing. Rather, Dible teaches using two separate power sources and
`
`respective matching networks to apply two separate excitation currents to two
`
`respective ends of a coil, and adjusting the phase of those power sources relative to
`
`each other in order to control the type of coupling generated, i.e., capacitive
`
`coupling, inductive coupling or some combination thereof:
`
`whereby said device becomes essentially an inductive coupling device
`when said first phase and said second phase are opposite in phase,
`said device becomes essentially a capacitive coupling device when
`said first phase and said second phase are in phase, said device
`becomes a combination inductive and capacitive coupling device
`when said first phase and said second phase differs by an angle that is
`between in phase and opposite in phase.
`(Ex. 1003 at 10:33-:41.)
`
`Element [1.d] “in which a phase portion and an anti-phase portion of capacitive
`currents coupled from the inductive coupling structure are
`selectively balanced;”
`
`
`
`9
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`As stated, Dible does not disclose anything about “a phase portion and an
`
`anti-phase portion of capacitive currents” emanating from an inductive coupling
`
`structure much less that they should be “selectively balanced.” In fact Dible
`
`teaches currents at the two terminals of an inductive coupling coil have a 180
`
`degree difference such as the conventional half-wave prior art structure that is
`
`disclosed in the ‘221 patent. (Ex. 1001 at 3:44-:49.) Therefore, Dible teaches
`
`away from selectively balancing a phase portion and an anti-phase portion of
`
`capacitive currents coupled from an inductive coupling structure.
`
` Furthermore, Dible’s scheme is itself fraught with problems that a
`
`PHOSITA in the field of RF matching would immediately recognize. For example,
`
`Dible provides a circuit teaching two power supplies powering each other through
`
`a coil (the coil that Dible identifies for power to the plasma). Dible teaches
`
`nothing about the electrical length of the coil, controlling the amplitudes of
`
`currents to the respective ends of the coil, or any means to prevent power
`
`emanating from one power supply from burning out the other power supply and/or
`
`its matching network, or overcoming instability from two independent power
`
`supplies
`
`and
`
`matching
`
`networks.
`
`Without solutions to these problems, the circuit would burn out. Furthermore, a
`
`PHOSITA would recognize that two prior art high frequency plasma power
`
`
`
`10
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`supplies and matching networks connected to each other in the manner shown
`
`would not admit an arbitrary relative phase relation between the ends of the coil for
`
`reasons of stability and various fundamental problems such as mentioned above.
`
`Dible offers no means to provide a stable selectable phase relation on a coil
`
`powering the plasma using two power sources in the circuits shown, and there was
`
`no prior art control circuit operable to perform the necessary function.
`
`The passage from Dible cited by Lam makes it crystal clear that Dible is not
`
`saying anything about “selectively balance[ing]” phase and anti-phase portions of
`
`capacitive currents coupled from an inductive coupling structure. (Pet. at 40,
`
`citing Ex. 1003 at 2:42-:56 and 4:45-:55.) What Dible is teaching is an approach
`
`for controlling the type of coupling—inductive, capacitive, or some combination of
`
`inductive and capacitive—by adjusting the relative phases of two separate
`
`“excitation currents” from two separate “excitation source[s].” (Id.)
`
`Element [1.e] “wherein said inductive coupling structure is adjusted using a wave
`adjustment circuit,”
`Again, the passages cited by Lam do not teach this claim element. Even if
`
`one were to assume that Dible’s “plasma generating system” were an “inductive
`
`coupling structure,” once it were “adjusted” it would be, according to Dible, a
`
`capacitive coupling structure (or some combination coupling structure), thus it
`
`would no longer an “inductive coupling structure.” (See Ex. 1003 at 4:45-:55)
`
`
`
`11
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`Accordingly, the claim language “said inductive coupling structure is adjusted
`
`using a wave adjustment circuit” is not met by Dible.
`
`While on one level this is a technicality, it evinces the underlying reality that
`
`the problems and solutions set forth in Dible, with the exception of employing a
`
`phase adjustment circuit, are totally alien from the problems and solutions set forth
`
`in the ‘221 patent.
`
`Element [1.f] “said wave adjustment circuit adjusting the phase portion and the
`anti-phase portion of the capacitively coupled currents.”
`As with claim element [1.d], Dible does not address “adjusting the phase
`
`portion and an anti-phase portion of the capacitively coupled currents.” Dible was
`
`focused entirely on adjusting the phases of two separate excitation currents in order
`
`to change the form of coupling.
`
`In short, the only aspect of Dible that relates to phase is the use of a phase
`
`adjustment circuit for an RF power source, which, of course, long preceded Dible.
`
`In fact, Dible teaches away from Flamm since it positively teaches the use of
`
`capacitively coupled discharges—“When the first phase and the second phase are
`
`in phase, the device essentially becomes a capacitive coupling device” (Ex. 1003 at
`
`1)—the very discharges that the ‘221 patent reduces or eliminates.
`
`D. Dependent Claims
`The ‘221 patent has a single independent claim and six claims that depend
`
`
`
`12
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`from that claim. At least because Lam has failed to demonstrate that independent
`
`claim 1 is anticipated by Lieberman or rendered obvious by Lieberman in view of
`
`Dible, none of the claims that depend from claim 1 are anticipated or obvious
`
`despite Lam’s introduction of additional prior art references purported to relate to
`
`those dependent claims. Hartness Int’l Inc. v. Simplimatic Eng. Co., 819 F.2d
`
`1100, 1108 (Fed. Cir. 1987) (“A fortiori, dependent claim 3 was nonobvious (and
`
`novel) because it contained all of the limitations of claim 1 plus a further
`
`limitation.”); Kimberly Clark Corp. v. Johnson & Johnson, 745 F.2d 1437, 1448-
`
`49 (Fed. Cir. 1984) (“We need consider no other claim because if the invention of
`
`claim 1 would not have been obvious the same is true as to the remaining
`
`dependent claims.”).
`
`IV. Conclusion
`
`For the foregoing reasons, the instant petition should be denied.
`
`
`
`
`
`
`
`Date: November 25, 2015
`
`
`
`
`
`
`Respectfully Submitted,
`
`By: /Christopher Frerking, reg. no. 42,557/
` Christopher Frerking, reg. no. 42,557
`
`174 Rumford Street
`Concord, New Hampshire 03301
`Telephone: (603) 706-3127
`Email: chris@ntknet.com
`
`Counsel for Daniel L. Flamm
`
`
`
`13
`
`
`
`Patent Owner’s Preliminary Response under 37 C.F.R. § 42.107
`Inter Partes Review of U.S. Patent No. 6,017,221
`IPR2015-01767
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the foregoing Patent Owner’s
`
`
`
`Preliminary Response under 37 C.F.R. § 42.107 was served by electronic mail
`
`on this day, November 25, 2015, on the following individuals:
`
`Michael Fleming
`(mfleming@irell.com)
`Samuel K. Lu
`(slu@irell.com)
`Kamran Vakili
`(kvakili@irell.com)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067-4276
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Beata Ichou
`Beata Ichou
`
`
`
`14
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
