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Paper 13
`
`
`Trials@uspto.gov
`571-272-7822 Entered: February 26, 2016
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`UNITED SERVICES AUTOMOBILE ASSOCIATION,
`Petitioner,
`
`v.
`
`NADER ASGHARI-KAMRANI and KAMRAN ASGHARI-KAMRANI,
`Patent Owner.
`____________
`
`Case IPR2015-01842
`Patent 8,266,432 B2
`____________
`
`
`Before SALLY C. MEDLEY, JUSTIN T. ARBES, and
`KIMBERLY McGRAW, Administrative Patent Judges.
`
`McGRAW, Administrative Patent Judge.
`
`
`
`
`DECISION
`Denying Institution of Inter Partes Review
`37 C.F.R. § 42.108
`
`
`
`
`
`
`
`

`
`IPR2015-01842
`Patent 8,266,432 B2
`
`
`I. INTRODUCTION
`Petitioner, United Services Automobile Association, filed a Petition
`
`requesting an inter partes review of claims 1–551 of U.S. Patent No.
`8,266,432 B2 (Ex. 1001, “the ’432 patent”). Paper 2 (“Pet.”). Patent
`Owner, Nader Asghari-Kamrani and Kamran Asghari-Kamrani, filed a
`Preliminary Response. Paper 7 (“Prelim. Resp.”). We have jurisdiction
`under 35 U.S.C. § 314(a), which provides that an inter partes review may
`not be instituted “unless . . . the information presented in the petition . . . and
`any response . . . shows that there is a reasonable likelihood that the
`petitioner would prevail with respect to at least 1 of the claims challenged in
`the petition.”
`For the reasons that follow, we do not institute an inter partes review
`of the ’432 patent.
`
`A. Related Proceedings
`
`According to Patent Owner, the ’432 patent is involved in the
`following lawsuit: Asghari-Kamrani et al. v. United Services Automobile
`Association, Case No. 2:15-cv-00478-RGD-LRL (E.D. Va.). Papers 6, 10.
`
`B. The ’432 Patent (Ex. 1001)
`
`The ’432 patent, titled “Centralized Identification and Authentication
`System and Method,” is directed to computerized methods and systems for
`verifying the identity of network users using dynamic, non-predictable, and
`
`
`1 Petitioner states on page 1 of the Petition that it is challenging claims 1–54.
`Given the substance of Petitioner’s arguments, we presume that this is a
`typographical error.
`
`2
`
`

`
`IPR2015-01842
`Patent 8,266,432 B2
`
`time dependent SecureCodes. See Ex. 1001, Abstract, 1:21–28. In one
`embodiment, the user signs up at a “central-entity” by providing his personal
`or financial information. Id., Abstract, Figs. 2, 3. Examples of central-
`entities include banks and credit card issuing companies. Id. at 2:13–16.
`When the user wants to buy goods or services from an external-entity, such
`as a merchant or an online site, the user requests, and then receives, a
`“SecureCode” from the central-entity. Id., Abstract, Figs. 2, 4. The user
`then provides his UserName and SecureCode as his digital identity to the
`external-entity, which then forwards the user’s digital identity along with an
`authentication request to the central-entity. Id., Abstract, 3:19–26; Figs. 2,
`4, 5. The central-entity then authenticates the user’s digital identity and
`sends an approval identification and authorization message to the external-
`entity. Id., Abstract, Figs. 2, 5.
`
`C. Claims
`
`Petitioner challenges independent claims 1 through 55. Claims 1, 25,
`48, and 52 are independent. Claim 1 is reproduced below:
`1.
`A method for authenticating a user during an
`electronic transaction between the user and an external-entity,
`the method comprising:
`receiving electronically a request for a dynamic code for
`the user by a computer associated with a central-entity during the
`transaction between the user and the external entity;
`generating by the central-entity during the transaction a
`dynamic code for the user in response to the request, wherein the
`dynamic code is valid for a predetermined time and becomes
`invalid after being used;
`providing by the computer associated with the central
`entity said generated dynamic code to the user during the
`transaction;
`receiving electronically by the central-entity a request for
`
`3
`
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`IPR2015-01842
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`
`
`authenticating the user from a computer associated with the
`external-entity based on a user-specific information and the
`dynamic code as a digital identity included in the request which
`said dynamic code was received by the user during the
`transaction and was provided to the external-entity by the user
`during the transaction; and
`authenticating by the central-entity the user and providing
`a result of the authenticating to the external-entity during the
`transaction if the digital identity is valid.
`
`
`D. Prior Art
`Petitioner relies upon the following prior art references:
`
`Brown, U.S. Patent No. 5,740,361, issued April 14, 1998 (“Brown,” Ex.
`1010).
`
`Myers, et. al., X.509 Internet Public Key Infrastructure Online Certificate
`Status Protocol – OCSP, RFC 2560, Network Working Group (June 1999)
`(“Myers,” Ex. 1011).
`
`Neuman, B.C. and Ts’o, T., Kerberos: An Authentication Service for
`Computer Networks, ISI Research Report, ISI/RS- 94-399, IEEE
`Communications Magazine (September 1994) (“Neuman,” Ex. 1012).
`
`
` E. Asserted Grounds of Unpatentability
`Petitioner argues the challenged claims are unpatentable based upon
`the following grounds:
`
`
`References
`Brown and Myers
`Neuman
`Neuman
`
`Pet. 2.
`
`Basis
`§ 103
`§ 102(b)
`§ 103
`
`Challenged Claims
`1–55
`1–3, 6–28, and 31–55
`4, 5, 29, and 30
`
`4
`
`

`
`IPR2015-01842
`Patent 8,266,432 B2
`
`
`II. ANALYSIS
`A. Claim Construction
`In an inter partes review, claim terms in an unexpired patent are given
`their broadest reasonable construction in light of the specification of the
`patent in which they appear. 37 C.F.R. § 42.100(b); see also In re Cuozzo
`Speed Techs., LLC, 778 F.3d 1271, 1279–81 (Fed. Cir. 2015), cert. granted
`sub nom., Cuozzo Speed Techs., LLC v. Lee, No. 15–446, 2016 WL 205946
`(U.S. Jan. 15, 2016). Under that standard, and absent any special
`definitions, we give claim terms their ordinary and customary meaning, as
`would be understood by one of ordinary skill in the art at the time of the
`invention. See In re Translogic Tech., Inc., 504 F.3d 1249, 1257 (Fed. Cir.
`2007). Any special definitions for claim terms must be set forth with
`reasonable clarity, deliberateness, and precision. See In re Paulsen, 30 F.3d
`1475, 1480 (Fed. Cir. 1994).
`The Board, however, may not “construe claims during IPR so broadly
`that its constructions are unreasonable under general claim construction
`principles. . . . [T]he protocol of giving claims their broadest reasonable
`interpretation . . . does not include giving claims a legally incorrect
`interpretation.” Microsoft Corp. v. Proxyconn, Inc., 789 F.3d 1292, 1298
`(Fed. Cir. 2015) (citation omitted). Rather, “claims should always be read in
`light of the specification and teachings in the underlying patent.” Id.
`
`“Central-Entity” and “External-Entity”
`
`The terms “central-entity” and “external-entity” are recited in
`independent claims 1, 25, 48, and 52. The Specification of the ’432 Patent
`defines a central-entity as “any party that has [a] user’s personal and/or
`
`5
`
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`
`IPR2015-01842
`Patent 8,266,432 B2
`
`financial information, UserName, [and] Password and generates [a]
`dynamic, non-predictable and time dependable SecureCode for the user.”
`Ex. 1001, 2:13–16. Examples of a central-entity include banks, credit card
`issuing companies, or any intermediary service companies. Id. at 2:16–18.
`The Specification defines an external-entity as “any party offering goods or
`services that users utilize by directly providing their UserName and
`SecureCode as digital identity.” Id. at 2:19–21. Examples of an external-
`entity include a merchant, service provider, or online site. Id. at 2:22–23.
`The Specification further states that an external-entity can also be an entity
`that receives the user’s digital identity indirectly from the user through
`another external-entity, in order to authenticate the user, such as a bank or
`credit card issuing company. Id. at 2:24–26.
`Petitioner asserts these two terms should be construed broadly enough
`for the “central-entity” to perform the operations of the “external-entity” and
`vice versa, because dependent claims 11, 46, 49, and 53 recite that the
`central-entity and external-entity are the “same entity.” Pet. 4–5. Petitioner
`asserts this interpretation is also consistent with the specification of the ’432
`Patent, which states the central-entity and the external-entity can both be
`“banks” or “credit card issuing companies.” Pet. 5 (citing Ex. 1001, 2:13–
`26; Ex. 1003 ¶ 31).
`We agree that the Specification and claims 11, 46, 49, and 53 describe
`embodiments in which the central-entity and the external-entity can be the
`same entity. In these circumstances, the same/single entity can perform the
`operations of both the external and central entity. However, we disagree
`with Petitioner that the terms should be interpreted so broadly so to construe
`an external-entity as an entity that can perform the claimed operations of
`
`6
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`
`IPR2015-01842
`Patent 8,266,432 B2
`
`either the central or external entity, or vice versa (i.e., that the central-entity
`should be interpreted as an entity that can perform the operations of either
`the central or external entities). Petitioner does not direct us to a description
`in the Specification that would support such a construction. Thus, although
`we agree that the Specification describes embodiments where the central-
`entity and the external-entity can be the same entity, and, thus, the same
`entity can perform the operations of both the external and central entity, we
`do not construe independent claims 1, 25, 48, and 52 as meaning an entity
`that performs the claimed operations of an external-entity constitutes a
`central-entity, or that an entity that performs the claimed operations of a
`central-entity constitutes an external-entity.
`Patent Owner asserts that under a proper construction, the central-
`entity and the external-entity must “use separated computers which
`communicate between each other via a communication network.” Prelim.
`Resp. 10. Patent Owner contends the Specification describes a
`computerized network system, where three parties –– a user, a central entity
`and an external entity –– communicate with each other via a communication
`network. Prelim. Resp. 12 (citing Ex. 1001, 4:40–43, 5:32–35, Fig. 2).
`Patent Owner states that because the “central entity computer and external
`entity computer communicate between each other via a communication
`network, the computers must be separated.” Id.
`We are not persuaded by Patent Owner’s assertions that the proper
`construction of “external-entity” or “central-entity” requires communication
`over a communications network or use of separated computers. Patent
`Owner has not identified a sufficient factual basis to import these limitations
`into the claims. We must be careful not to read a particular embodiment
`
`7
`
`

`
`IPR2015-01842
`Patent 8,266,432 B2
`
`appearing in the written description into the claim if the claim language is
`broader than the embodiment. See In re Van Geuns, 988 F.2d 1181, 1184
`(Fed. Cir. 1993) (“limitations are not to be read into the claims from the
`specification”). We, therefore, do not construe external-entity and central-
`entity as suggested by either Petitioner or Patent Owner, but rather construe
`the terms as defined in column 2 of the Specification and as described
`above.
`For purposes of this Decision, we need not construe any other
`limitations of the challenged claims.
`
`B. Asserted Grounds of Unpatentability
`1. Obviousness over Brown and Myers
`Petitioner contends that claims 1 through 55 are unpatentable under
`35 U.S.C. § 103 over the combination of Brown and Myers. Pet. 6–38. To
`support its contention, Petitioner provides explanations as to how the prior
`art allegedly teaches each claim limitation of the challenged claims. Id.
`Petitioner also relies upon a Declaration of Seth Nielson, Ph.D. Ex. 1003.
`In light of the arguments and evidence submitted, Petitioner has not
`established a reasonable likelihood that claims 1 through 55 are unpatentable
`as obvious over Brown and Myers.
`Analysis
`A patent claim is unpatentable under 35 U.S.C. § 103 if the
`differences between the claimed subject matter and the prior art are such that
`the subject matter, as a whole, would have been obvious at the time the
`invention was made to a person having ordinary skill in the art to which said
`subject matter pertains. KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 406
`(2007). The question of obviousness is resolved on the basis of underlying
`
`8
`
`

`
`IPR2015-01842
`Patent 8,266,432 B2
`
`factual determinations including: (1) the scope and content of the prior art;
`(2) any differences between the claimed subject matter and the prior art; (3)
`the level of ordinary skill in the art; and (4) objective evidence of
`nonobviousness. Graham v. John Deere Co., 383 U.S. 1, 17–18 (1966).
`The Supreme Court has made clear that we apply “an expansive and
`flexible approach” to the question of obviousness. KSR, 550 U.S. at 415.
`Whether a patent claiming the combination of prior art elements is obvious
`is determined by whether the improvement is more than the predictable use
`of prior art elements according to their established functions. Id. at 417. As
`the Supreme Court recognized, in many cases a person of ordinary skill “will
`be able to fit the teachings of multiple patents together like pieces of a
`puzzle,” recognizing that a person of ordinary skill “is also a person of
`ordinary creativity, not an automaton.” Id. at 420–21.
`The level of ordinary skill in the art is reflected by the prior art of
`record. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001); In
`re GPAC Inc., 57 F.3d 1573, 1579 (Fed. Cir. 1995).
`A dispositive issue concerns whether Petitioner has sufficiently
`established the cited art teaches or suggests “authenticating by the central-
`entity the user and providing a result of the authenticating to the external-
`entity during the transaction if the digital identity is valid” as recited in
`independent claim 1.
`Petitioner asserts the “authentication deity” of Brown constitutes a
`central-entity while the “service” of Brown constitutes an external-entity.
`See, e.g., Pet. 8, 13. Petitioner admits that Brown does not teach a central-
`entity that authenticates a user as required by claim 1 because in Brown the
`service (the asserted external-entity), and not the authentication deity
`
`9
`
`

`
`IPR2015-01842
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`
`(central-entity), authenticates the user. Id. at 19. However, Petitioner argues
`that because “under the [broadest reasonable interpretation], the ‘central-
`entity’ and the ‘external-entity’ can be the same entity,” it is sufficient that
`Brown’s service authenticates the user. Id. at 19–20 & n1. As noted above,
`we disagree with Petitioner’s claim construction regarding central and
`external entities. As such, we disagree with Petitioner’s contention that
`Brown’s teaching of an external-entity that authenticates a user satisfies the
`claim limitation requiring authentication by a central-entity.
`Petitioner alternatively argues that the combination of Myers and
`Brown teaches the disputed limitation, asserting that Myers teaches a
`central-entity that receives a service request from an external-entity to
`“‘provide the requested service,’ which is commonly used to authenticate a
`user.” Id. at 19. Petitioner contends that because Brown and Myers are both
`directed to preventing security risks imposed by replay attacks, one skilled
`in the art would be motivated to modify the method of Brown to have the
`authentication deity (central-entity), instead of the service (external-entity),
`perform the user authentication. Id. at 20.
`However, Petitioner’s argument does not explain how the
`combination of Myers and Brown teaches “providing a result of the
`authenticating to the external entity” as required by claim 1. Rather,
`Petitioner merely alleges that after the service in Brown verifies the results
`Ru, it calculates Rs, which “is sent to the user.” Id. (citing Ex. 1010, 10:15–
`20) (emphasis added). Petitioner further states that Brown describes Ru and
`Rs as being used by the “user and service to ‘mutually authenticate one
`another’” and thus, under the modified authentication protocol of Brown in
`view of Myers, the authentication deity verifies the user response, Ru, and
`
`10
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`

`
`IPR2015-01842
`Patent 8,266,432 B2
`
`transmits the response Rs to the user after determining Ru is correct. Pet. 21.
`Petitioner concludes that the “authentication deity . . . performing the
`authentication operations of the service during the reauthentication process,
`which includes verifying the user response, Ru, and transmitting the
`response, Rs, to the user if Ru is correct, discloses these limitations of the
`claim.” Id. (emphasis added). Notably, nowhere does Petitioner explain or
`allege how transmitting a response to a user teaches or suggests providing a
`result to an external-entity, as required by the claim. As such, we are not
`persuaded that Petitioner has presented sufficient evidence or argument to
`establish a reasonable likelihood that either Brown or the combination of
`Brown and Myers teaches “authenticating by the central-entity the user and
`providing a result of the authenticating to the external-entity during the
`transaction if the digital identity is valid” as recited in independent claim 1.
`Nor does Petitioner provide sufficient argument or evidence to
`establish a reasonable likelihood that either Brown or the combination of
`Brown and Myers teaches or suggests similar limitations found in
`independent claim 25 (“second central-entity computer adapted to . . .
`authenticate the user . . . and to provide a result of the authentication of the
`user to the external-entity”), claim 48 (“authenticating by the central-entity
`the user and providing a result of the authentication of the user to the
`external entity during the transaction if the digital identity is valid”), or
`claim 52 (“second central-entity computer adapted to . . . authenticate the
`user . . . and to provide a result of the authentication of the user to the
`external-entity during the electronic transaction”).
`For these reasons, we determine that Petitioner has not demonstrated a
`reasonable likelihood of prevailing on its challenge to independent claims 1,
`
`11
`
`

`
`IPR2015-01842
`Patent 8,266,432 B2
`
`25, 48, and 52 of the ’432 patent, or to dependent claims 2–24, 26–47, 49–
`51, and 53–55 as obvious over Brown and Myers.
`
`2. Anticipation of Claims 1–3, 6–28, and 31–55 by Neuman
`Petitioner contends that claims 1–3, 6–28, and 31–55 are anticipated
`under 35 U.S.C. § 102(b) by Neuman, a 1994 magazine article describing
`“Kerberos,” which is an authentication service for computer networks.
`Ex. 1012. To support its contention, Petitioner provides explanations as to
`how the prior art allegedly teaches each claim limitation of the challenged
`claims. Pet. 38–59. Petitioner also relies upon the Declaration of Seth
`Nielson, Ph.D. Ex. 1003. For the reasons that follow, we do not institute a
`review based on this challenge.
`
`Analysis
` “A claim is anticipated only if each and every element as set forth in
`the claim is found, either expressly or inherently described, in a single prior
`art reference.” Verdegaal Bros. v. Union Oil Co., 814 F.2d 628, 631 (Fed.
`Cir. 1987). The elements must be arranged as required by the claim, but this
`is not an ipsissimis verbis test, i.e., identity of terminology is not required.
`In re Bond, 910 F.2d 831, 832 (Fed. Cir. 1990).
`Petitioner contends Neuman discloses a distributed authentication
`service that allows a user to prove its identity to a verifier without sending
`data across a network. Pet. 38–39. Petitioner further contends that Neuman
`discloses a central-entity (the “authentication server”), an external-entity (the
`“verifier”), and a computer associated with a central-entity (the “client”). Id.
`(citing Ex. 1012, 34–35, Fig. 1; Ex. 1003 ¶ 97). A copy of Neuman Figure 1
`as annotated by Petitioner on page 39 of the Petition is reproduced below.
`
`
`12
`
`

`
`IPR2015-01842
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`
`
`
` Annotated Figure 1 of Neuman depicts a diagram illustrating the
`messages exchanged between a client (C) and either the authentication
`server (AS) or the verifier (V). Ex. 1012, 35.
`A dispositive issue for this challenge is whether Petitioner has
`sufficiently established Neuman discloses “authenticating by the central-
`entity the user and providing a result of the authenticating to the external-
`entity during the transaction if the digital identity is valid” as recited in
`independent claim 1.
`Petitioner contends Neuman describes a verifier (the asserted external-
`entity) authenticating a user, by disclosing “the verifier decrypting the ticket,
`the authenticator, and the time stamp included in the application response.”
`Pet. 42–43 (citing Ex. 1012, 35; Ex. 1003 ¶ 105); see also Ex. 1012, Fig. 1
`(steps 3 and 4). Petitioner further contends “under the broadest reasonable
`interpretation, when the verifier [authenticates the user], the authentication
`server thereby also performs these operations since they may be the same
`entity.” Pet. 43 (citing Ex. 1003 ¶ 107). However as noted above, we do not
`construe claim 1 as meaning an entity that performs the operations of an
`external-entity constitutes a central-entity, or vice versa. As such, we are not
`
`13
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`IPR2015-01842
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`
`persuaded by Petitioner’s argument that Neuman’s disclosure of
`authentication of a user by an external-entity satisfies the claim limitation
`requiring authentication of a user by a central-entity.
`Nor has Petitioner provided sufficient argument or evidence that
`Neuman teaches a central-entity that authenticates a user as required by
`claim 1. To the extent that Petitioner argues Neuman teaches a central-entity
`that authenticates a user, this argument is based upon applying Petitioner’s
`rejected claim construction to the prior art and not upon the express or
`inherent teachings of the prior art itself. See, e.g., Pet. 41–43; Ex. 1003
`¶¶ 103, 107. Petitioner merely asserts that the authentication server (central-
`entity) performs the same authentication operations performed by the
`verifier (external-entity) because under a broadest reasonable interpretation
`standard, the external and central entities are the same. Id. This allegation is
`not sufficient to establish that the authentication server does in fact
`authenticate a user as required by claim 1. Similarly, Dr. Nielson’s
`statement that “the authentication server and the verifier may be the same
`entity” because “Neuman does not explicitly suggest that such a
`configuration would be technically infeasible or would frustrate the purpose
`of the Kerberos protocol” (Ex. 1003 ¶ 103) is insufficient to establish that
`the two entities are inherently a single entity. “To establish inherency, the
`extrinsic evidence ‘must make clear that the missing descriptive matter is
`necessarily present in the thing described in the reference, and that it would
`be so recognized by persons of ordinary skill.’” In re Robertson, 169 F.3d
`743, 745 (Fed. Cir. 1999) (citation omitted). “Inherency, however, may not
`be established by probabilities or possibilities. The mere fact that a certain
`thing may result from a given set of circumstances is not sufficient.” Id.
`
`14
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`

`
`IPR2015-01842
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`
`(citation omitted). Here, an allegation that the verifier and authentication
`server may be the same entity because such a configuration would not be
`“technically infeasible” or “frustrate the purpose” of the reference is not
`sufficient to establish Neuman teaches that the authentication server and
`verifier are in fact the same entity.
`For these reasons, we determine that Petitioner has not demonstrated a
`reasonable likelihood of prevailing on its challenge to claim 1.
`Independent claims 25, 48, and 52 recite similar limitations.
`Petitioner does not provide any additional argument or evidence directed
`specifically to these independent claims, instead relying upon its arguments
`presented with respect to claim 1. For example Petitioner states Neuman
`anticipates claim 25 “for the same reasons discussed previously with respect
`to Ground 2, [1.0]-[1.5], supra.” Pet. 56; see also Pet. 59 (claims 48 and
`52).
`For these reasons, we determine that Petitioner has not demonstrated a
`reasonable likelihood of prevailing on its challenge to independent claims 1,
`25, 48, and 52 of the ’432 patent, or to dependent claims 2–3, 6–24, 26–28,
`31–47, and 49–51, and 53–55 as anticipated by Neuman. Therefore, we do
`not institute a review based on this challenge.
`
`3. Obviousness of Claims 4, 5, 29, and 30 over Neuman
`Petitioner contends that dependent claims 4, 5, 29, and 30 would have
`been obvious over Neuman. Pet. 59–60. As noted above, we determined
`that Petitioner has not demonstrated a reasonable likelihood of prevailing on
`its challenge to independent claims 1 and 25. None of Petitioner’s
`arguments regarding the dependent claims cure the deficiencies regarding
`the independent claims. Therefore, Petitioner has not demonstrated a
`
`15
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`IPR2015-01842
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`
`reasonable likelihood of prevailing on its challenge to claims 4, 5, 29, and 30
`as obvious over Neuman, and we do not institute a review based on this
`challenge.
`
`III. CONCLUSION
`
`For the foregoing reasons, we conclude that Petitioner has not
`demonstrated a reasonable likelihood of prevailing with respect to at least
`one claim of the ’432 patent challenged in the Petition. Therefore, we do not
`institute an inter partes review on any of the asserted grounds as to any of
`the challenged claims.2
`
`
`IV. ORDER
`
`In consideration of the foregoing, it is
`ORDERED that the Petition is denied and no trial is instituted.
`
`
`2 Because we determine that Petitioner has not demonstrated a reasonable
`likelihood of prevailing in challenging claims 1–55 of the ’432 patent for the
`reasons set forth above, we need not address Patent Owner’s remaining
`arguments.
`
`16
`
`

`
`17
`
`IPR2015-01842
`Patent 8,266,432 B2
`
`
`FOR PETITIONER:
`Michael Zoppo
`Thomas Rozylowicz
`FISH & RICHARDSON P.C.
`zoppo@fr.com
`IPR36137-0007IP1@fr.com
`
`FOR PATENT OWNER:
`
`Reece Nienstadt
`Lei Mei
`Krystyna Colantoni
`MEI & MARK LLP
`rnienstadt@meimark.com
`mei@meimark.com
`kcolantoni@meimark.com

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