Case No. IPR2016-00038
`U.S. Patent No. 6,292,974
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`_____________________
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`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`______________________
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`COSTCO WHOLESALE CORPORATION,
`Petitioner,
`
`v.
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`ROBERT BOSCH LLC,
`Patent Owner.
`______________________
`
`CASE NO. IPR2016-00038
`U.S. Patent No. 6,292,974
`______________________
`
`
`
`PATENT OWNER’S PRELIMINARY RESPONSE PURSUANT TO 35
`U.S.C. § 313 AND 37 C.F.R. § 42.107
`
`
`
`
`
`
`U.S. Patent No. 6,292,974
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`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________________
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________
`
`COSTCO WHOLESALE CORPORATION,
`Petitioner,
`
`v.
`
`ROBERT BOSCH LLC,
`Patent Owner.
`______________________
`
`CASE NO. IPR2016-00038
`U.S. Patent No. 6,292,974
`______________________
`
`
`
`PATENT OWNER’S PRELIMINARY RESPONSE PURSUANT TO 35
`U.S.C. § 313 AND 37 C.F.R. § 42.107
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`
`
`
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`
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`Case No. IPR2016-00038
`U.S. Patent No. 6,292,974
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`Table of Contents
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`I.
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`II.
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`INTRODUCTION ........................................................................................... 1
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`SUMMARY OF ARGUMENTS .................................................................... 1
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`III.
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`STANDARD FOR INSTITUTION................................................................. 4
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`IV. BRIEF OVERVIEW OF U.S. PATENT. NO. 6,292,974 ............................... 5
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`V.
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`PETITIONER IMPROPERLY INCORPORATES BY REFERENCE THE
`KRUGER DECLARATION ........................................................................... 6
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`VI. PETITIONER PUTS FORTH NO EVIDENCE THAT THE CITED
`REFERENCES DISCLOSE THE CLAIMED ELEMENTS FOUND IN
`ALL CHALLENGED CLAIMS ..................................................................... 8
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`VII. THE ALLEGED OBVIOUSNESS COMBINATIONS ARE DRIVEN BY
`IMPERMISSIBLE HINDSIGHT, IGNORE TEACHINGS AWAY, AND
`REST UPON CONCLUSORY ASSERTIONS ............................................11
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`VIII. CONCLUSION ..............................................................................................15
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`Case No. IPR2016-00038
`U.S. Patent No. 6,292,974
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`Table of Authorities
`
`Cases
`ActiveVideo Networks v. Verizon Comm’ns, Inc.,
`694 F.3d 1312 (Fed Cir. 2012) ......................................................................... 2, 5
`
`Apple Inc. v. ContentGuard Holdings, Inc.,
`IPR2015-00441, Paper 11 (PTAB July 13, 2015) ................................................ 2
`
`August Tech. Corp. v. Camtek Ltd.,
`655 F.3d 1278 (Fed. Cir. 2011) ............................................................................ 4
`
`Blackberry Corp. v. Mobilemedia Ideas LLC,
`IPR2013-00016, Paper 32 (PTAB Feb. 25, 2014) ................................................ 7
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`Cisco Sys., Inc. v. C-Cation Techs., LLC,
`IPR2014-00454, Paper 12 (PTAB Aug. 29, 2014) ........................................... 2, 7
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`Fidelity National Info. Serv’s, Inc. v. Datatreasury Corp.,
`IPR2014-00489, Paper 9 (PTAB Aug. 13, 2014) ................................................. 7
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`In re Fritch,
`972 F.2d 1260 (Fed. Cir. 1992) .......................................................................... 11
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`K/S HIMPP v. Hear-Wear Techs., LLC,
`751 F.3d 1362 (Fed. Cir. 2014) ............................................................................ 2
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`KSR Int’l Co. v. Teleflex, Inc.,
`550 U.S. 398 (2007) .............................................................................................. 4
`
`In re NTP, Inc.,
`654 F.3d 1279 (Fed. Cir. 2011) .......................................................................... 11
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`PCT Int’l, Inc. v. Amphenol Corp.,
`IPR2013-00229, Paper 17 (PTAB Dec. 24, 2013) ............................................... 7
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`SAS Inst., Inc. v. ComplementSoft, LLC,
`IPR2013-00581, Paper 15 (PTAB Dec. 30, 2013) ............................................... 4
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`SAS Inst., Inc. v. ComplementSoft, LLC,
`IPR2013-00581, Paper 17 (PTAB Feb. 25, 2014) ................................................ 3
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`Unified Patents Inc. v. OliviStar, LLC,
`IPR2015-01216, Paper 15 (PTAB Nov. 20, 2015) ............................................... 7
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`Vizio, Inc. v. Int’l Trade Comm’n,
`605 F.3d 1330 (Fed. Cir. 2010) ............................................................................ 4
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`
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`Statutes
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`35 U.S.C. § 314(a) ................................................................................................. 4, 5
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`35 U.S.C. § 316(e) ..................................................................................................... 4
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`
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`Regulations
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`37 C.F.R. § 42.6(a)(3) ............................................................................................ 1, 7
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`37 C.F.R. § 42.24(a)(1)(i) ...................................................................................... 1, 7
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`37 C.F.R. § 42.104(b)(4) ........................................................................................ 4, 9
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`37 C.F.R. § 42.108(b) ................................................................................................ 5
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`37 C.F.R. § 42.108(c) ................................................................................................. 4
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`
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`Other Authorities
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`Office Patent Trial Practice Guide, 77 Fed. Reg. 48,756 (Aug. 14,
`2012) ..................................................................................................................... 4
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`Case No. IPR2016-00038
`U.S. Patent No. 6,292,974
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`I.
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`INTRODUCTION
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`Patent Owner, Robert Bosch LLC (“Bosch”), submits this preliminary
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`response to the Petition filed by Costco Wholesale Corporation (“Petitioner” or
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`“Costco”) as Paper No. 1 in this proceeding, requesting inter partes review of
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`claims 1, 2, and 8 of U.S. Patent No. 6,292,974 (“Petition”). This response is
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`timely pursuant to the Board’s Notice in Paper No. 3.
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`The following arguments are not intended to be exhaustive with respect to
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`the grounds asserted in the Petition. Bosch respectfully submits the streamlined
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`arguments showing that denial of institution is appropriate here, and reserves the
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`right to provide additional evidence, including testimonial evidence, and include
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`new arguments, should the Board decide to institute review in this case.
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`Bosch respectfully submits that Petitioner has not established a reasonable
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`likelihood that it would prevail with respect to any of the challenged claims.
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`Accordingly, Bosch respectfully requests that the Board decline to institute inter
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`partes review for the reasons set forth below.
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`II.
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`SUMMARY OF ARGUMENTS
`The Petition fails for several reasons.
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`First, Petitioner violates 37 C.F.R. §§ 42.24(a)(1)(i) and 42.6(a)(3) by
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`improperly incorporating by reference the Kruger declaration into the Petition.
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`Under the Board’s prior decisions, the arguments incorporated by reference should
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`be disregarded. See, e.g., Cisco Sys., Inc. v. C-Cation Techs., LLC, IPR2014-
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`00454, Paper 12 at 10 (PTAB Aug. 29, 2014). Without this testimony, Bosch
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`submits that the Petition is insufficient to carry Petitioner’s burden, and institution
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`should be denied with respect to both grounds.
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`Second, Petitioner offers no evidence that the cited references disclose “a
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`component which is separate from said wiper strip and is mounted directly to the
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`convex surface of said support element” limitation of claims 1, 2, and 8 of the ’974
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`patent. Thus, Petitioner fails to present prima facie evidence of obviousness of all
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`challenged claims. Since the only two grounds asserted in the Petition are based
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`on the alleged obviousness of the invention over the prior art combinations,
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`institution should be denied on both grounds.
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`Third, the Petition is driven by improper hindsight and lacks articulated
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`reasons with rational underpinnings to support the proposed modifications. See,
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`e.g., Apple Inc. v. ContentGuard Holdings, Inc., IPR2015-00441, Paper 11 at 12
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`(PTAB July 13, 2015). Moreover, the references teach away from the proposed
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`combinations. And, the Petition provides only conclusory assertions with respect
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`to how the references might be combined. These assertions are insufficient to
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`support a claim of obviousness. See, e.g., K/S HIMPP v. Hear-Wear Techs., LLC,
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`751 F.3d 1362, 1365 (Fed. Cir. 2014); ActiveVideo Networks v. Verizon Comm’ns,
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`Inc., 694 F.3d 1312, 1327–28 (Fed Cir. 2012) (dismissing expert testimony that
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`“failed to explain how specific references could be combined, which
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`combination(s) of elements in specific references would yield a predictable result,
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`or how any specific combination would operate or read on the asserted claims” and
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`further dismissing expert testimony that generically recites a desire for more
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`efficient and cheaper systems that had more features for customers); SAS Inst., Inc.
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`v. ComplementSoft, LLC, IPR2013-00581, Paper 17 at 3–4 (PTAB Feb. 25, 2014)
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`(observing that the PTAB “is not required to take every statement by a petitioner’s
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`expert as established fact” and “is required to assess the persuasiveness of the
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`testimony in light of other factual evidence in the record, e.g., the explicit wording
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`of the prior art and the scope of the claimed invention”). Therefore, institution
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`should be denied with respect to both grounds.
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`Fourth, the Petition presents obviousness challenges without adequately
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`explaining (i) why a person of ordinary skill in the art would have combined or
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`modified the prior art, or (ii) how the combination or modification would fall
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`within the scope of the challenged claims. Both of these elements are essential to a
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`well-pleaded obviousness challenge.
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`Accordingly, Bosch respectfully submits that, for at least these reasons, the
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`Board should decline to institute the inter partes review of the ’974 patent.
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`III. STANDARD FOR INSTITUTION
`The Board, in considering whether to institute a trial, determines whether or
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`not a party has met the statutory institution standard. A petition for inter partes
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`review may be granted when “the information presented in the petition … shows
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`that there is a reasonable likelihood that the petitioner would prevail with respect to
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`at least 1 of the claims challenged in the petition.” 35 U.S.C. § 314(a); see also 37
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`C.F.R. § 42.108(c). A petitioner bears the burden of showing that this standard has
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`been met. See Office Patent Trial Practice Guide, 77 Fed. Reg. 48,756, 48,756
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`(Aug. 14, 2012) (“The Board ... may institute a trial where the petitioner
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`establishes that the standards for instituting the requested trial are met….”). A
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`petitioner also bears the burden of proving unpatentability by a preponderance of
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`the evidence. 35 U.S.C. § 316(e).
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`A petitioner making an obviousness challenge must show where each
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`claimed limitation is taught in the prior art. See, e.g., Vizio, Inc. v. Int’l Trade
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`Comm’n, 605 F.3d 1330, 1342–43 (Fed. Cir. 2010); August Tech. Corp. v. Camtek
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`Ltd., 655 F.3d 1278, 1287 (Fed. Cir. 2011); see also 37 C.F.R. § 42.104(b)(4). If a
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`petitioner asserts that a combination of prior art renders a claim unpatentable, it
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`must “set forth sufficient articulated reasoning with rational underpinning to
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`support its proposed obviousness ground.” SAS Inst., Inc. v. ComplementSoft,
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`LLC, IPR2013-00581, Paper 15 at 12 (PTAB Dec. 30, 2013) (citing KSR Int’l Co.
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`v. Teleflex, Inc., 550 U.S. 398, 418 (2007)); accord ActiveVideo Networks, 694
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`F.3d at 1327–28. The Board may “deny some or all grounds for unpatentability for
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`some or all of the challenged claims.” 37 C.F.R. § 42.108(b); see also 35 U.S.C. §
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`314(a).
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`It is a petitioner’s duty to provide sufficient grounds for institution. Here,
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`Petitioner has failed to live up to its duty. Bosch respectfully submits that
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`institution should be denied as to all grounds.
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`IV. BRIEF OVERVIEW OF U.S. PATENT. NO. 6,292,974
`U.S. Patent No. 6,292,974 (“the ’974 patent”) issued on September 25, 2001,
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`from a PCT application filed on July 9, 1998, which claims priority to a German
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`application filed on August 21, 1997.
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`The ’974 patent teaches a component with an acute angle to a plane parallel
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`to that of a support element, which deflects wind up and over the wiper blade. As
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`a consequence of this deflection, a component of the wind force is applied
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`downward toward the windshield, thereby increasing the contact pressure. More
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`completely, the ’974 patent describes and claims a wiper blade comprised of a
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`curved, band-shaped, spring-elastic support element that distributes the pressure
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`applied by the wiper arm, an elongated rubber-elastic wiper strip, a connection
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`device that is arranged directly on the convex side of the support element, and a
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`component that is separate from the wiper strip that is mounted directly to the
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`convex surface of the support element so as to form a leading-edge face extending
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`in a longitudinal direction of the support element and forming, as seen crosswise,
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`an acute angle with a plane which extends parallel to a plane formed by the convex
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`surface. See, e.g., claim 1 of the ’974 patent.
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`Figure 1 depicts a side view of a wiper blade of the ’974 invention. Figure 3
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`shows a cross-section of the wiper blade of Figure 1.
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`V.
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`PETITIONER IMPROPERLY INCORPORATES BY REFERENCE
`THE KRUGER DECLARATION
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`Bosch respectfully submits that the Kruger Declaration cannot be relied
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`upon to support the Petition because it amounts to an improper incorporation by
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`reference, which has the effect of circumventing the 60-page limit on petitions.
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`A petition requesting inter partes review is limited to 60 pages, and
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`incorporation by reference is not permitted. 37 C.F.R. §§ 42.24(a)(1)(i),
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`42.6(a)(3). The Board has consistently determined that declarations are not to be
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`used as a tool for circumventing page limits, and the tactic of incorporating lengthy
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`materials to circumvent the page limit has been determined to be improper. See,
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`e.g., Cisco, IPR2014-00454, Paper 12 at 10 (disregarding arguments made in
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`declaration that were improperly incorporated by reference; “Incorporation ‘by
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`reference amounts to a self-help increase in the length of the [] brief[,]’ and ‘is a
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`pointless imposition on the court’s time. A brief must make all arguments
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`accessible to the judges, rather than ask them to play archeologist with the
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`record.’” (alteration in original; citation omitted)); Unified Patents Inc. v.
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`OliviStar, LLC, IPR2015-01216, Paper 15 at 12–13 n.7 (PTAB Nov. 20, 2015)
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`(citing to a declaration to support conclusory statements in petition is improper
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`incorporation by reference); Blackberry Corp. v. Mobilemedia Ideas LLC,
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`IPR2013-00016, Paper 32 at 21 (PTAB Feb. 25, 2014); PCT Int’l, Inc. v.
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`Amphenol Corp., IPR2013-00229, Paper 17 at 2 (PTAB Dec. 24, 2013); Fidelity
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`National Info. Serv’s, Inc. v. Datatreasury Corp., IPR2014-00489, Paper 9 at 9–11
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`(PTAB Aug. 13, 2014).
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`Throughout the Petition, Petitioner broadly asserts that certain “[a]ppendices
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`to the Kruger Declaration illustrate” where each feature of each challenged claim is
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`disclosed in the prior art. See Petition at 18, 24, 25–26 (citing to Ex. 1013). These
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`statements are typically followed by a citation to the entirety of one or more of
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`Kruger Appendices A–E (Exs. 1014–1018). See id. The appendices alone
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`comprise fifteen pages and about 2.5 minutes of video. However, Petitioner does
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`not connect these citations to any particular claim limitation or unpatentability
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`argument.
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`This tactic amounts to an improper incorporation by reference and shifts the
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`burden to the Board to make arguments for Petitioner. Petitioner’s reliance on the
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`Kruger Declaration lacks any specificity and fails to support any particular aspect
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`of any argument of unpatentability. Accordingly, the Kruger Declaration and its
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`Appendices should be excluded from consideration, and Bosch respectfully
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`submits that Petitioner has thus failed to carry its burden with respect to all
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`grounds and all challenged claims. Therefore, institution should be denied on both
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`grounds.
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`VI. PETITIONER PUTS FORTH NO EVIDENCE THAT THE CITED
`REFERENCES DISCLOSE THE CLAIMED ELEMENTS FOUND IN
`ALL CHALLENGED CLAIMS
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`Bosch respectfully submits that Petitioner has not shown that the challenged
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`claims are unpatentable. Petitioner has not proposed any claim constructions, and
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`has failed to provide evidence that the prior art references disclose all claimed
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`elements under the plain and ordinary meanings of the claim terms. 1
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`Claim 1 includes the limitation: “a component which is separate from said
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`wiper strip and is mounted directly to the convex surface of said support element.”
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`Dependent claims 2 and 8, both of which depend on claim 1, incorporate this
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`limitation by reference. Petitioner cites no evidence of the presence of this
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`limitation in the cited prior art, and thus fails to meet its burden of specifying
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`elements that demonstrate unpatentability; indeed, Petitioner’s arguments contain
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`insufficient explanations and rest on irrelevant citations. See 37 C.F.R. §
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`42.104(b)(4) (petition must “specify where each element of the claim is found in
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`the prior art patents or printed publications relied upon.”).
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`In both grounds (Grounds 1 and 2), which are based on obviousness,
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`Petitioner relies upon the same primary reference Prohaska GB 2,106,775.
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`Prohaska teaches a conventional wiper blade having a superstructure including at
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`least one yoke. Ex. 1004 at 1:43–48. Prohaska teaches that the wiper strip needs
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`to be stiffened with a plastic or metal flexible strip, and discloses a spoiler made of
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`1 Bosch submits that a person of ordinary skill in the art in this case has an
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`undergraduate degree in mechanical engineering or a similar discipline, or several
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`years of experience in the field of wiper blade manufacture and design.
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`the stiffener material and moulded together with the stiffener, or clipped onto the
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`stiffener’s side. Id. at 1:43–52, Figs. 1–6.
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`Petitioner relies solely on Prohaska for disclosing the limitation “a
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`component which is separate from said wiper strip and is mounted directly to the
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`convex surface” of the support element. Petition at 19–22. Petitioner does not
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`argue that the secondary references it relies upon for both grounds, Appel and
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`Hoyler, disclose this limitation. Id. And the long quote from Prohaska, “spoiler
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`[i.e., component] that can be connected with the wiper element… which wiper
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`element is flexibly stiffened by a flexible strip extending over almost its entire
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`length, whereby the wiper element is provided with at least one spoiler, and
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`wherein the spoiler is formed on or attached on the flexible strip,” that is included
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`in the claim charts does not support Petitioner’s assertion. This quote, and the
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`Prohaska reference in general, do not disclose that the alleged spoiler “is mounted
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`directly to the convex surface of said support element.” Likewise, the cited Figures
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`3 and 6 do not disclose any such spoiler configuration. Petitioner, therefore, fails
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`to show that the prior art combinations disclose this limitation, and cannot establish
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`a prima facie obviousness case for all challenged claims of the ’974 patent.
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`Thus, the combinations that Petitioner presents in Grounds 1 and 2 are
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`missing at least one element of claims 1, 2, and 8 of the ’974 patent: “a component
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`which is separate from said wiper strip and is mounted directly to the convex
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`surface of said support element.” Accordingly, institution should be denied
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`because both Grounds 1 and 2 fail to establish a prima facie case of obviousness of
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`the inventions claimed in claims 1, 2 and 8 of the ’974 patent.
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`VII. THE ALLEGED OBVIOUSNESS COMBINATIONS ARE DRIVEN
`BY IMPERMISSIBLE HINDSIGHT, IGNORE TEACHINGS AWAY,
`AND REST UPON CONCLUSORY ASSERTIONS
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`Further, Petitioner has not shown why a person of ordinary skill in the art
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`would have been motivated to combine the prior art references as proposed in
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`Grounds 1 and 2. Petitioner is required to identify a specific rationale supporting
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`its contention that it would have been obvious to modify the prior art. See In re
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`Fritch, 972 F.2d 1260, 1266 (Fed. Cir. 1992) (“It is impermissible to use the
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`claimed invention as an instruction manual or ‘template’ to piece together the
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`teachings of the prior art so that the claimed invention is rendered obvious”); In re
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`NTP, Inc., 654 F.3d 1279, 1299 (Fed. Cir. 2011) (“The Board improperly relied on
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`hindsight reasoning to piece together elements to arrive at the claimed invention.
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`Care must be taken to avoid hindsight reconstruction by using the patent in suit as
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`a guide through a maze of prior art references, combining the right references in
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`the right way so as to achieve the result of the claims in suit.”). While a motivation
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`for combining and modifying the prior art may derive from numerous sources—
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`other than the ’974 patent itself—it must at least be identified and discussed. It is
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`not enough for Petitioner to assert, conclusorily, that “[c]ombining the angled
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`spoiler of Prohaska with the support element of Appel or Hoyler meets the
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`limitations of Claim 1 and yields predictable results.” Petition at 23. Petitioner
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`has to show how these elements are to be combined, and why.
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`Petitioner argues that it would have been obvious for a person of ordinary
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`skill in the art to have combined the spoiler of the Prohaska conventional bracketed
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`wiper blade with the components of the beam-type wiper blades disclosed in Appel
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`or Hoyler.2 Petitioner, however, does not provide any motivation to do so, or any
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`explanation as to how the resulting structure would be able to function as a wiper
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`blade. The motivation to combine cannot come from the ’974 patent itself.
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`Prohaska provides no such motivation, and, in fact, teaches away from the
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`invention of the ’974 patent.
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`As discussed in Section VI, supra, Prohaska is directed to a conventional
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`bracketed wiper blade “comprising a supporting structure including at least one
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`yoke element for holding a wiper element.” Ex. 1004 at 1:108–117; see also 4:13–
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`2
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`Petitioner bills Prohaska as the primary reference, even though the claim
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`charts in the Petition show that it discloses only “a wiper blade for windows of
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`motor vehicles” and a separate spoiler component. Petition at 18–22. According
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`to the Petition, a person of ordinary skill in the art would have considered “the
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`spoiler embodied in Figure 3 of Prohaska as a logical starting point.” Id. at 22.
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`17. It teaches a spoiler “formed on or attached on” the flexible stiffener strip used
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`to stiffen a wiper element. Id. at 1:48-52. Prohaska discloses that the spoiler
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`component is preferably molded together with the stiffener and made of the same
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`material, and that such molded stiffener-spoiler will “stiffen the wiper blade
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`flexibly.” Id. at 1:62–67. It also discloses that “spoilers closely arranged to the
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`windscreen are most effective against the attacking air stream.” Id. at 1:19–21,
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`Figs. 1–4, 6; see also 3:121–123 (“All embodiments shown in the drawings show a
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`wiper element which includes a spoiler closely arranged to the windscreen ….”).
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`When presenting the combination in Ground 1, Petitioner fails to explain
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`why a person of ordinary skill would have chosen to have the single-beam blade
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`construction of Appel, as opposed to the conventional-blade construction of the
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`primary reference Prohaska, or why he would have considered adding a separate
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`spoiler to the beam blade that would stiffen the beam and adversely affect the
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`sensitive force distribution of a beam blade’s spring-elastic support element.
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`Likewise, for the combination presented in Ground 2, Petitioner fails to
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`explain why a person of ordinary skill would have chosen a simple beam blade
`
`construction not disclosed anywhere in the Prohaska and Hoyler references, as
`
`opposed to the conventional-blade construction of the primary reference Prohaska
`
`or the graduated profile plastic bar of Hoyler; why he would have added a separate
`
`stiff spoiler to the resulting beam blade; or why he would have put that spoiler on
`
`
`
`13
`
`
`
`Case No. IPR2016-00038
`U.S. Patent No. 6,292,974
`top of the beam blade. Moreover, Hoyler also teaches away from this
`
`combination. Petitioner agrees that Hoyler teaches the importance of reducing the
`
`weight of a wiper blade and touts the benefits of doing so. Petition at 4, citing Ex.
`
`1006 (translation) at col. 2; see also Petition at 14. Petitioner does not explain
`
`why, in view of this disclosure, a person of ordinary skill in the art would have
`
`added an additional spoiler component to the wiper blade of Hoyler, thereby
`
`increasing—not reducing—its weight.
`
`Petitioner’s proposal to arrive at the ’974 invention by combining Prohaska
`
`with Appel or Hoyler makes it evident that Petitioner used impermissible hindsight
`
`gleaned from the ’974 patented invention to find some similar elements in the prior
`
`art and mush them together without any reason for doing so, or any expectation of
`
`success of the resulting apparatus as a functional wiper blade capable of efficiently
`
`cleaning the windows of motor vehicles.
`
`Therefore, in its Petition to invalidate the ’974 patent on Grounds 1 and 2,
`
`Petitioner has not established a reasonable likelihood that it would prevail in
`
`establishing obviousness of any of the challenged claims. Accordingly, Bosch
`
`respectfully requests that the Board decline to institute inter partes review of the
`
`’974 patent on any grounds.
`
`
`
`14
`
`
`
`Case No. IPR2016-00038
`U.S. Patent No. 6,292,974
`
`VIII. CONCLUSION
`For at least the reasons set forth above, the Board should decline to institute
`
`inter partes review of all challenged claims 1, 2, and 8 of the ’974 patent.
`
`
`
`DATED: January 28, 2016
`
`
`
`Respectfully submitted,
`
`
`
`
`
`Shearman & Sterling LLP
`
`/Enrique W. Iturralde/
`Enrique W. Iturralde (Reg. No. 72,883)
`599 Lexington Ave
`New York, NY 10022
`Tel: (212) 848-4000
`
`Agent for Patent Owner
`Robert Bosch LLC
`
`Mark A. Hannemann (pro hac vice)
`599 Lexington Ave
`New York, NY 10022
`Tel: (212) 848-4000
`
`Counsel for Patent Owner
`Robert Bosch LLC
`
`15
`
`
`
`Case No. IPR2016-00038
`U.S. Patent No. 6,292,974
`
`Certificate of Service
`
`
`The undersigned hereby certifies that the foregoing PATENT OWNER’S
`PRELIMINARY RESPONSE PURSUANT TO 35 U.S.C. § 313 AND 37 C.F.R. §
`42.107 was served via electronic mail on January 28, 2016, on the following
`counsel for Petitioner:
`
`
`Richard M. Koehl (richard.koehl@hugheshubbard.com)
`James R. Klaiber (james.klaiber@hugheshubbard.com)
`David E. Lansky (david.lansky@ hugheshubbard.com)
`
`/Enrique W. Iturralde/
`Enrique W. Iturralde (Reg. No. 72,883)
`599 Lexington Ave
`New York, NY 10022
`Tel: (212) 848-4000
`
`Agent for Patent Owner
`Robert Bosch LLC
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