UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________
`
`
`
`MICRON TECHNOLOGY, INC.
`Petitioner
`
`v.
`
`LIMESTONE MEMORY SYSTEMS LLC
`Patent Owner
`
`_______________________
`
`Case IPR. No. 2016-00094
`U.S. Patent No. 5,894,441
`Title: SEMICONDUCTOR MEMORY DEVICE
`WITH REDUNDANCY CIRCUIT
`
`_______________________
`
`
`
`Petitioner’s Request For Rehearing
`Under 37 C.F.R. § 42.71(d)
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________
`
`
`
`MICRON TECHNOLOGY, INC.
`Petitioner
`
`v.
`
`LIMESTONE MEMORY SYSTEMS LLC
`Patent Owner
`
`_______________________
`
`Case IPR. No. 2016-00094
`U.S. Patent No. 5,894,441
`Title: SEMICONDUCTOR MEMORY DEVICE
`WITH REDUNDANCY CIRCUIT
`
`_______________________
`
`
`
`Petitioner’s Request For Rehearing
`Under 37 C.F.R. § 42.71(d)
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
`Table of Contents
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`IPR No. 2016-00094
`U.S. Pat. No. 5,894,441
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`
`Page
`
`1.
`
`INTRODUCTION ................................................................................. 1
`APPLICABLE LEGAL STANDARDS ............................................... 3
`BASIS FOR RELIEF REQUESTED .................................................... 3
`The Board overlooked or misapprehended evidence and
`argument that McAdams’ redundant column selection
`line is activated in response to the first column address
`and the second word line address. .............................................. 3
`The Board viewed the McAdams “programmable with
`column and row address” passage “by itself” and
`overlooked passages which explain that it
`corresponds to the first column address and second
`word line. .......................................................................... 7
`The Board viewed the McAdams “appropriate
`addressing” passage “alone” and overlooked
`passages which explain that it corresponds to the
`first column address and second word line. .................... 10
`The Board overlooked or misapprehended the
`combination of McAdams and Minami for element 6.6 ........... 11
`The Board overlooked or misapprehended the reason for
`combining McAdams and Minami for claim 6. ........................ 12
`The Board should reassess obviousness for claims 8, 10,
`and 13. ....................................................................................... 14
`
`2.
`
`I.
`II.
`III.
`
`A.
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`B.
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`C.
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`D.
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`
`
`i
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`
`
`Table of Authorities
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`IPR No. 2016-00094
`U.S. Pat. No. 5,894,441
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`
`Page(s)
`
`Cases
`Handi Quilter, Inc. v. Bernina International AG,
`IPR2014-00270, Paper 17 at 24 (Dec. 30, 2014) ................................................... 3
`
`Merial Ltd. v. Virbac,
`IPR2014-01279, Paper 18 at 7 (Jan. 22, 2015) ...................................................... 3
`
`Muniauction, Inc. v. Thomson Corp.,
`532 F.3d 1318 (Fed. Cir. 2008) ............................................................................ 14
`
`Ultradent Products, Inc. v. Life-Like Cosmetics, Inc.,
`127 F.3d 1065 (Fed. Cir. 1997) .............................................................................. 4
`
`Statutes and Regulations
`35 U.S.C. § 103 .......................................................................................................... 1
`
`37 C.F.R. § 42.108 ..................................................................................................... 1
`
`37 C.F.R. § 42.71(c) ................................................................................................... 3
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`37 C.F.R. § 42.71(d) .................................................................................................. 3
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`
`
`i
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`IPR No. 2016-00094
`U.S. Pat. No. 5,894,441
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`I.
`
`INTRODUCTION
`On April 12, 2016, the Board issued a Decision denying institution of Inter
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`Partes Review of U.S. Pat. No. 5,894,441 (“441 Patent”) on Petitioner’s Ground 2.
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`Paper 8, Decision (“Dec.”). This Ground contends that claims 6-151 are invalid
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`under (pre-AIA) 35 U.S.C. § 103 because they are obvious over U.S. Pat. No.
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`5,270,975 (“McAdams”) in view of JP Pat. Appl. No. H06-052696 (“Minami”).
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`Petition (“Pet.”), Paper 1 at 4. First, the Board concluded that McAdams in view
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`of Minami does not teach the last limitation of claim 6, i.e., “the column
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`redundancy decoder limitation.” Dec. at 8-13. Second, the Board found that the
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`Petition does not provide sufficient reasoning with some rational underpinning to
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`support the legal conclusion of obviousness. Id. at 13-16.
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`This Request for Rehearing seeks reconsideration of Ground 2 for claims 6-
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`15. Petitioner respectfully submits that the Board overlooked or misapprehended
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`(1) the complete teachings of and contentions regarding McAdams that are set
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`forth in the Petition and Declaration of Dr. Jacob Baker (MICRON-1003) (“Baker
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`Decl.”), and instead incorrectly relied on passages from McAdams “alone” and “by
`
`itself,” and (2) the relevant teachings of Minami with respect to claim 6 and the
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`specific rationale for combining these teachings with McAdams for claim 6.
`
`
`1 Ground 2 also included claim 3, but Patent Owner disclaimed it. Dec. at 2.
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`
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`1
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`The column redundancy decoder limitation recites “a column redundancy
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`decoder activating said redundant column selection line in response to said first
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`column address when said second word line is activated.” Dec. at 9. By way of
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`example, the Board found that:
`
`The indication that each decoder is programmable ‘with column
`and row address information corresponding to a section of an array
`column containing a defective memory cell’ (id.), does not by itself
`indicate that the redundant column selection line is activated in
`response to the first column address (which is the same address that
`activates the first column selection line) when ‘said second word line
`is activated,’ as recited in claim 6.
`
`Id. at 10 (emphasis added). By viewing a snippet from McAdams “by itself,” the
`
`Board misapprehended or overlooked that McAdams discloses that its redundant
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`decoder is programmable—with any address—including (1) the first column
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`address (which also activates the first column selection line) and (2) the second
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`word line address (which activates the second word line), such that it activates a
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`redundant column selection line in response to this address. Also, the Board
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`overlooked or misapprehended that Minami supplements McAdams for claim 6 by
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`confirming that it would have been obvious for McAdams to use the conventional
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`DRAM addressing scheme, i.e., a word line is first activated using a word line
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`address and the column line is then activated using the column address
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`(“conventional row-then-column approach”). Thus, McAdams in view of
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`2
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`Minami’s conventional row-then-column approach teaches that the redundant
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`column selection line is activated “in response to said first column address when
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`the second word line is activated.”
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`II.
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`APPLICABLE LEGAL STANDARDS
`
`This Request is authorized under 37 C.F.R. § 42.71(d) because it is being
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`filed within 30 days of the entry of a decision not to institute a trial. Under 37
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`C.F.R. § 42.71(d), the Request “must specifically identify all matters the party
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`believes the Board misapprehended or overlooked, and the place where each
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`matter was previously addressed in a motion, an opposition, or a reply.” 37 C.F.R.
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`§ 42.71(c) provides that a panel will review the decision for an abuse of discretion.
`
`An abuse of discretion exists when the Board overlooks (1) relevant disclosures in
`
`a prior art reference, see Merial Ltd. v. Virbac, IPR2014-01279, Paper 18 at 7
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`(Apr. 15, 2015), or (2) reasons to combine, see Handi Quilter, Inc. v. Bernina Int’l
`
`AG, IPR2014-00270, Paper 17 at 24 (Dec. 30, 2014).
`
`III. BASIS FOR RELIEF REQUESTED
`
`A.
`
`The Board overlooked or misapprehended evidence and
`argument that McAdams’ redundant column selection line is
`activated in response to the first column address and the second
`word line address.
`
`It appears that the Board misapprehended two significant passages of
`
`McAdams by viewing the first passage “by itself” and the second passage “alone,”
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`Dec. at 10-11, thereby overlooking the full citations to McAdams and the
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`3
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`contentions that appear immediately before and after these passages. In
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`considering whether a reference discloses an element, the disclosure must be read
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`as a whole from the perspective of a person of ordinary skill in the art. Ultradent
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`Prod., Inc. v. Life-Like Cosmetics, Inc., 127 F.3d 1065, 1068 (Fed. Cir. 1997).
`
`The Petition explained, and the Board appears to have overlooked, the
`
`meaning of these two passages and their relevance to element 6.6 in the context of
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`McAdams’ DRAM architecture. As the Petition and the Baker Declaration
`
`explain, McAdams discloses a typical divided bit line DRAM array, wherein the
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`array comprises (1) columns that run vertically through the array and (2) rows that
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`run horizontally through the array. Pet. at 12-13, 32-34, 37-38; Baker Decl. ¶¶ 22-
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`23, 53-56, 58. A row address activates the row (word) line that runs horizontally,
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`and a column address activates a column selection line that runs vertically. Pet. at
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`12; Baker Decl. ¶¶ 22-23, 53-56. A row address and a column address together
`
`address one column section2; there are multiple sections within a single column
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`that are replaceable. Pet. at 12-13, 34, 43; Baker Decl. ¶¶ 22-23, 53-54, A24-27.
`
`McAdams discloses multiple column sections along a single column wherein
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`(1) a first column address and a first word line correspond to a first column section
`
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`2 The 441 Patent also refers to these sections as “segments” Pet. at 43 (citing
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`McAdams at 3:51-58).
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`4
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`(“first column section”), and (2) the same first column address and a second word
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`line correspond to a second column section (“second column section”). Pet. at 32-
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`34, 37-38, 43; Baker Decl. ¶¶ 53-54, A24-27. McAdams discloses replacing a
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`column section by programming its redundant decoder with the column address
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`and word line address (row address) of the section. Pet. at 13, 42-44. Indeed,
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`McAdams discloses that the redundant decoder is programmable with any address.
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`Id. at 43 (citing McAdams at 3:12-16, 3:51-58, 7:57-8:7, 8:44-61). Thus, if
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`memory cells in the second column section become defective, McAdams replaces
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`that section by programming the redundant column decoder with the first column
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`address and a second word line address. Pet. at 43.
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`The Petition explains that McAdams discloses the same basic architecture as
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`the 441 patent. Consistent with the broadest reasonable interpretation and the plain
`
`claim language, claim elements 6.5 and 6.6 refer to a column that includes both a
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`non-defective portion and a defective portion. Specifically, claim element 6.5
`
`requires a column decoder that activates a normal selection line in response to a
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`first column address and a first word line address (which correspond to non-
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`defective memory cells). Pet. at 7-8, 39-40; Baker Decl. at A36-37. And claim
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`element 6.6 requires a column redundancy decoder that activates a redundant
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`selection line in response to this same first column address and a second word line
`
`address. Pet. at 8-9, 42; Baker Decl. at A44. In other words, this address (first
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`5
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`column address and second word line) corresponds to a defective portion because
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`the address triggers the activation of a redundant selection line. Id.
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`Accordingly, as the Petition explains, these elements require: “while the first
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`column address and first word line activates the normal selection line [element
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`6.5], the same first column address and second word line activates the redundant
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`column selection line [element 6.6].” Pet. at 42. The Decision notes that this
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`statement is not a proposed construction. Dec. at 8. We agree. The statement
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`simply provides context for Petitioner’s contentions, namely, (1) that McAdams
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`discloses that its normal column decoder will use a first column address and a first
`
`word line to activate a normal column selection line (element 6.5), and (2) that
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`McAdams discloses that its redundant column decoder is programmable with this
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`same first column address and a second word line address to activate a redundant
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`column selection line (element 6.6). Pet. at 39-40, 42.
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`The Petition establishes, and the Board misapprehended or overlooked, that
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`McAdams discloses these contentions. For claim element 6.5, the Petition
`
`establishes that McAdams discloses a first column address and a first word line
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`that corresponds to a normal column selection line (and thus the column decoder
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`activates the first column selection line in response to this address). Pet. at 39-40.
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`And for claim element 6.6, the Petition establishes that McAdams discloses a
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`redundant decoder that is programmable with any address, including the same
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`6
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`first column address and a second word line that corresponds to a defective column
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`segment (and thus the redundant decoder will activate the redundant column
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`selection line in response to this address). Pet. at 42-44.
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`1.
`
`The Board viewed the McAdams “programmable with
`column and row address” passage “by
`itself” and
`overlooked passages which explain that it corresponds to
`the first column address and second word line.
`
`As noted above, the Board found that the McAdams “programmable with
`
`column and row address” disclosure by itself does not disclose element 6.6. In
`
`considering this passage by itself, the Board overlooked passages in the Petition
`
`that explain how McAdams’ redundant decoder is programmable with any
`
`address, including the first column address and second word line address.
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`Immediately preceding this contention, the Petition describes how the programmed
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`“column and row address” of McAdams would have been understood in this
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`context: “Specifically, [clause 1] while the first column address and first word line
`
`activates the normal selection line, [clause 2] the same first column address and
`
`second word line activates the redundant column selection line.” Pet. at 42. The
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`first clause refers to element 6.5, and the second clause refers to element 6.6. The
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`Petition’s contention therefore is that the same first column address and a second
`
`word line correspond to a defective portion. Id. McAdams then directly discloses
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`that its redundant decoder is programmable with the same first column address and
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`second word line because it is programmable with any column section address
`
`7
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`to replace defective portions: “each programmable with column and row
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`address information corresponding to a section of an array column containing a
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`defective memory cell. With this programming, memory cells in a segment of a
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`repair column can replace memory cells in a segment of an array column
`
`containing a defective memory cell.” Pet. at 43 (citing McAdams at 3:51-58).
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`Similarly, the sentence immediately following the passage that the Board
`
`read “by itself” confirms that McAdams discloses element 6.6: “depending on the
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`row address (first or second word line), activation of the redundant selection line
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`will occur, e.g., if the column and second word line address correspond to a
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`defective cell.” Pet. at 43.3 With this context, the McAdams passage that the
`
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`3 The Board found the reference to “the column” to be ambiguous because it does
`
`not “specify[] which one.” Dec. at 10. Respectfully, there is no ambiguity. First,
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`the immediately preceding passage spells out that “the column” under discussion is
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`the “first column address.” See Pet. at 42 (“the same first column address and
`
`second word line activates the redundant column selection line”). A subsequent
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`sentence likewise identifies “the column” as the first column address. Pet. at 43
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`(“(e.g., first column address and second word line) matches a defective cell”).
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`Second, read in the context, this sentence states the two conditions of elements 6.5-
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`6.6: (1) the first column address and first word line activate a normal column
`
`
`
`8
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`Board read in isolation discloses programming the redundant decoder with the first
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`column address and second word line because the column redundancy decoder is
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`“programmable with column and row address information corresponding” to a
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`defective column portion. Pet. at 43 (citing McAdams at 3:51-58). This passage
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`also includes a citation to McAdams at 3:12-16, further confirming that McAdams
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`discloses element 6.6 because the redundant column selection lines are “capable of
`
`replacing multiple defective column portions” (e.g., the portion corresponding to
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`the first column address and second word line). Pet. at 43.
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`Finally, the Petition’s “appropriate addressing” contention (see infra,
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`Section III.A.2) confirms McAdams’ disclosure of element 6.6. There, the Petition
`
`provides the relevant context: “the address (e.g., first column address and second
`
`word line) matches a defective cell,” citing to McAdams at 7:57-8:7 and 8:44-61,
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`which describe programming the redundant decoder with such an address to
`
`replace a defective column section. Pet. at 43-44. Thus, the “column and row
`
`address information” in the context of the complete McAdams disclosure refers to
`
`the first column address and the second word line of claim element 6.6.
`
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`selection line (6.5), and (2) the first column address and second word line activate
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`a redundant column selection line (6.6). See Baker Decl. at A44 (summary only
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`recites dependents claims because they incorporate elements of claim 6).
`
`9
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`2.
`
`The Board viewed the McAdams “appropriate addressing”
`passage “alone” and overlooked passages which explain that
`it corresponds to the first column address and second word
`line.
`
`In regards to the Petition’s contention at pages 43-44, the Board found that
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`“[t]he reference to ‘appropriate addressing’ (id.) alone is vague, and does not
`
`indicate that the redundant column selection line is activated in response to the first
`
`column address when the second word line is activated, as recited in claim 6.”
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`Dec. at 11 (emphasis added). In reaching this conclusion, the Board overlooked
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`passages in the Petition which show that “appropriate addressing” refers to the first
`
`column address and a second word line.
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`First, in addition to the context set forth above in Section III.A.1., how
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`“appropriate addressing” would have been understood is directly set forth in the
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`contention itself: “the redundant column decoder that activates the redundant
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`column selection lines if the address (e.g., first column address and second word
`
`line) matches a defective cell.” Pet. at 43 (emphasis added).
`
` Second, read together, the Petition’s discussion of elements 6.5-6.6 makes
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`clear that the “appropriate addressing” for element 6.6 includes a second word line,
`
`not the first word line. As to element 6.5, the Petition explains that the first
`
`column address and first word line correspond to a non-defective column section.
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`Pet. at 39-40. As to element 6.6, this contention relates to a defective column
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`section—a section that has the same column address as in element 6.5. Pet. at 42-
`
`10
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`43; Baker Decl. at A44. Accordingly, the word line in this contention that maps to
`
`element 6.6 necessarily must be different (a “second word line”) than the word line
`
`in element 6.5 because element 6.6’s word line corresponds to a defective column
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`section. Pet. at 32-34; Baker Decl. ¶¶ 22-23, 53-56, 58.
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`Third, the Board overlooked the full McAdams citation within this
`
`contention, which includes column 8:2-7. This passage explains that the redundant
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`decoder replaces any “segment of memory cells” (column section) by using (1) a
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`column address C, which in context is the first column address of elements 6.5-6.6,
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`and (2) a row address that corresponds to a defective bit line segment, which must
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`be a “second word line,” not the first, because the second corresponds to a
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`defective column section whereas the first does not. Pet. at 32-34, 39-40, 42-43.
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`Accordingly, the Petition shows that the redundancy decoder activates the
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`redundant selection line when the first column address and second word line
`
`address are provided.
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`B.
`
`The Board overlooked or misapprehended the combination of
`McAdams and Minami for element 6.6
`
`The Board misapprehended the Petition’s discussion of Minami with respect
`
`to elements 6.5-6.6. In discussing how McAdams in view of Minami discloses
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`element 6.6, the Petition referred to its discussion of “the previous limitation,”
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`citing Section 10.2.6 and element 6.5. Pet. at 44. The Board found that this
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`reference “does not provide sufficient specificity.” Dec. at 11. This was error,
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`11
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`because there is only one discussion of Minami with respect to element 6.5—the
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`teaching of “the conventional row-then-column approach exemplified in Minami.”
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`Pet. at 42. As Dr. Baker explains with respect to element 6.5, McAdams would
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`have been understood to use this “conventional row-then-column approach
`
`exemplified in Minami such that the controller in McAdams first enters the row
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`address (to open the word line) and second, enters the column address.” Baker
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`Decl. at A41. Then for element 6.6, Dr. Baker states that “McAdams would use
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`the conventional row-then-column approach exemplified in Minami” and cites
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`back to element 6.5. Id. at A47-48. Accordingly, the citation back to element 6.5
`
`specifies that the relevant teaching of Minami is the “conventional row-then-
`
`column approach.”
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`The Board appears to have overlooked or misapprehended the row-then-
`
`column teachings. Elements 6.5-6.6 require that the column selection lines are
`
`activated “when” the word lines are activated, i.e., the word lines are activated
`
`first. See, e.g., Baker Decl. A38, A41. For element 6.6, the second word line must
`
`be activated before the redundant column selection line. The Petition explains that
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`this row-then-column approach was conventional: “it would have been obvious to
`
`a person of ordinary skill in the art to activate the column decoder when the word
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`line is activated because that was the conventional operation.” Pet. at 40.
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`C.
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`The Board overlooked or misapprehended the reason for
`combining McAdams and Minami for claim 6.
`
`12
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`The Board erred in concluding that the Petition did not provide sufficient
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`reasons for combining McAdams and Minami. The Board overlooked, and did not
`
`address, the reason set forth in the Petition for combining McAdams and Minami
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`that is specific to claim 6, namely, that the row-then-column approach was the
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`conventional DRAM addressing approach. Dec. at 13-16. The Petition and Dr.
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`Baker’s Declaration state that Minami’s teaching of the conventional row-then-
`
`column approach provides the rationale for combining McAdams and Minami to
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`invalidate claim 6: “[t]he teachings in Minami supplement the disclosures in
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`McAdams and teaches, as is conventional and is how DRAMs work, that column
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`lines are accessed when a word line is activated as required by claim 6.” Baker
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`Decl. ¶ 73; see also Pet. at 26, 42; Baker Decl. at A47-48. Because it is so
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`conventional, the Declaration explains “that one of ordinary skill in the art would
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`have understood the system in McAdams would use the conventional row-then-
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`column approach.” Baker Decl. at A41 (citing McAdams’ “multiplexing” as
`
`suggesting the conventional approach). Indeed, Dr. Baker first explained (with
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`reference to the Prince textbook, MICRON-1007) that this was the conventional
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`operation of a DRAM, which directly supports his statements regarding the level of
`
`ordinary skill in the art. See Baker Decl. ¶ 23. However, the Petition concedes
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`that McAdams does not “expressly disclose” this conventional row-then-column
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`timing, but argues it would have been obvious in light of Minami, which shows
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`13
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`this conventional timing. Pet. at 40-42; Baker Decl. at A38-41. For additional
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`support, the Petition notes that McAdams discloses that its addressing is applicable
`
`to “any of several well known decoder circuit arrangements.” Pet. at 28; Baker
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`Decl. ¶ 76. Likewise, Dr. Baker states that the “multiplexing” of McAdams
`
`suggests the conventional approach. Baker Decl. at A41. The Board appears to
`
`have overlooked or misapprehended that Minami merely confirms that McAdams
`
`would be understood to activate a row before activating a column and that using
`
`such conventional addressing is obvious.4 See Muniauction, Inc. v. Thomson
`
`Corp., 532 F.3d 1318, 1325-27 (Fed. Cir. 2008) (holding that implementing a
`
`disclosure on a “conventional” web browser was obvious).
`
`D.
`
`The Board should reassess obviousness for claims 8, 10, and 13.
`
`The Decision did not specifically address dependent claims 8, 10, and 13.
`
`Dec. at 16. First, should the Board institute a trial on the ground that McAdams in
`
`view of Minami renders claim 6 obvious, then it should consider whether any
`
`additional Minami teachings are necessary to combine for claim 13. The Board
`
`focuses on (1) the substitution of Minami’s transistors T0-T3 and (2) Patent
`
`Owner’s arguments relating to this substitution. Dec. at 14-15. The Petition,
`
`
`4 Nowhere does the Petition argue for bodily incorporation of Minami’s
`
`components for claim 6. Pet. at 40-41, 44.
`
`14
`
`
`
`IPR No. 2016-00094
`U.S. Pat. No. 5,894,441
`
`however, first argues that under the broadest reasonable interpretation of “transfer
`
`gate,” McAdams discloses this element and the substitution of Minami’s transistors
`
`T0-T3 is therefore unnecessary. Pet. at 56-57. The Petition only argues that it
`
`would have been obvious to utilize Minami’s transistors T0-T3 if the Board were to
`
`adopt a narrow construction of “transfer gate.” Pet. at 57-58. Thus, if the Board
`
`adopts Petitioner’s proposed construction and institutes a trial on claim 6 (Pet. at
`
`10-11), it is irrelevant whether there is a rationale to substitute the transfer gates of
`
`Minami for circuitry of McAdams with respect to claim 13.
`
`Second, the Board should specifically consider the rationale for combining
`
`Minami and McAdams, e.g., lowering power consumption, for claims 8 and 10.
`
`Baker Decl. at A52-54; Pet. at 26, 46-47. The Board instead focuses on arguments
`
`relating to claim 13 and discusses modifications that are not necessary to render
`
`claims 8-10 obvious.
`
`Respectfully submitted,
`
`Dated: May 12, 2016
`
`By:
`
`
`
`
`
`
`Jeremy Jason Lang (Reg. No. 73604)
`Lead Counsel for Petitioner
`Weil, Gotshal & Manges LLP
`201 Redwood Shores Parkway
`Redwood Shores, CA 94065
`Telephone: 650-802-3237
`
`15
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e), that
`
`service was made on the Patent Owner as detailed below. Patent Owner has
`
`consented to service by electronic means.
`
`Date of service May 12, 2016
`
`Manner of service
`
`ELECTRONICALLY VIA EMAIL
`
`Documents served
`
`Petitioner’s Request For Rehearing Under 37 C.F.R.
`§ 42.71 (d)
`
`Persons served
`
`Patent Owner’s Counsel of Record
`
`Nicholas T. Peters
`PTO Registration No. 53,456
`FITCH EVEN TABIN & FLANNERY LLP
`120 South LaSalle Street, Suite 1600
`Chicago, Illinois 60603
`Telephone: (312) 577-7000
`Facsimile: (312) 577-7007
`Email: LimestoneIPR@fitcheven.com
`
`Paul B. Henkelmann
`PTO Registration No. 65,891
`FITCH EVEN TABIN & FLANNERY LLP
`120 South LaSalle Street, Suite 1600
`Chicago, Illinois 60603
`Telephone: (312) 577-7000
`Facsimile: (312) 577-7007
`Email: LimestoneIPR@fitcheven.com
`
`/Jeremy Jason Lang/
`
`Jeremy Jason Lang
`Lead Counsel for Petitioner
`Registration No. 73604
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