UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`NEOCHORD, INC.
`Petitioner
`
`v.
`
`UNIVERSITY OF MARYLAND, BALTIMORE
`
`Patent Owner
`______________
`
`Case No. IPR2016-00208
`Patent No. 7,635,386
`______________
`
`
`
`PATENT OWNER’S REPLY TO PETITIONER’S OPPOSITION TO
`PATENT OWNER’S MOTION TO DISMISS
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`NEOCHORD, INC.
`Petitioner
`
`v.
`
`UNIVERSITY OF MARYLAND, BALTIMORE
`
`Patent Owner
`______________
`
`Case No. IPR2016-00208
`Patent No. 7,635,386
`______________
`
`
`
`PATENT OWNER’S REPLY TO PETITIONER’S OPPOSITION TO
`PATENT OWNER’S MOTION TO DISMISS
`
`
`
`
`
`Patent Owner’s Reply to Petitioner’s Opposition
`Case No.: IPR2016-00208 - Atty Docket: HARP-001/02US
`Table of Contents
`
`
`Page
`
`
`I.
`
`II.
`
`UMB HAS NOT WAIVED SOVEREIGN IMMUNITY .............................. 1
`A. UMB Did Not Waive Immunity by Its Litigation Conduct ................. 2
`B. UMB Did Not Waive Immunity in the Harpoon MLA ....................... 5
`COVIDIEN IS INDISTINGUISHABLE AND CORRECTLY
`DECIDED ....................................................................................................... 6
`A.
`Covidien is not distinguishable ............................................................ 7
`B.
`This Case is Governed by FMC, not Cuozzo ....................................... 7
`C.
`Claims of Constitutional and Statutory Abrogation Are
`Meritless ............................................................................................... 9
`III. CONCLUSION ............................................................................................. 10
`
`-i-
`
`
`
`
`
`
`
`
`
`
`
`Patent Owner’s Reply to Petitioner’s Opposition
`Case No.: IPR2016-00208 - Atty Docket: HARP-001/02US
`Table of Authorities
`
`
`Page(s)
`
`
`Cases
`Baum Research and Dev. Co., Inc. v. Univ. of Mass. at Lowell,
`503 F.3d 1367 (Fed. Cir. 2007) ........................................................................ 2, 6
`Biomedical Patent Mgmt. Corp. v. California, Dep’t of Health Servs.,
`505 F.3d 1328 (Fed. Cir. 2007) ............................................................................ 9
`Central Virginia Community Coll. v. Katz,
`546 U.S. 356 (2006) .............................................................................................. 9
`Coll. Sav. Bank v. Florida Prepaid Postsecondary Educ. Expense Bd.,
`527 U.S. 666 (1999) .......................................................................................... 1, 2
`Cuozzo Speed Techs. LLC v. Lee,
`136 S. Ct. 2131 (2016) (Opp’n ) ................................................................... 7, 8, 9
`Edelman v. Jordan,
`415 U.S. 651 (1974) .......................................................................................... 2, 6
`Fed. Mar. Comm’n v. South Carolina State Ports Auth.,
`535 U.S. 743 (2002) ...................................................................................... 1, 7, 8
`
`Florida Dep’t of Health & Rehab. Servs. v. Florida Nursing Home
`Ass’n,
`450 U.S. 147 (1981) .............................................................................................. 6
`Florida Dep’t of State v. Treasure Salvors, Inc.,
`458 U.S. 670 (1982) .................................................................................. 2, 3, 4, 5
`Florida Prepaid Postsecondary Educ. Expense Bd. v. Coll. Sav. Bank,
`527 U.S. 627 (1999) ........................................................................................ 9, 10
`Hill v. Blind Ind. and Servs. of Maryland,
`179 F.3d 754 (1999) .......................................................................................... 4, 5
`
`
`
`
`
`-ii-
`
`
`
`
`
`Patent Owner’s Reply to Petitioner’s Opposition
`Case No.: IPR2016-00208 - Atty Docket: HARP-001/02US
`Table of Authorities
`(continued)
`
`Page(s)
`
`
`Lapides v. Bd. of Regents of Univ. Sys. of Georgia,
`535 U.S. 613 (2002) ...................................................................................... 3, 4, 5
`State Contracting & Eng’g Corp. v. State of Florida,
`258 F.3d 1329 (Fed. Cir. 2001) .................................................................... 3, 4, 5
`Vas-Cath, Inc. v. Curators of Univ. of Missouri,
`473 F.3d 1376 (Fed. Cir. 2007) ............................................................................ 3
`Statutes
`Patent Remedy Act ............................................................................................... 9, 10
`Other Authorities
`37 C.F.R. 42.5(c) ........................................................................................................ 5
`Fourteenth Amendment ........................................................................................... 10
`Fed. R. Civ. P. 12(b)(6) .............................................................................................. 2
`
`-iii-
`
`
`
`
`
`
`
`
`
`
`
`Patent Owner’s Reply to Petitioner’s Opposition
`Case No.: IPR2016-00208 - Atty Docket: HARP-001/02US
`Petitioner’s Opposition does not dispute (1) that UMB is a sovereign arm of
`
`the State of Maryland or (2) that, under Fed. Mar. Comm’n v. South Carolina State
`
`Ports Auth., 535 U.S. 743 (2002) (“FMC”), inter partes review (“IPR”)
`
`“substantially resembles” civil litigation, just as Covidien found. Petitioner also has
`
`no answer to UMB’s showing that it retains substantial rights in the ’386 Patent and
`
`that this IPR cannot proceed without UMB. Petitioner simply ignores the dispositive
`
`issue of substantial rights and asserts without argument that Harpoon “should be
`
`considered . . . the ‘effective patentee’.” Opp’n at 3. Petitioner purports to criticize
`
`the Covidien panel for ignoring “binding . . . precedent,” but that precedent has no
`
`bearing on the analysis of sovereign immunity. And Petitioner offers arguments for
`
`ostensible waiver and abrogation of immunity that are squarely precluded by
`
`decisions of the Supreme Court and Federal Circuit. Petitioner’s arguments are
`
`meritless. The IPR should be dismissed.
`
`I.
`
`UMB HAS NOT WAIVED SOVEREIGN IMMUNITY
`Petitioner claims that UMB waived immunity by defending on the merits
`
`before “belated[ly]” seeking dismissal, and waived expressly in the Harpoon MLA.
`
`The test for waiver of sovereign immunity “is a stringent one.” Coll. Sav. Bank v.
`
`Florida Prepaid Postsecondary Educ. Expense Bd., 527 U.S. 666, 675 (1999)
`
`(quotation marks and citation omitted). A State waives immunity only if it
`
`“voluntarily invokes [the] jurisdiction” of a forum (waiver by litigation conduct), or
`
`
`
`
`
`Patent Owner’s Reply to Petitioner’s Opposition
`Case No.: IPR2016-00208 - Atty Docket: HARP-001/02US
`provides a “clear declaration” that it will submit to jurisdiction (express waiver).
`
`Coll. Sav. Bank, 527 U.S. at 675-76. Neither applies here.
`
`A. UMB Did Not Waive Immunity by Its Litigation Conduct
`Petitioner concedes at page three of its brief that sovereign immunity “may be
`
`raised at any point of the proceedings,” Florida Dep't of State v. Treasure Salvors,
`
`Inc., 458 U.S. 670, 683 n.18 (1982), Edelman v. Jordan, 415 U.S. 651, 677-78
`
`(1974), yet in the same breath urges that UMB waived the defense by raising it
`
`“belated[ly],” and that the issue should be analyzed “in a manner analogous” to an
`
`FRCP 12(b)(6) motion. That is not the law of the Supreme Court or Federal
`
`Circuit—a fact underscored by the authority Petitioner offers in its support, a law
`
`student’s Note and a readily distinguishable 9th Circuit case that simply disagrees
`
`with the controlling Supreme Court rule.
`
`The rule that sovereign immunity “may be raised at any point of the
`
`proceedings,” does not mean that the defense can never be waived by conduct, but
`
`rather that the defense is not waived by raising it “late” outside the ordinary
`
`procedural course of the case. Treasure Salvors, 458 U.S. at 683 n.18; see, e.g.,
`
`Baum Research and Dev. Co., Inc. v. Univ. of Mass. at Lowell, 503 F.3d 1367, 1371
`
`(Fed. Cir. 2007). A state waives sovereign immunity through litigation conduct
`
`where it affirmatively invokes the jurisdiction of the forum, “voluntarily becom[ing]
`
`party to a cause” by filing suit, intervening in a suit, or removing a suit to the forum.
`
`
`
`2
`
`
`
`Patent Owner’s Reply to Petitioner’s Opposition
`Case No.: IPR2016-00208 - Atty Docket: HARP-001/02US
`See Lapides v. Bd. of Regents of Univ. Sys. of Georgia, 535 U.S. 613, 619 (2002)
`
`(internal quotation marks and citation omitted). That rule exists to prevent
`
`“seriously unfair results” from misuse of the privilege for tactical advantage.
`
`Lapides, 535 U.S. at 619; Vas-Cath, Inc. v. Curators of Univ. of Missouri, 473 F.3d
`
`1376, 1381-83 (Fed. Cir. 2007) (“the principles of federalism are not designed for
`
`tactical advantage”).
`
`A State does not waive sovereign immunity when it responds to a lawsuit
`
`brought against it and defends on the merits as UMB did here. See Treasure Salvors,
`
`458 U.S. at 683 n.18. As the Court held in Treasure Salvors “the fact that the State
`
`appeared and offered defenses on the merits does not foreclose consideration of the
`
`Eleventh Amendment issue; ‘the Eleventh Amendment defense sufficiently partakes
`
`of the nature of a jurisdictional bar’ that it may be raised at any point of the
`
`proceedings.” Id. In State Contracting & Eng'g Corp. v. State of Florida, 258 F.3d
`
`1329 (Fed. Cir. 2001), the State failed to move to dismiss patent infringement claims
`
`on sovereign immunity grounds and engaged in extensive litigation before seeking
`
`summary judgment on the merits and immunity. Id. at 1332–33. The Federal Circuit
`
`found it “quite clear that those activities do not amount to a waiver,” rejecting any
`
`suggestion that the State waived “by defending this litigation.” Id. at 1336 (citing
`
`Treasure Salvors, 458 U.S. at 683 n.18).
`
` The same result follows in this case. UMB did not voluntarily invoke PTAB
`
`
`
`3
`
`
`
`Patent Owner’s Reply to Petitioner’s Opposition
`Case No.: IPR2016-00208 - Atty Docket: HARP-001/02US
`jurisdiction but rather “was brought involuntarily into the case as a defendant.” See
`
`Lapides, 535 U.S. at 620. And UMB did not waive immunity merely by “defending
`
`this litigation” on the merits before first raising the defense. See Treasure Salvors,
`
`458 U.S. at 683 n.18; State Contracting, 258 F.3d at 1332.
`
`The correctness of that result is also confirmed by the fact that UMB enjoys
`
`no tactical advantage in raising its immunity defense now. See Lapides, 535 U.S. at
`
`619-23. UMB filed no previous motions to dismiss, and sought permission to make
`
`this motion promptly after the Covidien decision and before any Panel decision
`
`touching the merits. Even Petitioner has not suggested that this timing could confer
`
`an unfair tactical advantage on UMB. This case does not implicate the “seriously
`
`unfair results” that the rules of waiver by conduct are intended to address. See
`
`Lapides, 535 U.S. at 620.
`
`
`
`Petitioner purports to rely on the 9th Circuit’s decision in Hill v. Blind Ind.
`
`and Servs. of Maryland, 179 F.3d 754 (1999), where defendant repeatedly sought
`
`dismissal on jurisdictional grounds but withheld an immunity defense until the first
`
`day of trial. The Hill panel, scenting that defendant’s delay was tactical, held the
`
`defense was raised too late. Hill does not govern this proceeding, has never been
`
`cited by the Federal Circuit, fails to discuss Treasure Salvors (but expresses open
`
`disagreement with the rule there applied) and is readily distinguished. Here, unlike
`
`in Hill, UMB had not moved to dismiss on other grounds and it is undisputed that
`
`
`
`4
`
`
`
`Patent Owner’s Reply to Petitioner’s Opposition
`Case No.: IPR2016-00208 - Atty Docket: HARP-001/02US
`UMB could gain no unfair tactical advantage from the timing of its motion.
`
`
`
`Ultimately, Petitioner has not offered an argument for waiver by litigation
`
`conduct, but only an argument that UMB should be procedurally defaulted for
`
`raising the issue “late.” If a rule of procedural default was applicable, then the Board
`
`would have sound reason to excuse UMB’s lateness under 37 C.F.R. 42.5(c).
`
`Fundamental principles of federalism deprive the Board of jurisdiction, UMB enjoys
`
`no tactical advantage, and Petitioner has articulated no prejudice to its ability to
`
`respond to the motion. But UMB cannot be defaulted for failing to raise the issue
`
`earlier. Treasure Salvors, 458 U.S. at 683 n.18. The only litigation conduct that
`
`supports waiver is the voluntary invocation of the Board’s jurisdiction. Lapides, 535
`
`U.S. at 619-20. And it is “quite clear” that UMB’s conduct in merely “defending
`
`this litigation” without first raising the defense “do[es] not amount to a waiver.”
`
`State Contracting, 258 F.3d at 1336.
`
`B. UMB Did Not Waive Immunity in the Harpoon MLA
`Petitioner contends that, notwithstanding UMB’s express reservation of
`
`sovereign immunity in the Harpoon MLA, see MLA § 14.6, UMB waived immunity
`
`by agreeing that Harpoon may seek USPTO reexamination of the licensed patents.
`
`See Opp’n at 6-8. Petitioner misreads the MLA and applicable law. A waiver as to
`
`Harpoon, if any, is not a waiver as to Petitioner.
`
`A waiver of sovereign immunity may be found “‘only where stated by the
`
`
`
`5
`
`
`
`Patent Owner’s Reply to Petitioner’s Opposition
`Case No.: IPR2016-00208 - Atty Docket: HARP-001/02US
`most express language or by such overwhelming implications from the text as [will]
`
`leave no room for any other reasonable construction.’” Florida Dep't of Health &
`
`Rehab. Servs. v. Florida Nursing Home Ass'n, 450 U.S. 147, 150 (1981) (quoting
`
`Edelman, 415 U.S. at 673) (quotation marks and citation omitted).
`
`In § 3.7.1 of the MLA, Harpoon agreed to proceed by ex parte reexamination
`
`or reissue prior to bringing any Patent Challenge against UMB. Petitioner claims
`
`this “makes clear that UMB did not consider Patent Challenges at the USPTO to be
`
`subject to sovereign immunity.” Opp’n at 7. To the contrary, in MLA § 3.7.2, UMB
`
`expressly reserved the right to demand that Harpoon abandon any Patent Challenge
`
`other than “a request for reexamination or reissue under Section 3.7.1.” The MLA
`
`was executed in 2013, after the current IPR regime was in effect. UMB’s express
`
`reservation in § 3.7.2 therefore encompasses IPRs, and UMB has not waived
`
`immunity to IPRs.
`
`Still more importantly, even if UMB had waived immunity to a Harpoon IPR,
`
`it did not waive as to an IPR brought by Petitioner. Baum, on which Petitioner
`
`purports to rely, involved a district court action by a licensee against its licensor
`
`based on the contractual waiver of immunity between them. 503 F.3d at 1368-69.
`
`No authority permits the panel to construe a waiver of immunity with a contractual
`
`counter-party as a waiver of immunity against all comers.
`
`II. COVIDIEN IS INDISTINGUISHABLE AND CORRECTLY DECIDED
`
`
`
`6
`
`
`
`Patent Owner’s Reply to Petitioner’s Opposition
`Case No.: IPR2016-00208 - Atty Docket: HARP-001/02US
`A. Covidien is not distinguishable
`Petitioner claims that Covidien is not “sufficiently similar” to this case to “be
`
`controlling.” Opp’n at 8. But the only non-trivial dissimilarity Petitioner has
`
`identified is the timing of the motions to dismiss and, as discussed, the defense of
`
`sovereign immunity is not waived by raising it “late.” Petitioner also emphasizes
`
`that Covidien is not binding on this Panel. We commend Covidien to the Panel not
`
`as binding precedent, but because it is instructive and correctly decided.
`
`B.
`This Case is Governed by FMC, not Cuozzo
`As UMB discussed in its opening brief, under FMC, a sovereign has immunity
`
`
`
`against a federal administrative proceeding if that proceeding “strong[ly]
`
`resemble[es]” civil litigation. See FMC, 535 U.S. at 757. The Covidien panel
`
`carefully applied the FMC test to IPR, correctly determined that IPR shares the
`
`essential characteristics of the Maritime Commission proceeding in FMC, and held
`
`that a non-consenting sovereign therefore has immunity against IPR. Notably,
`
`Petitioner never suggests any factual distinction between the IPR process and the
`
`characteristic processes of civil litigation discussed in FMC.
`
`
`
`Because Petitioner cannot contest Covidien’s correct application of FMC to
`
`IPR, it instead contends that this case is not governed by FMC, but rather by the
`
`Supreme Court’s decision in Cuozzo Speed Techs. LLC v. Lee, 136 S. Ct. 2131
`
`(2016) (Opp’n at 10-12), a case having nothing to do with sovereign immunity and
`
`
`
`7
`
`
`
`Patent Owner’s Reply to Petitioner’s Opposition
`Case No.: IPR2016-00208 - Atty Docket: HARP-001/02US
`one Petitioner willfully misreads. Cuozzo did not hold, state, or imply that IPR fails
`
`to strongly resemble a civil lawsuit, which is the only question presented here.
`
`
`
`In Cuozzo the Court held that Congress authorized the PTO to make its own
`
`rule for patent claim construction in IPR, different from the rule applied in district
`
`court invalidity proceedings. 136 S. Ct. at 2142. Cuozzo had pointed to the
`
`“adjudicatory characteristics” of IPR to argue that Congress intended IPR as a
`
`“surrogate” for district court invalidity proceedings and the district court rule should
`
`therefore apply. Id. at 2143. The Court acknowledged the adjudicatory character of
`
`IPR but rejected Cuozzo’s “surrogate” argument. Id. at 2143-44. In its analysis, it
`
`found “most importantly . . . that “the purpose of the [IPR] proceeding is not quite
`
`the same as the purpose of district court litigation” and resembles the purpose of ex
`
`parte reexamination. Id. at 2144 (emphasis added).
`
`
`
`Contrary to Petitioner’s contentions, see Opp’n at 10-11, UMB has never
`
`argued that inter partes review is a “surrogate” for, nor that it serves the same
`
`purpose as a district court invalidity proceeding. Those issues have no bearing on
`
`the sovereign immunity question, which asks whether the process of IPR resembles
`
`civil litigation. See FMC, 535 U.S. at 757-58. Congress’s purpose in creating IPR,
`
`analyzed in Cuozzo, does not speak to the relevant fact that the process of IPR—
`
`adversarial, adjudicative and including formal motion practice such as this—
`
`overwhelmingly resembles a lawsuit. Cuozzo’s only relevance here is to underscore
`
`
`
`8
`
`
`
`Patent Owner’s Reply to Petitioner’s Opposition
`Case No.: IPR2016-00208 - Atty Docket: HARP-001/02US
`again the many respects in which the IPR process strongly resembles the process of
`
`civil litigation. See Cuozzo, 136 S. Ct. at 2143.
`
`Petitioner, who has ignored Cuozzo’s holding, reasoning and context, purports
`
`to criticize the Covidien panel for disregarding Cuozzo’s “binding . . . precedent”
`
`and “reaching a different legal conclusion as to the nature of IPR proceedings.”
`
`Opp’n at 12. But Covidien reached a “different conclusion” only in the trivial sense
`
`that it correctly addressed a different question. Cuozzo’s question and answer have
`
`no application to the issue before this Panel.
`
`C. Claims of Constitutional and Statutory Abrogation Are Meritless
`In Point IV(B) of its Opposition, Petitioner claims that the Article I Patent
`
`Clause exempts patent proceedings from sovereign immunity to the same extent that
`
`Bankruptcy Proceedings are exempt under the Bankruptcy Clause and Central
`
`Virginia Community Coll. v. Katz, 546 U.S. 356 (2006). Petitioner is wrong. In
`
`Florida Prepaid Postsecondary Educ. Expense Bd. v. Coll. Sav. Bank, 527 U.S. 627
`
`(1999), the Court held that the Patent Remedy Act unconstitutionally abrogates
`
`sovereign immunity in part because “Congress may not abrogate state sovereign
`
`immunity pursuant to its Article I powers . . . under the Patent Clause.” Id. at 636.
`
`In Biomedical Patent Mgmt. Corp. v. California, Dep’t of Health Servs., 505 F.3d
`
`1328 (Fed. Cir. 2007) the Federal Circuit rejected the same argument that Petitioner
`
`offers here, holding that Katz had not implicitly over-ruled Florida Prepaid. Id. at
`
`
`
`9
`
`
`
`Patent Owner’s Reply to Petitioner’s Opposition
`Case No.: IPR2016-00208 - Atty Docket: HARP-001/02US
`1343. Sovereign immunity thus applies fully to patent proceedings.
`
`In Point IV(C) Petitioner appears to argue that (1) Congress abrogated
`
`immunity in IPR proceedings in the Patent Remedy Act and (2) the Act has not been
`
`held unconstitutional in that respect. Opp’n at 13-14. To the contrary, abrogation
`
`requires that Congress “unequivocally express[ ] its intent” to abrogate immunity.
`
`Florida Prepaid, 527 U.S. at 635. Here, intent to abrogate is not unequivocally
`
`expressed since, among other things, the IPR regime was enacted twenty-years after
`
`the Patent Remedy Act, which had already been declared unconstitutional. If there
`
`were unequivocal intent, then abrogation would be unconstitutional for reasons
`
`stated in Florida Prepaid. Id. at 635-48. To subject a State patent owner to
`
`invalidity proceedings could not conceivably be defended as a valid exercise of
`
`Congress’s limited power, under § 5 of the Fourteenth Amendment, to remedy
`
`violations of constitutional rights, which is the sole source of Congress’s authority
`
`to abrogate immunity in patent proceedings. Id.
`
`III. CONCLUSION
`The IPR should be dismissed.
`
`Respectfully submitted,
`
`By: /Erik B. Milch/
`Erik B. Milch, Reg. No. 42,887
`Back-up Counsel for Patent Owner
`
`
`
`
`
`DATE: March 9, 2017
`
`COOLEY LLP
`1299 Pennsylvania Ave NW, Suite 700
`Washington, DC 20004
`
`10
`
`
`
`
`
`
`
`Patent Owner’s Reply to Petitioner’s Opposition
`Case No.: IPR2016-00208 - Atty Docket: HARP-001/02US
`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6
`I hereby certify, pursuant to 37 C.F.R. Section 42.6, that a complete copy of:
`
` PATENT OWNER’S REPLY TO PETITIONER’S
`OPPOSITION TO PATENT OWNER’S MOTION TO DISMISS
`
`is being served via electronic mail on the 9th day of March 2017, upon the counsel
`
`of record for the Petitioner as follows:
`
`Brad D. Pedersen
`pedersen@ptslaw.com
`Eric H. Chadwick
`chadwick@ptslaw.com
`Chad W. Wickman
`wickman@ptslaw.com
`Patterson Thuente Pederson, P.A.
`80 South 8th Street, Suite 4800
`Minneapolis, MN 55402
`
`With a courtesy copy to prps@ptslaw.com.
`
`
`DATE: March 9, 2017
`
`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Avenue NW
`Suite 700
`Washington, DC 20004
`
`Tel: (703) 456-8573
`Fax: (202) 842-7899
`
`Respectfully submitted,
`COOLEY LLP
`
`
`
`
`By: /Erik B. Milch/
`Erik B. Milch
`Reg. No. 42,887
`Back-up Counsel for Patent Owner
`
`11
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
