UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`MICROSOFT CORPORATION,
`Petitioner
`
`v.
`
`BRADIUM TECHNOLOGIES LLC,
`Patent Owner
`____________________
`
`CASE IPR2016-00449
`Patent 8,924,506 B2
`____________________
`
`PATENT OWNER BRADIUM TECHNOLOGIES LLC’S
`MOTION FOR OBSERVATIONS ON CROSS-EXAMINATION
`
`
`
`
`
`
`
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`MICROSOFT CORPORATION,
`Petitioner
`
`v.
`
`BRADIUM TECHNOLOGIES LLC,
`Patent Owner
`____________________
`
`CASE IPR2016-00449
`Patent 8,924,506 B2
`____________________
`
`PATENT OWNER BRADIUM TECHNOLOGIES LLC’S
`MOTION FOR OBSERVATIONS ON CROSS-EXAMINATION
`
`
`
`
`
`
`
`
`
`PATENT OWNER’S MOTION FOR OBSERVATIONS ON CROSS-
`EXAMINATION
`
`Pursuant to the Board’s Scheduling Order dated July 27, 2016 (Paper 10)
`
`and the Stipulation to Modify Due Dates 4 (Paper 36), Patent Owner Bradium
`
`Technologies LLC (“Bradium”) respectfully submits this Motion for Observations
`
`on Cross-Examination of Dr. William Michalson, who was deposed on February
`
`21, 2017.
`
`1.
`
`In Exhibit 2078, on page 6, line 12 to page 8, line 1, Dr. Michalson
`
`testifies that the copyright date of Exhibit 1030 is the year 2000. This testimony is
`
`relevant to Dr. Michalson’s assertion in Exhibit 1016 at paragraph 93 (page 62)
`
`that Exhibit 1030 is “a 1999 Microsoft Technical Report describing its
`
`‘TerraServer’ system for viewing geographic images online [that] teaches that
`
`UTM coordinates could simply be converted to a simple X, Y tile address,” and to
`
`Petitioner’s Reply (Paper 34) argument at pages 13–14 based on UTM in reliance
`
`on Dr. Michalson’s assertion. This testimony is relevant because it shows Dr.
`
`Michalson and Petitioner’s argument is based on a non-prior-art reference.
`
`2.
`
`In Exhibit 2078, on page 6, line 12 to page 8, line 1, Dr. Michalson
`
`testifies that the Exhibit 1030 states that it is an article that appeared in the
`
`proceedings of ACM SIGMOD in May 2000. This testimony is relevant to Dr.
`
`Michalson’s assertion in Exhibit 1016 at paragraph 93 (page 62) that Exhibit 1030
`
`is “a 1999 Microsoft Technical Report describing its ‘TerraServer’ system for
`1
`
`
`
`
`
`viewing geographic images online [that] teaches that UTM coordinates could
`
`simply be converted to a simple X, Y tile address,” and to Petitioner’s Reply
`
`(Paper 34) argument at pages 13–14 based on UTM in reliance on Dr. Michalson’s
`
`assertion. This testimony is relevant because it shows Dr. Michalson and
`
`Petitioner’s argument is based on a non-prior-art reference.
`
`3.
`
`In Exhibit 2078, on page 9, line 13 to page 10, line 24, Dr. Michalson
`
`testifies that he did not address reason number 4 offered by the authors of Exhibit
`
`1030 in his direct testimony, which is that the map tile client-server solution
`
`described in Exhibit 1030 “had not been attempted before” and that “many people
`
`felt it was impossible without using an object-oriented or object-relational system.”
`
`This testimony is relevant to Patent Owner’s Response (Paper 20) at page 38. This
`
`testimony is relevant because it shows that the portion of Exhibit 1030 not
`
`addressed by Dr. Michalson is consistent with Patent Owner’s argument that
`
`VRML is essentially a set of objects that that are linked to one another.
`
`4.
`
`In Exhibit 2078, on page 11, line 20 to page 13, line 2, Dr. Michalson
`
`testifies that Exhibit 1030 provides specifically that its user interface is designed to
`
`function adequately over low-speed (28.8 kbps) connections, while Reddy does not
`
`mention a particular speed of the connection to the internet for the PC or laptop
`
`that is disclosed by Reddy at Paragraph 48. This testimony is relevant to Patent
`
`Owner’s response (Paper 20) at Pages 11–12. This testimony is relevant because it
`
`
`
`2
`
`
`
`supports Patent Owner’s argument that the disclosure in Reddy of a “PC connected
`
`to the internet” does not disclose a particular communications channel for the PC.
`
`5.
`
`In Exhibit 2078, on page 18, line 11 to page 20, line 16, Dr.
`
`Michalson testifies that his assertion regarding Exhibit 2066 at Paragraph 39, page
`
`23 at lines 16-18 of his Reply Declaration (Ex. 1016) that “page 1 of Ex. 2066
`
`explains that SRI’s digital earth proposal is to extend TerraVision functionality to
`
`‘commercial, off-the-shelf’ software (id. at 1),” omitted the portion of the sentence
`
`he quotes that states “although perhaps with less functionality.” This testimony is
`
`relevant to Patent Owner’s response (Paper 20) at Page 25. This testimony is
`
`relevant because it shows that Dr. Michalson omitted information that supports
`
`Patent Owner’s argument that a standard VRML browser could not use the
`
`TerraVision II specific optimizations described in Reddy.
`
`6.
`
`In Exhibit 2078, on page 20, line 18 to page 23, line 3, Dr. Michalson
`
`testifies that the portion of Exhibit 2066 that he refers to at Paragraph 39, lines 16-
`
`20 of his Reply Declaration (Ex. 1016) refers to VRML support that is directly
`
`integrated into standard browser software. This testimony is relevant to Patent
`
`Owner’s Response (Paper 20) at Pages 22, 25. This testimony is relevant because
`
`it supports Patent Owner’s argument that the laptop disclosed by Reddy views
`
`VRML data with a standard VRML browser and not with TerraVision II.
`
`7.
`
`In Exhibit 2078, on page 25, line 13 to page 26, line 23, Dr.
`
`
`
`3
`
`
`
`Michalson testifies that Exhibit 2066, with respect to the portion stating “[b]y
`
`employing VRML as the file format . . . we allow for the possibility of users
`
`interacting with it using standard off-the-shelf VRML browser software,” the
`
`authors were saying that “the data structures that were adopted for Digital Earth
`
`and for the system that they’re building, that SRI is calling Digital Earth, it’s –
`
`were being designed such that they would be compatible with browsers that are
`
`capable of interpreting VRML.” This testimony is relevant to Patent Owner’s
`
`Response (Paper 20) at Pages 22, 25. This testimony is relevant because it
`
`supports Patent Owner’s argument that the laptop disclosed by Reddy views
`
`VRML data with a standard VRML browser and not with TerraVision II.
`
`8.
`
`In Exhibit 2078, page 27, line 2 to 22, Dr. Michalson testifies that
`
`Exhibit 2066 refers to the fact that the Digital Earth data structures can be directly
`
`accessed via an internet browser, for example, in the specific case of Windows 98,
`
`“you would be able to just point a – point the browser with the preinstalled VRML
`
`plug-in to a VRML serving website and it would interpret the VRML.” This
`
`testimony is relevant to Patent Owner’s Response (Paper 20) at Pages 22, 25. This
`
`testimony is relevant because it supports Patent Owner’s argument that the laptop
`
`disclosed by Reddy views VRML data with a standard VRML browser and not
`
`with TerraVision II.
`
`9.
`
`In Exhibit 2078, page 29, line 4 to page 31, line 2, Dr. Michalson
`
`
`
`4
`
`
`
`testifies that his Reply Declaration (Exhibit 1016) at Page 24, line 1 to line 5, in
`
`which he states that Exhibit 2066 “clearly states that it is ‘feasible’ that the features
`
`provided by TerraVision ‘could be implemented for a standard VRML browser
`
`through the use of various Java scripts embedded in the scene, or running
`
`externally to the browser,’” omits the text “some of the following” from the cited
`
`portion of Exhibit 2066, which in fact reads: “it is feasible that some of the
`
`following could be implemented for a standard VRML browser through the use of
`
`various Java scripts embedded in the scene, or running externally to the browser.”
`
`This testimony is relevant to Patent Owner’s Response (Paper 20) at Page 25. This
`
`testimony is relevant because it shows that Dr. Michalson omitted the material that
`
`supports Patent Owner’s argument that a standard VRML browser would not have
`
`the functionality of TerraVision II on which Petitioner relies.
`
`10.
`
`In Exhibit 2078, page 29, line 4 to page 31, line 2, Dr. Michalson
`
`testifies that, while he cited and quoted from the second full paragraph of Page 4 of
`
`Exhibit 2066 in his Reply Declaration (Exhibit 1016) at Page 24, line 1 to line 5,
`
`he did not quote the text a couple of lines earlier that states: “However, it is likely
`
`that certain capabilities will not be available in a standard VRML browser, or that
`
`they will be available at a lower performance level.” (Exhibit 2066, Page 4,
`
`Paragraph 2). This testimony is relevant to Patent Owner’s Response (Paper 20) at
`
`Page 25. This testimony is relevant because it shows that Dr. Michalson did not
`
`
`
`5
`
`
`
`address the material that supports Patent Owner’s argument that a standard VRML
`
`browser would not have the functionality of TerraVision II on which Petitioner
`
`relies.
`
`11.
`
`In Exhibit 2078, page 21, line 15 to page 33, line 17, Dr. Michalson
`
`testifies that the portion of Exhibit 2066 that he cites at Paragraph 54 at pages 35-
`
`36 of his Reply Declaration that refers to Windows NT also states that “[i]n the
`
`past, TerraVision has been deployed largely on SGI graphics workstations such as
`
`O2 and Octane.” (Exhibit 2066, Page 2). This testimony is relevant to Patent
`
`Owner’s Response (Paper 20) at Pages 20, 25. This testimony is relevant because
`
`it shows that Dr. Michalson did not address the material that supports Patent
`
`Owner’s argument that the “PC connected to the internet” of Reddy is not a limited
`
`bandwidth communications device.
`
`12.
`
`In Exhibit 2078, page 35, line 13 to line 23, Dr. Michalson testifies
`
`that one of the goals of SRI (authors of Exhibit 2066) is to “manage vast volumes
`
`of data distributed over advanced NGI networks.” This testimony is relevant to
`
`Patent Owner’s Response (Paper 20) at Page 26. This testimony is relevant
`
`because it supports Patent Owner’s argument that Reddy does not teach or suggest
`
`that TerraVision II is viable on a laptop.
`
`13.
`
`In Exhibit 2078, page 42, line 6 to page 43, line 9, Dr. Michalson
`
`testifies:
`
`
`
`6
`
`
`
`Q. I have a very simple question, whether you would agree with me
`that there's a distinction between what software is designed to run on
`versus what the software can possibly operate on.
`
`MR. DAY: Object to form.
`
`A. Not necessarily. I may -- I may design a piece of software on a
`particular platform with the expectation that it will run on other
`platforms. For example, we just finished talking about this Digital
`Earth SRI. That was something that they ran on some particular
`platforms but was clearly designed in such a way that many other
`platforms would have access.
`
`Q. And we looked earlier at the page referring to some specific
`platforms such as –
`
`MR. DAY: Objection.
`
`Q. -- Windows NT and SGI graphics work stations, right?
`
`MR. DAY: Object to form.
`
`A. Those were some specific examples, but for any platforms running
`at least Netscape or Internet Explorer or any other VRML compatible
`browser.
`
`This testimony is relevant to Patent Owner’s Response (Paper 20) at Pages 22, 25.
`
`This testimony is relevant because it shows the distinction between TerraVision II
`
`and a standard VRML browser such as “Netscape or Internet Explorer” that can
`
`“access” data without running the software designed by SRI.
`7
`
`
`
`
`
`14.
`
`In Exhibit 2078, page 44, line 24 to page 45, line 14, Dr. Michalson
`
`testifies that he has not examined the pleadings or complaint in the Bradium v.
`
`Microsoft litigation. This testimony is relevant to Petitioner’s Reply (Paper 34) at
`
`Page 3 and Exhibit 1016 (Michalson Reply Declaration) at Paragraph 30. This
`
`testimony is relevant to show the lack of basis for Petitioner’s claim, based on Dr.
`
`Michalson’s claim, that Bradium’s position in that litigation contradicts its position
`
`in this IPR.
`
`15.
`
`In Exhibit 2078, page 45, line 16 to page 46, line 7, Dr. Michalson
`
`testifies that he is not aware of discovery or depositions in the Bradium v.
`
`Microsoft litigation. This testimony is relevant to Petitioner’s Reply (Paper 34) at
`
`Page 3 and Exhibit 1016 (Michalson Reply Declaration) at Paragraph 30. This
`
`testimony to show the lack of basis for Petitioner’s claim, based on Dr.
`
`Michalson’s claim, that Bradium’s position in that litigation contradicts its position
`
`in this IPR.
`
`16.
`
`In Exhibit 2078, page 46, line 9 to line 20, Dr. Michalson testifies that
`
`he does not know whether the Court has construed claims in the Bradium v.
`
`Microsoft litigation. This testimony is relevant to Petitioner’s Reply (Paper 34) at
`
`Page 3 and Exhibit 1016 (Michalson Reply Declaration) at Paragraph 30. This
`
`testimony is relevant to show the lack of basis for Petitioner’s claim, based on Dr.
`
`Michalson’s claim, that Bradium’s position in that litigation contradicts its position
`
`
`
`8
`
`
`
`in this IPR.
`
`17.
`
`In Exhibit 2078, page 46, line 22 to page 48, line 1, Dr. Michalson
`
`testifies that he is not familiar with the relevant local rules of the Court with
`
`respect to contentions in the Bradium v. Microsoft litigation. This testimony is
`
`relevant to Petitioner’s Reply (Paper 34) at Page 3 and Exhibit 1016 (Michalson
`
`Reply Declaration) at Paragraph 30. This testimony is relevant to show the lack of
`
`basis for Petitioner’s claim, based on Dr. Michalson’s claim, that Bradium’s
`
`position in that litigation contradicts its position in this IPR.
`
`18.
`
`In Exhibit 2078, page 48, line 9 to page 49, line 12, Dr. Michalson
`
`testifies that he has not seen before Bradium’s First Amended Complaint (Ex.
`
`2074) in the Bradium v. Microsoft litigation. This testimony is relevant to
`
`Petitioner’s Reply (Paper 34) at Page 3 and Exhibit 1016 (Michalson Reply
`
`Declaration) at Paragraph 30. This testimony is relevant to show the lack of basis
`
`for Petitioner’s claim, based on Dr. Michalson’s claim, that Bradium’s position in
`
`that litigation contradicts its position in this IPR.
`
`19.
`
`In Exhibit 2078, page 50, line 8 to line 23, Dr. Michalson testifies that
`
`he has not considered and is not prepared to remark on the statement in Bradium’s
`
`First Amended Complaint (Ex. 2074) at Paragraph 73 (page 19) accusing
`
`“Microsoft’s Bing Maps Preview application for Microsoft Windows on a
`
`computer device, such as a smartphone, in combination with Microsoft servers.”
`
`
`
`9
`
`
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`This testimony is relevant to Petitioner’s Reply (Paper 34) at Page 3 and Exhibit
`
`1016 (Michalson Reply Declaration) at Paragraph 30. This testimony is relevant to
`
`show the lack of basis for Petitioner’s claim, based on Dr. Michalson’s claim, that
`
`Bradium’s position in that litigation contradicts its position in this IPR.
`
`20.
`
`In Exhibit 2078, page 53, line 21 to page 55, line 8, Dr. Michalson’s
`
`testimony includes the statement at page 54, lines 8 to 16:
`
`reasonable
`the broadest
`to
`reference
`in
`All communication
`interpretation of the claim language, all channels are fundamentally
`limited. They can be -- and those limitations form the expectations of
`throughput on the channel. What that throughput ends up being is
`going to be a result of the technology of the channel and the load that's
`on that channel.
`
`This testimony is relevant to Patent Owner’s Response (Paper 20) at pages 9–10
`
`and Petitioner’s Reply (Paper 34) at pages 1–2. This testimony is relevant to show
`
`that Patent Owner’s and Petitioner’s claim construction of the term “limited
`
`bandwidth communications channel” is overly broad.
`
`21.
`
`In Exhibit 2078, page 58, line 4 to line 19, Dr. Michalson’s testimony
`
`includes the statement:
`
`Q. Is that an example of a limited bandwidth communications
`channel, under your interpretation of plain and ordinary meaning as
`the term is used in the claims of the '343 and the '506 patents?
`A. Well --
`
`
`
`10
`
`
`
`MR. DAY: Object to form.
`A. -- relative to the broadest reasonable interpretation standard, all
`communications channels are limited. In the case of a 56 kilobit per
`second dial-up modem, that channel would be limited to 56 kilobit --
`kilobits per second. At least -- let me clarify. That user connection
`would be limited to 56 kilobits per second.
`
`This testimony is relevant to Patent Owner’s Response (Paper 20) at pages 9–10
`
`and Petitioner’s Reply (Paper 34) at pages 1–2. This testimony is relevant to show
`
`that Patent Owner’s and Petitioner’s claim construction of the term “limited
`
`bandwidth communications channel” is overly broad.
`
`22.
`
`In Exhibit 2078, page 59, line 17 to page 61, line 3 and page 61, line
`
`24 to page 64, line 15, Dr. Michalson testifies that Exhibit 2076 is Dr. Michalson’s
`
`declaration in Under Armour v. Adidas, IPR2015-00698, and Exhibit 2075 is the
`
`deposition of Dr. Michalson in this IPR. This testimony is relevant to Patent
`
`Owner’s Response (Paper 20) at pages 57–60. This testimony is relevant to
`
`provide a foundation for the testimony of Paragraphs 23 to 26, below
`
`23.
`
`In Exhibit 2078, page 64, line 20 to 66, line 8, Dr. Michalson testifies
`
`that he provided an opinion regarding the commercial success of a mobile
`
`application MapMyFitness (“MMF”), stating that: “[i]n my opinion, the
`
`commercial success of the MMD suite of products is plainly demonstrated by the
`
`number of MMF users and Under Armour’s purchase price of MMF.” This
`
`
`
`11
`
`
`
`testimony is relevant to Patent Owner’s Response (Paper 20) at pages 57–60. This
`
`testimony is relevant because it shows that Dr. Michalson previously opined that
`
`commercial success supported non-obviousness using the same type of information
`
`that Patent Owner relies on in this IPR.
`
`24.
`
`In Exhibit 2078, page 67, line 6 to page 68, line 7, Dr. Michalson
`
`testifies that he offered the following deposition testimony in Under Armour v.
`
`Adidas, IPR2015-00698 at Exhibit 2075, page 8, line 8 to page 9, line 2:
`
`Question: "I understand that you're not talking about that here. Well,
`so you mentioned two things. Again, it's the number of MMF users
`and Under Armour's purchase of MMF would be the two factors that
`you considered. Would there be any other factors that you would want
`information" -- I'm sorry -- "Would there be any other information
`that you would want
`to see
`to assess whether or not
`the
`MapMyFitness suite of products are commercially successful?"
`
`Answer: Line 21, "The Witness: I wasn't asked to consider any other
`factors, and I didn't consider any other factors. You know, if there
`were more factors that were brought to my attention or that I obtained,
`I would consider them, but I did not do that analysis," ending at Page
`9, Line 2.
`
`This testimony is relevant to Patent Owner’s Response (Paper 20) at pages 57–60.
`
`This testimony is relevant because it shows that Dr. Michalson previously opined
`
`that commercial success supported non-obviousness using the same type of
`
`
`
`12
`
`
`
`information that Patent Owner relies on in this IPR.
`
`25.
`
`In Exhibit 2078, page 69, line 5 to line 24, Dr. Michalson testifies that
`
`he offered the following deposition testimony in Under Armour v. Adidas,
`
`IPR2015-00698 at Exhibit 2075 beginning at page 6 line 13:
`
`Question: "Sure. So you mentioned two factors here in Paragraph 76.
`You state the commercial success is demonstrated, A, by the number
`of MMF users; and B, Under Armour's purchase of MapMyFitness.
`And my question is, hypothetically, would the profitability of
`MapMyFitness as a company be a relevant factor to your opinion to
`determining whether its products were a commercial success?"
`
`Answer: Line 23, page 6, "The Witness: In Paragraph 76, I'm not
`referring to the profitability of MapMyFitness. I'm referring to the
`number of users they accumulated and the fact that Under Armour
`purchased the company."
`
`This testimony is relevant to Patent Owner’s Response (Paper 20) at pages 55–57.
`
`This testimony is relevant because it shows that Dr. Michalson previously opined
`
`that commercial success supported non-obviousness using the same type of
`
`information that Patent Owner relies on in this IPR.
`
`26.
`
`In Exhibit 2078, at page 93, line 10 to page 95 line 8, Dr. Michalson
`
`testifies that he offered the opinion that “Running Shoes Guru” listing MMF as
`
`“one of the ten best running apps for Android in 2015” was evidence for his
`
`opinion that industry praise for MMF supported a conclusion of non-obviousness
`
`
`
`13
`
`
`
`in Under Armour v. Adidas, IPR2015-00698. This testimony is relevant to Patent
`
`Owner’s Response (Paper 20) at pages 59–60 and the Levanon Declaration (Ex.
`
`2004) at Paragraph 90. This testimony is relevant because it shows that Dr.
`
`Michalson previously opined that commercial success supported non-obviousness
`
`using the same type of information that Patent Owner relies on in this IPR.
`
`27.
`
`In Exhibit 2078, page 71, lines 4 to 22 and page 73, line 23 to page
`
`74, line 16, Dr. Michalson testifies that the following deposition testimony as
`
`reflected in Exhibit 2077, a deposition transcript of November 9, 2012 in the
`
`matter Visteon Global Technologies v. Garmin International, at page 18, lines 6 to
`
`22, is accurate:
`
`Q. Okay. What is your current salary?
`
`A. My current salary comes from both my consulting company and
`the university. Last year it was, I think, just a little bit shy of
`$600,000.
`
`Q. How much does the university pay you?
`
`It varies depending on what sponsored research I have, but
`A.
`currently it’s around $125,000.
`
`Q. And the rest comes from your consulting?
`
`A.
`
`Correct.
`
`Q. And of your consulting, how much of that portion is related to
`your law – law-related consulting?
`
`A.
`
`I would say probably about 70 or 80 is law-related consulting.
`
`This testimony is relevant to Exhibit 1019 at page 11, line 6 to page 12, line 5.
`
`
`
`14
`
`
`
`This testimony is relevant to show the financial stake of the witness in law-related
`
`consulting.
`
`28.
`
`In Exhibit 2078, at page 72, line 10 to page 73, line 11, Dr. Michalson
`
`testifies that:
`
`What's your current salary?
`
`A. Well, I think this past year --
`
`MR. DAY: Object to form?
`
`A. -- it was around 140,000 from WPI.
`
`BY MR. COULSON:
`
`Q. And you also obtained income from consulting?
`
`A. Yes.
`
`Q. And you also obtained income from legal consulting?
`
`A. Yes.
`
`Q. And what's your consulting income currently, roughly?
`
`A. I haven't calculated it for this year yet, but last year it was, I think,
`approximately 500,000.
`
`Q. And how much of that is legal consulting?
`
`A. Probably the majority of it. I don't know specifically. Probably 80
`or 90 percent. The 500,000 would include, actually, my wife's legal
`practice and my legal consulting. So, just legal consulting is probably
`350-ish.
`
`This testimony is relevant to Exhibit 1019 at page 11, line 6 to page 12, line 5.
`
`This testimony is relevant to show the financial stake of the witness in law-related
`
`consulting.
`
`
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`15
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`Dated: March 22, 2017
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`
`/Chris J. Coulson/
`Chris J. Coulson (Reg. No. 61,771)
`Lead Counsel for Patent Owner
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel.: (212) 425-7200
`Fax: (212) 425-5288
`ccoulson@andrewskurthkenyon.com
`
`Michael Zachary (admitted pro hac vice)
`Clifford Ulrich (Reg. No. 42,194)
`Attorneys for Bradium Technologies LLC
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on March 22,
`
`2017, the foregoing Patent Owner Bradium Technologies LLC’s Motion for
`
`Observations on Cross-Examination were served via electronic mail upon the
`
`following counsel of record for the Petitioner:
`
`Chun Ng (Reg. No. 36,878)
`Matthew Bernstein (pro hac vice)
`Patrick McKeever (Reg. No. 66,019)
`Vinay Sathe (Reg. No. 55,595)
`Evan S. Day (pro hac vice)
`PerkinsServiceBradiumIPR@perkinscoie.com
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`/Chris J. Coulson/
`Chris J. Coulson (Reg. No. 61,771)
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel.: (212) 425-7200
`Fax: (212) 425-5288
`ccoulson@andrewskurthkenyon.com
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