IN THE UNITED STATES
`
` PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
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`- - - - - - - - - - - - - x
`
` APPLE, INCORPORATED,
`
` Petitioner,
`
` v.
`
` PERSONALIZED MEDIA
`
` COMMUNICATIONS, LLC,
`
` Patent Owner.
`
` Case IPR2016-00754
`
` Patent 8,559,635 B1
`
`-and-
`
` Case IPR2016-01520
`
` Patent 8,559,635 B1
`
`- - - - - - - - - - - - -
`
` CONFERENCE CALL
`
` April 26, 2017; 1:00 pm
`
` BEFORE: TRENTON A. WARD
`
` KARL D. EASTHOM
`
` Administrative Patent Judges
`
`Reported By:
`Robin LaFemina
`Job no: 18689
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 1
`
`

`

`Page 2
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` A P P E A R A N C E S:
`
` For Petitioner
`
` KIRKLAND & ELLIS LLP
`
` 300 North LaSalle
`
` Chicago, Illinois 60654
`
` BY: JOEL MERKIN, ESQ.
`
` joel.merkin@kirkland.com
`
`-and-
`
` KIRKLAND & ELLIS LLP
`
` 601 Lexington Avenue
`
` New York, New York 10022
`
` BY: ALAN RABINOWITZ, ESQ.
`
` alan.rabinowitz@kirkland.com
`
` For Patent Owner
`
` PERSONALIZED MEDIA COMMUNICATIONS, LLC
`
` BY: THOMAS J. SCOTT, JR., General Counsel
`
` tscott@pmcip.com
`
`-and-
`
` GOODWIN & PROCTER LLP
`
` 901 New York Avenue, N.W.
`
` Washington, DC 20001
`
` BY: KRUPA PARIKH, ESQ.
`
` kparikh@goodwinlaw.com
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
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`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 2
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`

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` JUDGE WARD: Good afternoon.
`
` This is Judge Ward with the Patent
`
` Trial and Appeal Board, joined by my
`
` colleague Judge Easthom. This is a
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` conference call for Inter Partes Review
`
` Matter Number IPR2016-754, case in
`
` which Apple is the Petitioner and PMC
`
` is the Patent Owner.
`
` Who do we have on the line for
`
` Petitioner?
`
` MR. MERKIN: Good afternoon,
`
` Your Honor, this is Joel Merkin for
`
` Petitioner Apple, and with me is Alan
`
` Rabinowitz.
`
` JUDGE WARD: Thank you, Mr.
`
` Merkin and Mr. Rabinowitz.
`
` Anyone else going to be joining
`
` from Petitioner?
`
` MR. MERKIN: No one else.
`
` JUDGE WARD: Thank you. Great.
`
` And who do we have on the call
`
` for Patent Owner?
`
` MR. SCOTT: We have Thomas J.
`
` Scott, Jr., general counsel of
`
` Personalized Media Communications, and
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 3
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`

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` I have with me Krupa Parikh of the law
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` firm of Goodwin Procter.
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` JUDGE WARD: Okay. Mr. Scott,
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` is it?
`
` MR. SCOTT: Yes, that's correct.
`
` JUDGE WARD: Thank you,
`
` Mr. Scott. And Ms. Parikh, thank you
`
` for joining us.
`
` Is anyone else going to be
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` joining from Patent Owner?
`
` MR. SCOTT: No.
`
` JUDGE WARD: Okay. I understand
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` a court reporter is on the line. Who
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` is it that retained the court reporter?
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` MR. MERKIN: Petitioner Apple
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` has.
`
` JUDGE WARD: Okay. Thank you,
`
` Mr. -- is that Mr. Merkin?
`
` MR. MERKIN: Yes, it is.
`
` JUDGE WARD: Mr. Merkin, if you
`
` could please make sure to file a copy
`
` of that transcript in our record as
`
` soon as it becomes available to you
`
` after the call.
`
` MR. MERKIN: Will do, Your
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 4
`
`

`

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` Honor.
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` JUDGE WARD: Thank you. And
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` also, counsel, please remember when
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` you're speaking today if you could just
`
` announce your name when you begin to
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` speak, that way it will make it easier
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` for the court reporter to keep track.
`
` We scheduled this conference
`
` call today at Mr. Merkin's request, his
`
` request to have a discussion for
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` authorization regarding a motion to
`
` strike Exhibit 2140 in this case or in
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` the alternative for the ability to file
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` a sur-reply to Patent Owner's Motion to
`
` Amend. Mr. Merkin, I'm going to give
`
` you a chance to address those issues
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` and then allow Patent Owner to respond,
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` so Mr. Merkin, you have the floor.
`
` MR. MERKIN: Thank you, Your
`
` Honor. Yes, it's -- Exhibit 2140 is a
`
` new exhibit that Patent Owner filed
`
` with its reply to its Motion to Amend.
`
` It's a 143 page declaration submitted
`
` by an employee at PMC, and again filed
`
` for the first time with the reply.
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 5
`
`

`

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` That declaration purports to identify
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` 112 specification support, of course of
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` which Patent Owner has the burden of
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` proof to show in their original motion,
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` and it attempts to show that 112
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` support via a 100 -- I think it's
`
` 139-page table that's part of this 143
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` page declaration. There was also a
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` declaration by the same individual that
`
` was filed with the Motion to Amend in
`
` the original paper, but for this
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` particular declaration, this exhibit
`
` that we're referring to, 2140, this is
`
` an additional one that's cited just in
`
` the reply. In the reply itself, at the
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` very top of page 5 and this is paper 27,
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` Patent Owner states that additional
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` embodiments also provide support, then
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` it cites to Exhibit 2140 at paragraph 9,
`
` which is the 139 page declaration. So
`
` really Petitioner has two issues. One,
`
` this is improper reply evidence, should
`
` not have been -- to the extent Patent
`
` Owner wanted to rely on this
`
` specification support, they were
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 6
`
`

`

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` required to identify it in their
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` original motion, and also it's, you
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` know, improperly cited, it's incorporated
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` by reference, they're just citing to,
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` you know, 139 pages with a single cite
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` to a paragraph from this exhibit. And
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` so Petitioner would appreciate the
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` opportunity to file a motion to strike,
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` kind of set this out in a paper and
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` specifically identify all the places in
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` this new exhibit that are -- haven't
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` been presented previously in these new
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` embodiments that Patent Owner is
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` relying on, and, like I said in my
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` e-mail, to the extent the Board
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` wouldn't want to see a motion to
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` strike, we would also be open in the
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` alternative to filing a sur-reply to
`
` address the arguments.
`
` JUDGE WARD: Mr. Merkin, can I
`
` ask, I noticed in the record that you
`
` filed objections on April 19, 2017 to
`
` Exhibit 2140 along with some other
`
` exhibits, but you did object to Exhibit
`
` 2140 there. Did you receive a response
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 7
`
`

`

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` from the Patent Owner to those
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` objections?
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` MR. MERKIN: We have not
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` received a response with respect to
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` those objections.
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` JUDGE WARD: Can you indicate as
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` to why a Motion to Exclude as provided
`
` for in our rules would not be sufficient?
`
` MR. MERKIN: So we could file a
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` Motion to Exclude. It was something I
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` was actually going to raise. If that
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` would be the Board's preference, we
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` absolutely would be willing to include
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` this issue in a Motion to Exclude. In
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` my experience, and I've seen some
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` precedent of some panels preferring a
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` motion to strike in this issue, I've
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` also seen it addressed in a Motion to
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` Exclude, and so we would be open to
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` addressing this issue in a Motion to
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` Exclude if that's where the Board thinks
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` it's more appropriately addressed.
`
` JUDGE WARD: And what exactly,
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` just moving to your alternative
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` proposal, the sur-reply, what are the
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 8
`
`

`

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` matters that you wish to respond to in
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` there that you didn't have the
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` opportunity with respect to the reply?
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` I mean, I understand that we have what
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` you're alleging is a new declaration
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` with 2140, but to what extent are
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` there -- what are the issues that would
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` need to be addressed in that sur-reply?
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` MR. MERKIN: So it would be in
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` the new declaration, there is countless
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` number of, you know, new citations and
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` new evidence from additional embodiments
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` that in our view are still, given this
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` new evidence that's identified for the
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` first time in reply, still does not
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` support -- provide 112 support for the
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` amended claims, and so what we would
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` seek to do in the sur-reply would be to
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` really show where this declaration kind
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` of mischaracterizes that there is 112
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` support and show the Board that even
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` with these new pieces of evidence, it
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` still doesn't help a patent owner show
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` support.
`
` JUDGE WARD: Okay. Thank you,
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 9
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`

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` Mr. Merkin. Mr. Scott, I want to give
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` you a chance to respond to this request
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` by Mr. Merkin and specifically I would
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` like to know and have you address to
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` what extent there are differences
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` between Dr. Dorney's declaration,
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` Exhibit 2140, that you filed along with
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` your Motion to Amend in comparison to
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` the Dorney declaration 2140 which you
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` filed along with the reply.
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` MR. SCOTT: All right. The
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` issue here is that in both declarations,
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` and that's one thing that should be
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` clear, the new declaration incorporates
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` everything that was in the original
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` declaration and adds some additional
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` text from the specification that the
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` Patent Owner believes responds to
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` certain criticisms that the Petitioner
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` made for the 112 support initially
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` provided. Now, the point here is that
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` in the specification which as you're
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` aware is fairly lengthy, the various
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` embodiments are divided in terms of
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` examples, and in terms of the claims
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 10
`
`

`

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` 34, 35, 37 and 40, the Patent Owner
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` referred to Example 4 and referred to
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` that as supporting those beginning at
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` page 10 -- excuse me -- at page 11 of
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` the Motion to Amend and cited that
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` entire embodiment as support and then
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` explained in Dr. Dorney's declaration,
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` called out specific portions of that
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` example which provided that support,
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` and with respect to claim 36, we relied
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` upon Example 4 and that was the example
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` in the original declaration, and all
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` that this new declaration does is add
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` further citations from those examples,
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` which are specific examples, not in the
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` entirety, it's not a new embodiment,
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` that's a mischaracterization of what
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` this is, it is the same embodiment, the
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` same two examples, but just other
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` portions of the text that provide
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` support for those particular claims.
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` Now, I would like to point out that one
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` of the points here and this is really a
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` question with respect to the burden of
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` proof that only one limitation that's
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 11
`
`

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` an additional limitation in claim 36 is
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` questioned by the Patent Owner. As to
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` the other elements of support that the
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` Patent Owner -- rather, that the
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` Petitioner is relying on, those are
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` limitations which were in the original
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` claims of the case which are, of
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` course, the question of support is not
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` necessarily addressed in this
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` proceeding. I might further say that
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` Dorney's declaration again was very
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` clear in pointing out exactly where the
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` additional support relied and how it
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` was a part of the entire example, and
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` so there's nothing really new that's
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` been presented here at all. I mean,
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` another point is that -- and we'd
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` certainly be willing even though the
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` time is passed to allow this -- the
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` typical way in which one would address
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` points in a declaration and reply is
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` through taking the deposition of the
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` declarant and then filing observations
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` regarding his testimony, and that is an
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` option that was open to the Petitioner
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`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 12
`
`

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` and which it failed to avail itself of.
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` I don't think that at this point a
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` sur-reply and certainly not a Motion to
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` Strike the entire declaration is
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` appropriate since the Petitioner was on
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` fair notice of exactly which
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` embodiments the Patent Owner was
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` relying on and the fact that they are
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` examples that are self-contained, so
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` it's a complete mischaracterization and
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` very disingenuous to say that an
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` additional embodiment was cited.
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` JUDGE WARD: Let me ask you,
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` with respect to Exhibit 2140, it
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` appears that that is as Petitioner
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` noted a fairly lengthy declaration, and
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` I'm not asking for an exact number
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` here. What would be your estimation as
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` to the new material provided in Exhibit
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` 2140 in comparison to the earlier
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` exhibit by Dr. Dorney, Exhibit 2130?
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` MR. SCOTT: I mean, I think the
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` number of additional pages is less than
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` five.
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` JUDGE WARD: But there have
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 13
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`

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` been -- there is additional text, if
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` you will, that have been added to the
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` declaration of Dorney at 2140 as
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` compared to Exhibit 2130?
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` MR. SCOTT: There is no question
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` about that. It's additional text in
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` the two identified examples and
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` embodiments.
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` JUDGE WARD: Mr. Scott, let me
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` ask you this. Would Patent Owner be
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` opposed to permitting the Petitioner to
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` file the sur-reply to address that
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` subject matter or those additions that
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` have been made in Exhibit 2140?
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` MR. SCOTT: A sur-reply to which
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` we would have no further reply?
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` JUDGE WARD: Yes.
`
` MR. SCOTT: And so any points
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` that were made there would have to be
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` taken up at their end? I think that's
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` still unfair. They have -- since they
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` waived their right to take his
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` deposition and make observations on his
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` declaration, to allow them something
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` that's not contemplated by the rules is
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`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 14
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`

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` not something that we think is
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` appropriate.
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` JUDGE WARD: Okay. Thank you,
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` Mr. Scott. Anything else that you
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` would like to raise with respect to
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` Petitioner's proposal?
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` MR. SCOTT: Not at -- no.
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` JUDGE WARD: Thank you.
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` Mr. Merkin, back to you, I would
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` like you to respond to the question I
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` raised to Mr. Scott about a limited
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` sur-reply. Would that meet the
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` concerns of the Petitioner?
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` MR. MERKIN: Your Honor, we
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` would prefer a Motion to Strike. We
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` believe that this is improper to be
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` filed. We would -- if you allowed us
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` to file a sur-reply, we clearly would
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` do so. We want to address, and the
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` number of things to address, I am
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` looking at a comparison of the first
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` declaration and the second Dorney
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` declaration, this is not just a matter
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` that Patent Owner has added five pages
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` here, it's an extensive redo, there's
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`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 15
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` all sorts of text that has been
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` eliminated in this second Dorney
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` declaration and then additional texts
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` that has been added, so it's well over
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` additional 10 pages. It isn't just the
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` original declaration with 10 pages
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` added. It's not like that at all.
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` It's a Mulligan, it's a redo. Another
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` point that I need to respond to. Patent
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` Owner said that it was disingenuous for
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` me to characterize the new exhibit as
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` additional embodiments, that it is a
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` mischaracterization. I was literally
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` quoting Patent Owner's language at the
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` top of page 5 of their reply where they
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` have called it additional embodiments
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` also provide support. So this is not
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` my characterization. This is Patent
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` Owner's characterization that Exhibit
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` 2140 provides additional embodiments.
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` JUDGE WARD: Okay, thank you,
`
` Mr. Merkin.
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` Mr. Scott, would you like to
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` respond?
`
` MR. SCOTT: It merely says in
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`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 16
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` the declaration that those -- that the
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` examples disclose the functionality
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` that support all the embodiments in the
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` patent and these are just additional
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` examples. I mean, I don't think we
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` need to quibble about the words, but
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` the point is what was identified is a
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` specific embodiment called out in the
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` patent as Example 4 and Example 7.
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` JUDGE WARD: Thank you, Mr. Scott.
`
` Well, we appreciate the discussion from
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` the parties and we will -- we being my
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` colleagues and I will discuss further,
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` we will take your comments under
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` advisement and we will issue an order
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` directing you as to our decision with
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` respect to Petitioner's request.
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` So that concludes our discussion
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` of IPR2016-754.
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` I have an additional matter that
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` I'd like to address on this conference
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` call today if that is possible and that
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` is with respect to a request that was
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` made in the related case, IPR2016-1520,
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` and, Mr. Scott, an initial question for
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`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 17
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`

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`Page 18
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` you, we received a request from one of
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` your colleagues, Ms. Fink, for a
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` conference call to discuss the Patent
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` Owner's plan and contingent Motion to
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` Amend in the related case, the 1520
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` case. Are you amenable to discussing
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` that case on today's call?
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` MR. SCOTT: Absolutely.
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` JUDGE WARD: Okay.
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` And, Mr. Merkin, are you
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` amenable to the same?
`
` MR. MERKIN: I am, Your Honor.
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` JUDGE WARD: Okay. Mr. Scott,
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` let me preface the discussion by saying
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` that you as the Patent Owner are
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` entitled as a matter of right to file a
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` Motion to Amend under 35 USC 316d, but
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` our rule is to instruct that you are to
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` confer with the Board before filing
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` such a Motion to Amend and we
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` appreciate your request to do so.
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` Typically the purpose of such a
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` conference is to give the Patent Owner
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` and the parties generally guidance with
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` respect to our Motion to Amend
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`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 18
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` procedures and the nuances there.
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` Given that the Patent Owner has a lot
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` of experience with such Motions to
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` Amend in previous related cases, I will
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` save you my guidance discussion because
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` I know that you've heard it before,
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` but, Mr. Scott, I'll open the floor to
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` you if there's anything additional that
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` you would like to raise or discuss with
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` respect to your proposed Motion to
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` Amend in the 1520 case, you can raise
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` it now.
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` MR. SCOTT: I would -- we would
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` simply request that the Board confirm
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` the fact that we are filing a Motion to
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` Amend. I don't think there's anything
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` else to say.
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` JUDGE WARD: Thank you, Mr. Scott.
`
` Yes. Nothing else to say there. As I
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` mentioned, you are entitled to file
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` that motion as a matter of right and
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` our rules do state that you confer with
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` us before doing so, and you can
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` consider this conference as completing
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` that requirement under Rule 42.121.
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`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 19
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`

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`Page 20
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` Any comments from the Petitioner,
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` Mr. Merkin?
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` MR. MERKIN: No comments from
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` Petitioner, Your Honor.
`
` JUDGE WARD: Okay. Thank you to
`
` both parties for your ability to handle
`
` that additional matter today. I'm
`
` going to place you on mute and confer
`
` with my counsel and we'll be back on
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` the line momentarily, or my colleague.
`
` (Time noted: 1:20:01 p.m.)
`
` (Whereupon, Judge Ward and Judge
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` Easthom conferred.)
`
` (Time resumed: 1:20:32 p.m.)
`
` JUDGE WARD: Counsel, Judge Ward
`
` back on the line, and we are concluded,
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` as I mentioned. We will take your
`
` comments with respect to the 754 case
`
` under advisement and issue an order in
`
` that matter. Thank you very much.
`
` MR. MERKIN: Thank you.
`
` MR. SCOTT: Thank you.
`
` (Time noted: 1:20 p.m.)
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`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 20
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`

`

` C E R T I F I C A T I O N
`
`Page 21
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` I, ROBIN LaFEMINA, a Registered
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` Professional Reporter, Certified
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` LiveNote Reporter and Notary Public,
`
` within and for the State of New York,
`
` do hereby certify that the above
`
` transcript is a true and accurate copy
`
` of the minutes taken by myself
`
` stenographically at the aforementioned
`
` arbitration held on April 26, 2017.
`
` ROBIN LaFEMINA
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`212-400-8845 - Depo@TransPerfect.com
`
`APPLE EXHIBIT 1056
`APPLE v. PMC
`IPR2016-00754
`Page 21
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`

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`Page 22
`
`A
`ability 5:13 20:6
`absolutely 8:13
`18:8
`accurate 21:8
`add 11:13
`added 14:2 15:24
`16:4,7
`additional 6:14,17
`9:12 10:16 12:1
`12:13 13:12,23
`14:1,6 16:3,5,12
`16:16,20 17:4,20
`19:8 20:7
`additions 14:13
`address 5:16 7:19
`10:4 12:20 14:12
`15:19,20 17:21
`addressed 8:18,22
`9:8 12:9
`addressing 8:20
`adds 10:16
`Administrative
`1:22
`advisement 17:15
`20:19
`aforementioned
`21:10
`afternoon 3:1,11
`Alan 2:13 3:13
`alan.rabinowitz...
`2:14
`alleging 9:5
`allow 5:17 12:19
`14:24
`allowed 15:17
`alternative 5:13
`7:18 8:24
`amenable 18:6,11
`Amend 5:15,22
`6:10 10:8 11:5
`18:5,17,20,25
`19:4,11,16
`amended 9:17
`announce 5:5
`Appeal 1:3 3:3
`
`appears 13:15
`Apple 1:5 3:7,13
`4:15
`appreciate 7:7
`17:11 18:21
`appropriate 13:5
`15:2
`appropriately 8:22
`April 1:19 7:22
`21:11
`arbitration 21:11
`arguments 7:19
`asking 13:17
`attempts 6:5
`authorization 5:11
`avail 13:1
`available 4:23
`Avenue 2:11,22
`aware 10:23
`
`B
`back 15:9 20:9,16
`beginning 11:3
`believe 15:16
`believes 10:18
`Board 1:3 3:3 7:15
`8:21 9:21 18:19
`19:14
`Board's 8:12
`burden 6:3 11:24
`B1 1:13,16
`
`C
`C 2:1 21:1,1
`call 1:18 3:5,21
`4:24 5:9 17:22
`18:3,7
`called 11:8 16:16
`17:8
`case 1:12,15 3:6
`5:12 12:7 17:24
`18:5,6,7 19:11
`20:18
`cases 19:4
`certain 10:19
`certainly 12:18
`13:3
`
`Certified 21:4
`certify 21:7
`chance 5:16 10:2
`characterization
`16:18,19
`characterize 16:11
`Chicago 2:6
`citations 9:11 11:14
`cite 7:5
`cited 6:14 7:3 11:5
`13:12
`cites 6:19
`citing 7:4
`claim 11:10 12:1
`claims 9:17 10:25
`11:21 12:7
`clear 10:14 12:12
`clearly 15:18
`colleague 3:4 20:10
`colleagues 17:13
`18:2
`comments 17:14
`20:1,3,18
`Communications
`1:9 2:17 3:25
`compared 14:4
`comparison 10:8
`13:20 15:21
`complete 13:10
`completing 19:24
`concerns 15:13
`concluded 20:16
`concludes 17:18
`confer 18:19 19:22
`20:8
`conference 1:18 3:5
`5:8 17:21 18:3,23
`19:24
`conferred 20:13
`confirm 19:14
`consider 19:24
`contemplated
`14:25
`contingent 18:4
`copy 4:21 21:8
`correct 4:5
`counsel 2:18 3:24
`
`5:3 20:9,15
`countless 9:10
`course 6:2 12:8
`court 4:13,14 5:7
`criticisms 10:19
`
`D
`
`D 1:21
`DC 2:23
`decision 17:16
`declarant 12:23
`declaration 5:23
`6:1,8,9,12,20 9:5
`9:10,19 10:6,9,14
`10:16 11:7,12,13
`12:11,21 13:4,16
`14:3,24 15:22,23
`16:3,6 17:1
`declarations 10:12
`deposition 12:22
`14:23
`differences 10:5
`directing 17:16
`disclose 17:2
`discuss 17:13 18:3
`19:9
`discussing 18:6
`discussion 5:10
`17:11,18 18:14
`19:5
`disingenuous 13:11
`16:10
`divided 10:24
`doing 19:23
`Dorney 10:9 13:21
`14:3 15:22 16:2
`Dorney's 10:6 11:7
`12:11
`Dr 10:6 11:7 13:21
`
`E
`E