IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MYLAN PHARMACEUTICALS INC.
`Petitioner,
`
`v.
`
`RESEARCH CORPORATION TECHNOLOGIES, INC.,
`Patent Owner.
`
`Case No. IPR2016-01248
`Patent No. RE 38,551
`
`
`
`
`
`
`
`
`
`
`
`
`
`PATENT OWNER ABBREVIATED PRELIMINARY RESPONSE AND
`OPPOSITION TO PETITIONER’S MOTION FOR JOINDER
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MYLAN PHARMACEUTICALS INC.
`Petitioner,
`
`v.
`
`RESEARCH CORPORATION TECHNOLOGIES, INC.,
`Patent Owner.
`
`Case No. IPR2016-01248
`Patent No. RE 38,551
`
`
`
`
`
`
`
`
`
`
`
`
`
`PATENT OWNER ABBREVIATED PRELIMINARY RESPONSE AND
`OPPOSITION TO PETITIONER’S MOTION FOR JOINDER
`
`
`
`
`
`
`Patent No. RE 38,551
`
`
`
`Case No. IPR2016-01248
`
`
`
`Patent Owner Research Corporation Technologies, Inc. (“Patent Owner”)
`
`provides the following abbreviated preliminary response to the petition filed by
`
`Mylan Pharmaceuticals Inc. (“Petitioner” or “Mylan”) on June 23, 2016, and
`
`opposition to Mylan’s accompanying motion requesting joinder to Grounds 1A,
`
`1B, 3A and 3B of IPR2016-00204 (“the Argentum proceeding”).
`
`The Federal Circuit’s decision in Magnum Oil—issued after the decision to
`
`institute the Argentum proceeding—coupled with the also recent Federal Circuit
`
`Intelligent Bio-Systems decision, make clear that a petitioner must present its
`
`evidence in its petition, and that the failures of a petition cannot be cured through a
`
`reply paper. Here, Mylan’s Petition is a “substantial copy” of the Argentum
`
`petition, and in any event, Mylan, if joined, would be limited to the evidence and
`
`arguments presented in the Argentum petition. See Sections I and V, infra. This
`
`evidence fails to show the unpatentability of any claim of the ’551 patent. Because
`
`such deficiencies cannot be cured, the Board should deny Mylan’s Petition and
`
`accompanying Motion for Joinder. See 35 U.S.C. § 315(c).
`
`1
`
`
`
`Patent No. RE 38,551
`
`
`
`Case No. IPR2016-01248
`
`
`
`I.
`
`The Petition Should Be Denied as to Grounds 1A, 1B, 2A, 2B, 4A, and
`4B
`
`Patent Owner hereby
`
`incorporates by reference1
`
`its Patent Owner
`
`Preliminary Response in IPR2016-00204, which addressed the failure of the
`
`petition in that proceeding to establish a reasonable likelihood that any claim of the
`
`’551 patent is unpatentable, under any of the enumerated Grounds. See IPR2016-
`
`00204, Paper 9. In a decision instituting inter partes review as to Grounds 3A and
`
`3B, the Board found that Argentum’s petition had not established a reasonable
`
`likelihood that any claim of the ’551 patent was unpatentable under Grounds 1A,
`
`1B, 2A, 2B, 4A or 4B. See IPR2016-00204, Paper 19 at 22–23. Mylan’s Petition is
`
`a “substantial copy” of Argentum’s petition in IPR2016-00204 (see Pet. (Paper 2)
`
`at 1), which the Board has already found deficient as to Grounds 1A, 1B, 2A, 2B,
`
`
`1 As explained in the Board’s August 11, 2016 Order (Paper 6), the Board has
`
`authorized Patent Owner to incorporate by reference arguments and information in
`
`its Patent Owner Preliminary Response and in the Board’s Decision on Institution
`
`from the Argentum proceeding (i.e., Papers 9 and 19 in IPR2016-00204). See
`
`Paper 6 at 4; Ex. 2001 at 33:9–15.
`
`2
`
`
`
`Patent No. RE 38,551
`
`
`
`Case No. IPR2016-01248
`
`
`
`4A and 4B (see IPR2016-00204, Paper 19 at 8–12, 22–23; Paper 3 at 1).2 For the
`
`same reasons why the Board denied Argentum’s petition as to Grounds 1A, 1B,
`
`2A, 2B, 4A and 4B, Mylan’s Petition should be denied here as to those same
`
`grounds. See IPR2016-00204, Paper 19 at 8–12, 22–23. In addition, Petitioner has
`
`agreed that, pending the outcome of Argentum’s Request for Rehearing (IPR2016-
`
`00204, Papers 21 and 28), its Petition is limited to only the grounds already
`
`instituted in the Argentum proceeding. See Ex. 2001 at 8:6–9:18. As the Board has
`
`now denied Argentum’s Request for Rehearing (see IPR2016-00204, Paper 38 at
`
`6), Mylan’s Petition should be denied as to grounds 1A and 1B as well.
`
`II. The Petition Fails to Establish a Reasonable Likelihood that the Claims
`Are Unpatentable Under Grounds 3A or 3B
`A.
`
`Intervening Case Law Clarifies Petitioner’s Burden to
`Present Evidence of Unpatentability in Its Petition
`
`Subsequent to the Board’s May 23, 2016 decision to institute the Argentum
`
`proceeding, the Federal Circuit clarified that “it is inappropriate to shift the burden
`
`to the patentee after institution to prove that the patent is patentable,” and that “the
`
`petitioner continues to bear the burden of proving unpatentability after institution.”
`
`
`2 In any event, if Mylan—an otherwise time-barred party (Ex. 2001, 7:18–8:5)—is
`
`joined to the Argentum proceeding, Mylan will be limited to the evidence and
`
`arguments in the Argentum petition. See Section V, infra.
`
`3
`
`
`
`Patent No. RE 38,551
`
`
`
`Case No. IPR2016-01248
`
`
`
`In Re: Magnum Oil Tools Int’l, Ltd., __ F.3d __, 2016 WL 3974202, at *7 (Fed.
`
`Cir. 2016). Prior to Magnum Oil, it was unclear whether the burden of production
`
`may shift to the patent owner post-institution, to come forward with evidence of
`
`patentability. See Dynamic Drinkware, LLC v. Nat’l Graphics, Inc., 800 F.3d 1375,
`
`1379 (Fed. Cir. 2015) (noting that the burden of production may shift from the
`
`patent challenger to the patentee, in the context of establishing conception and
`
`reduction to practice). Magnum Oil resolved this question, rejecting the notion
`
`“that the burden of production shifts to the patentee upon the Board’s conclusion in
`
`an institution decision that ‘there is a reasonable likelihood that the petitioner
`
`would prevail.’” Magnum Oil, 2016 WL 3974202, at *6. Thus, both the burdens of
`
`persuasion and production to show unpatentability remain with the petitioner and
`
`do not shift to the patent owner at any time. See id. at *6–*8.
`
`This un-shifting burden of proof—a burden that remains with the petitioner
`
`throughout the proceeding—is particularly significant in light of additional recent
`
`Federal Circuit law, holding that “the expedited nature of IPRs bring[s] with it an
`
`obligation for petitioners to make their case in their petition to institute,” which
`
`must “identify ‘with particularity’ the ‘evidence that supports the grounds for the
`
`challenge to each claim.’” Intelligent Bio-Systems, Inc. v. Illumina Cambridge Ltd.,
`
`821 F.3d 1359, 1369 (Fed. Cir. 2016) (emphases added); see also id. at 1369–70
`
`(concluding petitioner’s reply brief and accompanying declaration were improper
`
`4
`
`
`
`Patent No. RE 38,551
`
`
`
`Case No. IPR2016-01248
`
`
`
`under 37 C.F.R. § 42.23(b) because petitioner “relied on an entirely new rationale”
`
`in its reply to explain motivation to combine). Thus, because a petitioner must both
`
`provide its evidence and make its case in its petition,3 and because the burdens of
`
`production and persuasion never shift to the patent owner, a petitioner’s failure to
`
`include key evidence in its petition is irremediable and cannot be cured through a
`
`reply paper.
`
`For example, as explained further below, the prior art on which Petitioner
`
`relies in Grounds 3A and 3B fails to disclose a “therapeutic composition” as
`
`construed by the Board, and as required by claim 10 of the ’551 patent. Because
`
`the burden of production never shifts from the Petitioner, as the Federal Circuit has
`
`now made clear (Magnum Oil, 2016 WL 3974202, at *6–*8), and because
`
`
`3 The Federal Circuit’s decision in Genzyme is not to the contrary. While the
`
`Federal Circuit in Genzyme observed that “the introduction of new evidence in the
`
`course of the trial is to be expected in inter partes review trial proceedings,” the
`
`“new evidence” cited in the reply in Genzyme had been cited in the petition and
`
`was already part of the record. See Genzyme Therapeutic Products Ltd.
`
`Partnership v. Biomarin Pharm. Inc., __ F.3d __ (Fed. Cir. 2016), 2016 WL
`
`3254734, at *5. In addition, the Board did not rely on that evidence to establish any
`
`claim limitations, or to fill in any gaps in the petition. See id. at *6.
`
`5
`
`
`
`Patent No. RE 38,551
`
`
`
`Case No. IPR2016-01248
`
`
`
`Petitioner cannot cure its failure of proof in its Reply (Intelligent Bio-Systems, 821
`
`F.3d at 1369), it is clear at this stage that Petitioner has not—and cannot—meet its
`
`burden of proving unpatentability of the claims.
`
`B.
`
`Petitioner Fails to Present Evidence Showing that the
`Claims Are Unpatentable
`
`Petitioner fails to present evidence to meet its burden of showing
`
`unpatentability of claims 1–9 over Kohn 1991 and Silverman. In the first instance,
`
`Petitioner fails to provide evidence showing that a POSA4 would have selected any
`
`functionalized amino acid (“FAA”) as a lead compound, much less selected
`
`Compound 3l in Kohn 1991 over other FAAs, including similarly potent FAAs,5
`
`given Compound 3l’s “synthetic and stability issues.” See Pet. at 46–47; IPR2016-
`
`00204, Paper 9 at 27–31 (discussing lead compound selection), 46 (discussing the
`
`problems with Compound 3l). Petitioner further fails to provide evidence showing
`
`that a POSA would have been motivated to modify Compound 3l in the way
`
`Petitioner suggests, given that a POSA would have known that similar
`
`
`4 Patent Owner incorporates by reference its description of the level of ordinary
`
`skill in the art from its Preliminary Response in the Argentum proceeding. See
`
`IPR2016-00204, Paper 9 at 9. However, regardless of the definition, the
`
`conclusions regarding insufficient evidence remain the same.
`
`5 See, e.g., Compound 3n in Kohn 1991 (Ex. 1012), Table 1.
`
`6
`
`
`
`Patent No. RE 38,551
`
`
`
`Case No. IPR2016-01248
`
`
`
`modifications in FAAs resulted in a reduction in activity; Petitioner similarly fails
`
`to provide evidence to show that a POSA would have had a reasonable expectation
`
`of success in making such modification. See Pet. at 47–48; IPR2016-00204, Paper
`
`9 at 47–49. Petitioner cannot cure any of these failures in its reply paper. Thus
`
`Petitioner has not—and cannot—meet its burden with respect to claims 1–9.6
`
`With respect to claim 10, the only basis appearing for Petitioner’s Ground
`
`3B assertion that claim 10 is obvious over Kohn 1991, Silverman, and the ’729
`
`
`6 Importantly, a recent judicial opinion confirmed the non-obviousness of
`
`lacosamide (the compound of claim 8) over Kohn 1991 Compound 3l. See UCB,
`
`Inc. et al. v. Accord Healthcare, Inc. et al., 1:13-cv-01206-LPS, Dkt. 313 (D. Del.)
`
`(Ex. 2003). The district court found that (1) “a POSA would not have selected any
`
`FAA as a lead compound,” and (2) “[e]ven if, contrary to the evidence, a POSA
`
`would have selected a nonaromatic FAA as a lead compound, such a person would
`
`not have selected compound 3l.” Id. at 84–88 (emphasis in original). The Court
`
`also found that (3) a POSA would not “have been motivated to change the
`
`NHOC[H]3 of compound 3l to the CH2OCH3 of lacosamide,” and (4) “a POSA
`
`would not have had a reasonable expectation of success from substituting an amine
`
`for a methylene in compound 3l.” Id. at 88–89; see Pet. at 46–48 (discussing
`
`modifying the NHOCH3 of compound 3l to the CH2OCH3 of lacosamide).
`
`7
`
`
`
`Patent No. RE 38,551
`
`
`
`Case No. IPR2016-01248
`
`
`
`patent, is the “rationales and prior art disclosures discussed in Ground 1B,” where
`
`Ground 1B concerns patentability over the LeGall Thesis together with the ’729
`
`patent. See Pet. at 50. Petitioner’s Ground 1B arguments are therefore directed to a
`
`different reference that is not at issue here.7 In any event, Petitioner fails to show
`
`that claim 10—which claims a “therapeutic composition”—is unpatentable.
`
`Critically, Petitioner fails to show any disclosure of a “therapeutic
`
`composition” in the ’729 patent or in any other prior art reference. In the Argentum
`
`proceeding, the Board found “therapeutic composition” to be a limitation of claim
`
`10 and construed this term as a composition “suitable for use as a treatment
`
`regimen over an extended period of time (chronic administration).” IPR2016-
`
`00204, Paper 19 at 7–8. This construction is also the construction adopted by the
`
`district court in the consolidated Delaware litigation, in which Petitioner was a
`
`
`7 The Argentum petition failed to establish that the LeGall Thesis is a printed
`
`publication. See IPR2016-00204, Paper 19 at 8–12. Because the Petition here is a
`
`“substantial copy” of Argentum’s petition in IPR2016-00204 (see Pet. at 1), and
`
`because, in any event, Petitioner is limited to solely those arguments and evidence
`
`in the Argentum petition (see Sections IV and V, infra), Petitioner likewise fails to
`
`meet its burden to establish that the LeGall Thesis is a printed publication.
`
`8
`
`
`
`Patent No. RE 38,551
`
`
`
`Case No. IPR2016-01248
`
`
`
`named defendant. UCB, Inc., et al. v. Accord Healthcare, Inc., et al., No. 13-1206
`
`(LPS), Dkt. 240 (D. Del.).
`
`Petitioner was fully aware of the consistent construction of this claim term
`
`by both the Board and the district court when it filed its Petition. Indeed, in its
`
`Petition, Petitioner repeatedly refers to the district court’s construction and argues
`
`against it. See Pet. at 10–12; see also Ex. 1007 (Petitioner’s exhibit providing the
`
`district court’s claim construction order). Nonetheless, Petitioner fails to provide
`
`any evidence that Kohn 1991, Silverman, and the ’729 patent teach or suggest a
`
`“therapeutic composition” as construed. Petitioner fails to provide any evidence
`
`because no such evidence existed in the prior art.
`
`
`
`Petitioner’s allegation that “Claim 10 is obvious because a POSA knew to
`
`use an effective amount of the active agent and also to use a pharmaceutical
`
`carrier” (Pet. at 32 (Ground 1B)) is insufficient and beside the point—nowhere
`
`does the Petition explain how the combination of Kohn 1991, Silverman, and the
`
`’729 patent meet the therapeutic composition limitation of claim 10 as construed.
`
`Petitioner fails to address this key limitation of claim 10—which requires that the
`
`composition be “suitable for use as a treatment regimen over an extended period of
`
`time (chronic administration)”—and thus its patentability challenge should be
`
`rejected.
`
`9
`
`
`
`Patent No. RE 38,551
`
`
`
`Case No. IPR2016-01248
`
`
`
`
`
`Petitioner’s patentability challenge should be rejected for the separate reason
`
`that Petitioner has not shown that a POSA would have reasonably expected to
`
`achieve a therapeutic composition—i.e., a composition “suitable for use as a
`
`treatment regimen over an extended period of time (chronic administration)”—of
`
`any of the compounds of claims 1–9, or of any FAA. A finding of obviousness
`
`requires “not only the existence of a motivation to combine elements from
`
`different prior art references, but also that a skilled artisan would have perceived a
`
`reasonable expectation of success in making the invention via that combination.”
`
`Medichem, S.A. v. Rolabo, S.L., 437 F.3d 1157, 1165 (Fed. Cir. 2006) (emphasis
`
`added). No liver toxicity data, which would indicate to a POSA whether a
`
`composition is suitable for chronic administration, appeared in the prior art for any
`
`FAA, let alone any of the compounds of claims 1–9. See Ex. 2002, 178:4–9.8 Thus,
`
`a POSA would not have had any data on which to base an expectation regarding
`
`suitability for chronic administration as to FAAs generally, or the compounds of
`
`claims 1–9 specifically. Indeed, liver toxicity data for lacosamide (the compound
`
`of claim 8, also known as (R)-N-benzyl-2-acetamido-3-methoxypropionamide, and
`
`referred to in the ’551 patent as “BAMP” (see Ex. 1001, 24:56–58)) was disclosed
`
`
`8 See IPR2016-00204, Paper 9 at 2–3 n.2.
`
`10
`
`
`
`Patent No. RE 38,551
`
`
`
`Case No. IPR2016-01248
`
`
`
`for the first time in the ’551 patent.9 See Ex. 1001, 25:44–29:36; Ex. 2002, 178:4–9
`
`(Dr. Heathcock’s testimony that no liver toxicity data for any FAA was disclosed
`
`in any prior art to the ’551 patent).
`
`
`
`In sum, Petitioner has failed to provide any evidence whatsoever in its
`
`Petition of a “therapeutic composition”—which is required by claim 10—in the
`
`prior art. In addition, as explained in the Patent Owner Preliminary Response (see,
`
`e.g., IPR2016-00204, Paper 9 at 46–50), Petitioner has also failed to provide any
`
`evidence that a POSA would have reasonably expected to achieve the compounds
`
`of claims 1–9, much less a “therapeutic composition” of any of these compounds.
`
`Petitioner has likewise failed to provide any evidence that a POSA would have
`
`reasonably expected to achieve a method of treating using these compounds, as
`
`recited in claims 11–13. Each of these failures shows that Petitioner has not met its
`
`initial burden to show a reasonable likelihood of unpatentability of the claims of
`
`the ’551 patent, and that Petitioner cannot meet its ultimate burden to show
`
`
`9 With respect to “therapeutic composition,” the district court (see note 6, supra)
`
`noted that its construction of this claim term—the same construction adopted by
`
`the Board in the Argentum proceeding—“presupposes that the compound will not
`
`result in liver toxicity.” Ex. 2003 at 64 n.19. “A medicine is not suitable for
`
`chronic administration if it will be toxic to the liver.” Id.
`
`11
`
`
`
`Patent No. RE 38,551
`
`
`
`Case No. IPR2016-01248
`
`
`
`unpatentability by a preponderance of the evidence. See Intelligent Bio-Systems,
`
`821 F.3d at 1369–70 (new theory of invalidity supported by new evidence not
`
`present in the petition cannot be presented for the first time in reply). Accordingly,
`
`the Board should deny the present Petition.
`
`III. Petitioner’s Motion for Joinder Should Be Denied
`Joinder requires, “as an initial matter, a determination that the petition
`
`accompanying the joinder motion warrants institution of review.” Lupin Ltd., et al.
`
`v. Senju Pharmaceutical Co., Ltd., IPR2015-01871, Paper 13 at 2 (P.T.A.B. Jan.
`
`25, 2016) (discussing 35 U.S.C. § 315(c)). The decision whether to grant joinder is
`
`discretionary. 35 U.S.C. § 315(c); 37 C.F.R. § 42.122. “The Board will determine
`
`whether to grant joinder on a case-by-case basis, taking into account the particular
`
`facts of each case, substantive and procedural issues, and other considerations.”
`
`Macronix Int’l Co., Ltd. v. Spansion LLC, IPR2014-00898, Paper 15 at 3 (P.T.A.B.
`
`Aug. 13, 2014). Here, because Petitioner has failed to establish in its Petition a
`
`reasonable likelihood that the claims are unpatentable, joinder is improper, and
`
`Petitioner’s motion to join the Argentum proceeding should be denied.
`
`IV. Petitioner’s Motion for Joinder as to Grounds 1A and 1B Falls with the
`Board’s Denial of Argentum’s Request for Rehearing
`
`Petitioner’s Motion for Joinder with respect to Grounds 1A and 1B is keyed
`
`to the now-denied Request for Rehearing in the Argentum proceeding. See Paper 3
`
`12
`
`
`
`Patent No. RE 38,551
`
`
`
`Case No. IPR2016-01248
`
`
`
`at 1–2; Ex. 2001 at 8:6–9:18; IPR2016-00204, Paper 38 at 6 (denying Argentum’s
`
`Request for Rehearing). Because Grounds 1A and 1B have not and will not be
`
`instituted in the Argentum proceeding, Mylan’s motion to join the Argentum
`
`proceeding with respect to these grounds should be denied, and any evidence or
`
`testimony concerning Grounds 1A and 1B presented in Mylan’s Petition or Motion
`
`for Joinder should be disregarded.
`
`V.
`
`If the Board Grants Petitioner’s Motion for Joinder, Petitioner Is
`Limited to an Understudy Role, and Its Evidence Is Limited to the
`Evidence in the Argentum Petition
`
` If the Board grants Petitioner’s motion to join the Argentum proceeding,
`
`Petitioner is limited to an “understudy” role, and is limited to the evidence and
`
`arguments presented in the Argentum petition. See Paper 6 at 2; Ex. 2001 at 10:4–
`
`11:11 (Petitioner agreeing to take an understudy role, such that it would not take its
`
`own depositions, be filing papers separate from Argentum, or making arguments
`
`separate from Argentum), 15:6–16:13 (Petitioner agreeing to be “a true me-too”
`
`petitioner), 17:16–18:7 (Board explaining that the joined petitioners, including
`
`Petitioner Mylan, “will be relying on all evidence and arguments that were made in
`
`[the Argentum] petition”). Petitioner may not seek “(a) additional briefing or
`
`pages, (b) to submit new evidence, such as declaration testimony, (c) additional
`
`time for cross-examination of witness or time during an oral hearing, or (d) to alter
`
`the trial schedule” set out in the scheduling order or otherwise agreed to during
`
`13
`
`
`
`Patent No. RE 38,551
`
`
`
`Case No. IPR2016-01248
`
`
`
`trial in the Argentum proceeding. Paper 6 at 2. In other words, Petitioner is limited
`
`to the arguments and evidence that were presented in the Argentum petition, and
`
`may not rely on any additional evidence or expert testimony, including any such
`
`additional evidence or testimony presented in its Petition or Motion for Joinder.
`
`Paper 6 at 3 (“[T]he later Petitioners, including Petitioner Mylan, agreed to assert
`
`arguments and evidence of record in IPR2016-00204 only, and not [to] rely on any
`
`additional evidence raised in Petitions or Motions for Joinder filed by the later
`
`Petitioners.”); Ex. 2001 at 15:6–16:13, 17:16–18:7.
`
`VI. Conclusion
`For the reasons discussed above, Federal Circuit case law now makes clear
`
`that the Petition’s deficiencies cannot be cured by a reply paper. Because Petitioner
`
`Mylan’s Petition fails to provide evidence showing the unpatentability of any claim
`
`of the ’551 patent, and because such deficiencies cannot be cured, Mylan’s Petition
`
`and its accompanying Motion for Joinder should be denied. However, should the
`
`Board grant Petitioner Mylan’s Motion for Joinder, the parties and the Board have
`
`agreed that Petitioner will be limited to an understudy role, and to only the
`
`evidence and arguments presented in the Argentum petition.
`
`
`
`14
`
`
`
`Patent No. RE 38,551
`
`Case No. IPR2016-01248
`
`Date: August 19, 2016
`
`Respectfully submitted,
`
`B %A rea
`
`.Reister
`
`Registration No. 36,253
`Jennifer L. Robbins
`
`Registration No. 61,163
`COVINGTON & BURLING LLP
`
`One CityCenter, 850 Tenth Street, NW
`Washington, DC 20001
`(202) 662-6000
`Attorneys for Patent Owner
`
`15
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6, I hereby certify that on this 19th day of August
`
`2016,
`
`the foregoing Patent Owner Abbreviated Preliminary Response and
`
`Opposition to Petitioner’s Motion for Joinder was served by electronic mail, by
`
`agreement of the parties, on the following counsel of record for Petitioner.
`
`Steven W. Parmelee (sparme1ee@wsgr.com)
`Michael T. Rosato (rnrosato@wsgr.com)
`Jad A. Mills (jmi1ls@wsgr.co1n)
`Wilson Sonsini Goodrich & Rosati
`
`701 Fifth Avenue, Suite 5100
`
`Seattle, WA 98104-7036
`
`Date: August 19, 2016
`
`
`
`
`en fer L. Robbins, Esq.
`Registration No.: 61,163
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
