Case IPR2016-01262
`Patent 7,764,777
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`
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`Paper No. 43
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`BRIGHT HOUSE NETWORKS, LLC
`WIDEOPENWEST FINANCE, LLC
`KNOLOGY OF FLORIDA, INC.
`BIRCH COMMUNICATIONS, INC,
`
`Petitioner
`
`v.
`
`FOCAL IP, LLC,
`
`Patent Owner
`________________
`
`Case IPR2016-01262
`Patent Number: 7,764,777
`_______________
`
`
`
`PATENT OWNER FOCAL IP, LLC’S REPLY IN SUPPORT OF
`PATENT OWNER’S CONTINGENT MOTION TO AMEND
`CLAIM 46 OF U.S. PATENT NO. 7,764,777
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`
`
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`
`
`Patent 7,764,777
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`
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`Paper No. 43
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`BRIGHT HOUSE NETWORKS, LLC
`WIDEOPENWEST FINANCE, LLC
`KNOLOGY OF FLORIDA, INC.
`BIRCH COMMUNICATIONS, INC,
`
`Petitioner
`
`v.
`
`FOCAL IP, LLC,
`
`Patent Owner
`________________
`
`Case IPR2016-01262
`Patent Number: 7,764,777
`_______________
`
`
`
`PATENT OWNER FOCAL IP, LLC’S REPLY IN SUPPORT OF
`PATENT OWNER’S CONTINGENT MOTION TO AMEND
`CLAIM 46 OF U.S. PATENT NO. 7,764,777
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`
`
`
`
`
`
`
`Case IPR2016-01262
`Patent 7,764,777
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`Paper No. 43
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`TABLE OF CONTENTS
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`I.
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`INTRODUCTION ........................................................................................... 1
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`II.
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`THE SUBSTITUTE CLAIM IS PATENTABLE OVER ARCHER .............. 1
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`III. THE SUBSTITUTE CLAIM IS PATENTABLE OVER LEWIS .................. 6
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`IV. THE SUBSTITUTE CLAIM IS PATENTABLE OVER LAPIER ................ 9
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`V.
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`THE SUBSTITUTE CLAIM IS PATENTABLE AND NOT OBVIOUS ... 10
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`Paper No. 43
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`UPDATED LIST OF EXHIBITS
`
`Declaration of Regis J. “Bud” Bates filed with Preliminary
`Response
`Ray Horak, Communications Systems & Networks, (2nd ed.
`2000)
`Ray Horak, Webster’s New World Telecom Dictionary (2008)
`Ray Horak, Telecommunications and Data Communications
`(2007)
`Prosecution History of U.S. Patent No. 7,764,777
`(“’777ProsHist”)
`Harry Newton, Newton’s Telecom Dictionary, (23rd ed. 2007)
`Declaration of John P. Murphy in Support of Unopposed Motion
`for Pro Hac Vice Admission
`Declaration of Hanna F. Madbak in Support of Unopposed
`Motion for Pro Hac Vice Admission
`Corrected Declaration of Hanna F. Madbak in Support of
`Unopposed Motion for Pro Hac Vice Admission
`U.S. Patent No. 6,574,328
`Opening Claim Construction Expert Declaration of Dr. Eric
`Burger filed by certain Defendants in the underlying district
`court litigation Case No. 3:15-cv-00742-TJC-MCR, Dkt No. 89-
`2, filed 08/12/16.
`Deposition Transcript of Dr. La Porta, Feb. 24, 2017, for
`IPR2016-01259, -01261, -01262, and 01263
`Deposition Transcript of Dr. La Porta, Feb. 23, 2017, for
`IPR2016-01259, -01261, -01262, and 01263 (“La Porta Dep.”)
`Deposition Transcript of Mr. Willis, Mar. 1, 2017, for IPR2016-
`01254 and -01257. (“Willis Dep.”)
`Declaration of Regis J. “Bud” Bates in Support of Response
`(“BatesDec”)
`Petition filed in IPR2016-01261 (“-01261 Pet.”)
`Petition filed in IPR2016-01254 (“-01254 Pet.”)
`Petition filed in IPR2016-01260 (“-01260 Pet.”)
`Declaration of Dr. La Porta in support of the Petition, Ex. 1002
`of IPR2016-01262 (“La Porta Dec. of IPR2016-01262”)
`Declaration of Mr. Willis in support of the Petition, Ex. 1002 of
`iii
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`2001
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`2002
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`2003
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`IPR2016-01254 (“Willis Dec. of IPR2016-01254”)
`Declaration of Dr. Lavian in support of the Petition, Ex. 1002 of
`IPR2016-01258 (“Lavian Dec. of IPR2016-01258”)
`Deposition Transcript of Dr. Lavian, March 29, 2017, for
`IPR2016-01256, -01258, and -01260 (“Lavian Dep.”)
`Declaration of Dr. Lavian in support of the Petition, Ex. 1002 of
`IPR2016-01256 (“Lavian Dec. of IPR2016-01256”)
`Declaration of Regis J. “Bud” Bates in Support of Motion to
`Amend (“BatesDec”)
`Listing of Section 112 Written Description Support for the
`Proposed Substitute Claims
`Application No. 11/948,965, filed on November 20, 2007
`(annotated with line numbers)
`Application No. 10/426,279, filed on April 30, 2003 (annotated
`with line numbers)
`Application No. 09/565,565, filed on May 4, 2000 (annotated
`with line numbers)
`U.S. Pat. No. 4,646,296 (filed on July 9, 1984)
`U.S. Patent No. 6,381,323 to Schwab, et al. (“Schwab”)
`U.S. Patent No. 6,463,145 to O’Neal et al. (“O’Neal”)
`U.S. Patent No. 6,683,870 to Archer (“Archer”)
`U.S. Patent No. 5,958,016 to Chang et al. (“Chang”)
`U.S. Patent No. 6,353,660 to Burger et al. (“Burger”)
`U.S. Patent No. 6,798,767 to Alexander et al. (“Alexander”)
`PCT Application No. WO 99/14924 to Shtivelman
`(“Shtivelman”)
`U.S. Patent No. 5,809,128 to McMullin (“McMullin”)
`U.S. Patent No. 6,445,694 to Swartz (“Swartz”)
`An Overview of Signaling System No. 7, Abdi R. Modarressi,
`and Ronald A. Skoog, April, 1992
`U.S. Patent No. 4,646,296 to Bartholet et al. (“Bartholet”)
`$200 Billion Broadband Scandal, Bruce Kushnick, 2006
`U.S. Patent No. 6,744,759 to Sidhu et al. (“Sidhu”)
`U.S. Patent No. 6,041,325 to Shah et al. (“Shah”)
`U.S. Patent No. 5,802,160 to Kugell et al. (“Kugell”)
`Karen Kaplan, Can I Put You on Hold? Profits are Calling, Los
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`Angeles Times, February 3, 1997
`Redline Comparison of the Proposed Substitute Claims and the
`Original Claims and Clean Versions of the Proposed Substitute
`Claims
`“Cheat Sheet” listing the various IPRs by docket number, along
`with the identity of the petitioner, claims at issue, and art at issue
`Declaration of Thomas La Porta in Support of Petition for Inter
`Partes Review of U.S. Patent No. 8,457,113, June 23, 2016,
`submitted in support of IPR2016-01261
`Declaration of Dr. Tal Lavian in Support of Petition for Inter
`Partes Review of U.S. Patent No. 7,764,777, June 23, 2016,
`submitted in support of IPR2016-01258
`Application No. 12/821,119, filed on June 22, 2010
`Declaration of Regis J. “Bud” Bates in Support of Reply in
`Support of Motion to Amend (“ReplyDec”)
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`I.
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`INTRODUCTION
`Substitute Claim 49 is patentable over each of the references identified in
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`Petitioner’s response. ReplyDec, ⁋ 32. Notably, Petitioner failed to map numerous
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`limitations of the Substitute Claim to each of the references, but rather focused on
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`certain features without any context as to how it would read on the claimed invention
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`as a whole. As explained below, each of the references fails to teach, suggest, or
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`disclose several limitations of the Substitute Claim. Id. Indeed, Petitioner failed to
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`provide any reasons supporting an obviousness argument. A POSA would not
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`modify any of these references with a predictable result to reach the solution claimed
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`in the Substitute Claim, and Petitioner does not explain how or why any of these
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`references could be modified with a predictable result. Id. PO believes Petitioner
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`bears the burden of proving that the Substitute Claim is not patentable.
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`II. THE SUBSTITUTE CLAIM IS PATENTABLE OVER ARCHER
`Archer fails to teach, suggest, or disclose numerous limitations of the
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`Substitute Claim. ReplyDec, ⁋ 33. For example, Archer fails to disclose that
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`“communications, including the first request to establish the incoming call, between
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`the tandem access controller and the particular PSTN tandem switch, occur without
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`passing through any of the edge switches,” as recited in the Substitute Claim. Archer
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`does not use the term “tandem,” “class 4,” or any other term that refers to the claimed
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`PSTN tandem switch. Mot. at 16. Rather, Archer teaches that data to and from the
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`purported TAC and the PSTN tandem switch must first pass through an edge switch
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`Paper No. 43
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`of the PSTN. Mot. at 16-18; ReplyDec, ⁋ 33.
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`Petitioner’s position that converter 126 receives digital signals in a PCM
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`format directly from a PSTN tandem switch is wrong. ReplyDec, ⁋ 34. As an initial
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`matter, Petitioner’s use of the phrase “gateway 126” throughout its response and
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`expert declaration is misleading. Archer consistently uses the terminology
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`“converter 126” (at least 7 times). Archer never uses the terminology “gateway
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`126.” Although Archer states that “converter 126 can also be referred to as a
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`gateway, a digitizer or an encoder,” there can be no legitimate dispute that “converter
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`126” is an edge device that receives analog voice signals from an edge switch of the
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`PSTN where the converter then converts the analog signals to a digital format.
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`ReplyDec, ⁋ 34.
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`In Fig. 2, telephone 114 is connected to circuit switched network 118, which
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`may be the PSTN. Archer at 4:66-5:9. Archer explicitly notes that, while the core
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`of the PSTN is digital, the lines connecting homes and business to COs are still
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`predominantly analog. Id. at 5:25-32 (emphasis added). These analog lines are
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`what connect Archer’s circuit switched network 118 to converter 126. Id. at Fig. 2;
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`ReplyDec, ⁋ 35.
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`Figure 3 and its related disclosure remove any doubt that converter 126
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`receives analog voice signals and converts them to a digital format. As shown in
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`Paper No. 43
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`Fig. 3, converter 126 receives signals from PSTN 118. Archer at Fig. 3, 5:47-58.
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`Converter 126 is comprised of modem bank 70, control circuitry 72, and router 74.
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`Archer’s inclusion of modem bank 70 in the converter is particularly telling. Archer
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`describes that modem 70 “translates the signals into digital signals which can be
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`handled by router 74.” Id. This means that Archer’s modem receives analog signals
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`via the PSTN and translates them to digital signals. ReplyDec, ⁋ 36.
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`Petitioner contends that converter 126 “communicates on the PSTN using SS7
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`signaling and digital voice protocol used by PSTN tandem switches.” Resp. at 6-7.
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`Petitioner further contends that converter 126 “passes information (e.g., voice and
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`signaling) through it, and sends and receives such information in digital formats
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`(e.g., PCM voice and IP voice packets).” Resp. at 7. This position does not square
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`with the actual teachings of Archer. ReplyDec, ⁋ 37.
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`First, PCM stands for pulse coded modulation and simply assigns a digital
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`value to the amplitude of an analog signal at regular intervals, and is used in
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`everything from .wav files to DVDs to HDMI to VoIP signaling – it is hardly unique
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`to telephony products. ReplyDec, ⁋ 38. Because PCM is a digital representation of
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`an analog signal, there would be no reason for converter 126 to include modem bank
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`70 if it received information from the PSTN in a digital format. Indeed, the whole
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`point of a modem (modulator / demodulator) is to convert an analog signal (e.g.,
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`from a telephone line) to a digital format or vice versa. Id. A person of ordinary
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`skill (POSA) would know that modem bank 70 that is external to the PSTN and
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`would be coupled to an edge switch, not to a PSTN tandem switch. Id.
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`Second, Archer does not use the word “tandem” anywhere it its disclosure.
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`Nor does Archer use the term “SS7 signaling” in its disclosure. Petitioner’s attempts
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`to convince the Board that Archer’s modem receives digital voice directly from a
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`PSTN tandem switch along with SS7 signaling is simply made up. ReplyDec, ⁋ 39.
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`Third, the only commercially available product Archer describes as
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`performing the functionality of converter 126 is the Netspeak Webphone Gateway
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`Exchange. Archer at 5:63-67. A POSA would know that the Netspeak product
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`connects to the PSTN through an edge switch and is designed to receive analog
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`signals from a PSTN edge switch, not a tandem switch. ReplyDec, ⁋ 40. Finally,
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`the terms used to describe to converter 126 – “converter,” “gateway,” and “digitizer”
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`– make clear that converter 126 is responsible for converting voice signals received
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`in a first format (analog) to a second format (digital), or vice versa. Id.; Archer at
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`5:33-36. It makes no sense to interpret Archer’s converter 126 as receiving digital
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`signals and simply passing them along in digital format over the IP network. Id. In
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`such a scenario, a modem would not be used. Id.
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`Petitioner’s Response mischaracterizes the testimony of Patent Owner’s
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`expert, Mr. Bates. Petitioner asserts that “Mr. Bates testified that the digital format
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`used by Archer’s gateway 126 to communicate voice information with PSTN 118
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`(136)— [is] PCM….” Resp. at 8. This assertion is false. ReplyDec, ⁋ 41. Mr.
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`Bates never testified that converter 126 communicated voice signals with PSTN 118
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`in a PCM format. Id. The citations in support of this statement contain no such
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`testimony. Id. Nor did “Mr. Bates acknowledge[] that Archer’s gateway 126 would
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`typically be connected to a PSTN tandem switch, not an edge switch, in PSTN 118
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`(136).” Resp. at 8; ReplyDec, ⁋ 41. Again, the testimony pointed to by Petitioner
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`contains no such statement, acknowledgement, or suggestion by Mr. Bates. To the
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`contrary, Mr. Bates acknowledged that PCM is a digital format that could be used
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`by a PSTN tandem switch. ReplyDec, ⁋ 41. Archer only discusses PCM as being
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`used by the IP network 130. Id. Indeed, as previously discussed, Archer expressly
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`contemplates that the PSTN voice signals are sent to converter 126 connection is an
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`analog format, thus requiring the use of a modem in order to convert the analog
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`signal into a digital format (i.e., PCM) that can be used by IP network 130. Id. These
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`analog signals could only come from an edge switch, which typically convey data in
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`an analog format to external devices. Id. As such, Archer does not disclose the
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`limitation “communications, including the first request to establish the incoming
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`call, between the tandem access controller and the particular PSTN tandem switch,
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`Paper No. 43
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`occur without passing through any of the edge switches.” Id.
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`Additionally, Archer fails to disclose “control criteria is previously entered
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`via a web-based interface” that would allow a subscriber to set call control features.
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`ReplyDec, ⁋ 42. In the underlying Petition, Petitioner attempted to cure this
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`deficiency with combination to Chang’s purported TAC. However, Chang’s
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`purported TAC cannot receive a call request to establish the incoming call, as
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`required by the Substitute Claim. Mot. at 19-21; ReplyDec, ⁋ 42. It is unclear how
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`or why a POSA would modify Archer with Chang, or vice versa, with a predictable
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`result to reach the solution claimed in the Substitute Claim. Id. Further, Archer fails
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`to disclose a TAC that processes the calls in a manner required by the Substitute
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`Claim of “blocking the incoming call received at the tandem access controller in
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`accordance with the control criteria.” ReplyDec, ⁋ 42.
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`III. THE SUBSTITUTE CLAIM IS PATENTABLE OVER LEWIS
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`Petitioner’s characterization of Lewis is contrary to the reference’s actual
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`disclosure. As set forth below, Lewis does not teach, suggest, or disclose (1) a
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`tandem access controller, (2) the call processing steps, including blocking the
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`incoming call received at the TAC in accordance with the control criteria, and (3)
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`receiving a first request to establish the incoming call to subsequently establish two
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`way voice communication in the manner required by the Substitute Claim.
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`Paper No. 43
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`ReplyDec, ⁋ 43.
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`On the first point, the descriptive language of the term “tandem access
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`controller” indicates that it is a controller associated with a tandem switch, not an
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`edge switch. Mot. at 3. Petitioner points to open architecture switch 502 as
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`satisfying the TAC limitation. Resp. at 13-18. However, open architecture switch
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`502 is associated with voice switch 506, which is an edge switch, not a tandem
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`switch. Lewis at Fig. 5, 20:30-58, 27:3-18; ReplyDec, ⁋ 44. As the name implies,
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`an open architecture switch is simply a switch that determines whether a particular
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`call is a voice call or a data call, where voice calls are terminated at the edge switch
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`506 in the conventional manner and data calls (non-voice calls) are terminated at a
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`modem 514, which routes the data to an ISP or private data network. Id. There is
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`no disclosure that open architecture switch 502 has any capabilities to apply call
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`features. Nor is there any disclosure that open architecture switch has the capability
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`to identify control criteria previously associated with the specified recipient where
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`“the control criteria is previously entered via a web-based interface” that would
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`allow a subscriber to set call control features. ReplyDec, ⁋ 44. Petitioner did not
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`even attempt to show that Lewis discloses these limitations. Id.
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`On the second point, Lewis does not teach, suggest, or disclose a TAC that
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`processes the calls in a manner required by the Substitute Claim of “blocking the
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`Paper No. 43
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`incoming call received at the tandem access controller in accordance with the control
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`criteria.” Mot. at 25; ReplyDec, ⁋ 45. Lewis is devoid of any teaching, suggestion,
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`or disclosure that its purported TAC is capable of “blocking the incoming call
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`received at the tandem access controller in accordance with the control criteria.”
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`ReplyDec, ⁋ 45. Petitioner did not even attempt to show that Lewis discloses these
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`limitations. Id.
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`On the third point, Patent Owner construed a request to establish the incoming
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`call as “signaling indicating a request to set up a connection that provides for a two
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`way voice communication.” Mot. at 7. Petitioner did not contest this construction.
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`Thus, the Substitute Claim requires that the tandem access controller receive “a first
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`request to establish the incoming call” to set up a connection that provides for a two
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`way voice communication. The entire invention of Lewis is directed to separating
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`data calls from voice calls, and Petitioner relies exclusively on the data call
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`embodiment (i.e., non-voice calls). ReplyDec, ⁋ 46. The data call embodiment
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`relied upon by Petitioner actually teaches away from the ability to provide voice
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`communications because Lewis teaches that voice calls are diverted to the voice
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`switch 506, which is an edge switch, not a tandem access controller. See, e.g., Lewis
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`at 20:30-58, 27:3-18, Fig. 5, Fig. 10A (step 1008 “distinguish between data calls and
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`voice calls”), Fig. 10C (step 1030 and 1042 where if the initial determination is
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`Paper No. 43
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`whether the call is a data call or a voice call); ReplyDec, ⁋ 46. Other than a generic
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`definition of VoIP provided by Lewis at 2:50-55, the only other disclosure of VoIP
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`in Lewis is at 26:9-13, which corresponds to Fig. 9A. This disclosure is clear that
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`Lewis is simply teaching that there are many ways to originate the initial call, such
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`as the “calling party 914” being able to initiate a call using VoIP. After a VoIP call
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`request is received, the invention in Lewis still operates in the same manner—where
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`voice calls are diverted to voice switch 506 (edge switch) without ever being
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`received by the modem NAS bay 514. ReplyDec, ⁋ 46. Additionally, a VoIP call
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`from one VoIP caller to another VoIP caller would never even traverse through a
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`PSTN tandem switch. Id. Petitioner mischaracterizes the teachings of Lewis in a
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`futile attempt to change the invention disclosed in Lewis. See, for example, block
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`quote at page 17 of the Response where Petitioner intentionally omits the disclosure
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`that “the technique distinguishes between data calls and voice calls” where the
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`method transmits voice calls to voice switch 506. Lewis is clear that voice calls are
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`never received at modem NAS bay 514, as alleged by Petitioner. ReplyDec, ⁋ 46.
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`IV. THE SUBSTITUTE CLAIM IS PATENTABLE OVER LAPIER
`As set forth below, LaPier does not teach, suggest, or disclose a tandem access
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`controller or the call processing steps, as required by the Substitute Claim.
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`ReplyDec, ⁋ 47.
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`Paper No. 43
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`On the first point, the descriptive language of the term “tandem access
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`controller” indicates that it is a controller associated with a tandem switch. Mot. at
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`3. The purported TAC in LaPier has no association with a tandem switch, but, rather,
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`its function is to simply act as a protocol converter between protocols of any type of
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`PSTN switch, including edge switches, and Internet protocols. LaPier at 4:56-67,
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`Figs. 1B, 1C; ReplyDec, ⁋ 48.
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`On the second point, Petitioner presented no arguments that LaPier’s
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`purported TAC teaches, suggests, or discloses the capability to identify control
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`criteria previously associated with the specified recipient where “the control criteria
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`is previously entered via a web-based interface” that would allow a subscriber to set
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`call control features. ReplyDec, ⁋ 49.
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`Further, Petitioner made no efforts to indicate why these deficiencies of
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`LaPier would be obvious. For LaPier to operate in the manner required by the
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`Substitute Claim would require extensive and unreasonable modifications to the
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`existing PSTN architecture, where it is unclear how or why a POSA would modify
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`LaPier or the existing PSTN architecture with a predictable result to reach the
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`solution claimed in the Substitute Claim. ReplyDec, ⁋ 50.
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`V. THE SUBSTITUTE CLAIM IS PATENTABLE AND NOT OBVIOUS
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` There is simply no evidence in the record that anyone, prior to the date of the
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`Paper No. 43
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`invention, with all of the necessary tools in hand – PBXs, tandem switches,
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`gateways, modem banks, IN equipment – had any reason to add call features and
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`process calls in the manner recited in the Substitute Claim, or ever conceived of such
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`a solution. ReplyDec, ¶ 51. Petitioner has not provided any reasons as to how or
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`why any reference could be modified or combined to read on each of the limitations
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`recited in the Substitute Claim. Further, Petitioner did not even attempt to address
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`the majority of the claim limitations. Petitioner did not even attempt to show how
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`any prior art reference could possibly render the Substitute Claim obvious. Indeed,
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`to utilize these references in the manner required by the Substitute Claim would
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`require extensive and unreasonable modifications to the existing PSTN architecture,
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`such that a POSA would have no reason to modify the references in the manner
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`required by the Substitute Claim. Id. To modify or combine any of the art to read
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`on the Substitute Claim would require impermissible hindsight by using the claimed
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`invention as a blueprint. Id. Thus, the invention recited in the Substitute Claim is
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`patentable. ReplyDec, ⁋ 52.
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`Dated: July 31, 2017
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`Respectfully Submitted,
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`/s/ Brent N. Bumgardner
`Brent N. Bumgardner
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`11
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`Case IPR2016-01262
`Patent 7,764,777
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`Paper No. 43
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`CERTIFICATE OF SERVICE
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`
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`I hereby certify that on this 31st day of July, 2017, a copy of Patent Owner
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`FOCAL IP, LLC’s Reply in Support of Patent Owner’s Contingent Motion to
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`Amend has been served in its entirety via email on the following:
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`Wayne Stacy
`BAKER BOTTS L.L.P.
`2001 Ross Avenue
`Dallas, TX 75201
`Phone: (214) 953-6678
`Facsimile: (214) 661-4678
`wayne.stacy@bakerbotts.com
`
`Sarah J. Guske
`BAKER BOTTS L.L.P.
`101 California Street, #3070
`San Francisco, CA 94111
`Phone: (415) 291-6205
`Facsimile: (415) 291-6305
`sarah.guske@bakerbotts.com
`
`May Eaton
`BAKER BOTTS L.L.P.
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`Phone: (650) 739-7520
`Facsimile: (650) 739-7620
`may.eaton@bakerbotts.com
`
`Patrick McPherson
`Duane Morris LLP
`505 9th St. NW, Ste 1000
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`
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`12
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`Case IPR2016-01262
`Patent 7,764,777
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`Washington DC 20004
`Tel: 202-776-5214
`Fax: 202-776-7801
`PDMcPherson@duanemorris.com
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`Christopher Tyson
`Duane Morris LLP
`505 9th St. NW, Ste 1000
`Washington DC 20004
`Tel: 202-776-7851
`Fax: 202-776-7801
`CJTyson@duanemorris.com
`
`Kyle Lynn Elliott
`Spencer Fane LLP
`1000 Walnut, Suite 1400
`Kansas City, MO 64106
`Tel: 816-292-8150
`Fax: 816-474-3216
`sfbbaction@spencerfane.com
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`Dated: July 31, 2017
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`Paper No. 43
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`Respectfully Submitted,
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`/s/ Brent N. Bumgardner
`Brent N. Bumgardner
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`Registration No. 48,476
`NELSON BUMGARDNER, P.C.
`3131 W. 7th Street, Suite 300
`Fort Worth, Texas 76107
`Telephone: (817) 377-3490
`Email: brent@nelbum.com
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