UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`
`BAKER HUGHES INCORPORATED and
`BAKER HUGHES OILFIELD OPERATIONS, INC.,
`Petitioners
`
`v.
`
`PACKERS PLUS ENERGY SERVICES INC.,
`Patent Owner
`
`___________________
`
`Case IPR2016-01506
`Patent 7,861,774
`___________________
`
`
`
`EXCLUSIVE LICENSEE RAPID COMPLETIONS LLC’S
`MOTION TO RECONSIDER INSTITUTION DECISION
`
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`
`BAKER HUGHES INCORPORATED and
`BAKER HUGHES OILFIELD OPERATIONS, INC.,
`Petitioners
`
`v.
`
`PACKERS PLUS ENERGY SERVICES INC.,
`Patent Owner
`
`___________________
`
`Case IPR2016-01506
`Patent 7,861,774
`___________________
`
`
`
`EXCLUSIVE LICENSEE RAPID COMPLETIONS LLC’S
`MOTION TO RECONSIDER INSTITUTION DECISION
`
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`Case IPR2016-01506
`Patent 7,861,774
`
`TABLE OF CONTENTS
`
`INTRODUCTION ........................................................................................... 1
`
`PRECISE RELIEF REQUESTED .................................................................. 1
`
`I.
`
`II.
`
`III. LEGAL STANDARDS ................................................................................... 1
`
`IV. ARGUMENT ................................................................................................... 2
`
`A.
`
`B.
`
`The Panel Relied on a Legally Erroneous Interpretation of
`35 U.S.C. § 314(a). ................................................................................ 2
`
`The Panel Relied on an Erroneous Interpretation of Law in
`Evaluating Lane-Wells Under § 102(b). ............................................... 9
`
`
`
`
`
`
`- i -
`
`
`
`Case IPR2016-01506
`Patent 7,861,774
`
`
`
`Cases
`
`
`TABLE OF AUTHORITIES
`
`
`Arnold Partnership v. Dudas
`
`362 F.3d 1338 (Fed. Cir. 2004) ....................................................................... 2
`
`Blue Coat Sys., Inc. v. Finjan, Inc.
`IPR2017-01441, Paper 11-12 (PTAB Jan. 23, 2017) ...................................... 5
`
`
`Chao v. Roy’s Const., Inc.
`
`517 F.3d 180 (3d Cir. 2008) ........................................................................2, 8
`
`Conopco, Inc. v. The Proctor & Gamble Co.
`
`IPR2014-00628, Paper 21 (PTAB Oct. 20, 2014) ........................................... 3
`
`Donovan v. Adams Steel Erection, Inc.
`
`766 F.2d 804 (3d Cir. 1985) ............................................................................ 2
`
`In re Lister
`
`583 F.3d 1307 (Fed. Cir. 2009) .................................................................9, 10
`
`In re Magnum Oil Tools Int’l, Ltd.
`
`No. 2015-1300, 2016 WL 3974202 (Fed. Cir. July 25, 2016) ........................ 3
`
`LG Elecs. Inc. v. Core Wireless Licensing S.A.R.L.
`
`IPR2016-00986, Paper No. 12 (PTAB Aug. 22, 2016) .......................... 4, 5, 6
`
`Netapp Inc. v. Crossroads Sys., Inc.
`
`IPR2015-00776, Paper 12 (PTAB Sept. 8, 2015) ........................................... 8
`
`Nvidia Corp. v. Samsung Elecs. Co.
`
`IPR2016-00134, Paper 9 (PTAB May 4, 2016) ..........................................4, 6
`
`Samsung Elec. Co. v. Rembrandt Wireless Techs., LP
`
`IPR2015-00114, Paper No. 14 (Jan. 28, 2015) ............................................... 5
`
`- ii -
`
`
`
`
`
`
`
`
`Case IPR2016-01506
`Patent 7,861,774
`
`
`Toyota Motor Corp. v. American Vehicular Sciences LLC
`
`IPR2015-00262, Paper 10 (PTAB Jan. 29, 2015) .......................................3, 4
`
`US Endodontics, LLC v. Gold Standard Instruments, LLC
`
`IPR2015-01476, Paper 13 (PTAB Oct. 26, 2015) ........................................... 7
`
`Statutes
`
`35 U.S.C. § 102(b) .................................................................................................1, 9
`
`35 U.S.C. § 314(a) ........................................................................................... passim
`
`35 U.S.C. § 315(d) ..................................................................................................... 4
`
`35 U.S.C. § 325(d) ........................................................................................ 2, 3, 4, 5
`
`37 C.F.R. § 42.71(c) ................................................................................................... 2
`
`37 C.F.R. § 42.71(d) .................................................................................................. 1
`
`- iii -
`
`
`
`
`
`
`
`
`Case IPR2016-01506
`Patent 7,861,774
`
`
`I.
`
`INTRODUCTION
`
`The Panel recently issued institution decisions in three IPRs based on similar
`
`or identical reasons. IPR2016-01496, IPR2016-01505, IPR2016-01506. While
`
`Respondent intends to challenge those reasons in each proceeding as it advances,
`
`the Board’s decisions also contain two legal errors that justify reconsideration.
`
`Specifically, the Panel: (1) mistakenly concluded that discretionary denial of
`
`institution under 35 U.S.C. § 314(a) requires a showing of “substantial similarity;”
`
`and (2) it applied the incorrect legal test when evaluating whether Lane-Wells
`
`qualifies as prior art under 35 U.S.C. § 102(b). Respondent requests that the Board
`
`reconsider its decision regarding those issues and deny institution.
`
`II.
`
`PRECISE RELIEF REQUESTED
`
`Respondent requests rehearing and reversal of the institution decisions in
`
`IPR2016-01496, IPR2016-01505, IPR2016-01506 as to all claims and grounds.1
`
`III. LEGAL STANDARDS
`
`“A party dissatisfied with a decision may file a request for rehearing,
`
`without prior authorization from the Board.” 37 C.F.R. § 42.71(d). “The request
`
`must specifically identify all matters the party believes the Board misapprehended
`
`or overlooked, and the place where each matter was previously addressed in a
`
`motion, an opposition, or a reply.” Id.
`
`
`1 For ease of reading, Respondent files this identical motion in each proceeding.
`
`
`
`
`- 1 -
`
`
`
`Case IPR2016-01506
`Patent 7,861,774
`
`
`
`When asked to review a decision on a petition, a panel looks for an abuse of
`
`discretion. 37 C.F.R. § 42.71(c). An abuse of discretion occurs when a decision is
`
`based on an erroneous interpretation of law, or if a factual finding is not supported
`
`by substantial evidence, or if the decision represents an unreasonable judgment in
`
`weighing relevant factors. Arnold Partnership v. Dudas, 362 F.3d 1338, 1340 (Fed.
`
`Cir. 2004).
`
`“It is settled that where an agency departs from established precedent
`
`without announcing a principled reason for such a reversal, its action is arbitrary,
`
`and an abuse of discretion, and should be reversed.” Donovan v. Adams Steel
`
`Erection, Inc., 766 F.2d 804, 807 (3d Cir. 1985) (internal citations omitted). This
`
`principle precludes an agency from disregarding its prior case law without a
`
`“principled reason.” Chao v. Roy’s Const., Inc., 517 F.3d 180, 190 (3d Cir. 2008).
`
`IV. ARGUMENT
`
`A. The Panel Relied on a Legally Erroneous Interpretation of 35
`U.S.C. § 314(a).
`
`In addition to disputing the merits of the Petition in its Preliminary
`
`Response, Respondent identified two statutory bases for denial of the petition: 35
`
`U.S.C. § 325(d) and § 314(a). See Prel. Resp. at §§ II.A-C. Respondent also cited
`
`prior PTAB precedent explaining the contours of these provisions. Id. Although
`
`the institution decision acknowledged these arguments, it only analyzed
`
`
`
`
`- 2 -
`
`
`
`Case IPR2016-01506
`Patent 7,861,774
`
`
`Respondent’s § 325(d) argument. It appears that the Panel mistakenly concluded
`
`that rejection of a Petition under § 314(a) requires a patent owner to prove
`
`substantial similarity as contemplated by § 325(d). As explained below, this
`
`conclusion was legal error, and Respondent requests reconsideration of its § 314(a)
`
`challenge under the correct standard.2
`
`Section 325(d) identifies substantial similarity as one factor that the Board
`
`may consider when denying a petition; it contains no language limiting the Board’s
`
`authority to only considering that factor when exercising its discretion to deny a
`
`petition. Conopco, Inc. v. The Proctor & Gamble Co., IPR2014-00628, Paper 21
`
`at 6 (PTAB Oct. 20, 2014) (explaining that similarity between petitions is just “one
`
`
`2 The Panel also erred to the extent it based its decision on arguments
`
`omitted from the Petition or shifted the burden onto respondent to demonstrate
`
`substantial similarity. See In re Magnum Oil Tools Int’l, Ltd., No. 2015-1300,
`
`2016 WL 3974202, at *10 (Fed. Cir. July 25, 2016) (finding “no support for the
`
`PTO’s position that the Board is free to adopt arguments on behalf of petitioners
`
`that could have been, but were not, raised by the petitioner during an IPR”); Toyota
`
`Motor Corp. v. American Vehicular Sciences LLC, IPR2015-00262, Paper 10 at 3
`
`(PTAB Jan. 29, 2015) (denying Petition where Petitioner failed to explain why it
`
`did not include the grounds of a follow-on petition in an earlier filed petition).
`
`
`
`
`- 3 -
`
`
`
`Case IPR2016-01506
`Patent 7,861,774
`
`
`of several circumstances that inform our decision to decline to institute review”).
`
`Indeed, the Board has previously explained that § 314(a) and § 325(d) provide
`
`“separate” bases for denial of a petition, and that there is no substantial similarity
`
`requirement under § 314(a). See, e.g., Nvidia Corp. v. Samsung Elecs. Co.,
`
`IPR2016-00134, Paper 9 at 6-7 and 12-13 (PTAB May 4, 2016) (explaining the
`
`different factors considered in a § 314(a) analysis and a § 325(d) analysis); LG
`
`Elecs. Inc. v. Core Wireless Licensing S.A.R.L., IPR2016-00986, Paper No. 12 at
`
`15 (PTAB Aug. 22, 2016) (listing § 314(a) factors without reference to § 325(d)).
`
`Lest there be any doubt as to the Board’s authority, § 315(d) states:
`
`[D]uring the pendency of an inter partes review, if another proceeding
`or matter involving the patent is before the Office, the Director may
`determine the manner in which the inter partes review or other
`proceeding or matter may proceed, including providing for stay,
`transfer, consolidation, or termination of any such matter or proceeding.
`
`This provision allows the Board to terminate a serial petition, and it contains no
`
`requirement that the Board find substantial similarity between the follow-on
`
`petition and the earlier petition.
`
`This makes sense. The Board has consistently warned petitioners against
`
`abusive serial petitions. Toyota Motor Corp., Paper No. 7 at 7-8 (explaining that
`
`“the opportunity to read Patent Owner’s Preliminary Response in [the previous IPR
`
`proceeding], prior to filing the Petition here, is unjust”); Samsung Elec. Co. v.
`
`
`
`
`- 4 -
`
`
`
`Case IPR2016-01506
`Patent 7,861,774
`
`
`Rembrandt Wireless Techs., LP, IPR2015-00114, Paper No. 14 at 7 (Jan. 28,
`
`2015). (“Petitioner is requesting, essentially, a second chance to challenge the
`
`claims. We, however, are not persuaded that a second chance would help ‘secure
`
`the just, speedy, and inexpensive resolution of every proceeding.’”). For these
`
`warnings to carry weight, they must be applicable even if a follow-on petition
`
`contains arguments that are not substantially similar to an earlier filed petition.
`
`Indeed, the risk of abuse may be greatest when a later-filed petition is dissimilar to
`
`an earlier-filed petition, e.g., because the petitioner developed new theories after
`
`reviewing a preliminary response or institution decision.
`
`To be sure, a number of the Board’s prior decisions have denied petitions
`
`under both § 325(d) and § 314(a). But see, e.g., LG Elecs., IPR2016-00986, Paper
`
`No. 12 at 15 (denying petition under 314(a) without evaluating substantial
`
`similarity under § 325(d)); Blue Coat Sys., Inc. v. Finjan, Inc., IPR2017-01441,
`
`Paper 11-12 at 8-10 (PTAB Jan. 23, 2017) (denying petition as to grounds that
`
`were substantially similar and also new grounds). However, neither party has cited
`
`any statutory authority or past precedent requiring a finding of substantial
`
`similarity before denying a petition under § 314(a). By imposing such a
`
`requirement, the Panel has signaled a dramatic policy shift and actually encouraged
`
`abusive, serial petitions. After all, why should a petitioner worry about presenting
`
`its best arguments in a petition if it can use that petition as a placeholder to elicit a
`
`
`
`
`- 5 -
`
`
`
`Case IPR2016-01506
`Patent 7,861,774
`
`
`preliminary response and then supplement its theories in a later petition by merely
`
`swapping out one asserted reference? Accordingly, Respondent requests that the
`
`Board reconsider its § 314(a) challenge consistent with the Board’s past precedent.
`
`This precedent indicates that the Board considers seven factors when
`
`evaluating a challenge under § 314(a). See, e.g., Nvidia Corp., IPR2016-00134,
`
`Paper 9 at 6-7; LG Elecs., IPR2016-00986, Paper No. 12 at 15. Factors one and
`
`two relate to the Board’s finite resources. Factor three considers whether the initial
`
`and follow-on petitions relate to the same claims. Factor four considers whether
`
`the petitioner knew or should have known of the later-filed theories earlier. Factor
`
`five and six consider whether the petitioner obtained a tactical advantage by filing
`
`the follow-on petition after reviewing the patent owner’s preliminary response.
`
`Factor seven considers the petitioner’s excuse for filing serial petitions. Id.
`
`Respondent’s Preliminary Response demonstrates that all of these factors
`
`weigh against institution of this Petition. Petitioners waited until after they had
`
`reviewed Respondent’s Preliminary Responses to file follow-on petitions against
`
`the exact same claims addressed in their initial Petition. Prelim. Resp. at § II.B.
`
`The Petition offers no justification as to why Petitioners waited so long to file these
`
`serial petitions, and in fact, when pressed to explain why they could not have
`
`asserted their Lane-Wells theories earlier, they refused to respond or provide
`
`substantiating evidence. Id. at § II.A. This is not a situation where the Board is
`
`
`
`
`- 6 -
`
`
`
`Case IPR2016-01506
`Patent 7,861,774
`
`
`called upon to resolve a split of authority or to decide between competing
`
`interpretations of the facts. The case law regarding § 314(a) is established and the
`
`basic facts are undisputed. Consistent application of the Board’s precedent to these
`
`facts calls for denial of this Petition.
`
`Even if the Board were to consider the similarity of the Petitions in
`
`evaluating this § 314(a) challenge, that consideration does not weigh in favor of
`
`institution. To justify the burden and expense of a follow-on petition, a petitioner
`
`must demonstrate that its asserted grounds “are improvements upon [the] grounds”
`
`that have already been instituted. US Endodontics, LLC v. Gold Standard
`
`Instruments, LLC, IPR2015-01476, Paper 13 at 9-10 (PTAB Oct. 26, 2015).
`
`Petitioners have not done so.
`
`The Panel identified only a single difference between the two theories at
`
`issue—the cased/open hole distinction between Thomson and Lane Wells.
`
`However, it is unclear why this distinction is particularly relevant with regard to
`
`the ’505 and ’634 patents given that nearly all of the challenged claims do not even
`
`contain open hole limitations. With regard to the open hole claims, Petitioners
`
`have not asserted Lane-Wells or Thomson as stand alone references. Thus, the
`
`relevant inquiry is not whether these two references are substantially similar, but
`
`whether the proposed Thomson-Ellsworth and Lane-Wells-Ellsworth combinations
`
`are substantially similar. They are. As to both of these theories, Petitioners allege
`
`
`
`
`- 7 -
`
`
`
`
`that a POSITA would employ the proposed combinations in open hole wells.
`
`Indeed, the fact that Petitioners seek consolidation of these theories is evidence of
`
`Case IPR2016-01506
`Patent 7,861,774
`
`their similarity.
`
`More importantly, even if the asserted grounds are meaningfully different,
`
`the Panel erred by failing to consider why these Petitions are different. “Absent a
`
`good reason, a subsequently filed petition that only corrects defects identified by a
`
`Board decision in a prior petition is not typically granted.” Netapp Inc. v.
`
`Crossroads Sys., Inc., IPR2015-00776, Paper 12 at 8 (PTAB Sept. 8, 2015). If the
`
`difference identified by the Panel arose in response Respondent’s Preliminary
`
`Response, then this fact weighs against institution, not in favor of it.
`
`Here, the open hole/cased hole distinction identified by the Board was the
`
`primary issue addressed in Respondent’s preliminary response in IPR2016-00596.
`
`See, e.g., Prelim. Resp. at 29 (“As to this key question—whether a PHOSITA
`
`would have expected an open hole version of Thompson to work for its intended
`
`purpose—Petitioners offer no evidence.”). Thus, the Panel’s finding that the
`
`follow-on Petition attempts to correct this deficiency is a fact that should weigh
`
`decisively against institution.
`
`This Panel has discretion when evaluating a challenge under § 314(a).
`
`However, that discretion is not unconstrained; the Board must be mindful of its
`
`past precedent. See supra § III; Chao, 517 F.3d at 190. Accordingly, Respondent
`
`
`
`
`- 8 -
`
`
`
`
`respectfully requests that the Panel evaluate its § 314(a) challenge to the Petition
`
`Case IPR2016-01506
`Patent 7,861,774
`
`and deny institution.
`
`B.
`The Panel Relied on an Erroneous Interpretation of Law in
`Evaluating Lane-Wells Under § 102(b).
`
`In its Preliminary Response, Respondent asserted that Petitioners had failed
`
`to show that Lane-Wells qualifies as prior art under 35 U.S.C. § 102(b).
`
`Specifically, it asserted that Petitioners had only provided evidence that Lane-
`
`Wells was received at a library, not that it was publicly accessible, i.e., that an
`
`ordinarily skilled artisan, exercising reasonable diligence, could locate the
`
`reference. Prelim. Resp. at 13-14. The Panel found otherwise, stating:
`
`Petitioner provides evidence that Lane-Wells was received not by just
`any library, but the Library of Congress. Additionally, Petitioner
`provides evidence that Lane-Wells was received by the Library of
`Congress not shortly before, but decades before the earliest possible
`priority date of the ’505 patent.
`
`IPR2016-01496, Decision at 12. However, it was legal error for the Panel to
`
`conclude that these facts qualify Lane-Wells as prior art.
`
`The mere fact that a document is stored in the Library of Congress is
`
`insufficient to qualify the document as prior art under 35 U.S.C. § 102(b). In re
`
`Lister, 583 F.3d 1307, 1314 (Fed. Cir. 2009). In In re Lister, the reference at issue
`
`was submitted to the copyright office and stored in the Library of Congress. Id. at
`
`1313. The Patent Office argued that the reference was “publicly accessible”
`
`
`
`
`- 9 -
`
`
`
`Case IPR2016-01506
`Patent 7,861,774
`
`
`because it could be located through a copyright database search and through two
`
`commercial database services. Id. at 1315. The Federal Circuit concluded that the
`
`reference was publicly accessible through the commercial services, but not through
`
`the copyright database because that database did not allow for keyword searching.
`
`Id. Because the Patent Office had failed to show that the commercial database
`
`services had incorporated the reference as of the relevant critical date, it found that
`
`the Patent Office had failed to even present a prima facie case that the reference
`
`was prior art. Id. at 1317. Notably, the Federal Circuit reached this conclusion
`
`despite finding that the reference was received by the Library of Congress years
`
`before the relevant critical date.
`
`Thus, it was legal error for the Panel to forgo an analysis as to whether
`
`Lane-Wells was indexed and cataloged in a meaningful way. See Prelim. Resp. at
`
`12-13 (citing relevant authority). Alternatively, to the extent the Panel based its
`
`decision on factual assumptions as to the operation of the Library of Congress, this
`
`too would have been error. Considering the evidence of record and the applicable
`
`law, Petitioners have failed to show that Lane-Wells was publicly accessible as of
`
`the relevant priority date. The record is simply devoid of any evidence as to how
`
`this reference was indexed or how a person of skill in the art could actually locate
`
`it without already being aware of its existence.
`
`
`
`
`- 10 -
`
`
`
`Case IPR2016-01506
`Patent 7,861,774
`
`
`
`This is not an issue that Petitioners may correct with supplemental evidence.
`
`35 U.S.C. § 314(a) permits institution of a petition only if the petition itself
`
`demonstrates that the petitioner is likely to prevail. Because the evidence included
`
`in the Petitions fails to establish even a prima facie case of invalidity under the
`
`relevant Federal Circuit authority, Petitioners cannot carry their burden under §
`
`314(a). If Petitioners do attempt to submit supplemental evidence to address this
`
`issue, it only highlights the deficiency in the Petitions. This is especially true here
`
`where Respondent requested that Petitioners explain how they located Lane-Wells
`
`so that it could address this issue in its Preliminary Responses, but Petitioners
`
`refused the request. Ex. 2003. Accordingly, Respondent respectfully requests that
`
`the Panel reconsider its decision and find that Petitioners failed to meet their
`
`burden of establishing Lane-Wells as prior art.
`
`
`
`
`- 11 -
`
`
`
`
`Dated: February 14, 2017
`
`
`
`
` Respectfully submitted,
`
`Case IPR2016-01506
`Patent 7,861,774
`
`Rapid Completions LLC
`
`
`By /Justin T. Nemunaitis/
`Hamad M. Hamad, Reg. No. 64,641
`Bradley W. Caldwell (pro hac vice)
`Justin T. Nemunaitis (pro hac vice)
`CALDWELL CASSADY CURRY, P.C.
`2101 Cedar Springs Road, Suite 1000
`Dallas, Texas 75201
`Telephone: 214.888.4848
`Facsimile: 214.888.4849
`hhamad@caldwellcc.com
`bcaldwell@caldwellcc.com
`jnemunaitis@caldwellcc.com
`rapid@caldwellcc.com
`
`Dr. Gregory Gonsalves, Reg. No. 43,639
`GONSALVES LAW FIRM
`2216 Beacon Lane
`Falls Church, Virginia 22043
`Telephone: 571.419.7252
`gonsalves@gonsalveslawfirm.com
`
`
`
`
`
`
`
`
`
`
`
`Case IPR2016-01506
`Patent 7,861,774
`
`CERTIFICATION OF SERVICE
`
`
`
` The undersigned hereby certifies that the foregoing document was
`
`
`
`served electronically via e-mail in its entirety on the following counsel of record
`
`for Petitioner:
`
`Mark T. Garrett (Lead Counsel)
`Eagle H. Robinson (Back-up Counsel)
`NORTON ROSE FULBRIGHT US LLP
`mark.garrett@nortonrosefulbright.com
`eagle.robinson@nortonrosefulbright.com
`
`
`
`Date: February 14, 2017
`
`
`
`
`
`
`
`
`
`
`
` /Hamad M. Hamad/
`
`Hamad M. Hamad, Reg. No. 64,641
`
`
`
`
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
