`
`
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`APPLE INC.,
`
`Petitioner,
`
`v.
`
`REALTIME DATA, LLC D/B/A IXO,
`
`Patent Owner.
`____________________
`
`Case IPR2016-01737
`Patent No. 8,880,862
`____________________
`
`
`
`
`Patent Owner’s Reply In Support Of Its Motion To Amend
`
`
`
`
`
`
`
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`
`Table of Contents
`Introduction ........................................................................................................ 1
`I.
`II. Legal standard .................................................................................................... 1
`III. The motion indisputably meets all requirements of 37 C.F.R. § 42.121 ........... 2
`IV. Apple’s obviousness theory does not teach “preloading,” as the cross-
`examination testimony of its expert reveals .............................................................. 2
`A. The specification’s teachings limit the broadest reasonable interpretation
`of “preloading” ........................................................................................... 2
`B. The ’862 specification teaches that “preloading” must begin before a
`request for boot data has been received over computer bus ....................... 4
`C. Apple’s obviousness theories as to the “preloading” limitation fail .......... 6
`1. Settsu only begins loading boot data after receiving a request over
`computer bus, as Dr. Neuhauser admitted ............................................ 7
`2. Zwiegincew cannot be combined with Settsu ....................................... 8
`V. Apple has failed to prove that any other prior art renders the proposed
`substitute claims unpatentable .................................................................................10
`
`
`
`
`
`
`
`
`
`
`
`- i -
`
`
`
`
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`
`Exhibit List
`
`
`Description
`Declaration of S. Desmond Jui in Support of Motion for
`Admission Pro Hac Vice
`Declaration of Kayvan B. Noroozi in Support of Motion
`for Admission Pro Hac Vice
`Office Patent Trial Practice Guide, 77 Fed. Reg. 48756-
`773, dated August 14, 2012
`Deposition Exhibit Declaration of Dr. Charles J. Neuhauser
`filed in IPR2016-01737 proceeding (not filed)
`Deposition Exhibit Declaration of Dr. Charles J. Neuhauser
`filed in IPR2016-01738 proceeding (not filed)
`Deposition Exhibit Declaration of Dr. Charles J. Neuhauser
`filed in IPR2016-01739 proceeding (not filed)
`Excerpt from Microsoft Computer Dictionary, 5th Ed.,
`Microsoft (2002)
`Declaration of Dr. Godmar Back (“Dr. Back Dec.”)
`Curriculum Vitae of Dr. Godmar Back
`Prosecution History of U.S. Provisional Patent Application
`No. 60/801,114
`Deposition Transcript of Charles J. Neuhauser, dated June
`2, 2017
`Excerpt from Joint Claim Construction and Prehearing
`Statement in matter Realtime Data, LLC d/b/a IXO v.
`Apple Inc., C.A. No. 16-cv-02595-JB (N.D. Cal.)
`Excerpt from Operating System Concepts, Silberschatz et
`al. (2009)
`UNUSED
`UNUSED
`Application No. 11/551,211 as filed
`Application No. 09/776,267 as filed
`U.S. Patent No. 6,539,456 (“Stewart”)
`U.S. Patent No. 6,173,381 (“Dye ’381”)
`U.S. Patent No. 6,434,695 (“Esfahani”)
`U.S. Patent No. 6,073,232 (“Kroeker”)
`Declaration of Dr. Godmar Back in Support of Motion to
`Amend
`
`- ii -
`
`
`
`Exhibit No.
`2001
`
`2002
`
`2003
`
`2004
`
`2005
`
`2006
`
`2007
`
`2008
`2009
`2010
`
`2011
`
`2012
`
`2013
`
`2014
`2015
`2016
`2017
`2018
`2019
`2020
`2021
`2022
`
`
`
`
`
`
`2023
`
`2024
`
`2025
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`Excerpts from the Prosecution History of U.S. Patent No.
`7,181,608 (Application No. 09/776,267)
`Deposition Transcript of Charles J. Neuhauser, dated
`September 27, 2017
`Declaration of Dr. Godmar Back in Support of Patent
`Owner’s Reply to its Motion to Amend
`
`
`
`
`
`- iii -
`
`
`
`
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`
`I.
`
`Introduction
`Apple does not dispute that Realtime’s motion satisfies § 42.121. And Apple
`
`makes no serious attempt to show that the proposed substitute claims are
`
`unpatentable over Sukegawa, its primary reference in the trial. Instead, Apple now
`
`falls back on Settsu and Zwiegincew. Yet the cross-examination testimony of
`
`Apple’s expert, Dr. Neuhauser, as well as the testimony of Patent Owner’s expert,
`
`Dr. Back, reveals that Settsu and Zwiegincew both fail to teach “preloading,” as
`
`the proposed substitute claims require. Apple’s other arguments also fail. Apple
`
`had every opportunity to make a full evidentiary showing, yet it has presented no
`
`analysis as to how any other prior art—whether Esfahani, the art cited in its district
`
`court invalidity contentions, or the art cited on the face of the patent—renders any
`
`proposed claim unpatentable. Apple has thus failed to meet its burden, and the
`
`Board should grant the proposed claims if it finds the original claims unpatentable.
`
`II. Legal standard
`In light of the Federal Circuit’s recent en banc decision in Aqua Products v.
`
`Matal, the Board must assess the patentability of proposed substitute claims
`
`“without placing the burden of persuasion on the patent owner.” No. 2015-1177,
`
`2017 WL 4399000, at *1, *29 (Fed. Cir. Oct. 4, 2017). Rather, it is Petitioner’s
`
`burden “to prove all propositions of unpatentability, including for amended
`
`claims.” Id. And the only relevant art for purposes of that determination is “the
`
`
`
`
`
`
`- 1 -
`
`
`
`
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`prior art cited in the IPR and any new art relevant to § 102 or § 103 that the
`
`petitioner asks be introduced into the IPR.” Id. at *18. Indeed, even before Aqua
`
`Products, the Federal Circuit had made clear—and the PTO had agreed—that
`
`patent owners have no obligation to present particularized analysis of the
`
`patentability of proposed substitute claims over prior art known to them but not of
`
`record in the underlying proceeding. Nike, Inc. v. Adidas AG, 812 F.3d 1326, 1350
`
`(Fed. Cir. 2016) (holding that the Board cannot deny proposed amended claims on
`
`the basis that the patent owner did not discuss prior art not of record), overruled on
`
`other grounds by Aqua Prod., 2017 WL 4399000.
`
`III. The motion indisputably meets all requirements of 37 C.F.R. § 42.121
`Patent Owner has demonstrated that the proposed substitute claims meet
`
`each requirement of §42.121. Mot. 2-17. Neither Apple’s response, nor the lengthy
`
`declaration of its expert, Dr. Neuhauser, contains any assertion to the contrary. The
`
`proposed claims’ compliance with §42.121 is thus undisputed.
`
`IV. Apple’s obviousness theory does not teach “preloading,” as the cross-
`examination testimony of its expert reveals
`A. The specification’s teachings limit the broadest reasonable
`interpretation of “preloading”
`The “broadest reasonable interpretation” standard does not permit imbuing a
`
`claim limitation with scope that exceeds the teachings of the specification, as the
`
`Federal Circuit recently made clear in In re Smith Int’l, No. 2016-2303, 2017 WL
`
`
`
`
`
`
`- 2 -
`
`
`
`
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`4247407, at *4-5 (Fed. Cir. Sept. 26, 2017). There, the Board had found that the
`
`term “body” was a “generic term” that was not defined by the specification, and
`
`could be reasonably interpreted to cover a drilling tool’s internal components. Id.
`
`The Board had rejected patent owner’s argument that the specification consistently
`
`referred to and depicted the “body” of a drilling tool as distinct from other
`
`separately defined components. Id. It also rejected patent owner’s argument that
`
`the Board’s interpretation would render “body” indistinguishable from “tool,”
`
`which the specification used to describe the overall drilling tool. Id. The Board
`
`reasoned that since the specification did not expressly define “body,” and did not
`
`disclaim the Board’s interpretation, its interpretation must be “reasonable.” Id.
`
`The Federal Circuit disagreed, and reversed. The appellate court emphasized
`
`that the “broadest reasonable interpretation” standard is not a “broadest possible
`
`interpretation” standard. Id. (emphasis original). To the contrary, the outer bounds
`
`of a limitation’s “broadest reasonable interpretation” must be determined “in light
`
`of the specification.” Id. (emphasis original). Thus where an interpretation lacks
`
`any support in the specification, and exceeds the teachings of the specification, it is
`
`“unreasonable.” Id. at 6. That is so even if the specification does not expressly
`
`define the term or expressly disclaim otherwise unsupported claim scope. Id. In
`
`short, the Federal Circuit made clear that the Board should not “strain” the breadth
`
`of claims beyond the scope of the teachings of the specification. Id.
`
`
`
`- 3 -
`
`
`
`
`
`
`B.
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`The ’862 specification teaches that “preloading” must begin before
`a request for boot data has been received over computer bus
`Section V of the ’862 specification, titled “Instant Boot Device for
`
`Operating System, Application Program and Loading,” specifically contrasts the
`
`“preloading” approach taught in the specification from prior art approaches. Ex.
`
`1001 at 20:36-22:11. The specification explains that “with conventional boot
`
`device controllers, after reset, the boot device controller will wait for a command
`
`over the computer bus (such as PCI).” Id. at 20:38-40. It then explains that since
`
`the boot device controller is typically ready to operate before the computer bus,
`
`“this wait period is unproductive time.” Id. at 20:40-43. And it further explains that
`
`once a boot device controller receives a command for boot data over the computer
`
`bus, “a long delay is seen by the computer user.” Id. at 20:45-48.
`
`The specification then proposes a solution: “a technique of data preloading
`
`to decrease the computer system boot time.” Id. at 20:50-53 (emphasis added).
`
`Specifically, the specification teaches that “prior to host system reset [e.g., PCI bus
`
`reset], the data storage controller can proceed to pre-load the portions of the
`
`computer operating system from the boot device (e.g., hard disk) into the on-board
`
`cache memory.” Id. at 20:58-61 (emphasis added). “Preloading” thus commences
`
`before the computer bus has been reset, i.e., before commands can be sent or
`
`received across the computer bus. Ex. 2025 ¶ 9. The specification further clarifies
`
`
`
`
`
`
`- 4 -
`
`
`
`
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`that fact, stating “it is advantageous for the boot device controller to preload [ ]
`
`portions [of the operating system] and not wait until it is commanded to load the
`
`operating system.” Ex. 1001 at 20:63-66 (emphasis added). “Once the data is
`
`preloaded, when the computer bus issues its first commands to the data storage
`
`controller seeking operating system data, the data will already be available in the
`
`cache memory of the data storage controller.” Id. at 21:3-6 (emphasis added).
`
`In situations where a request is made “for boot data that is not preloaded in
`
`the local memory of the data storage controller . . ., the controller will retrieve the
`
`requested data from the boot device. . . .” Id. at 21:60-65 (emphasis added). Thus
`
`if boot data begins loading from a boot device only after a request for that data has
`
`been made, the boot data would not be considered “preloaded” for purposes of the
`
`’862 patent. Ex. 2025 ¶ 10.
`
`Consistent with the above, Apple’s expert, Dr. Neuhauser has testified that
`
`“preloading” of boot data, as taught in the ’862 patent, must begin before a request
`
`for the boot data has been received over a computer bus. Ex. 2024 at 61:6-62:3.
`
`Dr. Neuhauser agreed that the specification of the patent describes a problem
`
`and a solution. Ex. 2024 at 60:4-7. The problem, as Dr. Neuhauser acknowledged,
`
`was that traditional loading processes that existed prior to the ‘862 patent were too
`
`slow and could be improved and made faster. Id. at 60:8-16. The patent’s solution,
`
`as Dr. Neuhauser agreed, includes the concept of “preloading” as taught in the
`
`
`
`- 5 -
`
`
`
`
`
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`specification. Id. at 60:18-21. Dr. Neuhauser further admitted that an approach
`
`whereby the boot device controller begins loading boot data after receiving a
`
`command for that data over computer bus is not “preloading.” Id. at 61:6-20. And
`
`he also admitted that the concept of “preloading,” as taught in the ‘862
`
`specification, requires moving boot data into memory before a request has been
`
`made for that data over computer bus. Id. at 61:21-62:3. Moreover, as Patent
`
`Owner’s expert, Dr. Back, further explains, the ’862 patent’s specification contains
`
`no alternative teaching as to “preloading.” Ex. 2025 ¶ 12. Rather, in every instance
`
`in which the specification gives context to “preloading,” it would be clear to one of
`
`ordinary skill in the art that “preloading” must begin before a request for the data
`
`has been received over a computer bus. Id. Thus, the broadest reasonable
`
`interpretation of “preloading” cannot include beginning to load operating system
`
`boot data only after receiving a request for that data over computer bus. Id.
`
`C. Apple’s obviousness theories as to the “preloading” limitation fail
`Apple’s expert, Dr. Neuhauser, relies entirely on two prior art references for
`
`his obviousness allegations as to the “preloading” limitation of all proposed
`
`amended claims: Settsu and Zwiegincew. See Ex. 1030 ¶¶ 26, 38. As shown below,
`
`Dr. Neuhauser’s cross-examination testimony establishes that neither reference
`
`teaches “preloading” within the scope of the proposed claims.
`
`
`
`
`
`
`
`
`- 6 -
`
`
`
`
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`Settsu only begins loading boot data after receiving a
`request over computer bus, as Dr. Neuhauser admitted
`In his declaration, Dr. Neuhauser alleged that the process by which Settsu’s
`
`1.
`
`mini OS module 7 transfers the OS main body module 8 from boot device 3 into
`
`memory 2 constitutes “preloading.” Ex. 2024 at 110:22-111:2. Dr. Neuhauser
`
`further alleged that the mini OS module 7 in Settsu is the “boot device controller”
`
`that “receives a command over a computer bus to load the portion of the boot
`
`data,” for purposes of the proposed substitute claims. Id. at 110:9-20.
`
`Yet on cross-examination, Dr. Neuhauser admitted that the process in Settsu
`
`that he calls “preloading”—transferring the OS main body module 8 from boot
`
`device 3 into memory 2—only begins after the mini OS module 7 (his “boot
`
`device controller”) has, under his own theory, received a command over a
`
`computer bus to load the boot data. Id. at 112:2-10 (admitting that Settsu begins
`
`“preloading” after receiving a command over a computer bus to load the boot
`
`data). And Dr. Neuhauser further admitted that his alleged “boot device controller”
`
`in Settsu—mini OS module 7—“does not transfer any data” into memory before
`
`it has received a command over computer bus to load that data. Id. at 111:3-15.
`
`Patent Owner’s expert, Dr. Back, agrees. Ex. 2025 ¶¶ 13-14.
`
`Accordingly, under Apple’s own theory, Settsu’s alleged “boot device” only
`
`begins loading boot data after receiving an alleged request for that data over
`
`
`
`
`
`
`- 7 -
`
`
`
`
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`computer bus—never before—and Settsu thus does not teach “preloading” within
`
`the broadest reasonable interpretation of that term.1 Ex. 2025 ¶ 15; Ex. 2022 ¶ 61
`
`(“Settsu only teaches loading boot data when it is accessed or requested by the
`
`system, not ahead of time.”). The proposed substitute claims are thus patentable
`
`over Settsu, and Apple has failed to meet its burden to the contrary.
`
`Zwiegincew cannot be combined with Settsu
`2.
`Dr. Neuhauser’s declaration also alleges that Zwiegincew teaches
`
`“preloading.” Ex. 1030 ¶ 38. Specifically, the declaration alleges that by teaching
`
`the “prefetching” of “scenario files” to avoid the problem of “hard page faults,”
`
`Zwiegincew teaches “preloading” of “boot data.” Id. It further proposes that a
`
`POSA would be motivated to incorporate those teachings from Zwiegincew as part
`
`of Settsu’s boot process of loading the OS main body module 8 from boot device 3
`
`into memory 2. Ex. 2024 at 91:10-16, 106:5-11, 117:12-17; Ex. 1030 ¶ 20.
`
`As Dr. Neuhauser admitted, however, a POSA would not want to use
`
`Zwiegincew’s prefetching approach before the virtual memory manager in an
`
`1 Dr. Neuhauser admitted that data can be “loaded” yet not “preloaded,” Ex.
`
`2024 at 47:22-48:6, and further admitted he did not consider that distinction in
`
`writing his declaration. Id. at 42:22-43:5. Dr. Neuhauser thus did nothing to ensure
`
`that Settsu or Zwiegincew teaches “preloading,” rather than simply “loading.”
`
`
`
`
`
`
`- 8 -
`
`
`
`
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`operating system has been enabled. Id. at 103:23-104:16; Ex. 2025 ¶¶ 18-19. A
`
`POSA would recognize that Zwiegincew’s prefetching solution typically cannot be
`
`used until after the virtual memory manager has been enabled. Ex. 2024 at 102:14-
`
`103:22; Ex. 2025 ¶¶ 18-20. Indeed, the problem of “hard page faults,” which
`
`“prefetching” is intended to address, cannot occur before an operating system’s
`
`virtual memory manager has been enabled. Ex. 2024 at 101:3-13; Ex. 2025 ¶ 18.
`
`Accordingly, a POSA would not and could not use Zwiegincew’s “prefetching”
`
`before Settsu’s virtual memory manager had been enabled. Id. at ¶ 20.
`
`Settsu’s virtual memory manager, however, is not enabled until OS main
`
`body module 8 has already been loaded into memory 2, i.e., after the point at
`
`which Dr. Neuhauser opines a POSA would be motivated to use Zwiegincew’s
`
`“prefetching” approach. Ex. 2025 ¶¶ 21-22. That is because Settsu’s virtual
`
`memory manager is a module within the OS main body module 8, as Settsu’s
`
`Figures 3 and 5 clearly show. Ex. 1006; Ex. 2025 ¶ 21. As Dr. Neuhauser
`
`acknowledged, the modules within Settsu’s OS main body 8 are not enabled
`
`before the OS main body module 8 has moved from boot device 3 into memory 2.
`
`Ex. 2024 at 105:17-106:4. It thus necessarily follows that a POSA would not and
`
`could not use Zwiegincew’s prefetching technique (which requires virtual memory
`
`manager to be enabled) to “preload” Settsu’s OS main body module 8 into memory
`
`2 (i.e., before Settsu’s virtual memory manager has been enabled), as Dr.
`
`
`
`- 9 -
`
`
`
`
`
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`Neuhauser has proposed. Id. at 106:5-11; Ex. 2025 ¶ 22. In any case, such an
`
`approach would still not constitute “preloading” under the ’862 patent because it
`
`would only begin after Settsu’s mini OS module 7 (which Dr. Neuhauser calls the
`
`“boot device controller”) had received a request over computer bus to load the OS
`
`main body module 8 (the alleged “boot data”) into memory. Id. at ¶ 23.
`
`Accordingly, Apple’s obviousness theory as to Settsu and Zwiegincew also
`
`fails to demonstrate unpatentability as to any proposed claim. Id. at ¶ 24.
`
`V. Apple has failed to prove that any other prior art renders the proposed
`substitute claims unpatentable
`Apple also argues the proposed claims should not issue in light of
`
`Sukegawa, Esfahani, its invalidity contentions in the district court litigation, and
`
`the prior art cited on the face of the patent. Apple’s assertions are meritless.
`
`Apple argues that a POSA would have found it obvious to use volatile
`
`memory as part of Sukegawa’s boot process, and that the proposed substitute
`
`claims are unpatentable based on Grounds 1-5 of the Petition. Resp. 7-8. That
`
`argument fails on two levels. First, Apple’s assertions are entirely unsupported;
`
`Dr. Neuhauser provided no testimony to support Apple’s obviousness allegations
`
`as to Sukegawa. Ex. 2024 at 14:14-25. Indeed, Dr. Neuhauser has never supported
`
`such a theory in any of his declarations. Id. at 18:20-19:19. Apple’s assertions
`
`based on Sukegawa are thus pure attorney argument, and cannot meet its burden of
`
`
`
`
`
`
`- 10 -
`
`
`
`
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`proof. As Dr. Back explains, a POSA would not be motivated to modify Sukegawa
`
`in the way Apple proposes. Ex. 2025 ¶ 26. Second, as Dr. Neuhauser admitted,
`
`Sukegawa teaches loading boot data into memory in one cycle and using that data
`
`for booting the operating system “in the next power on cycle.” Ex. 2024 at 22:7-11.
`
`By contrast, all of the proposed substitute claims require “preloading [ ] during the
`
`same boot sequence in which a boot device controller receives a command over a
`
`computer bus to load the portion of boot data.” (emphasis added). Since Sukegawa
`
`indisputably loads its “boot data” during one cycle for use during a next cycle,
`
`Sukegawa cannot meet the proposed amended claims. Ex. 2025 ¶ 27.
`
`Apple’s arguments based on Esfahani likewise fail. It was Apple’s burden to
`
`put forth an element-by-element theory of unpatentability based on specific
`
`references. Although Apple knew the risk that it would bear that burden under
`
`Aqua Products, and although Dr. Neuhauser had no limitation on the length of his
`
`declaration, Apple chose not to make any specific showing based on Esfahani. Ex.
`
`2024 at 9:18-25, 14:1-12. And as Dr. Back explains, Esfahani does not teach
`
`“preloading” within the meaning of the ’862 patent. Ex. 2025 ¶ 28. Rather,
`
`Esfahani teaches that its Open Firmware first initializes, and then locates its “Boot
`
`Info file (40),” which Open Firmware then loads into RAM (12). Ex. 2020 at Fig.
`
`6A, 8:40-9:6. It further teaches that “[b]y default, the Boot Info file 40 is located
`
`by . . . searching for a file with a predetermined file type.” Id. at 8:5-10. A POSA
`
`
`
`
`- 11 -
`
`
`
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`would thus understand that Esfahani teaches that its boot data is first requested and
`
`located in response to a command over computer bus, and only begins to load after
`
`such a request has been received, and is thus not “preloaded.” Ex. 2025 ¶ 28.
`
`Apple’s invalidity contentions and its passing reference to the entirety of the
`
`prior art cited on the face of the patent likewise fail. Apple’s invalidity contentions
`
`are not specifically directed to each of the limitations of the proposed amended
`
`claims, and thus cannot demonstrate unpatentability as to any proposed claim. Ex.
`
`2025 ¶ 29. Moreover, the invalidity contentions simply provide various quotations
`
`from the cited prior art, but never explain how or why those quotations teach the
`
`relevant limitations. For example, although the invalidity contentions identify ten
`
`references as purportedly teaching “preloading,” none of Apple’s invalidity charts
`
`demonstrates that any of those references in fact teaches beginning to load boot
`
`data before a command for that data has been received over computer bus. Id. And
`
`with respect to the twenty eight pages of prior art listed on the face of the patent,
`
`Apple provides no analysis at all. Realtime has stated its belief that the proposed
`
`claims are patentable over all references at issue during prosecution, Mot. 18-19,
`
`and is not required to do more. Nike, Inc. v. Adidas AG, 812 F.3d 1326, 1350 (Fed.
`
`Cir. 2016), overruled on other grounds by Aqua Products, Inc. v. Matal, No. 2015-
`
`1177, 2017 WL 4399000, at *1 (Fed. Cir. Oct. 4, 2017) (placing burden of proving
`
`unpatentability of proposed amended claims on petitioner).
`
`
`
`- 12 -
`
`
`
`
`
`
`
`
`
`IPR2016-01737
`REPLY ISO MOTION TO AMEND
`
`Respectfully submitted,
`
`/s/ Kayvan B. Noroozi
`
`William P. Rothwell, Reg. No. 72,522
`NOROOZI PC
`2245 Texas Drive, Suite 300
`Sugar Land, TX 77479
`
`Kayvan B. Noroozi, Admitted Pro Hac Vice
`NOROOZI PC
`1299 Ocean Ave., Suite 450
`Santa Monica, CA 90401
`
`Attorneys for Patent Owner
`
`
`
`
`Date: October 11, 2017
`
`
`
`
`
`
`- 13 -
`
`
`
`
`
`
`
`
`Certificate of Service
`
`The undersigned hereby certifies that the foregoing Patent Owner’s Reply
`
`in Support of Its Motion to Amend and the Associated Exhibits 2024-2025 were
`
`served electronically via e-mail on October 11, 2017, on the following counsel of
`
`record for Petitioner:
`
`W. Karl Renner – IPR39521-0025IP1@fr.com
`
`
`
`
`
`
`
`/s/ William P. Rothwell
`
`William P. Rothwell, Reg. No. 72,522
`NOROOZI PC
`2245 Texas Drive, Suite 300
`Sugar Land, TX 77479
`
`Attorney for Patent Owner
`
`
`Date: October 11, 2017
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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
