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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.,
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`Petitioner,
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`v.
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`REALTIME DATA, LLC D/B/A IXO,
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`Patent Owner.
`____________________
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`Case IPR2016-01738
`Patent No. 8,880,862
`____________________
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`PATENT OWNER’S SUPPLEMENTAL RESPONSE IN SUPPORT OF
`ITS MOTION TO AMEND
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`IPR2016-01737
`SUPPLEMENTAL RESPONSE ON MOTION TO AMEND
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`Table of Contents
`I. Apple’s supplemental response should be rejected in its entirety .................... 1
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`II. A POSA would not combine Sukegawa, Kroeker, and Dye as proposed ........ 2
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`A. A POSA would not be motivated to add RAM to Sukegawa ..................... 2
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`1. The evidence refutes the alleged “cost” motivation ............................ 3
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`2. The evidence refutes the alleged “speed” motivation .......................... 5
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`B. Apple’s evidence does not support combining Sukegawa with Dye .......... 7
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`III. A POSA would not combine Sukegawa, Esfahani, and Dye as proposed ....... 9
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`IV. Esfahani does not teach “preloading,” either alone or in combination ........... 10
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`V. Apple’s theory based on Settsu and Zwiegincew still fails ............................ 11
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`IPR2016-01737
`SUPPLEMENTAL RESPONSE ON 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
`
`Exhibit No.
`2001
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`2002
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`2003
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`2004
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`2005
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`2006
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`2007
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`2008
`2009
`2010
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`2011
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`2012
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`2013
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`2014
`2015
`2016
`2017
`2018
`2019
`2020
`2021
`2022
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`2023
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`2024
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`2025
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`2026
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`2027
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`2028
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`2029
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`2030
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`2031
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`IPR2016-01737
`SUPPLEMENTAL RESPONSE ON 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
`Deposition Transcript of Charles J. Neuhauser, dated
`November 21, 2017
`Declaration of Dr. Godmar Back in Support of Patent
`Owner’s Supplemental Response in Support of its Motion
`to Amend
`Excerpts from PC Magazine, Vol. 18 No. 21, dated
`December 1, 1999
`Excerpts from PC Magazine, Vol. 19 No. 5, dated March 7,
`2000
`Excerpts from PC Magazine, Vol. 19 No. 6, dated March
`21, 2000
`Rough draft of telephonic hearing transcript, held October
`13, 2017
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`IPR2016-01737
`SUPPLEMENTAL RESPONSE ON MOTION TO AMEND
`Apple’s supplemental response should be rejected in its entirety
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`I.
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`To demonstrate obviousness, a petitioner “must articulate ‘[1] how specific
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`references could be combined, [2] which combination(s) of elements in specific
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`references would yield a predictable result, or [3] how any specific combination
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`would operate or read on the asserted claims.’” Dell Inc. et al v. Realtime Data
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`LLC, IPR2016-01002, Paper 71 at 10 (citing and quoting ActiveVideo Networks,
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`Inc. v. Verizon Commc’ns, Inc., 694 F.3d 1312, 1327-28 (Fed. Cir. 2012)).
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`All three showings, and others, must appear in the body of petitioner’s brief,
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`and cannot be merely incorporated by reference from its expert’s declaration. See,
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`e.g., Cisco Sys., Inc. v. C-Cation Techs., LLC, IPR2014-00454, Paper 12 at 7-10
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`(Aug. 29, 2014) (informative) (citing 37 C.F.R. § 42.6(a)(3)).
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`When Apple requested this additional briefing, the Board reminded it of that
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`reality. See Ex. 2031 at 22:24-23:6 (“If the arguments cannot be made and amply
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`supported in their brief, they can’t be made and amply supported.”).
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`Despite that warning, Apple has attempted to present three complex
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`obviousness combinations in only 12 pages of briefing by incorporating large
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`portions of its expert’s declaration by reference. For example, Apple’s briefing as
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`to the combination of Sukegawa, Esfahani, and Dye does not discuss Dye at all,
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`contains only conclusory assertions of a motivation to combine, does not discuss
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`how the combination would be created, and is silent as to how the combination
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`IPR2016-01737
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`would (a) operate or (b) read on the asserted claims. Instead, that section of the
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`brief ends with a sentence that incorporates by reference eighteen paragraphs of
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`the new expert declaration. Supp. Opp. 1-5 (citing Ex. 1045 ¶¶ 44-61). The
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`combination of Sukegawa, Kroeker, and Dye is equally deficient, culminating in
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`one sentence that incorporates twenty nine paragraphs by reference. Id. at 5-8
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`(citing Ex. 1045 ¶¶ 15-43). And the section on Settsu and Zwiegincew relies on a
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`single sentence as to the construction of “preloading,” for which Apple
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`incorporates nine paragraphs of its new expert declaration by reference. Id. at 9.
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`Apple’s brief thus does not meet its obligations under ActiveVideo and the
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`law of obviousness, and the Board should reject all of the theories presented in
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`Apple’s supplemental brief on that basis alone. See Ex. 2031 at 22:24-23:6.
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`II. A POSA would not combine Sukegawa, Kroeker, and Dye as proposed
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`Apple bears the burden of demonstrating the obviousness of the proposed
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`claims. Aqua Products v. Matal, No. 2015-1177, 2017 WL 4399000, at *1, *29
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`(Fed. Cir. Oct. 4, 2017). To do so, Apple must show that a POSA would have been
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`motivated to combine the art as proposed. ActiveVideo, 694 F.3d at 1327.
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`As shown below, Apple has failed to meet that burden on several levels.
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`A. A POSA would not be motivated to add RAM to Sukegawa
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`Apple’s proposed combination of Sukegawa, Kroeker, and Dye requires that
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`a POSA would be motivated to modify Sukegawa by “the addition of DRAM to
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`IPR2016-01737
`SUPPLEMENTAL RESPONSE ON MOTION TO AMEND
`Sukegawa’s cache system controller 3,” based on Kroeker. Ex. 2027 ¶ 12. Apple
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`and Dr. Neuhauser present only two purported motivations for that modification:
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`cost and speed. Ex. 2027 ¶ 15. But Dr. Neuhauser’s deposition, as well as Dr.
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`Back’s testimony, establishes that a POSA would not be motivated on either basis.
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`1.
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`The evidence refutes the alleged “cost” motivation
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`Dr. Neuhauser alleges that “in February of 2000 the cost of DRAM was
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`significantly less than the cost [of] flash memory,” and that a POSA would have
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`been motivated by the alleged cost advantage of DRAM over flash to supplement
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`the flash in Sukegawa with DRAM. Ex. 1045 ¶ 25; Ex. 2027 ¶¶ 15, 17.
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`At his deposition, however, Dr. Neuhauser admitted that the sole piece of
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`evidence he relies on to support the alleged cost advantage of DRAM over flash in
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`February 2000 is a single sentence from the Dye reference, which was written no
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`later than April 1999. Ex. 2027 ¶ 19. Dr. Neuhauser further acknowledged that the
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`immediately preceding sentence in Dye teaches that flash prices were dropping
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`quickly at that time, and that a POSA would have known that the cost of flash was
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`improving rapidly compared to RAM during the late 1990s and early 2000s. Id. at
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`¶¶ 20-22 (quoting Ex. 2026 at 83:13-85:12 (agreeing that the Dye “passage taken
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`as a whole suggests that the cost of flash is dropping”)). Dr. Neuhauser then
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`acknowledged that “just based on Dye,” a POSA “wouldn’t have had a certainty”
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`that flash actually cost more than RAM in February 2000. Id. at ¶ 23. Accordingly,
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`SUPPLEMENTAL RESPONSE ON MOTION TO AMEND
`in light of Dr. Neuhauser’s deposition testimony, it is undisputed that a POSA
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`would not conclude from Dye that “in February of 2000 the cost of DRAM was
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`significantly less than the cost [of] flash memory.” Id. at ¶¶ 18-24.
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`To the contrary, actual advertisements for flash and DRAM memory from
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`December 1999 through March 2000 show that DRAM was more expensive than
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`flash on a per-megabyte basis, or at least equally as expensive—not less. Id. at ¶¶
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`25-28. For instance, the December 1999 issue of PC Magazine shows that 32 MB
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`of flash cost $50 less than the same amount of SDRAM, and that 96 MB of flash
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`cost $70 less compared to only 64 MB of SDRAM. Id. at ¶ 25. By March 7, 2000,
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`64 MB of flash cost $80 less than the same amount of SDRAM. Id. at ¶ 26. And as
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`of March 21, 2000, the same flash cost $50 less than the same SDRAM. Id. at ¶ 27.
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`Thus the evidence shows that a POSA could have easily bought flash more cheaply
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`than DRAM as of February 2000—refuting Apple’s “cost” motivation. Id. at ¶ 28.
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`Apple’s problems do not end there. Dr. Neuhauser’s purported “cost”
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`motivation focuses only on the relative cost of DRAM memory to flash, but Dr.
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`Neuhauser admitted on cross-examination that a POSA would also face—and need
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`to consider—numerous implementation costs from adding DRAM in the manner
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`proposed to Sukegawa’s system. Ex. 2027 ¶¶ 30-32. According to Dr. Neuhauser, a
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`POSA would “have to consider” and “certainly would consider,” for example,
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`“whether they had board space available, whether they had certain types of
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`SUPPLEMENTAL RESPONSE ON MOTION TO AMEND
`connectors available, certain power supplies available already, or would they have
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`to add a new power supply.” Ex. 2026 at 142:23-145:24; Ex. 2027 ¶ 31. Apple’s
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`expert also noted that a POSA would know that deciding to add DRAM to
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`Sukegawa’s system without considering the implementation costs could cause
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`them to “get hurt.” Id. Yet Dr. Neuhauser admitted that he did not discuss or
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`consider any of those crucial implementation costs in his declaration. Ex. 2027 ¶
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`31 (quoting Ex. 2026 at 142:23-145:24 (“Q. You don’t talk about those
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`considerations in your declaration, right? A. No, I do not.”)).
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`As Dr. Back explains, a POSA would have viewed those implementation
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`costs as significant, and would have been dissuaded from pursuing the combination
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`in light of those costs regardless of whether DRAM memory cost less than flash in
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`February 2000, but especially because the evidence shows it did not. Ex. 2027 ¶
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`32. The evidence thus refutes Apple’s “cost” motivation. Id. at ¶ 33.
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`2.
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`The evidence refutes the alleged “speed” motivation
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`Dr. Neuhauser also alleges that speed would have motivated a POSA to
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`modify Sukegawa by adding volatile RAM for use as part of Sukegawa’s boot
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`loading process. He states that “flash memory is slower to access than DRAM” and
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`that “flash memory is significantly slower to write than RAM.” Ex. 1045 ¶ 25.
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`Yet at his deposition, Dr. Neuhauser repeatedly admitted that the actual
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`impact of the proposed modification on the speed of Sukegawa’s boot process,
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`IPR2016-01737
`SUPPLEMENTAL RESPONSE ON MOTION TO AMEND
`which is the relevant issue, would be “unknowable.” Ex. 2027 ¶ 39 (quoting, inter
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`alia, Ex. 2026 at 48:8-20 (“whether the total time, you know, from the beginning
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`of the boot cycle to some particular point during this process of booting is longer
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`or shorter in the combination is unknowable”)). Dr. Neuhauser further confirmed
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`that the relative read/write speed of flash versus RAM did not affect the
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`“unknowability” of the net impact on speed. Ex. 2027 ¶ 40 (quoting Ex. 2026 at
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`56:15-59:2 (“Q. And that fact doesn’t change even if we assume that RAM is faster
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`to write to and read from than nonvolatile flash, right? [A.] I don’t think it changes
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`the unknowability . . . .”)). He also testified that, based on his declaration, a POSA
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`would not know whether the proposed modification would increase speed and, in
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`fact, that it was a “difficult engineering question” that his declaration did not
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`consider. Ex. 2027 ¶¶ 41-42 (quoting Ex. 2026 at 67:23-69:6). Dr. Neuhauser’s
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`own testimony thus refutes and forecloses Apple’s “speed” motivation.
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`As Dr. Back further explains, Sukegawa loads boot data into memory in one
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`cycle for use during the next power-on cycle. Ex. 2027 ¶ 36. Thus, during a
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`particular boot cycle, the boot data has already been fully written into non-volatile
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`flash, and only needs to be read from the flash. Id. By comparison, the proposed
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`combination modifies Sukegawa by also writing some boot data into RAM during
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`a boot cycle and reading it out during that same boot cycle. Id. at ¶ 37.
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`Accordingly, a POSA motivated by a “speed” improvement would need to have
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`IPR2016-01737
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`confidence that the boot speed of modified Sukegawa (with DRAM) would be
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`faster than that of unmodified Sukegawa. Id. at ¶¶ 35, 37. But Dr. Neuhauser’s
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`declaration contains no analysis of the net speed impact of the proposed
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`modification, and does not consider the issue at all, as he admitted. Id. at ¶ 43.
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`Moreover, a POSA pursuing the modification would face significant and complex
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`implementation costs, which Dr. Neuhauser enumerated at his deposition, but did
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`not consider in his declaration. Id. at ¶¶ 30-32. Thus on this record, it is indeed
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`“unknowable” that the proposed modification would yield any speed benefit, but it
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`is known that it would entail serious costs. Id. A POSA would not have sought to
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`incur those costs for a speed benefit she could not expect to achieve. Id. at 44.
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`*
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`*
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`*
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`The evidence thus refutes Apple’s only two purported motivations for the
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`combination of Sukegawa and Kroeker, and the combination fails.
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`B. Apple’s evidence does not support combining Sukegawa with Dye
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`Apple’s combination theory also fails with respect to Sukegawa and Dye.
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`Apple’s brief contains no explanation of how or why a POSA would have been
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`motivated to further modify the combination of Sukegawa and Kroeker by adding
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`Dye’s compression system. Nonetheless, Dr. Neuhauser’s cross-examination
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`testimony, along with Dr. Back’s testimony, demonstrates that Apple has failed to
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`show that a POSA would be motivated to do so. Ex. 2027 ¶¶ 45-53.
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`IPR2016-01737
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`As Dr. Neuhauser expressly stated at his deposition: “Data compression in
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`Dye is not cheap.” Ex. 2027 ¶ 47 (quoting Ex. 2026 at 97:4-98:10). He elaborated
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`that the “highly parallel data compression engine” of Dye is “quite complex” and
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`requires a non-trivial cost. Id. He also noted that implementing Dye’s compression
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`system would require, for instance, specialized compression logic, which would
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`also entail costs. Id. Dr. Neuhauser acknowledged that a POSA would certainly
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`consider the costs associated with a given system design in evaluating its merits.
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`Ex. 2027 ¶ 49. And Dr. Back agrees that the various costs associated with Dye’s
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`compression approach “would have been extremely relevant to a POSA’s decision
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`whether to modify Sukegawa to add Dye’s compression system.” Id.
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`Yet Dr. Neuhauser admitted that he did not consider any of the costs
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`associated with combining Dye’s compression teachings with Sukegawa when he
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`rendered his opinion that a POSA would be motivated to do so. Ex. 2026 at 98:11-
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`100:5. Instead, Dr. Neuhauser and Apple assume that a POSA would pursue a
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`combination purely based on its potential benefits in isolation, without considering
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`the countervailing costs. Ex. 2027 ¶¶ 48, 50. Dr. Neuhauser and Apple do not
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`provide any explanation why a POSA would be motivated to combine Sukegawa
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`with Dye despite the relevant costs. Id. But as Dr. Neuhauser admitted, and Dr.
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`Back confirms, a person of any reasonable skill in the art would have considered
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`those costs, which have “many aspects.” Id. at ¶¶ 49-50. Indeed, Dr. Neuhauser’s
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`IPR2016-01737
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`motivation to combine Sukegawa and Kroeker rests largely on the importance of
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`costs—a consideration he conveniently ignores when discussing the combination
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`of Sukegawa and Dye. Id. at ¶ 52. As Dr. Back explains, a POSA would find the
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`costs and complexities of Dye to be a significant disincentive against combining it
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`with Sukegawa, and would not pursue the combination. Id. at ¶¶ 50-51.
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`III. A POSA would not combine Sukegawa, Esfahani, and Dye as proposed
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`Dr. Neuhauser and Apple also allege that a POSA would have been
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`motivated by Esfahani to incorporate volatile RAM into Sukegawa’s flash-based
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`boot process, once again citing the same two purported motivations: cost and
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`speed. Ex. 2027 ¶¶ 56-59. Once again, the evidence refutes both motivations.
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`As discussed, a POSA would have known in February 2000 that flash could
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`be obtained more cheaply than RAM, and that adding RAM to Sukegawa’s system
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`would entail significant implementation costs. Ex. 2027 ¶¶ 25-33. Thus a POSA
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`would not have found a “cost” motivation for adding RAM to Sukegawa in the
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`manner proposed, id., and Dye does not suggest otherwise. Id. at ¶¶ 17-24, 66-67.
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`Esfahani also provides no teaching or suggestion to the contrary. Apple and
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`Dr. Neuhauser both purport to quote Esfahani for the statement that, at the time
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`Esfahani was written, RAM was “inexpensive . . . compared to ROM.” Ex. 1045 ¶
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`45; Paper 39 at 2 (emphasis Apple’s). But as Dr. Neuhauser was forced to admit on
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`cross-examination, Esfahani says no such thing. Ex. 2026: at 200:3-8, 198:22-
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`199:23; Ex. 2027 ¶¶ 63-64. Rather, the actual quotation from Esfahani states that
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`the cost, capacity, and speed of RAM, disk space, and ROM had all improved as
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`compared to the original Macintosh. Ex. 2027 ¶¶ 62, 64.
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`As Dr. Back explains, neither that statement nor any other aspect of Esfahani
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`would teach or suggest to a POSA that RAM was inexpensive compared to ROM
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`as of the time Esfahani was written. Id. at ¶ 65. Rather, a POSA would understand
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`that Esfahani taught the use of RAM in the boot process for reasons that have
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`nothing to do with the relative cost of RAM, or to improving Sukegawa’s system.
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`Id. Esfahani provides no cost motivation for adding RAM to Sukegawa. Id.
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`And for the same reasons discussed in II.A.2, supra, a POSA would not
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`have been motivated to add RAM into Sukegawa in the hopes of improving
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`Sukegawa’s boot speed, which would have been “unknowable.” Id. at ¶¶ 34-44, 68.
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`Finally, Apple’s superficial analysis fails to show that a POSA would have
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`combined Sukegawa and Dye. See Section II.B, supra; Ex. 2027 ¶¶ 45-53, 69.
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`IV. Esfahani does not teach “preloading,” either alone or in combination
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`As Dr. Back has previously explained, and reiterates, the ’862 patent’s
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`specification teaches that “preloading” must begin before a request for the boot
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`data has been received over computer bus. Ex. 2027 ¶¶ 70, 74. Dr. Neuhauser has
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`previously admitted the same, and there are no contrary teachings in the ’862
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`specification. Id. at ¶¶ 70-71, 76. By contrast, Esfahani teaches that its boot data is
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`loaded into volatile RAM only after the CPU, system bus, and a low-level
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`firmware OS have all been initialized. Ex. 2027 ¶ 72. Thus Esfahani cannot teach
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`or suggest “preloading,” whether alone or in combination. Id. at ¶¶ 73-77.
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`Apple’s contrary arguments are wrong. Apple argues that Esfahani teaches
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`“preloading” (1) because its boot data “is expected (or likely) to be used following
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`reset”; and (2) because “preloading” may continue or end after the boot process has
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`begun. Ex. 1045 ¶¶ 63-65. Both arguments are irrelevant, and without merit.
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`First, merely loading boot data that is “expected (or likely) to be used
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`following reset” is not “preloading”; it is simply loading. Ex. 2027 ¶ 74. Whereas
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`“preloading” begins before commands can be exchanged over computer bus,
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`Esfahani teaches that its boot loading only begins after the bus has initialized. Id.
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`Second, the point is not when “preloading” may continue or end, but that it
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`must begin before a command for the boot data has been received over computer
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`bus, which Esfahani does not teach. Id. at ¶ 75. Esfahani only teaches the
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`conventional “loading” that “preloading” sought to improve. Id. at ¶¶ 74, 77.
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`V. Apple’s theory based on Settsu and Zwiegincew still fails
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`As with Esfahani, Apple’s theory that Settsu teaches “preloading” rests on
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`an incorrect interpretation of the limitation. Id. at ¶ 79. Dr. Neuhauser previously
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`admitted that the “preloading” he identifies in Settsu would only and always begin
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`after the point at which a request for boot data has been received over bus. Id. at ¶¶
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`80, 84. Apple’s latest briefing and Dr. Neuhauser’s latest declaration do not change
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`that aspect of their Settsu-based theory, and that alone is fatal. Id. at ¶¶ 80-81, 84.
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`Instead, they seek to work around Dr. Back’s critique that Zwiegincew’s
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`“prefetching” teachings cannot be used in Settsu in the manner Dr. Neuhauser had
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`proposed. Id. at ¶ 82. But the new proposal to load Settsu’s virtual memory
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`manager before other modules (which was not so “obvious” even to Dr.
`
`Neuhauser, id. at ¶ 83), would still not allow Zwiegincew’s “prefetching”
`
`technique to be used in the manner proposed. Id. at ¶¶ 85, 90. While Zwiegincew’s
`
`approach requires loading through an on-demand page faulting process, Settsu’s
`
`OS main body module 8 is not loaded in that fashion. Id. at ¶ 85. Thus loading the
`
`virtual memory manager module first would not render Zwiegincew’s
`
`“prefetching” technique usable for loading Settsu’s OS main body module 8. Id.
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`Moreover, simply loading the virtual memory manager module first would not
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`necessarily cause it to function. Id. That module relies on other parts of the
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`operating system that must also be loaded, as a POSA would recognize. Id. Finally,
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`Zwiegincew’s teachings relate to booting applications, not operating systems, and
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`a POSA would not find it obvious to extend those teachings to the realm of booting
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`operating system kernels, which do not use “paging.” Id. at ¶¶ 88-90. Apple’s
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`reliance on a CIP by Zwiegincew does not show otherwise: as Dr. Neuhauser
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`admitted, the Zwiegincew ’968 reference is not prior art. Id. at ¶¶ 86-87.
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`- 12 -
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`IPR2016-01737
`SUPPLEMENTAL RESPONSE ON 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
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`Date: December 2, 2017
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`- 13 -
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`Certificate of Service
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`The undersigned hereby certifies that the foregoing PATENT OWNER’S
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`SUPPLEMENTAL RESPONSE IN SUPPORT OF ITS MOTION TO
`
`AMEND was served electronically via e-mail on the following counsel of record
`
`for Petitioner:
`
`W. Karl Renner – IPR39521-0025IP1@fr.com
`
`
`
`
`/s/ Kayvan B. Noroozi
`
`Kayvan B. Noroozi, Admitted Pro Hac Vice
`NOROOZI PC
`1299 Ocean Ave., Suite 450
`Santa Monica, CA 90401
`
`Attorney for Patent Owner
`
`
`Date: December 2, 2017
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