Filed on behalf of TQ Delta LLC
`By: Peter J. McAndrews
`McAndrews, Held & Malloy, Ltd.
`500 W. Madison St., 34th Floor
`Chicago, IL 60661
`Tel: 312-775-8000
`Fax: 312-775-8100
`E-mail:
`pmcandrews@mcandrews-ip.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`CISCO SYSTEMS, INC.,
`Petitioner,
`
`v.
`
`TQ DELTA, LLC,
`Patent Owner.
`_____________
`
`Case IPR2016-01760
`Patent No. 9,094,268
`_____________
`
`PATENT OWNER’S MOTION FOR OBSERVATION
`
`1
`
`
`
`
`
`
`
`
`
`By: Peter J. McAndrews
`McAndrews, Held & Malloy, Ltd.
`500 W. Madison St., 34th Floor
`Chicago, IL 60661
`Tel: 312-775-8000
`Fax: 312-775-8100
`E-mail:
`pmcandrews@mcandrews-ip.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`CISCO SYSTEMS, INC.,
`Petitioner,
`
`v.
`
`TQ DELTA, LLC,
`Patent Owner.
`_____________
`
`Case IPR2016-01760
`Patent No. 9,094,268
`_____________
`
`PATENT OWNER’S MOTION FOR OBSERVATION
`
`1
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`
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`
`
`
`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
`
`
`Patent Owner TQ Delta, LLC (“Patent Owner”) submits this motion for
`
`observation regarding cross-examination of Dr. Sayfe Kiaei, a reply declarant for
`
`Petitioner.
`
`Observation #1: In Ex. 2017, on page 90, line 19 to page 91, line 7, Dr. Kiaei
`
`testified that the superframe structure and initialization described in the ADSL
`
`Standard, Ex. 1009 are ADSL standard requirements: “So the framing structure is
`
`one of those ADSL standard requirements, and initialization exchange and all that
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`stuff is part of that as well.” This testimony is relevant to Dr. Kiaei’s declaration
`
`testimony that “even if Yamano’s burst-mode protocol does not result in a
`
`continuous stream of superframes [as required by the ADSL standard], a POSITA
`
`would still find Yamano and the ANSI standard compatible.” (Ex. 1012 at ¶ 23).
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`The testimony is relevant because it contradicts Dr. Kiaei declaration testimony
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`and Petitioner’s Reply assertion that Yamano’s burst-mode embodiment is
`
`compatible with the ADSL standard. See Reply at 19-20.
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`Observation #_2: Dr. Kiaei admits that the objective of synchronization is to lock
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`the frequency of the transmitter and the frequency of the receiver. Ex. 2017, at
`
`page 53, line 25 to page 54, line 3 (“THE WITNESS: In line 44 [of col. 5 of the
`
`’404 patent] its talking about locking the frequencies . . . . The objective of this
`
`whole operation is to lock the frequency of the transmitter and the frequency of the
`
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`1
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`
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`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
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`receiver.”)1. Separately, Dr. Kaiei admits that an embodiment described in the’268
`
`patent, performs synchronization of the frequency of the master clock of the
`
`transmitter with the CPE by using a PLL to minimize the difference/error between
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`the master clock in the transmitter and the clock in the receiver. Ex. 2017, at page
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`50, line 19 (“THE WITNESS: the PLL, that is one example of synchronization
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`used here.”); id. at page 54, line 14 to page 55, line 5 (“THE WITNESS: The PLL
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`is a block that the input of it is a reference clock . . . And the output signal has a
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`frequency which is related to the input frequency. So what [the PLL] tries to do is
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`to minimize the difference between the output frequency in a relationship . . . [The
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`PLL] does look at a difference in the error in terms of output frequency and the
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`input frequency.”); id. at page 55, lines 9 to 12 (“[The patent] is talking about the
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`pilot tone . . . which has a pure tone of fixed frequency and phase. It’s
`
`synchronizing it with the receiver to make sure that the frequency of it is the same .
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`. . .”) (emphasis added); See also, Ex. 2017, at pages 59, line 24-page 60, line 25
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`(confirming PLL corrects errors as set forth in Ex. 2016 at p. 184).
`
`This testimony is relevant because it undermines Dr. Kiaei declaration
`
`testimony that “[t]he claims at issue . . . do [not] require correcting errors or
`
`differences in the timing between transceivers.” See Ex. 1012 at ¶ 5. This
`
`
`1 US Patent 9,094,268 and US Patent 8,611,404 share a common specification.
`2
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`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
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`testimony is further relevant because it confirms Dr. Chrissan’s opinions set forth
`
`in his declaration and deposition testimony regarding the proper construction of the
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`claimed “maintaining synchronization with a second transceiver.” Ex. 2005 at ¶¶
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`83-86 and Ex. 1011 at 63:4 – 69:1 and 83:11 – 89:6.
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`Observation # 3: Dr. Kiaei admits that the objective of synchronization in the
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`context of the ’268 patent specification is to lock the frequency of the transmitter
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`and the frequency of the receiver. Ex. 2017, at page 53, line 25 to page 54, line 3
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`(“THE WITNESS: In line 44 [of col. 5 of the ’404 patent] its talking about
`
`locking the frequencies . . . . The objective of this whole operation is to lock the
`
`frequency of the transmitter and the frequency of the receiver.”). Dr. Kiaei
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`testified that in Yamano “[t]he synchronization is done to synchronize periodically
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`enabling the non-idle detector such that the non-idle detector is activated and is
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`enabled by the time that the non-idle detector signal arrives and is able to enable
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`that to perform the -- to indicate there is a packet data coming or not.” Ex. 2004, at
`
`page 174, lines 18-24. Dr. Kiaei’s testimony is relevant because it supports Patent
`
`Owner and its Expert’s contention that Yamano does not disclose “maintaining
`
`synchronization with a second transceiver,” as this limitation is understood in view
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`of the specification. Response at pages 29-34.
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`Observation # 4: Dr. Kiaei agrees that bit allocation and fine gain parameters are
`
`
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`3
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`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
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`derived, in part, from signal-to-noise ratio, that in turn is, in part, determined from
`
`attenuation that, in turn, is representative of the electronic characteristic of the
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`loop. Ex. 2017, at page 14, lines 10-16 (“A. Yes if the line resistance changes, the
`
`attenuation of the line will change.”); Ex. 2017, at page 15, lines 14-17 (“THE
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`WITNESS: . . . one of the parameters that determines the signal-to-noise ratio is
`
`the attenuation of the line.”); and Ex. 2017, at page 17, lines 4-7 (“[f]rom the
`
`signal-to-noise ratio and other parameters, [the modem] determines the bits and
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`gains and so forth.”). Dr. Kiaei maintains that Bowie’s stored loop characteristics
`
`include not
`
`just parameters
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`that are values representing
`
`the electronic
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`characteristics of the particular wire loop but also include parameters like “signal
`
`to noise ratio and so forth, including bits and gains” that are, in part, a function of
`
`the electronic characteristics of the particular wire loop. Ex. 2017, at page 20,
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`lines 5-8; Ex. 2004, page 56, lines 16-17 (“A. The number of bits is part of the
`
`characteristics -- the loop characteristics.”). However, in Wi-Lan Inc. v. Westell
`
`Tech., Inc., a patent infringement case involving Bowie, Ex. 1005, and where Dr.
`
`Kiaei was retained as plaintiff’s expert witness (see Ex. 1004 at. 4), the court
`
`interpreted Bowie’s loop characteristics as “values representing the electronic
`
`characteristics of the particular wire loop” and rejected a construction that Bowie’s
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`loop characteristics are “values that are a function of the electronic characteristics
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`
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`4
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`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
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`of the particular wire loop.” Ex. 2017 at page 33, lines 17-23; and Ex. 2015 at p.
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`26.
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`This is relevant because the Wi-Lan court relied on Bowie’s disclosure at
`
`4:64-5:4 to reject the overbroad interpretation of Bowie’s loop characteristics that
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`Plaintiff Wi-Lan, Dr. Kiaei’s purported client, advocated for and that Dr. Kiaei
`
`advocates for in this case. This is further relevant because it undermines
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`Petitioner’s attorney argument that Bowie’s stored loop characteristics are
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`“parameters associated with a full power mode.” Reply at p. 16.
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`Observation # 5: Dr. Kiaei has, in this proceeding and other proceedings,
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`consistently claimed in his Curriculum Vitae that he worked as plaintiff’s expert
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`witness from 2007-2011 in a patent infringement action where Bowie (Ex. 1005)
`
`was asserted. Ex. 1004 (“8. 2007-2011 Wi-LAN, Inc. Vs. Wesrell (sic)
`
`Technologies, Mckool Smith, Representing Wi-LAN DSL Modem,
`
`Communications, Signal Processing”) (construing loop characteristics as noted in
`
`the prior observation); and IPR2015-01444, Ex. 1003 at p. 4. When asked about
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`this listing on his C.V. at his deposition, and about his involvement in the Wi-LAN
`
`case, Dr. Kiaei testified inconsistently about his involvement and ultimately
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`claimed that he had not worked on the matter. Ex. 2017, at pages 20-26 and 34-37
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`(“I don’t remember all the details of it,” “I did not do any work,” “I did some
`
`
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`5
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`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
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`consulting for them,” “I was not involved in that case by any means,” “[t]his is
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`more of in-house . . . consulting with them as a technical consultant,” “they
`
`interviewed me. They talked to me a couple of times and that was it,” “I should
`
`actually delete that [case] from [my CV]”).
`
`This testimony is relevant because it goes to Dr. Kiaei’s general credibility
`
`and truthfulness. See Fed. R. Evid. 608. It is further relevant because the court in
`
`Wi-LAN v. Westell (Ex. 2015 at p. 26) interpreted Bowie’s disclosure of loop
`
`characteristics in a manner that contradicts Dr. Kiaei’s opinion, and confirms
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`Patent Owner’s expert’s opinion (Ex. 2005 at ¶¶ 95-97) that Bowie’s loop
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`characteristics are not parameters associated with the full power mode. It is further
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`relevant because it undermines Petitioner’s contention that “Patent Owner’s attack
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`on Dr. Kaiei’s” credibility has no merit. See Reply at 30.
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`Observation # 6: Dr. Kiaei testified that Yamano does not discuss implementation
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`details of its periodic poll or other timing signals. Ex. 2017 at page 113, line 19 to
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`page 114, line 22 (“Q. Okay. . . . is the other periodic poll or other timing signal
`
`that is exchanged between the two ends, the far end transmitter and the near end
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`receiver, is that in addition to the non-idle state signal and packet data? . . . . A.
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`The implementation of the details of how the data is preceded by preamble or other
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`things are not discussed in detail”); Ex. 2017 at page 121, lines 2-5 (“A. Okay. I
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`6
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`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
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`guess what I want to point out here, the key issue in here is that it’s not the details
`
`of the implementation but that what the claim says in terms of a staying in the low
`
`power mode.”).
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`This is relevant because Dr. Kiaei previously testified that designing ADSL
`
`systems is not trivial and is complicated (Ex. 2004, at page 198, lines 6-8
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`(“Designing ADSL system is not parking your car in the garage. Designing ADSL
`
`system would require significant amount of timing.”)) and, thus, it undermines Dr.
`
`Kiaei reply declaration testimony that notwithstanding the lack of details in
`
`Yamano, modifying Bowie’s “circuitry to also detect a timing signal, as taught in
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`Yamano, would be well within the level of a POSITA.” Ex. 1012 at ¶ 21. This is
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`still further relevant because Petitioner and Dr. Kiaei have failed to addressed the
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`specifics of how Bowie would be modified and/or combined with the disclosure of
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`Yamano to render the claims obvious.
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`Observation # 7: In Ex. 2017, at page 121, lines 2-5, Dr. Kiaei testified as
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`follows: “A Okay. I guess what I want to point out here, the key issue in here is
`
`that it’s not the details of the implementation but that what the claim says in terms
`
`of a staying in the low power mode.” This is relevant because it shows that Dr.
`
`Kiaei used the claims to guide his understanding of Yamano and to supplement
`
`lack of details in Yamano. This is relevant because it supports Patent Owner’s
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`7
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`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
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`contention that the entirety of Dr. Kiaei analysis is based on hindsight (Response at
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`pages 40-43) and undermines Petitioner’s reply assertion that the Petition does not
`
`rely on hindsight (Reply at 21).
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`Observation # 8: Dr. Kiaei admits that Yamano describes a single carrier system
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`that would need to be modified for multicarrier operation. Ex. 2017, at page 71,
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`lines 23-25 (referencing Ex. 1006, Fig. 4) (“THE WITNESS: I believe it could be
`
`an MCM receiver with some modifications or -- or clear definition of some of
`
`these blocks.”); Ex. 2017, at page 73, lines 2-19 (“Figure 400, looking at this, is a
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`general receiver structure, which can be modified . . . “). This testimony is
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`relevant because it confirms Dr. Chrissan’s deposition testimony that Yamano is a
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`single carrier system that is not readily adaptable to a multicarrier ADSL system.
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`Ex. 1011, at page 103, lines 19-23 (“[Dr. CHRISSAN:] I will say that this is not a
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`multicarrier transmitter, this is a single carrier -- this is a single carrier transmitter,
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`and that is described in my declaration in more than one place.”); Ex. 1011, at page
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`109, lines 1-4 (Q. Could you adapt the teachings of Yamano for use in a
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`multicarrier system? A. No, you could not adapt the teachings of Yamano for use
`
`in a multicarrier system.”). This testimony that Yamano’s disclosure does not
`
`relate to an ADSL transceiver is relevant because its undermines Dr. Kiaei and
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`Petitioner’s assertion that a “POSITA would have understood that the teachings of
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`8
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`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
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`Yamano could be combined with that of Bowie since Bowie teaches ‘ADSL units’
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`(Ex. 1005 at 3:23-37) and Yamano references applying its power-saving
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`techniques to ‘xDSL modems’.” Petition at page 22. The testimony that
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`Yamano’s modem is single carrier is further relevant because the challenged
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`claims recite a “multicarrier transceiver.” See e.g., Ex. 1001, 10:6 (claim 1).
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`Observation # 9: In Ex. 2017, page 65, lines 9-13, Dr. Kiaei testified that a
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`“POSITA will know how to modify the Bowie's circuits and the timing detecting
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`signal that Yamano is teaching so that in the low power mode, it can also detect a
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`synchronized – synchronization signal and detect resume signal.” In contrast, Dr.
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`Kiaei previously testified that Bowie’s resume signal detector 115 and Yamano’s
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`non-idle detector are “two different things.” Ex. 2004 at page 107, lines 15-20 (Q.
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`Okay. Isn’t the function of Yamano’s non-idle detector substantially the same if
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`not identical to Bowie’s resume signal detector 115? A. Not exactly. They are two
`
`different things.”). This is relevant because it goes to Dr. Kiaei’s credibility and
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`undermines Dr. Kiaei and the Petitioner’s contention that “modifying . . . Bowie to
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`also detect Yamano’s timing signal would be well within the level of a POSITA
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`since Yamano teaches similar circuitry . . . .” Ex. 1012 at ¶ 21.
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`Observation # 10: Dr. Kiaei testified that the non-idle detector of Yamano does
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`not receive the periodic poll or other timing signal. Ex. 2017, at page 105, lines
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`
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`9
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`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
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`13-16 (“Q. Is it your position then that the non-idle detector also receives the
`
`periodic poll or other timing signal? A. Non-idle detector receives the poll? No”).
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`This testimony is relevant because Dr. Kiaei contradicts ¶ 20 of his Reply
`
`Declaration, where he stated that “a POSITA would understand that Yamano’s
`
`non-idle detector 401 is active, at least periodically, in order to receive the timing
`
`signal to maintain synchronization . . . .” Ex. 1012 at ¶ 20. This deposition
`
`testimony is also relevant because it shows that Dr. Kiaei has no basis for his
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`assertion in Ex. 1003 at p. 48 that Yamano teaches “a receive circuit maintains
`
`synchronization with a remote transceiver while processing is reduced in the
`
`receive circuit.”
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`Observation # 11: Dr. Kiaei testified that the conclusion at ¶ 22 in his Reply
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`Declaration that “Yamano teaches that its modem transmits and receives data via
`
`‘an analog signal in accordance with a conventional modem protocol, such as
`
`xDSL. Ex.1006, 7:18-20’” is an out of context citation to Yamano and does not
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`concern the burst-mode protocol. Ex. 2017, at page 84, line 11 to page 85, line 5;
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`Ex. 2017, at page 86, line 8 to page 87, line 11 (citing Ex. 1006 at 13:41-44). This
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`undermines Dr. Kiaei and the Petitioner’s conclusion that Yamano’s burst mode
`
`uses the same method of transmitting data as other ADSL modems. See Ex. 1012
`
`at ¶ 24 and Reply at 20.
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`10
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`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
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`Observation # 12: At Ex. 2017, page 110, lines 7-12 Dr. Kiaei states that the non-
`
`idle state signal may or may not be the periodic poll or timing signal, the alleged
`
`synchronization signal. Ex. 2017 at page 110, lines 7-12 (Q. So the non-idle state
`
`signal is the timing signal? A. Not necessarily. Q So the non-idle state signal is not
`
`the timing signal? A Not necessarily.”). However, previously, Dr. Kiaei testified
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`that Yamano’s non-idle detector 401 “is periodically enabled and -- such that then
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`he can detect a non-idle signal coming in and then see if there’s any data or not,
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`and then it’s disabled again” (Ex. 2004, at page 170, lines 4-7) and that the non-
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`idle state signal that indicates the presence of data is not the periodic poll or other
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`timing signal recited in Yamano at 15:16-32. Ex. 2004, page 211, lines 9-12. (“Q.
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`Is the non-idle signal the poll that is described in Yamano, column 15, lines 16 to
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`32? THE WITNESS: No, it’s not.”). This testimony is relevant because it goes to
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`Dr. Kiaei’s credibility and further demonstrates that Petitioner cannot demonstrate
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`in Yamano the claim element, “maintaining synchronization with a second
`
`transceiver.”
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`Observation # 13: Dr. Kiaei testified that Yamano does not describe the nature
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`and implementation of the periodic poll or other timing signal that is allegedly the
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`“synchronization signal” and that he “think[s] the POSITA should know how to do
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`that.” Ex. 2017, at pages 121, lines 18 – pages 123, line 4 (“Q. You have not cited
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`11
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`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
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`to anything in Yamano that describes what the periodic poll or other timing signal
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`is, correct? A. In this declaration, supplemental declaration, I have not, and I don’t
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`recall what I have said in my previous declaration or deposition to point out to that,
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`but I believe the POSITA will clearly understand how the polling mechanism is --
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`or developing a synchronization between transmitter and receiver and other timing
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`signals. As I said before, one could be a tone or a clock between the two. . . . .
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`What I’m saying is that a POSITA will know what the nature and implementation
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`of that poll or synchronous signal could be depending on the implementation. Q.
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`Is there any teaching in Yamano? A. I think polling mechanism is a well-known
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`mechanism in computer science, the polling going on between printers and
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`processors and so on and so forth and the networking . . . We do discuss that in the
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`junior/senior classes, computer science, computer architecture. So a POSITA
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`should know that. And maintaining some sort of a synchronization between them
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`like a clock or pilot tone, a POSITA should also know that because that could be
`
`potentially similar to a full power mode synchronization, as well as I believe that
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`Bowie discusses that in terms of time intervals that it’s able to get out of the low
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`power mode to the -- having a detector to get out of low power mode to full power
`
`mode. So these type of synchronization signals, I think the POSITA should know
`
`how to do that.”) (emphasis added).
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`12
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`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
`
`
`This testimony is relevant because it demonstrates that Yamano does not
`
`describe any type of synchronization, and Petitioner therefore has failed to make a
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`prima facie case of obviousness with respect to “maintaining synchronization with
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`a second transceiver.”
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`Observation # 14: Dr. Kiaei has been consistently inconsistent about when
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`Yamano’s periodic poll or other timing signal is received or what receives the
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`periodic poll or other timing signal. Ex. 2017, at page 105, lines 13-16 (“Q. Is it
`
`your position then that the non-idle detector also receives the periodic poll or other
`
`timing signal? A. Non-idle detector receives the poll? No”); id., at page 99, lines
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`3-6 (“Q. Is it your opinion that the quote, “a timing signal, is a periodic poll or
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`some other timing signal? A Not necessarily.”); Ex. 2004, at page 200, line 22 to
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`page 201, line 9 (Q. BY MR. WIMBISCUS: And the periodic poll that you’re
`
`referring to must be received by the receiver circuit 400 when it is in standby
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`mode, correct? A. I did not say that in my statement. Q. Is the periodic poll
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`received by receiver circuit 400 when it is in standby mode? THE WITNESS:
`
`No.); Ex. 2004 at page 216, lines 21-25 (A. It is the periodic poll or timing signal is
`
`used in low power mode or full power mode to allow the 401 circuit to be enabled
`
`and allow the synchronization between transmitter and receiver.); Ex. 2004, at
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`page 212, line 23 to page 213, line 2 (“Q. And, in your opinion, the
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`13
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`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
`
`synchronization signal can also be operating while the receiver is in full power
`
`mode, correct? A. It could be.”); Ex. 2004, at 214, lines 7-11 (Q. Does Yamano
`
`teach that receiver circuit 400 receives the periodic poll that you find to be a
`
`synchronization signal while the receiver circuit 400 is in normal mode? A. It
`
`could possibly do that.”). This testimony is relevant because it demonstrates that
`
`Dr. Kiaei’s opinions are not credible and further that Yamano does not teach the
`
`claim element, “receiving, in the low power mode, a synchronization signal.”
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`Observation # 15: In Ex. 2017, on page 124, line 3 to page 131, line 11, Dr. Kiaei
`
`confirms that in the ’268 patent and Yamano (Ex. 1006), the echo canceller is part
`
`of the receiver. Ex. 2017, page 130, line 25 to page 131, line 11 (Q So the echo
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`canceller in figure 404 is in the block marked receiving section 16, correct? A Uh-
`
`huh. Q So the echo canceller in figure 1 of the ’404 patent is in the block marked
`
`receiving section 16, correct? A Into ’40 -- Q ’4 patent? A ’404 patent, it's showing
`
`the echo canceller within the block 16. Q Yes. And in the Yamano figure 2, the
`
`echo canceller is in the receiver of a conventional modem according to Yamano,
`
`correct? A That's what they show, correct.). This is relevant because it contradicts
`
`Petitioner’s Reply assertion that the echo canceller is part of both the receiver and
`
`transmitter. See Reply at 10 (citing Ex. 1012, ¶ 14). This is further relevant
`
`because Petitioner has relied solely on a disabled echo canceller being part of the
`
`
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`14
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`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
`
`transmitter to demonstrate a multicarrier transceiver with a transmitter that has a
`
`
`
`
`
`/Peter J. McAndrews/
`Peter J. McAndrews
`Registration No. 38,547
`McANDREWS, HELD & MALLOY,
`LTD.
`500 West Madison St., Suite 3400
`Chicago, IL 60661
`Telephone: (312) 775-8000
`Lead Counsel for Patent Owner
`
`
`
`low power mode as required by the claims.
`
`Dated: October 2, 2017
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`15
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`Patent Owner Motion for Observation
`IPR2016-01760
`Patent No. 9,094,268
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify, pursuant to 37 C.F.R. Section 42.6, that a complete copy of
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`the attached CORRECTED PATENT OWNER’S MOTION FOR
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`OBSERVATION is being served on October 2, 2017, by electronic mail to the
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`following:
`
`Lead Counsel
`David L. McCombs
`HAYNES & BOONE, LLP
`2323 Victory Ave., Suite 700
`Dallas, TX 75219
`Tel. 214-651-5533
`Fax 214-200-0853
`david.mccombs.ipr@haynesboone.com
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`Dated: October 2, 2017
`
`
`
`
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`
`
`
`
`
`Back-up Counsel
`Theodore M. Foster
`Tel. 972-739-8649
`Gregory P. Huh
`Tel. 972-739-6939
`Russell Emerson
`Tel. 214-651-5328
`HAYNES & BOONE, LLP
`2323 Victory Ave., Suite 700
`Dallas, TX 75219
`Fax 972-692-9156
`ipr.theo.foster@haynesboone.com
`michael.parsons@haynesboone.com
`russell.emerson.ipr@haynesboone.com
`
`
`
`/Peter J. McAndrews/
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`
`
`
`
`
`
`Peter J. McAndrews
`Registration No. 38,547
`McANDREWS, HELD & MALLOY,
`LTD.
`500 West Madison Street, 34th Floor
`Chicago, Illinois 60661
`Telephone: (312) 775-8000
`
`16
`
`
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