throbber
Trials@uspto.gov
`571-272-7822
`
`Paper 13
`Entered: June 9, 2017
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`GLOBALFOUNDRIES U.S. INC.,
`Petitioner,
`
`v.
`
`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`____________
`
`Case IPR2017-00920
`Patent 6,538,324 B1
`____________
`
`
`
`
`Before JUSTIN T. ARBES, MICHAEL J. FITZPATRICK, and
`JENNIFER MEYER CHAGNON, Administrative Patent Judges.
`
`Opinion for the Board filed by Administrative Patent Judge ARBES.
`
`Opinion Concurring-in-Part, Dissenting-in-Part filed by Administrative
`Patent Judge FITZPATRICK.
`
`ARBES, Administrative Patent Judge.
`
`DECISION
`Granting Institution of Inter Partes Review
`37 C.F.R. § 42.108
`
`Granting Petitioner’s Motion for Joinder
`37 C.F.R. § 42.122
`
`

`

`IPR2017-00920
`Patent 6,538,324 B1
`
`
`Petitioner GlobalFoundries U.S. Inc. filed a Petition (Paper 1, “Pet.”)
`
`requesting inter partes review of claims 1–3, 5–7, and 9 (“the challenged
`
`claims”) of U.S. Patent No. 6,538,324 B1 (Ex. 1001, “the ’324 patent”) and
`
`a Motion for Joinder (Paper 3, “Mot.”) with Case IPR2016-01264 (“the
`
`-1264 Case”). Patent Owner Godo Kaisha IP Bridge 1 filed a Combined
`
`Opposition to Petitioner’s Motion for Joinder and Preliminary Response.
`
`Paper 8 (“Opp.”). Petitioner filed a Reply. Paper 12 (“Reply”).1
`
`Pursuant to 35 U.S.C. § 314(a), the Director may not authorize an
`
`inter partes review unless the information in the petition and preliminary
`
`response “shows that there is a reasonable likelihood that the petitioner
`
`would prevail with respect to at least 1 of the claims challenged in the
`
`petition.” For the reasons that follow, we institute an inter partes review as
`
`to claims 1–3, 5–7, and 9 of the ’324 patent on certain grounds of
`
`unpatentability, and grant Petitioner’s Motion for Joinder.
`
`
`
`I. BACKGROUND
`
`A. Related Proceedings
`
`On June 24, 2016, Taiwan Semiconductor Manufacturing Company,
`
`Ltd. (“TSMC”) filed a petition in the -1264 Case requesting an inter partes
`
`review of the challenged claims of the ’324 patent. On December 21, 2016,
`
`we instituted an inter partes review. Taiwan Semiconductor Mfg. Co., Ltd.
`
`v. Godo Kaisha IP Bridge 1, Case IPR2016-01264 (PTAB Dec. 21, 2016)
`
`(Paper 7) (“-1264 Dec. on Inst.”). Patent Owner filed its Response and
`
`
`1 Petitioner’s original Reply exceeded the five-page limit set forth in
`37 C.F.R. § 42.24(c)(2). On April 17, 2017, we authorized Petitioner by
`email to re-file its Reply and expunged the original version. See Papers
`11, 12.
`
`
`
`2
`
`

`

`IPR2017-00920
`Patent 6,538,324 B1
`
`Motion to Amend on March 7, 2017, and TSMC filed its Reply and
`
`Opposition to the Motion to Amend on May 22, 2017.
`
`On January 23, 2017, GlobalFoundries, Inc. (Petitioner’s corporate
`
`parent) filed a petition in Case IPR2017-00757 requesting an inter partes
`
`review of the challenged claims based on the same asserted grounds as the
`
`petition in the -1264 Case, along with a Motion for Joinder. The Petition
`
`listed GlobalFoundries, Inc. as the sole real party-in-interest. See
`
`IPR2017-00757, Paper 2, 40. Petitioner subsequently filed its Petition and
`
`Motion for Joinder in the instant proceeding on February 16, 2017, listing
`
`itself and GlobalFoundries, Inc. as real parties-in-interest. See Pet. 40.
`
`On March 10, 2017, we dismissed the petition in Case IPR2017-00757.
`
`See IPR2017-00757, Paper 15.
`
`
`
`B. The Prior Art
`
`Petitioner relies on the following prior art:
`
`U.S. Patent No. 5,893,752, issued April 13, 1999
`(Ex. 1004, “Zhang”);
`
`U.S. Patent No. 6,887,353 B1, filed Dec. 19, 1997, issued
`May 3, 2005 (Ex. 1005, “Ding”); and
`
`Sun et al., “Properties of Reactively Sputter-Deposited
`Ta – N Thin Films,” Thin Solid Films, vol. 236, pp. 347–351
`(1993) (Ex. 1007, “Sun”).
`
`
`
`3
`
`
`
`

`

`IPR2017-00920
`Patent 6,538,324 B1
`
`
`C. The Asserted Grounds
`
`Petitioner challenges claims 1–3, 5–7, and 9 of the ’324 patent on the
`
`following grounds:
`
`References
`
`Basis
`
`Claims Challenged
`
`Zhang and
`Ding
`
`Zhang, Ding,
`and Sun
`
`35 U.S.C. § 103(a)2
`
`1–3, 5–7, and 9
`
`35 U.S.C. § 103(a)
`
`1–3, 5–7, and 9
`
`
`
`II. DISCUSSION
`
`A. The Petition
`
`Petitioner asserts the same grounds of unpatentability as those on
`
`which we instituted a trial in the -1264 Case. See Pet. 9, 37; -1264 Dec. on
`
`Inst. 17. Petitioner presents the same arguments as those made by TSMC in
`
`its petition in the -1264 Case. Compare Pet. 9–40, with IPR2016-01264,
`
`Paper 2, 12–51; see also Mot. 7 (Petitioner representing that they “are
`
`essentially identical”); Opp. 8 (Patent Owner arguing against “[i]nstituting
`
`an essentially identical IPR proceeding involving the same prior art, the
`
`same arguments, and the same evidence”). Patent Owner does not argue the
`
`merits of Petitioner’s asserted grounds in its Combined Opposition and
`
`Preliminary Response. We incorporate our previous analysis regarding the
`
`asserted grounds of unpatentability, and conclude that Petitioner has
`
`
`2 The Leahy-Smith America Invents Act, Pub. L. No. 112-29, 125 Stat. 284
`(2011) (“AIA”), amended 35 U.S.C. § 103. Because the challenged claims
`of the ’324 patent have an effective filing date before the effective date of
`the applicable AIA amendment, we refer to the pre-AIA version of
`35 U.S.C. § 103.
`
`
`
`4
`
`

`

`IPR2017-00920
`Patent 6,538,324 B1
`
`demonstrated a reasonable likelihood of prevailing on the grounds of
`
`unpatentability asserted in the Petition for the same reasons. See -1264 Dec.
`
`on Inst. 5–17.
`
`
`
`B. The Motion for Joinder
`
`The AIA created administrative trial proceedings, including inter
`
`partes review, as an efficient, streamlined, and cost-effective alternative to
`
`district court litigation. 35 U.S.C. § 315(c) provides (emphasis added):
`
`JOINDER.—If the Director institutes an inter partes review, the
`Director, in his or her discretion, may join as a party to that
`inter partes review any person who properly files a petition
`under section 311
`that
`the Director, after receiving a
`preliminary response under section 313 or the expiration of the
`time for filing such a response, determines warrants the
`institution of an inter partes review under section 314.
`
`“Any request for joinder must be filed, as a motion under § 42.22, no later
`
`than one month after the institution date of any inter partes review for which
`
`joinder is requested.” 37 C.F.R. § 42.122(b). Joinder may be authorized
`
`when warranted, but the decision to grant joinder is discretionary. See
`
`35 U.S.C. § 315(c); 37 C.F.R. § 42.122. The Board determines whether to
`
`grant joinder on a case-by-case basis, taking into account the particular facts
`
`of each case, substantive and procedural issues, and other considerations.
`
`See Sony Corp. of Am. v. Network-1 Security Solutions, Inc., Case
`
`IPR2013-00495, slip op. at 3 (PTAB Sept. 16, 2013) (Paper 13) (“Sony”).
`
`When exercising its discretion, the Board is mindful that patent trial
`
`regulations, including the rules for joinder, must be construed to secure the
`
`just, speedy, and inexpensive resolution of every proceeding. See 35 U.S.C.
`
`§ 316(b); 37 C.F.R. § 42.1(b).
`
`
`
`5
`
`

`

`IPR2017-00920
`Patent 6,538,324 B1
`
`
`As the moving party, Petitioner has the burden of proof in establishing
`
`entitlement to the requested relief. 37 C.F.R. §§ 42.20(c), 42.122(b).
`
`A motion for joinder should (1) set forth the reasons why joinder is
`
`appropriate; (2) identify any new ground(s) of unpatentability asserted in the
`
`petition; and (3) explain what impact (if any) joinder would have on the trial
`
`schedule for the existing review. See Sony, at 3; Mot. 6. Petitioner should
`
`address specifically how briefing and/or discovery may be simplified to
`
`minimize schedule impact. See Kyocera Corp. v. SoftView LLC, Case
`
`IPR2013-00004, slip op. at 4 (PTAB Apr. 24, 2013) (Paper 15)
`
`(representative); Mot. 6.
`
`
`
`1. Timeliness of the Motion for Joinder
`
`Patent Owner argues that the Motion for Joinder should be denied as
`
`untimely under 37 C.F.R. § 42.122(b), which specifies that “[a]ny request
`
`for joinder must be filed, as a motion under § 42.22, no later than one month
`
`after the institution date of any inter partes review for which joinder is
`
`requested.” Opp. 2–5. We instituted an inter partes review in the -1264
`
`Case on December 21, 2016, and Petitioner filed its Motion for Joinder in
`
`the instant proceeding on February 16, 2017. Thus, the Motion was filed
`
`after the one-month period set forth in 37 C.F.R. § 42.122(b). Under
`
`37 C.F.R. § 42.5(b), however, the Board “may waive or suspend a
`
`requirement of [part 42 of the Board’s rules] and may place conditions on
`
`the waiver or suspension.” Patent Owner argues that there is no reason why
`
`Petitioner could not have filed its Motion within one month of institution in
`
`the -1264 Case, particularly given the fact that it filed a nearly identical
`
`
`
`6
`
`

`

`IPR2017-00920
`Patent 6,538,324 B1
`
`petition within one month in Case IPR2017-00757.3 Opp. 4. Petitioner
`
`responds that special circumstances exist to waive the one-month
`
`requirement. Reply 3. We agree with Petitioner.
`
`Similar to the situation in Sony, where the petitioner filed a first
`
`petition and motion for joinder within the one-month period that was denied,
`
`and then a second petition and motion for joinder after the one-month period
`
`that was granted, here Petitioner’s parent company filed its petition in Case
`
`IPR2017-00757 within one month of institution in the -1264 Case, then
`
`Petitioner re-filed shortly thereafter to include both entities as real parties-in-
`
`interest. See Sony, at 6–9. Also similar to the facts of Sony and explained
`
`further below, Petitioner’s “asserted grounds and arguments are identical to
`
`those already at issue in the existing proceeding, joinder would require no
`
`change to the trial schedule, [and] joinder would impose no added burden on
`
`the existing parties because [Petitioner is] willing to have only a limited
`
`‘understudy’ role.” See id. at 9. Thus, we are persuaded to exercise our
`
`discretion to waive the one-month requirement under 37 C.F.R. § 42.122(b),
`
`and turn to whether joinder should be granted, taking into account
`
`substantive, procedural, and other considerations.
`
`
`
`2. Substantive Issues
`
`Petitioner argues that joinder with the -1264 Case is appropriate
`
`because its asserted grounds and supporting evidence are “essentially the
`
`same” as that of the -1264 Case. See Mot. 3; see also Reply 2 (“The Petition
`
`asserts the same grounds of unpatentability as those on which a trial was
`
`
`3 Petitioner filed its petition and motion for joinder in Case IPR2017-00757
`on January 23, 2017, the first business day following January 21, 2017.
`
`
`
`7
`
`

`

`IPR2017-00920
`Patent 6,538,324 B1
`
`instituted in case IPR2016-01264.”). Patent Owner does not dispute that the
`
`asserted grounds and evidence are identical to those on which a trial was
`
`instituted in the -1264 Case. We agree with Petitioner that the Petition raises
`
`no new issues beyond those already before us in the existing proceeding,
`
`which weighs in favor of joinder.
`
`Patent Owner argues that Petitioner’s actions “raise questions” as to
`
`whether it identified correctly all real parties-in-interest in this proceeding.
`
`Opp. 10–13. Specifically, GlobalFoundries, Inc. filed the original petition in
`
`Case IPR2017-00757, identifying itself as the only real party-in-interest, but
`
`Petitioner now identifies both itself and GlobalFoundries, Inc. Id. at 10–12.
`
`Patent Owner also points to a statement made by Petitioner in a related case
`
`that “the Petition had been timely filed because it was filed less than one
`
`year after the date [Broadcom Ltd. (‘Broadcom’)] was served with both the
`
`summons and the complaint.” Id. at 12 (citing IPR2017-00903, Paper 2,
`
`87–88). We are not persuaded that Petitioner’s identification of an
`
`additional real party-in-interest in the instant proceeding would raise
`
`significant new issues beyond those already at issue in the -1264 Case. Nor
`
`are we persuaded by Patent Owner’s citation to the statement regarding
`
`Broadcom, because Petitioner did not in fact identify Broadcom as a real
`
`party-in-interest in that proceeding. See IPR2017-00903, Paper 2, 86–88.
`
`Given the similarities in substantive issues between the instant proceeding
`
`and the -1264 Case, we conclude that the impact of joinder on the existing
`
`proceeding would be minimal.4
`
`
`
`
`4 To the extent Patent Owner believes any additional briefing is necessary in
`the -1264 Case, Patent Owner may request a conference call.
`
`
`
`8
`
`

`

`IPR2017-00920
`Patent 6,538,324 B1
`
`
`3. Procedural Issues
`
`Petitioner argues that because the asserted grounds and supporting
`
`evidence mirror what was presented in the -1264 Case, “joinder would not
`
`affect the pending schedule in [the -1264 Case] nor increase the complexity
`
`of that proceeding, minimizing costs.” Mot. 3; see Reply 2–3. Petitioner
`
`further states that it “is willing to act as an ‘understudy’ to TSMC, only
`
`assuming an active role in the event TSMC settles with” Patent Owner.
`
`Mot. 3; see Reply 2–3. Specifically, Petitioner
`
`proposes that as long as TSMC remains in the joined IPR,
`[Petitioner] agrees to remain in a circumscribed “understudy”
`role without a separate opportunity to actively participate.
`Thus, [Petitioner] will not file additional written submissions,
`nor will [Petitioner] pose questions at depositions or argue at
`oral hearing without the prior permission of TSMC. Only in
`the event that TSMC settles will [Petitioner] seek to become
`active in the joined IPR.
`
`Mot. 7; see also Reply 5 (“Petitioner is willing to abide by such additional
`
`conditions as the Board deems appropriate.”). Because joinder would
`
`require no change to the existing trial schedule and Petitioner agrees to have
`
`only a limited “understudy” role if joined, the procedural impact of joinder
`
`on the -1264 Case would be minimal, which weighs in favor of joinder.
`
`Patent Owner argues that permitting joinder “would frustrate the
`
`possibility of settlement” with TSMC in the -1264 Case, as “[n]either Patent
`
`Owner nor TSMC would have an incentive to simplify and streamline the
`
`IPR issues via settlement if [Petitioner] looms in the background.” Opp. 5.
`
`The possible chilling effect of joinder on settlement is a factor present in
`
`most, if not all, joinder situations, and must be weighed together with all of
`
`the other facts. We are persuaded that the similarities in issues, lack of any
`
`impact on the existing trial schedule, and fact that Petitioner consents to
`
`
`
`9
`
`

`

`IPR2017-00920
`Patent 6,538,324 B1
`
`procedural protections that will maintain TSMC’s control over the
`
`proceeding outweigh any potential effect on settlement.
`
`Patent Owner also argues that, if joinder is granted, we should impose
`
`additional conditions on Petitioner’s participation in the -1264 Case. Opp.
`
`13–15. Much of what Patent Owner requests is already stated in Petitioner’s
`
`proposal above. We agree with Patent Owner, though, that given its
`
`“understudy” role, Petitioner should be permitted to file papers, engage in
`
`discovery, and participate in depositions and oral argument only after
`
`obtaining authorization from the Board, not TSMC. See id. Petitioner may
`
`request a conference call to obtain such authorization if necessary.
`
`
`
`4. Conclusion
`
`Based on all of the considerations above, we are persuaded that
`
`Petitioner has met its burden of demonstrating that joinder is warranted
`
`under the circumstances. Petitioner will have a limited role in the -1264
`
`Case, as explained below. If at some point the -1264 Case is terminated
`
`with respect to TSMC, the role of any remaining party or parties in the
`
`proceeding will be reevaluated.
`
`
`
`In consideration of the foregoing, it is hereby:
`
`III. ORDER
`
`ORDERED that an inter partes review is instituted as to claims
`
`1–3, 5–7, and 9 of the ’324 patent;
`
`FURTHER ORDERED that pursuant to 35 U.S.C. § 314(a), inter
`
`partes review of the ’324 patent is hereby instituted commencing on the
`
`
`
`10
`
`

`

`IPR2017-00920
`Patent 6,538,324 B1
`
`entry date of this Decision, and pursuant to 35 U.S.C. § 314(c) and
`
`37 C.F.R. § 42.4, notice is hereby given of the institution of a trial;
`
`FURTHER ORDERED that the trial is limited to the following
`
`grounds of unpatentability, and no other grounds as to claims 1–3, 5–7, and
`
`9 of the ’324 patent are authorized:
`
`Claims 1–3, 5–7, and 9 under 35 U.S.C. § 103(a) as unpatentable over
`
`Zhang and Ding; and
`
`Claims 1–3, 5–7, and 9 under 35 U.S.C. § 103(a) as unpatentable over
`
`Zhang, Ding, and Sun;
`
`FURTHER ORDERED that Petitioner’s Motion for Joinder with
`
`Case IPR2016-01264 is granted, and GlobalFoundries U.S. Inc. is joined as
`
`a party to Case IPR2016-01264;
`
`FURTHER ORDERED that Case IPR2017-00920 is instituted, joined,
`
`and terminated under 37 C.F.R. § 42.72, and all further filings in the joined
`
`proceeding shall be made in Case IPR2016-01264;
`
`FURTHER ORDERED that unless given prior authorization by the
`
`Board, Petitioner is not permitted to file papers, engage in discovery, or
`
`participate in any deposition or oral argument in Case IPR2016-01264.
`
`Petitioner, however, is permitted to appear in Case IPR2016-01264 so that it
`
`receives notification of filings and may attend depositions and oral
`
`argument.5 Should Petitioner believe it necessary to take any further action,
`
`Petitioner should request a conference call to obtain authorization from the
`
`Board; and
`
`
`5 Counsel for TSMC and Petitioner should refer to the Board’s website for
`information regarding filings in the Patent Trial and Appeal Board End to
`End (PTAB E2E) system.
`
`
`
`11
`
`

`

`IPR2017-00920
`Patent 6,538,324 B1
`
`
`FURTHER ORDERED that a copy of this Decision be entered into
`
`the file of Case IPR2016-01264.
`
`
`
`
`
`12
`
`

`

`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`GLOBALFOUNDRIES U.S. INC.,
`Petitioner,
`
`v.
`
`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`____________
`
`Cases IPR2017-00920
`Patent 6,538,324 B1
`____________
`
`
`
`FITZPATRICK, Administrative Patent Judge, concurring-in-part,
`dissenting-in-part.
`
`I concur with the majority’s decision to join GlobalFoundries U.S.
`
`Inc. (“Global”) as co-petitioner in the previously instituted inter partes
`
`review (Case IPR2016-01264). I dissent from the remainder of the
`
`majority’s decision, including the decision to grant the Motion for Joinder
`
`and to “institute[], join[], and terminate[]” Case IPR2017-00920.
`
`I. The Motion For Joinder Should Not Be Granted
`
`The Motion for Joinder seeks “joinder” of a Global-petitioned inter
`
`partes review with Case IPR2016-01264. Paper 3, 8 (“Global respectfully
`
`requests that its Petition for Inter Partes Review of U.S. Patent No.
`
`6,538,324 B1 be granted and that the proceedings be joined with Taiwan
`
`Semiconductor Manufacturing Company Limited (“TSMC”) v. Godo Kaisha
`
`1
`
`
`

`

`IPR2017-00920
`Patent 6,538,324 B1
`
`IP Bridge 1, Case No. IPR2016-01264.”). But, the statutory sub-section
`
`under which Global seeks relief, 35 U.S.C. § 315(c), does not permit joining
`
`an inter partes review to another inter partes review. Id.; but cf. id. § 315(d)
`
`(referring to “consolidation” of a pending inter partes review and “another
`
`proceeding or matter involving the patent”). Section 315(c) refers to joining,
`
`rather, a “person” “as a party” to an instituted inter partes review. It states
`
`the following:
`
`(c) JOINDER.—If the Director institutes an inter partes review,
`the Director, in his or her discretion, may join as a party to that
`inter partes review any person who properly files a petition
`under section 311
`that
`the Director, after receiving a
`preliminary response under section 313 or the expiration of the
`time for filing such a response, determines warrants the
`institution of an inter partes review under section 314.
`
`35 U.S.C. § 315(c) (emphasis added). Hence, although I concur in the
`
`decision to join Global as co-petitioner in Case IPR2016-01264, I do not
`
`agree with the majority’s decision to grant the Motion for Joinder, which
`
`seeks relief not authorized by § 315(c) and not properly labeled “joinder.”
`
`II. The Petition Should Not Be Granted
`
`Granting a petition for an additional inter partes review is not
`
`necessary to grant joinder. 35 U.S.C. § 315(c). As a prerequisite to joining
`
`a person as a party to an instituted inter partes review, the statute requires
`
`us—as the Director’s delegates6—to determine that the person to be joined
`
`has properly filed a petition that “warrants the institution of an inter partes
`
`
`6 Although § 325(d) refers only to determinations by “the Director,” the
`Director has delegated institution authority to the Board. See 37 C.F.R.
`§ 42.4(a).
`
`
`
`2
`
`

`

`IPR2017-00920
`Patent 6,538,324 B1
`
`review.” Granting the person’s petition (i.e., institution), however, is not a
`
`prerequisite to granting the person’s request for joinder.
`
`And, “a petition to institute an inter partes review” (35 U.S.C.
`
`§ 311(a)) is distinct from “a request for joinder” (35 U.S.C. § 315(b)). In
`
`fact, although “[a]n inter partes review may not be instituted if the petition
`
`requesting the proceeding is filed more than 1 year after the date on which
`
`the petitioner, real party in interest, or privy of the petitioner is served with a
`
`complaint alleging infringement of the patent,” that petitioner may still be
`
`joined to an instituted an inter partes review (if one exists) that was filed by
`
`a different petitioner. 35 U.S.C. § 315(b).
`
`As the majority notes supra, the Petition before us presents the same
`
`grounds of unpatentability as those on which we instituted trial in Case
`
`IPR2016-01264. I would deny the Petition under 35 U.S.C. § 325(d). The
`
`majority implicitly recognizes that an additional inter partes review based
`
`on the Petition would be duplicative of Case IPR2016-01264 and, thus, it
`
`terminates the inter partes review that it institutes. But, the majority does
`
`not explain the legal basis for terminating it. Clearly, Case IPR2017-00920
`
`is not being terminated under 35 U.S.C. § 317. Nor is a final written
`
`decision being entered pursuant to 35 U.S.C. § 318.
`
`I concur with the majority’s decision to join Global as co-petitioner in
`
`Case IPR2016-01264, but I would not grant Global’s Motion for Joinder or
`
`3
`
`its Petition.
`
`
`
`
`
`
`
`

`

`IPR2017-00920
`Patent 6,538,324 B1
`
`PETITIONER:
`
`Christopher P. Carroll
`Shamita D. Etienne-Cummings
`WHITE & CASE, LLP
`christopher.carroll@whitecase.com
`setienne@whitecase.com
`
`
`
`PATENT OWNER:
`
`Neil F. Greenblum
`Michael J. Fink
`Arnold Turk
`GREENBLUM & BERNSTEIN, P.L.C.
`ngreenblum@gbpatent.com
`mfink@gbpatent.com
`aturk@gbpatent.com
`
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`4
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