Case IPR2017-00925 for
`U.S. Patent No. 7,126,174
`
`
`
`Filed on behalf of Godo Kaisha IP Bridge 1
`
`By: Neil F. Greenblum (ngreenblum@gbpatent.com)
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: (703) 716-1191
`Fax: (703) 716-1180
`
`
`
`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 IPR2017-00925
`U.S. Patent No. 7,126,174
`____________
`
`PATENT OWNER’S COMBINED OPPOSITION TO PETITIONER’S
`MOTION FOR JOINDER AND PRELIMINARY RESPONSE
`
`
`Mail Stop PATENT BOARD, PTAB
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`U.S. Patent No. 7,126,174
`
`
`
`Filed on behalf of Godo Kaisha IP Bridge 1
`
`By: Neil F. Greenblum (ngreenblum@gbpatent.com)
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: (703) 716-1191
`Fax: (703) 716-1180
`
`
`
`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 IPR2017-00925
`U.S. Patent No. 7,126,174
`____________
`
`PATENT OWNER’S COMBINED OPPOSITION TO PETITIONER’S
`MOTION FOR JOINDER AND PRELIMINARY RESPONSE
`
`
`Mail Stop PATENT BOARD, PTAB
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`Case IPR2017-00925 for
`U.S. Patent No. 7,126,174
`
`I.
`
`INTRODUCTION
`
`Patent Owner, Godo Kaisha IP Bridge 1 (“IP Bridge”) submits this
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`Combined Opposition To Petitioner’s Motion For Joinder And Preliminary
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`Response (“Opposition”) in response to Petitioner GlobalFoundries, U.S. Inc.’s
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`(“Global U.S.”) Motion for Joinder (Paper 3) and Petition filed in Case IPR2017-
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`00925. Global U.S. seeks to join Case IPR2017-00925 with Case IPR2016-01246,
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`which was instituted on January 4, 2017.
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`A similar Petition and Motion for Joinder were filed by GlobalFoundries,
`
`Inc. (“Global”) in IPR2017-00849. The Petition in this case (IPR2017-00925)
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`filed by Global U.S. states that the Petition filed in IPR2017-00849 will be
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`withdrawn (IPR2017-00925 Petition, p. 88, footnote 15). A call was held with the
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`Board on February 22, 2017 and the Board issued an Order in Cases IPR2017-
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`00753, IPR2017-00757, IPR2017-00849, IPR2017-00850, IPR2017-00919,
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`IPR2017-00920, IPR2017-00925 and IPR2017-00926 authorizing Petitioner to file
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`a motion to dismiss the petition in Cases IPR2017-00753, IPR2017-00757,
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`IPR2017-00849 and IPR2017-00850 within one week of a filing date being
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`accorded to the corresponding Petitions in Cases IPR2017-00919, IPR2017-00920,
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`IPR2017-00925 and IPR2017-00926. Cases IPR2017-00925 and IPR2017-00926
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`were accorded filing dates on February 23, 2017 (Paper 5). Petitioner filed
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`Unopposed Motions to Dismiss Cases IPR2017-00849 and IPR2017-00850 on
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`
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`1
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`
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`March 2, 2017. The Board granted the Motions to Dismiss in Cases IPR2017-
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`00849 and IPR2017-00850 (and in Cases IPR2017-00753 and IPR2017-00757) on
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`Case IPR2017-00925 for
`U.S. Patent No. 7,126,174
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`March 10, 2017.
`
`Petitioner acknowledges that the present Motion for Joinder was “filed after
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`the one month date on which [IPR2016-01246] was instituted under 37 C.F.R. §§
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`42.22 and 42.122(b).” Motion for Joinder (Paper 3), p. 5.
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`II. ARGUMENT
`
`A.
`
`Petitioner’s Motion for Joinder Should Be Denied Because It Was
`Not Timely Filed
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`Joinder is governed by 35 U.S.C. § 315(c), which provides the Director with
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`discretion whether or not to permit a party to join an instituted IPR proceeding:
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`(c) Joinder. - If the Director institutes an inter partes review,
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`the Director, in his or her discretion, may join as a party to that
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`inter partes review any person who properly files a petition
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`under section 311 that the Director, after receiving a
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`preliminary response under section 313 or the expiration of the
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`time for filing such a response, determines warrants the
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`institution of an inter partes review under section 314.
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`The PTAB Rules require that a request for joinder must be filed within one
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`month after the institution date of an IPR proceeding:
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`(b) Request for joinder. Joinder may be requested by a patent
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`owner or petitioner. Any request for joinder must be filed, as a
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`motion under § 42.22, no later than one month after the
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`Case IPR2017-00925 for
`U.S. Patent No. 7,126,174
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`institution date of any inter partes review for which joinder is
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`requested. The time period set forth in § 42.101(b) shall not
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`apply when the petition is accompanied by a request for joinder.
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`37 C.F.R. § 42.122(b)(emphasis added).
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`IPR2016-01246 was instituted on January 4, 2017. Petitioner’s Motion for
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`Joinder was filed February 17, 2017, more than one month after institution of Case
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`IPR2016-01246. The rule governing when a request for joinder can be made
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`specifically requires that “[a]ny request for joinder must be filed . . . no later than
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`one month after the institution date of any inter partes review for which joinder is
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`requested.” 37 C.F.R. § 42.122(b). In other words, joinder with an existing IPR
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`proceeding is permitted only if the joinder request is made within one month of a
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`decision to institute that IPR proceeding.
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`Global U.S. readily admits that its Motion for Joinder was filed more than
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`one month after the institution date of IPR2016-01246. Thus, it is undisputed that
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`the Motion for Joinder is untimely filed. Nothing prevented Global U.S. from
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`filing a timely request to join IPR2016-01246. However, for its own reasons, it did
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`not comply with the rules which require that a joinder request “must be filed … no
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`later than one month after the institution date…” 37 C.F.R. § 42.122(b) (emphasis
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`added). Global U.S. did not provide reasonable justification for excusing its
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`untimeliness.
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`3
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`Case IPR2017-00925 for
`U.S. Patent No. 7,126,174
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`The only reason that Global U.S. provides for filing the duplicative Petition
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`is that TSMC might settle with Patent Owner. See Motion, pp. 4, 8 (“Global is
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`willing to act as an “understudy” to TSMC, only assuming an active role in the
`
`event TSMC settles with IP Bridge.”). Global U.S. could have timely filed its
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`petition as required by 37 C.F.R. § 42.122(b). Global filed a substantially similar
`
`motion for joinder, but then requested dismissal of the petition (Paper 11). Global
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`U.S. has not provided any reason why it could not have timely filed a request for
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`joinder, and having failed to timely do so, must bear the consequences.
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`
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`Global U.S. asserts that (1) Joinder will not impact the Board’s ability to
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`complete the review in a timely manner; (2) Joinder will promote efficiency by
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`consolidating issues, avoiding duplicate efforts, and preventing inconsistencies;
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`and (3) Joinder will not prejudice IP Bridge (Patent Owner). Motion, pp. 7-9.
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`Patent Owner disagrees with these assertions.
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`
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`With respect to the first assertion, joinder could impact the Board’s ability to
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`complete the review in a timely manner. As noted above, neither the Petition nor
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`the Motion for Joinder explains the relationship, if any, between Global and Global
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`U.S., or why it was necessary to withdraw the Petition filed by Global and file
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`another Petition by Global U.S. As such, there may be issues concerning the real
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`party(ies) in interest, which will likely require discovery to resolve. As the Patent
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`Owner’s discovery period will soon close, joinder could require the adjustment of
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`4
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`the schedule, which could impact the Board’s ability to complete the review in a
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`Case IPR2017-00925 for
`U.S. Patent No. 7,126,174
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`timely manner.
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`
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`With respect to the second assertion, joinder will not promote efficiency by
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`consolidating issues, avoiding duplicate efforts, and preventing inconsistencies.
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`Given that the Petition relies on the same prior art, the same arguments, and the
`
`same expert declaration previously presented to the Office, for the reasons set forth
`
`in the following section, the Petition should be denied under 35 U.S.C. § 325(d).
`
`
`
`As for the third assertion, Global U.S. is simply wrong. Permitting Global
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`U.S. to join IPR2016-01246 will prejudice Patent Owner as it would frustrate the
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`possibility of settlement under 35 U.S.C. § 317. Neither Patent Owner nor TSMC
`
`would have an incentive to simplify and streamline the IPR issues via settlement if
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`Global U.S. looms in the background. Thus, permitting Global U.S. to join
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`IPR2016-01246 would unnecessarily burden the Board and harass Patent Owner.
`
`Accordingly, for all of these reasons, Petitioner’s untimely Motion for
`
`Joinder should be denied. 37 C.F.R. § 42.122(b).
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`B.
`
`If The Board Denies The Motion For Joinder, The Board Should
`Deny Institution Of The Petition Under 35 U.S.C. § 325(d)
`
`If the Board denies Petitioner’s Motion for Joinder, the Board should also
`
`deny institution of the Petition pursuant to 35 U.S.C. § 325(d), which in pertinent
`
`part authorizes the Board to reject IPR petitions asserting positions previously
`
`presented:
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`5
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`Case IPR2017-00925 for
`U.S. Patent No. 7,126,174
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`In determining whether to institute or order a proceeding under
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`this chapter, chapter 30, or chapter 31, the Director may take
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`into account whether, and reject the petition or request because,
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`the same or substantially the same prior art or arguments
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`previously were presented to the Office. 35 U.S.C. § 325(d).
`
`The legislative history of Section 325(d) confirms Congress’ intent that the Board
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`can reject duplicative IPR petitions. For example, Senator Jon Kyl stated that
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`Section 325(d) “allows the Patent Office to reject any request for a proceeding,
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`including a request for ex parte reexamination, if the same or substantially the
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`same prior art or arguments previously were presented to the Office with respect to
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`that patent.” 157 Cong. Rec. S1042 (daily ed. Mar. 1, 2011) (Statement of Sen.
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`Kyl). Thus, it is clear that the Board can reject a petition where “the same or
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`substantially the same prior art or arguments previously were presented to the
`
`Office.” 35 U.S.C. § 325(d); see also Office Patent Trial Practice Guide, 77 Fed.
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`Reg. 48756, 48765 (Aug. 14, 2012). The Board’s discretion to deny duplicative
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`petitions is necessary to avoid inefficient and wasteful use of the Board’s resources
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`and time. See 35 U.S.C. § 316(b)(regulations should take into account, inter alia,
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`“the effect of any such regulation on the efficient administration of the Office, and
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`the ability of the Office to timely complete proceedings instituted under this
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`chapter”); 37 C.F.R. § 42.1(b) (“This part shall be construed to secure the just,
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`speedy, and inexpensive resolution of every proceeding.”).
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`6
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`Case IPR2017-00925 for
`U.S. Patent No. 7,126,174
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`The Board has repeatedly exercised its discretion to deny duplicative, late-
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`filed petitions that rely on the same prior art and arguments, on the grounds that it
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`would be a “waste of time, effort, and resources to relitigate the same issues.”
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`Unified Patents, Inc. v. PersonalWeb Techs., LLC, No. IPR2014-00702, Paper 13
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`(PTAB July 24, 2014); see also ZTE Corp. and ZTE (USA) Inc. v. ContentGuard
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`Holdings, Inc., No. IPR2013-00454, Paper 12 (PTAB Sept. 25, 2013); Medtronic,
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`Inc. v. Nuvasive, Inc., No. IPR2014-00487, Paper 8 (PTAB Sept. 11, 2014);
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`Medtronic, Inc. v. Robert Bosch Healthcare Sys., Inc., No. IPR2014- 0436, Paper
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`17 (PTAB June 19, 2014); Initiative for Responsibility in Drug Pricing, LLC v.
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`Wyeth, LLC, No. IPR2014-01259, Paper 8 (PTAB February 13, 2015).
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`Indeed, the Board has recognized that the efficient resolution of IPR
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`proceedings justifies rejecting duplicative petitions even when it prevents a
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`different petitioner from having “an opportunity to submit arguments or evidence
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`with respect to” the challenged patent claims. Unified Patents, Inc. v. PersonalWeb
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`Techs., LLC, No. IPR2014-00702, Paper 13 (PTAB July 24, 2014).
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`Global U.S.’s Petition is a duplicative filing. It is not only substantively
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`duplicative of TSMC’s petition in IPR2016-01246, it is also duplicative of the
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`Petition filed by Global in IPR2017-00849, which was voluntarily dismissed. As
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`Global U.S. admits, the instant Petition mirrors the pending IPR Petition filed by
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`TSMC, challenging the same claims with the same arguments and the same prior
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`art. Motion, p. 5 (The prior art, arguments and evidence in the present Petition
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`“are essentially identical to the grounds for which the Board instituted” IPR2016-
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`01246.). Global U.S. relies on the same expert declaration submitted by TSMC.
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`Global U.S.’s arguments for instituting this duplicative petition are that
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`TSMC might settle, and that its previously filed Petition did not name the correct
`
`real parties-in-interest. These positions have no support in law or policy justifying
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`the late institution of a copied petition. In fact, such an outcome would frustrate the
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`purpose of settlement under 35 U.S.C. § 317; neither party to the previously
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`instituted IPR proceeding has an incentive to simplify and streamline the IPR
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`issues via settlement if the specter of Global U.S.’s copycat Petition looms in the
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`background. Granting Global U.S.’s copied Petition and instituting a proceeding
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`would unnecessarily burden the Board and harass Patent Owner.
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`Instituting an essentially identical IPR proceeding involving the same prior
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`art, the same arguments, and the same evidence further prejudices Patent Owner, if
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`not joined to the earlier IPR proceeding, requiring it to defend multiple
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`proceedings brought by different petitioners. Section 315(c) provides that “the
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`Director, in his or her discretion, may join as a party to that inter partes review any
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`person who properly files a petition … that the Director … determines warrants the
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`institution of an inter partes review…” (Emphasis added). “[I]n determining
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`whether to institute or order a proceeding …, the Director may take into account
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`whether, and reject the petition or request because, the same or substantially the
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`same prior art or arguments previously were presented to the Office.” 35 U.S.C. §
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`325(d)(emphasis added). Under 35 U.S.C. § 325(d), the Board “has broad
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`discretion to deny a petition that raises substantially the same prior art or
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`arguments previously presented to the Office.” Conopco, Inc. v. The Procter &
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`Gamble Co., No. IPR2014-00506, Paper 17, Decision Denying Institution of Inter
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`Partes Review at 6 (PTAB July 7. 2014). Permitting duplicate petitions where
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`joinder is not appropriate, “would risk encouraging parties to engage in a pattern of
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`duplicative filings that harass patent owners.” MaxLinear, Inc. v. Cresta Tech.
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`Corp., Case IPR2015-00593 (Aug. 14, 2015) (Paper 9). “The statutory structure of
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`the America Invents Act includes a more appropriate mechanism for petitioners to
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`assert grounds upon which inter partes review has already been instituted - a
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`request for joinder under 35 U.S.C. § 315(c).” Id. However, as Petitioner did not
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`timely file such a request, joinder should be denied.
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`Accordingly, the Board should reject the Petition because, the same prior art
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`and arguments have been presented to the Office. 35 U.S.C. § 325(d). Global U.S.
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`had the opportunity to join IPR2016-01246 but failed to timely file its request.
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`Global U.S.’s current Petition appears to have been filed to correct an
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`alleged error in naming the real part(ies)-in-interest in an earlier filed petition, but
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`Global U.S. has not been forthright in its efforts. Global originally asserted that
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`there had been a non-substantive clerical or typographical error (IPR2017-00849,
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`Motion to Correct filed February 14, 2017 (Paper 6)), which later proved to be
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`untrue as Global U.S. subsequently represented that it had not named the correct
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`real parties-in-interest in IPR2017-00849. IPR2017-00849 Motion to Dismiss filed
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`March 2, 2017 (Paper 11). Notably, the Motion to Dismiss does not mention the
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`earlier filed Motion to Correct. Such cavalier lack of candor should not be
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`condoned. Additionally, Patent Owner should not be unnecessarily prejudiced in
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`view of Global U.S.’s actions. For these additional reasons, the Board should
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`reject the Petition under 35 U.S.C. § 325(d).
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`C. Petitioner’s Actions Raise Questions As To The Real Party-In-
`Interest
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`Global has manufacturing centers, trusted foundries, R&D offices, design
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`centers, and regional offices around the U.S and the world. See Exhibit 2001, p. 3;
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`Exhibit 2002. Global U.S. has not provided any explanation of the relationship
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`between Global and Global U.S.
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`The only comments made relating to changing Global to Global U.S. were
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`set forth in a Motion to Correct Petition Pursuant to 37 C.F.R. § 42.104(c), filed
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`February 14, 2017 (“Motion to Correct”). The Motion to Correct simply asserted,
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`without providing any supporting facts, that, “This proposed amendment only
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`corrects a non-substantive clerical or typographical error in the petition and would
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`have no substantial substantive effect on the proceedings.” Motion to Correct, p. 2.
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`The Motion to Correct indicated that the filing date should not be affected by the
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`correction. Id.
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`The refiling of the Petition and Motion for Joinder with a new filing date of
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`February 17, 2017, after the one month requirement of §42.122(b), coupled with an
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`indication that the first filed Petition will be withdrawn, certainly suggests that
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`more than an error of a typographical nature was requested to be corrected.
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`Indeed, the Motion to Dismiss filed on March 2, 2017 in IPR2017-00849 (Paper
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`11) establishes that contrary to Petitioner’s representation, it was not merely an
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`“error of a typographical nature” but rather the Petition did not name the correct
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`real parties-in-interest. Also, the Patent Trial and Appeal Board End to End
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`(PTAB E2E) system specifically requires the user to input the real party(ies)-in-
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`interest such that identifying the wrong real party(ies)-in-interest would not likely
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`be a non-substantive clerical or typographical error. Thus, Petitioner’s assertion is
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`further belied by the fact that the act of electronically filing with the PTAB
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`requires confirmation as to the identities of the real parties-in-interest.
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`This raises issues as to who are the real party(ies)-in-interest. In fact, the
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`same requested corrections were filed in IPR2017-00753 and IPR2017-00757. It
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`appears to be strange that the same “error of a typographical nature” was made by
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`two different sets of lead counsel/backup counsel, and the powers of attorney
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`11
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`signed for both Global and Global U.S. were signed by the same person. IPR2017-
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`00849, Papers 1 and 4.
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`Furthermore, in another Petition recently filed by Global U.S. (Case
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`IPR2017-00903), Global U.S. stated that the Petition had been timely filed because
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`it was filed less than one year after the date Broadcom was served with both the
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`summons and the complaint. IPR2017-00903, Paper 2, pp. 87-88. Broadcom is
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`accused of infringing the ‘324 patent in the pending litigation Godo Kaisha IP
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`Bridge 1 v. Broadcom Limited et al., Case No. 2-16-cv-00134 (E.D. Tex. February
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`14, 2016). This litigation has been identified as a related matter in both this Case
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`IPR2017-00925 and Case IPR2017-00903. Case IPR2017-00925, Paper 2, p. 89;
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`Case IPR2017-00903, Paper 2, p. 86.
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`
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`Global U.S.’s statement about Broadcom raises additional concerns
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`regarding the real party(ies)-in-interest, as there is no need for Global U.S. to
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`have mentioned the Broadcom litigation unless the relationship between
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`Global U.S. and Broadcom is such that Broadcom is another real party-in-
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`interest.
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`Issues relating to the real party-in-interest, including potential additional
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`discovery, would not be conducive to help “secure the just, speedy, and
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`inexpensive resolution of every proceeding.” 37 C.F.R. § 42.1(b). Permitting
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`institution and joinder under the present circumstances would appear to
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`unnecessarily waste the Board’s limited resources.
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`Thus, Petitioner’s actions raise questions as to the real party(ies)-in-interest.
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`Moreover, Petitioner’s misrepresentation to the Board about typographical errors
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`suggests the appropriateness of sanctions in addition to termination of this
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`proceeding under the provisions of §325(d).
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`D. If The Board Permits Joinder Over Patent Owner’s Objections, The
`Board Should Do So Only If Global U.S. Agrees To Abide By Certain
`Conditions
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`Patent Owner maintains that the Motion for Joinder should be denied and the
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`Board should dismiss the Petition under 35 U.S.C. § 325(d). However, if the
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`Board were to deny the Motion for Joinder and not dismiss the Petition, Patent
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`Owner would be severely prejudiced by having to defend two IPR proceedings
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`involving the same patents, the same arguments, and the same expert witness. As
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`such, in the event the Board does not dismiss the Petition under 35 U.S.C. §
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`325(d), the Board should permit joinder provided Global U.S. agrees to abide by at
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`least certain conditions.
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`Global U.S.’s proposal “to remain in a circumscribed ‘understudy’ role
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`without a separate opportunity to actively participate,” (Motion, p.8) should be
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`further limited, and Global U.S. should be required to further agree that it will not
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`file additional written submissions, nor will Global U.S. pose questions at
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`depositions or argue at oral hearing without the prior permission of the Board,
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`rather than permission of TSMC as proposed. Requiring permission from only
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`TSMC would make it very easy for Global U.S. to take an active role, thereby
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`circumventing its agreement to remain in an understudy role “without a separate
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`opportunity to actively participate.” Moreover, Global U.S. stated: “Only in the
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`event that TSMC settles will Global [U.S.] seek to become active in the joined
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`IPR.” Motion, p. 8.
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`Furthermore, the Board should require Global U.S. to agree to abide by the
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`following conditions which are consistent with its proposal:
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`1. Global U.S. agrees to proceed based solely on the arguments and evidence
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`presented and maintained by TSMC in IPR2016-01246.
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`2. Global U.S. consents to being added to the case caption of IPR2016-01246
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`as a Petitioner without any active participation or involvement that is
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`separate from TSMC.
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`3. Global U.S. agrees to remain in a circumscribed “understudy” role in
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`IPR2016-01246 without any right to separate briefing or discovery. Global
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`U.S. will not file additional written submissions, not pose questions at
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`depositions and not argue at oral hearing without the prior authorization of
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`the Board.
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`4. TSMC will conduct cross-examination and other discovery on behalf of
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`TSMC and Global U.S., and Patent Owner is not required to provide
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`separate discovery responses or additional deposition time as a result of the
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`consolidation.
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`5. Global U.S. will seek authorization from the Board to become active in
`
`IPR2016-01246 only in the event that TSMC settles.
`
`6. Global U.S. acknowledges that the estoppel provisions of 35 U.S.C. § 315(e)
`
`will be applicable to it even if it remains in a circumscribed “understudy”
`
`role.
`
`Patent Owner will be prejudiced if Global U.S. is permitted to join IPR2016-
`
`01246. If the Board is inclined to permit Global U.S to join IPR2016-01246, in an
`
`attempt to limit the prejudice to Patent Owner, the Board should require Global
`
`U.S. to agree to abide by the above conditions before permitting it to join
`
`IPR2016-01246.
`
`III. CONCLUSION
`
`For the foregoing reasons, the Board is respectfully requested to deny the
`
`motion for joinder and deny institution of the Petition under 35 U.S.C. § 325(d).
`
`Dated: March 15, 2017
`
`Respectfully submitted by:
`
`/Neil F. Greenblum/
`Neil F. Greenblum
`Registration No. 28,394
`Greenblum & Bernstein, P.L.C.
`
`
`
`
`
`15
`
`
`
`Case IPR2017-00925 for
`U.S. Patent No. 7,126,174
`
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: 703-716-1191
`Fax: 703-716-1180
`Email: ngreenblum@gbpatent.com
`
`Attorney for Patent Owner, IP Bridge
`
`
`
`16
`
`{J709907 03045974.DOC 2}
`
`
`
`Case IPR2017-00925 for
`U.S. Patent No. 7,126,174
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true copy of the foregoing:
`
`PATENT OWNER’S COMBINED OPPOSITION TO PETITIONER’S
`MOTION FOR JOINDER AND PRELIMINARY RESPONSE
`
`was served by electronic mail on this 15th day of March, 2017, upon Counsel for
`
`Petitioner, as follows:
`
`Kent J. Cooper (kent.cooper@kjcooperlaw.com);
`and Adam Floyd (floyd.adam@dorsey.com).
`
`
`
`
`/Neil F. Greenblum/
`Neil F. Greenblum
`Registration No. 28,394
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: 703-716-1191
`Fax: 703-716-1180
`Email: ngreenblum@gbpatent.com
`
`
`
`
`
`
`
`
`
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