IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTS INC.
`
`Petitioner
`
`V.
`
`SILVER STATE INTELLECTUAL TECHNOLOGIES, INC.
`
`Patent Owner
`
`Case N0.: IPR2017~01531
`
`Patent No. 7,650,234
`
`PATENT OWNER’S PRELIMINARY RESPONSE
`
`PURSUANT TO 37 CFR §42.107
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTS INC.
`
`Petitioner
`
`V.
`
`SILVER STATE INTELLECTUAL TECHNOLOGIES, INC.
`
`Patent Owner
`
`Case N0.: IPR2017~01531
`
`Patent No. 7,650,234
`
`PATENT OWNER’S PRELIMINARY RESPONSE
`
`PURSUANT TO 37 CFR §42.107
`
`
`
`TABLE OF CONTENTS
`
`INTRODUC I ION ............................................................................................... 6
`
`THE PETITION SHOULD BE SUMMARILY DISMISSED FOR
`
`SEEEKING TO IMPROPERLY WASTE THE BOARD’S AND PATENT
`
`OWNER’S RESOURCES ......................................................................................... 7
`
`A. The Petition Seeks To Resolve A Controversy That Has Already Been
`
`Resolved ................................................................................................................. 7
`
`B. The Petition Is The First Of Multiple Petitions Copied From Previously—
`
`terminated IPRs ...................................................................................................... 9
`
`C. The Board Is Well Within Its Authority And Board Precedent In Refusing To
`
`Waste Its Resources By Granting The Petition .................................................... 10
`
`D. Denying Unified’s Petition Would Not Unfairly Burden Unified, And Would
`
`Protect The Integrity Of The Office ..................................................................... 13
`
`III.
`
`PATENT OWNER DOES NOT CONSENT TO INTER PARTES REVIEW,
`
`WHICH MAY BE UNCONSTITUTIONAL ......................................................... 15
`
`IV. CONCLUSION .............................................................................................. 19
`
`
`
`TABLE OF AUTHORITIES
`
`CASES
`
`Blue Coat Systems LLC v Finjan, Inc.
`IPR2016—01443 ................................................................... 11-12,14
`
`Google Inc. v. Silver State Intellectual Technologies, Inc.
`IPR2015—01737 .......................................................................... 7, 8
`
`Google Inc. v. Silver State Intellectual Technologies, Inc.
`IPR2015—01738 ................................................................... 7, 8, 9, 12
`
`Google Inc. v. Silver State Intellectual Technologies, Inc.
`IPR2015-01746 .......................................................................... 7, 8
`
`Google Inc. v. Silver State Intellectual Technologies, Inc.
`IPR2015~01747 ......................................................................... 7, 8
`
`Google Inc. v. Silver State Intellectual Technologies, Inc.
`IPR2015—01748 ......................................................................... 7, 8
`
`Oil States Energy Services, LLC v. Green’s Energy Group, LLC
`Case 16—712(U.S. June 12, 2017) ...................................................... 14
`
`Samsung Electronics Co., Ltd. v Nvidia Corporation
`IPR2015~01270&IPR2015-01314 .................................................... 11
`
`Unified Patents Inc. v. Silver State IntelleCtual Technologies, Inc.
`IPR2017—01531 ....................................................................... 9, 12
`
`Zetec, Inc. v Westinghouse Electric Company, LLC,
`IPR2014—00384 ........................................................................... 10
`
`
`
`TABLE OF AUTHORITIES - continued
`
`STATUTES
`
`35 U.S.C. §314 ............................................................................... 10
`
`35 U.S.C. §316 ............................................................................... 11
`
`OTHER AUTHORITIES
`
`37 CFR §42.23 ................................................................................. 5
`
`37 CFR §42.71 ............................................................................... 11
`
`37 C.F.R §42.107 ............................................................................. 6
`
`
`
`STATEMENT OF MATERIAL FACTS IN DISPUTE
`
`Petitioner Unified Patents Inc. (hereinafter “Unified”) did not submit a
`
`statement of material facts in its Petition. Accordingly, no response is due pursuant
`
`to 37 C.F.R §42.23(a), and no facts are admitted.
`
`
`
`Case No.: IPR2017-01531
`
`Patent No.: 7,650,234
`
`INTRODUCTION
`
`Pursuant
`
`to 37 C.F.R §42.107,
`
`this paper presents the Patent Owner’s
`
`Preliminary Response to the Petitioner’s Petition for Inter Partes Review of US.
`
`Patent No. 7,650,234. For at least the reasons discussed herein, Patent Owner
`
`submits that the requested Review should not be instituted, and in any event Patent
`
`Owner does not consent to this proceeding.
`
`The Inter Partes Review process was instituted to help resolve patent disputes
`
`in a more efficient manner. Over the years, the Board has recognized instances in
`
`which lPRs have been used inappropriately and in a manner that wastes both the
`
`Board’s and Patent Owner’s resources without providing any real benefit.
`
`In such
`
`cases, the Board has refused to institute, and has even dismissed, unnecessary and
`
`inappropriate IPRs.
`
`The present Petition is an example of an inappropriate Petition that is destined
`
`to cost both the Board and the Patent Owner substantial resources without providing
`
`any benefit. As discussed in more detail below, Petitioner Unified appears to be
`
`adopting a practice in which it copies Petitions from proceedings that were resolved
`
`and terminated long ago. Thus, Petitioner seeks Inter Partes Review of patent issues
`
`that have already been resolved, and regarding which there is no dispute in need of
`
`
`
`Case No.: IPR2017—0153l
`
`Patent No.: 7,650,234
`
`resolution. This is a blatant waste of both the Board’s and Patent Owner’s resources,
`
`which waste is an abuse of the IPR process that the Board should not countenance.
`
`Unified’s inappropriate and wasteful Petition should be dismissed.
`
`THE PETITION SHOULD BE SUMMARILY DISMISSED FOR
`
`SEEEKING TO IMPROPERLY WASTE THE BOARD’S AND PATENT
`
`OWNER’S RESOURCES
`
`A.
`
`The Petition Seeks To Resolve A Controversy That Has Already
`
`Been Resolved
`
`As noted by Petitioner, in 2015, Patent Owner sued Google for infringement
`
`of the ‘234 Patent and several other patents. As part of its response, Google filed
`
`IPR Petitions for the ‘234 Patent (see IPR2015-01738) as well as four other patents
`
`involved in the lawsuit, which patents and associated IPRs are listed below
`
`(collectively, the “Google IPRs”):
`
`US Patent 6,525,768
`IPR 2015—01737
`
`
`IPR2015—01746
`
`
`US Patent 6,529,824
`
`US Patent 8,700,312
`
`US Patent 8,538,498
`lPR2015-Ol747
`
`
`IPR2015—Ol 748
`
`
`
`Case No.2 IPR2017—01531
`
`Patent No.: 7,650,234
`
`The Google lawsuit was settled, and as there were no longer any disputes in
`
`connection with any of these patents, each of these IPRs was appropriately
`
`terminated in the preliminary stages on joint motion of the parties. See IPRZOIS—
`
`01747 (Paper 9); IPR 2015—01737 (Paper 9); IPR2015—01746 (Paper 9); IPR2015—
`
`01738 (Paper 9); IPR2015~01748 (Paper 9).
`
`Since the Google lawsuit was settled there have been no further actions in
`
`connection with the ‘234 Patent or any of the other patents for which Google filed
`
`Petitions. Patent Owner has taken no action to enforce any of these patents against
`
`any party, and has had no communication at all to that effect with Petitioner Unified.
`
`Further, Unified does not even appear to make any product that could possibly
`
`infringe the ‘234 Patent or the other patents from the Google IPRs. There simply is
`
`no dispute in connection with the ‘234 Patent.
`
`Notwithstanding the lack of any dispute, Petitioner has now obtained and
`
`copied Google’s Petition. Indeed, the outstanding Petition is nearly a word-for—word
`
`copy of Google’s Petition in IPR2015—01738.
`
`Since the only dispute concerning the ‘234 patent has long been resolved, and
`
`since Unified does not infringe the ‘234 patent — and indeed could never infringe the
`
`‘234 patent — the present Petition, if granted, would not resolve any valid patent
`
`dispute, and will simply lead to a proceeding that will waste the Board’s and the
`
`
`
`Case N0.: IPR2017—01531
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`Patent N0.: 7,650,234
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`Patent Owner’s resources. In addition, there would be no prejudice to Petitioner or
`
`to the public if the Board declines to waste its time on the present Petition. For
`
`example, if any such dispute ever arose in the future, Unified, or a third party, could
`
`simply do as Unified has done here, and copy the Google petition (or add to it, for
`
`example, by citing to art not already before the USPTO during examination of the
`
`underlying application).
`
`B.
`
`The Petition Is The Second Of Multiple Petitions Copied From
`
`Previously-terminated IPRs
`
`The present Petition is the second step down a slippery slope of multiple
`
`unnecessary IPRs. Shortly before filing this Petition, Unified filed a Petition in
`
`IPR2017—Ol 198 challenging Patent Owner’s US Patent 8,538,498, which is another
`
`of the 5 patents asserted against Google.
`
`In the earlier Petition, Unified copied
`
`substantially word—for—word the Petition filed by Google in IPR2015-Ol747. As in
`
`the current proceeding, the patent dispute underlying lPR2015—01747 was resolved
`
`long ago and no enforcement activity has taken place since the Google lawsuit was
`
`settled. Also, Unified not only has never been accused of infringement, but makes
`
`no products and is incapable of infringing.
`
`If the Board countenances Unified’s Petition in this instance and in the prior
`
`Petition, it seems likely that Unified will be emboldened to file recycled petitions
`
`
`
`Case No.: IPR2017—0153l
`
`Patent No.2 7,650,234
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`copying the rest of the Google IPRs, for a total of FIVE pointless IPRs that recycle
`
`Petitions from long—resolved proceedings, leading to a colossal waste of the Board’s
`
`and Patent Owner’s resources.
`
`C.
`
`The Board 15 Well Within Its Authority And Board Precedent
`
`In Refusing To Waste Its Resources By Granting The Petition
`
`The Board has considerable discretion in deciding whether to institute an Inter
`
`Partes Review. The Board should exercise its considerable discretion to protect its
`
`limited resources, and ensure its effort is applied to proceedings that will lead to
`
`resolution of real disputes.
`
`As noted by the Board in Zetec, Inc. v Westinghouse Electric Company, LLC,
`
`IPRZOl4—00384, Paper 10, at p. 5, “The standard for institution is written in
`
`permissive terms——identifying when the United States Patent and Trademark Office
`
`(‘the Office’) is authorized to institute an inter partes review. Thus, Congress has
`
`given the Office discretion whether to institute a review or not institute a review.”
`
`(Citing 35 U.S.C. §3l4(a)).
`
`In Zetec, the Board determined that the Petition “would place a significant
`
`burden on the Board and contravene the efficient administration of the Office.” See
`
`Zetec at p. 15. Thus, the Board “decline[d] to expend our resources”, and denied the
`
`Petition. Zetec at p. 15.
`
`
`
`Case N0.: lPRZOl7~OlS3l
`
`Patent N0.: 7,650,234
`
`There is much authority supporting the Board’s discretion to avoid instituting
`
`wasteful, inappropriate, and even abusive lPRs. Congress intended IPRs to solve
`
`real problems, and thus contemplated steps to prevent abuse of the process, “or any
`
`other improper use ofthe proceeding, such as to harass or to cause unnecessary delay
`
`or an unnecessary increase in the cost of the proceeding.” 35 U.S.C. §3l6(a)(6).
`
`Congress also specifically directed the Office to consider the effects of such
`
`proceedings on “the integrity of the patent system, [and] the efficient administration
`
`ofthe Office .
`
`.
`
`.
`
`35 use. §316(b).
`
`Thus, when the Board detects that an IPR proceeding is being used in a way
`
`that is improper or that compromises the efficient administration of the Office (e.g.,
`
`wastefully expends the Office’s resources), the Board is well within its discretion to
`
`decline to waste its precious resources on an improper proceeding.
`
`The Board has previously used its discretion to avoid lPRs that would subject
`
`the Board and the parties to unnecessary expense. Citing 37 C.F.R. §42.7l(a), the
`
`panel in Samsung Electronics Co, Ltd. v sz‘dz‘a Corporation noted that “the rules
`
`do provide us the discretion to ‘take up petitions or motions for decisions in any
`
`order’ and to ‘grant, deny, or dismiss any petition or motion’ or enter any appropriate
`
`order.” IPR2015~01270 & IPR2015—013l4, Paper ll, at p. 3. See also Id. at p. 2
`
`
`
`Case No.: IPR2017—0153l
`
`Patent No.2 7,650,234
`
`(Board terminated proceedings to “preserve both the Board’s and parties’
`
`resources” .
`
`Several panels of the Board have weighed the “finite resources of the Board”
`
`in deciding to exercise discretion not to institute review. See Blue Coat Systems LLC
`
`v Finjan, Inc. IPR2016—01443, Paper 10, at pp. 8—9 (Discussing factors and citing
`
`several other cases considering similar factors).
`
`Also, as discussed above, the present IPR represents the second step on a
`
`slippery slope for the Board. In total, 5 Petitions for Inter Partes Review were filed
`
`by Google in connection with 5 patents asserted in the now—settled lawsuit. All 5
`
`Google IPRs were appropriately terminated after the lawsuit was settled. As
`
`discussed above, Unified’s current Petition regarding the ‘234 Patent is the second
`
`Petition that simply recycles, substantially word-for—word, Google’s previous
`
`Petition. So far, then, Unified has recycled two of the five Google IPRs. It seems
`
`that Unified is testing the Board to see whether it will countenance such pointless
`
`IPRs, and will recycle the other 5 Google IPRs if it believes it can get away with it.
`
`If the Board countenances Unified’s improper Petition in this case, the Board
`
`likely can anticipate a total of 5 similarly improper recycled Inter Partes Reviews
`
`inspired by the long~settled Google lawsuit.
`
`In connection with each of these
`
`potentially FIVE trials that Unified seems intent to pursue, the parties will incur
`
`
`
`Case No.: IPR2017—0153l
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`Patent No.: 7,650,234
`
`substantial expense in preparing and presenting expert declarants for deposition,
`
`submitting substantive briefs and motions, and presenting at an oral hearing. The
`
`Board will also have to expend substantial resources, likely being requested to
`
`address various procedural disputes, address potential requests for additional
`
`discovery, preside over an oral hearing, and draft a substantive decision on
`
`institution and a final written decision on the merits.
`
`If trial is instituted, a substantial portion of the Board’s and Patent Owner’s
`
`resources will be dedicated to resolving a non—existent patent dispute that was, in
`
`fact, resolved long ago.
`
`This colossal waste of resources can be avoided if the Board exercises its
`
`discretion to decline to institute trial in response to the present Petition.
`
`Denying Unified’s Petition Would Not Unfairly Burden
`D.
`Unified, And Would Protect The Integrity Of The Office
`
`Should the Board decide not to institute trial, Unified is not without recourse.
`
`Unified can request a rehearing,
`
`in which it can explain why instituting this
`
`proceeding would not be a colossal waste of the Board’s (and Patent Owner’s) finite
`
`resources, and why recycling Google’s petition from the long—resolved patent
`
`dispute maintains the integrity of the Office. Given the facts currently before us, it
`
`seems reasonable for the Board to deny the Petition and require Unified to explain
`
`
`
`Case No.11PR2017—0153l
`
`Patent No.: 7,650,234
`
`itself. If Unified’s justification is sound, it may still obtain the relief it seeks.
`
`If, as
`
`suspected, Unified has no valid justification for filing the recycled Google lPRS, and
`
`this Petition in particular, then the Board can save substantial resources to be applied
`
`to resolving actual disputes, and Patent Owner will be relieved from incurring
`
`hundreds of thousands of dollars of expenses defending against a nonexistent
`
`controversy.
`
`Unified also has other options. For example, there have been instances in
`
`which a Petitioner has been permitted to file a Reply after a Preliminary Response
`
`in order to explain itself. See Blue Coat Systems LLC v Finjan, Inc. IPR2016—01443,
`
`Paper 13, at p. l. Patent Owner would be amenable to Unified being given such an
`
`opportunity. If Unified is unable or unwilling to explain why its suspicious recycling
`
`of terminated IPR Petitions related to long-resolved patent disputes justifies tying up
`
`substantial Board and Patent Owner resources, trial should not be instituted.
`
`The resources at stake for both Patent Owner and the Board are substantial.
`
`Petitioner Unified must not be allowed to misuse the IPR process to “resolve” issues
`
`that were resolved long ago and are currently moot. At the very least, Unified must
`
`explain its suspicious actions of recycling petitions from long—resolved proceedings
`
`in which there is no current dispute.
`
`
`
`Case No.: IPR2017—01531
`
`Patent No.: 7,650,234
`
`III.
`
`PATENT OWNER DOES NOT CONSENT TO INTER PARTES
`
`REVIEW, WHICH MAY BE UNCONSTITUTIONAL
`
`Patent Owner notes that the Supreme Court has granted a petition for writ of
`
`certiorari to address whether Inter Partes Review is unconstitutional. See Oil States
`
`Energy Services, LLC v. Green’s Energy Group, LLC, Case 16~712 (U.S. June 12,
`
`2017). Patent Owner wishes to clarify that it does not consent to its inclusion in the
`
`current Inter Partes Review proceeding.
`
`IV.
`
`PETITIONER MISCHARACTERIZES CLAIM TERMS
`
`Perhaps recognizing that its cited art does not teach or suggest the claimed
`
`invention, Petitioner seeks to convince the Board that claim terms should be
`
`construed in a manner that completely changes the meaning of the terms.
`
`Petitioner’s attempt to change the meaning of claim terms should be rejected by the
`
`Board.
`
`A.
`
`“Searching the database” means “searching the database”
`
`All of the independent claims (Claims 1, 9, 17 and 24) recite the phrase
`
`“searching the database.” Petitioner Unified seeks to construe this phrase as
`
`“analyzing data from the database.” Clearly, “searching” and “analyzing data” have
`
`different meanings. Thus, adopting Petitioner’s proposed construction would change
`
`
`
`Case No.: lPR2017—01531
`
`Patent No.: 7,650,234
`
`Patent Owner proposes that “searching the database” be given its normal and
`
`ordinary meaning. Searching a database is a well—known, well understood operation.
`
`A person of ordinary skill in the art, if asked what was entailed in the step of
`
`searching a database for some information, would surely understand that the step
`
`entails looking for certain information in a computer database. This phrase needs
`
`no re—definition.
`
`The law is clear that a patentee may act as his own lexicographer, but if the
`
`patentee wishes for a term to carry a meaning that differs from its normal and
`
`ordinary meaning, the patentee must clearly demonstrate his intent to redefine the
`
`term. There is no such redefinition of “searching the database” in the ‘234 patent.
`
`Thus, the well—understood term “searching the database” must retain its normal and
`
`ordinary meaning. The specification, such as at least at col. 7, l. 19 — col. 8, l. 55,
`
`discusses that servers 622 and 630, receive a request from a processor 103, and in
`
`response obtain information from numerous databases.
`
`It goes without saying that
`
`in order to obtain such information, the servers must first look for and locate it, which
`
`of necessity involves “searching the database” for that information. The ‘234
`
`specification clearly supports the plain meaning of the phrase “searching the
`
`database.”
`
`
`
`Case N0.: IPR2017-01531
`
`Patent No.: 7,650,234
`
`If an IPR is instituted, the Board must not change the meaning of the well~
`
`known, well—understood, clear, common, and fully—supported phrase “searching the
`
`database,” but should instead allow this phrase to retain its normal and ordinary
`
`meaning.
`
`THE CITED REFERENCES DO NOT TEACH OR SUGGEST ALL
`
`OF THE CITED LIMITATIONS
`
`Petitioner bases each and every one of Grounds 1—4 on US Patent No.
`
`6,401,027 to Xu (Exh. 1004). However, Xu does not teach or suggest the limitations
`
`that Petitioner claims it does, and is not likely to impact the validity of the ‘234
`
`claims.
`
`Xu teaches a system that builds a database of historic traffic patterns and
`
`develops predicted traffic based on historic averages (see col. 11, l. 61 — col 12, l.
`
`25). Such predictions are broadcast, and such broadcasts are received and stored by
`
`in-vehicle devices 21 (col. 13, 11. 22—50).
`
`Petitioner appears to admit that Xu does not teach “searching the database” in
`
`the manner recited in the claims. Indeed, Petitioner refers to Xu’s in—vehicle device
`
`21 as “analyzing” information that it has received in a broadcast of information.
`
`Petitioner does not even try to characterize such “analyzing” as “searching the
`
`
`
`Case No.: IPR2017-0153l
`
`Patent No.: 7,650,234
`
`does not teach at least this requirement. As such, Xu cannot anticipate any of Claims
`
`1, 9, l7 and 24, or the claims that depend therefrom.
`
`As Petitioner has implied, Patent Owner also has strong arguments that the
`
`“flagged geographical block including the location of in—vehicle device 21 in Xu do
`
`not correspond to a ‘coverage area,’ as claimed.” (Petition at 49). While Patent
`
`Owner does not here discuss such arguments in depth, this argument, and others,
`
`further demonstrate that Xu cannot anticipate the claims.
`
`Notably, Ground 2 combines US Patent No. 5,835,881 to Trovato with Xu in
`
`a challenge of dependent Claims 8, 16, 22 and 29. However, Trovato does not cure
`
`the failings of Xu in connection with the base independent claims from which these
`
`claim depend, and thus the Xu/Trovato combination does not teach or suggest all of
`
`the limitations of Claims 8, 16, 22 and 29.
`
`In Grounds 3 and 4, Petitioner further adds US. Patent No. 5,933,100 to
`
`Golding to the combination in an effort to cure the failings of Xu. However, Patent
`
`Owner submits that the devices in these references operate substantially differently
`
`from one another and are not properly combinable, and even if combined they would
`
`not teach or suggest all the recited limitations of the ‘234 claims.
`
`
`
`Case No.: IPR2017—0153l
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`Patent No.: 7,650,234
`
`VI. CONCLUSION
`
`For the foregoing reasons, Unified’s Petition amounts to an unacceptable and
`
`improper use of the Inter Partes Review process which, if countenanced by the
`
`Board, will lead to the filing of at least five pointless IPR proceedings that will waste
`
`substantial portions of the Board’s and the Patent Owner’s resources without
`
`resolving any real patent—related dispute. At the very least, Unified should be
`
`required to explain why the Board should countenance its suspicious practice of
`
`copying Petitions from long-terminated IPRs associated with controversies that have
`
`long been resolved to challenge patents that are not in dispute. Denying institution,
`
`while inviting Unified to explain why this suspicious Petition will help resolve a real
`
`dispute, will not unfairly burden Unified.
`
`Further, Petitioner’s cited references, taken alone or in combination, do not
`
`teach or suggest all of the limitations recited in the claims.
`
`
`
`Case No.: lPR2017—01531
`
`Patent No.: 7,650,234
`
`The Board should deny Unified’s Petition in its entirety and not institute
`
`proceedings in this matter.
`
`Respectfully submitted,
`
`Klein, O’Neill & Singh, LLP
`
`Dated:
`
`September 12, 2017
`
`By
`
`/Glen L Nuttall/
`Glen L. Nuttall
`
`Glen L. Nuttall (Reg. No. 46,188)
`Daniel M. Cavanagh (Reg. No. 41,661)
`KLEIN, O’NEILL & SINGH, LLP
`16755 Von Karman, Suite 275
`Irvine, CA 92606
`
`Main: (949) 955-1920
`Fax: (949) 955-1921
`gnuttall@koslaw.com
`dcavanagh@koslaw.com
`Counselfor Patent Owner Silver
`State Intellectual Technologies,
`Inc.
`
`
`
`Case No.: IPR2017—01531
`
`Patent No.: 7,650,234
`
`CERTIFICATE OF SERVICE IN COMPLIANCE WITH 37 CFR §42.6(e)(4)
`
`The undersigned certifies that a complete copy of this PATENT OWNER’S
`
`PRELIMINARY RESPONSE UNDER 37 CFR §42.107 is being served by
`
`electronic mail, by agreement of the parties, on September 12, 2017 to:
`
`Petitioner’s lead counsel Ashraf A. Fawzy by email to the following email
`
`address: afawzy@unifiedpatents.com; and
`
`Petitioner’s back-up counsel Jonathan Stroud by email to the following email
`
`address: jonathangQunifiedpatents.com.
`
`Lead and back—up counsel both have the following street address: 1875
`
`Connecticut Ave. NW, Floor 10, Washington, DC, 20009.
`
`By
`
`/ Glen L Nuttall/
`Glen L Nuttall (Reg. No. 46,188)
`Daniel M. Cavanagh (Reg. No. 41,661)
`KLEIN, O’NEILL & SINGH, LLP
`
`16755 Von Karman, Suite 275
`
`Irvine, CA 92606
`
`
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