throbber
Paper No. ____
`Filed: October 11, 2019
`
`
`
`
`
`Filed on behalf of: Visa Inc. and Visa USA Inc.
`By: Matthew A. Argenti
`
`Michael T. Rosato
`WILSON SONSINI GOODRICH & ROSATI
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________________
`
`VISA INC. and VISA U.S.A. INC.,
`APPLE INC.,
`Petitioners,
`
`v.
`
`UNIVERSAL SECURE REGISTRY LLC,
`Patent Owner.
`_____________________________
`
`Case No. IPR2018-013501
`Patent No. 8,856,539
`_____________________________
`
`
`PETITIONERS’ SURREPLY TO PATENT OWNER’S
`CONDITIONAL MOTION TO AMEND
`
`
`
`1 Apple Inc., which filed a petition in IPR2019-00727, has been joined as a
`party to this proceeding.
`
`

`

`
`
`TABLE OF CONTENTS
`
`Page
`
`I. 
`II. 
`
`III. 
`
`iii. 
`
`PO PROPOSES AN UNREASONABLE NUMBER OF CLAIMS ................ 1 
`PO IMPROPERLY REINTRODUCES DISCLAIMED SUBJECT
`MATTER TO AMEND SUBSTITUTE CLAIM 52 ........................................ 1 
`PO’S PROPOSED SUBSTITUTE CLAIMS LACK WRITTEN
`DESCRIPTION SUPPORT ............................................................................. 2 
`A. 
`Limitations 39[c], 48[a], 51[d], and 52[pre]: The specification
`both fails to disclose and is inconsistent with a lack of
`communication between the secure registry and the entity .................. 2 
`i. 
`PO’s citations do not disclose a lack of communications........... 2 
`ii. 
`Limitations 39[c], 48[a], and 52[pre] are not limited to
`“the transaction process” ............................................................. 3 
`The specification’s biometric verification is a
`communication ............................................................................ 4 
`Limitations 46[b] and 52[c] plainly require biometric
`verification prior to receipt of the transaction request, which is
`undisclosed ............................................................................................ 5 
`PO’s citations do not support limitations 40[b] and 46[d] .................... 5 
`Limitation 51[b] lacks written description support for multiple
`entities.................................................................................................... 6 
`IV.  THE SUBSTITUTE CLAIMS ARE OBVIOUS ............................................. 6 
`A. 
`PO’s arguments that Brener does not disclose limitations 39[c],
`48[a], 51[d], and 52[pre] are inconsistent with its written
`description arguments ........................................................................... 6 
`Desai and Pare teach limitations 39[e] and 47[b] ................................. 8 
`Brener and Schneier disclose limitations 40[b] and 46[c][d] ............... 9 
`Brener discloses a “Public ID Code” (limitation 52[f][g]) ................. 11 
`
`B. 
`
`C. 
`D. 
`
`B. 
`C. 
`D. 
`
`-i-
`
`

`

`
`
`V. 
`
`THE SUBSTITUTE CLAIMS DO NOT RECITE PATENT-
`ELIGIBLE SUBJECT MATTER .................................................................. 12 
`VI.  THE PROPOSED SUBSTITUTE CLAIMS ARE INDEFINITE ................. 12 
`VII.  CONCLUSION .............................................................................................. 12 
`VIII.  APPENDIX – LIST OF EXHIBITS .............................................................. 14 
`
`-ii-
`
`

`

`
`
`I.
`
`PO PROPOSES AN UNREASONABLE NUMBER OF CLAIMS
`PO does not dispute that for claims 1-3, 16, 21-24, and 38, PO has proposed
`
`at least two substitute claims in proceedings before the Board. Yet the rule
`
`presumes “that only one substitute claim would be needed to replace each
`
`challenged claim.” 37 C.F.R. § 42.121(a)(3) (emphasis added). The plain
`
`language of the presumption is not limited to a single motion or proceeding.
`
`PO’s refusal to show whether its substitute claims are patentably distinct
`
`from the substitute claims pending in IPR2018-00812 does nothing to address the
`
`conundrum created by two competing motions to amend. If PO wanted to avoid
`
`the dilemma of multiple amendments, it could have requested consolidation or
`
`proposed the same amendments in both IPRs. It is not in the public interest to
`
`grant amendments in one proceeding that potentially would not survive the other.
`
`II.
`
`PO IMPROPERLY REINTRODUCES DISCLAIMED SUBJECT
`MATTER TO AMEND SUBSTITUTE CLAIM 52
`PO’s argument that claim 52’s scope is “entirely different than disclaimed
`
`claims” is conclusory and unexplained. Reply 2-3. Disclaimed claims 5 and 7
`
`recite “credit card account information” and “bank account information,”
`
`respectively. Thus, each has overlapping scope with the substitute claim’s “public
`
`ID number that identifies a financial account number.”
`
`PO also misses the point with respect to its disclaimer of a nearly identical
`
`“public ID code” limitation in the ’137 patent. Both patents have the same
`
`-1-
`
`

`

`
`
`inventor and are directed to very similar subject matter. PO disclaimed a “public
`
`ID code” limitation to avoid a CBM challenge yet now seeks an end-run around
`
`the AIA’s challenges by introducing equivalent subject matter. The Board should
`
`find PO is estopped from engaging in such gamesmanship and lack of candor.
`
`III. PO’S PROPOSED SUBSTITUTE CLAIMS LACK WRITTEN
`DESCRIPTION SUPPORT
`A. Limitations 39[c], 48[a], 51[d], and 52[pre]: The specification both
`fails to disclose and is inconsistent with a lack of communication
`between the secure registry and the entity
`i. PO’s citations do not disclose a lack of communications
`PO cites to ’729 Application 17:27-18:1 and Figure 8 as describing an
`
`embodiment with “no communications between the secure registry and the entity
`
`during the transaction process.” Reply 4. First, PO recognizes that a user
`
`“presents the resultant code to the merchant,” and the merchant sends that code to
`
`the secure registry. Reply 4. PO provides no reason to narrowly construe
`
`“communications” to exclude communications that pass through an intermediary.
`
`Second, PO does not point to any positive disclosure of the claimed lack of
`
`communications during the transaction process. Because the specification is silent,
`
`it fails to allow a POSITA “to recognize the inventor invented what is claimed.”
`
`Q.I. Press Controls, BV v. Lee, 752 F.3d 1371, 1380-81 (Fed. Cir. 2014) (negative
`
`limitation not supported by specification that lacks a positive disclosure); Ex Parte
`
`Nam Khong Then, Appeal 2018-006067, 2019 WL 2244822 at *2 (P.T.A.B. May
`
`-2-
`
`

`

`
`
`8, 2019) (“[T]he Specification lacks affirmative disclosure of the recited negative
`
`limitation.”); c.f. Santarus, Inc. v. Par Pharmaceutical, Inc., 694 F.3d 1344, 1351
`
`(Fed. Cir. 2012) (“Negative claim limitations are adequately supported when the
`
`specification describes a reason to exclude the relevant limitation.”).
`
`Third, with respect to claims 39 and 48 PO argues that “communicating
`
`with” implies a one-way communication. Reply 4-5. But this contradicts the ’539
`
`patent itself, which describes a communication from a USR database “providing an
`
`appropriate code” as a “communication … with the database.” Ex-2008, 10:25-30.
`
`The lack of supporting disclosure alone is enough to reject the amendments.
`
`But the specification also provides multiple examples of communications between
`
`the secure registry and entity. As discussed below, PO’s arguments that these
`
`communications fall outside the claim exclusions are incorrect.
`
`ii. Limitations 39[c], 48[a], and 52[pre] are not limited to “the
`transaction process”
`PO does not dispute that the “training process” is a communication between
`
`the secure registry and the entity. Opp. 4. Instead, PO argues that such
`
`communications are not within the scope of negative limitations 39[c], 48[c], and
`
`52[pre] because they occur “before a transaction is initiated and a provider makes a
`
`request to access secure data.” Reply 5; see also Reply 4 (“no communications …
`
`during the transaction process.”). But the limitations simply refer to a lack of
`
`communication prior to receiving a transaction request. It is irrelevant if the
`
`-3-
`
`

`

`
`
`training process occurs before PO’s artificial delineation of a “transaction process,”
`
`a term only found in claim 51. The training process occurs before “the transaction
`
`request is received,” and therefore supports a lack of written description.
`
`PO’s citation to claim 51 undermines its argument. Claim 51 states the
`
`request is received “during a transaction process initiated after completion of the
`
`training process and termination of communications between the secure registry
`
`and the entity.” CMTA A4. PO knew how to distinguish the training process from
`
`the excluded communication. Claims 39, 48, and 52 make no such distinction.
`
`iii. The specification’s biometric verification is a
`communication
`The specification describes additional communication between the entity
`
`and the secure registry in the form of biometric verification. Opp. 5. In response,
`
`PO argues the substitute claims are broad enough to encompass several
`
`hypotheticals that appear nowhere in the specification. For example, PO concedes
`
`the specification describes storing biometric information in the USR database but
`
`argues the claims do not require such storage. Reply 6. PO also asserts biometric
`
`verification could occur without communication or at another time. Reply 6-8.
`
`Arguing the claims should be broadly interpreted to cover undisclosed
`
`embodiments in no way solves PO’s written description dilemma.
`
`Moreover, none of these arguments addresses the fact that the biometric
`
`verification in the specification is communication between the secure registry and
`
`-4-
`
`

`

`
`
`entity. PO cites to verification done at the point of use, but PO does not address
`
`how verification can take place without the user communicating the necessary
`
`biometric information. See Reply 6-7 (citing Ex-2008, 5:16-17).
`
`B.
`
`Limitations 46[b] and 52[c] plainly require biometric verification
`prior to receipt of the transaction request, which is undisclosed
`
`PO argues that the terms “having been” and “having had” do not
`
`“necessarily … require that biometric verification of the user take place before the
`
`transaction request is received.” Reply 8. PO’s argument is baseless. Claim 46
`
`recites “receiving from the provider a transaction request … for an entity …, an
`
`identity of the entity … having been verified using a biometric.” CMTA A3
`
`(emphasis added); see also id., A5 (claim 52). The plain language facially requires
`
`the verification to occur before receipt of the request or code. PO does not dispute
`
`that this timing requirement lacks written description support.
`
`C.
`
`PO’s citations do not support limitations 40[b] and 46[d]
`
`Limitations 40[b] and 46[d] require use of a “time value representative of
`
`when the time-varying multicharacter code was generated.” CMTA A2, A3. But
`
`PO’s citations to the ’729 Application refer to “the time the number was
`
`received” and “the time of receipt of the code.” Reply 9 (emphasis added by PO).
`
`Plainly, the time of generation and the time of receipt are different things.
`
`Also, rather than identify relevant disclosure for the “mapping” requirement,
`
`PO argues the time value is used to determine the validity of the code. Id. at 9-10.
`
`-5-
`
`

`

`
`
`But PO does not address Petitioner’s argument and evidence that determining
`
`validity is not the same as the recited mapping to the identity of the entity. Opp. 7.
`
`D. Limitation 51[b] lacks written description support for multiple
`entities
`
`Limitation 51[b] requires “a training process by establishing
`
`communications between the secure registry system and the entities.” CMTA A4.
`
`PO cites support for a training process “for a single entity” but does not identify
`
`support for a training process involving multiple entities. Reply 10.
`
`IV. THE SUBSTITUTE CLAIMS ARE OBVIOUS
`A.
`PO’s arguments that Brener does not disclose limitations 39[c],
`48[a], 51[d], and 52[pre] are inconsistent with its written
`description arguments
`
`PO argues Brener does not disclose limitations 39[c], 48[a], 51[d], and
`
`52[pre] because “the customer computer 100 must first login and connect to the
`
`secure provider 110 to … initiate purchase transactions.” Reply 11. Yet PO’s
`
`argument cannot be reconciled with its written description position. In addition,
`
`PO’s arguments mischaracterize Brener and are undermined by PO’s own expert.
`
`If the priority applications support the claimed lack of communication
`
`between the entity and secure registry, Brener does as well. Opp. 9-10. PO does
`
`nothing to refute this, since PO takes inconsistent positions to both argue written
`
`description support and overcome prior art disclosure. PO argues communications
`
`before “a provider makes a request to access secure data” are irrelevant to written
`
`-6-
`
`

`

`
`
`description (Reply 5). By contrast, PO argues Brener’s description of a customer’s
`
`pre-transaction login and connection process fails to disclose the claimed lack of
`
`communication. Reply 12-13. PO cannot have it both ways. PO does not explain
`
`why Brener’s login procedure is a communication excluded by the claims, but the
`
`’729 Application training procedure is not.
`
`Further, PO’s argument that Brener’s customer computer and secure
`
`provider “maintain communications” prohibited by the claims fails for at least two
`
`reasons. First, the only such communication PO identifies is the customer’s use of
`
`the secure connection to “access the vendor computers 140 and carry out purchase
`
`transactions.” Reply 13. But PO’s expert admitted this would be a communication
`
`with the vendor, not the secure provider. Ex-1023, 22:20-23:23 (testifying that a
`
`communication is “with” the “party you’re addressing it to when the message is
`
`just being transmitted” and that “proxies along the line were not communicated
`
`with because they are not the intended recipient”); 50:14-24 (admitting Brener’s
`
`customer computer is “always using the secure computer as a proxy”).
`
`Second, even if the customer’s initial purchase request was deemed a
`
`communication with the secure provider, it is not excluded by the claims because it
`
`occurs before the vendor sends a transaction request to the secure provider. That
`
`is, the customer sends a purchase request through the secure provider to the
`
`vendor, and the vendor subsequently transmits a transaction request to the secure
`
`-7-
`
`

`

`
`
`provider. PO identifies no communication from the user to the secure provider
`
`taking place at the time the vendor sends the transaction request. Reply. 11-15.
`
`The mere fact that the user and secure computer are connected to allow for
`
`communication does not demonstrate that a communication is actually taking place
`
`at the specific time PO argues the claim limitation is directed to. See Ex-1023,
`
`44:2-23 (communication taking place before transaction request is received is “not
`
`part of the process described in the claim”); 53:12-54:9 (Brener’s VPN “enables
`
`communication” but that “doesn’t necessitate” sending messages). Like the ’539
`
`patent, Brener is silent on the communications between customer and secure
`
`provider once a transaction is initiated. If PO is correct that such silence provides
`
`written support, then Brener’s silence likewise discloses the limitations.
`
`PO also argues Petitioner’s reliance on Desai is flawed for failure to explain
`
`how Brener would be modified to eliminate the VPN connection between the
`
`customer computer and the secure provider. Reply 15. But Petitioner never
`
`proposed modifying Brener to remove its VPN functionality, because the VPN
`
`connection does not constitute an excluded communication.
`
`B. Desai and Pare teach limitations 39[e] and 47[b]
`
`PO does not dispute that Desai teaches validating users such as merchants.
`
`Reply 16-18; see also Opp. 10. Instead, PO argues Desai does not need to validate
`
`the merchant’s identity prior to executing a restriction mechanism because
`
`-8-
`
`

`

`
`
`“possession of the correct private key … confirms that the correct party is
`
`accessing the data.” Reply 18. But limitations 39[e] and 47[b] are not limited to
`
`validating a provider in order to cause execution of a restriction mechanism. Thus,
`
`Desai’s disclosure of merchant validation teaches the limitations.
`
`Nevertheless, PO is wrong that Desai’s merchant validation is unrelated to
`
`its data access restrictions. Desai teaches treating registered and unregistered
`
`members differently when determining access rights. See, e.g., Ex-1007, 27:36-
`
`28:17, Figs. 41-42. This includes an embodiment where the system determines
`
`(i.e., validates) whether a user like a merchant is registered before executing a
`
`restriction mechanism. Id., 27:54-28:17, Fig. 42 (step 4304: “Is user a member?”).
`
`If the user is not registered, the user may “be required to go through the sign-up
`
`process.” Id., 27:64-65. This sign-up process involves “enter[ing] a universal
`
`identification code, which may be called a ZKEY [which is] used as the universal
`
`identification code to uniquely identify the new member.” Id., 21:15-18.
`
`PO also argues Petitioner failed to provide a motivation to combine Pare
`
`with other references. Reply 18. But no additional motivation is needed.
`
`Petitioner cited Pare to show it is consistent with Desai, and Petitioner provided a
`
`reason to incorporate validation into the combination. Opp. 10, 17 (explaining
`
`merchant validation was optimal way of incorporating granular access controls).
`
`C. Brener and Schneier disclose limitations 40[b] and 46[c][d]
`
`-9-
`
`

`

`
`
`PO fails to address Schneier’s teachings or Petitioner’s proffered motivation
`
`to combine Brener and Schneier. Opp. 13-14. Instead, PO misrepresents the
`
`teachings of Brener. First, PO argues Brener 13:6-10 only discloses a customer
`
`object containing a digital signature sent to the bank, not the secure provider.
`
`Reply 19-20. Yet Brener also discloses that the vendor can send the customer
`
`object to the secure provider. Ex-1005, 2:19-3:11. PO does not explain why these
`
`two teachings are “not directly attributable to one another.” Reply 19.
`
`Second, PO’s reliance on 16:14-26 as supporting PO’s interpretation of 13:6-
`
`10 is misplaced. See id. at 20. Whereas in 13:6-10 Brener states that the customer
`
`object includes a digital signature, in 16:14-26 Brener describes the bank obtaining
`
`a digital signature subsequent to receipt of the customer object.
`
`Third, PO’s rebuttal argument focuses entirely on payment approval by a
`
`bank and fails to address the anonymous shipping disclosure of Brener cited in the
`
`Opposition. See, e.g., Opp. 13 (citing Ex-1005, 2:19-3:7, 10:14-17).
`
`Fourth, PO argues sending the digital signature to the secure provider is
`
`“unnecessary” because “the secure provider 110 already has authenticated the
`
`identity of the customer using the certificate upon login.” Reply 20-21. PO’s
`
`argument makes little sense. A customer being logged into the secure provider
`
`does not authenticate a customer object received from a vendor, especially as there
`
`may be multiple customers logged in. If the secure provider could ascertain the
`
`-10-
`
`

`

`
`
`identity of a customer from a transaction request merely because the customer is
`
`logged-in, Brener’s entire customer object linking scheme would be unnecessary.
`
`See, e.g., Ex-1005, 16:1-6 (describing confirming “the identity of the purchaser”);
`
`see also id., 8:3-20 (“[T]he linking information can be stored in the database 170
`
`of bank computer 150 so that only the bank, and not the secure provider, actually
`
`knows the true identity and address of the customer.”) (emphasis added).
`
`Thus, Brener discloses that a customer object, which can contain a digital
`
`signature, is sent to the secure provider. PO does not dispute that a POSITA would
`
`be motivated in view of Schneier to include a timestamp in such a signature, or that
`
`this would satisfy the claim limitations.
`
`D. Brener discloses a “Public ID Code” (limitation 52[f][g])
`
`PO argues it is improper to use Brener’s linking information for both the
`
`claimed “mapping … to an identity of the entity” and the claimed “public ID
`
`code.” Reply 21-22. But PO does not explain why the linking information cannot
`
`be used for both purposes. Brener makes clear that the linking information maps to
`
`both customer information and financial information, and can be used by both the
`
`secure provider and bank. See, e.g., Ex-1005, 8:9-14 (“The linking information is
`
`stored … in … secure provider computer 110 [and] matches up each customer
`
`object with the customer’s personal information [such as name and address].”);
`
`9:24-26 (“[T]he linking information … link[s] the customer object with …
`
`-11-
`
`

`

`
`
`customer account information.”); 10:28-11:2; 14:16-22.
`
`V. THE SUBSTITUTE CLAIMS DO NOT RECITE PATENT-ELIGIBLE
`SUBJECT MATTER
`Petitioner improperly incorporates by reference a magistrate judge’s report
`
`and recommendation—not yet adopted by the district court—that analyzes
`
`different claims on a different record. Reply 25; see 37 C.F.R. § 42.6(a)(3). PO’s
`
`remaining arguments are conclusory and do not rebut Petitioner’s undisputed
`
`evidence, analysis, or cited law. See Opp. 21-24. PO did not depose Dr. Tygar on
`
`Ex-1021, nor does PO’s expert address subject matter eligibility in Ex-2011.
`
`VI. THE PROPOSED SUBSTITUTE CLAIMS ARE INDEFINITE
`PO’s arguments do not reconcile the contradiction Petitioner identified for
`
`claims 39, 46, 51, and 52. See Opp. 24-25. Instead, PO provides examples where
`
`the provided information is “a transaction result.” Reply 25. Yet these claims
`
`require this information “to enable transactions.” CMTA A1. PO does not explain
`
`how a transaction result could be used to enable that transaction.
`
`PO also does not dispute limitations 46[b] and 52[c] do not specify “what
`
`location the biometrics are verified at” or who performs the verification. Reply 25.
`
`PO’s expert’s claim that “such breadth does not render the claims indefinite” is
`
`conclusory. Ex-2011, ¶54. Accordingly, the limitations are indefinite.
`
`VII. CONCLUSION
`PO’s Contingent Motion to Amend should be denied.
`
`-12-
`
`

`

`
`
`
`
`
`Dated: October 11, 2019
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/ Matthew A. Argenti /
`Matthew A. Argenti, Lead Counsel
`Reg. No. 61,836
`
`
`
`-13-
`
`

`

`
`
`VIII. APPENDIX – LIST OF EXHIBITS
`
`Description
`Exhibit No.
`1001
` U.S. Patent No. 8,856,539 to Weiss
`
`1002
`
` Declaration of Justin Douglas Tygar, PhD.
`
`1003
`
`
`
`Curriculum Vitae of Justin Douglas Tygar
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`1015
`
`File History for U.S. Patent No. 8,856,539
`
`
` WO 00/14648 to Brener
` U.S. Patent No. 4,885,778 to Weiss
` U.S. Patent No. 6,820,204 to Desai et al.
` WO 01/13275 to Junda et al.
` U.S. Patent Publication No. 2001/0029485 to Brody et al.
` U.S. Provisional Patent Application No. 60/186,166
` Dynamic, Random House Webster’s Unabridged Dictionary,
`Second Edition, 2001
` Dynamic, The American Heritage Dictionary of the English
`Language, Third Edition, 1996
` Dynamic, Academic Press Dictionary of Science and Technology,
`1992
`
`
`
`
`
`Plaintiff’s Answering Brief in Opposition to Defendant’s Motion
`to Dismiss Plaintiff’s Complaint, Case 1:17-cv-00585-JFB,
`September 29, 2017
`
`Transcript of Deposition of Bjorn Markus Jakobsson, Ph.D.,
`August 1, 2019
`
`-14-
`
`

`

`
`
`Exhibit No.
`1016
`
`
`Description
`
`Bruce Schneier, Applied Cryptography, Second Edition:
`Protocols, Algorithms, and Source Code in C, John Wiley &
`Sons, Inc., 1996
`
`1017
`
`
`
`Stuart E. Weiner, “Electronic Payments in the U.S. Economy: An
`Overview,” Federal Reserve Bank of Kansas City, Economic
`Review Fourth Quarter, 1999 (available from www.kc.frb.org)
`
`1018
`
`1019
`
`1020
`
`1021
`
`1022
`
` Matthew Humphries, “Use Apple Pay, Get McDonald’s Fries for
`Free,” PCMag, April 19, 2018
`(https://www.pcmag.com/news/360532/use-apple-pay-get-
`mcdonalds-fries-for-free)
`
`
`
`
`
`
`
`Juli Clover, “Apple Launches New Summertime Savings Apple
`Pay Promotion,” MacRumors.com, July 19, 2018
`(https://www.macrumors.com/2018/07/19/apple-pay-
`summertime-savings-promotion/)
`
`“Payments Volume Growth Boosts Visa’s 2018 Earnings; Key
`Initiatives to Drive Future Value,” Frobes, October 29, 2018
`(https://www.forbes.com/sites/greatspeculations/2018/10/29/pa
`yments-volume-growth-boosts-visas-2018-earnings-key-
`initiatives-to-drive-future-value/#25fabaeb6585)
`
`Second Declaration of Justin Douglas Tygar, Ph.D.
`
` WO 98/04996 to Pare
`
`1023
`
`
`
`Transcript of Deposition of Bjorn Markus Jakobsson, Ph.D.,
`October 1, 2019
`
`
`
`
`
`-15-
`
`

`

`
`
`CERTIFICATE OF SERVICE
`
`I certify that the foregoing Petitioners’ Surreply to Patent Owner’s
`
`Conditional Motion to Amend and Exhibit 1023 were served on this 11th day of
`
`October, 2019, on the Patent Owner at the correspondence address of the Patent
`
`Owner as follows:
`
`James M. Glass
`Tigran Guledjian
`Christopher A. Matthews
`Nima Hefazi
`Richard Lowry
`Razmig Messerian
`QUINN EMANUEL URQUHART & SULLIVAN LLP
`jimglass@quinnemanuel.com
`tigranguledjian@quinnemanuel.com
`chrismathews@quinnemanuel.com
`nimahefazi@quinnemanuel.com
`richardlowry@quinnemanuel.com
`razmesserian@quinnemanuel.com
`qe-usr-ipr@quinnemanueal.com
`
`And on the remaining petitioners as follows:
`
`Monica Grewal
`Benjamin Fernandez
`Mark Selwyn
`WILMER CUTLER PICKERING HALE AND DOOR LLP
`monica.grewal@wilmerhale.com
`ben.fernandez@wilmerhale.com
`mark.selwyn@wilmerhale.com
`wh-apple-usr-ipr@wilmerhale.com
`
`
`
`
`-16-
`
`

`

`
`
`
`
`Date: October 11, 2019
`
`
`
`Respectfully submitted,
`
`
`
`/ Matthew A. Argenti /
`Matthew A. Argenti, Lead Counsel
`Reg. No. 61,836
`
`
`
`
`
`-17-
`
`

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