`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`Canon Inc., Canon U.S.A., Inc., and Axis Communications AB,
`
`Petitioners,
`
`v.
`
`Avigilon Fortress Corporation,
`
`Patent Owner.
`______________________
`
`Case No. IPR2019-00314
`
`U.S. Patent No. 7,932,923
`______________________
`
`
`PATENT OWNER’S OPPOSITION TO PETITIONERS’ MOTION TO
`SUBMIT SUPPLEMENTAL INFORMATION UNDER 37 C.F.R. § 42.123(a)
`
`
`
`
`
`
`Patent Owner’s Opp. to Petitioners’ Mot. to Submit Supp. Info.
`IPR2019-00314
`
`I.
`II.
`
`TABLE OF CONTENTS
`INTRODUCTION ......................................................................................... 1
`PETITIONERS’
`EXHIBITS
`ARE
`PROPERLY
`CHARACTERIZED AS SUPPLEMENTAL EVIDENCE, NOT
`SUPPLEMENTAL INFORMATION ......................................................... 2
`III. EVEN IF THE EXHIBITS ARE NOT SUPPLEMENTAL
`EVIDENCE, PETITIONERS’ MOTION SHOULD STILL BE
`DENIED .......................................................................................................... 3
`A.
`Petitioners Improperly Attempt To Submit Exhibits 1049, 1051,
`And 1053 Without The Board’s Authorization. .................................... 3
`Petitioners’ Remaining Requests Should Also Be Denied. .................. 6
`B.
`IV. CONCLUSION .............................................................................................. 9
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`i
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`
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`Patent Owner’s Opp. to Petitioners’ Mot. to Submit Supp. Info.
`IPR2019-00314
`
`PATENT OWNER’S EXHIBIT LIST
`
`Description
`
`ii
`
`Exhibit
`No.
`2001 Declaration of Michael W. De Vries in Support of Unopposed Motion
`to Appear Pro Hac Vice on Behalf of Patent Owner Avigilon Fortress
`Corporation.
`
`2002 Declaration of Adam R. Alper in Support of Unopposed Motion to
`Appear Pro Hac Vice on Behalf of Patent Owner Avigilon Fortress
`Corporation.
`
`2003 Declaration of Akshay S. Deoras in Support of Unopposed Motion to
`Appear Pro Hac Vice on Behalf of Patent Owner Avigilon Fortress
`Corporation.
`
`37 C.F.R. § 1.132 Declaration of Kenneth A. Zeger (excerpt of U.S.
`Patent No. 7,868,912 Reexamination).
`
`Thomas Olson & Frank Brill, Moving Object Detection & Event
`Recognition Algorithms for Smart Cameras, 1 PROC. 1997 IMAGE
`UNDERSTANDING WORKSHOP 159-175 (1997).
`
`Jonathan D. Courtney, Automatic Video Indexing Via Object Motion
`Analysis, 30(4) PATTERN RECOGNITION 607-625 (1997).
`
`2007 U.S. Patent No. 6,628,835 to Brill et al.
`
`2008 Young Francis Day, et al, Spatio-Temporal Modeling of Video Data
`for On-Line Object-Oriented Query Processing, Proceedings of the
`International Conference on Multimedia Computing and Systems 98-
`105 (1995).
`
`Forouzan Golshani & Nevenka Dimitrova, A Language for Content-
`Based Video Retrieval, 6 MULTIMEDIA TOOLS AND APPLICATIONS,
`289-312 (1998).
`IPR2018-00138; IPR2018-00140, Ex. 2009 (Grindon Dep. Transcript
`Aug. 15, 2018).
`
`
`2004
`
`2005
`
`2006
`
`2009
`
`2010
`
`
`
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`
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`Patent Owner’s Opp. to Petitioners’ Mot. to Submit Supp. Info.
`IPR2019-00314
`
`Description
`
`Exhibit
`No.
`2011 Declaration of Jennifer A. Babbitt.
`
`SearchWorks Catalog Entry for Thomas Olson & Frank Brill, Moving
`Object Detection & Event Recognition Algorithms for Smart Cameras,
`1 PROC. 1997 IMAGE UNDERSTANDING WORKSHOP 159-175 (1997).
`
`Scanned Cover and Front Matter of Jonathan D. Courtney, Automatic
`Video Indexing Via Object Motion Analysis, 30(4) PATTERN
`RECOGNITION 607-625 (1997).
`
`2014 MRC Standards Wikipedia Search.
`
`2015 Declaration of Jennifer A. Babbitt for Sur-Reply.
`
`LinkedIn Profile of Marilyn McSweeney.
`
`2017 Declaration of Jennifer A. Babbitt in Support of Patent Owner’s
`Opposition to Petitioner’s Motion for Authorization to Compel
`Testimony and/or Documents.
`
`
`2012
`
`2013
`
`2016
`
`
`
`iii
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`
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`Patent Owner’s Opp. to Petitioners’ Mot. to Submit Supp. Info.
`IPR2019-00314
`
`I.
`
`
`INTRODUCTION
`Patent Owner Avigilon Fortress Corporation (“Patent Owner”) submits this
`
`Opposition to Petitioner Canon Inc., Canon U.S.A., Inc., and Axis Communications
`
`AB’s (collectively, “Petitioners”) Motion to Submit Supplemental Information
`
`Pursuant to 37 C.F.R. § 42.123(a) (the “Motion”) dated August 16, 2019 (Paper 19).
`
`Petitioners seek to cure the defects in the Petition and Florio declaration (Ex. 1007)
`
`as they relate to the alleged printed publication status of the Dimitrova and Brill
`
`references. Patent Owner submits that the request should be denied for at least three
`
`reasons. First, Petitioners’ request is properly characterized as a request to file
`
`supplemental evidence, as the Motion makes clear that the purpose of the exhibits is
`
`to support the admissibility of the declaration of Emily Florio (Ex. 1007). Such a
`
`request is premature, as the proper time to request to file supplemental evidence is
`
`in an opposition to a motion to exclude evidence, which has not been filed. Second,
`
`Petitioners seek to file supplementary information that they present for the first time
`
`in their motion and was not discussed at the August 9, 2019 telephone conference
`
`regarding Petitioners’ request to file supplemental evidence, or at any time prior in
`
`communication between the parties. The Board did not authorize Petitioners to file
`
`a motion requesting to file these exhibits, and Patent Owner respectfully submits that
`
`Petitioners’ request should be denied for that reason as well. Third, Patent Owner
`
`requests that the Board deny the Motion to submit the remaining exhibits, which
`
`
`
`1
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`
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`Patent Owner’s Opp. to Petitioners’ Mot. to Submit Supp. Info.
`IPR2019-00314
`Petitioners chose not to file with the Petition, even though they were all readily
`
`available to them at that time, a factor that the Board considers, even when a motion
`
`is made within one month of the institution decision.
`
`II.
`
`PETITIONERS’ EXHIBITS ARE PROPERLY CHARACTERIZED
`AS SUPPLEMENTAL EVIDENCE, NOT SUPPLEMENTAL
`INFORMATION
`Petitioners make clear that the true purpose of their exhibits is to support the
`
`admissibility of the declaration of Emily Florio, Ex. 1007, which Patent Owner has
`
`objected to. Motion at 2, 4, 6 (“[A]s an employee of the UVA Library this evidence
`
`directly addresses Patent Owner’s argument that Ms. Florio lacks sufficient personal
`
`knowledge of the practices of the UVA Library.”), 7 (“This information concerning
`
`the MARC standard is relevant because Ms. Florio’s declaration includes an
`
`explanation of how MARC records work and an examination of MARC records for
`
`the Brill and Dimitrova references in support of her testimony regarding public
`
`accessibility.”); Ex. 3002 (“On July 22, 2019, Patent Owner filed Objections to
`
`Evidence in IPR2019-00311 and IPR2019-00314 relating to Exhibit 1007, the Florio
`
`Declaration, and its testimony regarding whether a number of the prior art references
`
`in the subject petitions are printed publications. Petitioners Canon and Axis seek
`
`authorization to file a motion addressing these objections in two ways.”). Indeed,
`
`Petitioners refer to the exhibits as “supplemental evidence.” Motion at 2.
`
`
`
`2
`
`
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`Patent Owner’s Opp. to Petitioners’ Mot. to Submit Supp. Info.
`IPR2019-00314
`Exhibits produced in response to evidentiary objections are supplemental
`
`evidence, the filing of which is governed by 37 C.F.R. § 42.64(b)(2). See
`
`CaptionCall, L.L.C. v. Ultratec, Inc., IPR2015-00636, 00637, Paper 18 at 2 (PTAB
`
`Jan. 6, 2016). The proper time to file supplemental evidence is with an opposition
`
`to a motion to exclude. Id.; 37 C.F.R. § 42.64(c). Petitioners’ Motion is thus
`
`premature and should be denied.
`
`III. EVEN IF THE EXHIBITS ARE NOT SUPPLEMENTAL EVIDENCE,
`PETITIONERS’ MOTION SHOULD STILL BE DENIED
`Even if the Board disagrees that the exhibits Petitioners seek to file are more
`
`properly characterized as supplemental evidence, Patent Owner respectfully submits
`
`that the Board should deny the request to file the exhibits as supplemental
`
`information.
`
`A.
`
`Petitioners Improperly Attempt To Submit Exhibits 1049, 1051,
`And 1053 Without The Board’s Authorization.
`To the extent the Board disagrees that Exhibits 1049, 1051, and 1053 are
`
`supplemental evidence, Patent Owner submits Petitioners also failed to satisfy the
`
`requirements under Rule § 42.123, which requires Petitioners seek authorization
`
`from the Board before filing a motion to submit the exhibits as supplemental
`
`information. Exhibit 1049 is alleged to be a declaration from the University of
`
`Virginia library. Motion at 2. Exhibit 1051 purportedly is a copy of Brill from the
`
`University of Wisconsin library. Id. Exhibit 1053 allegedly is a declaration from
`
`
`
`3
`
`
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`Patent Owner’s Opp. to Petitioners’ Mot. to Submit Supp. Info.
`IPR2019-00314
`the University of Wisconsin library that Petitioners served on August 23, 2019—the
`
`day this brief is due. Id. These three unauthorized documents should not be admitted
`
`as supplemental information, because Petitioners failed to satisfy the requirements
`
`of 37 C.F.R. § 42.123. Exhibit 1053 also should not be admitted because it was
`
`served so late as to prejudice Patent Owner’s response in this brief.
`
`First, the procedure for the filing of supplemental information is clear: a party
`
`must obtain authorization to file a motion to submit supplemental information from
`
`the Board. 37 C.F.R. § 42.123. Petitioners, however, did not do so as to Exhibits
`
`1049, 1051, and 1053. Rather, during the August 9, 2019 conference call with the
`
`Board, Petitioners only sought “authorization to move to submit as supplemental
`
`information certain pieces of supplemental evidence that we already served on
`
`Patent Owner.” Ex. 1050 at 6:6-9 (emphasis added); see also id. at 4:5-11, 6:1-5.
`
`They made no request to include other documents that had not been previously
`
`served on Patent Owner. Id. Exhibits 1049, 1051, and 1053 had not been served on
`
`Patent Owner at that point, as Petitioners acknowledge. Motion at 2 (“[T]hree
`
`additional documents, besides those already served as supplemental evidence, are
`
`being requested to be submitted here.”) (emphasis added). Patent Owner was never
`
`given the opportunity before the Motion to argue that the Board should not authorize
`
`Petitioners’ Motion to Submit Supplemental Information as to these three
`
`
`
`4
`
`
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`Patent Owner’s Opp. to Petitioners’ Mot. to Submit Supp. Info.
`IPR2019-00314
`unauthorized documents. Petitioners’ Motion fails to satisfy 37 C.F.R. § 42.123 on
`
`its face and should be denied.
`
`Second, to the extent that the Board considers Petitioners’ reques as to
`
`Exhibits 1049, 1051, and 1053, the request must satisfy 37 C.F.R. § 42.123(b),
`
`because it was made for the first time in the Motion, thirty-nine days after trial was
`
`instituted. Under Rule 42.123(b), Petitioners must “show why the supplemental
`
`information reasonably could not have been obtained earlier, and that consideration
`
`of the supplemental information would be in the interests-of-justice.” (emphasis
`
`added). Petitioners make no attempt to satisfy either requirement. Exhibit 1049
`
`allegedly is a declaration from the University of Virginia library that Petitioners
`
`obtained without a subpoena. Motion at 2. Petitioners have not attempted to explain
`
`why this declaration “could not have been obtained earlier.” Similarly, Exhibit 1051
`
`is a purported copy of Brill from the University of Wisconsin library, sought to be
`
`submitted without any explanation as to why it was not included with the Petition or
`
`submitted earlier. Lastly, regarding Exhibit 1053, an alleged declaration from the
`
`University of Wisconsin library, Petitioners explained that the University of
`
`Wisconsin librarian who writes declarations was unavailable until August 22, 2019.
`
`Motion, fn. 1; Ex. 1052. But Petitioners do not explain when they requested the
`
`declaration, nor do they attempt to explain why the declaration could not have been
`
`obtained long ago, prior to the submission of the Petition, and presumably before the
`
`
`
`5
`
`
`
`Patent Owner’s Opp. to Petitioners’ Mot. to Submit Supp. Info.
`IPR2019-00314
`librarian’s window of unavailability. Moreover, Patent Owner only received the
`
`declaration a few hours before its Opposition was due, giving it insufficient
`
`opportunity to fully respond to the request to file it, which should be denied for at
`
`least that reason.
`
`B.
`Petitioners’ Remaining Requests Should Also Be Denied.
`Under 37 C.F.R. § 42.123(a), a party may file a motion to submit supplemental
`
`information if it meets the following requirements: “(1) [a] request for the
`
`authorization to file a motion to submit supplemental information is made within
`
`one month of the date the trial is instituted” and “(2) [t]he supplemental information
`
`must be relevant to a claim for which the trial has been instituted.” 37 C.F.R. §
`
`42.123(a). The Board, however, regularly denies such motions even if the
`
`requirements for filing the motion are met. Redline Detection, LLC v. Star
`
`Envirotech, Inc., IPR2013-00106, Paper 24 (PTAB Aug. 5, 2013), aff’d 811 F.3d
`
`435 (Fed. Cir. 2015); Laboratoire Francais du Fractionnement et des
`
`Biotechnologies S.A. v. Novo Nordisk Healthcare AG, IPR2017-00028, Paper 22
`
`(PTAB Jun. 13, 2017); ZTE Corp. v. ContentGuard Holdings, Inc., IPR 2013-00139
`
`Paper 27 (PTAB Jun. 30, 2013); Ooma, Inc. v. Deep Green Wireless LLC, IPR2017-
`
`01541, Paper 14 (PTAB Jan. 23, 2018).
`
`In ZTE, the petitioner sought to submit supplemental information under
`
`§ 42.123(a) that would “bolster its position” after trial was instituted. ZTE,
`
`
`
`6
`
`
`
`Patent Owner’s Opp. to Petitioners’ Mot. to Submit Supp. Info.
`IPR2019-00314
`IPR2013-00139, Paper 27 at 2. However, the Board denied the petitioner’s request
`
`because it found that § 42.123 is not a means to “bolster [a] position, particularly if
`
`that evidence was in the petitioner’s possession at the time of filing of the petition.”
`
`Id. at 3. Here, Petitioners similarly attempt to bolster their arguments with evidence
`
`regarding the alleged printed publication status of Dimitrova and Brill. See Motion
`
`at 4 (“the supplemental information presented here . . . provid[es] additional
`
`evidence of the publication of these references”).
`
`Similarly, in Redline, the Board denied a motion to submit supplemental
`
`information under § 42.123(a) where the petitioner “ha[d] not alleged that any of the
`
`arguments or evidence in the newly submitted declaration is information that
`
`reasonably could not have been submitted with the Petition.” IPR2013-00106, Paper
`
`24 at 4. In its Request for Rehearing (Paper 29) and on appeal, the petitioner argued
`
`that the legislative history of Rule § 42.123 prevents the Board from considering
`
`“factors articulated in subsections (b) and (c) if the timeliness and relevance
`
`conditions in subsection (a) are satisfied.” Redline, 811 F.3d at 444. The Board
`
`disagreed, and the Federal Circuit upheld the Board’s interpretation of Rule §
`
`42.123(a), holding that it was “consistent with the regulation’s plain language” and
`
`that “[r]equiring admission of supplemental information so long as it was timely
`
`submitted and relevant to the IPR proceeding” would alter the intended purpose of
`
`
`
`7
`
`
`
`Patent Owner’s Opp. to Petitioners’ Mot. to Submit Supp. Info.
`IPR2019-00314
`the IPR and “cut against” the mandate that the Board ensures the efficient and timely
`
`completion of IPR proceedings. Id. at 445.
`
`Petitioners apparently did not require a subpoena to obtain any of the exhibits
`
`they seek to file and yet provide no reason for why they were not submitted with the
`
`Petition or at any time before now. Petitioners failed to submit adequate declarations
`
`from librarians with personal knowledge of the shelving practices at the relevant
`
`libraries with the Petition, and they now attempt to rectify their mistake by
`
`submitting declarations from librarians (Ex. 1049, and 1053), which is improper.
`
`Petitioners also failed to provide sufficient evidence of the printed publication status
`
`of the references at the time of the Petition, and now attempt to remedy it by
`
`submitting additional copies of Brill (Ex. 1046 and 1051). Petitioners also failed to
`
`adequately explain with credible testimony what a MARC record is, and now
`
`attempt to cure that deficiency by submitting screenshots of two webpages (Ex. 1042
`
`and 1043). Admitting Petitioners’ exhibits now with information that was readily
`
`available to them at the time the Petition was filed, allows Petitioners to “bolster
`
`[their] positions” in a way that is not in the interest of justice.
`
`Further, Petitioners’ declaration from counsel (Ex. 1041) inadequately
`
`authenticates the exhibits sought to be filed, because it fails to provide testimonial
`
`evidence from a witness with personal knowledge of how the exhibits were obtained
`
`and whether they are authentic. The Board regularly holds that such a declaration is
`
`
`
`8
`
`
`
`Patent Owner’s Opp. to Petitioners’ Mot. to Submit Supp. Info.
`IPR2019-00314
`insufficient to authenticate exhibits, in particular with respect to exhibits allegedly
`
`demonstrating public availability. ASM IP Holding B.V. v. Kokusai Elec. Corp.,
`
`IPR2019-00369, Paper 8 at 20-22 (PTAB Jun. 27, 2019) (finding that a declaration
`
`from petitioner’s counsel attesting to how the printouts were generated falls short of
`
`authenticating the webpage printouts, in the context of a public availability dispute);
`
`see also Standard Innovation Corp. v. Lelo, Inc., IPR2014-00148, Paper 41 at 11
`
`(PTAB Apr. 23, 2015) (holding printouts of webpages were not authenticated
`
`because petitioner had not provided testimony of any witness attesting to the
`
`reliability of the contents or having personal knowledge that the printouts were
`
`authentic, in the context of a public availability dispute). Petitioners’ motion should
`
`be denied for this reason as well.
`
`IV. CONCLUSION
`For the foregoing reasons, Patent Owner respectfully requests the Board deny
`
`Petitioners’ Motion to Submit Supplemental Information.
`
`
`
`Dated: August 23, 2019
`
`
`
`
`
`By:
`
`
`
`Respectfully submitted,
`
`/s/ Eugene Goryunov/
`Eugene Goryunov (Reg. No. 61,579)
`KIRKLAND & ELLIS LLP
`300 North LaSalle
`Chicago, IL 60654
`Telephone: 312-862-2000
`Facsimile: 312-862-2200
`
`9
`
`
`
`
`
`Patent Owner’s Opp. to Petitioners’ Mot. to Submit Supp. Info.
`IPR2019-00314
`Lead Counsel for Patent Owner
`Avigilon Fortress Corporation
`
`Akshay S. Deoras (pro hac vice)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: 415-439-1400
`Facsimile: 415-439-1500
`akshay.deoras@kirkland.com
`
`Michael W. De Vries (pro hac vice)
`KIRKLAND & ELLIS LLP
`333 South Hope Street
`Los Angeles, CA 90071
`Telephone: 213-680-8400
`Facsimile: 213-680-8500
`michael.devries@kirkland.com
`
`
`
`10
`
`Reza Dokhanchy (Reg. No. 62,795)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: 415-439-1400
`Facsimile: 415-439-1500
`reza.dokhanchy@kirkland.com
`
`Adam R. Alper (pro hac vice)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: 415-439-1400
`Facsimile: 415-439-1500
`adam.alper@kirkland.com
`
`Back-Up Counsel for Patent Owner
`Avigilon Fortress Corporation
`
`
`
`
`
`
`
`
`
`
`
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`Patent Owner’s Opp. to Petitioners’ Mot. to Submit Supp. Info.
`IPR2019-00314
`
`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a copy of the foregoing PATENT
`
`OWNER’S OPPOSITION TO PETITIONERS’ MOTION TO SUBMIT
`
`SUPPLEMENTAL INFORMATION PURSUANT TO 37 C.F.R. § 42.123(A)
`
`was served on August 23, 2019 via electronic service on lead and back up counsel:
`
`
`Axis Communications AB
`Lead Counsel
`
`C. Gregory Gramenopoulos (Reg. No.
`36,532)
`Finnegan, Henderson, Farabow,
`Garrett & Dunner LLP
`901 New York Avenue, NW
`Washington, DC 20001-4413
`Telephone: 202-408-4263
`Facsimile: 202-408-4400
`gramenoc@finnegan.com
`
`
`
`Canon Inc. and Canon U.S.A., Inc.
`Lead Counsel
`
`Joseph A. Calvaruso (Reg. No. 28,287)
`Orrick, Herrington, & Sutcliffe LLP
`2050 Main Street, Suite 1110
`Irvine, CA 92614-8255
`Telephone: 212-506-5140
`Facsimile: 949-567-6710
`ipprosecution@orrick.com
`jcalvaruso@orrick.com
`
`
`
`11
`
`
`Axis Communications AB
`Backup Counsel
`
`Kelly S. Horn (Reg. No. 70,657)
`Guang-Yu Zhu (Reg. No. 66,250)
`Finnegan, Henderson, Farabow,
`Garrett & Dunner LLP
`901 New York Avenue, NW
`Washington, DC 20001-4413
`Telephone: 202-408-43131
`Facsimile: 202-408-4400
`kelly.horn@finnegan.com
`guang-yu.zhu@finnegan.com
`
`
`
`Canon Inc. and Canon U.S.A., Inc.
`Back-Up Counsel
`
`Richard F. Martinelli (Reg. No. 52,003)
`Orrick, Herrington, & Sutcliffe LLP
`2050 Main Street, Suite 1110
`Irvine, CA 92614-8255
`Telephone: 212-506-5140
`Facsimile: 949-567-6710
`ipprosecution@orrick.com
`rmartinelli@orrick.com
`
`
`
`
`
`Patent Owner’s Opp. to Petitioners’ Mot. to Submit Supp. Info.
`IPR2019-00314
`
`
`Dated: August 23, 2019
`
`Reza Dokhanchy (Reg. No. 62,795)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: 415-439-1400
`Facsimile: 415-439-1500
`reza.dokhanchy@kirkland.com
`
`Adam R. Alper (pro hac vice)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: 415-439-1400
`Facsimile: 415-439-1500
`adam.alper@kirkland.com
`
`
`
`
`
`
` /s/ Eugene Goryunov
`
`Eugene Goryunov (Reg. No. 61,579)
`KIRKLAND & ELLIS LLP
`300 North LaSalle
`Chicago, IL 60654
`Telephone: 312-862-2000
`Facsimile: 312-862-2200
`eugene.goryunov@kirkland.com
`
`Akshay S. Deoras (pro hac vice)
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: 415-439-1400
`Facsimile: 415-439-1500
`akshay.deoras@kirkland.com
`
`Michael W. De Vries (pro hac vice)
`KIRKLAND & ELLIS LLP
`333 South Hope Street
`Los Angeles, CA 90071
`Telephone: 213-680-8400
`Facsimile: 213-680-8500
`michael.devries@kirkland.com
`
`
`
`12
`
`
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