`
`Quest Ex. 1021
`PopSockets v. Quest
`IPR2019-01067
`
`
`
`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`QUEST USA CORP.,
`
`Petitioner,
`
`VS
`
`Case No.:
`
`IPR 2019—01067
`
`INC., 216.861.9270
`
`POPSOCKETS, LLC,
`
`Patent Owner.
`
`CONFERENCE CALL
`
`CADY REPORTING SERVICES,
`
`CADY REPORTING SERVICES, INC. 216-861-9270
`
`
`
`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`PARTICIPANTS ON THE CONFERENCE CALL:
`
`JUDGE JESSICA KAISER
`
`JUDGE STACY MARGOLIES
`
`STEVE AUVIL
`
`On behalf of the Petitioner:
`
`JAKETIC, ESQ.
`BRYAN J.
`SQUIRE, PATTON, BOGGS
`127 Public Square, 4900 Key Tower
`Cleveland, Ohio 44114
`216.479.8609
`
`bryan.jaketic@squirepb.com
`
`On behalf of POPSOCKETS, LLC:
`MICHAEL FLEMING, ESQ.
`IRELL & MANELLA, LLP
`1800 Avenue Of The Stars, Suite 900
`Los Angeles, California 90067
`310.277.1010
`
`mfleming@irell.com
`
`IAN R. WASHBURN, ESQ.
`IRELL & MANELLA, LLP
`1800 Avenue Of The Stars, Suite 900
`Los Angeles, California 90067
`310.277.1010
`iwashburn@irell.com
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`CADY REPORTING SERVICES, INC. 216-861-9270
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`
`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`CLEVELAND, OHIO, THURSDAY, SEPTEMBER 5, 2019;
`
`12:02 P.M.
`
`—oOo—
`
`JUDGE KAISER:
`
`So this is Judge
`
`Jessica Kaiser. This is a conference call in
`
`IPR 2019-01067.
`
`As
`
`I said,
`
`I have Judge
`
`Stacy Margolies on the line with me.
`
`Can we have counsel for Petitioner
`
`introduce themselves and who is with him on
`
`the call.
`
`MR.
`
`JAKETIC:
`
`Hi Judge Kaiser
`
`and Judge Margolies. This is Bryan Jaketic
`
`from Squire, Patton, Boggs and I'm here with
`
`Steve Auvil
`
`the lead counsel on behalf of
`
`Petitioner Quest USA Corporation.
`
`JUDGE KAISER: Mr. Jaketic,
`
`I
`
`understand you arranged to have a court
`
`reporter on the line;
`
`is that right?
`
`MR.
`
`JAKETIC:
`
`That's correct,
`
`Your Honor.
`
`JUDGE KAISER: Once you have the
`
`transcript from this call, will you please
`
`file that as an Exhibit
`
`into the record in
`
`this case.
`
`MR.
`
`JAKETIC:
`
`Yes, Your Honor.
`
`CADY REPORTING SERVICES,
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`INC., 216.861.9270
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`CADY REPORTING SERVICES, INC. 216-861-9270
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`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`JUDGE KAISER: Very good.
`
`Can I have counsel for Patent Owner
`
`introduce themselves and who is with them on
`
`the call.
`
`MR. FLEMING:
`
`Yes, Your Honor.
`
`This is Mike Fleming from Irell & Manella.
`
`I'm representing Popsockets Patent Owner and
`
`with me is my colleague Ian Washburn.
`
`JUDGE KAISER:
`
`I understand that
`
`we are having this call because at
`
`Petitioner's request based on Petitioner's
`
`request
`
`to seek fees to file a reply to
`
`Patent Owner's preliminary response in this
`
`case.
`
`So I will let counsel for Petitioner
`
`kick us off and explain the request that
`
`brings us here today.
`
`MR.
`
`JAKETIC:
`
`Thank you, Your
`
`Honor. This is Brian Jaketic on behalf of
`
`Petitioner. There are three issues that were
`
`raised in the preliminary response that
`
`Petitioner was unaware of at
`
`the time that we
`
`filed the petition, and we would appreciate
`
`the opportunity to file a reply to answer
`
`those issues that were raised by Patent
`
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`INC., 216.861.9270
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`CADY REPORTING SERVICES, INC. 216-861-9270
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`
`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`Owner.
`
`The first issue is a claim construction
`
`issue, it's actually the claim construction
`
`of two different terms,
`
`those terms being the
`
`words "lock" and "secure." This was raised
`
`at Paper 8 on page 11.
`
`The reason this comes into play is
`
`because Patent Owner relies on the preferred
`
`constructions of "lock" and "secure" to argue
`
`that a prior art reference which is WO
`
`2013-138500, we used this as Exhibit 1008 and
`
`refer to it as the Barnett PCT.
`
`Patent Owner
`
`argues that the Barnett PCT does not meet
`
`these elements of "lock" and "secure" in the
`
`independent claims 1,
`
`9 and 16, and Barnett
`
`PCT is part of grounds 1
`
`through 5 of the
`
`petition.
`
`I want
`
`to note here that the patent at
`
`issue,
`
`the '107 patent,
`
`is involved in a
`
`co—pending litigation which is PopSockets LLC
`
`versus Quest USA Corporation, and that is
`
`case No. 1:17—CV—02584 in the Eastern
`
`District of New York.
`
`The background here is that Petitioner
`
`provided Patent Owner with his initial
`
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`
`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`invalidity contentions on October 11 of 2018.
`
`And those initial invalidity contentions
`
`included a detailed chart comparing the
`
`claims of the Barnett PCT. And that chart is
`
`included in Exhibit 1019 of the petition.
`
`This is on pages 80 through 119 of the PDF.
`
`If it hadn't been aware of Petitioner's
`
`petition with regards to Barnett PCT as of
`
`October 11, 2018,
`
`the parties in litigation
`
`then reaped claim construction issues between
`
`December 14, 2018, and March 8, 2019. All
`
`this was done prior to the filing of the
`
`petition for I.R., and we provided those
`
`briefs as Exhibits 1016 through 1019 in the
`
`petition.
`
`During this time in the litigation,
`
`Patent Owner never indicated that it believed
`
`the construction was necessary for the word
`
`"lock" or for the word "secure." Petitioner
`
`was unaware of this position until it
`
`received the preliminary response that was
`
`filed on August 19 of 2019.
`
`So because Patent Owner has raised these
`
`new claim construction issues, Petitioner
`
`would like the opportunity to provide its own
`
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`INC., 216.861.9270
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`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`preferred constructions for these terms and a
`
`preliminary reply.
`
`JUDGE KAISER:
`
`So, Mr. Jaketic,
`
`in your petition I know you proposed
`
`constructions for specific claim terms, and
`
`that you requested that we apply plain and
`
`ordinary meanings to all claim terms.
`
`For
`
`your proposed reply, would you still be
`
`relying on the plain and ordinary meaning of
`
`these two terms that you phrased here "lock"
`
`and "secure"?
`
`MR.
`
`JAKETIC:
`
`We would not, Your
`
`Honor.
`
`We are still working through what we
`
`believe the proper construction would be.
`
`But we would propose an affirmative
`
`construction of these two terms.
`
`JUDGE KAISER: But would you
`
`be -- I understand that you want
`
`to propose a
`
`construction, but would your position be that
`
`that construction is the plain and ordinary
`
`meaning of those two terms?
`
`In other words,
`
`I'm trying to understand
`
`if what you want
`
`to do in your reply is
`
`consistent with what you said in your
`
`petition or if you are proposing to do
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`INC., 216.861.9270
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`
`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`something different?
`
`MR.
`
`JAKETIC:
`
`I understand. We
`
`would be offering our construction which we
`
`understand to be the ordinary and customary
`
`meaning of these terms.
`
`We would not simply
`
`say that plain and ordinary meaning should be
`
`applied.
`
`JUDGE KAISER: Anything else you
`
`want
`
`to say about
`
`the portion of your
`
`proposed reply that would relate to those two
`
`claim constructions?
`
`MR.
`
`JAKETIC:
`
`That covers
`
`everything for the claim construction issue.
`
`JUDGE KAISER:
`
`I
`
`think the other
`
`issue is the preamble;
`
`is that right?
`
`MR.
`
`JAKETIC: Your Honor,
`
`there
`
`are two other issues. There is the issue
`
`that they raised with respect to 35 USC
`
`Section 325(d), and there is also the
`
`preamble issue that we noted.
`
`I'd be happy
`
`to address either of those right now.
`
`JUDGE KAISER: Why don't you
`
`start with the 325(d)
`
`issue.
`
`MR.
`
`JAKETIC:
`
`Thank you, Your
`
`Honor.
`
`So this is another issue that was
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`
`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`raised by Patent Owner
`
`in its preliminary
`
`response.
`
`Patent Owner argued that the same
`
`or substantially the same prior art or
`
`arguments previously were presented to the
`
`office, and we would like an opportunity to
`
`explain that in fact the office has not
`
`considered the same art or argument.
`
`Each ground that is presented includes
`
`at least one reference that was not
`
`in front
`
`of the examiner.
`
`I note that Patent Owner
`
`focuses on grounds 1
`
`through 5
`
`in making this
`
`section 325 argument, noting that grounds 1
`
`through 5 of the petition include the Barnett
`
`PCT, and Patent Owner notes that the
`
`corresponding U.S. Patent was cited on the
`
`state of the '107 patent.
`
`But
`
`the rest of these,
`
`there is not one
`
`single ground that relies on (inaudible)
`
`the
`
`Barnett PCT as a 102 piece of prior art.
`
`These are grounds of invalidity, and each of
`
`these grounds includes an additional
`
`reference that was not before the examiner.
`
`JUDGE KAISER: Mr. Jaketic,
`
`I
`
`don't think you need to go into necessarily
`
`what
`
`the entirety of the substance of what
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`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`would be in your reply.
`
`I
`
`think what we are
`
`most interested in,
`
`for the purposes of this
`
`call,
`
`is whether there is good cause for
`
`Petitioner not having raised these issues
`
`earlier. And my prior question was about
`
`whether what you wanted in the reply was
`
`consistent with what was in the petition.
`
`So that's more on the order of what we
`
`are interested in in this call if you want
`
`to
`
`focus your presentation there.
`
`MR.
`
`JAKETIC:
`
`I understand.
`
`Thank you, Your Honor.
`
`The surprise that we had in the response
`
`was Patent Owner's position that the office
`
`had considered the Karmatz provisional during
`
`the original prosecution.
`
`The Karmatz
`
`provisional
`
`included as Exhibit 1010 —— I'm
`
`sorry, 1009 in our petition.
`
`And what
`
`the office considered —— it
`
`actually considered the carmat's patent and
`
`that's Exhibit 1010 and the carmat's patent
`
`was cited on the face of the patent, but
`
`the
`
`Karmatz provisional was not cited by the
`
`patent office. There is no indication that
`
`the provisional was considered by the patent
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`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`office.
`
`And what Patent Owner does here, it
`
`notes —— makes a statement that the carmat's
`
`provisional
`
`issued as the Karmatz patent.
`
`And this position is very different from what
`
`it has taken in two other IPRs,
`
`IPR
`
`2018—00497 and IPR 2018—01294.
`
`Those two IPRs, which both of Your
`
`Honors are involved in,
`
`involve another
`
`patent V031 patent that has some of the same
`
`subject matter, and there the Karmatz
`
`provisional and the Karmatz patent have both
`
`come into play, and Patent Owner has taken
`
`the position that the carmat's patent is
`
`actually not entitled to be prior to date of
`
`the carmat's provisional because the
`
`teachings of the carmat's provisional are
`
`different from the embodiments that are shown
`
`in the carmat's patent.
`
`It's now flipped that and they are
`
`taking the opposite stance that the carmat's
`
`provisional
`
`is actually incorporated into the
`
`carmat's patent. And that by considering the
`
`carmat's patent,
`
`the patent office actually
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`did consider the carmat's provisional.
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`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`That is one factual point we wanted to
`
`clarify as a reason why section 325 does not
`
`apply in this instance.
`
`JUDGE KAISER:
`
`It sounds like
`
`that's your position about why you didn't
`
`anticipate a 325(d) argument is because it's
`
`different from what you were relying on and
`
`Petitioner is not
`
`in favor of that.
`
`MR.
`
`JAKETIC:
`
`Yes, Your Honor;
`
`that
`
`is correct.
`
`JUDGE KAISER: Why don't we move
`
`to the preamble issue from the —— but there
`
`is not a lot you want
`
`to say about this
`
`because it sounds like the parties are in
`
`agreement that the preamble is not limiting
`
`for purposes of this proceeding.
`
`MR.
`
`JAKETIC:
`
`Sure.
`
`So the
`
`final point, You Honor,
`
`thank you,
`
`is that
`
`the Patent Owner
`
`in its preliminary response
`
`has taken the position that the preamble is
`
`not limiting, and I do want
`
`to note that
`
`Petitioner has made different arguments in
`
`the litigation but due to judicial efficiency
`
`Petitioner would agree that the preamble may
`
`be true but nonlimiting for the purposes of
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`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`inter partes reveal.
`
`Petitioner notes that the Patent
`
`Owner does not distinguish any of the prior
`
`art references based on the preamble.
`
`The reason I wanted to point this out
`
`specifically,
`
`though,
`
`is that we feel it's
`
`important
`
`to clarify that the preamble
`
`states,
`
`"An expandable socket for attachment
`
`to a portable media player or a portable
`
`media player case." That entire preamble is
`
`not limiting.
`
`This statement
`
`in the preamble of "for
`
`attachment" is different from language that
`
`comes from the plor rotor (phonetic)
`
`in the
`
`claim where the claim recites a platform
`
`adapted to engage a portion of the portable
`
`media player.
`
`And I wanted to note on the record that
`
`that "for attachment" language in the
`
`preamble is not limiting and the "adapted to
`
`engage" language in the claim body is part of
`
`the claim, but that that is different from
`
`the "for attachment" language.
`
`It appeared
`
`to us that those two terms got conflated in
`
`the preliminary response, and I just wanted
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`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`to clarify that.
`
`JUDGE KAISER: Mr. Jaketic,
`
`I
`
`just want
`
`to again reiterate we are not
`
`trying to argue the merits of the case here
`
`at this point. Really all we are trying to
`
`do right now is decide whether -- by we
`
`I
`
`mean the board —— is trying to decide whether
`
`you've shown good cause so that we can decide
`
`whether to grant
`
`the need to file this reply.
`
`So if you can sort of focus your argument
`
`on that,
`
`I
`
`think it will really help us to
`
`get
`
`to the meat of what we need to decide
`
`here.
`
`MR.
`
`JAKETIC:
`
`I understand, Your
`
`Honor.
`
`Then that sums up our position on the
`
`preamble not being limited.
`
`JUDGE KAISER:
`
`If we were to
`
`grant your request
`
`to file or reply to
`
`preliminary response, when would you propose
`
`to do that?
`
`How long would you need?
`
`MR.
`
`JAKETIC:
`
`I
`
`think we need
`
`two weeks, Your Honor.
`
`JUDGE KAISER:
`
`How many pages
`
`would you need?
`
`MR.
`
`JAKETIC:
`
`If we're to
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`CADY REPORTING SERVICES,
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`INC., 216.861.9270
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`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
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`
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`address all these issues,
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`I believe 15 pages
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`would cover it.
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`JUDGE KAISER:
`
`I want
`
`to hear
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`from Patent Owner's counsel Mr. Fleming,
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`please.
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`MR. FLEMING:
`
`Yes, Your Honor.
`
`This is Mike Fleming. First point
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`I would
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`like to make is that it's entirely
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`foreseeable that we would be arguing plain
`
`and ordinary meaning for "secure" and "lock."
`
`What
`
`the Petitioner did not tell you is
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`that on April 30, 2019, before the filing of
`
`this petition on May 7, 2019, PopSocket filed
`
`Plaintiff's disclosure of terms requiring
`
`construction and proposed construction, and
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`in that paper Popsockets asserted that plain
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`and ordinary meaning shall apply to all claim
`
`terms.
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`The points that he claimed to are claim
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`terms that are only at
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`issue in the district
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`court and that construction there is still
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`the plain and ordinary meaning is just
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`explaining what is the plain and ordinary
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`meaning based on intrinsic record.
`
`In our Patent Owner's preliminary
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`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
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`
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`response, we are arguing plain and ordinary
`
`meaning for "lock" and "secure" based upon
`
`intrinsic record. This is entirely
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`foreseeable especially considering the art
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`that's be applied.
`
`The Petitioner certainly
`
`should have anticipated us making these
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`constructions.
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`The other thing is rule 42 104(b)(3)
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`places the burden on the Petitioner to set
`
`forth claim construction in the petition.
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`There is nothing in the rules that require
`
`the Patent Owner to map out our arguments
`
`before they file their petition.
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`The other aspect is Petitioner has not
`
`explained why it could not have anticipated
`
`our arguments related to identified claim
`
`terms which the Patent Owner represents
`
`solely on the intrinsic record of the
`
`challenged patent. And in another panel,
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`the
`
`board found similar facts that
`
`indeed this
`
`does not establish good cause, and that case
`
`is V—a—l—e—r—i—t—a—s versus Roche Diabetes
`
`Care IPR 2019-00552 paper No. 9.
`
`As far as for the 325(b) argument,
`
`they're entirely (inaudible). First point is
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`INC., 216.861.9270
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`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`Petitioner is on notice that 325(b)
`
`issues
`
`are on the forefront of the board.
`
`The
`
`petition was filed on May 7, 2019.
`
`Petitioner should not have been surprised
`
`that this was an issue that the petition
`
`should have addressed.
`
`The AIA statute is at
`
`the board's discretion to deny petition is
`
`the same or substantially same and will be
`
`presented to the office.
`
`The board has issued a formative
`
`decision effective on December 15, 2017, on
`
`the issue well before the petition's filing.
`
`And on August 2018,
`
`there was an update to
`
`the Patent Office File Practice Guide the
`
`325(b) argument is foreseeable.
`
`The facts of
`
`this case compel a 325(b) argument all the
`
`factors are met.
`
`Petitioner should have been well aware
`
`of the examination file history of the case
`
`in their file and should anticipate the
`
`325(b) argument.
`
`As for the preamble, it appears to us
`
`that this is just an opportunity for them to
`
`bolster their petition.
`
`We have said that
`
`the preamble is not limiting and we had not
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`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
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`made any arguments as far as distinguishing
`
`the art.
`
`We don't see how this at all raises
`
`to our requirement for a reply.
`
`JUDGE KAISER: Very good.
`
`I
`
`think first,
`
`let me say,
`
`I
`
`think we
`
`understand both partys' positions.
`
`I'm going
`
`to go off line for a minute and confer with
`
`my colleague and I will return.
`
`(Whereupon,
`
`a short break was taken.)
`
`JUDGE KAISER:
`
`I had some
`
`difficulty with my phone and I had to
`
`disconnect and dial back in so I apologize,
`
`the delay was a bit longer than I
`
`intended,
`
`but it sounds like you all were able to work
`
`out some things with the court reporter.
`
`So I have had a chance to confer with
`
`Judge Margolies and we are going to take
`
`Petitioner's request under advisement and
`
`issue an order in due course that sets out
`
`our determination.
`
`I did want
`
`to ask a couple of things
`
`before we contemplate how we want
`
`to proceed.
`
`The first is for Mr. Fleming.
`
`If we were to
`
`grant Petitioner a reply, would Patent Owner
`
`request for you to file a surreply?
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`CADY REPORTING SERVICES,
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`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`MR. FLEMING:
`
`Yes, Your Honor.
`
`JUDGE KAISER: Very good.
`
`Then
`
`if we granted to file a reply on all the
`
`issues that have been raised,
`
`I believe
`
`Mr. Jaketic requested two weeks and 15 pages.
`
`What would Patent Owner request for its
`
`surreply in that instance?
`
`MR. FLEMING:
`
`We could live with
`
`two weeks and 15 pages too.
`
`JUDGE KAISER:
`
`Then going to
`
`Mr. Jaketic,
`
`if we authorized a reply but we
`
`limit the scope of that reply to only the
`
`claim construction issues, what
`
`time frame
`
`would you propose to file that reply?
`
`MR.
`
`JAKETIC:
`
`I still appreciate
`
`two weeks and we would need a full 15 pages.
`
`JUDGE KAISER:
`
`10 pages?
`
`MR.
`
`JAKETIC:
`
`10 pages would be
`
`fine, Your Honor.
`
`JUDGE KAISER:
`
`Then, Mr. Fleming,
`
`for that more limited scope of a reply, what
`
`would Patent Owner request for a surreply?
`
`MR. FLEMING:
`
`Two weeks and 10
`
`pages as well.
`
`JUDGE KAISER: Okay.
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`INC., 216.861.9270
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`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`
`
`Before we adjourn, anything else from
`
`the Petitioner?
`
`MR.
`
`JAKETIC:
`
`Yes, Your Honor.
`
`I just wanted to note on the record that in
`
`its argument, Patent Owner noted that there
`
`was an April 30th claim construction
`
`disclosure, and that's actually the claim
`
`construction disclosure for a different
`
`Patent
`
`in a different litigation that was
`
`later consolidated for the '107 patent. That
`
`claim construction disclosure was for U.S.
`
`Patent No. 10054259, not
`
`the '107 patent that
`
`is at
`
`issue here, Your Honor.
`
`JUDGE KAISER: Okay.
`
`MR.
`
`JAKETIC:
`
`This is the only
`
`point
`
`I wanted to note.
`
`JUDGE KAISER: Anything further
`
`from Patent Owner?
`
`MR. FLEMING:
`
`Your Honor,
`
`I'm
`
`not sure that's correct.
`
`I had a meeting
`
`with a law firm that's handling the
`
`litigation.
`
`JUDGE KAISER: This document
`
`that's being discussed is not
`
`in the record
`
`before us; right?
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`— September 5th, 2019
`Conference Call
`Quest USA Corp. vs. Popsockets, LLC
`
`MR. FLEMING:
`
`No, it's not.
`
`JUDGE KAISER: Okay.
`
`I don't
`
`think it's something we are going to consider
`
`at this time if it's not
`
`in the record.
`
`Anything else from Patent Owner?
`
`MR. FLEMING:
`
`No, Your Honor.
`
`JUDGE KAISER: All right.
`
`Thank
`
`you both for your time and that adjourns this
`
`conference call. Have a good Day.
`
`MR. FLEMING:
`
`Thank you, Your
`
`MR.
`
`JAKETIC:
`
`Thank you, Your
`
`Honor.
`
`You too.
`
`(Whereupon, at the hour of 1:35 p.m.,
`
`the
`
`conference call concluded.)
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`CADY REPORTING SERVICES,
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`INC., 216.861.9270
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`CADY REPORTING SERVICES, INC. 216-861-9270
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`
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`Conference Call -September 5th, 2019
`
`
`Quest USA Corp. vs. Popsockets, LLC
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`22
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`REPORTER'S CERTIFICATE
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`1
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`2
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`3
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`THE STATE OF OHIO,
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`SS:
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`4
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`COUNTY OF CUYAHOGA.
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`5
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`I, Debra Lynn Ketring, state that the
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`6
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`conference call by me reduced to stenotype and
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`7
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`afterwards transcribed on a computer, and that the
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`8
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`foregoing is a true and correct transcript of the
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`9
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`conversation so given by all parties.
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`10
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`I do further certify that this conference call
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`11
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`was taken at the time and place in the foregoing
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`12
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`caption specified. I do further certify that I am
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`13
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`not a relative, counsel or attorney of either
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`14
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`party, or otherwise interested in the event of this
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`15
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`action.
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`IN WITNESS WHEREOF, I have hereunto set my
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`hand and affixed my seal of office at Cleveland,
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`Ohio, on this day of------------'
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`Debra Lynn Ketring, CSR, Notary Public
`within and for the State of Ohio
`My Commission Expires February 18, 2024
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`CADY REPORTING SERVICES, INC., 216.8 61.9270 22
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`CADY REPORTING SERVICES, INC. 216-861-9270
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