Lenovo Holding Company, Inc., et al. (Petitioners)
`v.
`DoDot Licensing Solutions LLC (Patent Owner)
`Case IPR2019-01278, IPR2019-01279
`U.S. Patent Nos. 8,020,083, 8,510,407
`
`Petitioner’s Demonstratives
`Wednesday, October 28, 2020
`
`1:00 pm Eastern
`
`Alexandria, VA (virtual)
`Petitioner Demonstrative Exhibit – Not Evidence- 1
`Petitioner Demonstrative Exhibit – Not Evidence – 1
`
`
`v.
`DoDot Licensing Solutions LLC (Patent Owner)
`Case IPR2019-01278, IPR2019-01279
`U.S. Patent Nos. 8,020,083, 8,510,407
`
`Petitioner’s Demonstratives
`Wednesday, October 28, 2020
`
`1:00 pm Eastern
`
`Alexandria, VA (virtual)
`Petitioner Demonstrative Exhibit – Not Evidence- 1
`Petitioner Demonstrative Exhibit – Not Evidence – 1
`
`
`
`All Challenged Claims are Invalid
`
`• The challenged claims are obvious
`
`• The term “template” should be construed broadly enough to
`include text and executable code as recited in the claims
`and specification
`
`• Dependent claims 8 and 20 of the ’407 Patent are obvious
`over Razavi, Anderson, and Fortin
`
`• Patent Owner’s secondary considerations evidence is
`insufficient to overcome the prima face case of obviousness
`
`Petitioner Demonstrative Exhibit – Not Evidence – 2
`
`
`
`Challenged Claims of the ’083 & ’407 Patents
`
`• U.S. 8,020,083: Claims 1-16
`
`• U.S. 8,510,407: Claims 1, 8-13, and 20-24
`
`Petition, Paper 1, at 22-63.
`Patent Owner Response, Paper 15, at 8-17.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 3
`
`
`
`Instituted Grounds
`
`• U.S. 8,020,083
`• Claims 1-16 under § 103 in view of Hoff & Berg
`• Claims 1-16 under § 103 in view of Razavi & Anderson
`
`• U.S. 8,510,407
`• Claims 1, 9-13, and 21-24 under § 103 in view of Hoff, Berg, & Nazem or AAPA
`• Claims 8 and 20 under § 103 in view of Hoff, Berg, Nazem or AAPA, and Fortin
`• Claims 1, 9-13, and 21-24 under § 103 in view of Razavi & Anderson
`• Claims 8 and 20 under § 103 in view of Razavi, Anderson, and Fortin
`
`Petitioner Demonstrative Exhibit – Not Evidence – 4
`
`
`
`‘083 and ’407 Patents
`
`•
`
`“Directed to accessing and displaying Internet content which
`includes a definition for rendering a graphical user interface
`and a URL pointing to [the time-varying] Internet content to
`be downloaded and presented within said user interface.”
`• Present content in a configurable frame (i.e., graphical user
`interface “GUI”).
`• Seek to avoid situation where content was “typically trapped
`within the frame of a browser.”
`• Teach that content providers can develop Networked
`Information Monitors (“NIM”).
`
`’407 Patent, Abstract, 1:67-2:9, 2:59-61, 5:18-31.
`’407 Petition, Paper 1, at 2-8;
`Petitioner Demonstrative Exhibit – Not Evidence – 5
`‘083 Petition, Paper 1 at 2-4.
`
`
`
`‘083 and ’407 Patents
`
`• The term “NIM” does not appear in the ’083 Patent, but
`rather is incorporated from the ’407 Patent
`• NIM = “Application Media Package”
`• Template = “Template” or “Dot Definition”
`
`’407 Patent, Abstract, 1:67-2:9, 2:59-61, 5:18-31.
`’407 Petition, Paper 1, at 2-8;
`‘083 Petition, Paper 1 at 2-4; Reply at 2.
`Petitioner Demonstrative Exhibit – Not Evidence – 6
`
`
`
`‘083 and ’407 Patents
`
`’083 Patent, Fig. 5;
`’083 Petition, Paper 1, at 26;
`‘083 Patent, Ex 2003, ¶129.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 7
`
`
`
`‘407 Patent Specification: NIM
`
`’407 Patent, 5:21-24.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 8
`
`
`
`’083 Patent – Claim 1
`
`1. [1. preamble] A client device, the client device comprising:
`[1.A] electronic storage having stored thereon a plurality of networked information monitor
`templates defining a plurality of networked information monitors, the plurality of networked
`information monitor templates comprising a first networked information monitor template
`defining a first networked information monitor, wherein the first networked information
`monitor template comprises:
`[1.B]: (1) a content reference . . . .
`[1.C]: (2) a definition of a graphical user interface of the first networked information monitor . . .
`[1.D]: (3) instructions configured (i) to cause the first networked information monitor to
`request content from the network location in the content reference via the TCP/IP protocol, and
`[1.E] (ii) to cause the first networked information monitor to generate the graphical user
`interface . . . .
`[1.F]: an electronic display; and
`[1.G] one or more processors configured to access the first networked information monitor
`template, and to execute the first networked information monitor template such that the
`graphical user interface of the first networked information monitor is presented to a user on the
`electronic display having content received from the content reference therein.
`
`’083 Petition, Paper 1, at 10-11.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 9
`
`
`
`’407 Patent – Claim 1
`
`1. [1. preamble] A client computing device configured to access content over a network, the client
`computing device comprising:
`[1.A] electronic storage configured to store networked information monitor template associated
`with a networked information monitor, [1.B] the networked information monitor template
`having therein a definition of a viewer graphical user interface having a frame within which
`time-varying content in a web browser-readable language may be presented on a display
`associated with the client computing device, wherein the frame of the viewer graphical user
`interface lacks controls for enabling a user to specify a network location at which content for the
`networked information monitor is available; and
`[1.C] one or more processors configured to execute one or more computer program modules,
`the one or more computer program modules being configured to access the networked
`information monitor defined by the networked information monitor template, wherein
`accessing the networked information monitor defined by the networked information monitor
`template results in:
`[1.C] a definition of a viewer graphical user interface within which content in a web browser-
`readable language may be presented on the display of the client computing device; and
`[1.D] [1.E] . . . . [1.G]
`
`’407 Petition, Paper 1, at 13-14.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 10
`
`
`
`NIM v. NIM Template
`
`Petitioner and Patent Owner agree that:
`1.
`the NIM is “a fully configurable frame with one or more
`controls” through which content is presented to the user;
`and
`2. The NIM and NIM template are separate limitations.
`
`’407 Patent, 1:35-44, 2:28-30, 4:53-67.
`’407 Petition at 2-8; ’083 Petition at 2-4.
`’407 Patent Owner Response, Paper 18, at 8; ’083 Patent Owner Response, Paper 20, at 7.
`Petitioner Demonstrative Exhibit – Not Evidence – 11
`’407 Reply at 2; ’083 Reply at 2.
`
`
`
`NIM v. NIM Template
`The Parties disagree on the construction of NIM template
`• NIM Template should be accorded its plain and ordinary
`meaning, namely templates that are executable and/or
`include text
`• The claims explicitly recite “executing” the NIM Template
`• The intrinsic record supports Petitioner’s construction
`• The extrinsic record also supports Petitioner’s construction
`• Patent Owner’s proposed construction: “a data structure that
`defines the NIM; it is not the NIM and it is not an executable
`program (i.e., compiled code)” attempts to rewrite the claims and
`ignores the specification
`’407 Patent, 1:35-44, 2:28-30, 4:53-67.
`’407 Petition at 2-8; ’083 Petition at 2-4.
`’407 Patent Owner Response, Paper 18, at 8; ’083 Patent Owner Response, Paper 20, at 7.
`Petitioner Demonstrative Exhibit – Not Evidence – 12
`’407 Reply at 2; ’083 Reply at 2.
`
`
`
`Claim Construction Begins with the Claims
`
`Sunovion Pharm., Inc. v. Teva Pharm. USA,
`Inc., 731 F.3d 1271, 1276 (Fed. Cir. 2013)
`(citations omitted) (“When construing claim
`terms, we first look to, and primarily rely on,
`the intrinsic evidence, including the
`claims themselves, the specification, and the
`prosecution history of the patent, which is
`usually dispositive.”)
`
`Interactive Gift Exp., Inc. v. Compuserve
`Inc., 256 F.3d 1323, 1331 (Fed. Cir. 2001)
`(“In construing claims, the analytical focus
`must begin and remain centered on the
`language of the claims themselves.”)
`
`’083 Reply, Paper 21, at 3.
`Petitioner’s Motion to Strike at 3.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 13
`
`
`
`Intrinsic Evidence – The Claims
`
`•
`
`’083 Patent, Claim 1:
`– electronic storage having stored thereon ... networked information
`monitor template compris[ing]:
`– 1.E. instructions configured (i) to cause the first networked
`information monitor to request content..., and (ii) to cause the first
`networked information monitor to generate the graphical user
`interface . . . .
`– 1.G. one or more processors configured to . . . execute the first
`networked information monitor template
`
`’407 Patent Owner Response, Paper 18, at 2, 8; ’083 Patent Owner Response, Paper 20, at 7.
`’407 Reply at 7; ’083 Reply at 4-5.
`Petitioner Demonstrative Exhibit – Not Evidence – 14
`
`
`
`“Execute” Has a Plain and Ordinary Meaning
`
`• Dr. Sacerdoti admitted at his deposition that “execute” has a
`plain and ordinary meaning to one of ordinary skill in the art.
`(Ex. 1019 at 59:5-7)
`• “Compiled means that source code is translated into a
`lower level language which then is – which then is
`executed” so that the source code is no longer needed
`“because the source code was used to translate into an
`executable program” (Id. at 20:15-21:8).
`
`’083 Reply at 4-5; ’407 Reply at 6-7.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 15
`
`
`
`Lexicography: Must be Clear and Express
`
`Thorner v. Sony Computer Entm’t Am. LLC,
`669 F.3d 1362, 1365 (Fed. Cir. 2012) (“To act
`as its own lexicographer, a patentee must
`clearly set forth a definition of the disputed
`claim term other than its plain and ordinary
`meaning” and must “clearly express an
`intent to redefine the term.”)
`
`Merck & Co., Inc. v. Teva Pharm. USA, Inc.,
`395 F.3d 1364, 1379 (Fed. Cir. 2005)(Unless
`the specification “clearly, deliberately, and
`precisely” spells out how a claim term is to be
`used, the plain and ordinary meaning
`controls.)
`
`’083 Reply at 5-6; ’407 Reply at 3.
`Petitioner’s Motion to Strike at 3.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 16
`
`
`
`No Lexicography: Executable Embodiments
`
`Verizon Servs. Corp. v. Vonage Holdings
`Corp., 503 F.3d 1295, 1305 (Fed. Cir. 2007)
`(rejecting proposed claim interpretation that
`would exclude disclosed examples in the
`specification)
`
`Invitrogen Corp. v. Biocrest Mfg., L.P., 327
`F.3d 1364, 1369 (Fed. Cir. 2003) (finding
`district court's claim construction erroneously
`excluded an embodiment described in an
`example in the specification, where the
`prosecution history showed no such disavowal
`of claim scope)
`
`’083 Reply at 7; ’407 Reply at 5.
`Petitioner’s Motion to Strike at 3.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 17
`
`
`
`Intrinsic Evidence – Executable NIM Templates
`
`’407 Patent, 3:8-9.
`
`• The second executable module “defines a NIM frame” it is a
`NIM template, as are “NIM definition modules.”
`
`’407 Patent, 34:9-15.
`
`’083 Reply at 8-9; ’407 Reply at 5-6.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 18
`
`
`
`Execute – Intrinsic Evidence
`
`• “Execute” is not re-defined by the patents.
`– The specification’s use of the term “execute” is consistent with the
`plain and ordinary meaning.
`– “Web server 58 has many components, including a variety of
`modules and data structures to assist users that want to log into
`system 10.” 6:25-27.
`
`’083 Reply at 8-9; ’407 Reply at 6.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 19
`
`
`
`Extrinsic Evidence – Modules are Executable
`
`• Dr. Sacerdoti confirmed at his deposition that:
`• “A module would be a chunk of code” (Ex. 1019 at
`69:22-70:13); and
`• An “executable module” is “executable computer code.”
`(Ex. 1019 at 69:22-70:13).
`
`’083 Reply at 8-9; ’407 Reply at 5-6.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 20
`
`
`
`No Lexicography From Non-limiting Examples
`
`Innova/Pure Water, Inc. v. Safari Water
`Filtration Sys., Inc., 381 F.3d 1111, 1117 (Fed.
`Cir. 2004) (“particular embodiments
`appearing in the written description will not
`be used to limit claim language that has
`broader effect. . . . even where a patent
`describes only a single embodiment, claims
`will not be “read restrictively unless the
`patentee has demonstrated a clear intention
`to limit the claim scope using words or
`expressions of manifest exclusion or
`restriction.”)
`
`’083 Reply at 7; ’407 Reply at 4.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 21
`
`
`
`No Lexicography From One Embodiment
`
`’407 Patent, 25:6-7.
`
`’083 Reply at 6-7; ’407 Reply at 3-4.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 22
`
`
`
`Patent Owner’s Infringement Allegations
`
`...
`
`...
`
`’083 Reply at 9-10; ’407 Reply at 8-9.
`Ex. 1015 (DoDot’s Second Amended Complaint) at 6-11.
`Petitioner Demonstrative Exhibit – Not Evidence – 23
`
`
`
`Patent Owner Cannot Reverse Course Now
`
`“It is axiomatic that claims are construed
`the same way for both invalidity and
`infringement.”Amgen Inc. v. Hoechst
`Marion Roussel, Inc., 314 F.3d 1313, 1330
`(Fed. Cir. 2003)
`
`’083 Reply at 9-10; ’407 Reply at 8-9.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 24
`
`
`
`Dr. Madisetti’s Testimony
`• The NIM template contains the instructions/data for
`creating a GUI. Ex. 1003, ¶ 32
`
`•
`
`•
`
`[T]he “channel” applications disclosed in Hoff and Berg
`include similar definitions. Specifically, the channel
`applications contain instructions and data used to
`create a GUI and display content therein. Therefore,
`the “channel” applications in Hoff and Berg include the
`claimed NIM template. Ex. 1003, ¶ 162.
`
`[T]he applet in Razavi contains the instructions and
`data used to create a GUI on the client and to display
`content within that GUI. Ex. 1003, ¶ 276.
`
`‘083 Petition 29-30, 39; ‘407 Petition 30-31, 52
`Petitioner Demonstrative Exhibit – Not Evidence – 25
`
`
`
`Dr. Sacerdoti’s Testimony
`
`• Patent Owner and its expert assert that the terms
`“applications” and “apps” are somehow different
`
`• However, Dr. Sacerdoti helped draft and prosecute an
`application that makes clear the terms are
`synonymous.
`
`•
`
`“...applications operating on mobile devices (such as
`the iPhone™ Android™, and other smartphones and
`similar devices), sometimes called ‘mobile apps’
`herein.” Ex. 2004, at ¶ 6; Ex. 1014, at 1:28-31.
`
`’083 Reply at 8; ’407 Reply at 9-10.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 26
`
`
`
`Hoff
`
`Hoff, Fig. 1; ’407 Petition, at 8-9, 20-41; ’083 Petition at 5-6, 18-37.
`Petitioner Demonstrative Exhibit – Not Evidence – 27
`
`
`
`Berg
`
`Berg, at 3-4; ’407 Petition, at 9-10, 20-41; ’083 Petition at 6-7, 18-37.
`Petitioner Demonstrative Exhibit – Not Evidence – 28
`
`
`
`Hoff & Berg Render the ’083 Claims Obvious
`
`• Hoff and Berg describe applications of Marimba’s Castanet.
`
`• Hoff discloses three elements: (1) a tuner; (2) a transmitter; and (3) a
`channel. Hoff, 1:54-67.
`
`• Channels can be any “software application” developed by “content
`providers.” Id., 1:54-67; 4:8-10, 19-24.
`
`• Berg discloses using Castanet, the “Java-centric (but not limited to
`Java) push technology” to distribute content. Berg, 1.
`
`• Berg discloses a HotJavaBean component, which is an HTML
`renderer, used in a Castanet channel to render full “style-sheets,
`applets, and frames” in a GUI, such that “by deploying an application
`via Castanet, you do not have to forego the web capabilities of a
`browser.” Berg, 3.
`
`’083 Petition at 5-7, 18-37.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 29
`
`
`
`Hoff & Berg Render the ’083 Claims Obvious
`• Hoff discloses that in response to a request from the tuner (located on
`the client), the transmitter (located on the server) sends code and data
`(NIM template) to the client that the client uses to display a channel
`(NIM) to a user. Petition, at 18-25, citing Hoff, Abstract, 2:45-48, 2:64-66,
`3:2-5, 4:49-57.
`
`•
`
`“To obtain the initial channel data, tuner process 152 uses network
`interface 141 to send a subscribe request to transmitter process 121.
`Transmitter process 121 will respond with an update reply containing
`channel data 133 . . . . In response, tuner process 152 stores channel
`data 1613 in storage system 154. Once the channel data is loaded, tuner
`process 152 can start channel application 153. Channel application
`153 is the active application corresponding to a channel 159 which
`is executed by operating system 150 from the code stored in
`channel data 161.” Hoff, 4:49-57.
`
`• See also Madisetti Decl. (Ex.1003), ¶¶75-78, 88-97, 118-121, 159-162,
`174-183
`’083 Reply at 11; ’407 Reply at 9-10.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 30
`
`
`
`Hoff/Berg/Nazem Render the ’407 Claims Obvious
`
`• Hoff and Berg describe applications of Marimba’s Castanet.
`
`• Nazem teaches web sites coded in HTML that include time-varying
`content (e.g., stock quotes, weather data, and sports scores).
`Madisetti Decl. ¶ 13 (citing Nazem, 1:60-2:14 (“Typically, the pages
`served are news pages, giving the user a custom selection of stock
`quotes, news headlines, sports scores, weather, and the like.”)).
`
`’407 Petition, at 8-10, 13, 20-41.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 31
`
`
`
`Berg was Publicly Accessible
`
`A prior art reference is publicly accessible if
`“disseminated or otherwise made available to
`the extent that persons interested and
`ordinarily skilled in the subject matter or art
`exercising reasonable diligence, can locate
`it.” Kyocera Wireless Corp. v. ITC, 545 F.3d
`1340, 1350 (Fed. Cir. 2008)
`
`’083 Reply at 13; ’407 Reply at 12.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 32
`
`
`
`Berg was Publicly Accessible
`• Mr. Berg testified that his article was publicly accessible and his
`testimony is unchallenged. Berg Dec. (Ex. 1005), at ¶¶ 2-3.
`
`Ex. 1007, at 1, 9.
`
`’407 Petition, at 9-10; ’083 Petition at 6-7.
`Petitioner Demonstrative Exhibit – Not Evidence – 33
`
`
`
`Sacerdoti Analysis of Berg
`
`’407 Reply at 12; ’083 Reply at 12.
`Ex. 1019, 78:22-79:7.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 34
`
`
`
`Razavi
`
`Razavi, Fig. 4; ’407 Petition, at 10-12, 20-41; ’083 Petition at 7-9, 18-37.
`Petitioner Demonstrative Exhibit – Not Evidence – 35
`
`
`
`Anderson
`
`Anderson, Fig. 2; ’407 Petition, at 12, 41-67; ’083 Petition at 9, 37-65.
`Petitioner Demonstrative Exhibit – Not Evidence – 36
`
`
`
`The Razavi & Anderson Combination
`
`One of skill in the art would have combined Razavi and
`Anderson:
`
`• Razavi and Anderson disclose similar systems in which
`Java applets can be downloaded over the Internet from a
`server and executed on a client device.
`
`• A POSA would have been motivated to employ the client
`computing device of Anderson to download and execute
`the detachable applets disclosed in Anderson.
`
`• Anderson discloses a conventional and well-known client
`device and network architecture routinely used to execute
`software programs, such as the applet disclosed in Razavi.
`
`’407 Petition at 62-63; ’083 Petition at 63-64.
`Petitioner Demonstrative Exhibit – Not Evidence – 37
`
`
`
`Dependent Claims
`
`• Fortin discloses a java applet that processes a markup
`language file to generate a GUI. Madisetti Decl. ¶ 224
`(citing Fortin ¶¶ 62-64).
`
`•
`
`“the ‘java applet’ 34 is utilized by the browser 32 to process
`documents in the markup language. . . . the applet
`accesses the file containing the markup language
`document and parses it in state 52 . . . [f]or example,
`referring to the document shown in Appendix II, a diagram
`having a size of 2,000 pixels by 2,000 is first defined …
`[t]he position of each graphical object within the diagram is
`determined. The graphical objects are then drawn on the
`display.”
`
`’407 Petition at 37-41, 64-67.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 38
`
`
`
`Dependent Claims
`
`Patent Owner only separately argues dependent claims 8 and
`20 of the ’407 Patent.
`• Claim 8. The client computing device of claim 1, wherein
`the networked information monitor template includes a
`markup language file.
`
`• Fortin discloses a Java application and an associated
`markup language file. The Java application can parse the
`markup language file to generate a GUI. Fortin discloses
`the use of the markup language file allows the generation of
`more advanced GUIs. Fortin, ¶¶ 6, 62-64.
`
`• One of skill in the art would modify Berg, Razavi, or
`Anderson to provide the more advanced GUI features of
`Fortin.
`’407 Petition at 13, 37-41, 64-67.
`Madisetti, ¶¶222-27; 368-369.
`
`Petitioner Demonstrative Exhibit – Not Evidence – 39
`
`
`
`Secondary Considerations
`
`To demonstrate nonobviousness based on
`“commercial success,” Patent Owner must “show
`both commercial success and that a nexus exists
`between that success and the merits of the claimed
`invention.” Transocean Offshore Deepwater Drilling,
`Inc. v. Maersk Drilling USA, Inc., 699 F.3d 1340, 1350
`(Fed. Cir. 2012)
`
`“To establish commercial success, the patentee must
`be armed with evidence of market share, growth in
`market share, and replacement of prior sales by
`others.” Brand Mgmt, Inc. v. Menard, Inc., No. 97-
`1329, 1998 WL 15241 at *11 (Fed. Cir. Jan. 14,
`1998)
`
`’083 Reply at 17-21; ’407 Reply at 16-20.
`Petitioner Demonstrative Exhibit – Not Evidence – 40
`
`
`
`Secondary Considerations Fail
`
`Patent Owner fails to show commercial success:
`
`• Mr. Ramde offers a speculative valuation of Patent
`Owner’s company during the height of the Internet
`bubble. He notes that he “was not familiar with that
`actual deal” but understands the deal collapsed.
`
`• The product was never completed or sold, rather it was
`offered in “beta-form” “free of charge.”
`
`• The company never made a profit, instead losing ~$1.1
`million per month during Mr. Ramde’s tenure.
`
`’083 Reply at 17-21; ’407 Reply at 16-20.
`Petitioner Demonstrative Exhibit – Not Evidence – 41
`
`
`
`Secondary Considerations Fail
`
`Patent Owner fails to show the requisite nexus:
`
`• Mr. Ramde testifies only that the inventors “enabled the
`delivery of custom-tailored content from the Internet
`without using a web browser and without the need for
`each Dot to be a standalone application.”
`
`• Patent Owner does not tie this stated aspiration to the
`claims.
`
`’083 Reply at 17-21; ’407 Reply at 16-20.
`Petitioner Demonstrative Exhibit – Not Evidence – 42
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Petitioner’s
`
`Demonstratives have been served electronically via email upon the following:
`
`Lewis E. Hudnell, III
`Hudnell Law Group PC
`lewis@hudnelllaw.com
`
`Perry Goldberg
`Progress LLP
`goldberg@progressllp.com
`
`Dated: October 27, 2020
`
`By: /John C. Alemanni/
`John C. Alemanni
`Reg. No. 47,384
`Lead Counsel for Petitioners
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
