UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.
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`Petitioner
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`v.
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`UNILOC 2017 LLC
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`Patent Owner
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`IPR2019-00056
`PATENT 6,467,088
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`PATENT OWNER PRELIMINARY RESPONSE TO PETITION
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`PURSUANT TO 37 C.F.R. §42.107(a)
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`Page 1 of 24
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.
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`Petitioner
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`v.
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`UNILOC 2017 LLC
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`Patent Owner
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`IPR2019-00056
`PATENT 6,467,088
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`PATENT OWNER PRELIMINARY RESPONSE TO PETITION
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`PURSUANT TO 37 C.F.R. §42.107(a)
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`Page 1 of 24
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`IPR2019-00056
`U.S. Patent 6,467,088
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`Table of Contents
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`I.
`II.
`III.
`IV.
`V.
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`INTRODUCTION .................................................................................... 1
`THE ’088 PATENT .................................................................................. 1
`RELATED PROCEEDINGS .................................................................... 3
`LEVEL OF ORDINARY SKILL IN THE ART ...................................... 3
`PETITIONER DOES NOT PROVE A REASONABLE
`LIKELIHOOD OF UNPATENTABILITY FOR ANY
`CHALLENGED CLAIM .......................................................................... 4
`A.
`Claim Construction ......................................................................... 4
`B.
`The Applied References Fail to Disclose
`“compar[[ing]/[e]] the determined component and
`information specifying at least one additional
`component currently implemented in the electronic
`device with at least one of [[a]/[the]] list of known
`acceptable configurations for the electronic device and
`[[a]/[the]] list of known unacceptable configurations for
`the electronic device” (Independent Claims 1, 11, and
`21) ................................................................................................... 5
`1.
`Cole in view of MacInnis and Elgressy
`(Petitioner’s Proposed Ground 1) Fails to
`Disclose “…least one of [[a]/[the]] list of known
`acceptable configurations for the electronic
`device and [[a]/[the]] list of known unacceptable
`configurations for the electronic device” ............................. 6
`Pitzel in view of Cole and Elgressy (Petitioner’s
`Proposed Ground 2) Fails to Disclose “…least
`one of [[a]/[the]] list of known acceptable
`configurations for the electronic device and
`[[a]/[the]] list of known unacceptable
`configurations for the electronic device” ........................... 10
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`2.
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`ii
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`C.
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`IPR2019-00056
`U.S. Patent 6,467,088
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`The Petition fails to Prove Obviousness of Any
`Dependent Claim .......................................................................... 15
`THE PETITION REDUNDANTLY CHALLENGES ALL
`CLAIMS (CLAIMS 1-21) ...................................................................... 15
`THE CONSTITUTIONALITY OF INTER PARTES REVIEW
`IS THE SUBJECT OF A PENDING APPEAL ..................................... 18
`VIII. CONCLUSION ....................................................................................... 18
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`VI.
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`VII.
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`iii
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`IPR2019-00056
`U.S. Patent 6,467,088
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`I.
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`INTRODUCTION
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`Uniloc 2017 LLC (“Uniloc” or “Patent Owner”) submits this Preliminary
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`Response to Petition IPR2019-00056 for Inter Partes Review (“Pet.” or “Petition”)
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`of United States Patent No. 6,467,088 (“the ’088 patent” or “EX1001”) filed by
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`Apple, Inc. (“Petitioner”). The instant Petition is procedurally and substantively
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`defective for at least the reasons set forth herein.
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`II.
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`THE ’088 PATENT
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`The ’088 patent is titled “Reconfiguration Manager for Controlling Upgrades
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`of Electronic Devices.” The ʼ088 patent issued October 15, 2002, from U.S. Patent
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`Application No. 09/343,607 filed January June 30, 1999.
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`The inventors of the ’088 patent observed that, at the time, many different
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`electronic devices, such as desktop, laptop and palmtop computers, personal digital
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`assistants (PDAs), telephones, televisions, set-top boxes and other consumer
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`electronic processing devices, it was common for there to be improvements to
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`software or hardware components of those electronic devices. And that users of
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`those electronic devices would often prefer to upgrade their devices, incrementally,
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`rather than discard their current devices and purchase new ones. And that for many
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`of those upgrades, it was generally necessary to determine if the new or improved
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`component is compatible with the rest of the device, and if not, what other
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`1
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`components would need simultaneous upgrading in order to provide the desired
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`compatibility, and that making those compatibility determinations could be
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`particularly difficult if the range of possible device configurations is large and the
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`interaction among device components is complex. EX1001, 1:12-39. Further, the
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`inventors of the ’088 patent also observed that while a number of different
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`techniques had been developed for updating components of electronic devices, there
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`were numerous problems and shortcomings with those existing techniques,
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`including such as failing to ensure compatibility among software and hardware
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`components for a variety of different electronic devices. Id., 1:30-2:14.
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`According to the invention of the ’088 patent, a reconfiguration manager is
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`provided that may be implemented on a computer or other data processing device to
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`control the reconfiguration of software or other components of an electronic device
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`such as a computer, personal digital assistant (PDA), set-top box, television, etc. In
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`accordance with the invention, a reconfiguration manager receives a reconfiguration
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`request, e.g., a software upgrade request from the electronic device, and determines
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`one or more device components that are required to implement the reconfiguration
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`request. The reconfiguration manager also determines, e.g., from information
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`supplied by the electronic device as part of the request, identifiers of one or more
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`additional components currently implemented in the electronic device. The
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`reconfiguration manager then compares the needed and currently implemented
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`2
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`components with previously-stored lists of known acceptable and unacceptable
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`configurations for the electronic device. If the needed and currently implemented
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`components correspond to a configuration on the list of acceptable configurations,
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`the request is approved and the needed components are downloaded or otherwise
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`supplied to the electronic device. If the needed and currently implemented
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`components correspond to a configuration on the list of unacceptable configurations,
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`the request is denied. The invention ensures that upgrades are compatible with the
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`configuration of a given device before they are implemented in that device, thereby
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`avoiding problems associated with inconsistent upgrades. Id., 2:22-67
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`III. RELATED PROCEEDINGS
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`The following proceedings are currently pending cases concerning U.S. Pat.
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`No. 6,467,088 (EX1001).
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`Case Caption
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`Case Number
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`District Case Filed
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`Uniloc USA, Inc. et al v. Apple
`Inc.
`IV. LEVEL OF ORDINARY SKILL IN THE ART
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`1-18-cv-00296
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`TXWD Apr. 09, 2018
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`The Petition alleges that a person of ordinary skill in the art (“POSITA”) “for
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`the ’088 patent would have had at least a Bachelor’s Degree in computer science,
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`computer engineering, or a related subject or the equivalent, and two years of
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`experience working with databases, computer networks, and related technologies.”
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`3
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`Pet. 7-8. Given that Petitioner fails to meet its burden of proof when purportedly
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`applying its own definition of a person of ordinary skill in the art, Patent Owner does
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`not offer a competing definition for purposes of this proceeding.
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`V.
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`PETITIONER DOES NOT PROVE A REASONABLE LIKELIHOOD
`OF UNPATENTABILITY FOR ANY CHALLENGED CLAIM
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`Petitioner has the burden of proof to establish entitlement to relief. 37 C.F.R.
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`§42.108(c) (“review shall not be instituted for a ground of unpatentability unless
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`. . . there is a reasonable likelihood that at least one of the claims challenged . . . is
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`unpatentable”). The Petition fails to meet this burden.
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`The Petition raises the following challenges:
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`Claims
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`Ground
`1
`2
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`1-21
`1-21
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`Reference(s)
`Cole1, MacInnis2 and Elgressy3
`Pitzel4, Cole, and Elgressy
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`A. Claim Construction
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`Patent Owner submits that the Board need not construe any claim term in a
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`particular manner in order to arrive at the conclusion that the Petition is
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`substantively deficient. Wellman, Inc. v. Eastman Chem. Co., 642 F.3d 1355, 1361
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`
`
` 1
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` EX1002, U.S. Patent No. 5,752,042.
`2 EX1003, PCT Application Publication No. WO 97/30549.
`3 EX1004, U.S. Patent No. 6,449,723.
`4 EX1005, U.S. Patent No. 7,062,765.
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`4
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`(Fed. Cir. 2011) (“need only be construed to the extent necessary to resolve the
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`controversy”). However, in the event that trial is instituted, Patent Owner reserves
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`the right to object to Petitioner’s proposed construction and provide Patent Owner’s
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`proposed construction.
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`B.
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`The Applied References Fail to Disclose “compar[[ing]/[e]] the
`determined component and information specifying at least one
`additional component currently implemented in the electronic
`device with at least one of [[a]/[the]] list of known acceptable
`configurations for the electronic device and [[a]/[the]] list of known
`unacceptable configurations for the electronic device”
`(Independent Claims 1, 11, and 21)
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`The Petition’s two grounds redundantly challenges claims 1-21, without
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`providing any alleged justification for such inefficient redundancies, and thus the
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`Board should only consider one of the two grounds (See Section VI, below).
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`Regardless, none of the applied references under either of Petitioner’s grounds
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`discloses the required claim limitations “compar[[ing]/[e]] the determined
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`component and information specifying at least one additional component currently
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`implemented in the electronic device with at least one of [[a]/[the]] list of known
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`acceptable configurations for the electronic device and [[a]/[the]] list of known
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`unacceptable configurations for the electronic device” of independent claims 1, 11,
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`and 21. More particularly, none of the applied reference discloses lists of known
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`acceptable and known unacceptable configurations.
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`5
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`IPR2019-00056
`U.S. Patent 6,467,088
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`1.
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`Cole in view of MacInnis and Elgressy (Petitioner’s Proposed
`Ground 1) Fails to Disclose “…least one of [[a]/[the]] list of
`known acceptable configurations for the electronic device and
`[[a]/[the]] list of known unacceptable configurations for the
`electronic device”
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`In Petitioner’s proposed Ground 1, for the claim limitation requiring at least
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`one of a “list of known acceptable configurations for the electronic device” and a
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`“list of known unacceptable configurations for the electronic device”, the Petition
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`relies exclusively on Cole for allegedly disclosing either one of the required lists.5
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`However, Cole fails to disclose either a list of known acceptable
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`configurations or a list of known unacceptable configurations for the electronic
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`device, as required by the claim language. The plain language of the claim limitation
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`requires that the lists be: (1) previously determined (i.e., “known”) and (2) specific
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`to the electronic device in question (i.e., “for the electronic device”). This
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`5 The Petition hypothetically and conditionally proposes a combination with
`MacInnis only for the purposes of the situation where “the device component
`required to implement the reconfiguration request” is a particular component
`requested by the electronic device. Pet. 23; see also Pet. 18-19 (describing MacInnis
`as disclosing a user terminal requesting “a particular software module” for
`installation.). The Petition also proposes a hypothetical combination with Elgressy
`only for the purposes of the situation where two lists are deemed required. See Pet.
`23-28 (describing Elgressy as disclosing a system where a gateway compares the
`resources of the computer needed by an executable object with the resources allowed
`or prohibited by a Security Policy.). Thus, the Petition relies solely on Cole for
`allegedly disclosing the claim requirement of a “list of known acceptable
`configurations.”
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`6
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`requirement is further confirmed by the specification of the ’088 patent:
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`IPR2019-00056
`U.S. Patent 6,467,088
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`EX1001, 4:62-5:18 (highlighting added).
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`As seen in the passages above, the claim language requires a previously
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`determined set of known bad configurations that can be searched and a previously
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`determined set of known good configurations that can be searched for a current
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`configuration for a specific electronic device (i.e. “device X”). In other words, the
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`claim language requires that the list contain previously determined acceptable or
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`unacceptable configurations specific to the electronic device in question. Cole fails
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`to disclose either such list.
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`As the Petition shows, Cole only discloses and utilizes a list of all available
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`updates without regard to the electronic device. The example given by Cole itself
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`(and used in the Petition) is illustrative, stating, that the “table list[s] code updates
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`available in content server 17”:
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`EX1002, 4:1-24 (highlighting added).
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`In other words, Cole merely looks to apply any and all code updates that are
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`stored in its content server 17, without regard for the specific electronic device and
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`certainly not utilizing a list of known acceptable/unacceptable configurations for the
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`specific electronic device. Cole makes this clearer in stating:
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`“In the illustrated embodiment, this determination is made
`by correlating the meta data in data base 13 to the basic
`system information obtained from client 14. Matches
`between the meta data and the basic system information
`indicate
`that
`the corresponding code updates are
`potentially appropriate for client 14.”
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`EX1002, 3:62-4:1 (emphasis added).
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`As disclosed above, the system of Cole merely iterates through every
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`available code update available, without information or knowledge about known
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`acceptable or unacceptable configurations for the electronic device, as is required
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`by the claim language. Even a match of Cole’s “meta data” can only be described
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`by Cole as a potentially appropriate.
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`This is further confirmed by the example from Cole:
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`9
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`U.S. Patent 6,467,088
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`EX1002, 4:25-33 (highlighting added).
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`As shown in the passage above, the system of Cole iterates through each and
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`every code update available on its content server 17 without any prior regard for the
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`electronic device. Indeed, the system of Cole iterates through each and every code
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`update available each and every time it is run without information or knowledge of
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`any previous iterations. Thus, there is nothing in Cole that discloses creating a list
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`of acceptable or unacceptable configurations for the specific electronic device.
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`Likewise, there is nothing in Cole that discloses previously determining and
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`maintaining such a list.
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`Thus, the Petition should be denied because it fails to show the required
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`“compar[[ing]/[e]] the determined component and information specifying at least
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`one additional component currently implemented in the electronic device with at
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`least one of [[a]/[the]] list of known acceptable configurations for the electronic
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`device and [[a]/[the]] list of known unacceptable configurations for the electronic
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`device”, in its proposed Ground 1.
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`2.
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`Pitzel in view of Cole and Elgressy (Petitioner’s Proposed
`Ground 2) Fails to Disclose “…least one of [[a]/[the]] list of
`known acceptable configurations for the electronic device and
`[[a]/[the]] list of known unacceptable configurations for the
`electronic device”
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`Similarly, and as described in Section V.B.1, above, Petitioner’s proposed
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`U.S. Patent 6,467,088
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`Ground 2 also fails for the claim limitation requiring at least one of a “list of known
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`acceptable configurations for the electronic device” and a “list of known
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`unacceptable configurations for the electronic device”. Here, the Petition relies
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`primarily on Pitzel, to hedges its bets using Cole in the identical manner as in its
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`proposed Ground 1 “to the extent” Pitzel is lacking. However, Pitzel – just like Cole
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`– fails to disclose the required claim limitation.6
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`Similar to Cole’s deficiencies, nothing in Pitzel discloses either a list of
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`known acceptable configurations or a list of known unacceptable configurations for
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`the electronic device, as required by the claim language. As discussed in Section
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`V.B.1, above, the plain language of the claim limitation requires that the lists be: (1)
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`previously determined (i.e., “known”) and (2) specific to the electronic device in
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`question (i.e., “for the electronic device”). This requirement is further confirmed by
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`the specification of the ’088 patent:
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`
`
` 6
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` Just like with Cole, the Petition proposes a hypothetical combination with Elgressy
`only for the purpose of a situation where two lists are deemed required. See Pet. 53-
`56 (describing Elgressy as disclosing a system where a gateway compares the
`resources of the computer needed by an executable object with the resources allowed
`or prohibited by a Security Policy.).
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`11
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`EX1001, 4:62-5:18 (highlighting added).
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`As seen in the passage above, the claim language requires a previously
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`determined set of known bad configurations that can be searched and a previously
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`determined set of known good configurations that can be searched for a current
`
`configuration of a specific electronic device (i.e. “device X”). In other words, the
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`claim language requires that the list contain previously determined acceptable or
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`unacceptable configurations specific to the electronic device in question. Pitzel fails
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`to disclose either such list.
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`Pitzel discloses in its “METHOD OF OPERATION” section that the client
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`computer initiates an upgrade request of one or more components through the user
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`accessing a plurality of web pages hosted on a configuration server, where at least
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`one of the web pages has information about one of the components. EX1005, 7:15-
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`30. By its own description, the configuration server of Pitzel merely hosts a
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`catalogue of all available components for the user to choose from. Nothing in that
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`transaction shows or utilizes the required list of known acceptable or unacceptable
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`configurations for the electronic device. In other words, hosting a catalogue of every
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`available component without regard for the specific electronic device is not the
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`required list of known acceptable or unacceptable configurations for the specific
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`electronic device.
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`The Petition’s cherry-picked fragment of a quote from Pitzel fares no better.
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`The Petition argues, by selecting a fragment of a sentence out of an entire section
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`from Pitzel, that the limitation is met because the component server allegedly
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`“select[s] components that are compatibly operable with the client.” Pet. 48.
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`However, the Petition presents the quoted fragment in conclusory fashion and
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`without context. A review of the relevant section in full reveals that upon the system
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`of Pitzel determining a user’s upgrade request of a component has not expired, for
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`that particular component, the upgrade handler module selects appropriate version(s)
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`of the upgrade to send back to the user. See EX1005, 9:29-10:30. Even in that
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`scenario, the system describes the upgrade handler searching among all of the
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`possible versions(s) of the components in determining what to send back to the user.
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`Nothing in that transaction shows or utilizes the required list of known acceptable or
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`unacceptable configurations for the electronic device. In other words, searching
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`through all possible version(s) of the component(s) without regard for the specific
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`electronic device is not the required list of known acceptable or unacceptable
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`configurations for the specific electronic device.
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`Moreover, as already shown in Section V.B.1, above, Petitioner’s reliance on
`
`Cole also fails. The system of Cole iterates through each and every code update
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`available on its content server without any prior regard for the electronic device. In
`
`other words, the system of Cole merely iterates through each and every code update
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`available each and every time, without information or knowledge of any previous
`
`iterations. As such, there is nothing in Cole that discloses creating a list of acceptable
`
`or unacceptable configurations for the specific electronic device, nor is there
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`anything in Cole that discloses previously determining and maintaining such a list.
`
`See Section V.B.1, above.
`
`Thus, the Petition should be denied because it fails to show the required
`
`“compar[[ing]/[e]] the determined component and information specifying at least
`
`one additional component currently implemented in the electronic device with at
`
`least one of [[a]/[the]] list of known acceptable configurations for the electronic
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`device and [[a]/[the]] list of known unacceptable configurations for the electronic
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`device”, in its proposed Ground 2.
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`C. The Petition fails to Prove Obviousness of Any Dependent Claim
`
`The deficiencies of the Petition articulated above concerning the challenged
`
`independent claims apply also taint the analysis of the challenged dependent claims.
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`Accordingly, the Petition should be denied in its entirety.
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`VI. THE PETITION REDUNDANTLY CHALLENGES ALL CLAIMS
`(CLAIMS 1-21)
`
`The Petition redundantly challenges all of the claims of the ’088 Patent,
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`without providing any alleged justification for such inefficient redundancies. As the
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`Board has previously explained, “multiple grounds, which are presented in a
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`redundant manner by a petitioner who makes no meaningful distinction between
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`them, are contrary to the regulatory and statutory mandates, and therefore are not all
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`entitled to consideration.” See Liberty Mut. Ins. Co. v. Progressive Cas. Ins. Co., No.
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`CBM2012-00003, Paper 7 (P.T.A.B. Oct. 25, 2012). Such redundancies place a
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`significant burden on both the Board and the patent owner, causing unnecessary
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`delay, compounding costs to all parties involved, and compromising the ability to
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`complete review within the statutory deadline. Id.; 37 C.F.R. § 42.1(b); see also 37
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`C.F.R. § 42.108. As such, analyzing the petition and eliminating redundant grounds
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`streamlines the proceeding. Idle Free Sys., Inc. v. Bergstrom, Inc., IPR2012-00027,
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`Paper 26 at 4-5 (P.T.A.B. June 11, 2013); Liberty Mut., CBM2012-00003, Paper 7
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`at 2.
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`The Petition presents grounds that are vertically redundant with respect to
`
`each other. Vertical redundancy “involves a plurality of prior art applied both in
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`partial combination and in full combination. In the former case, fewer references
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`than the entire combination are sufficient to render a claim obvious, and in the latter
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`case the entire combination is relied on to render the same claim obvious.” Liberty
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`Mut., CBM2012-00003, Paper 7 at 3. In such instances where reliance on a
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`combination and separate reliance on a portion thereof are both alleged to
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`sufficiently present a prima facie case of invalidity, “[t]here must be an explanation
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`of why the reliance in part may be the stronger assertion as applied in certain
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`instances and why the reliance in whole may also be the stronger assertion in other
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`instances.” Id. (emphasis in original).
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`If one of the alternative grounds is better from all perspectives, then the Board
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`should only consider the stronger ground and not burden the Patent Owner and the
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`Board with the weaker ground. Further, if there is no difference in the grounds, the
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`Petitioner should assert only one of the grounds. Id. at 12. “Only if the Petitioner
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`reasonably articulates why each ground has strength and weakness relative to the
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`other should both grounds be asserted for consideration.” Id. (emphasis added).
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`Petitioner makes no effort to justify its vertically redundant theories by
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`explaining why “the reliance in part [e.g., on the primary reference alone] may be
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`the stronger assertion as applied in certain instances and why the reliance in whole
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`[e.g., the full combination of identified references] may also be the stronger assertion
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`in other instances.” Id. Indeed, the Petition does not even acknowledge the
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`gamesmanship of hedging its bets through the redundancy of Grounds 1 and 2.
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`The Board in Eizo Corp. v. Barco N.V.7 flatly rejected a similar attempt to
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`hedge bets and unnecessarily multiply the work of both the Board and the Patent
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`Owner. The Board there found insufficient the petitioner’s “conclusory assertion”
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`that “[t]o the extent [the first prior art reference] may not explicitly teach” the
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`limitation, the second prior art reference “explicitly teaches this limitation.” The
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`Board explained that “such an assertion fails to resolve the exact differences sought
`
`to be derived from” the second prior art reference. Id.
`
`The Board’s precedential authority on these procedural issues is clear. Here,
`
`Petitioner impermissibly seeks the benefit of different bites at the apple, without
`
`providing a bi-directional explanation of the relative strengths and weaknesses of
`
`each redundantly offered ground. If Petitioner believes the obviousness challenges
`
`are necessary to addresses certain weaknesses of the challenge based on the Cole-
`
`
`
` IPR2014-00358, Paper 11 (P.T.A.B. July 23, 2014)
`
` 7
`
`17
`
`Page 20 of 24
`
`
`
`IPR2019-00056
`U.S. Patent 6,467,088
`
`MacInnis-Elgressy combination, Petitioner
`
`is obligated
`
`to articulate
`
`those
`
`weaknesses in the Petition itself. Because Petitioner chose to not offer such
`
`concessions, presumably for strategic reasons, the Board need not and should not
`
`consider the merits of the redundant challenges based on obviousness.
`
`VII. THE CONSTITUTIONALITY OF INTER PARTES REVIEW IS THE
`SUBJECT OF A PENDING APPEAL
`
`In a pending appeal to the Federal Circuit, Polaris Innovations Ltd. v.
`
`Kingston Technology, No. 18-01768, Dkt. No. 27, the patent owner Polaris argued
`
`that the Board’s appointment of administrative patent judges violates the
`
`Appointments Clause of Article II, and that their decisions must be set aside,
`
`because administrative patent judges are “appointed by the Secretary of Commerce,
`
`in consultation with the Director” of the USPTO, but without appointment by the
`
`President and confirmation by the Senate in violation of Article II, Section 2, Clause
`
`2 of the Constitution. Out of an abundance of caution, Patent Owner hereby adopts
`
`this constitutional challenge now to ensure the issue is preserved pending the appeal.
`
`VIII. CONCLUSION
`For at least the reasons set forth above, Uniloc respectfully requests that the
`
`18
`
`Page 21 of 24
`
`
`
`Board deny all challenges in the instant Petition.8
`
`Date: February 8, 2019
`
`
`
`
`
`
`
`Respectfully submitted,
`
`IPR2019-00056
`U.S. Patent 6,467,088
`
`
`By: /s/ Brett A. Mangrum
`Brett A. Mangrum; Reg. No. 64,783
`Attorney for Patent Owner
`
`
`
` 8
`
` Patent Owner does not concede, and specifically denies, that there is any legitimacy
`to any arguments in the instant Petition that are not specifically addressed herein.
`
`19
`
`Page 22 of 24
`
`
`
`IPR2019-00056
`U.S. Patent 6,467,088
`
`CERTIFICATE OF COMPLIANCE
`
`Pursuant to 37 C.F.R. § 42.24(d), we certify that this Preliminary Response
`
`to Petition complies with the type-volume limitation of 37 C.F.R. § 42.24(b)(1)
`
`because it contains fewer than the limit of 14,000 words, as determined by the
`
`word-processing program used to prepare the brief, excluding the parts of the
`
`brief exempted by 37 C.F.R. § 42.24(a)(1).
`
`Date: February 8, 2019
`
`Respectfully submitted,
`
`By: /s/ Brett A. Mangrum
`Brett A. Mangrum; Reg. No. 64,783
`Attorney for Patent Owner
`
`i
`
`Page 23 of 24
`
`
`
`IPR2019-00056
`U.S. Patent 6,467,088
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6(e), we certify that we served an electronic copy
`of the foregoing PATENT OWNER’S PRELIMINARY RESPONSE PURSUANT
`TO 37 C.F.R. § 42.107(a) along with any accompanying exhibits via the Patent
`Review Processing System (PRPS) to Petitioner’s counsel at the following
`addresses identified in the Petition’s consent to electronic service:
`
`Larissa S. Bifano (Reg. No. 59,051)
`James M. Heintz (Reg. No. 41,828)
`Michael Van Handel (Reg. No. 68,292)
`Apple-Uniloc-IPR@dlapiper.com
`
`Date: February 8, 2019
`
`Respectfully submitted,
`
`By: /s/ Brett A. Mangrum
`Brett A. Mangrum; Reg. No. 64,783
`Attorney for Patent Owner
`
`ii
`
`Page 24 of 24
`
`
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