`571-272-7822
`
`Paper 21
`Date: June 30, 2020
`CONSOLIDATED SCHEDULING ORDER
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`MEDTRONIC, INC. and MEDTRONIC VASCULAR, INC.,
`Petitioner,
`v.
`TELEFLEX INNOVATIONS S.À.R.L.,
`Patent Owner.
`
`
`IPR2020-00126 (Patent 8,048,032 B2)
`IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128 (Patent RE45,380)
`IPR2020-00129 (Patent RE45,380)
`IPR2020-00130 (Patent RE45,380)
`IPR2020-00132 (Patent RE45,760)
`IPR2020-00134 (Patent RE45,760)
`IPR2020-00135 (Patent RE45,776)
`IPR2020-00136 (Patent RE45,776)
`IPR2020-00137 (Patent RE47,379)
`IPR2020-00138 (Patent RE47,379)
`
`
`
`
`
`
`Before SHERIDAN K. SNEDDEN, JON B. TORNQUIST, and
`CHRISTOPHER G. PAULRAJ, Administrative Patent Judges.
`TORNQUIST, Administrative Patent Judge.
`
`
`CONSOLIDATED SCHEDULING ORDER
`
`
`
`
`
`IPR2020-00126, IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128, IPR2020-00129, IPR2020-00130 (Patent RE45,380)
`IPR2020-00132, IPR2020-00134 (Patent RE45,760)
`IPR2020-00135, IPR2020-00136 (Patent RE45,776)
`IPR2020-00137, IPR2020-00138 (Patent RE47,379)
`
`
`A. BACKGROUND
`On June 8, 2020, we instituted inter partes reviews in IPR2020-00126
`
`IPR2020-00128, IPR2020-00129, IPR2020-00132, IPR2020-00135, and
`IPR2020-00137. See, e.g., IPR2020-00126, Paper 22. On the same day, we
`issued a Scheduling Order in each of these proceedings. See IPR2020-
`00126, Paper 23.
`
`On June 25, 2020, we instituted inter partes reviews in IPR2020-
`00127, IPR2020-00130, IPR2020-00134, IPR2020-00136, and IPR2020-
`00138. See, e.g., IPR2020-00130, Paper 20.
`
`Because there is significant overlap of issues and prior art between the
`instituted proceedings, and to facilitate the handling of these proceedings in
`an efficient manner, we issue the following Consolidated Scheduling Order
`for the above-identified proceedings, including a separate briefing schedule
`for the issue of conception and reduction to practice. The prior Scheduling
`Order for IPR2020-00126 IPR2020-00128, IPR2020-00129, IPR2020-
`00132, IPR2020-00135, and IPR2020-00137 is hereby superceded by this
`Consolidated Scheduling Order.
`B.
`CONCEPTION AND REDUCTION TO PRACTICE
`In IPR2020-00126, -00128, -00129, -00132, -00134, -00135, and -
`
`00137, Patent Owner asserts that Itou is not prior art to the challenged
`patents because the inventions recited in the challenged claims were
`conceived and reduced to practice “before Itou’s priority date.” See
`IPR2020-00126, Paper 8, 21. In view of the common legal and factual
`issues presented, we provide a consolidated briefing and argument schedule
`
`2
`
`
`
`IPR2020-00126, IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128, IPR2020-00129, IPR2020-00130 (Patent RE45,380)
`IPR2020-00132, IPR2020-00134 (Patent RE45,760)
`IPR2020-00135, IPR2020-00136 (Patent RE45,776)
`IPR2020-00137, IPR2020-00138 (Patent RE47,379)
`
`for this issue. Specifically, Patent Owner may file a separate Patent Owner
`Response of 5000 words addressing only the issue of conception and
`reduction to practice for the patents challenged in IPR2020-00126, -00128, -
`00129, -00132, -00134, -00135, and -00137, Petitioner may file a 2800 word
`Reply, and Patent Owner may file a 2800 word Sur-reply.
`C.
`BRIEFING ON ASSERTED GROUNDS
`Briefing on all issues other than conception and reduction to practice
`in IPR2020-00126, -00128, -00129, -00132, -00134, -00135, and -00137
`shall be submitted in a Patent Owner Response of 12,000 words, a Reply of
`4750 words, and a Sur-Reply of 4750 words.
`The briefing schedule and word count limits for IPR2020-00127,
`IPR2020-00130, IPR2020-00136, and IPR2020-00138 remain unmodified
`and follow the schedule set forth in Appendix A (set forth below) and the
`word count limits set forth in 37 C.F.R. § 42.24.
`D. ORAL ARGUMENT
`If requested by DUE DATE 4, the Board anticipates two separate oral
`hearings. The oral hearings may be held during the morning and afternoon
`of the same day (DUE DATE 8), or they may be spread out over multiple
`days. The first hearing will address conception and reduction to practice in
`IPR2020-00126, -00128, -00129, -00132, -00134, -00135, and -00137 and
`the second hearing will address all other issues set forth in the parties’
`briefings in each of the above-captioned cases (including IPR2020-00127,
`IPR2020-00130, IPR2020-00136, and IPR2020-00138). If any party
`anticipates that additional time for oral hearings are necessary to address the
`
`3
`
`
`
`IPR2020-00126, IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128, IPR2020-00129, IPR2020-00130 (Patent RE45,380)
`IPR2020-00132, IPR2020-00134 (Patent RE45,760)
`IPR2020-00135, IPR2020-00136 (Patent RE45,776)
`IPR2020-00137, IPR2020-00138 (Patent RE47,379)
`
`issues presented in these proceedings, the parties shall address that issue
`during an initial conference call with the Board.
`Additionally, to the extent that any party anticipates that live
`testimony may be useful to present the factual issues in these proceedings,
`the parties shall make a request for such live testimony and identify all
`witnesses that it anticipates calling at the hearing as part of the Request for
`Oral Hearing submitted on DUE DATE 4. Although the Board does not
`envision that live testimony will be necessary at many oral arguments, the
`panel may consider whether live testimony is appropriate for the underlying
`factual issues related to conception and reduction to practice in IPR2020-
`00126, -00128, -00129, -00132, -00134, -00135, and -00137. For guidance
`on the scope and procedures for live testimony at Oral Argument, we refer
`the parties to DePuy Synthes Products, Inc. v. Medidea, L.L.C., Case
`IPR2018-00315, Paper 29 (Jan. 23, 2019) (precedential) and K-40
`Electronics, LLC v. Escort, Inc., Case IPR2013-00203, Paper 34 (May 21,
`2014) (precedential).
`GENERAL INSTRUCTIONS
`E.
`Initial and Additional Conference Calls
`1.
`The parties are directed to contact the Board within a month of this
`Order if there is a need to discuss proposed changes to this Scheduling Order
`or proposed motions that have not been authorized in this Order or other
`prior Order or Notice. See Consolidated Trial Practice Guide (“Consolidated
`
`4
`
`
`
`IPR2020-00126, IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128, IPR2020-00129, IPR2020-00130 (Patent RE45,380)
`IPR2020-00132, IPR2020-00134 (Patent RE45,760)
`IPR2020-00135, IPR2020-00136 (Patent RE45,776)
`IPR2020-00137, IPR2020-00138 (Patent RE47,379)
`
`Practice Guide”)1 at 9–10, 65 (guidance in preparing for a conference call);
`see also 84 Fed. Reg. 64,280 (Nov. 21, 2019). A request for an initial
`conference call shall include a list of proposed motions, if any, to be
`discussed during the call.
`The parties may request additional conference calls as needed. Any
`email requesting a conference call with the Board should: (a) copy all
`parties, (b) indicate generally the relief being requested or the subject matter
`of the conference call, (c) include multiple times when all parties are
`available, (d) state whether the opposing party opposes any relief requested,
`and (e) if opposed, either certify that the parties have met and conferred
`telephonically or in person to attempt to reach agreement, or explain why
`such meet and confer did not occur. The email may not contain substantive
`argument and, unless otherwise authorized, may not include attachments.
`See Consolidated Practice Guide at 9–10.
`2.
`Protective Order
`No protective order shall apply to this proceeding until the Board
`enters one. If either party files a motion to seal before entry of a protective
`order, a jointly proposed protective order shall be filed as an exhibit with the
`motion. It is the responsibility of the party whose confidential information is
`at issue, not necessarily the proffering party, to file the motion to seal.2 The
`Board encourages the parties to adopt the Board’s default protective order if
`
`
`1 Available at https://www.uspto.gov/TrialPracticeGuideConsolidated.
`2 If the entity whose confidential information is at issue is not a party to the
`proceeding, please contact the Board.
`
`5
`
`
`
`IPR2020-00126, IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128, IPR2020-00129, IPR2020-00130 (Patent RE45,380)
`IPR2020-00132, IPR2020-00134 (Patent RE45,760)
`IPR2020-00135, IPR2020-00136 (Patent RE45,776)
`IPR2020-00137, IPR2020-00138 (Patent RE47,379)
`
`they conclude that a protective order is necessary. See Consolidated Practice
`Guide at 107–122 (App. B, Protective Order Guidelines and Default
`Protective Order). If the parties choose to propose a protective order
`deviating from the default protective order, they must submit the proposed
`protective order jointly along with a marked-up comparison of the proposed
`and default protective orders showing the differences between the two and
`explain why good cause exists to deviate from the default protective order.
`The Board has a strong interest in the public availability of trial
`proceedings. Redactions to documents filed in this proceeding should be
`limited to the minimum amount necessary to protect confidential
`information, and the thrust of the underlying argument or evidence must be
`clearly discernible from the redacted versions. We also advise the parties
`that information subject to a protective order may become public if
`identified in a final written decision in this proceeding, and that a motion to
`expunge the information will not necessarily prevail over the public interest
`in maintaining a complete and understandable file history. See Consolidated
`Practice Guide at 21–22.
`
`Discovery Disputes
`3.
`The Board encourages parties to resolve disputes relating to discovery
`on their own. To the extent that a dispute arises between the parties relating
`to discovery, the parties must meet and confer to resolve such a dispute
`before contacting the Board. If attempts to resolve the dispute fail, a party
`may request a conference call with the Board.
`
`6
`
`
`
`IPR2020-00126, IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128, IPR2020-00129, IPR2020-00130 (Patent RE45,380)
`IPR2020-00132, IPR2020-00134 (Patent RE45,760)
`IPR2020-00135, IPR2020-00136 (Patent RE45,776)
`IPR2020-00137, IPR2020-00138 (Patent RE47,379)
`
`
`Testimony
`4.
`The parties are reminded that the Testimony Guidelines appended to
`the Consolidated Practice Guide at 127–130 (App. D, Testimony Guidelines)
`apply to this proceeding. The Board may impose an appropriate sanction for
`failure to adhere to the Testimony Guidelines. 37 C.F.R. § 42.12. For
`example, reasonable expenses and attorneys’ fees incurred by any party may
`be levied on a person who impedes, delays, or frustrates the fair examination
`of a witness.
`
`Cross-Examination
`5.
`Except as the parties might otherwise agree, for each due date:
`Cross-examination ordinarily takes place after any supplemental evidence is
`due. 37 C.F.R. § 42.53(d)(2).
`Cross-examination ordinarily ends no later than a week before the
`filing date for any paper in which the cross-examination testimony is
`expected to be used. Id.
`
`6. Motion to Amend
`Patent Owner may file a motion to amend without prior authorization
`from the Board. Nevertheless, Patent Owner must confer with the Board
`before filing such a motion. 37 C.F.R. § 42.121(a). To satisfy this
`requirement, Patent Owner should request a conference call with the Board
`no later than two weeks prior to DUE DATE 1. See Section B below
`regarding DUE DATES.
`Patent Owner has the option to receive preliminary guidance from the
`Board on its motion to amend. See Notice Regarding a New Pilot Program
`
`7
`
`
`
`IPR2020-00126, IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128, IPR2020-00129, IPR2020-00130 (Patent RE45,380)
`IPR2020-00132, IPR2020-00134 (Patent RE45,760)
`IPR2020-00135, IPR2020-00136 (Patent RE45,776)
`IPR2020-00137, IPR2020-00138 (Patent RE47,379)
`
`Concerning Motion to Amend Practice and Procedures in Trial Proceedings
`under the America Invents Act before the Patent Trial and Appeal Board, 84
`Fed. Reg. 9497 (Mar. 15, 2019) (“MTA Pilot Program Notice”); see also
`Consolidated Practice Guide at 67. If Patent Owner elects to request
`preliminary guidance from the Board on its motion, it must do so in its
`motion to amend filed on DUE DATE 1.
`Any motion to amend and briefing related to such a motion shall
`generally follow the practices and procedures described in MTA Pilot
`Program Notice unless otherwise ordered by the Board in this proceeding.
`The parties are further directed to the Board’s Guidance on Motions to
`Amend in view of Aqua Products (https://go.usa.gov/xU6YV), and
`Lectrosonics, Inc. v. Zaxcom, Inc., IPR2018-01129, Paper 15 (PTAB Feb.
`25, 2019) (precedential).
`At DUE DATE 3, Patent Owner has the option to file a reply to the
`opposition to the motion to amend and preliminary guidance, or a revised
`motion to amend. See MTA Pilot Program Notice at 9500–01. Patent
`Owner may elect to file a revised motion to amend even if Patent Owner did
`not request to receive preliminary guidance on its motion to amend. A
`revised motion to amend must provide amendments, arguments, and/or
`evidence in a manner that is responsive to issues raised in the preliminary
`guidance and/or Petitioner’s opposition.
`If Patent Owner files a revised motion to amend, the Board shall enter
`a revised scheduling order setting the briefing schedule for that revised
`
`8
`
`
`
`IPR2020-00126, IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128, IPR2020-00129, IPR2020-00130 (Patent RE45,380)
`IPR2020-00132, IPR2020-00134 (Patent RE45,760)
`IPR2020-00135, IPR2020-00136 (Patent RE45,776)
`IPR2020-00137, IPR2020-00138 (Patent RE47,379)
`
`motion and adjusting other due dates as needed. See MTA Pilot Program
`Notice at 9501, App. 1B.
`As also discussed in the MTA Pilot Program Notice, if the Board
`issues preliminary guidance on the motion to amend, and Patent Owner files
`neither a reply to the opposition to the motion to amend nor a revised motion
`to amend at DUE DATE 3, Petitioner may file a reply to the Board’s
`preliminary guidance, no later than three (3) weeks after DUE DATE 3. The
`reply may only respond to the preliminary guidance. Patent Owner may file
`a sur-reply in response to Petitioner’s reply to the Board’s preliminary
`guidance. The sur-reply may only respond to arguments made in the reply
`and must be filed no later than three (3) weeks after Petitioner’s reply. See
`MTA Pilot Program Notice at 9502. No new evidence may accompany the
`reply or the sur-reply in this situation.
`7.
`Oral Argument
`Requests for oral argument must comply with 37 C.F.R. § 42.70(a).
`To permit the Board sufficient time to schedule the oral argument, the
`parties may not stipulate to an extension of the request for oral argument
`beyond the date set forth in the Due Date Appendix.
`Unless the Board notifies the parties otherwise, oral argument, if
`requested, will be held at the USPTO headquarters in Alexandria.
`Seating in the Board’s hearing rooms may be limited, and will be
`available on a first-come, first-served basis. If either party anticipates that
`more than five (5) individuals will attend the argument on its behalf, the
`party should notify the Board as soon as possible, and no later than the
`
`9
`
`
`
`IPR2020-00126, IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128, IPR2020-00129, IPR2020-00130 (Patent RE45,380)
`IPR2020-00132, IPR2020-00134 (Patent RE45,760)
`IPR2020-00135, IPR2020-00136 (Patent RE45,776)
`IPR2020-00137, IPR2020-00138 (Patent RE47,379)
`
`request for oral argument. Parties should note that the earlier a request for
`accommodation is made, the more likely the Board will be able to
`accommodate additional individuals.
`F. DUE DATES
`This Order sets due dates for the parties to take action after institution
`of the proceeding. The parties may stipulate different dates for DUE
`DATES 1, 5, and 6, as well as the portion of DUE DATE 2 related to
`Petitioner’s reply (earlier or later, but no later than DUE DATE 3 for Patent
`Owner’s sur-reply) and the portion of DUE DATE 3 related to Patent
`Owner’s sur-reply (earlier or later, but no later than DUE DATE 7). The
`parties may not stipulate to a different date for the portion of DUE DATE 2
`related to Petitioner’s opposition to a motion to amend, or for the portion of
`DUE DATE 3 related to Patent Owner’s reply to an opposition to a motion
`to amend (or Patent Owner’s revised motion to amend) without prior
`authorization from the Board. In stipulating to move any due dates in the
`scheduling order, the parties must be cognizant that the Board requires four
`weeks after the filing of an opposition to the motion to amend (or the due
`date for the opposition, if none is filed) for the Board to issue its preliminary
`guidance, if requested by Patent Owner. A notice of the stipulation,
`specifically identifying the changed due dates, must be promptly filed. The
`parties may not stipulate an extension of DUE DATES 4, 7, and 8.
`In stipulating different times, the parties should consider the effect of
`the stipulation on times to object to evidence (37 C.F.R. § 42.64(b)(1)), to
`supplement evidence (§ 42.64(b)(2)), to conduct cross-examination
`
`10
`
`
`
`IPR2020-00126, IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128, IPR2020-00129, IPR2020-00130 (Patent RE45,380)
`IPR2020-00132, IPR2020-00134 (Patent RE45,760)
`IPR2020-00135, IPR2020-00136 (Patent RE45,776)
`IPR2020-00137, IPR2020-00138 (Patent RE47,379)
`
`(§ 42.53(d)(2)), and to draft papers depending on the evidence and cross-
`examination testimony.
`
`DUE DATE 1
`
`1.
`Patent Owner may file—
`a. A response to the petition (37 C.F.R. § 42.120), as discussed
`above. If Patent Owner elects not to file a response, Patent Owner must
`arrange a conference call with the parties and the Board. Patent Owner is
`cautioned that any arguments not raised in the response may be deemed
`waived.
`b. A separate response to the petition addressing conception and
`reduction to practice in IPR2020-00126, -00128, -00129, -00132, -00134, -
`00135, and -00137.
`c. A motion to amend the patent (37 C.F.R. § 42.121).
`DUE DATE 2
`2.
`Petitioner may file a reply to the Patent Owner’s response.
`Petitioner may file a reply to the Patent Owner’s response
`
`regarding conception and reduction to practice.
`Petitioner may file an opposition to the motion to amend.
`DUE DATE 3
`3.
`Patent Owner may file a sur-reply to Petitioner’s reply.
`Patent Owner may file a sur-reply to Petitioner’s reply
`regarding conception and reduction to practice.
`Patent Owner may also file either:
`
`11
`
`
`
`IPR2020-00126, IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128, IPR2020-00129, IPR2020-00130 (Patent RE45,380)
`IPR2020-00132, IPR2020-00134 (Patent RE45,760)
`IPR2020-00135, IPR2020-00136 (Patent RE45,776)
`IPR2020-00137, IPR2020-00138 (Patent RE47,379)
`
`
`a. a reply to the opposition to the motion to amend and/or preliminary
`guidance (if provided); or
`b. a revised motion to amend.
`NOTE: If Patent Owner files neither of the above papers (a reply to
`the opposition or a revised motion to amend), and the Board has issued
`preliminary guidance, Petitioner may file a reply to the preliminary
`guidance, no later than three (3) weeks after DUE DATE 3. Patent Owner
`may file a sur-reply to Petitioner’s reply to the preliminary guidance no later
`than three (3) weeks after Petitioner’s reply.
`DUE DATE 4
`4.
`Either party may file a request for oral argument, including a request
`for live testimony and identification of all witnesses (may not be extended
`by stipulation).
`
`DUE DATE 5
`5.
`Petitioner may file a sur-reply to Patent Owner’s reply to the
`opposition to the motion to amend.
`Either party may file a motion to exclude evidence (37 C.F.R.
`§ 42.64(c)).
`
`DUE DATE 6
`6.
`Either party may file an opposition to a motion to exclude evidence.
`Either party may request that the Board hold a pre-hearing conference.
`DUE DATE 7
`7.
`Either party may file a reply to an opposition to a motion to exclude
`evidence.
`
`12
`
`
`
`IPR2020-00126, IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128, IPR2020-00129, IPR2020-00130 (Patent RE45,380)
`IPR2020-00132, IPR2020-00134 (Patent RE45,760)
`IPR2020-00135, IPR2020-00136 (Patent RE45,776)
`IPR2020-00137, IPR2020-00138 (Patent RE47,379)
`
`
`DUE DATE 8
`8.
`Both oral arguments (if requested by either party) shall be held on this
`date. Approximately one month prior to the arguments, the Board will issue
`an order setting the start time of the hearings and the procedures that will
`govern the parties’ arguments.
`
`13
`
`
`
`IPR2020-00126, IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128, IPR2020-00129, IPR2020-00130 (Patent RE45,380)
`IPR2020-00132, IPR2020-00134 (Patent RE45,760)
`IPR2020-00135, IPR2020-00136 (Patent RE45,776)
`IPR2020-00137, IPR2020-00138 (Patent RE47,379)
`
`
`DUE DATE APPENDIX
`
`DUE DATE 1 .................................................................. September 17, 2020
`Patent Owner’s response to the petition
`Patent Owner’s response regarding conception and reduction to
`practice
`Patent Owner’s motion to amend the patent
`DUE DATE 2 ................................................................... December 10, 2020
`Petitioner’s reply to Patent Owner’s response to petition
`Petitioner’s reply to Patent Owner’s response regarding conception
`and reduction to practice
`Petitioner’s opposition to motion to amend
`DUE DATE 3 ....................................................................... January 21, 2021
`Patent Owner’s sur-reply to reply
`Patent Owner’s sur-reply to reply regarding conception and reduction
`to practice
`Patent Owner’s reply to opposition to motion to amend
`(or Patent Owner’s revised motion to amend)3
`DUE DATE 4 ....................................................................... January 28, 2021
`Request for oral argument (may not be extended by stipulation)
`DUE DATE 5 ..................................................................... February 18, 2021
`Petitioner’s sur-reply to reply to opposition to motion to amend
`Motion to exclude evidence
`
`
`3 If Patent Owner files neither a reply to Petitioner’s opposition to the MTA
`nor a revised MTA, the parties are directed to Section B(3) above.
`
`14
`
`
`
`IPR2020-00126, IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128, IPR2020-00129, IPR2020-00130 (Patent RE45,380)
`IPR2020-00132, IPR2020-00134 (Patent RE45,760)
`IPR2020-00135, IPR2020-00136 (Patent RE45,776)
`IPR2020-00137, IPR2020-00138 (Patent RE47,379)
`
`DUE DATE 6 ..................................................................... February 25, 2021
`Opposition to motion to exclude
`Request for prehearing conference
`DUE DATE 7 ........................................................................... March 4, 2021
`Reply to opposition to motion to exclude
`DUE DATE 8 ........................................................................... March 8, 2021
`Oral arguments (if requested)
`
`
`15
`
`
`
`IPR2020-00126, IPR2020-00127 (Patent 8,048,032 B2)
`IPR2020-00128, IPR2020-00129, IPR2020-00130 (Patent RE45,380)
`IPR2020-00132, IPR2020-00134 (Patent RE45,760)
`IPR2020-00135, IPR2020-00136 (Patent RE45,776)
`IPR2020-00137, IPR2020-00138 (Patent RE47,379)
`
`FOR PETITIONER:
`
`Cyrus Morton
`cmorton@robinskaplan.com
`
`Sharon Roberg-Perez
`sroberg-perez@robinskaplan.com
`
`Christopher Pinahs
`cpinahs@robinskaplan.com
`
`
`FOR PATENT OWNER:
`
`Derek Vandenburgh
`dvandenburgh@carlsoncaspers.com
`
`Dennis Bremer
`dbremer@carlsoncaspers.com
`
`
`16
`
`