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`Paper No.
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`Filed: September 23, 2020
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner,
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`v.
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`BELL NORTHERN RESEARCH, LLC,
`Patent Owner.
`____________________
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`Case IPR2020-00611
`Patent 8,416,862
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`
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`Petitioner’s Request for Rehearing
`Under 37 C.F.R. § 42.71(d)(2)
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`IPR2020-00611
`Patent 8,416,862
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`TABLE OF CONTENTS
`STATEMENT OF THE PRECISE RELIEF REQUESTED .......................1
`I.
`LEGAL STANDARD ..........................................................................2
`II.
`III. STATEMENT OF REASONS FOR RELIEF REQUESTED .....................2
`A.
`The Board Overlooked or Misapprehended that Samsung’s
`Expert Testimony Outweighs BNR’s Attorney Arguments ...............3
`The Board Improperly Discounted Samsung’s Expert’s
`Testimony Based on a Requirement of Personal Knowledge of
`the Practices of a Specific Library .................................................7
`The Board Improperly Imposed a Requirement That Samsung
`Establish the Publication Date of References Citing Haykin ........... 11
`IV. CONCLUSION ................................................................................. 14
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`B.
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`C.
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`i
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`TABLE OF AUTHORITIES
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`IPR2020-00611
`Patent 8,416,862
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` Page(s)
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`Cases
`BioMarin Pharma. Inc. v. Genzyme Therapeutic Prods. Ltd. P’ship,
`IPR2013-00534, Paper 80, 5–6 (Jan. 7, 2015) .............................................. 7
`Google LLC v. IPA Techs. Inc.,
`IPR2019-00728, Paper 11 (Sept. 4, 2019) .................................................... 9
`GoPro, Inc. v. Contour IP Holding LLC,
`IPR2015-01078, Paper 28 (Dec. 28, 2015) ................................................... 6
`In re Hall,
`781 F.2d 897 (Fed. Cir. 1986) .................................................................... 7
`Hulu, LLC v. Sound View Innovations, LLC,
`IPR2018-01039, Paper 29 (Dec. 20, 2019) .......................................... passim
`Jazz Pharms. Inc. v. Amneal Pharms., Inc.,
`895 F.3d 1347 (Fed. Cir. 2018) .................................................................. 4
`LG Elecs., Inc. v. Bell N. Research, LLC,
`IPR2020-00108, Paper 14 (May 20, 2020) ............................................. 9, 10
`Medtronic, Inc. v. Barry,
`891 F.3d 1368 (Fed. Cir. 2018) .................................................................. 4
`RPX Corp. v. IYM Techs. LLC,
`IPR2017-01888, Paper 16 (May 14, 2018) ................................................... 6
`Samsung Elecs. Co., Ltd. v. M & K Holdings Inc.,
`IPR2018-00696, Paper 48 (Sept. 4, 2019) .................................................. 11
`Seabery North America Inc. v. Lincoln Global, Inc.,
`IPR2016-00840, Paper 40 (Mar. 15, 2017)................................................... 6
`Unified Patents Inc. v. Sound View Innovations, LLC,
`IPR2018-00599, Paper 50 (Sept. 9, 2019) .................................................... 9
`
`ii
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`IPR2020-00611
`Patent 8,416,862
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`
`Valeo North America, Inc. v. Magna Elecs., Inc.,
`IPR2014-01204, Paper 26 (Apr. 10, 2015) ................................................... 7
`Statutes
`35 U.S.C. § 102(a) ........................................................................................ 1
`Other Authorities
`37 C.F.R. § 42.71(d)...................................................................................... 2
`37 C.F.R. § 42.108(c) .................................................................................... 3
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`iii
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`IPR2020-00611
`Patent 8,416,862
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`
`I.
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`STATEMENT OF THE PRECISE RELIEF REQUESTED
`Petitioner Samsung Electronics Co., Ltd. (“Petitioner” or “Samsung”)
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`requests rehearing of the Board’s Decision (Paper 11, “Decision”), denying
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`institution of Samsung’s IPR petition (Paper 1, “Petition”) for claims 9-12 of U.S.
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`Patent No. 8,416,862 (“the ’862 patent”). The Board found that Samsung did not
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`establish that Haykin (Ex.1010) qualifies as prior art under 35 U.S.C. § 102(a). The
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`Board’s Decision is erroneous in several respects, as Samsung established a
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`reasonable likelihood that Haykin qualifies as a printed publication under the totality
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`of the evidence.
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`Patent Owner Bell Northern Research, LLC (“Patent Owner” or “BNR”) did
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`not submit expert testimony supporting its arguments regarding Haykin, yet the
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`Board credited BNR’s attorney arguments concerning details relating to the
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`publication history of Haykin over the expert testimony of Dr. Ingrid Hsieh-Yee
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`submitted by Samsung. Dr. Hsieh-Yee offered her expert opinion based on a
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`detailed analysis of relevant facts and her two-plus decades of experience in the
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`library sciences. The Board improperly discounted her testimony based on a
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`requirement of personal knowledge of past practices of the Library of Congress,
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`including at the time of publication of the Haykin reference. Similarly, the Board
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`provided no legal guidance to support its criticism of Samsung for not sufficiently
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`establishing the publication dates of prior art references citing Haykin. The Board
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`1
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`misapprehended the testimony of Dr. Hsieh-Yee, who offered her opinion as a
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`IPR2020-00611
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`librarian expert in the field of cataloging and classification relevant to the underlying
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`questions as to the public availability of a Library of Congress stamped textbook
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`(like Haykin). The Board at a minimum should have instituted trial for further
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`development of the record regarding this factual dispute, or at least offered Samsung
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`the opportunity to address the requirements that the Board imposed in its Decision.
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`For these reasons, Samsung respectfully requests that the Board reconsider its
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`decision and institute review.
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`II. LEGAL STANDARD
`“A party dissatisfied with a decision may file a single request for rehearing.”
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`37 C.F.R. § 42.71(d). “The request must specifically identify all matters the party
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`believes the Board misapprehended or overlooked, and the place where each matter
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`was previously addressed in a motion, an opposition, or a reply.” Id.
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`III. STATEMENT OF REASONS FOR RELIEF REQUESTED
`The Board found that “Petitioner does not identify, with particularity,
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`evidence sufficient to establish a reasonable likelihood that Haykin was publicly
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`accessible—and thus qualifies as a printed publication—no later than December 24,
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`2004 (or prior to April 21, 2005, the earliest possible effective filing date for the
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`challenged claims).” (Decision at 16; see also id. at 7-15.) Respectfully, the Board
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`erred for several reasons, as discussed below.
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`2
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`A. The Board Overlooked or Misapprehended that Samsung’s
`Expert Testimony Outweighs BNR’s Attorney Arguments
`The Petition cited to Hulu, LLC v. Sound View Innovations, LLC, IPR2018-
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`01039, Paper 29 (Dec. 20, 2019) (precedential) (Petition at 6), which held that at the
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`institution stage, a petitioner must establish a “reasonable likelihood that a reference
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`qualifies as a printed publication.” Hulu at 13. Hulu further explained that “[w]e do
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`not hold that any particular indicia per se is sufficient at the institution stage” and
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`“[r]ather, the indicia on the face of a reference, such as printed dates and stamps, are
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`considered as part of the totality of the evidence.” Id. at 17-18; see also id. at 21.
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`The Board overlooked or misapprehended Hulu’s instruction as it failed to
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`account for Dr. Hsieh-Yee’s detailed expert analysis (Ex. 1019) opining on
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`numerous pertinent facts including publication-related indicia on Haykin, which
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`clearly outweighed BNR’s attorney arguments (at least at this pre-institution stage).
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`Instead, the Board’s Decision simply adopted BNR’s unsupported attorney
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`arguments without explaining why Dr. Hsieh-Yee’s testimony was not credible.
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`Even if BNR had submitted testimonial evidence (which it did not) with its
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`preliminary response (Paper 8, “POPR”), “a genuine issue of material fact created
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`by such testimonial evidence will be viewed in the light most favorable to the
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`petitioner solely for purposes of deciding whether to institute an inter partes
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`review.” Hulu at 16-17 n.6 (citing 37 C.F.R. § 42.108(c)).
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`3
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`Indeed, as Hulu recognized, the printed publication inquiry calls for a legal
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`conclusion based on underlying factual findings, where “[t]he underlying factual
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`findings include whether the reference was publicly accessible.” Id. at 8-9 (citing
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`Medtronic, Inc. v. Barry, 891 F.3d 1368, 1380 (Fed. Cir. 2018); Jazz Pharms. Inc.
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`v. Amneal Pharms., Inc., 895 F.3d 1347, 1355-56 (Fed. Cir. 2018)). Dr. Hsieh-Yee
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`provided extensive testimony regarding Haykin’s public accessibility, analyzing in
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`detail numerous facts (Ex. 1019 at ¶¶36-49) and providing her expert opinion that
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`Haykin “would have been available for public access by December 24, 2004, at the
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`latest” (id. at ¶50). The Petition, supported by Dr. Hsieh-Yee’s testimony,
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`established that Haykin was “publicly accessible before the alleged invention of the
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`’862 patent.” (Petition at 4-6; Ex. 1019 at ¶¶1-18, 36-50; see also Ex. 1019 at pp.68-
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`87 (Dr. Hsieh-Yee’s CV).)
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`In concluding that Samsung’s evidence is insufficient, the Board, relying on
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`BNR’s attorney arguments, noted that Haykin has a listed copyright date of 2005
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`and a call number that includes “2005.” (Decision at 13; POPR at 58.) Dr. Hsieh-
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`Yee, too, noted these facts (Ex. 1019 at ¶¶37-38, 42), but she also evaluated other
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`indicia in Haykin and many other aspects of the Library of Congress’ cataloging
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`process making Haykin available to the public (id. at ¶¶38-48), based on her
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`“understanding of the ordinary and customary cataloging and processing practices
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`of libraries” (overlooked by the Board), to arrive at her expert conclusion. (Id. at
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`4
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`¶50.) Even focusing on indicia alone would have compelled a different result—the
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`Board (based on BNR’s attorney arguments) noted repeatedly Haykin’s 2005
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`copyright date, but under BNR’s own logic the date stamp “LIBRARY OF
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`CONGRESS APR 05 2004 COPYRIGHT OFFICE” on the copyright page of
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`Haykin—directly adjacent to the 2005 copyright date—constitutes probative
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`evidence supporting Samsung’s position thoroughly discussed by Dr. Hsieh-Yee.
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`(Ex. 1010 at 6 (emphasis added); Ex. 1019 at ¶¶37, 46-48, 50; Petition at 5.) The
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`Board overlooked these facts. Indeed, such a contrast in indicia underscores the
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`need for expert testimony for the public accessibility analysis, and also the
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`importance of considering the totality of the evidence, including the lack of any
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`evidence that would support any discredit of Dr. Hsieh-Yee’s ultimate expert
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`opinion that Haykin was publicly available December 24, 2004, at the latest.
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`The Board also relied on BNR’s attorney arguments regarding Field 008 of
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`Haykin’s MARC record. (Decision at 13; POPR at 57-58.) Dr. Hsieh-Yee, too,
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`analyzed the MARC record, including Field 008. (Ex. 1019 at ¶40; see also id. at
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`¶¶39, 41-45, Appx. 1010-B (pp.149-150).) But unlike BNR, Dr. Hsieh-Yee relied
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`on her training (Ph.D. in Library and Information Sciences), her years of relevant
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`experience working in multiple libraries, and teaching in the field for more than 25
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`years (id. at ¶6) along with her expertise in library cataloging (id. at ¶7; see also id.
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`at ¶¶8-9) and familiarity with the MARC record standard (id. at ¶8) to form her
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`5
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`expert opinion that the MARC record, along with all of the other evidence she
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`considered, demonstrated that Haykin was publicly available at the latest on
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`December 24, 2014 . As an expert in library cataloging who is “very familiar” with
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`MARC records (id. at ¶8), Dr. Hsieh-Yee’s opinion merited more weight than
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`BNR’s attorney arguments.
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`Given Dr. Hsieh-Yee’s credentials, her extensive expert testimony and
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`underlying supporting facts, the Board erred in finding that Samsung did not
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`establish a reasonable likelihood that Haykin qualifies as a printed publication. Any
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`questions concerning the factual underpinnings relating to this issue should have
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`been left for trial, where cross-examination of Dr. Hsieh-Yee and other instruments
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`of discovery could frame the issue for a proper assessment of such evidence. Thus,
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`the Board should have instituted trial to let the record develop further for fully
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`evaluating the disputes raised by BNR. See Hulu, IPR2018-01039, Paper 29 at 21
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`(“Should trial be instituted, Patent Owner may challenge Petitioner’s evidence, and
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`Petitioner may respond if appropriate, as indicated herein.”); see also id. at 3, 8, 13-
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`16. Indeed, the Board routinely allows parties to develop the record regarding public
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`availability of references post-institution. See, e.g., Seabery North America Inc. v.
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`Lincoln Global, Inc., IPR2016-00840, Paper 40 at 5-6 (Mar. 15, 2017); RPX Corp.
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`v. IYM Technologies LLC, IPR2017-01888, Paper 16 at 3-4 (May 14, 2018); GoPro,
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`Inc. v. Contour IP Holding LLC, IPR2015-01078, Paper 28 at 3-5 (Dec. 28, 2015);
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`6
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`Valeo North America, Inc. v. Magna Elecs., Inc., IPR2014-01204, Paper 26 at 4-5
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`IPR2020-00611
`Patent 8,416,862
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`(Apr. 10, 2015); BioMarin Pharma. Inc. v. Genzyme Therapeutic Prods. Ltd. P’ship,
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`IPR2013-00534, Paper 80, 5–6 (Jan. 7, 2015). Samsung should have been afforded
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`the same treatment here, especially given the evidence and unrebutted expert
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`testimony in this record.
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`B. The Board Improperly Discounted Samsung’s Expert’s
`Testimony Based on a Requirement of Personal Knowledge of the
`Practices of a Specific Library
`The Board improperly faulted Samsung for not relying on the declaration of
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`“someone who has first-hand knowledge of the practices of the Library of Congress
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`during the relevant time period.” (Decision at 14.) While the Board cited In re Hall
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`regarding a declarant’s factual testimony about his library’s general practices
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`(Decision at 14), the Federal Circuit in that case did not require that a librarian expert
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`must have first-hand knowledge of the specific library housing the reference in the
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`relevant time period to support her opinions as to the public availability of the
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`reference. In re Hall, 781 F.2d 897, 899 (Fed. Cir. 1986). Rather, In re Hall
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`described one exemplary scenario that supported a printed publication finding, but
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`as explained in Hulu it is the totality of the evidence that governs the ultimate
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`conclusion. Hulu, IPR2018-01039, Paper 29 at 17-18.
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`Samsung offered Dr. Hsieh-Yee as an expert witness to provide her opinion
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`concerning Haykin. Indeed, Dr. Hsieh-Yee is an expert on library cataloging and a
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`7
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`Professor in the Department of Library and Information Science at a university, and
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`IPR2020-00611
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`she holds a Ph.D. in Library and Information Studies. (Petition at 4 (citing Ex.
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`1019); Ex. 1019 at ¶¶6-7.) She has published books regarding library cataloging and
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`has taught courses in that subject. (Ex. 1019 at ¶7.) Additionally, for her analysis
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`she relied on documents that other experts in her field would reasonably rely upon
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`when forming their opinions (id. at ¶2), and she explained that she is “very familiar”
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`with the MARC standard that she testified about. (Id. at ¶8; see also id. at ¶¶9-12,
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`Appx. 1010-B (pp.148-150).) Dr. Hsieh-Yee’s CV explains that she was the
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`Principal Investigator for a Library of Congress Action Plan involving cataloging
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`and metadata education in the 2002-2003 timeframe—which is before and
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`contemporaneous with the 2004-2005 time frame associated with the publication
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`issues involving Haykin. (Ex. 1019 at p.83; see also id. at p.71 (citing to a report by
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`Dr. Hsieh-Yee involving the same Library of Congress Action Plan); Petition at 4
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`(citing Ex. 1019 at ¶¶1-8, including ¶5).) These facts, which the Decision does not
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`address, support Dr. Hsieh-Yee’s opinions concerning Haykin and its availability at
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`the Library of Congress at the time.
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`In light of Dr. Hsieh-Yee’s extensive qualifications on subjects relevant to
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`Haykin’s public accessibility, the Board erred in imposing such a narrow
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`requirement as described above (which Dr. Hsieh-Yee’s experience set forth in her
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`CV supported and at a minimum warranted Samsung an opportunity to defend).
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`8
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`Accordingly, the Board overlooked and/or misapprehended the significance of Dr.
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`Hsieh-Yee’s testimony and the underlying factual record associated with her
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`qualifications and her expert opinion offered in this case. As discussed above in
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`Section III.A, the totality of the evidence, not any specific requirement regarding a
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`librarian expert, controls the public accessibility inquiry. Here, Dr. Hsieh-Yee’s
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`experience and detailed testimony contribute significantly to the totality of the
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`evidence, particularly given that BNR did not submit any testimony from a declarant
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`with such personal knowledge to rebut Dr. Hsieh-Yee’s expert testimony.
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`The Board was also inconsistent in propounding such requirements against
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`Samsung in this case. Petitioners have offered the testimony of librarian experts on
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`the procedures by which libraries catalog items and make them available to the
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`public without specific testimony as to their personal knowledge of such library
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`procedures at the time a non-patent literature reference at-issue, and the Board
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`routinely has accepted such expert testimony at the institution stage. See, e.g.,
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`Unified Patents Inc. v. Sound View Innovations, LLC, IPR2018-00599, Paper 50 at
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`26-34 (Sept. 9, 2019) (finding a reference publicly available based in part on Dr.
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`Hsieh-Yee’s testimony); Google LLC v. IPA Techs. Inc., IPR2019-00728, Paper 11
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`at 25 (Sept. 4, 2019) (same); LG Elecs., Inc. v. Bell N. Research, LLC, IPR2020-
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`00108, Paper 14 at 39 (May 20, 2020). Indeed, in the prior IPR on the ’862 patent,
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`the Board instituted the IPR and in doing so, the Board correctly did not impose any
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`9
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`requirement on petitioner (LG) to establish that its librarian expert had first-hand
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`knowledge of the practices, in the relevant time period, of the library where a
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`reference in question was maintained. LG Elecs., Inc., IPR2020-00108, Ex. 1021;
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`LG Elecs., Inc., IPR2020-00108, Paper 14 at 39. Samsung’s petition should have
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`been afforded the same treatment here on the same patent.
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`The Board also criticized Dr. Hsieh-Yee’s testimony regarding at most three
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`months elapsing between sending the physical copy of Haykin to the Library of
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`Congress’s processing unit and the book becoming accessible to the public. (Ex.
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`1019 at ¶¶47, 48, 50; Decision at 14.) The existing record before the Board shows
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`that Dr. Hsieh’s testimony on that point was based on her substantial experience and
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`expertise in library procedures and cataloguing, and an overly conservative estimate
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`given her undisputed opinion that “[i]n most academic libraries a newly cataloged
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`book becomes available for the public . . . usually within a week.” (Ex. 1019 at ¶47.)
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`To the extent the Board’s finding with respect to Dr. Hsieh-Yee’s testimony was
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`based on a perceived credibility concern, those issues should have been left for
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`trial—especially since BNR did not present any evidence, much less expert
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`testimony, on this point in rebuttal. The Board erred in finding Dr. Hsieh-Yee’s
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`supported testimony less reliable than other indicia described only by BNR’s
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`attorneys. (Decision at 14.)
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`10
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`C. The Board Improperly Imposed a Requirement That Samsung
`Establish the Publication Date of References Citing Haykin
`Dr. Hsieh-Yee also provided her opinion regarding citations to Haykin in
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`publications before the ’862 patent’s critical date. (Ex. 1019 at ¶49, Appx. 1010-C
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`(pp.152-153); Exs. 1045-1047; Petition at 5-6.) Such citations to Haykin contribute
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`significantly to the totality of the evidence. Yet, the Board found Samsung did not
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`“establish[] sufficiently the publication dates of those citing references.” (Decision
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`at 15.) But the Board did not cite any legal authority imposing such a requirement.
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`The Board thus erred in requiring this of Samsung when the relevant inquiry is
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`whether the totality of the evidence establishes a reasonable likelihood that Haykin
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`was publicly accessible before the invention date. Hulu at 17-18, 21.
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`In fact, the Board has previously found that even when references citing to a
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`prior art reference subject to printed publication review were not publicly available
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`prior to the critical date of a patent, they can nonetheless be corroborating evidence
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`regarding the publicly accessibility of the given reference. Samsung Elecs. Co., Ltd.
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`v. M & K Holdings Inc., IPR2018-00696, Paper 48 at 27-28 (Sept. 4, 2019) (finding
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`that although certain references were not “publicly available prior to … the critical
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`filing date of the [patent-at-issue],” “they corroborate [the petitioner’s] showing” of
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`public accessibility of a reference-at-issue). Similarly here, the references cited by
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`Dr. Hsieh-Yee corroborate Samsung’s showing regarding public accessibility.
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`11
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`(Petition at 5-6; Ex. 1019 at Appx. 1010-C (pp.152-153); see also id. at ¶¶36-49;
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`Exs. 1045-1047 (three references cited in Appendix 1010-C).)1 The Board never
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`made such an assessment in its decision here.
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`Indeed, in its preliminary response, BNR did not present any evidence
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`disputing the publication dates of several citing references identified by Dr. Hsieh-
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`Yee. The Board overlooked this undisputed evidence, which contributes
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`significantly to the totality of the evidence. For instance, BNR never disputed the
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`publication date of the Sun and Olavarrieta references (Exhibits 1045-1046), so on
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`balance, the Board should have weighed that undisputed evidence in favor of
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`Samsung, at least at the pre-institution stage.
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`1 That the Petition described such publications as being “prior to April 21, 2005”
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`does not detract from Samsung’s argument because the Petition established the
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`impropriety of claiming priority to that date and demonstrated that the ’862 patent
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`cannot properly claim an invention date earlier than July 13, 2015. (Petition at 3-5.)
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`Dr. Hsieh-Yee’s testimony thus supports Petitioner’s argument that the citing
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`publications are prior to July 13, 2005. (Id.; see also id. at 6 (noting that Haykin was
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`“publicly accessible before the alleged invention of the ’862 patent”) (emphasis
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`added).) The Board did not appear to consider these facts, which would have
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`supported institution.
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`12
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`The existing record shows that Exhibit 1045 (an IEEE publication by Sun cited
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`in Dr. Hsieh-Yee’s declaration in Appendix 1010-C) bears the indicia “26-29
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`September 2004” (Ex. 1045 at 1-2) and a 2004 copyright date (id. at 3, 7-81). Dr.
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`Hsieh-Yee identified a September 2004 date for Sun. (Ex. 1019 at p.152; see also
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`id. at ¶49). Although that paper specifies “Kaykin” instead of “Haykin” and
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`“Prentice Hall” instead of the complete publisher name (“Pearson Prentice Hall”),
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`such typographical errors do not detract from the paper’s corroborative value. (Ex.
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`1045 at 81.) The Board’s concern that “[t]he citation may very well be to a different,
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`2004 version of Haykin” (Decision at 16) is itself speculative, and should not have
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`overcome the unrebutted sworn testimony of Samsung’s expert who testified
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`otherwise. Any concerns about this speculative issue should have been left for trial,
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`where cross-examination or other evidence could have addressed such questions,
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`particularly here where there is no record evidence or argument from BNR
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`suggesting that a different version of Haykin was published in 2004.
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`Similarly, the record shows that Exhibit 1046 (Olavarrieta paper cited in Dr.
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`Hsieh-Yee’s declaration in Appendix 1010-C) bears indicia of a conference in 2004
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`and cites Haykin (Ex. 1046 at 1 (“October 26-29, 2004”), 6), and Dr. Hsieh-Yee
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`identified an October 2004 date for that paper (Ex. 1019 at p.152; see also id. at ¶49).
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`Indeed, the fact that Olavarrieta bears indicia specifying “2004” (supported by Dr.
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`Hsieh-Yee’s testimony) and nevertheless specifies “2005” in its citation to Haykin
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`13
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`(Ex. 1046 at 546) actually shows the need for expert testimony (which was provided
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`by Samsung) to consider the totality of the evidence instead of merely relying on
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`isolated indicia, as discussed above in Section III.A.
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`The Board should have thus instituted IPR so that any disputes (to the extent
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`BNR raised them) regarding the content of the citing references could be evaluated
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`with the benefit of a fuller record (e.g., via supplemental information and/or cross-
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`examination).
`
`IV. CONCLUSION
`For all of the above reasons, Samsung respectfully requests that the denial of
`
`institution be vacated, and that the Board reconsider its Decision and institute inter
`
`partes review of claims 9-12 of the ’862 patent based on the underlying merits.
`
`Dated: September 23, 2020
`
`Respectfully submitted,
`
`By: /Naveen Modi/
`Naveen Modi (Reg. No. 46,224)
`Counsel for Petitioner Samsung
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`14
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`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), I certify that I caused to be served on the
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`counsel for Patent Owner a true and correct copy of the foregoing Petitioner’s
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`Request for Rehearing Under 37 C.F.R. § 42.71(d)(2) by electronic means on the
`
`date below at the following address of record:
`
`Steven W. Hartsell
`Alexander E. Gasser
`Joseph M. Ramirez
`Paul J. Skiermont
`Sadaf R. Abdullah
`Mieke K. Malmberg
`Steven J. Udick
`BNR_SDTeam@skiermontderby.com
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`Dated: September 23, 2020
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`
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`
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`Respectfully submitted,
`
` /Naveen Modi/
`Naveen Modi
`Reg. No. 46,224
`Counsel for Petitioner Samsung
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