Paper No. 6
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`APPLE INC.,
`Petitioner,
`
`v.
`
`COREPHOTONICS, LTD.,
`Patent Owner.
`____________
`
`Case No. IPR2020-00861
`U.S. Patent No. 10,230,898
`____________
`
`
`PATENT OWNER’S PRELIMINARY RESPONSE
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`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`COREPHOTONICS, LTD.,
`Patent Owner.
`____________
`
`Case No. IPR2020-00861
`U.S. Patent No. 10,230,898
`____________
`
`
`PATENT OWNER’S PRELIMINARY RESPONSE
`
`
`
`Case No. IPR2020-00861
`U.S. Patent No. 10,230,898
`
`TABLE OF CONTENTS
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`INTRODUCTION .................................................................. 1
`I.
`II. OVERVIEW OF THE ’898 PATENT ....................................... 2
`III. LEGAL STANDARDS ........................................................... 5
`IV. CLAIM CONSTRUCTION ..................................................... 7
`V.
` .............................................................................................. 9
`A.
`Fundamentally Different Digital Zoom System .............................. 9
`B.
`Discloses the Properly Construed “No-Switching Criteria” ......... 14
`VI. CONCLUSION .................................................................... 17
`
`THE PETITION FAILS TO ESTABLISH THE REASONABLE
`LIKELIHOOD OF A PRIMA FACIE CASE OF OBVIOUSNESS
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`The Petition Fails to Demonstrate a Motivation to Combine
`Techniques from Martin’s Autostereoscopic System into a
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`The Petition Fails to Demonstrate That the Disclosed Combination
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`
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`i
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`Case No. IPR2020-00861
`U.S. Patent No. 10,230,898
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`Cases
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`TABLE OF AUTHORITIES
`
`ActiveVideo Networks, Inc. v. Verizon Commc’ns, Inc.,
`694 F.3d 1312 (Fed. Cir. 2012) .................................................................. 6
`
`Apple Inc. v. Samsung Elecs. Co.,
`839 F.3d 1034 (Fed. Cir. 2016) ................................................................ 13
`
`Ariosa Diagnostics v. Verinata Health, Inc.,
`805 F.3d 1359 (Fed. Cir. 2015) .................................................................. 6
`
`In re Magnum Oil Tools Int’l, Ltd.,
`829 F.3d 1364 (Fed. Cir. 2016) .................................................................. 6
`
`InTouch Technologies, Inc. v. VGO Commc’ns, Inc.,
`751 F.3d 1327 (Fed.Cir.2014) .................................................................. 14
`
`Monarch Knitting Mach. Corp. v. Sulzer Morat GmbH,
`139 F.3d 877 (Fed. Cir. 1998) .................................................................. 13
`
`Personal Web Techs., LLC v. Apple, Inc.,
`848 F.3d 987 (Fed. Cir. 2017) .................................................................. 13
`
`Wasica Finance GMBH v. Continental Auto. Systems,
`853 F.3d 1272 (Fed. Cir. 2017) .................................................................. 6
`
`Other Authorities
`
`
`
`37 C.F.R. § 42.108 .......................................................................................... 5
`
`
`
`ii
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`Case No. IPR2020-00861
`U.S. Patent No. 10,230,898
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`I.
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`INTRODUCTION
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`The petition fails to demonstrate a reasonable likelihood of prevailing in
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`its challenge to any claim of the ’898 patent. As conceded by the petition, no
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`cited prior art reference discloses the claimed limitations. Instead, Petitioner
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`assembles increasingly speculative combinations of prior art in ways no per-
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`son of ordinary skill would do. The arguments in the Petition are rooted in
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`hindsight bias and a “jigsaw puzzle” approach to obviousness, which the
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`Board should reject.
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`In addition, the petition fails to show that Petitioner’s combination of
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`references disclose the “no-switching criteria” limitation of the ’898 patent.
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`The plain and ordinary meaning of “no-switching criteria” refers to “one more
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`criteria determined based on inputs obtained from the two camera images.”
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`The petition ignores this plain meaning and instead treats “no-switching cri-
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`terion” in an overbroad manner, applying the limitation to any threshold used
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`to switch. A POSITA based on the intrinsic evidence would not understand
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`this term as broadly as asserted by Petitioner.
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`Once properly understood, the prior art does not disclose any of the chal-
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`lenged claims. Petitioner relies on the Togo reference to purportedly disclose
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`1
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`this claim limitation. But the Togo reference discloses the use of predeter-
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`mined mechanical thresholds similar to the reference distinguished in the file
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`history. Even if the references can be combined as argued by Petitioner, Peti-
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`tioner has failed to show how they disclose the “no-switching criterion.”
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`The petition should be denied institution.
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`II. OVERVIEW OF THE ’898 PATENT
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`The ’898 patent is generally directed to “thin digital cameras with optical
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`zoom operating in both video and still mode.” Ex. 1001 at 3:18–22. It was
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`issued on March 12, 2019 and claims priority to a provisional patent applica-
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`tion filed on August 13, 2015. As the patent describes, in the prior art, optical
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`zooming required mechanically moving lens elements together, which were
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`“typically more expensive, larger and less reliable than fixed focal length
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`lenses.” Id. at 1:44–46. This is a particular problem for cameras that can go in
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`mobile devices, like smartphones. Another prior art alternative was digital
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`zoom, i.e., cropping the image and using computational methods to create the
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`appearance of zoom, but at the cost of resolution. Id. at 1:46–51.
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`The prior art discloses multi-aperture imaging systems attempting to sim-
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`ulate the effect of a zoom lens. Id. at 1:52–53. One such system created com-
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`posite images but the solution requires “very large processing resources in
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`addition to high frame rate requirements and high power consumption.” Id. at
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`2:6–33. Another solution used a combination of lens with particular FOV
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`characteristics to allow simulated zooming, but the solution “leads to parallax
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`artifacts when moving to the Tele camera in video mode.” Id. at 2:34–50.
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`Other prior art solutions failed to resolve registration error or were only ap-
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`plicable to “fused still images.” Id. at 2:51–3:10.
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`The patent owner, Corephotonics, developed an innovative dual-aperture
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`camera technology that uses two fixed-focal length lenses, a wide-angle lens
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`as typically found in smartphones with single-aperture cameras, and a minia-
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`ture telephoto lens with higher resolution in a narrower field of view. The pe-
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`titioner, Apple, adopted this technology in its iPhone models with dual rear
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`cameras, starting with the iPhone 7 Plus in September 2016 and continuing
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`with its successive generations of new iPhone models. The technology is also
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`now used in smartphones made by other manufacturers, such as Samsung and
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`Huawei.
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`Ex. 1001 at Fig. 1B.
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`
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`To make this technology a reality, Corephotonics developed solutions to
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`practical issues, some of which are the subject matter of the ’898 patent. For
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`example, Corephotonics developed technology that transitions between wide-
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`angle (“Wide”) images and telephoto (“Tele”) images while taking video. This
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`is done by using a “no-switching criterion” that is “determined by inputs from
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`both Wide and Tele image data.” Id. at 4:37–42 (emphasis added); see also id.
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`at 6:54–57, 10:2–5. The preferred embodiment in the specification includes
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`six exemplary methods for determining the “no-switching criterion”:
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`1. if the shift calculated by GR is greater than a first threshold,
`for example 50 pixels.
`2. if the disparity range calculated by GR is greater than a second
`threshold, for example 20 pixels, because in this case there is no
`global shift correction that will suppress movement/jump for all
`objects distances (smooth transition is impossible for all objects).
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`3. if the effective resolution score of the Tele image is lower than
`that of the Wide image. In this case, there is no point in perform-
`ing the transition because no value (i.e. resolution) is gained.
`Smooth transition is possible but undesirable.
`4. if the GR fails, i.e. if the number of matching pairs found is
`less than a third threshold, for example 20 matching pairs.
`5. if, for example, that are imaged onto the overlap area are cal-
`culated to be closer than a first threshold distance, for example
`30 cm, because this can result in a large image shift to obtain ST.
`6. if some objects (for example two objects) that are imaged in
`the overlap area are calculated to be closer than a second thresh-
`old distance, for example 50 cm, while other objects (for exam-
`ple two objects) are calculated to be farther than a third threshold
`distance for example 10 m. The reason is that the shift between
`an object position in the Wide and Tele cameras is object distance
`dependent, where the closer the objects the larger the shift, so an
`image containing significantly close and far objects cannot be
`matched by simple transformation (shift scale) to be similar and
`thus provide ST between cameras.
`Id. at 10:5–36.
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`III. LEGAL STANDARDS
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`The petitioner has the burden to “demonstrate that there is a reasonable
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`likelihood that at least one of the claims challenged in the petition is unpatent-
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`able.” 37 C.F.R. § 42.108. A petition challenging a claim on grounds of obvi-
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`ousness must sufficiently explain (1) “how specific references could be
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`combined,” (2) “which combination(s) of elements in specific references
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`would yield a predictable result,” and (3) “how any specific combination
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`would operate or read on” the claims. ActiveVideo Networks, Inc. v. Verizon
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`Commc’ns, Inc., 694 F.3d 1312, 1327–28 (Fed. Cir. 2012).
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`Moreover, a petitioner may not rely on the Board to substitute its own
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`reasoning to remedy the deficiencies in a petition. In re Magnum Oil Tools
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`Int’l, Ltd., 829 F.3d 1364, 1381 (Fed. Cir. 2016) (rejecting the Board’s reliance
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`on obviousness arguments that “could have been included” in the petition but
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`were not, and holding that the Board may not “raise, address, and decide un-
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`patentability theories never presented by the petitioner and not supported by
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`the record evidence”); Ariosa Diagnostics v. Verinata Health, Inc., 805 F.3d
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`1359, 1367 (Fed. Cir. 2015) (holding that “a challenge can fail even if different
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`evidence and arguments might have led to success”). Nor may the petitioner
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`remedy the deficiencies in a reply brief. Wasica Finance GMBH v. Continental
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`Auto. Systems, 853 F.3d 1272, 1286 (Fed. Cir. 2017) (“Rather than explaining
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`how its original petition was correct, Continental’s subsequent arguments
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`amount to an entirely new theory of prima facie obviousness absent from the
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`petition. Shifting arguments in this fashion is foreclosed by statute, our prec-
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`edent, and Board guidelines.”) (internal citations omitted).
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`IV. CLAIM CONSTRUCTION
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`The petition does not address claim construction, instead purporting to
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`analyze “the claims consistent with ordinary and customary meaning as would
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`be understood by a POSITA in light of the specification.” Paper 2 at 8. Peti-
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`tioner’s arguments, discussed in more detail below, illustrate that Petitioner
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`has adopted a claim construction of “no-switching criterion” inconsistent with
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`the specification. “No-switching criterion” should be construed as “one more
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`criteria determined based on inputs obtained from the two camera images.”
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`Patentee’s proposed construction is supported throughout the intrinsic
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`evidence. In the claims, the no-switching criterion may include “global regis-
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`tration,” which requires inputs from both the Wide and Tele lenses. E.g., Ex.
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`1001 at claims 2 (“wherein the no-switching criterion includes a shift between
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`the Wide and Tele images calculated by global registration”), 13 (same); see
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`also id. at 8:34–36 (“As used herein “global registration” refers to an action
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`for which the inputs are the Wide and Tele images.”). The no-switching crite-
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`rion may also include a comparison of the effective resolutions of the Wide
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`and Tele lenses (id. at claims 4, 15) or analysis of the images from the Wide
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`and Tele lenses (id. at claims 5–7, 16–18). Like the claims, the specification
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`consistently refers to the “no-switching criterion” as requiring inputs from
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`both the Wide and Tele lenses. Id. at 4:37–39 (“the camera controller config-
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`ured to evaluate a no-switching criterion determined by inputs from both Wide
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`and Tele image data”), 4:51–53 (same), 6:54–57 (“It is configurable to evalu-
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`ate a no-switching criterion determined by inputs from both Wide and Tele
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`image data and to make a decision regarding video output.”), 10:2–5
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`(“Switching from the Wide camera output to the transformed Tele camera out-
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`put will be performed unless some special condition (criterion), determined
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`based on inputs obtained from the two camera images, occurs.”), 10:5–36
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`(listing 6 exemplary criteria, all of which are determined based on inputs from
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`the Wide and Tele lenses).1
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`1 In the file history, original claims 1 and 12 (issued claims 1 and 11) expressly
`required that the no-switching criterion be “determined by inputs from both
`Wide and Tele image data.” Ex. 1002 at 292, 294. This language was removed
`from the claims to increase clarity. Id. at 296–97. The clarifying amendment
`does not change the plain and ordinary meaning of no-switching criterion,
`neither to broaden nor to narrow the meaning of no-switching criterion. This
`is further emphasized by the fact that the cited prior art, Shabtay, was success-
`fully distinguished because it did not teach the use of no-switching criteria at
`all: “Shabtay teaches that at any ZF higher that the up-transfer ZF a camera
`outputs a Tele image.” Id. at 297–98 (emphasis in original). The amendment
`to remove the language as to how no-switching criteria was generated was
`unrelated to patentee’s argument.
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`Accordingly, the Board should construe “no-switching criterion” as “one
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`more criteria determined based on inputs obtained from the two camera im-
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`ages.”
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`V. THE PETITION FAILS TO ESTABLISH THE
`REASONABLE LIKELIHOOD OF A PRIMA FACIE CASE
`OF OBVIOUSNESS
`
`A. The Petition Fails to Demonstrate a Motivation to Combine
`Techniques from Martin’s Autostereoscopic System into a Fun-
`damentally Different Digital Zoom System
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`Petitioner presents the same improper combination of references (Golan
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`in view of Martin) in related petition IPR2020-00860. Indeed, despite the ’898
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`patent claiming a different invention than the patent at issue in the -860 Peti-
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`tion (U.S. Patent No. 10,326,942), Petitioner has used the exact same argu-
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`ment to support its motivation to combine. Accordingly, Petitioner’s
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`motivation to combine Golan and Martin fail for the same reasons expressed
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`in the -860 petition.
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`Martin is directed to an autostereoscopic system that emphasizes parallax
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`effects to create the desired three-dimensional illusions, while the ’898 patent
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`is directed to an invention that seeks to reduce or remove parallax effects. The
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`claims of the ’898 patent are directed to a “zoom digital camera” with multiple
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`apertures (a “Wide imaging section” and a “Tele imaging section”). Ex. 1001
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`9
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`at claims 1, 11. Such a camera seeks to “approximate the effect” of a large and
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`expensive lens that uses mechanically moving elements to provide optical
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`zoom. Id. at 1:42–51. As explained in the ’898 patent, parallax effects are un-
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`desirable in this system and detract from its ability to “approximate” the per-
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`formance of a mechanical zoom system. Id. at 2:48–50, 7:50–53, 11:64–12:2.
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`Indeed, both the ’898 patent and Petitioner recognize that it is desirable
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`to “remove parallax artifacts” in a digital zoom camera, not to emphasize
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`them. Id. at 11:67; see also Paper 2 at 29 (The goal of “avoiding output image
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`degradation” is also the reason that Petitioner argues Golan and Martin would
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`be combined with Togo). As the ’898 specification explains, parallax makes
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`it more difficult to switch between different cameras. Id. at 7:50–53.
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`The goals of the autostereoscopic display system disclosed in Martin are
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`very different. The purpose of Martin is to “produc[e] two-dimensional im-
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`ages that, upon display, can be perceived to be three-dimensional.” Ex. 1006
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`at 1:18–19. Martin teaches achieving this by displaying two images that in-
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`tentionally differ due to parallax:
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`Particularly, retinal disparity results in parallax information (i.e.,
`an apparent change in the position, direction of motion, or other
`visual characteristics of an object caused by different observa-
`tional positions) being supplied to the brain. Because each eye
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`has a different observational position, each eye can provide a
`slightly different view of the same scene. The differences be-
`tween the views represents parallax information that the brain
`can use to perceive three dimensional aspects of a scene.
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`Ex. 1006 at 1:51–59 (emphasis added); see also Paper 2 at 16-17 (describing
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`Martin as using “parallax images” to create the perception of a moving three-
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`dimensional image).
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`In other words, while parallax artifacts are undesirable effects that stand
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`in the way of the goal of approximating a mechanical zoom lens, in Martin
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`the parallax artifacts are vital. Rather than seeking to minimize parallax effects
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`as the ’898 patent describes in the specification, Martin intentionally empha-
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`sizes the parallax effects to create an autostereoscopic display.2 If the parallax
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`effects were diminished, as discussed by the ’898 patent, the autostereoscopic
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`display that is the goal of Martin could not be achieved.
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`The ’898 patent teaches that, in the context of the invention, parallax
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`causes a “‘jump’ (discontinuous) image change” when “a dual-aperture cam-
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`era switches the camera output between cameras or points of view.” Ex. 1001
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`2 “Autostereoscopic techniques . . . product images with a three dimensional
`illusion without the use of special glasses.” Ex. 1006 at 2:14–17. In other
`words, as Martin describes the art, the goal is to produce “three-dimensional
`illusions.” Id. at 1:26.
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`11
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`at 7:42-53. While these image discontinuities are disfavored in the ’898 pa-
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`tent, they are vital to the teachings of Martin. Ex. 1006 at 1:51–59 (“The dif-
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`ferences between the views represents parallax information that the brain can
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`use to perceive three dimensional aspects of a scene.”). The petition does not
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`mention this critical discrepancy at all. And Petitioner’s failure to explain this
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`discrepancy is further emphasized by its argument that “avoiding output im-
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`age degradation” would be a reason to combine Golan and Martin with Togo.
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`Paper 2 at 29. Petitioner does not explain why avoiding image degradation
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`would be a reason for combining Golan and Martin with Togo but the fact that
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`Martin emphasizes discontinuities due to parallax effects would be ignored
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`when combining Golan and Martin. Without the benefit a hindsight, a POSITA
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`would not choose to combine Golan with Martin.
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`Moreover, the alleged motivations to combine Golan with Martin that the
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`Petition does set forth fail to meet the legal standard for obviousness. The
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`Petition argues that Golan and Martin are “analogous prior art and are in the
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`same field of endeavor” and that both have a need for “alignments having sub-
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`pixel accuracy.” Paper 2 at 19. Even if these arguments are accepted as true,
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`they do not establish the necessary motivation to combine the two references.
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`Apple Inc. v. Samsung Elecs. Co., 839 F.3d 1034, 1051 (Fed. Cir. 2016) (find-
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`ing that “concluding that the references are within the scope and content of
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`the prior art to be considered for obviousness (i.e. analogous art) does not end
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`the inquiry” – motivation to combine must still be shown); Personal Web
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`Techs., LLC v. Apple, Inc., 848 F.3d 987, 993–94 (Fed. Cir. 2017) (“that rea-
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`soning seems to say no more than that a skilled artisan, once presented with
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`the two references, would have understood that they could be combined. And
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`that is not enough: it does not imply a motivation to pick out those two refer-
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`ences and combine them to arrive at the claimed invention.”).
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`The petition further argues that a POSITA would have incorporated Mar-
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`tin’s teaching of “critical alignment” into Golan “to achieve a stable transition
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`in the continuous zoom video output images.” Paper 2 at 19–20. But, the Fed-
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`eral Circuit has taught that “[d]efining the problem in terms of its solution
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`reveals improper hindsight in the selection of the prior art relevant to obvi-
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`ousness.” Monarch Knitting Mach. Corp. v. Sulzer Morat GmbH, 139 F.3d
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`877, 881 (Fed. Cir. 1998).
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`Petitioner’s combination of Martin with Golan ignores the differences in
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`how and why they combine images that would have prevented a POSITA from
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`being motivated to combine them. Instead, the petition relies on impermissible
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`hindsight, using the claims of the ’898 patent as a roadmap to combine the
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`references. Martin’s “critical alignment” is treated as a jigsaw puzzle piece to
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`fill in the missing claim element. See InTouch Technologies, Inc. v. VGO
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`Commc’ns, Inc., 751 F.3d 1327, 1351 (Fed. Cir. 2014) (warning against a “jig-
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`saw puzzle” approach to obviousness). This improper approach to obvious-
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`ness should be rejected and the petition denied institution.
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`B.
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`The Petition Fails to Demonstrate That the Disclosed Combi-
`nation Discloses the Properly Construed “No-Switching Crite-
`ria”
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`Even if Golan and Martin are properly combined, Petitioners fails to
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`show that the combination of Golan, Martin and Togo disclose the no-switch-
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`ing criterion required in all of the challenged claims. As discussed above, the
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`plain and ordinary meaning of no-switching criterion to a POSITA in light of
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`the specification is “one more criteria determined based on inputs obtained
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`from the two camera images.” Petitioner fails to show that its purported “no-
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`switching criteria” is based on two camera images. Instead, Petitioner argues
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`that any threshold analysis, regardless of what it is, can be a no-switching
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`criteria. This is inconsistent with the plain and ordinary meaning of the claim
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`term, as described above.
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`In Togo, as Petitioner itself describes the reference, the decision as to
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`whether to switch lenses is based either on a predetermined magnification
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`threshold (called “A”) and/or a predetermined distance threshold (called “B”).
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`Paper 2 at 26 (citing Ex. 1010 at FIG. 7, [0049], [0061]–[0062], [0066]–
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`[0067]). Petitioner fails to show how this teaching discloses a no-switching
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`criterion like the one claimed in the ’898 patent.
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`Indeed, Togo does not disclose a no-switching criterion as understood
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`by a POSITA because it does not use inputs from the Wide and Tele camera
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`images at all. Instead, Togo’s first threshold is based on the magnification set-
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`ting for the device itself, which is a mechanical setting unrelated to the camera
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`images. Togo’s disclosure is actually very similar to the disclosure of the
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`Shabtay reference, which the Patentee successfully distinguished because it
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`taught that switching occurred with any “ZF higher than the up-transfer ZF”
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`predetermined in Shabtay. Ex. 1002 at 297-98. Togo’s second threshold, dis-
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`tance, is based on a mechanical characteristic of the Togo device as opposed
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`to inputs from the images. Togo teaches that distance is approximated using
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`“an output signal of the autofocusing means or a control signal controlling the
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`autofocusing means” that is attached to Togo’s wide-angle lens. Ex. 1010 at
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`[0019]; see also id. at [0032] (distance is estimated from “an actuator control
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`voltage of the autofocus adjustment means 9”), [0023] (autofocus adjustment
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`means 9 is attached to the wide-angle lens system). This threshold is not re-
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`lated to the camera images. And, even if this distance calculation were related
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`to an image, it would only be related to one of the images (the wide-angle
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`image), not both images as required for a no-switching criterion in the ’898
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`patent.
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`Petitioner’s argument regarding claim 4 further emphasizes Petitioner’s
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`inappropriate approach.3 Claim 4 requires the no-switching criterion to in-
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`clude an analysis of the effective resolution of both the Tele and Wide images.
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`Paper 2 at 55. Petitioner does not identify any disclosure in Togo where the
`
`effective resolution of each image is used to determine a no-switching crite-
`
`rion. This is hardly surprising given that, as described above, the thresholds
`
`identified by Petitioner in Togo are predetermined based on mechanical char-
`
`acteristics and have little to do with either of the actual images captured by
`
`the Togo device. Instead, Petitioner identifies Togo’s general statements about
`
`image quality at various focal lengths. Paper 2 at 55-57. Togo does not, how-
`
`ever, determine image quality of actual images, as required by claim 4. This
`
`
`3 Challenged claim 15 is similar to claim 4.
`
`16
`
`
`
`Case No. IPR2020-00861
`U.S. Patent No. 10,230,898
`
`further shows that Petitioner has failed to show that Togo discloses the no-
`
`switching criterion limitation in the challenged claims.
`
`
`
`For this reason, all of Petitioner’s challenges fail, even if Golan and
`
`Martin can be combined.
`
`VI. CONCLUSION
`
`For the reasons set forth above, the petition fails to establish a reasonable
`
`likelihood of prevailing on any challenged claim. Patent Owner respectfully
`
`requests that the Board deny institution.
`
`
`
`Dated: September 11, 2020
`
`
`
` /Neil A. Rubin/
`Neil A. Rubin (Reg. No. 67,030)
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, CA 90025
`Telephone: 310-826-7474
`
`Attorney for Patent Owner,
`COREPHOTONICS, LTD.
`
`17
`
`
`
`Case No. IPR2020-00861
`U.S. Patent No. 10,230,898
`
`CERTIFICATE REGARDING WORD COUNT
`
`Pursuant to 37 C.F.R. § 42.24(d), Patent Owner certifies that there are 3,444
`
`words in the paper excluding the portions exempted under 37 C.F.R. §
`
`42.24(a)(1).
`
`
`
`
` /Neil A. Rubin/
`Neil A. Rubin (Reg. No. 67,030)
`
`
`18
`
`
`
`Case No. IPR2020-00861
`U.S. Patent No. 10,230,898
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that “Patent Owner’s Preliminary Response” (Paper No. 6)
`
`was served on September 11, 2020 by email sent to:
`
`David W. O’Brien
`Hong Shi
`HAYNES AND BOONE, LLP
`600 Congress Ave. Suite 1300
`Austin, TX 78701
`Telephone: 512-867-8400
`Email: david.obrien.ipr@haynesboone.com
`Email: hong.shi.ipr@haynesboone.com
`
`Andrew S. Ehmke
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`Telephone: 214-651-5000
`Email: andy.ehmke.ipr@haynesboone.com
`
`
` /Neil A. Rubin/
`Neil A. Rubin (Reg. No. 67,030)
`
`
`19
`
`
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