UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________________________
`
`
`Intel Corporation
`Petitioner,
`v.
`ParkerVision, Inc.
`Patent Owner
`
`____________________________________________
`
`Case No. IPR2020-01265
`Patent No. 7,110,444
`____________________________________________
`
`
`PETITIONER’S ORAL HEARING DEMONSTRATIVES
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________________________
`
`
`Intel Corporation
`Petitioner,
`v.
`ParkerVision, Inc.
`Patent Owner
`
`____________________________________________
`
`Case No. IPR2020-01265
`Patent No. 7,110,444
`____________________________________________
`
`
`PETITIONER’S ORAL HEARING DEMONSTRATIVES
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`United States Patent and Trademark Office
`Before the Patent Trial and Appeal Board
`
`Intel Corporation, Petitioner,
`v.
`ParkerVision, Inc., Patent Owner.
`
`IPR2020-01265
`Petition for Inter Partes Review of U.S. Patent No. 7,110,444
`November 1, 2021
`
`DEMONSTRATIVE EXHIBIT– NOT EVIDENCE
`
`1
`
`
`
`The ’444 Patent
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`2
`
`Ex. 1001 (’444 Patent).
`
`
`
`Technology Background: Up-Conversion
`
` Wireless devices communicate with each other by
`transmitting and receiving electromagnetic (EM)
`signals.
`
` Before transmission, information exists as a low
`frequency “baseband signal,” which is shifted to a
`higher frequency “radio frequency” or “RF” signal.
`
` Shifting a signal from a lower frequency to a higher
`frequency is called “up-conversion.”
`
`Paper 3 (Petition) at 10-16.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`3
`
`
`
`Technology Background: Down-Conversion
`
` Received RF signals are shifted back down to a lower
`frequency to process the received information.
`
` Shifting a signal from a higher frequency to a lower
`frequency is called “down-conversion.”
`
`Lower Frequency EM Signal
`
`Time
`
`Amplitude
`
`Down-conversion
`
`Time
`
`Higher Frequency EM Signal
`
`Amplitude
`
`Paper 3 (Petition) at 15-16.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`4
`
`
`
`’444 Patent: Alleged Invention
`
`Modulating a high frequency carrier signal
`with a low frequency signal to produce a
`high frequency modulated signal is called
`“up-conversion.”
`
`Paper 3 (Petition) at 20-21.
`
`Ex. 1001 (’444 Patent) at Fig. 70A.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`5
`
`“Universal
`frequency
`translation”
`(UFT) module
`
`
`
`’444 Patent: Alleged Invention
`
`Modulating a high frequency carrier signal
`with a low frequency signal to produce a
`high frequency modulated signal is called
`“up-conversion.”
`
`Modulating a high frequency carrier signal
`with a low frequency signal to produce a
`high frequency modulated signal is called
`“up-conversion.”
`
`Ex. 1001 (’444 Patent) at Fig. 20A.
`
`Modulating a high frequency carrier signal
`with a low frequency signal to produce a
`high frequency modulated signal is called
`“up-conversion.”
`
`Paper 3 (Petition) at 20, 22; Ex. 1001 (’444 Patent) at Fig. 70A.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1001 (’444 Patent) at Fig. 20A-1.
`
`6
`
`
`
`The ’444 Patent: Patent Owner Concedes Claims 1
`and 5 are Unpatentable
`
`Paper 18 (POR) at 1, fn. 1.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`7
`
`
`
`The ’444 Patent: Claim 3
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`8
`
`Ex. 1001 (’444 Patent) at 61:1-18.
`
`
`
`The ’444 Patent: Grounds for Petition
`
` Ground 1: Claim 3 is Obvious Over Tayloe in
`View of TI Datasheet
`
` Ground 2: Claim 3 is Obvious Over Tayloe in
`View of Kawada
`
`Paper 3 (Petition) at 47.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`9
`
`
`
`Prior Art: Tayloe (Ex. 1004)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1004 (Tayloe).
`
`10
`
`
`
`Prior Art: Tayloe (Ex. 1004)
`
`Ex. 1004 (Tayloe) at Abstract.
`.
`
`Paper 3 (Petition) at 31-38.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1004 (Tayloe) at 1:10-:15.
`.
`11
`
`
`
`Prior Art: Tayloe (Ex. 1004)
`
`Paper 3 (Petition) at 32.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`12
`
`Ex. 1004 (Tayloe) at Fig. 3.
`
`
`
`’444 Patent: Patent Owner Mischaracterizes Its
`Claimed Invention
`
`Paper 18 (POR) at 1.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`13
`
`Paper 18 (POR) at 1.
`
`
`
`’444 Patent: Patent Owner Mischaracterizes Its
`Claimed Invention
`
`Paper 18 (POR) at 32.
`
`Paper 18 (POR) at 32.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`14
`
`
`
`’444 Patent: Patent Owner Mischaracterizes Its
`Claimed Invention
`
`Paper 21 (Reply) at 4-9.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`15
`
`Ex. 2007 (’551 Patent) at 2:51-65.
`
`
`
`’444 Patent: Patent Owner Mischaracterizes Its
`Claimed Invention
`
`Modulating a high frequency carrier signal with a low frequency
`signal to produce a high frequency modulated signal is called “up-
`conversion.”
`
`Paper 21 (Reply) at 7.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`16
`
`Ex. 2007 (’551 Patent) at 9:1-21.
`
`
`
`’444 Patent: Patent Owner Mischaracterizes Its
`Claimed Invention
`
`Modulating a high frequency
`carrier signal with a low
`frequency signal to produce a high
`frequency modulated signal is
`called “up-conversion.”
`
`Paper 21 (Reply) at 8.
`
`Ex. 2007 (’551 Patent) at Fig. 45A.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`17
`
`
`
`’444 Patent: Patent Owner Mischaracterizes Its
`Claimed Invention
`
`Ex. 1031, IPR2014-00948 (POR) at 17.
`
`Paper 21 (Reply) at 8.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`18
`
`
`
`’444 Patent: Patent Owner Mischaracterizes Its
`Claimed Invention
`
`Ex. 2007 (’551 Patent) at Fig. 83E.
`
`Paper 21 (Reply) at 9.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`19
`
`
`
`ParkerVision Does Not Dispute Disclosure of the
`Following Elements of Claim 3 in Tayloe
`
`Claim 3 of the ’444 Patent:
`
`Undisputed Elements:
`
`
`
`Ex. 1001 (’444 Patent) at Cl. 3; Paper 21 (Reply) at 1.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`20
`
`
`
`Claim Construction: “Storage Element”
`
`Claim
`Term
`
`Petitioner’s
`Proposed Construction
`
`Patent Owner’s
`Proposed Construction
`
`“storage
`element”
`
`“an element that stores a
`nonnegligible amount of
`energy from an input
`electromagnetic (EM) signal”
`
`“an element of an energy transfer
`system that stores non-negligible
`amounts of energy from an input
`electromagnetic signal”
`
`Paper 21 (Reply at 10) at 3; Paper 16 (POR) at 45, 49.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`21
`
`
`
`Claim Construction: “Storage Element”
`
` The patent defines storage element/module.
`
`Ex. 2007 (’551 Patent) at 66:65-67.
`
`Ex. 2007 (’551 Patent) at 100:4-6.
`
`Paper 23 (Petitioner’s Reply) at 4.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`22
`
`
`
`Claim Construction: “Storage Element”
`
`“When a patentee explicitly defines a claim term in
`the patent specification, the patentee’s definition
`controls.” Martek Biosciences Corp. v. Nutrinova, Inc.,
`579 F.3d 1363, 1380 (Fed. Cir. 2009).
`
`Paper 21 (Reply) at 11.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`23
`
`
`
`Claim Construction: “Storage Element”
`
` Nothing in the specification limits storage
`element/module to an energy transfer system.
`
`Paper 21 (Reply) at 10-13.
`
`Ex. 2007 (’551 Patent) at 66:55-67.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`24
`
`
`
`Patent Owner Previously Argued In
`Support Of Petitioner’s Construction
`
`Ex. 1032-IPR2014-00948 (POPR) at 37.
`
`Paper 21 (Reply) at 11-12.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`25
`
`Ex. 1032-IPR2014-00948 (POPR) at 21-22.
`
`
`
`The Board Relied On Patent Owner’s Argument
`
`Ex. 1033-IPR2014-00948 (Institution Decision) at 10.
`
`Paper 21 (Reply) at 11-12.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`26
`
`
`
`Patent Owner Previously Argued The Specification
`Explicitly Defines Storage Module/Element
`
`Ex. 1032-IPR2014-00948 (POPR) at 21-22.
`
`Ex. 1033-IPR2014-00948 (Institution Decision) at 10.
`
`Paper 21 (Reply) at 11.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`27
`
`
`
`Claim Construction: Patent Owner’s BRI
`Argument
`
`Paper 26 (Sur-Reply) at 12-13.
`
`Paper 26 (Sur-Reply) at 12-13.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`28
`
`
`
`Patent Owner Previously Argued The Specification
`Explicitly Defines Storage Module/Element
`
`“When a patentee explicitly defines a claim term in the patent
`specification, the patentee’s definition controls.” Martek Biosciences
`Corp. v. Nutrinova, Inc., 579 F.3d 1363, 1380 (Fed. Cir. 2009).
`
`“When a patentee explicitly defines a claim term in the patent
`specification, the patentee’s definition controls.” Mexichem
`Amanco Holding S.A. de C.V. v. Honeywell Int’l Inc., 702 F. App’x
`993, 994 (Fed. Cir. 2017) (quoting Martek, 579 F.3d at 1380)
`(affirming construction “consistent with the definition ... in the
`patents’ specifications”).
`
`Paper 21 (Reply) at 11.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`29
`
`
`
`The District Court Never “Revisited” Its Construction
`
`Patent Owner’s Representation:
`
`Paper 26 (Sur-Reply) at 10.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`30
`
`Paper 26 (Sur-Reply) at 10.
`
`
`
`Claim Construction: District Court Claim
`Construction Positions
`
`Claim Term Petitioner’s
`Proposed
`Construction
`
`Patent Owner’s
`Proposed
`Construction
`
`District Court’s
`Construction
`
`“storage
`element” (’444
`patent)/ “storage
`module” (’706
`patent)
`
`“an element that stores a
`non-negligible amount of
`energy from an input
`electromagnetic (EM)
`signal”
`
`“An element of an energy
`transfer system that stores
`non-negligible amounts of
`energy from an input
`electromagnetic signal for
`driving a low impedance
`load”
`
`“an element of an energy
`transfer system that stores
`non-negligible amounts of
`energy from an input
`electromagnetic signal” (No.
`6:20-CV-108-ADA)
`
`“a module of an energy
`transfer system that stores
`non-negligible amounts of
`energy from an input
`electromagnetic signal for
`driving a low impedance
`load” (No. 6:20-CV-562-
`ADA)
`Paper 7 (Notice on Claim Construction) at 2; Paper 12 (Notice on Claim Construction) at 1;
`Ex. 1038 (Claim Construction Order) at 2.
`
`Paper 21 (Reply) at 15.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`31
`
`
`
`Tayloe: Discloses an “Energy Transfer System”
`
` The common feature of the patent’s “energy
`transfer” embodiments is the use of a control signal
`with non-negligible apertures.
`
`Paper 18 (POR) at 33.
`
`Paper 18 (POR) at 33.
`
`Ex. 2007 (’551 Patent) at 66:33-54.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`32
`
`
`
`Tayloe: Discloses an “Energy Transfer System”
`
` It is undisputed that Tayloe uses a control signal with
`non-negligible apertures.
`
`Ex.1029 (Steer Dep.) at 105:6-9.
`
`Paper 18 (POR) at 33.
`
`Ex. 1029 (Steer Dep.) at 105:22-106:3.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`33
`
`
`
`Tayloe: Patent Owner’s Response
`
` In the POR, Patent Owner argues that Tayloe does
`not disclose a “storage element” that drives a low
`impedance load.
`
`Paper 18 (POR) at 60-70, 74-75.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`34
`
`Paper 18 (POR) at 74.
`
`
`
`’444 Patent: Low Impedance Load Not Required
`
`Ex. 2007 (’551 Patent) at 67:37-47.
`
`Paper 21 (Reply) at 22.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`35
`
`
`
`’444 Patent: Low Impedance Load Not Required
`
`Ex. 2007 (’551 Patent) at Cl. 1.
`
`Paper 21 (Reply) at 23.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`36
`
`
`
`’444 Patent: Low Impedance Load Not Required
`
`Ex. 2007 (’551 Patent) at Cl. 64.
`
`Paper 21 (Reply) at 23.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`37
`
`Ex. 2007 (’551 Patent) at Cl. 66.
`
`
`
`’444 Patent: Low Impedance Load Not Required
`
`Ex. 2007 (’551 Patent) at Cl. 68.
`
`Paper 21 (Reply) at 23-24.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`38
`
`
`
`’444 Patent: Low Impedance Load Not Required
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`Paper 21 (Reply) at 23.
`
`Ex. 2007 (’551 Patent) at Cl. 74.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`39
`
`
`
`’444 Patent: Patent Owner Mischaracterizes Claim
`68
`
`Paper 26 (Sur-Reply) at 26, fn. 21.
`
`Paper 26 (Sur-Reply) at 26.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`40
`
`
`
`’444 Patent: Low Impedance Load Not Required
`
`Ex. 1029 (Steer Tr.) at 80:14-16.
`
`Paper 21 (Reply) at 24.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`41
`
`
`
`’444 Patent: Low Impedance Load Not Required
`
`Paper 21 (Reply) at 24.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`42
`
`Ex. 1029 (Steer Tr.) at 86:12-21.
`
`
`
`Tayloe: Low Impedance Load Disclosed
`
`Ex. 1004 (Tayloe) at Fig. 3 (excerpt).
`
`Paper 21 (Reply) at 26-27.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`43
`
`
`
`Tayloe: Low Impedance Load Disclosed
`
`Ex. 1030 (Subramanian Decl.) at ¶ 17.
`
`Paper 21 (Reply) at 27.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`44
`
`
`
`Tayloe: Low Impedance Load Disclosed
`
`Paper 21 (Reply) at 27.
`
`Ex. 1030 (Subramanian Decl.) at ¶ 18.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`45
`
`
`
`Tayloe: Low Impedance Load Disclosed
`
`Ex. 1030 (Subramanian Decl.) at ¶ 18.
`
`Paper 21 (Reply) at 27.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`46
`
`
`
`Tayloe: Low Impedance Load Disclosed
`
`Paper 21 (Reply) at 26-27.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`47
`
`Ex. 1004 (Tayloe) at Fig. 3 (excerpt);
`Ex. 1030 (Subramanian Decl.) at ¶ 16.
`
`
`
`Tayloe: Low Impedance Load Disclosed
`
`Ex. 1030 (Subramanian Decl.) at ¶ 20.
`
`Paper 21 (Reply) at 26-27.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`48
`
`
`
`Tayloe: Low Impedance Load Disclosed
`
`Paper 21 (Reply) at 25-27.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`49
`
`Ex. 1030 (Subramanian Decl.) at ¶ 21.
`
`
`
`Tayloe: Low Impedance Load Disclosed
`
`Ex. 1030 (Subramanian Decl.) at ¶ 21.
`
`Paper 21 (Reply) at 26-27.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`50
`
`
`
`Tayloe: Patent Owner’s Arguments on Tayloe’s Load
`Impedance
`
` Patent Owner argues “Dr. Subramanian admits that Tayloe’s
`summing amplifiers use operational amplifiers (op-amps)” and
`that “[o]perational amplifiers are high impedance loads.”
`
`Paper 26 (Sur-Reply) at 3-4.
`
`Paper 26 (Sur-Reply) at 3-4.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`51
`
`Ex. 1004 (Tayloe) at Fig. 3 (excerpt);
`Paper 21 (Reply) at 26.
`
`
`
`Tayloe: Patent Owner’s Arguments on Tayloe’s Load
`Impedance
`
` Patent Owner argues “Dr. Subramanian admits that Tayloe’s
`summing amplifiers use operational amplifiers (op-amps)” and
`that “[o]perational amplifiers are high impedance loads.”
`
` But Dr. Subramanian testified as follows:
`Q.
`[I]sn’t it true that an OP amp would ideally have
`an infinite input impedance to resist the flow of
`input current into the device?
`
`Paper 26 (Sur-Reply) at 3-4.
`
`A.
`
`Dr. Vivek Subramanian
`
`Paper 26 (Sur-Reply) at 3-4.
`
`So the answer is actually, for the constraints
`you’ve imposed on it, no … [R]eal OP amps—in
`fact, the most—the OP amp which has sold more
`parts than any other OP amp in the history of
`mankind does not have an infinite input
`impedance. In fact, it has a relatively low input
`impedance.”
`
`Ex. 2028 (Subramanian Tr.) at 96:24-97:11.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`52
`
`
`
`Tayloe: Patent Owner’s Arguments on Tayloe’s Load
`Impedance
`
` Patent Owner argues “Dr. Subramanian admits that Tayloe’s
`summing amplifiers use operational amplifiers (op-amps)” and
`that “[o]perational amplifiers are high impedance loads.”
`
`Paper 26 (Sur-Reply) at 3-4.
`
` But Dr. Subramanian testified as follows:
`
`Q.
`
`A.
`
`And again, you – do OP amps generally have a
`high input impedance?
`
`It depends … there is a range of input
`impedances that they have … if you look at
`[Figure 3] just based on the presence of the
`resistors, it’s clear that there must be bias
`currents flowing into the systems, otherwise you
`wouldn’t use these [OP amps] …
`Ex. 2028 (Subramanian Tr.) at 154:4-16.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`53
`
`Dr. Vivek Subramanian
`
`Paper 26 (Sur-Reply) at 3-4.
`
`
`
`Tayloe: Patent Owner’s Arguments on Tayloe’s Load
`Impedance
` Patent Owner argues Dr. Subramanian “admitted that the
`resistor before the Tayloe op-amp … [is] a compensation
`resistor” … “eliminat[ing] his only basis as to why he viewed the
`op-amp as presenting a low impedance load.”
`
`Paper 26 (Sur-Reply) at 5-6.
`
` But Dr. Subramanian testified as follows:
`
`Q.
`
`A.
`
`And what about the resistor at the positive
`terminal? … is that a compensation resistor?
`
`If by compensation resistor it’s used to account
`for the fact that there is some biased current
`going in and it is used to deal with that, then the
`answer is yes, that’s true. Then that attests to the
`fact that the bias current is nonnegligible. If it
`were negligible, you wouldn’t have to do that.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`54
`
`Ex. 2028 (Subramanian Tr.) at 183:24-185:12.
`
`Dr. Vivek Subramanian
`
`Paper 26 (Sur-Reply) at 4.
`
`
`
`Tayloe: Patent Owner’s Arguments on Tayloe’s Load
`Impedance
`
`Paper 26 (Sur-Reply) at 27.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`55
`
`
`
`Tayloe: Patent Owner’s New “Non-Negligible
`Amounts of Energy” Argument
` Patent Owner incorrectly asserts
`that Tayloe’s capacitors do not
`store non-negligible amounts of
`energy.
`
`Paper 26 (Sur-Reply) at 1.
`
`Paper 26 (Sur-Reply) at 1.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`56
`
`
`
`Tayloe: Patent Owner’s New “Non-Negligible
`Amounts of Energy” Argument
`
` Step 1: “calculate the amount of energy that was
`available from the input EM signal during a sampling
`aperture”
`
`Paper 26 (Sur-Reply) at 17-21; Exhibit 2022.
`
` Step 2: calculate “the amount of energy transferred
`to the [storage] element [i.e.Tayloe’s capacitor]
`during that sampling aperture”
`
`Paper 26 (Sur-Reply) at 17-18, 21-22; Exhibit 2022.
`
` Step 3: “calculate the percentage of available energy
`that is held on Tayloe’s capacitor”
`
`Paper 26 (Sur-Reply) at 17-18, 22-23; Exhibit 2022.
`
`Paper 26 (Sur-Reply) at 14-25; Paper 34 (Pet.’s Mot. to Exclude) at 5.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`57
`
`
`
`Tayloe: Patent Owner’s New “Non-Negligible
`Amounts of Energy” Argument
`
`Paper 34 (Pet.’s Mot. to Exclude) at 8; Response to Paper 26 (Sur-Reply) at 16.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`58
`
`Paper 26 (Sur-Reply) at 16.
`
`
`
`Tayloe: Patent Owner’s New “Non-Negligible
`Amounts of Energy” Argument
`
`Paper 18 (POR) at 73.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`59
`
`Paper 18 (POR) at 73.
`
`
`
`Tayloe: Patent Owner’s Response
`
`Paper 18 (POR) at 74.
`
`Paper 34 (Pet.’s Mot. to Exclude) at 8; Paper 18 (POR) at 74.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`60
`
`
`
`Tayloe: Patent Owner Expert Deposition
`
`Dr. Michael Steer
`
`Paper 37 (Pet.’s Reply in Support of Mot. to Exclude) at 3; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1029 (Steer Tr.) at 119:9-19.
`
`61
`
`
`
`Tayloe: Patent Owner’s New Calculations Are
`Untimely
`
`“Though Patent Owner highlighted the claim language ‘within the
`survey area’ as part of its argument that this language required an
`actual, physical survey, Patent Owner did not argue in the Response
`that the synthetic source points of Zwartjes were not located within
`the corresponding survey area. Accordingly, Patent Owner waived this
`argument, and may not raise it in the Sur-Reply.”
`
`In-Depth Geophysical, Inc. v. Conocophillips Co., No. IPR2019-00850, 2020 WL
`5261306, at *9 (P.T.A.B. Sept. 3, 2020).
`
`Paper 37 (Pet.’s Reply in Support of Mot. to Exclude) at 4; Response to Paper 26 (Sur-Reply) at 15-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`62
`
`
`
`Tayloe: Patent Owner’s New Calculations Are
`Unfairly Prejudicial
`
`“The reason for limiting the scope of a reply (and surreply) is to
`promote procedural fairness…. Parties are charged with bringing their
`best arguments forward in a manner that provides the opposing party
`an opportunity to fairly test those arguments. Belatedly raising
`arguments for the first time in the final brief … does not permit
`occasion to challenge those arguments in the absence of an endless
`parade of additional briefing.”
`
`3M Co. v. Westech Aerosol Co., No. IPR2018-00576, 2019 WL 1878045 at *3
`(P.T.A.B. Apr. 26, 2019).
`
`Paper 34 (Pet.’s Mot. to Exclude) at 11; Response to Paper 26 (Sur-Reply) at 15-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`63
`
`
`
`Tayloe: Patent Owner’s New Calculations Are
`Unfairly Prejudicial
`
`Paper 26 (Sur-Reply) at 16.
`
`Paper 21 (Reply) at 19-20.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`64
`
`
`
`Tayloe: Dr. Subramanian’s Calculations
`
`Paper 21 (Reply) at 19-20.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`65
`
`Exhibit 1030 (Subramanian Decl.) at ¶ 12.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`66
`
`Exhibit 2022 at 1.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`67
`
`Exhibit 2022 at 2.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`68
`
`Exhibit 2022 at 3.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`69
`
`Exhibit 2022 at 4.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`70
`
`Exhibit 2022 at 5.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`71
`
`Exhibit 2022 at 6.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`72
`
`Exhibit 2022 at 7.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`73
`
`Exhibit 2022 at 8.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`74
`
`Exhibit 2022 at 9.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`75
`
`Exhibit 2022 at 10.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`76
`
`Exhibit 2022 at 11.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`77
`
`Exhibit 2022 at 12.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`78
`
`Exhibit 2022 at 13.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`79
`
`Exhibit 2022 at 14.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`80
`
`Exhibit 2022 at 15.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`81
`
`Exhibit 2022 at 16.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`82
`
`Exhibit 2022 at 17.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`83
`
`Exhibit 2022 at 18.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`84
`
`Exhibit 2022 at 19.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`85
`
`Exhibit 2022 at 20.
`
`
`
`Tayloe: Patent Owner’s Exhibit 2022
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`86
`
`Exhibit 2022 at 21.
`
`
`
`Tayloe: Assumptions in Exhibit 2022
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`The power P is held constant when calculating the energy delivered
`to a resistor R.
`
`Ex. 2028 (Subramanian Tr.) at 31:23-33:15.
`The voltage applied to the load resistor RL is a perfect sinusoid when
`calculating available power that can be transferred to RL.
`Ex. 2028 (Subramanian Tr.) at 75:12-76:9; 45:24-46:23.
`The time scale for TON encompasses a very large number of cycles of
`the sinusoid when calculating the available energy during TON.
`Ex. 2028 (Subramanian Tr.) at 47:2-49:7.
`The power source is a DC source when calculating the available
`energy during a time TX.
`
`Ex. 2028 (Subramanian Tr.) at 66:1-8; 70:5-71:13.
`The capacitor has no leakage/internal discharge path when calculating
`the energy that has been transferred to the capacitor.
`Ex. 2028 (Subramanian Tr.) at 72:11-73:25.
`The assumptions underlying the “maximum power transfer theorem”
`are met in calculating the available power.
`Ex. 2028 (Subramanian Tr.) at 41:10-41:18; 43:23-44:13.
`
`Paper 34 (Pet.’s Mot. to Exclude) at 13-14; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`87
`
`
`
`Tayloe: Patent Owner’s New “Non-Negligible
`Amounts of Energy” Argument
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`88
`
`Paper 26 (Sur-Reply) at 20-21.
`
`
`
`Tayloe: Patent Owner’s New “Non-Negligible
`Amounts of Energy” Argument
`
`STEP 1:
`
`Paper 26 (Sur-Reply) at 21-22.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`89
`
`
`
`Tayloe: Patent Owner’s New “Non-Negligible
`Amounts of Energy” Argument
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`90
`
`Ex. 1022 (Steer Declaration) ¶¶ 255-56.
`
`
`
`Tayloe: Patent Owner’s New “Non-Negligible
`Amounts of Energy” Argument
`
`STEP 1:
`
`Paper 26 (Sur-Reply) at 21; Exhibit 2022.
`
`Paper 34 (Pet.’s Mot. to Exclude) at 11, fn. 3; Response to Paper 26 (Sur-Reply) at 21.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`91
`
`
`
`Tayloe: Patent Owner’s New “Non-Negligible
`Amounts of Energy” Argument
`
`STEP 2:
`
`Paper 26 (Sur-Reply) at 22; Exhibit 2022.
`
`Paper 34 (Pet.’s Mot. to Exclude) at 11, fn.3; Response to Paper 26 (Sur-Reply) at 22.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`92
`
`
`
`Tayloe: Patent Owner’s New “Non-Negligible
`Amounts of Energy” Argument
`
`STEP 3:
`
`Paper 26 (Sur-Reply) at 22; Exhibit 2022.
`
`Paper 34 (Pet.’s Mot. to Exclude) at 11, fn.3; Response to Paper 26 (Sur-Reply) at 22.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`93
`
`
`
`Tayloe: Patent Owner’s New “Non-Negligible
`Amounts of Energy” Argument
`
`Paper 26 (Sur-Reply) at 22; Exhibit 2022.
`
`Even if Tayloe’s capacitor stores 0.193% of
`the energy available in its input signal, this
`amount is non-negligible.
`
`Paper 34 (Pet.’s Mot. to Exclude) at 11, fn. 3; Response to Paper 26 (Sur-Reply) at 17-23.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`94
`
`
`
`’551 Patent: Non-Negligible Amounts of Energy
`
`Exhibit 1025 (’551 Patent) at Cl. 1.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`95
`
`
`
`’551 Patent: Non-Negligible Amounts of Energy
`
`Exhibit 1025 (’551 Patent) at Cl. 41-42.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`96
`
`
`
`United States Patent and Trademark Office
`Before the Patent Trial and Appeal Board
`
`Intel Corporation, Petitioner,
`v.
`ParkerVision, Inc., Patent Owner.
`
`IPR2020-01265
`Petition for Inter Partes Review of U.S. Patent No. 7,110,444
`November 1, 2021
`
`DEMONSTRATIVE EXHIBIT– NOT EVIDENCE
`
`97
`
`
`
`The ’444 Patent: Claim 3
`
`Modulating a high frequency carrier signal
`with a low frequency signal to produce a
`high frequency modulated signal is called
`“up-conversion.”
`
`Paper 3 (Petition) at 20.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`98
`
`Ex. 1001 (’444 Patent) at Fig. 70A, 61:1-18.
`
`
`
`The ’444 Patent: Claim 3
`
`Modulating a high frequency carrier signal
`with a low frequency signal to produce a
`high frequency modulated signal is called
`“up-conversion.”
`
`Modulating a high frequency carrier signal
`with a low frequency signal to produce a
`high frequency modulated signal is called
`“up-conversion.”
`
`Paper 3 (Petition) at 22.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`99
`
`Ex. 1001 (’444 Patent) at Figs. 20A, 20A-1, 61:1-18.
`.
`
`
`
`’444 Patent: [Preamble]
`
`Ex. 1001 (’444 Patent), Cl. 3.
`
`Ex. 1004 (Tayloe) at 1:5-6.
`.
`
`Paper 3 (Petition) at 48-50, 74.
`
`Ex. 1004 (Tayloe) at Abstract.
`.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`100
`
`
`
`Element [3A]
`
`Ex. 1001 (’444 Patent), Cl. 3.
`
`Ex. 1004 (Tayloe) at 1:5-6.
`.
`
`Ex. 1004 (Tayloe) at 6:1-6.
`
`Ex. 1004 (Tayloe) at 1:51-52.
`
`Paper 3 (Petition) at 50-52, 75.
`
`Ex. 1004 (Tayloe) at Fig. 3.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`101
`
`
`
`Element [3B]
`
`Ex. 1001 (’444 Patent) at Cl. 3.
`
`Paper 3 (Petition) at 52-54, 75.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`102
`
`Ex. 1004 (Tayloe) at Fig. 3.
`
`
`
`Element [3C]
`
`Ex. 1001 (’444 Patent) at Cl. 3.
`
`Paper 3 (Petition) at 60-63, 75.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`103
`
`Ex. 1004 (Tayloe) at Fig. 3.
`
`
`
`Element [3D]
`
`Modulating a high frequency carrier signal with a low
`frequency signal to produce a high frequency modulated
`signal is called “up-conversion.”
`
`Ex. 1001 (’444 Patent) at Cl. 3.
`
`Paper 3 (Petition) at 66-68.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`104
`
`Ex. 1004 (Tayloe) at Fig. 3.
`
`
`
`Element [3E]
`
`Modulating a high frequency carrier signal with a low
`frequency signal to produce a high frequency modulated
`signal is called “up-conversion.”
`
`Ex. 1001 (’444 Patent) at Cl. 3.
`
`Paper 3 (Petition) at 75-78.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`105
`
`Ex. 1004 (Tayloe) at Fig. 3.
`
`
`
`Prior Art: TI Datasheet (Ex. 1005)
`
`Ex. 1005 (TI Datasheet) at 1.
`
`Ex. 1019 (Honeycutt Decl.) at 5.
`
`Paper 3 (Petition) at 39-41.
`
`Ex. 1005 (TI Datasheet) at 1.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`106
`
`
`
`Prior Art: TI Datasheet (Ex. 1005)
`
`Paper 3 (Petition) at 40.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`107
`
`Ex. 1005 (TI Datasheet) at 2.
`
`
`
`Prior Art: Kawada (Ex. 1008)
`
`Ex. 1008 (Kawada).
`
`Paper 3 (Petition) at 41-43.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`108
`
`
`
`Prior Art: Kawada (Ex. 1008)
`
`Ex. 1008 (Kawada) at 1:18-27.
`
`Ex. 1008 (Kawada) at 6:15-19.
`
`Paper 3 (Petition) at 41-43.
`
`Ex. 1008 (Kawada) at Fig. 1.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`109
`
`
`
`Undisputed Motivation to Combine
`Tayloe + (TI Datasheet or Kawada)
`
` A POSITA would have been motivated to combine
`the teachings of Tayloe with the teachings of TI
`Datasheet
`
` First, Tayloe expressly discloses that its switch can be
`implemented with a specific, commercially available
`multiplexer—the SN74CBT3253 multiplexer. (Ex. 1004
`(Tayloe) at 5:33-37.)
`
` TI Datasheet is the datasheet for the SN74CBT3253
`multiplexer. (Ex. 1005 (TI Datasheet) at 1.)
`
`Paper 3 (Petition) at 43-45; Ex. 1002 (Subramanian Decl.) at ¶¶ 99-100.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`110
`
`
`
`Undisputed Motivation to Combine
`Tayloe + (TI Datasheet or Kawada)
` Second, Tayloe separately discloses that its switch can
`be implemented with a generic multiplexer. (Ex. 1004
`(Tayloe) at Fig. 7, 5:1-16.)
`
`Modulating a high frequency carrier
`signal with a low frequency signal to
`produce a high frequency modulated
`signal is called “up-conversion.”
`
` Both TI Datasheet and Kawada disclose standard
`multiplexers that a POSITA would have known to use
`as the switch in Tayloe’s down-conversion receiver. (Ex.
`1005 (TI Datasheet) at 1; Ex. 1008 (Kawada) at 1:11-17.)
`
`Paper 3 (Petition) at 43, 44-46; Ex. 1002 (Subramanian Decl.) at ¶ 99, 101.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`111
`
`
`
`Undisputed Motivation to Combine
`Tayloe + (TI Datasheet or Kawada)
`
` Third, combining the teachings of Tayloe with the
`teachings of either TI Datasheet or Kawada would have
`merely involved:
`
` A combination of prior art elements according to
`known methods to yield predictable results; and
`
` A simple substitution of one known element for
`another known element to obtain predictable results
`
` Fourth, Patent Owner does not dispute that a POSITA
`would have been motivated to combine the teachings of
`the references
`
`Paper 3 (Petition) at 46-47; Ex. 1002 (Subramanian Decl.) ¶ 99, 102.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`112
`
`
`
`Secondary Considerations of Non-Obviousness:
`Patent Owner’s Arguments are Improper
`
` Patent Owner contends that “secondary considerations
`demonstrate that the invention of claim 3 of the ’444 patent was
`not obvious.”
`
` But Patent Owner does not identify those considerations or
`provide any explanation.
`
` Patent Owner instead improperly cites its expert’s declaration
`without discussing the substance of the cited paragraphs.
`
` Patent Owner’s expert improperly relies on unsupported
`allegations of industry use, and does not tie his opinions to the
`claimed invention.
`
`Paper 18 (POR) at 74-75; Ex. 2021 (Steer Decl.) ¶¶ 228-239.
`
`Paper 21 (Reply) at 28-30.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`113
`
`
`
`Secondary Considerations: Patent Owner’s
`Arguments Are Improper
`
`Patent Owner’s Response
`
`Paper 16 (POR) at 75.
`
`Paper 18 (POR) at 75.
`
`Paper 23 (Reply) at 30.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`114
`
`Paper 18 (POR) at 74-75.
`
`
`
`Secondary Considerations of Non-Obviousness:
`Patent Owner’s Arguments are Improper
`
`Paper 21 (Reply) at 28.
`
`“[I]ncorporating evidence into a petition by referenc
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
