IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`Filed on behalf of Supercell Oy
`
`By:
`JENNIFER R. BUSH, Reg. No 50,784
`MICHAEL J. SACKSTEDER
`BRIAN HOFFMAN, Reg. No. 39,713
`KEVIN X. MCGANN, Reg. No. 48,793
`GREGORY HOPEWELL, Reg. No. 66,012
`GEOFFREY MILLER
`ERIC ZHOU, Reg. No. 68,842
`FENWICK & WEST LLP
`801 California Street
`Mountain View, CA 94041
`Telephone: 650.988.8500
`Facsimile: 650.938.5200
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`SUPERCELL OY,
`Petitioner
`
`v.
`
`GREE, INC.,
`Patent Owner.
`
`
`Case IPR2020-01553
`Patent 10,076,708 B2
`_____________
`
`PETITIONER’S REPLY TO PATENT OWNER’S
`PRELIMINARY RESPONSE PURSUANT TO 37 C.F.R. § 42.108(c)
`
`
`
`
`
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`Filed on behalf of Supercell Oy
`
`By:
`JENNIFER R. BUSH, Reg. No 50,784
`MICHAEL J. SACKSTEDER
`BRIAN HOFFMAN, Reg. No. 39,713
`KEVIN X. MCGANN, Reg. No. 48,793
`GREGORY HOPEWELL, Reg. No. 66,012
`GEOFFREY MILLER
`ERIC ZHOU, Reg. No. 68,842
`FENWICK & WEST LLP
`801 California Street
`Mountain View, CA 94041
`Telephone: 650.988.8500
`Facsimile: 650.938.5200
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`SUPERCELL OY,
`Petitioner
`
`v.
`
`GREE, INC.,
`Patent Owner.
`
`
`Case IPR2020-01553
`Patent 10,076,708 B2
`_____________
`
`PETITIONER’S REPLY TO PATENT OWNER’S
`PRELIMINARY RESPONSE PURSUANT TO 37 C.F.R. § 42.108(c)
`
`
`
`
`
`
`IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`TABLE OF CONTENTS
`The Fintiv Factors Favor Institution ................................................................ 1
`SCM is a Printed Publication ........................................................................... 5
`GREE Mischaracterizes Supercell’s Arguments and Argues
`Limitations Not Claimed ................................................................................. 6
`
`
`A.
`B.
`C.
`
`
`
`
`i
`
`
`
`IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`TABLE OF AUTHORITIES
`
`Page(s)
`
`CASES
`Apple Inc. v. Seven Networks, LLC,
`IPR2020-00235, Paper 10 (PTAB July 28, 2020) ................................................ 5
`Apple v. Fintiv,
`IPR 2020-00019 ........................................................................................ 1, 2, 4, 5
`Comcast Cable Commc’ns, LLC v. Veveo, Inc.,
`IPR 2019-00239 .................................................................................................... 1
`Hulu, LLC, v. Sound View Innovations, LLC,
`IPR2018-01039, Paper 29, 9 (P.T.A.B. Dec. 20, 2019) ....................................... 5
`NanoCellect Biomedial, Inc., v. Cytonome/ST, LLC,
`IPR2020-00551, Paper 19 (PTAB Aug. 27, 2020) ............................................... 5
`Oticon Medical AB v. Cochlear Limited,
`IPR2019-00975, Paper No. 15 (PTAB Oct. 16, 2019) ......................................... 2
`Sand Revolution II, LLC v. Cont’l Intermodal Grp.,
`IPR2019-01393, Paper 24 (P.T.A.B. June 16, 2020) ....................................... 4, 5
`Snap, Inc. v. SRK Technology LLC,
`IPR2020-00820, Paper 15 (P.T.A.B. Oct. 21, 2020) ............................................ 1
`Sotera Wireless, Inc. v. Masimo Corp.,
`IPR2020-01019, Paper 12 (Dec. 1, 2020)............................................................. 1
`VMWare, Inc. v. Intellectual Ventures I LLC,
`IPR2020-00407, Paper 13 (PTAB Aug. 18, 2020) ............................................... 5
`STATUTES AND RULES
`35 U.S.C. § 102 .......................................................................................................... 5
`35 U.S.C. § 314 ...................................................................................................... 1, 8
`
`
`ii
`
`
`
`IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`EXHIBIT LIST (37 CFR § 42.63(e))
`
`Exhibit
`
`Description
`
`1001
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`1015
`
`1016
`
`U.S. Patent No. 10,076,708 to Yoshikawa
`
`File History of U.S. Patent No. 10,076,708
`
`U.S. Patent No. 10,413,832 to Yoshikawa
`
`File History of U.S. Patent No. 10,413,832
`
`U.S. Patent No. 10,583,365 to Yoshikawa
`
`File History of U.S. Patent No. 10,583,365
`
`Expert Declaration of Ravin Balakrishnan
`
`Curriculum Vitae of Ravin Balakrishnan
`
`Robert Corrina, “What is a Role Playing Game?”, Gamasutra,
`March 11, 2009
`
`“Secret of Monkey Island, The Download (Adventure Game)”,
`old-games.com
`
`Gus Mustrapa, “Scarce Borderlands Weapons Scratch That Old
`Diablo Itch”, WIRED, October 20, 2009
`
`“Vending Machine”, Borderlands Wiki, 13:39, February 25, 2012
`Revision
`
`M.J. Stephey, “A Brief History of Scrabble”, TIME, Dec. 7, 2008
`
`Game Rules”, World English-Language Scrabble Players’
`Association (WESPA), Version 2.0, issued by the WESPA Rules
`Committee 17 November 2010
`
`Scrabble Dating, Donald Sauter
`
`Scrabble Complete PC Manual, Infogrames Interactive, Inc., 2002
`
`iii
`
`
`
`IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`
`Exhibit
`
`1017
`
`1018
`
`1019
`
`1020
`
`1021
`
`1022
`
`1023
`
`1024
`
`1025
`
`1026
`
`1027
`
`1028
`
`1029
`
`1030
`
`1031
`
`1032
`
`Description
`
`Francis Chang et al., “Modeling Player Session Times of On-line
`Games”, NetGames '03: Proceedings of the 2nd workshop on
`Network and system support for games, May 2003
`
`John Carter, “The Original Magic Rulebook”, December 25, 2004
`
`“Rarity”, MTG Wiki, 29 Jan. 2010 Revision
`
`“Magic: The Gathering Online 3.0 and the Theory of Virtual
`Objects”, Gamespy, March 27, 2005
`
`“Now Everyone Can Play the Pokémon Trading Card Game
`Online”, Kotaku, August 25, 2011
`
`U.S. Patent 9,511,285 to Hawkins
`
`U.S. Patent Pub. No. 2009/0051114 to Robbers et al.
`
`U.S. Patent 8,352,542 to Stroffolino
`
`“Scrabble/Rules”, Wikibooks
`
`Scrabble Complete (PC CD-ROM), Infogrames
`
`“Amazon.com: Scrabble Complete: Video Games”, Amazon.com
`
`“Hasbro Family Game Night: Scrabble Xbox Live Gameplay”,
`IGN, YouTube
`
`POPR, PGR2020-00053
`
`Scott McKeown, Congress Urged to Investigate PTAB
`Discretionary Denials, Patents Post-Grant (June 30, 2020)
`
`Scott McKeown, District Court Trial Dates Tend to Slip After
`PTAB Discretionary Denials, Patents Post-Grant (July 24, 2020)
`
`Plaintiff's Opposition to Defendant's Motion for Relief re
`Governmental Restrictions re COVID-19 (19-00161), Dkt. 102
`
`iv
`
`
`
`IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`
`Exhibit
`
`Description
`
`1033
`
`1034
`
`1035
`
`1036
`
`1037
`
`1038
`
`1039
`
`1040
`
`1041
`
`1042
`
`Fourth Amended Docket Control Order (19-00310), Dkt. 62
`
`Plaintiff Gree, Inc.’s Paragraph 1 and 3 Initial and Additional
`Disclosures, Feb. 18, 2020 (19-00310)
`
`Defendant Supercell Oy’s Notice of Deposition of Tomoki
`Yasuhara, Aug. 7, 2020 (19-00310)
`
`Defendant Supercell Oy’s Notice of Rule 30(b)(6) Deposition of
`Plaintiff Gree, Inc.
`
`Amended Docket Control Order, entered October 7, 2020
`[Dkt. 81], Civil Case No. 19-cv-00310-JRG-RSP (E.D. Tex.)
`
`Sixth Amended Docket Control Order [Dkt 94], entered on
`October 23, 2020, Case No. 19-cv-00311 (E.D. Texas)
`
`Order (Granting Continuance of In-Person Jury Trials) (Dkt. 261),
`entered on November 20, 2020, Infernal Technology, LLC, et al.
`v. Sony Interactive Entertainment LLC, Case. No. 19-cv-00248
`(E.D. Texas)
`
`Texas COVID-19 Active Case Data By County, available at
`https://dshs.state.tx.us/coronavirus/TexasCOVID-
`19ActiveCaseDatabyCounty.xlsx (retrieved February 8, 2021).
`
`Texas Department of State Health Services Website, Texas
`COVID-19 Data, available at
`https://dshs.texas.gov/coronavirus/additionaldata.aspx (retrieved
`February 8, 2021).
`
`New coronavirus variant could take over by spring, experts day,
`The Dallas Morning News, Jan. 16, 2021, available at
`https://www.dallasnews.com/news/2021/01/16/new-coronavirus-
`variant-could-take-over-by-spring-experts-say/.
`
`v
`
`
`
`IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`
`Description
`
`Katie Buehler, COVID-19 Outbreak Leads to Mistrial in EDTX,
`Law360 (Nov. 17, 2020),
`https://www.law360.com/articles/1329617/covid-19-outbreak-
`leads-to-mistrial-in-edtx
`Order entered on November 20, 2020, Solas OLED Ltd. v.
`Samsung Display Co., Ltd., [Dkt 302], Case No. 2:19-cv-00152-
`JRG.
`
`Exhibit
`
`1043
`
`1044
`
`
`
`
`
`vi
`
`
`
`IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`A. The Fintiv Factors Favor Institution
`Proper application of the Fintiv factors demonstrates that the Board should not
`
`exercise its discretion to deny institution under 35 U.S.C. § 314. First, Factor 4
`
`seeks to avoid inefficiency and the possibility of conflicting decisions, concerns
`
`that are absent here due to the lack of overlap between the IPR and the parallel
`
`litigation. Apple v. Fintiv, IPR 2020-00019, Paper 11 at 13 (P.T.A.B. Mar. 20,
`
`2020) (Precedential); see also Sotera Wireless, Inc. v. Masimo Corp., IPR2020-
`
`01019, Paper 12 (Dec. 1, 2020) (precedential as to § II.A); Snap, Inc. v. SRK
`
`Technology LLC, IPR2020-00820, Paper 15 at 15 (P.T.A.B. Oct. 21, 2020)
`
`(Precedential); Comcast Cable Commc’ns, LLC v. Veveo, Inc., IPR 2019-00239,
`
`Paper 15 at 14-16 (P.T.A.B. July 5, 2019).
`
`There is no overlap whatsoever between the art in the IPR grounds and that
`
`applied in the litigation invalidity contentions. GREE mischaracterizes SCM
`
`(Ground 2) as “undisputedly also asserted in the parallel district court proceeding,”
`
`referencing a litigation expert report. POPR at 23, citing Ex. 2006. However, in
`
`actuality SCM is discussed only in the “general state of the prior art” section, not as
`
`“asserted prior art.” See Ex. 2006 at p. 2. Thus, GREE’s assertion is patently false.
`
`In addition, SCM is only present in Ground 2; Ground 1 has no overlap.
`
`GREE points to PTAB precedent holding that “some overlap” along with
`
`non-overlapping challenges “weigh marginally” against exercising discretion (POPR
`
`1
`
`
`
`IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`at 24, citing IPR2020-00919, Paper 9 at 11-12). However, the facts of that case are
`
`distinguishable since there is no overlap here. Thus, Factor 4 weighs strongly in
`
`favor of institution. See Oticon Medical AB v. Cochlear Limited, IPR2019-00975,
`
`Paper No. 15 (PTAB Oct. 16, 2019) (instituted based in part on lack of overlap).
`
`Factor 6 is “other circumstances that impact the Board’s exercise of
`
`discretion, including the merits.” Fintiv at 14. The Fintiv Order focuses this factor
`
`on the strength on the merits of the invalidity grounds raised in the petition. Id. at
`
`14-16. The Fintiv Order provides an example in which institution is favored “if the
`
`merits of a ground raised in the petition seem particularly strong.” Id. at 14-15.
`
`The Order cites to four additional decisions in which the strength of the merits
`
`outweighed other considerations. Id. at 15, n. 29. As discussed below, GREE’s
`
`counterarguments merely amount to limitations not claimed, mischaracterizations
`
`of Supercell’s arguments, and an unsupported printed publication challenge. None
`
`of these diminish the strong merits of the grounds, and as in the cases cited above,
`
`the strength of the merits should outweigh the other factors. Id.
`
`Regardless of the trial date, Factor 2 should be afforded little weight because
`
`the trial will be addressing different art. Furthermore, determining the true trial
`
`date requires speculation. GREE argues the current trial date should be taken at
`
`“face value.” POPR at 11, citing Fintiv at 13. However, taking the current trial date
`
`at face value is not tenable at this point. The record indicates that the Eastern
`
`2
`
`
`
`IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`District of Texas court is at least triple booked for the trial date. See Ex. 1039,
`
`1044 (setting jury selection for both the Solas and Sony cases for the identical date
`
`and time as the corresponding district court litigation). Further, the trial date has
`
`already been moved twice, resulting in a delay of five months. Ex. 1037-1039. In
`
`addition, the court closed down for over three months, which will undoubtedly
`
`cause a cascade of delays to the Court’s calendar, which are likely to impact the
`
`trial date.
`
`Nor is it likely that jury trials will resume on March 1, since the continuing
`
`pandemic makes further delays likely. Infection rates have increased dramatically
`
`since the closure, including an increase of over 340% between December 2020 and
`
`February 1, 2021. See Exs. 1040, 1041. To make matters worse, more contagious
`
`strains are now spreading
`
`that may
`
`trigger a new surge of
`
`infections
`
`notwithstanding the rollout of vaccines. Ex. 1042. Jury trials are especially
`
`susceptible because they involve parties who “often reside internationally or in
`
`domestic locations with a variety of travel restrictions and quarantines.” Ex. 1039
`
`at 3. The Closure Order describes how the Court conducted jury trials August-
`
`November 2020 with extensive safety precautions, yet 15 individuals in another
`
`court in the district contracted COVID-19 during a trial, forcing a mistrial. See
`
`Ex. 1043; Ex.1039 at n.3.
`
`3
`
`
`
`IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`
`The safety issues cannot be overcome through remote trials. The Closure
`
`Order makes it clear that the Court requires jury trials to be held in person: “the
`
`Court believes that the fair adjudication of the rights of the parties… requires jury
`
`trials to be conducted in-person.” Ex. 1039 at 3. Thus, there is no alternative to
`
`waiting until jury trials are safe and practical.
`
`In view of these circumstances, and as in Sand Revolution, “it is unclear that
`
`the court in the related district court litigation will adhere to any currently
`
`scheduled jury trial date or, if it is changed, when such a trial will be held.” Sand
`
`Revolution II, LLC v. Cont’l Intermodal Grp., IPR2019-01393, Paper 24 at 9
`
`(P.T.A.B. June 16, 2020) (informative). Determining whether and when the Court
`
`will conduct any future trials requires substantial speculation. The Board, in
`
`contrast, “continues to be fully operational.” Id.
`
`Moreover, this factor implicates Factors 4 and 6. Fintiv, at 9. On the whole,
`
`the Proximity factor weighs in favor of institution.
`
`The Investment factor (Factor 3) is neutral, because, to the extent the court
`
`has invested, it invested primarily in non-overlapping issues, e.g., determining
`
`issues related to potential invalidity based on different references, or related to
`
`alleged infringement. There has been only minimal investment in the issues
`
`overlapping with the IPR, such as claim construction.
`
`4
`
`
`
`IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`
`Factor 1 (stay) and Factor 5 (same parties) should be given little weight, and
`
`are not dispositive.
`
`The holistic NHK-Fintiv analysis favors institution. The Board has found
`
`Factors 4 and 6 to be definitive several times in reaching its decision to institute,
`
`regardless of its finding regarding the other factors. See, e.g., Sand Revolution, at 9;
`
`Apple Inc. v. Seven Networks, LLC, IPR2020-00235, Paper 10 (PTAB July 28,
`
`2020); NanoCellect Biomedial, Inc., v. Cytonome/ST, LLC, IPR2020-00551, Paper
`
`19 (PTAB Aug. 27, 2020); VMWare, Inc. v. Intellectual Ventures I LLC, IPR2020-
`
`00407, Paper 13 (PTAB Aug. 18, 2020). Here, Factors 4 and 6 similarly are strong,
`
`and thus this IPR should be instituted consistent with those cases. Moreover, in this
`
`case at least Factor 2 also weighs in favor of institution as discussed above. Thus,
`
`overall the Fintiv factors favor institution.
`
`SCM is a Printed Publication
`B.
`There should be no doubt that SCM qualifies a printed publication under 35
`
`U.S.C. § 102 (b). “The determination of whether a document is a ‘printed
`
`publication’ under 35 U.S.C. § 102 ‘involves a case-by-case inquiry into the facts
`
`and circumstances surrounding the reference’s disclosure to members of the
`
`public.’” Hulu, LLC, v. Sound View Innovations, LLC, IPR2018-01039, Paper 29, 9
`
`(P.T.A.B. Dec. 20, 2019) (precedential).
`
`5
`
`
`
`IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`
`As GREE notes, SCM itself bears a 2002 publication date. Other evidence,
`
`submitted with the initial petition, demonstrates that this date is accurate, including
`
`Wayback Machine archives of the publisher Infogrames’s website showing the
`
`game on sale in 2002, an Amazon store page showing the game on sale in 2011
`
`and listing the game’s 2002 release date, and as Dr. Balakrishnan’s testimony that
`
`the SCM game manual was included with the CD-ROM of the purchased game.
`
`See Ex. 1026, Ex. 1027, Ex. 1007. Thus, GREE is the party trying to overcome
`
`evidence with mere conclusory statements. See POPR at 41-45.
`
`C. GREE Mischaracterizes Supercell’s Arguments and Argues
`Limitations Not Claimed
`GREE bases its arguments in the POPR on limitations that are not claimed.
`
`For example, GREE argues that Hawkins does not teach “displaying a plurality of
`
`cells and acquirable item information …” because the cards in Hawkins are not
`
`cards “that a user can newly ‘acquire.’” POPR at 34. However, the claims do not
`
`require that the “plurality of items” are items that the user can “newly acquire,”
`
`nor do they recite any requirement that an item be acquired following a selection
`
`request. In addition, the specification several times describes embodiments of
`
`“acquirable item information” as including items that have already been acquired
`
`by the user, for example, including “an acquisition count” of items in the
`
`acquirable item information examples. See, e.g., Ex. 1001, Abstract; 1:62; 2:28;
`
`6
`
`
`
`IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`2:63; 4:63; 5:19; 7:52. Thus, this argument is a veiled attempt by GREE to limit
`
`the claims to a singular embodiment described in the specification, but not recited.
`
`Similarly, with regards to SCM, GREE argues that the letter tiles in Scrabble
`
`on the player’s rack are not “acquirable items,” due to already having been
`
`obtained by the player. Id. at 46. However, as discussed above, “acquirable item
`
`information” may include information about items that have already been acquired
`
`by the player; the claims impose no limitation on the “plurality of items” relating
`
`to whether they have already been acquired.
`
`GREE also argues that Hawkins does not disclose the “selected randomly”
`
`element of the claims, because a user’s Noble cards for a game are “pre-selected.”
`
`POPR at 37. However, Supercell relied primarily on the Hero cards of Hawkins as
`
`showing the selected randomly limitation, making it irrelevant whether the Noble
`
`cards are selected randomly (which they are). See Petition at 49. In addition, GREE
`
`mischaracterizes Supercell’s application of the Noble cards. The Petition relies on
`
`drawing the cards from a deck into the player’s hand during a game for this claim
`
`element, not the pre-selection of cards that make up the player’s deck, as argued by
`
`GREE. See POPR at 37.1
`
`
`1 GREE implies that the pre-selection means the cards are necessarily “pre-organized
`
`or pre-staged,” even though the reference contains no disclosure to that effect. Id.
`
`7
`
`
`
`IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`
`With regards to SCM, GREE argues that it does not disclose this limitation
`
`because the letter tiles originally selected to be placed on the player’s letter rack
`
`are drawn blindly, such that the rarity values of the tiles are not shown. See POPR
`
`at 46. Again, GREE mistakes Supercell’s reliance for this element as being on the
`
`initial drawing of letter tiles to the player’s rack. Rather, Supercell relied on the
`
`player request to select a letter tile already displayed on their rack to be placed and
`
`displayed on the board. See Petition at 59-65; Ex. 1007, ¶¶95-97; ¶136.
`
`
`Accordingly, the Petition should not be denied under § 314(a).
`
`
`
`Dated: February 8, 2021
`
`Respectfully submitted,
`FENWICK & WEST LLP
`
`/Jennifer R. Bush/
`Jennifer R. Bush
`Reg. No. 50,784
`Attorneys for Petitioner Supercell Oy
`
`
`
`8
`
`
`
`IPR2020-01553
`Petitioner’s Reply to Patent Owner’s Preliminary Response
`
`
`CERTIFICATION OF SERVICE ON PATENT OWNER
`
`The undersigned hereby certifies that the foregoing Petitioner’s Reply to
`
`Patent Owner’s Preliminary Response and accompanying Exhibits 1037 through
`
`1044 were served on Patent Owner’s lead and back-up counsel in its entirety by
`
`electronic service at the email addresses provided below:
`
`Andrew W. Rinehart
`Kilpatrick Townsend & Stockton LLP
`1001 West Fourth Street
`Winston-Salem, NC 27101
`arinehart@kilpatricktownsend.com
`
`Scott A. McKeown
`Ropes & Gray
`2099 Pennsylvania Avenue, N.W.
`Washington, D.C. 2006
`scott.mckeown@ropesgray.com
`
`
`FENWICK & WEST LLP
`
`/Jennifer R. Bush/
`Jennifer R. Bush
`Reg. No. 50,784
`Attorneys for Petitioner Supercell Oy
`
`
`
`
`John C. Alemanni
`Kilpatrick Townsend & Stockton LLP
`4208 Six Forks Road, Suite 1400
`Raleigh, NC 27609
`jalemanni@kilpatricktownsend.com
`
`Joshua H. Lee
`Kilpatrick Townsend & Stockton LLP
`1100 Peachtree Street NE, Suite 2800
`Atlanta, GA 30309-6582
`jlee@kilpatricktownsend.com
`
`Dated: February 8, 2021
`Fenwick & West LLP
`801 California Street
`Mountain View, CA 94041
`Telephone: (650) 988-8500
`
`
`9
`
`
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