UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`
`
`
`Paper No. 52
`Filed: May 2, 2022
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`
`
`
`
`
`
`
`QUALCOMM INCORPORATED and
`ZYXEL COMMUNICATIONS CORPORATION1,
`
`Petitioners,
`
`v.
`
`UNM RAINFOREST INNOVATIONS,
`
`Patent Owner.
`
`
`
`
`
`
`
`
`
`
`PTAB Case No. IPR2021-00375
`Patent 8,265,096 B2
`
`
`
`
`
`
`
`
`
`
`REPLY IN SUPPORT OF
`PATENT OWNER’S REVISED MOTION TO AMEND
`
`
`1 ZyXEL Communications Corporation was joined as a Petitioner in this proceeding
`based on a petition and motion for joinder filed in IPR2021-00734, which were
`granted.
`
`
`
`
`
`
`
`
`
`Paper No. 52
`Filed: May 2, 2022
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`
`
`
`
`
`
`
`QUALCOMM INCORPORATED and
`ZYXEL COMMUNICATIONS CORPORATION1,
`
`Petitioners,
`
`v.
`
`UNM RAINFOREST INNOVATIONS,
`
`Patent Owner.
`
`
`
`
`
`
`
`
`
`
`PTAB Case No. IPR2021-00375
`Patent 8,265,096 B2
`
`
`
`
`
`
`
`
`
`
`REPLY IN SUPPORT OF
`PATENT OWNER’S REVISED MOTION TO AMEND
`
`
`1 ZyXEL Communications Corporation was joined as a Petitioner in this proceeding
`based on a petition and motion for joinder filed in IPR2021-00734, which were
`granted.
`
`
`
`TABLE OF CONTENTS
`
`I.
`
`II.
`
`A.
`
`B.
`
`INTRODUCTION ........................................................................................... 1
`
`PATENT OWNER’S REVISED MOTION SHOULD BE TREATED AS A
`REPLY ............................................................................................................. 2
`
`PATENT OWNER’S REVISED MOTION IS A REPLY. ....................... 3
`
`PATENT OWNER’S PAPER PROPERLY ADDRESSES WRITTEN
`DESCRIPTION SUPPORT ....................................................................... 4
`
`III.
`
`PATENT OWNER’S WRITTEN DESCRIPTION SUPPORT IS PROPER. 7
`
`IV. THE PROPOSED AMENDED CLAIMS ARE PATENTABLE. .................. 9
`
`V.
`
`CONCLUSION ..............................................................................................12
`
`
`
`ii
`
`
`
`TABLE OF AUTHORITIES
`
`CASES:
`
`B.E. Tech., L.L.C. v. Google, Inc., No. 2015-1827,
`2016 U.S. App. LEXIS 20591, (Fed. Cir. Nov. 17, 2017) .................................... 8
`
`
`REGULATIONS:
`
`37 C.F.R. § 42.1 ......................................................................................................... 4
`
`ADMINISTRATIVE DECISIONS:
`
`
`Greene's Energy Grp., LLC v. Oil States Energy Services, LLC, IPR2014-00216,
`Paper 53 at 26 (PTAB May 1, 2015) .................................................................... 8
`
`
`Intel Corp. v. Alacritech, Inc., IPR2017-01392, Paper 81 at 64–65
`(PTAB Nov. 26, 2018) .......................................................................................... 7
`
`
`Lectrosonics, Inc. v. Zaxcom, Inc., IPR2018-01129, Paper 15 at 8
`(PTAB Feb. 25, 2019) .......................................................................................4, 5
`
`
`Lippert Components, IPR2018-00777, Paper 28 at 52
`
`(PTAB Sept. 24, 2019) ................................................................................ 5, 6, 8
`
`Orthofix Medical Inc. v. Spine Holdings, LLC, IPR2020-01411, Paper 33 at 3,
`(PTAB Oct. 27, 2021) ............................................................................................ 3
`
`
`Respironics, Inc. v. Zoll Med. Corp., IPR2013-00322, Paper 46 at 24
`(PTAB Sept. 17, 2014) ......................................................................................... 8
`
`
`
`
`
`
`
`
`
`
`
`
`
`iii
`
`
`
`I.
`
`INTRODUCTION
`
`Patent Owner UNM Rainforest Innovations (hereinafter “UNM” or “Patent
`
`Owner”) respectfully submits this Reply in Support of its Revised Motion to Amend
`
`to request amendment of certain claims of U.S. Patent 8,265,096 B2 (EX1001, “’096
`
`Patent”), responding to Petitioners’ Opposition To Patent Owner’s Revised Motion
`
`To Amend (Paper 49) (“Opposition”).
`
`First, Petitioners argue that Patent Owner’s Revised Motion should be
`
`expunged because it does not suggest new amendments in addition to those already
`
`submitted in the original Motion to Amend. Second, Petitioners argue that when
`
`treated as a reply, Patent Owner’s Revised Motion should not be allowed to address
`
`the written description support because it is too late to do so. However, the Board
`
`already recognized in the Preliminary Guidance that the claims as a whole find
`
`proper support in the written description. Further, Petitioners have already
`
`unilaterally administered the appropriate self-help by submitting its “sur-reply” in a
`
`full 25 pages—which is the allotment for an opposition to a revised motion, and the
`
`approach taken by Patent Owner is expressly contemplated by the Office’s rules.
`
`Third, Petitioners’ complaint that Patent Owner relies on string citations without
`
`further explanation is unfounded because Patent Owner supplied short precise
`
`citations along with descriptive parentheticals explaining the disclosure individually
`
`
`
`1
`
`
`
`for each and every claim element. Fourth, for the reasons explained below, the
`
`proposed substitute claims are not rendered obvious over the prior art.
`
`II.
`
`PATENT OWNER’S REVISED MOTION SHOULD BE TREATED
`AS A REPLY
`
`In its Opposition, Petitioners asked for extraordinary remedies that would be
`
`unjust and highly prejudicial to Patent Owner and the integrity of these proceedings.
`
`Petitioners concede that Patent Owner’s Motion is a reply and that the Opposition is
`
`a sur-reply. Paper 49 at 5. In a parallel filing, Petitioners recognized that there is
`
`uncertainty surrounding the interpretation and application of the rules governing the
`
`revised motion to amend practice. IPR2021-00377, Paper 47 at 12, fn. 1. Yet,
`
`Petitioners ask that Patent Owner’s Motion be disregarded and expunged. Paper 49
`
`at 3-4. Not surprisingly, no decisions, including the ones on which Petitioners rely,
`
`support such a draconian result. Petitioners then ask that the written description
`
`support that Patent Owner provided in direct response to the Board’s Preliminary
`
`Guidance be completely disregarded. Id. at 5-8. Again, such drastic relief has not
`
`been granted, even in the decisions Petitioners cite. What Petitioners actually seek
`
`is to strip Patent Owner of its due process rights by depriving Patent Owner the
`
`meaningful opportunity to preserve its claims as required by the AIA and the
`
`Office’s implementing rules. Petitioners’ extreme positions must therefore be
`
`rejected.
`
`
`
`2
`
`
`
`A. PATENT OWNER’S REVISED MOTION IS A REPLY.
`
`As Petitioners candidly (and accurately) stated, “P.O.’s RMTA … can only
`
`be considered a reply.” Paper 49 at 5. Although the amendments requested in Patent
`
`Owner’s Motion are identical to those requested in Patent Owner’s original Motion
`
`to Amend (Paper 37), Patent Owner submitted its revised Motion to address certain
`
`shortcomings identified by the Board in its Preliminary Guidance. Patent Owner
`
`styled its filing a Revised Motion to Amend out of an abundance of caution because,
`
`as Petitioners recognized in a parallel filing, the rules regarding the form of a filing
`
`after issuance of the Board’s preliminary guidance are uncertain. IPR2021-00377,
`
`Paper 47 at 12, fn. 1. Petitioners’ argument for the most extreme remedy—
`
`expungement of the paper—is improper and unnecessary form-over-substance under
`
`the circumstances. The very decision on which Petitioners rely demonstrates as
`
`much. See Orthofix Medical Inc. v. Spine Holdings, LLC, IPR2020-01411, Paper 33
`
`at 3 (PTAB Oct. 27, 2021). The Board there treated the revised motion to amend as
`
`a reply and, to offset any perceived unfairness, increased the page limit for
`
`Petitioner’s sur-reply. Id. (“Under the circumstances, we deem Paper 30 as Patent
`
`Owner’s reply to opposition to motion to amend. To afford Petitioner a fair
`
`opportunity, we increase the page limit for the sur-reply to reply to opposition to
`
`motion to amend from 12 pages to 25 pages.”). Here, Petitioners have already taken
`
`advantage of the enlarged 25 page limit in their Opposition.
`
`
`
`3
`
`
`
`Petitioners therefore feign prejudice if Patent Owner’s Motion is accepted.
`
`Paper 49 at 3. But, Petitioners were clearly able to fully respond to Patent Owner’s
`
`Motion in the allotted time. And, as noted above, Petitioners have submitted an
`
`Opposition using the same page limit (25) as Patent Owner’ Motion. Thus, the only
`
`threat of prejudice under these circumstances is to Patent Owner.
`
`Petitioners’ position that it is improper for Patent Owner to restate the same
`
`amendment from its original Motion to Amend (see Paper 49 at 2-3) is expressly
`
`belied by the Office rules that it cites but studiously misrepresents. Those rules
`
`provide that a “revised MTA may also include substitute claims, arguments or
`
`evidence previously presented in the original MTA.” 84 F.3d Reg. 9495, 9498 (Mar.
`
`15, 2019). Moreover, Petitioners’ positions are not in accord with construing rules
`
`in a manner that will secure a just and speedy result. 37 C.F.R. § 42.1. For example,
`
`Patent Owner could have addressed Petitioners’ complaint that it “filed an improper
`
`revised MTA” (Paper 49 at 3) by simply adding a superficial and inconsequential
`
`amendment to create the illusion of proper form. This would serve no meaningful
`
`purpose. Patent Owner therefore did what is intended: it filed a reply that
`
`specifically and fully addresses the issues raised in the Preliminary Guidance.
`
`B. PATENT OWNER’S PAPER PROPERLY ADDRESSES WRITTEN
`DESCRIPTION SUPPORT
`
`Petitioners point to Lectrosonics to argue that, as a reply, Patent Owner’s
`
`Motion should not be allowed to address the written description support because it
`4
`
`
`
`
`
`is too late to do so in the first instance on reply. Paper 49 at 4-5 (citing Lectrosonics,
`
`Inc. v. Zaxcom, Inc., IPR2018-01129, Paper 15 at 8 (PTAB Feb. 25, 2019)).
`
`Petitioners further cite Lippert to support the argument that Patent Owner’s more
`
`detailed identification of written description support for the original (as opposed to
`
`amended) claim elements is improper. Paper 49 at 5 (citing Lippert Components,
`
`IPR2018-00777, Paper 28 (PTAB Sept. 24, 2019)). This matter is distinguished
`
`from Lippert in two important and dispositive ways. First, unlike Lippert, the Board
`
`here already recognized in the Preliminary Guidance that the portions identified by
`
`Patent Owner meet the written description requirement: “(i) column 5, lines 17–18
`
`and lines 35–36, column 7, lines 23–24, column 7, line 61 to column 8, line 6, and
`
`column 9, lines 18–20 in the ’096 Patent disclosure and (ii) corresponding portions
`
`of the Specification, as filed, of the ’855 Application, . . . along with adjacent
`
`disclosures at paragraphs 35–37 and Figures 6A, 6B, 7 of the ’855 Application
`
`appear to provide adequate written description support for proposed substitute
`
`claims 44–47, 49, and 50 as a whole.” Paper 42 at 7 (emphasis added). Patent
`
`Owner merely addressed this part of the Preliminary Guidance.
`
`Further, Lippert is inapposite because it found the written description
`
`requirement lacking because of undue string citations.
`
`Exhibits 2012 and 2013 are deficient on the merits. As other Board
`panels have found, mere string citations to an original application’s
`disclosure without explanation are insufficient to meet a patent owner’s
`burden of production. . . . With the meager showing in Exhibits 2012
`5
`
`
`
`
`
`and 2013, it is unclear whether the citations for a given claim limitation
`are to be understood as a combination of disclosures that, taken
`together, disclose the corresponding limitation, or whether Patent
`Owner contends each citation within a string is sufficient to disclose the
`corresponding limitation. It is not the Board’s responsibility to search
`through the string citations to find sufficient written description support
`for each limitation, and we decline to do so.
`
`Lippert Components, IPR2018-00777, Paper 28 at 52. The patent owner in Lippert
`
`did indeed present string cites with no explanation as to what each cite was supposed
`
`to show. See IPR2018-00777, Exhibits 2012-2013. Unlike Lippert, Patent Owner
`
`identified—separately for each element—pinpoint citations along with parenthetical
`
`explanations to explain in detail how each claim element is disclosed. Compare id.
`
`with Motion at 5-20. Due to Patent Owner’s element-specific pinpoint citations with
`
`parenthetical explanations, the Board will not have to “search through the string
`
`citations to find sufficient written description support for each limitation” as it
`
`declined to do in Lippert.
`
`Finally, Petitioners argue that “if P.O.’s RMTA is deemed to be a reply, then
`
`this paper would be a sur-reply, which would prevent Petitioners from presenting
`
`new evidence to explain why P.O.’s alleged written description support is deficient.”
`
`Paper 49 at 6. Petitioners willfully ignore the fact that they did in fact address the
`
`written description support proffered by Patent Owner. Id. at 7-10. Indeed,
`
`Petitioners expanded their “sur-reply” from 12 to 25 pages to take full advantage of
`
`the opportunity to do so.
`
`
`
`6
`
`
`
`III. PATENT OWNER’S WRITTEN DESCRIPTION SUPPORT IS
`PROPER.
`
`Petitioners argue that “P.O.’s alleged showing of written description support
`
`consists exclusively of string citations, with no further explanation as to the cited
`
`materials supports the claims.” Paper 49 at 7. This is demonstrably false. Each of
`
`Patent Owner’s citations indicates specifically which claim element it pertains to,
`
`and includes a parenthetical explanation of its relevance, as demonstrated by the
`
`below example:
`
`
`
`Motion at 6; see also Motion at 5-20 for the remaining claim elements. Every last
`
`one of the allegedly supporting decisions cited by Petitioners is inapposite, as they
`
`all relate to “string citations without explanation.” See, e.g., Intel Corp. v.
`
`Alacritech, Inc., IPR2017-01392, Paper 81 at 64–65 (PTAB Nov. 26, 2018) (“mere
`
`
`
`7
`
`
`
`string citations without explanation . . .”); B.E. Tech., L.L.C. v. Google, Inc., No.
`
`2015-1827, 2016 U.S. App. LEXIS 20591, *21-22 (Fed. Cir. Nov. 17, 2017)
`
`(discussing “string citations without explanation”); Greene's Energy Grp., LLC v.
`
`Oil States Energy Services, LLC, IPR2014-00216, Paper 53 at 26 (PTAB May 1,
`
`2015) (“A string citation does not explain . . .”); Respironics, Inc. v. Zoll Med. Corp.,
`
`IPR2013-00322, Paper 46 at 24 (PTAB Sept. 17, 2014) (“Zoll's string citations
`
`[without explanation] amount to little more than an invitation … to peruse the cited
`
`evidence and piece together a coherent argument for them”); Lippert, IPR2018-
`
`00777, Paper 28 (concerning “string citations to an original application’s disclosure
`
`without explanation . . .”). Unlike every one of these cases, Patent Owner provided
`
`parenthetical explanations to every last one of its pinpoint citations, and has further
`
`indicated which specific claim element each is relevant to. These claim-element
`
`specific pinpoint citations with explanatory parentheticals minimizes the burden on
`
`the Board to verify that the written description properly supports the claim elements.
`
`Finally, Petitioners argue that Patent Owner does not show support for the
`
`original claim elements to the provisional ’798 Application. Paper 49 at 9. This is
`
`irrelevant. Patent Owner’s proposed amendment is contingent upon a finding of
`
`unpatentability of original claim 1. Written description support in the ’798
`
`Application for original claim 1 is provided in detail in Patent Owner’s Response
`
`(Paper 38) and sur-reply (Paper 43). If the Board finds this showing sufficient, then
`
`
`
`8
`
`
`
`Claim 1 will not be found unpatentable (because the primary prior art reference
`
`(Talukdar) does not predate the ’798 Application), and the Revised Motion to
`
`Amend will be rendered moot.
`
`IV. THE PROPOSED AMENDED CLAIMS ARE PATENTABLE.
`
`To start, Petitioners’ Opposition, for the most part, merely repeats verbatim
`
`the arguments in its original Opposition (Paper 41) which the Board already rejected
`
`in its Preliminary Guidance. (Paper 42). However, notably absent is Petitioners’
`
`original argument blatantly mischaracterizing the record by implying that the
`
`proposed amended limitation is ‘naturally present’ in the original claims which were
`
`“invalid over the combination of Talukdar and Li, as described in Ground of the
`
`Petition. Notably, the Board granted institution on Ground 1.” Paper 41 at 1.
`
`Petitioners intentionally omitted that the Board’s institution decision found only
`
`Claim 1 (the basis for proposed amended claim 44) likely to be obvious. As to Claim
`
`8, the Board found that “we are not persuaded that Petitioner establishes sufficiently,
`
`for the purpose of institution, that Talukdar and Nystrom renders obvious the subject
`
`matter of claim 8” on the basis of the claim element “wherein the second
`
`communication system has pilot symbols that are denser than those in the first
`
`communication system.” Paper 14 at 47. This, of course, is the exact proposed
`
`amended limitation added in Amended Claim 44. Tellingly, Petitioners removed
`
`this erroneous argument from their revised Opposition.
`
`
`
`9
`
`
`
`The additional claim element “wherein the second communication system has
`
`pilot symbols that are denser than those in the first communication system” is not
`
`taught by Talukdar, Li, or Nystrom. Petitioners rely solely on Li to teach this
`
`limitation, arguing first that if the disclosure of U.S. Provisional Patent Application
`
`No. 60/929,798 (“the ’798 Application”) teaches denser pilot symbols (as argued by
`
`Patent Owner), then so does Li. Paper 41 at 6. This is wrong for several reasons.
`
`First, Li does not rely on the same disclosure as the ’798 Application – naturally, the
`
`conclusions drawn by a POSITA would differ from two different disclosures.
`
`Second, Li addresses pilot symbols only in reference to its Fig. 7, which illustrates
`
`an embodiment of its invention and identifies the pilot symbols:
`
`first communications system
`
`second communications system
`
`
`
`
`
`EX1016 at Fig. 7. Li’s figure 7 illustrates the effect of Li’s teaching of halving the
`
`symbol period. Notably, the number of Pilot symbols before and after remains the
`
`same – there are seven pilot symbols during the same time-period both before and
`
`after Li’s modification.
`
` Further, as the Board already noted, “the first
`
`communication system (top graph in Li’s Figure 7) has two pilot symbols in a period
`
`
`
`10
`
`
`
`T, and the second communication system (bottom graph in Li’s Figure 7) also has
`
`two pilot symbols in period T.” Paper 42 at 13. Petitioners’ and their expert’s
`
`supposition that Li teaches more pilot symbols in the same time-period is explicitly
`
`contradicted by Fig. 7.
`
`Petitioners respond only by first admitting that “P.O. is correct that both
`
`frames of Figure 7, which relates to splitting symbols across both frequency and
`
`time, show the same number of total symbols and the same number of pilot
`
`symbols.” Paper 49 at 16 (emphasis added). Regardless, Petitioners argue that “this
`
`is simply because the two frames of figure 7 show different numbers of subcarriers.”
`
`Id. “If,” Petitioners speculate, “Frame 710 were expanded to show 12 subcarriers
`
`(the same number of subcarriers as Frame 700), there would be 14 pilot symbols in
`
`96 total symbols, resulting in more pilot symbols per unit time.” Id. However, this
`
`speculation is not disclosed in Li. The fact that Petitioners note that “nothing in the
`
`teachings of Li is limited to halving the number of subcarriers between the two
`
`communication systems” (id.) does not remedy this shortcoming. What is disclosed
`
`in Li’s Fig. 7 is two frames that have the same number of pilot symbols. Notably,
`
`Petitioners did not submit expert testimony from Dr. Roy, nor any portion of Li,
`
`indicating that a POSITA would have interpreted Li’s Fig. 7 in that manner. In
`
`summary, there is simply no support to credit Petitioners’ attorney argument that
`
`Fig. 7 should be interpreted to show more pilot symbols than it actually does.
`
`
`
`11
`
`
`
`Petitioners additionally argue that Li’s teaching (illustrated in Fig. 5)
`
`regarding shortening the symbol period implies that there will be more pilot symbols
`
`in a given time period. This is also explicitly contradicted by Li’s Fig. 7 which
`
`illustrates that—despite the shortened symbol period—the total number of pilot
`
`symbols (seven pilot symbols), as well as the number of pilot symbols during a time
`
`period T (two pilot symbols)—remains the same. The Board is correct in its finding
`
`that “Li does not disclose that the shortened period symbols are pilot symbols” and
`
`that “Li does not mention pilot symbols at all with respect to Figure 5.” Finally, Li
`
`does not disclose any example “showing that the second communication system
`
`would have twice the number of pilot symbols per unit time.” Paper 41 at 12. To
`
`the contrary, Li’s Fig. 5 does not reference pilot symbols at all, and Li’s figure 7,
`
`which is the only reference to pilot symbols, flatly contradicts Petitioners’ statement.
`
`The remainder of Petitioners’ argument is the same as that the Board has already
`
`considered and rejected in the Preliminary Guidance.
`
`V. CONCLUSION
`
`For the reasons set forth herein, Patent Owner asserts that the proposed
`
`amended claims meet all statutory requirements and respectfully requests that the
`
`Board allow proposed amended claim 44 and dependent amended claims 45-47, 49,
`
`and 50 in the event the corresponding original claims are found unpatentable.
`
`
`
`
`
`12
`
`
`
`Dated: May 2, 2022
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`/s/ Jay P. Kesan
`Jay P. Kesan, Reg. No. 37,488
`DIMUROGINSBERG, PC
`DGKEYIP GROUP
`1750 Tyson’s Blvd. Suite 1500
`Tysons Corner, VA 22102
`jkesan@dimuro.com
`Telephone: (703) 289-5118
`
`Alfonso Chan, Reg. No. 45,964
`SHORE CHAN LLP
`901 Main Street, Suite 3300
`Dallas, TX 75202
`achan@shorechan.com
`Telephone: (214) 593-9110
`
`Attorneys for Patent Owner
`UNM RAINFOREST INNOVATIONS
`
`
`
`13
`
`
`
`UPDATED LIST OF EXHIBITS
`
`Exhibit No.
`
`Descriptions
`
`2001
`
`2002
`
`2003
`
`2004
`
`2005
`
`2006
`
`2007
`
`2008
`
`2009
`
`2010
`
`2011
`
`2012
`
`2013
`
`2014
`
`2015
`
`2016
`
`2017
`
`
`
`Declaration of Dr. Branimir Vojcic
`
`’096 Provisional
`
`2018 Economic Impact Report
`
`’096 claim chart
`
`Dell litigation scheduling order
`
`Dell litigation amended scheduling order
`
`Dell litigation notice of withdrawn claims
`
`Asus litigation notice of withdrawn claims
`
`Apple litigation joint motion to dismiss with prejudice
`
`Apple litigation order of dismissal
`
`Asus ROG Phone 3 Home Page
`
`Asus litigation Qualcomm subpoena
`
`Supplemental Declaration of Dr. Branimir Vojcic
`
`Excerpts from 12-06-21 rough draft depo transcript of Sumit Roy,
`Ph.D.
`
`04/11/22 Declaration of Branimir Vojcic, D.SC., In Support of
`UNM Rainforest Innovations’ Revised Motion to Amend
`Declaration of Henning Schmidt in Support of Motion for
`Admission Pro Hac Vice
`Declaration of Cecil E. Key in Support of Motion for Admission
`Pro Hac Vice
`
`14
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6(e)(4) and 42.25(b), the undersigned certifies
`that on May 2, 2022, a complete copy of the Reply in Support of Patent Owner’s
`Revised Motion to Amend was filed electronically through the Patent Trial and
`Appeal Board’s PTABE2E System and provided, via electronic service, to the
`Petitioners by serving the correspondence address of record.
`
`Dated: May 2, 2022
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Jay P. Kesan
`Jay P. Kesan
`
`
`
`
`
`15
`
`
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
