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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
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`PATENT TRIAL AND APPEAL BOARD
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`HONEYWELL INTERNATIONAL, INC., TCT MOBILE (US) INC., TCT
`MOBILE (US) HOLDINGS INC., TCL COMMUNICATION TECHNOLOGY
`HOLDINGS LIMITED, TCT MOBILE INTERNATIONAL LIMITED, TCT
`MOBILE, INC., CRADLEPOINT, INC., SIERRA WIRELESS, INC., THALES
`DIS AIS DEUTSCHLAND GMBH
`
`Petitioner
`
`v.
`
`3G LICENSING S.A.
`Patent Owner
`
`
`
`_____________________
`CASE: IPR2021-00908
`U.S. PATENT NO. 7,319,718
`_____________________
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`PETITIONER’S REPLY
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`
`
`
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`
`
`
`Table of Contents
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`INTRODUCTION ......................................................................................... 1
`ARGUMENT ................................................................................................. 2
`A.
`The Near Co-extensiveness Of Petitioner’s Prior Art Renders Obvious
`The Challenged Claims Of The ’718 Patent ......................................... 2
`Patent Owner’s “Throughput” Arguments Fail To Overcome The
`Obviousness Of The Challenged Claims .............................................. 5
`1.
`The ’718 Patent Does Not Claim or Describe Any Throughput
`Advantages Commensurate In Scope With The Claimed
`Process ........................................................................................ 5
`Dr. Smith’s “throughput” analysis actually shows that the
`proposal in Philips46 provides better throughput using Dr.
`Smith’s own metrics. .................................................................. 9
`Nokia, In Combination With Philips46, Renders Obvious The Claims
`Challenged In Ground 2 ...................................................................... 12
`Philips46 Renders Obvious Claim 19 ................................................. 14
`D.
`The Board Should Not Ignore Any Arguments .................................. 15
`E.
`CONCLUSION ............................................................................................ 16
`
`
`B.
`
`C.
`
`I.
`II.
`
`III.
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`IPR2021-00908
`U.S. PATENT NO. 7,319,718
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`2.
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`i
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`IPR2021-00908
`U.S. PATENT NO. 7,319,718
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`
`List of Exhibits
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`Ex. 1001: U.S. Patent No. 7,319,718 to Ruh et al. (“the ’718 patent”)
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`Ex. 1002: Declaration of Dr. Paul Clark
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`Ex. 1003: File History of U.S. Patent Application No. 10/365,498 (issued as the
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`’718 patent)
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`Ex. 1004: TDoc R1-02-0046 submitted to 3GPP TSG RAN WG1#23 by Philips,
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`titled Coding of Channel Quality Information (“Philips46”)
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`Ex. 1005: R1-02-0654 submitted to 3GPP TSG RAN Meeting No. 25 titled
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`Basis sequences for HS-DPCCH Channel Quality information code
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`(“ChangeReq”)
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`Ex. 1006: Meeting Minutes from TSG-RAN Working Group 1 Meeting No. 23
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`beginning January 8, 2002 (Presented at Meeting No. 24, Feb. 18-22,
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`2002)
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`Ex. 1007: Meeting Minutes from TSG-RAN Working Group 1 Meeting No. 24
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`beginning February 18, 2002 (Presented at Meeting No. 25, April 9-
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`12, 2002)
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`Ex. 1008: Meeting Minutes from TSG-RAN Working Group 1 Meeting No. 25
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`beginning April 9, 2002 (Presented at Meeting No. 26, May 13, 2002)
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`ii
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`
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`Ex. 1009: Meeting Minutes from TSG-RAN Working Group 1 Meeting No. 26
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`IPR2021-00908
`U.S. PATENT NO. 7,319,718
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`beginning May 13, 2002 (Presented at Meeting No. 27, July 2-5,
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`2002)
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`Ex. 1010: TDoc R1-02-0354 submitted to 3GPP TSG RAN WG1#23 by Philips,
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`titled Coding of Channel Quality Information (rev1)
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`Ex. 1011: Curriculum Vitae of Dr. Paul Clark
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`Ex. 1012: Sisvel International S.A. et al v. Honeywell International, Inc., Case
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`No. 1:20-cv-00652, Dkt. No. 18 (Scheduling OrderF)
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`Ex. 1013: TDoc R1-01-1324
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`Ex. 1014: TS 25.212 v3.7.0
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`Ex. 1015: Declaration of Craig Bishop
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`Ex. 1016: TDoc R1-01-1204 submitted to TSG RAN WG1 No. 22 by Philips,
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`titled Performance Requirements for Channel Quality Signaling
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`Ex. 1017: Curriculum Vitae of Craig Bishop
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`Ex. 1018: Sisvel International S.A. et al v. Honeywell International, Inc., Case
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`No. 1:19-cv-01143, Dkt. No. 68 (Order Granting Stipulated Stay)
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`Ex. 1019: RESERVED
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`Ex. 1020: List of TSG RAN WG1 email subscribers in January 2002
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`Ex. 1021: TDoc R1-02-0019 submitted to TSG RAN WG1 #23 by Nokia, titled
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`Channel coding and error detection for uplink QI signaling (“Nokia”)
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`iii
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`
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`Ex. 1022: TDoc R1-01-1144 submitted to TSG RAN WG1 #22 by Ericsson,
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`IPR2021-00908
`U.S. PATENT NO. 7,319,718
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`titled Coding for channel-quality-related information
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`Ex. 1023: U.S. Patent No. 6,854,082 to Rhee
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`Ex. 1024: WO 96/38928 to Koch et al.
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`Ex. 1025: RESERVED
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`Ex. 1026: 3GPP Partnership Project Description
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`Ex. 1027: 3GPPE Working Procedures
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`Ex. 1028: GSM and UMTS: The Creation of Global Mobile Communication
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`Ex. 1029: 3GPP Frequently Asked Questions
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`Ex. 1030: RAN1 #25 Meeting Information
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`Ex. 1031: RAN1 #25 Meeting Invitation and Registration
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`Ex. 1032: Deposition Transcript of Dr. Michael Smith
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`iv
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`U.S. PATENT NO. 7,319,718
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`
`Table of Abbreviations
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`3GPP
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`CQI
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`DPCCH
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`DPCH
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`DPDCH
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`LSB
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`Third Generation Partnership Project
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`Channel Quality Information
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`Dedicated Physical Control Channel
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`Dedicated Physical Channel
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`Dedicated Physical Data Channel
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`Least Significant Bit
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`MSB or MOB Most Significant Bit
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`RAN
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`TDoc
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`TFCI
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`UE
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`Radio Access Network
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`Temporary Document
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`Transmit Format Combination Indicator
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`User Equipment
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`v
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`IPR2021-00908
`U.S. PATENT NO. 7,319,718
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`As set forth in the Petition (Paper 7), claims 1, 2 4–7, 9–13, and 15–23
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`(“Challenged Claims”) of the ’718 patent are unpatentable. The Board found that
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`the Petition demonstrated “a reasonable likelihood that [Petitioner] would prevail in
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`showing the unpatentability of at least one of the challenged claims.” Institution
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`Decision (“ID”) (Paper 23), at 2-3. Patent Owner’s Response (“POR”) (Paper 33)
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`fails to undermine the arguments in the Petition or the preliminary findings made in
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`the ID. For at least the reasons set forth herein, as well as those in the Petition,
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`claims 1, 2 4–7, 9–13, and 15–23 should be found unpatentable.
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`I.
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`INTRODUCTION
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`Patent Owner’s POR fails to address or undermine the fact that the industry
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`was widely understood to have been evaluating a number of different codes and
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`encoding methods as of the priority date of the ’718 patent. The POR treats the
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`Petition’s obviousness challenges as anticipatory references, attacking the various
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`references in their individual capacities rather than addressing the obviousness
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`theories articulated in the Petition. See POR, Sections III.A, III.C. The POR further
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`relies on unclaimed (and undisclosed) comparisons and calculations to support its
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`cursory non-obviousness arguments; ignoring the simplicity of the actual claim
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`language. See POR, Section III.B. The fact of the matter is, the applicant of the
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`’718 patent prosecuted broad claims relating to certain mathematical processes when
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`1
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`obtaining the ’718 patent and must live with the disclosures it provided during
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`prosecution.
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`Petitioner has never advanced a theory that the claimed basis sequences
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`appear in their claimed form in any relied upon prior art reference. Instead, the
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`Petition explains how the prior art of record renders obvious the claimed
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`mathematical encoding of prior art information bits using standard matrix
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`multiplication methods.
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`II. ARGUMENT
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`A. The Near Co-extensiveness Of Petitioner’s Prior Art Renders
`Obvious The Challenged Claims Of The ’718 Patent
`The ’718 patent claims various methods of coding channel quality information
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`(“CQI”), which are, in the context of the ’718 patent and the prior art, simply five
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`information bits: a binary representation of a number between one and thirty-one.
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`Ex. 1002, ¶¶39, 55; ID, 14-15. The five-bit binary representation of the CQI is
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`multiplied, using standard matrix multiplication, with five basis sequences that take
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`the form of a (20,5) matrix. Ex. 1002, ¶¶91-93; ID, 15-16. Each of the five basis
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`sequences is a one-by-twenty vector, and the combination of these vectors make up
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`a (20,5) matrix. ID, 17-20. For each of the aforementioned characteristics, both
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`Petitioner’s expert, Dr. Clark, and Patent Owner’s expert, Dr. Smith, agree that the
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`’718 Patent and Philips46 are identical. Ex. 1032, 63:19-64:8.
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`2
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`In fact, the only difference between Claim 1 and the Philips46 proposal is the
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`last two entries in the final row of the (20,5) matrix, indicated below.1 Ex. 1002,
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`¶¶97-98; Ex. 1032, 63:19-64:8.
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`
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`Ex. 1002, ¶109.
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`
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`Petitioner has never contended that Philips46 or Nokia2 disclose the exact
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`same 20,5 CQI code as is claimed in the ’718 patent. As explained in greater detail
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`1 Patent Owner does not present any arguments for any dependent claim,
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`addressing only independent claims 1, 6, and 19.
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`2 Patent Owner does not contest the prior art status of any of Petitioner’s prior art
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`references.
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`3
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`in the Petition, the claimed basis sequences are obvious in view of Philips46.
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`Petition at Section VII.C (obviousness in view of Philips46).
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`As the Petition explained, a POSITA would have understood that as of the
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`priority date of the ’718 patent there was extensive industry analysis underway
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`evaluating ways to accurately convey CQI representations by providing the requisite
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`level of protection for the various bits representing that CQI. Ex. 1001, 7:33–34;
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`Ex. 1004, 1; Ex. 1002, ¶¶96, 99, 114, 182. One example of this analysis is found in
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`Philips46. Ex. 1004.
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`Philips46 provides “significant extra protection” to the MSB, as the MSB is
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`represented an additional three times in the resulting codeword, and “a little more
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`robustness to the next most significant bit,” as the next MSB is represented one
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`additional time in the result. Ex. 1004, 1; Ex. 1002, ¶79. A POSITA reading
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`Philips46 would have understood that there is a benefit to providing the most
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`protection to the MSB, namely it “would decrease the aggregate magnitude of
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`transmission errors.” See Ex. 1002, ¶¶108, 91-93, 55-56; ID at 19-20. Indeed, a
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`POSITA reading Philips46 would have understood that the last four bits of the
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`resulting code word of Philips46 were the MSB repeated three times, and the second
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`MSB repeated once. Ex. 1002, ¶¶91-92.
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`The benefits of providing additional protection to the MSB was known, as
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`was the understanding that additional protection for the MSB is provided by
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`4
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`repeating the MSB in the codeword resulting from encoding the CQI information
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`with known basis sequences. Id.; Ex. 1023, 1:50-53; Ex. 1024, 10-11. Further, it
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`was known that adjusting the position of a “1” bit in an extended row of the known
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`(20,5) code basis sequences resulted in appending a corresponding input bit to the
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`resulting codeword. Id. For example, setting the 18th row to (0,0,0,0,1) would result
`
`in the MSB of the CQI appearing in the 18th position in the resulting code word. Ex.
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`1002, ¶¶90-93. Similarly, setting the 18th row to (0,0,0,1,0) would result in the
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`second MSB of the CQI appearing in the 18th position in the resulting code word.
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`Ex. 1002, ¶¶90-93.
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`Accordingly, and for those reasons set forth in the Petition, a POSITA would
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`have understood that the difference between Philips46 and the claimed invention is
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`simply an obvious option available to a POSITA looking to provide the most
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`protection to the MSB.
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`B.
`
`Patent Owner’s “Throughput” Arguments Fail To Overcome The
`Obviousness Of The Challenged Claims
`1.
`
`The ’718 Patent Does Not Claim or Describe Any
`Throughput Advantages Commensurate In Scope With The
`Claimed Process
`
`In response to the near identity of the Challenged Claims and the prior art, the
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`POR argues that the ’718 patent is not obvious because the “the ’718 patent is
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`concerned with maximizing the entire system throughput.” POR at 11 (emphasis
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`5
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`in original). However, the ’718 patent provides no evidence as to what this
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`throughput is, the extent of the difference (if any) of throughput between the ’718
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`patent’s basis sequence and the prior art, or linking of throughput to anything in the
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`claims. PO’s argument is not commensurate in scope with the claimed process.
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`As an initial matter, the claims of the ’718 patent do not mention any
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`throughput or tie any claim element to throughput. Ignoring this, PO and Dr. Smith
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`argue that an unclaimed, undescribed benefit somehow demonstrates the non-
`
`obviousness of the claims, in the face of what is plainly a result-effective variable.3
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`PO has failed to rebut, or otherwise address, the Petition’s argument that
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`optimizing the prior art’s (20,5) basis sequences is nothing more than modifying a
`
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`3 It was known that by adjusting the position of the “1” in the 16-20th rows of the
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`basis sequences of the code, the bit afforded the protection changes. Ex. 1002,
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`¶112. A POSITA would have known that the selection of where to place this “1”
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`directly impacts which bit of the CQI information bits receives protection. Ex.
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`1002, ¶¶111–112. In other words, a POSITA would have understood that
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`adjusting the position of the “1” would adjust which CQI bit appears as the 20th
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`bit of the codeword, as the known relationship between basis sequences and
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`coding equation make such results entirely predictable. Id.
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`6
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`result-effective variable to arrive at the optimal arrangement for providing the most
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`protection for the MSB. Petition, 37-38.
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`As the prior art linear algebra (which is identical to the mathematical
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`processes claimed and used in the ’718 patent) results in routine matrix
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`multiplication, a POSITA would have understood the positioning of the bits in the
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`basis sequences to be a result-effective variable. Ex. 1002, ¶¶111-115.
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`It was known to use (20,5) matrices of basis sequences to encode CQI,
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`ensuring accurate CQI was received. In re Aller, 220 F.2d 454, 456 (CCPA 1955)
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`(“where the general conditions of a claim are disclosed in the prior art, it is not
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`inventive to discover the optimum or workable ranges by routine experimentation.”).
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`All the ’718 patent represents is the selection of one collection of basis sequences
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`being used according to the exact same equations used before. See generally, Ex.
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`1004. The ’718 patent does not describe how its claimed matrix of basis sequences
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`provides any change in throughput. Instead, this is textbook obviousness, where the
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`’718 patent simply is a modification to a readily optimizable parameter, and is thus
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`not patentable under 35 U.S.C. § 103. Aller, 220 F.2d at 456.
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`Additionally, the specification provides no evidence that any throughput
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`differences between Philips46 and the claimed basis sequences matters. The
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`specification, at best, provides an apples-to-orange comparison of what the
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`specification refers to as “C1” and the claimed basis sequences. Ex. 1001, 11:45-
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`7
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`53, 11:60-63, 12:4-7. However, C1 is the basis sequences found in Table 2 of the
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`’718 patent, which is an un-filled in matrix, actually comprising only 16 rows of
`
`basis sequences.
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`
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`Ex. 1001, 7:1-14. Dr. Smith was unable to explain how the alleged comparisons
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`could have been calculated, given the Table 2 matrix is missing four rows of basis
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`sequences (thus resulting in only a 16 bit codeword, see Ex. 1002, ¶90). Ex. 1032,
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`52:1-13; see also Ex. 1032, 52:1-60:4. Even more egregious, Dr. Smith spent almost
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`five minutes looking for an answer as to what “version” of Table 2 was used for the
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`alleged “throughput” calculations he relied upon. See Ex. 1032, 57:2-3 (time stamps
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`ranging from 1:35 to 1:40). He was unable to explain how the comparisons were
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`calculated, confirming PO’s “throughput” argument is unpersuasive. Id.
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`Given this lack of clarity, little to no weight can be placed on the unclaimed,
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`undescribed, and undiscernible “throughput” argument that PO has put forth.
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`Instead, it is clear from the simple claims and the near identity of the prior art, that
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`the challenged claims of the ’718 patent are obvious.
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`8
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`Dr. Smith’s “throughput” analysis actually shows that the
`proposal in Philips46 provides better throughput using Dr.
`Smith’s own metrics.
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`2.
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`When attempting to defend his throughput opinions, Dr. Smith argued that his
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`appendix documents, which post-date the ’718 patent, support his throughput
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`argument. Even if these documents are proper for this type of argument—which
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`Petitioner contends they are not, as they post-date the ’718 patent and are extrinsic
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`to the patent itself—the evidence confirms the obviousness of the challenged claims.
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`PDF page 75 of Exhibit 2006 is a paper from LG Electronics, entitled
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`Comparison of CQI Coding methods. Ex. 2006, 754. Notably, this paper is dated
`
`after the priority date of the ’718 Patent (however, it further supports the variety of
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`analysis that was at work regarding existing basis sequences). Regardless, Dr. Smith
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`identified the throughput analysis at section 4.3 of this paper, beginning on page 79,
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`as support for his opinion that the claimed basis sequences are not obvious. Ex.
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`1032, 116:5-118:12. Dr. Smith confirmed that the basis sequences proposed by
`
`Philips46 are plotted as the light blue “X” and the LG proposal (which Dr. Smith
`
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`4 Patent Owner did not comply with 37 C.F.R. § 42.63(d)(2)(i), making citation to
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`the volumes appended to Dr. Smith’s second declaration (Ex. 2006) difficult.
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`Petitioner cites to the PDF page and attempts to clarify with as much detail as
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`possible for the record where the information is found.
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`9
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`contended is that claimed by the ’718 patent) is plotted as the purple asterisk (i.e.,
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`Case3). Ex. 1032, 119:1-14. However, the alleged “throughput” at certain points
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`on the x-axis, namely the six and nine errors per slot points, shows that the Philips46
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`proposal actually had better throughput:
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`
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` Expanded below
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`10
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` Expanded below
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`Philips46, light blue, has better (or equal) throughput than Case3 (purple)
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`Ex. 2006, PDF page 79.
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`11
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`Despite his strained reliance on this post-dated document, Dr. Smith was
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`unaware of what the error bounds were of the document, but insisted that Case3 was
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`“the best.” Ex. 1032, 120:10-18, 121:1-15. However, when asked to zoom in,
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`despite his use of a magnifying glass at other times during the deposition (Ex. 1032,
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`32:17-33:8), was unable to discern that the Philips46 throughput is actually better.
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`Ex. 1032, 121:16-124:10. When pushed, any alleged throughput difference was
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`simply “very close to each other.” Ex. 1032, 124:2-10.
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`
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`Even in the event that Dr. Smith is correct, and somehow “throughput” is
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`relevant to the challenged claims and his extrinsic evidence is appropriate to rely
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`upon, the very same extrinsic evidence actually confirms that the “throughput” of
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`the Philips46 proposal is at least as good if not better.
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`C. Nokia, In Combination With Philips46, Renders Obvious The
`Claims Challenged In Ground 2
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`Patent Owner only addresses Nokia, but fails to respond to Petitioner’s
`
`obviousness theories presented in the Petition. POR, 21-22. This is Patent Owner’s
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`only argument with regard to independent claim 6; all other arguments are waived.5
`
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`5 Claim 6 does not even claim the specific basis sequences of Claim 1. Compare
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`Ex. 1001, Claim 6 with Ex. 1001, Claim 13.
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`12
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`As set forth in the Petition, the combination of Philips46 and Nokia render
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`these claims obvious. Petition, Section VII.D. Dr. Smith did not address Claim 6,
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`let alone the invalidity theories presented in the Petition and supported by Dr. Clark.
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`As such, there is no contrary evidence that has been introduced into the record to
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`disturb the Board’s preliminary decision. ID at 20-26.
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`Regardless, the combination, as proposed, is based on the information on the
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`face of Philips46 itself; the face of Philips46 specifically references Nokia as “[1]”
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`in the “References” portion of the third page. Ex. 1004, 3; Ex. 1002 ¶185. A
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`POSITA would have naturally looked to Nokia for its teachings on the prior art
`
`regarding existing CQI encoding schemes. The combination is proper.
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`Nokia confirms that, when appending additional bits, they are added to the
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`end of the 16 coded bits from the bi-orthogonal (16,5) TFCI coding scheme. Ex.
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`1021, 1. In Nokia, the appended bits are the “four least reliable information bits.”
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`Ex. 1021, 1. However, as Philips46 notes, “it is also desirable that if possible the
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`most significant bits of the data are better protected than the least significant bits.”
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`Ex. 1004, 1. To accomplish this stated goal of providing better protection to the
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`most significant bits, a POSITA would have appended the MSB of data (a4) of the
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`information bits four times to the resulting codeword of Nokia to provide the most
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`protection possible to the MSB, instead of appending the four bits suggested by
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`13
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`Nokia. This results in the same 20 bit codeword that would result from the
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`modification to Philips46 that would have bene obvious to a POSITA.
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`This modification of Nokia, in view of Philips46, renders obvious claim 6.
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`PO does not make any arguments regarding dependent claims 7 or 9-13 which
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`depend from claim 6.
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`D.
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`Philips46 Renders Obvious Claim 19
`
`Independent claim 19 claims a specific manner of obtaining the (20,5) matrix
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`of basis sequences, namely “repeating a further respective basis sequence four more
`
`times.” Ex. 1001, claim 19. Claim 19 requires the last bit of each of the basis
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`sequences of the well-known (16,5) matrix of basis sequences is repeated four times
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`when extending the (16,5) matrix to the (20,5) matrix.
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`As an initial matter, and PO does not dispute this, Claim 19 does not require
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`any specific (20,5) matrix. Instead, it simply states that the claimed (20,5) matrix is
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`“obtained from a 16,5 TFCI code comprising five 16-bit basis sequences, by
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`extending each 16-bit basis sequence by repeating a further respective basis
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`sequence bit four times.” Ex. 1001, Cl. 19. Notably, it does not specify which basis
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`sequence bit is repeated four times. Philips46 itself states that “we propose to extend
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`the basis vectors of the (16,5) TFCI code as shown in Table 1.” Ex. 1004, 1. As
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`such, the extension of the existing TFCI code is exactly what Philips46 contemplated
`
`as the process to arrive at the (20,5) matrix. Philips46, which states “that if possible,
`
`14
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`
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`IPR2021-00908
`U.S. PATENT NO. 7,319,718
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`the most significant bits of the data are better protected than the least significant
`
`bits,” provides the motivation to arrive at the specific extension of dependent claim
`
`20. Ex. 1004, 1; Ex. 1002, ¶¶108, 159-169.
`
`PO provides no evidence to support its position and has no citation to any
`
`expert testimony. Accordingly, the unrebutted testimony of Dr. Clark, coupled with
`
`the positions articulated in the Petition, renders obvious Claims 19-23.6
`
`E.
`
`The Board Should Not Ignore Any Arguments
`
`The POR alleges that certain arguments must be ignored by the Board. This
`
`is incorrect. The Federal Circuit’s holding in Qualcomm Inc. v. Apple Inc., No.
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`2020-1558 (Fed. Cir. Feb. 1, 2022) focused on a Ground that was based on AAPA
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`and Majcherczak. Slip Op. at 6. Here, the Petition provides two Grounds of
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`unpatentability: Ground 1 (Philips46) and Ground 2 (Philips46 and Nokia).
`
`It is well understood from Qualcomm that “general knowledge and non-
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`Section 311(b) art [e.g., AAPA] may have a role to play in IPR proceedings.” Id. at
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`9. The Petition does not present a ground where AAPA forms “the basis” of the
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`invalidity theory, which is what Qualcomm excludes. Id. at 10. Indeed, the Federal
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`Circuit expressly rejected PO’s argument, stating “it does not follow that AAPA is
`
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`6 PO does not present any independent argument as it relates to dependent claims
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`20-23.
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`15
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`
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`IPR2021-00908
`U.S. PATENT NO. 7,319,718
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`categorically excluded from an inter partes review.” Id. at 13. In other words, “a
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`petitioner may rely on evidence beyond prior art documents in an inter partes review,
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`even if such evidence itself may not qualify as the “basis” for a ground set forth in a
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`petition.” Id. at 14. The Petition is clear as to what forms the basis of its challenges:
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`Philips46 and the combination of Philips46 and Nokia. Petition at 29.
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`III. CONCLUSION
`
`The Petition properly sets forth the basis for the unpatentability of the
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`Challenged Claims. The POR fails to undermine any of the arguments in the Petition
`
`or any of the conclusions drawn by the ID. The Challenged Claims should be found
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`unpatentable.
`
`Dated: May 2, 2022
`
`Respectfully submitted by,
`
`K&L GATES LLP,
`
`By:
`
`/Benjamin E. Weed/
`
`Benjamin E. Weed
`Reg. No. 65,939
`K&L GATES LLP
`70 W. Madison Street, Suite 3100
`Chicago, IL 60602
`benjamin.weed.PTAB@klgates.com
`T: (312) 781-7166
`F: (312) 827-8152
`
`Counsel for Petitioner
`
`16
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`
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`IPR2021-00908
`U.S. PATENT NO. 7,319,718
`
`
`Certificate of Service
`
`I hereby certify that on May 2, 2022, I caused a true and correct copy of the
`
`foregoing to be served on the following counsel for Patent Owner by electronic mail
`
`to the following email addresses:
`
`Timothy Devlin
`Stephanie Berger
`Andrew DeMarco
`DEVLIN LAW FIRM LLC
`Email: TD-PTAB@devlinlawfirm.com
`Email: nbenchell@devlinlawfirm.com
`Email: sberger@devlinlawfirm.com
`Email: ademarco@devlinlawfirm.com
`Email: dlflitparas@devlinlawfirm.com
`
`
`
`
`
`
`
`/Benjamin E. Weed/
`Benjamin E. Weed
`Reg. No. 65,939
`K&L Gates LLP
`70 W. Madison Street, Suite 3100
`Chicago, IL 60602
`benjamin.weed.PTAB@klgates.com
`T: (312) 781-7166
`F: (312) 827-8152
`
`
`
`
`
`
`By:
`
`17
`
`
`
`Certification of Word Count Under 37 C.F.R. § 42.24(d)
`
`IPR2021-00908
`U.S. PATENT NO. 7,319,718
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`
`The undersigned hereby certifies that the foregoing Petitioner’s Reply
`
`
`
`contains 3,063 words as specified by 37 C.F.R. § 42.24, according to the word count
`
`feature of the word-processing software used to prepare the Reply.
`
`
`
`
`
`
`
`/Benjamin E. Weed/
`Benjamin E. Weed
`Reg. No. 65,939
`K&L Gates LLP
`70 W. Madison Street, Suite 3100
`Chicago, IL 60602
`benjamin.weed.PTAB@klgates.com
`T: (312) 781-7166
`F: (312) 827-8152
`
`
`
`
`
`
`
`By:
`
`18
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`
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