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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`APPLE INC.,
`Petitioner
`
`v.
`SCRAMOGE TECHNOLOGY, LTD.,
`Patent Owner
`
`———————
`
`IPR2022-00118
`U.S. Patent No. 10,804,740
`
`
`
`
`PETITIONER’S SUR-REPLY
`TO PATENT OWNER’S REVISED MOTION TO AMEND
`
`
`
`
`
`
`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`TABLE OF CONTENTS
`
`PETITIONER’S EXHIBIT LIST ............................................................................ iii
`
`I.
`
`II.
`
`INTRODUCTION ........................................................................................... 1
`
`PATENT OWNER’S PROPOSED CLAIM CONSTRUCTIONS ARE
`INCONSISTENT AND UNDULY NARROW .............................................. 1
`
`A.
`
`B.
`
`The term “otherwise separate” cannot mean “otherwise not
`connected” based on the surrounding claim language and the
`Board’s Preliminary Guidance ............................................................. 2
`
`Patent Owner’s construction of “receiving space” is premised on a
`non-existent “horizontal boundary” and reads in an embodiment
`from the specification ........................................................................... 5
`
`II.
`
`KATO RENDERS OBVIOUS THE SUBSTITUTE CLAIMS AS
`WRITTEN ....................................................................................................... 8
`
`A. Kato renders obvious a “discrete” connecting unit that is
`“otherwise separate” from the coil ....................................................... 8
`
`B.
`
`Kato renders obvious a “receiving space” as recited in substitute
`claim 23 .............................................................................................. 10
`
`III. CONCLUSION ..............................................................................................12
`
`CERTIFICATE OF SERVICE ................................................................................14
`
`ii
`
`
`
`
`
`Ex.1001
`
`Ex.1002
`
`Ex.1003
`Ex.1004
`
`Ex.1005
`Ex.1006
`
`Ex.1007
`
`Ex.1008
`Ex.1009
`
`Ex.1010
`
`Ex.1011
`Ex.1012
`
`Ex.1013
`
`Ex.1014
`
`Ex.1015
`
`Ex.1016
`
`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`PETITIONER’S EXHIBIT LIST
`
`U.S. 10,804,740
`
`Prosecution History of U.S. 10,804,740
`
`Declaration of Dr. Joshua Phinney under 37 C.F.R. § 1.68
`Curriculum Vitae of Dr. Joshua Phinney
`
`U.S. Patent Application Publication 2009/0021212 (Hasegawa)
`U.S. Patent Application Publication 2007/0069961
`
`U.S. Patent Application Publication 2014/0306656 A1 Tabata et al
`
`U.S. Patent 8,384,263 B2 to Hiramatsu et al
`Reserved
`
`Reserved
`
`Reserved
`Reserved
`
`Reserved
`
`Reserved
`Scheduling Order, Scramoge Technology Limited v. Apple Inc.,
`WDTX-6-21-cv-00579 (filed Sept. 28, 2021)
`Plaintiff’s Preliminary Disclosure of Asserted Claims and
`Infringement Contentions to Apple Inc., Scramoge Technology
`Limited v. Apple Inc., WDTX-6-21-cv-00579 (served Sept. 7, 2021)
`
`Ex.1017
`
`U.S. Patent Publication No. 2008/0164840 to Kato et al.
`
`Ex.1018
`
`Supplemental Declaration of Dr. Joshua Phinney under 37 C.F.R.
`§ 1.68
`
`iii
`
`
`
`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`Ex.1019
`
`The Merriam-Webster Dictionary, Merriam-Webster, Inc., 1995.
`
`Ex.1020
`
`Ex.1021
`
`Ex.1022
`Ex.1023
`
`The Wayback Machine, capture of “Separate | Define Separate at
`Dictionary.com” on February 7, 2012,
`https://web.archive.org/web/20120207103735/http://dictionary.refe
`rence.com:80/browse/separate
`Second Supplemental Declaration of Dr. Joshua Phinney under 37
`C.F.R. § 1.68
`U.S. 9,178,369
`
`
`Suzuki – U.S. 8,421,574
`
`
`
`
`
`iv
`
`
`
`
`I.
`
`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`INTRODUCTION
`In response to the Board’s Preliminary Guidance, Patent Owner further
`
`amended the claims of the ’740 patent to add specific words and phrases. See
`
`Revised Motion (Paper 28). These amendments were not sufficient to overcome
`
`the Kato reference so Patent Owner now asks the Board to interpret its own added
`
`words as different words. Aside from the inherent unreasonableness of this request,
`
`Patent Owner’s desired interpretations are (i) inconsistent with the surrounding
`
`language, (ii) ignore the Board’s Preliminary Guidance, and (iii) import
`
`embodiments from the specification. Accordingly, Petitioner respectfully requests
`
`that the Board find each of substitute claims 21-23 unpatentable.
`
`II.
`
`PATENT OWNER’S PROPOSED CLAIM CONSTRUCTIONS ARE
`INCONSISTENT AND UNDULY NARROW
`In traditional claim construction disputes, the parties construe static claim
`
`language in a patent drafted years or decades ago. That is not the situation here.
`
`Under the Motion to Amend Pilot Program, Patent Owner has been given two
`
`opportunities to draft new claim language that clearly delineates the claimed
`
`invention over the prior art put forth by Petitioner. Patent Owner failed to do that.
`
`Now, it attempts to use claim construction as an end-around. For example, Patent
`
`Owner urges the Board to replace the words “otherwise separate” it added to the
`
`substitute claims with the words “otherwise not connected.” PO Reply (Paper 37),
`
`1
`
`
`
`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`
`3-4. Similarly, it wants to replace the words “receiving space” with “a
`
`discontinuity that reduces the thickness of a portion of the adhesive layer.” PO
`
`Reply, 8-9. Patent Owner had two chances to add this desired language into the
`
`claims, but it chose not to. Instead, it is asking for a third bite at the apple—and
`
`doing so with claim interpretations that ignore basic claim construction principles
`
`and the Board’s Preliminary Guidance.
`
`A. The term “otherwise separate” cannot mean “otherwise not
`connected” based on the surrounding claim language and the Board’s
`Preliminary Guidance
`Patent Owner asserts that the “otherwise separate” limitation of claims 21
`
`and 22 “requires that the connecting unit and the coil are not connected, except at
`
`the interconnection of the first-third and second-fourth terminal connections.” PO
`
`Reply, 4. This interpretation cannot be right for three reasons.
`
`First, “otherwise separate” cannot mean “otherwise not connected” because
`
`such a reading would be inconsistent with the other recitation of “separate” in
`
`substitute claims 21 and 22. See Digital Biometrics, Inc. v. Identix, Inc., 149 F.3d
`
`1335, 1345 (Fed. Cir. 1998) (“the same word appearing in the same claim should
`
`be interpreted consistently”). Specifically, both claims recite that the connecting
`
`unit is “connected to a circuit separate from the connecting unit”—that is, the
`
`connecting unit is both “connected” to the circuit and “separate.” Thus, in claims
`
`21 and 22, “separate” does not mean “not connected.” For this reason alone, the
`
`2
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`
`
`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`
`Board should reject Patent Owner’s construction that requires the term “separate”
`
`to encompass both “not connected” and “connected” in the same claim.
`
`Second, the Board’s Preliminary Guidance (“Guidance,” Paper 26)
`
`explained that the term “separate” in the context of the ’740 patent does not mean
`
`“not connected.” Guidance, 8. The Board’s explanation was in response to
`
`Petitioner’s argument in its first Opposition (“First Opposition,” Paper 23) that the
`
`original substitute claims 21 and 22 were indefinite because the connecting unit
`
`could not be both connected and separate. First Opposition, 9. Specifically, the
`
`Board explained in its Guidance that:
`
`The claimed interconnection of the terminals within the
`wireless power receiver does not alter that fact that the
`terminals of the separate and discrete connecting unit (the third
`and fourth terminals) remain separate from the terminals of the
`coil (the first and second terminals).
`
`Guidance, 8 (emphasis added).
`
`Patent Owner now seeks to adopt Petitioner’s previous understanding of
`
`“separate” that the Board declined to adopt. This is both procedurally improper and
`
`prejudicial because a revised motion to amend must be “responsive to issues raised
`
`in the preliminary guidance.” Scheduling Order, 5. Petitioner specifically relied
`
`upon the Board’s guidance that “separate” does not mean “not connected” when
`
`applying the prior art in the Opposition to Revised Motion to Amend (Paper 34).
`
`3
`
`
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`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`
`See Second Opposition, 12-14. Patent Owner cannot now seek a construction of
`
`“separate” that contradicts the Board’s preliminary guidance.
`
`Third, Patent Owner’s analysis of the term “otherwise separate” also
`
`contradicts its own claim analysis in the Patent Owner Response (Paper 17). In the
`
`current PO Reply, Patent Owner asserts that “the claimed ‘otherwise separate’
`
`requirement refers back to the preceding limitations relating to the first-third and
`
`second-forth interconnections in both claims 21-22, which means the coil and the
`
`connecting unit have no other connections.” PO Reply, 3. For support, Patent
`
`Owner cites to a dictionary that defines “otherwise” as “something to the
`
`contrary.” PO Reply, 3-4 (citing Ex.2024). In other words, Patent Owner’s theory
`
`is that because the claim earlier recites that portions of the coil and connecting unit
`
`are “connected,” then the adjective “otherwise” before “separate” means that they
`
`are otherwise “not connected.” PO Reply, 4. The fatal flaw in this analysis is that
`
`Patent Owner previously argued in its Response that the term “connected” in the
`
`’740 patent claims means “separate.” Response, 12 (“Accordingly, the ’740
`
`Patent claims’ use of the term ‘connected’ further confirms that the ‘connecting
`
`unit’ is separate and distinct from the ‘coil.’”). How can it both be true that
`
`“otherwise separate” means “otherwise not connected” and “connected” means
`
`“separate”? Specifically, when substitute claim 21 recites the connection terminals
`
`of the coil and connecting unit as “connected,” then by Patent Owner’s earlier
`
`4
`
`
`
`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`
`logic, the coil and connecting unit are already separate. The connecting unit cannot
`
`be “otherwise” separate from the coil if it is already separate. See Ex.2024
`
`(defining “otherwise” as “something to the contrary”).
`
`Patent Owner’s shifting and contradictory interpretations of its claims should
`
`be rejected. The Board should instead hold Patent Owner to the specific words that
`
`it chose for the substitute claims in its Revised Motion: “otherwise separate.” And
`
`to ensure consistency with the surrounding claim language and to give weight to
`
`the Board’s preliminary guidance, “otherwise separate” cannot encompass a
`
`reading that requires the connecting unit to be “otherwise not connected” to the
`
`coil. When “otherwise separate” is given any other meaning, the Kato reference
`
`meets substitute claims 21 and 22.
`
`Patent Owner’s construction of “receiving space” is premised on a
`B.
`non-existent “horizontal boundary” and reads in an embodiment from
`the specification
`Patent Owner asks the Board to construe “receiving space” as “a
`
`discontinuity that reduces the thickness of a portion of the adhesive layer.” PO
`
`Reply, 8. To support its position, Patent Owner repeatedly refers to a “horizontal
`
`boundary” that is allegedly recited in substitute claim 23:
`
`Claim 23 establishes a frame of reference for the terms ‘upper’
`and ‘lower’ by reciting that the receiving space is defined by a
`horizontal boundary. The term “horizontal boundary” refers
`to the periphery of the receiving space in a horizontal plane.
`
`5
`
`
`
`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`
`PO Reply, 8-9 (emphasis added); see also id. at 9 (“the horizontal boundary does
`
`not extend beyond the periphery of the adhesive layer”). Substitute claim 23,
`
`however, does not recite a “horizontal boundary.” Instead, it recites “wherein the
`
`third connection terminal is connected to the first connection terminal horizontally
`
`within a boundary defining the receiving space.” By the express words of the
`
`claim, the term “horizontally” refers to where the third and first connections
`
`terminal are connected and does not define the receiving space.
`
`This is important because Patent Owner’s interpretation of “receiving space”
`
`is predicated upon this non-existent “horizontal boundary.” From the “horizontal
`
`boundary,” Patent Owner creates a “horizontal reference frame” that it applies to
`
`the recited surfaces of the “adhesive layer.” PO Reply, 9 (“The ‘upper surface’ and
`
`‘lower surface’ relative to this horizontal reference frame therefore refer to the
`
`planer surfaces of the adhesive layer separated vertically from each other which
`
`form the thickness of the adhesive layer.”). In turn, Patent Owner references these
`
`“upper and the lower horizontal surfaces of the adhesive layer” in its statement of
`
`what the “receiving space” limitation “requires”:
`
`[T]he “receiving space” limitation of claim 23 requires: (1) a
`discontinuity that reduces the thickness of a portion of the
`adhesive layer, and that (2) the discontinuity extends between
`upper and the lower horizontal surfaces of the adhesive layer (3)
`continually from the inside of the coil to the outside of the coil.
`
`6
`
`
`
`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`
`PO Reply, 10. The Board should reject Patent Owner’s construction of “receiving
`
`space” out of hand because it is based upon a term—“horizontal boundary”—that
`
`is not recited or even suggested in substitute claim 23.
`
`To the extent Patent Owner’s analysis points to specific embodiments in the
`
`’740 patent specification (i.e., Fig. 26), those embodiments may not be read into
`
`the claims. See Phillips v. AWH Corp., 415 F.3d 1303, 1320 (Fed. Cir. 2005).
`
`Where, as here, the claim language is not limiting, Patent Owner may not
`
`“confin[e] the claims to those embodiments.” Id. at 1323. Fig. 26 may illustrate a
`
`discontinuity that reduces the thickness of a portion of the adhesive layer, but the
`
`substitute claim simply recites a “receiving space.” Patent Owner had the option to
`
`narrow the term “receiving space” in its Revised Motion to Amend—but elected
`
`not to. Instead, it is now asking the Board to read the particular “discontinuity” of
`
`Fig. 26 into the claim language.
`
`The only requirement Patent Owner added in its Revised Motion with
`
`respect to the “receiving space” is that it “extends between the upper surface and
`
`lower surface of the adhesive layer continually from inside the coil to outside the
`
`coil.” This limitation does not limit the shape or form of the receiving space, nor
`
`does it limit the receiving space to an empty space—and thus this limitation is not
`
`responsive to the Board’s Preliminary Guidance. See Guidance, 16-17 (“Further
`
`the claims do not recite the shape of the receiving space, and do not recite what
`
`7
`
`
`
`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`
`may be received in the receiving space. For example, claim 23 does not recite that
`
`the receiving space receives only the connecting unit, or that the shape of the
`
`receiving space be related to the shape of the connecting unit, or that the
`
`connecting unit be insertable into the receiving space, or that the receiving space
`
`be an empty space.”).
`
`The Board should therefore reject Patent Owner’s re-interpretation of its
`
`own substitute claim 23 because its interpretation (i) is premised on a non-recited
`
`“horizontal boundary,” (ii) improperly reads in an embodiment from the
`
`specification, and (iii) fails to limit the “receiving space” in any of the ways
`
`outlined in the Guidance.
`
`II. KATO RENDERS OBVIOUS THE SUBSTITUTE CLAIMS AS
`WRITTEN
`
`Each of Patent Owner’s arguments for why Kato does not render the
`
`substitute claims obvious hinges on its improper claim constructions. When the
`
`claims are interpreted based on the actual words selected by Patent Owner in its
`
`Revised Motion, Kato renders them obvious.
`
`A. Kato renders obvious a “discrete” connecting unit that is
`“otherwise separate” from the coil
`
`As explained in the Second Opposition at [21.5], Kato’s “flexible printed-
`
`circuit board 90” discloses the recited “discrete connecting unit.” Second
`
`Opposition, 7-10. Fig. 18 illustrates Kato’s circuit board 90 at a manufacturing step
`
`8
`
`
`
`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`
`in which the coil has not yet been adhered or “stuck” to the board. Ex.1017,
`
`[0034]. Figs. 17 and 19 illustrate the completed secondary power-transmission coil
`
`21WD, in which the coil 40 “is stuck on the surface of the flexible printed-circuit
`
`board 90 though an adhesion sheet 42.” Ex. 1017, [0081]. The PO Reply asserts
`
`that “once the coil (40) is ‘stuck’ to the circuit board (30), the circuit board (30)
`
`ceases to be ‘discrete’ and ‘otherwise separate’ from the coil, as required by
`
`claims 21-22.” PO Reply, 5.
`
`First, with respect to the term “discrete,” even after the coil is stuck to the
`
`circuit board as shown in Figs. 17 and 19, the circuit board remains a discrete
`
`element according to Patent Owner’s own dictionary definition. See Ex.2023, 1
`
`(defining “discrete” as “constituting a separate entity : individually distinct”).
`
`When describing its completed device in association with Figs. 17 and 19, Kato
`
`consistently refers to the circuit board as a distinct element from the coil. See, e.g.,
`
`Ex.1017, [0033] (“FIG. 17 is a schematic front view of a noncontact power-
`
`transmission coil having a flexible printed-circuit board with the shape
`
`substantially fit to a planar coil formed of a spirally-wound electric wire.”).
`
`Second, when the term “otherwise separate” is not restricted to Patent
`
`Owner’s improper interpretation of “otherwise not connected,” Kato’s circuit
`
`board 90 is otherwise separate from the coil 40. As explained in association with
`
`[21.8], Kato’s Fig. 18 that illustrates the circuit board 90 is a separate element and
`
`9
`
`
`
`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`
`separable from the other elements of Kato’s device, including the planar coil.
`
`Ex.1017, [0034]; Second Opposition, 12-14. In other words, because the circuit
`
`board 90 is an entirely separate element from the coil, it at least encompasses the
`
`“otherwise separate” claim language. Adhering the coil 40 to the circuit board 90
`
`may connect them, but they are still otherwise separate. This comports with the
`
`Board’s guidance that connected elements may still be separate. This also
`
`comports with Patent Owner’s own analysis in its Patent Owner Response that
`
`connected elements are separate. And, as explained in the Second Opposition, Kato
`
`additionally shows that when the coil contact portions 35 and 36 are connected to
`
`the circuit board 90, the remainder of the coil is otherwise physically separate from
`
`the circuit board because the adhesive layer 42 separates them. Second Opposition,
`
`14.
`
`Accordingly, when “otherwise separate” is given any meaning other than
`
`Patent Owner’s improper meaning of “otherwise not connected,” Kato meets
`
`substitute claims 21 and 22.
`
`B. Kato renders obvious a “receiving space” as recited in substitute
`claim 23
`
`When substitute claim 23 is not unduly narrowed by Patent Owner’s
`
`interpretation of “receiving space,” Kato renders it obvious. As explained and
`
`illustrated in the Second Opposition, Kato teaches that its adhesive layer 42
`
`10
`
`
`
`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`
`includes a receiving space for the various elements of the coil 40. Second
`
`Opposition, 16-19. For example, the adhesive layer 42 includes an inner gap for
`
`coil contact portion 36, an outer gap for the coil contact portion 35, and a space
`
`where the coil is received and “stuck” on, as illustrated in Fig. 19 below. Id.
`
`Outer
`portion of
`
`Ex.1017, Fig. 19 (annotated); Ex.1021, 26.
`
`
`With respect to element [23.1], Patent Owner argues that “the adhesive sheet
`
`42 does not have a discontinuity that reduces the thickness of the adhesive sheet
`
`42, to accommodate the thickness of the circuit board 35 [sic].” PO Reply, 11. Not
`
`only does this argument improperly require the “receiving space” to be “a
`
`discontinuity that reduces the thickness,” but it further requires the receiving space
`
`to “accommodate the thickness of the circuit board.” This is facially incorrect
`
`because independent substitute claim 22 simply recites that the connecting unit is
`
`“disposed corresponding to the receiving space”—there no requirement for the
`
`connecting unit to be insertable into the receiving space. See Guidance, 16. For the
`
`11
`
`
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`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`
`same reason, Patent Owner is wrong that Kato fails because the “‘inner gap’ does
`
`not extend between the top and bottom planer surfaces of the adhesive sheet … so
`
`it can accommodate the circuit board.” PO Reply, 11.
`
`Patent Owner further argues that the “‘outer gap’ is outside of the periphery
`
`of the adhesive layer and is therefore not within the receiving space defined by the
`
`horizontal boundary, per claim 23.” PO Reply, 12. As explained above, claim 23
`
`does not actually recite a “horizontal boundary” nor require the receiving space to
`
`be defined by one. This argument further fails because Kato plainly states that
`
`outer gap corresponds to where material is “not formed” to accommodate coil
`
`contact portion 35. Second Opposition, 17 (citing Ex.1017, [0082]). Finally, Patent
`
`Owner argues that “the alleged ‘receiving space where the coil is received and
`
`‘stuck’ on’ does not extend between upper and lower horizontal surfaces, as
`
`required by claim 23.” PO Reply, 12. Claim 23, however, does not require the
`
`“upper” and “lower” surfaces of the adhesive layer to be “horizontal surfaces”—
`
`and thus this argument should be rejected.
`
`III. CONCLUSION
`For the foregoing reasons, Patent Owner’s arguments in its Reply should be
`
`rejected, and the substitute claims should be found unpatentable.
`
`12
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`
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`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`Respectfully submitted,
`
`
`
`/Scott T. Jarratt/
`Scott T. Jarratt
`Lead Counsel for Petitioner
`Registration No. 70,297
`
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`
`
`Dated: March 3, 2023
`HAYNES AND BOONE, LLP
`2323 Victory Avenue, Suite 700
`Dallas, Texas 75219
`
`
`Customer No. 27683
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`13
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`IPR2022-00118 / U.S. Patent 10,804,740
`Petitioner’s Sur-Reply to Patent Owner’s Revised Motion to Amend
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that, in accordance with 37 C.F.R. § 42.6(e),
`
`service was made on Patent Owner as detailed below.
`
` Persons served
`
`Date of service March 3, 2023
`Manner of service Electronic Mail: bcooper@bc-lawgroup.com;
`jpetrsoric@bc-lawgroup.com; ap@lombardip.com;
`ehuang@lombardip.com; Scramoge_Counsel@b-clg.com
`
`Documents served Petitioner’s Sur-Reply to Patent Owner’s Revised Motion
`to Amend
`Brett Cooper
`John Petrsoric
`BC Law Group, P.C.
`200 Madison Avenue, 24th Floor
`New York, NY 10016
`
`Antonio Papageorgiou
`Eric Huang
`Lombard & Geliebter LLP
`230 Park Avenue, 4th Floor West
`New York, NY 10169
`
`
`
`
`
`
`
`
`/Scott T. Jarratt/
`Scott T. Jarratt
`Lead Counsel for Petitioner
`Registration No. 70,297
`
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`14
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