`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`
`APPLE INC.,
`Petitioner
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner
`____________
`
`IPR2022-00118
`Patent 10,804,740
`____________
`
`
`PATENT OWNER’S SUR-REPLY
`
`
`
`
`
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`
`
`Table of Contents
`Introduction ....................................................................................................... 1
`I.
`II. The Challenged Claims Require Separate Structures for the “First and
`Second Connection Terminals” and the “Connecting Unit” ............................. 2
`III. The Petition Relies on the Same Structure in Hasegawa for the “First
`and Second Connection Terminals” and the “Connecting Unit” ...................... 8
`IV. The Petition Fails to Identify a “Wiring Layer” in Hasegawa ........................ 12
`V. Conclusion ...................................................................................................... 12
`
`
`
`i
`
`
`
`
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`Table of Authorities
`
`Cases
`Am. Piledriving Equip., Inc. v. Geoquip, Inc.,
`637 F.3d 1324 (Fed. Cir. 2011) ............................................................................. 3
`
`Apple Inc. v. Kilbourne,
`IPR2019-00233, Paper 40 (P.T.A.B. March 25, 2020) ......................................... 4
`
`Becton, Dickinson & Co. v. Tyco Healthcare Grp., LP,
`616 F.3d 1249 (Fed. Cir. 2010) ................................................................. 2, 3, 4, 6
`
`Comcast Cable Comm’ns, LLC v Promptu Sys. Corp.,
`838 F. App’x 551 (Fed. Cir. Jan. 4, 2021) ............................................................ 3
`
`Gaus v. Conair Corp.,
`363 F.3d 1284 (Fed. Cir. 2004) ......................................................................... 2, 5
`
`Kyocera Senco Indus. Tools Inc. v. Int’l Trade Comm’n,
`22 F.4th 1369 (Fed. Cir. 2022) .............................................................................. 2
`
`Regents of Univ. of Minn. v. AGA Med. Corp.,
`717 F.3d 929 (Fed. Cir. 2013) ........................................................................... 3, 4
`
`Unwired Planet, LLC v. Apple Inc.,
`829 F.3d 1353 (Fed. Cir. 2016) ............................................................................. 5
`
`
`
`
`
`
`ii
`
`
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`2002
`
`2003
`
`2004
`
`PATENT OWNER’S EXHIBIT LIST
`Exhibit No. Description
`2001
`Notice of IPR Petitions, Scramoge Technology Ltd. v. Apple Inc.,
`Case No. 6:21-cv-00579-ADA, Dkt. No. 35 (W.D. Tex. Nov. 11,
`2021)
`Scheduling Order, Scramoge Technology Ltd. v. Apple Inc., Case
`No. 6:21-cv-00579-ADA, Dkt. No. 33 (W.D. Tex. Sept. 28, 2021)
`Law360 Article: West Texas Judge Says He Can Move Faster
`Than PTAB
`Text Order Denying Motion to Stay Pending IPR, Solas OLED
`Ltd. v. Google, Inc., Case No. 6:19-cv-00515-ADA (W.D. Tex.
`June 23, 2020)
`Order Denying Motion to Stay Pending IPR, Multimedia Content
`Management LLC v. DISH Network L.L.C., Case No. 6:18-cv-
`00207-ADA, Dkt. No. 73 (W.D. Tex. May 30, 2019)
`
`2005
`
`2006
`
`2007
`
`2008
`
`2009
`
`2010
`
`Scheduling Order, Correct Transmission LLC v. Adtran, Inc.,
`Case No. 6:20-cv-00669-ADA, Dkt. No. 34 (W.D. Tex. Dec. 10,
`2020)
`
`Scheduling Order, Maxell Ltd. v. Amperex Technology Ltd., Case
`No. 6:21-cv-00347-ADA, Dkt. No. 37 (W.D. Tex. Nov. 8, 2021)
`
`Standing Order Governing Proceedings in Patent Cases, Judge
`Alan D. Albright
`
`Claim Construction Order, Solas OLED Ltd. v. Apple Inc., Case
`No. 6:19-cv-00537-ADA, Dkt. No. 61 (W.D. Tex. Aug. 30, 2020)
`
`Plaintiff Scramoge Technology Ltd.’s Amended Preliminary
`Disclosure of Asserted Claims and Infringement Contentions to
`Apple Inc. in Scramoge Technology Ltd. v. Apple Inc., Case No.
`6:21-cv-00579-ADA (W.D. Tex.)
`
`iii
`
`
`
`
`
`
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`2011
`
`2012
`
`2013
`
`2014
`
`2015
`
`2016
`
`2017
`
`2018
`
`2019
`
`2020
`
`2021
`
`2022
`
`Defendant Apple Inc.’s First Amended Preliminary Invalidity
`Contentions in Scramoge Technology Ltd. v. Apple Inc., Case No.
`6:21-cv-00579-ADA (W.D. Tex.)
`
`Android Authority article: LG Innotek’s Latest wireless charger is
`Three times faster
`
`Scheduling Order, Scramoge Technology Ltd. v. Google LLC,
`Case No. 6:21-cv-00616-ADA, Dkt. No. 28 (W.D. Tex. Nov. 15,
`2021)
`
`Defendants’ Joint Reply Claim Construction Brief in Scramoge
`Technology Ltd. v. Apple Inc., Case No. 6:21-cv-00579-ADA
`(W.D. Tex.)
`
`Scheduling Order, Scramoge Technology Ltd. v. Apple Inc., Case
`No. 6:21-cv-00579-ADA, Dkt. No. 56 (W.D. Tex. Feb. 11, 2022)
`
`Specification Filed in U.S. Pat. Appl. No. 13/663,012, now U.S.
`Patent No. 9,806,565
`
`Specification Filed in U.S. Pat. Appl. No. 16/264,360, now U.S.
`Patent No. 10,804,740
`
`July 27, 2022 Deposition Transcript of Joshua Phinney, Ph.D.
`
`Excerpts of Prosecution History of U.S. Patent Application Serial
`No. 13/663,012
`
`U.S. Patent Publication No. 2008/0197597
`
`U.S. Patent No. 10,270,291
`
`Declaration of John Petrsoric in Support of Motion for Admission
`Pro Hac Vice
`
`iv
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`I.
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`Introduction
`Patent Owner Scramoge Technology Ltd. (“Patent Owner”) submits this sur-
`
`reply in response to Petitioner’s Reply to Patent Owner’s Response (“Reply”) with
`
`respect to the inter partes review of U.S. Patent No. 10,804,740 (“the ’740 Patent”).
`
`The challenged claims of the ’740 patent require “first and second connection
`
`terminals” that are distinct from the “connecting unit” and its constituent “third and
`
`fourth connection terminals.” Petitioner asserts the opposite, that “[n]othing in the
`
`claims or the intrinsic record requires that the first and second terminals be ‘separate
`
`and distinct’ from the connecting unit.” Reply at 12. Petitioner is not correct and,
`
`consequently, Petitioner’s reliance on Hasegawa’s
`
`lead
`
`lines 35 and 34
`
`simultaneously being able to satisfy both the “first and second connection terminals”
`
`and the “connecting unit” cannot be correct.
`
`The black-letter law is clear that, where a claim list elements separately, those
`
`elements are presumed to be distinct. In its response to the Petition, Patent Owner
`
`presented analysis of the claim language and the intrinsic record that confirms that
`
`presumption. In Reply, Petitioner does not identify either claim language or
`
`language in the written description or prosecution history that refutes that
`
`presumption or the analysis presented by Patent Owner. Petitioner’s assertion that
`
`the pointing to the same structure in Hasegawa, namely lead lines 34 and 35, to
`
`satisfy both the “first and second connection terminals” and the “connecting unit,”
`
`
`
`1
`
`
`
`
`as required by the challenged claims of the ’740 patent, cannot be correct.
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`Consequently, Petitioner’s arguments of unpatentability based on Hasegawa cannot
`
`be correct. The Board should find the challenged claims not unpatentable.
`
`II. The Challenged Claims Require Separate Structures for the “First and
`Second Connection Terminals” and the “Connecting Unit”
`The challenged claims separately recite a “first connection terminal,” a
`
`“second connection terminal,” and a “connecting unit.” The claims further recite
`
`that the “connecting unit comprises” a “third connection terminal connected to the
`
`first connection terminal” and a “fourth connection terminal connected to the second
`
`connection terminal.” Ex. 1001, 19:61-20:9, 21:5-20.
`
`As set forth in the Patent Owner’s Response, “[w]here a claim lists elements
`
`separately, ‘the clear implication of the claim language’ is that those elements are
`
`‘distinct component[s]’ of the patented invention.” Becton, Dickinson & Co. v. Tyco
`
`Healthcare Grp., LP, 616 F.3d 1249, 1254 (Fed. Cir. 2010) (quoting Gaus v. Conair
`
`Corp., 363 F.3d 1284, 1288 (Fed. Cir. 2004)). The implication or presumption that
`
`claim elements listed separately are distinct components may be overcome if there
`
`is claim language or language in the written description that rebuts the implication
`
`or presumption. See, e.g., Kyocera Senco Indus. Tools Inc. v. Int’l Trade Comm’n,
`
`22 F.4th 1369, 1382 (Fed. Cir. 2022).
`
`
`
`2
`
`
`
`Petitioner cannot overcome the presumption here. With respect to claim
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`
`
`language, the challenged claims separately recite (i) “a first connection terminal”;
`
`(ii) “a second connection terminal”; (iii) “a connecting unit”; and (iv) the sub-
`
`components of the “connecting unit,” including “a third connection terminal,” “a
`
`fourth connection terminal” and “a wiring layer.” Claim 6 is exemplary:
`
`6. A wireless power receiver, comprising:
`an adhesive layer comprising a receiving space;
`a coil on the adhesive layer;
`a first connection terminal connected to an outer end of the coil;
`a second connection terminal connected to an inner end of the coil; and
`a connecting unit overlapping the receiving space in a vertical direction
`perpendicular to the adhesive layer,
`wherein the connecting unit comprises:
`a third connection terminal connected to the first connection
`terminal;
`a fourth connection terminal connected to the second connection
`terminal; and
`a wiring layer connected to the third connection terminal and the
`fourth terminal.
`
`
`The challenged claims are inherently structured such that “adhesive layer,”
`
`“coil,” “first connection terminal,” “second connection terminal,” and “connecting
`
`unit” are separate from one another. Furthermore, the claims explicitly require that
`
`the “first connection terminal” be “connected to” the “third connection terminal”
`
`sub-component of the “connecting unit” and that the “second connection terminal”
`
`be “connected to” the “fourth connection terminal” sub-component of the
`
`“connecting unit.” When the separate claim elements are identified as being
`
`
`
`3
`
`
`
`
`“connected” or “coupled,” the claims require that the elements be structurally
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`separate. See Becton, Dickinson, 616 F.3d at 1254-56; Regents of Univ. of Minn. v.
`
`AGA Med. Corp., 717 F.3d 929, 935-36 (Fed. Cir. 2013); Comcast Cable Comm’ns,
`
`LLC v Promptu Sys. Corp., 838 F. App’x 551, 552-53 (Fed. Cir. Jan. 4, 2021)
`
`(nonprecedential); Am. Piledriving Equip., Inc. v. Geoquip, Inc., 637 F.3d 1324,
`
`1332-34 (Fed. Cir. 2011).
`
`Petitioner counters that “[n]othing in the claim language itself or in the
`
`intrinsic record requires that the first and second connection terminals be separate
`
`from the connecting unit” and that, absent guidance to the contrary, only different
`
`meanings should be afforded to the claim limitations in question. Reply 8-9.
`
`Petitioner concludes that “[n]othing in the intrinsic record precludes” the “first and
`
`second connection terminals” from being “part of the connecting unit.” To reach
`
`this conclusion, Petitioner ignores the significant “guidance to the contrary”
`
`presented in Patent Owner’s Response.
`
`Petitioner cites to three cases, Linear Tech. Corp. v. Int'l Trade Comm’n,
`
`Intell. Prop. Dev., Inc. v. UA-Columbia Cablevision of Westchester, Inc., and Apple
`
`Inc. v. Kilbourne, to support Petitioner’s proposition that the “first and second
`
`connection terminals” may overlap with the “connecting unit.” However, none of
`
`these cases counters the weight of evidence presented by Patent Owner supporting
`
`the presumption that the “first connection terminal” and “second connection
`
`
`
`4
`
`
`
`
`terminal” are structurally distinct from the “connecting unit” and its “third
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`connection
`
`terminal” and “fourth connection
`
`terminal.”
`
` Patent Owner
`
`acknowledges that each of these cases is consistent with Patent Owner’s cited
`
`Federal Circuit law that the “implication” or “presumption” with respect to
`
`separately-recited claim elements may be overcome by analysis of the claims
`
`themselves, and the intrinsic record. Apple, in particular, is further instructive. The
`
`Board in Apple contrasted certain Federal Circuit cases, including Becton, Dickinson
`
`and Regents of Univ. of Minn., where separately-recited claim elements “must be
`
`separate and distinct structures” with other Federal Circuit cases where multiple
`
`claim elements may correspond to a single structure. Apple Inc., IPR2019-00233,
`
`Paper 40, at 32-35. The Board analyzed the claim language as whole, looking for
`
`“inter-relationship” between the claim limitations in the form of limiting language
`
`such as “connected to” or “affixed to,” as well as by examining the specification. Id.
`
`at 32-38. In doing so, the Board recognized that an analysis of the claim language
`
`as a whole and the intrinsic record was required to confirm or refute the
`
`implication/presumption.
`
`In the present circumstances, the analysis presented in Patent Owner’s
`
`Response confirms that the “first and second connection terminals” are separate and
`
`distinct from the “connecting unit” and its constituent “third and fourth connection
`
`terminals,” including through consideration of the claim language as a whole, the
`
`
`
`5
`
`
`
`
`specification, and the prosecution history. The claims separately recite the “first
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`connection terminals,” the “second connection terminals,” and the “connecting
`
`unit.” The claims further recite limiting language that the “third connection terminal
`
`[of the connecting unit is] connected to the first connection terminal” and the “fourth
`
`connection terminal [of the connecting unit is] connected to the second connection
`
`terminal.” Further, as demonstrated in the Patent Owner’s Response, the
`
`specification reinforces that the “first connection terminal” and “second connection
`
`terminal” are structurally distinct from the “connecting unit” and its “third
`
`connection terminal” and “fourth connection terminal.” Patent Owner’s Response
`
`at 12-16, 20-22. The prosecution history reinforces the same. Patent Owner’s
`
`Response at 16-19, 23. Petitioner does not present contrary evidence on any point,
`
`merely concluding that “nothing in the claim language or the intrinsic record
`
`suggests that one part of the connecting unit cannot connect to another part of the
`
`connecting unit.” Reply at 9-10.
`
`The claims recite a “first connection terminal” and a “second connection
`
`terminal” separately from a “connecting unit” but recite a “third connection
`
`terminal,” a “fourth connection terminal,” and a “wiring layer” as subcomponents of
`
`the “connecting unit.” The inherent structure of the claims do not allow for the “first
`
`connection terminal” and the “second connection terminal” to be part of the
`
`“connecting unit.” Petitioner is incorrect that “the patentee chose to draft the claims
`
`
`
`6
`
`
`
`
`broadly by not specifying any relationship between the first and second connection
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`terminals and connecting unit.” Reply at 11 (emphasis in original).
`
`The specification similarly supports the “first connection terminal” and the
`
`“second connection terminal” as separate from the “connecting unit.” See Patent
`
`Owner’s Response at 12-16. Petitioner provides no specification citation to the
`
`contrary. Rather than offer evidence to Patent Owner’s analysis of the specification,
`
`Petitioner simply argues that it is not enough that all of the embodiments contain a
`
`particular limitation, citing to Unwired Planet, LLC v. Apple Inc. , 829 F.3d 1353,
`
`1359 (Fed. Cir. 2016). In doing so, Petitioner is suggesting that the written
`
`description support for separate and distinct claim elements must rise to the level of
`
`specification disclaimer. But that is not the law. See Gaus, 363 F.3d at 1288
`
`(“Nothing in the descriptions of those two components suggests that their structures
`
`or functions overlap. To the contrary, the specification plainly describes the two
`
`components as separate.”).
`
`With respect to Patent Owner’s analysis of the prosecution history, Petitioner
`
`contends that the statement in the prosecution of a parent application to the ’740
`
`patent does not amount to disclaimer. Reply at 5-7. While Patent Owner does not
`
`concede that the cited statements do not amount to disavowal of claim scope, the
`
`scope of disavowal, while potentially determinative, is not necessary to the analysis
`
`of whether the “first connection terminal” and the “second connection terminal” are
`
`
`
`7
`
`
`
`
`separate from the “connecting unit” in the challenged claims. At the very least,
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`Patent Owner’s citations to the prosecution history are consistent with the claim
`
`language and specification in that the applicants of the ’740 patent considered the
`
`“first connection terminal” and the “second connection terminal” to be separate and
`
`distinct from the “connecting unit.” Again, Petitioner provides no evidence from the
`
`prosecution history to the contrary.
`
`Finally, Petitioner suggests that, because “separate” means “not connected,”
`
`Patent Owner’s proposed construction is non-sensical in light of the explicit claim
`
`requirement that the “first and second connection terminals” be connected to the
`
`“third and fourth connection terminals.” Reply at 10. This is a fanciful assertion
`
`given that many cases readily recognize that “separate” structures can be
`
`“connected” to each other. See, e.g., Becton, Dickinson, 616 F.3d at 1253-56
`
`(holding that the claimed spring means and hinged arm are “separate structures” that
`
`are “connected to” each other).
`
`III. The Petition Relies on the Same Structure in Hasegawa for the “First
`and Second Connection Terminals” and the “Connecting Unit”
`With respect to the “first connection terminal” limitations, [6.3] and [16.3].
`
`Petitioner asserts that these limitations are met by the outer end lead line 35 of
`
`Hasegawa. See, e.g., Petition at 26; see also Ex. 1003, ¶ 53 (“the outer end lead line
`
`
`
`8
`
`
`
`
`35 is a connection terminal because it electrically connects the outer end of the coil
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`to the connection pad 103.”) (emphasis in original).
`
`
`
`Petition at 25, Ex. 1003 at 31.
`
`With respect to the “second connection terminal” limitations, [6.4] and [16.4].
`
`Petitioner asserts that these limitations are met by the inner end lead line 34 of
`
`Hasegawa. See, e.g., Petition at 28; see also Ex. 1003, ¶ 63 (“the inner end lead line
`
`34 is a connection terminal because it electrically connects the inner end of the coil
`
`to the connection pad 103.”)(emphasis in original).
`
`
`
`9
`
`
`
`
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`
`
`Petition at 27, Ex. 1003 at 37.
`
`With respect to the “connecting unit” limitations, [6.5] and [16.5], Petitioner
`
`asserts that these limitations are met by the collection of lead lines 34 and 35, coil
`
`connection pads 103, and the wiring pattern of substrate 100 of Hasegawa. See, e.g.,
`
`Petition at 32, 41; see also Ex. 1003, ¶¶ 73, 94 (“Hasegawa’s teaching of electrically
`
`connecting the planar coil to the portable telephone with lead lines, coil connection
`
`pads, and a wiring layer (together a connecting unit), where the lead line 34 is
`
`disposed within the slit in the adhesive spacer member and thus overlaps it in every
`
`direction renders obvious “a connecting unit …”)(emphasis in original).
`
`
`
`10
`
`
`
`
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`
`
`Petition at 30, Ex. 1003 at 40.
`
`Petitioner identifies the same components in Hasegawa, lead lines 34 and 35
`
`to satisfy both the “first connection terminal”/“second connection terminal” and the
`
`“connecting unit” limitations in the claims of the ’740 Patent. Because the claims
`
`of the ’740 patent require separate and distinct components/structures for the
`
`claimed “first connection terminal” and “second connection terminal” and the
`
`claimed “connecting unit,” it cannot be the case that lead line 35 satisfies both the
`
`claimed “first connection terminal” and the claimed “connecting unit,” and lead line
`
`34 satisfies both the claimed “second connection terminal” and the claimed
`
`“connecting unit.”
`
`
`
`11
`
`
`
`
`IV. The Petition Fails to Identify a “Wiring Layer” in Hasegawa
`Petitioner’s reply still fails to the relationship of connection pads 103 to the
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`wiring pattern of the substrate. Petitioner argues that the Petition and accompanying
`
`declaration of Dr. Phinney explain how “Figure 4 of Hasegawa specifically depicts
`
`that the wiring pattern connects to the connection pads 103.” Reply at 15-16 (citing
`
`Petition at 30-32, 35-37 and Ex. 1003 at ¶¶ 67, 80-83). At most, the cited passages
`
`contain a version of Figure 4 of Hasegawa annotated in purple to indicate a “Wiring
`
`pattern.” There is no further explanation of how this satisfies the “wiring layer”
`
`requirement of the claims.
`
`V. Conclusion
`
`Because Petitioner does not identify separate components in Hasegawa to
`
`satisfy each of the “first connection terminal”/“second connection terminal” and the
`
`“connecting unit” limitations, as required by the claims of the ’740 Patent, Petitioner
`
`has not satisfied its burden to show that Hasegawa meets all of the limitations of the
`
`claims of the ’740 Patent. In addition, Petitioner has failed to establish that
`
`Hasegawa discloses the required “wiring layer” of the “connecting unit.” Patent
`
`Owner respectfully requests that all challenged claims be found not unpatentable.
`
`
`
`
`
`
`
`12
`
`
`
`
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`Respectfully submitted,
`
`
`Dated: December 8, 2022
`
`
`
`
`
`/s/ Brett Cooper
`
`
`
`
`
`Brett Cooper (Reg. No. 55,085)
`Lead counsel for Patent Owner
`
`
`
`
`
`
`
`13
`
`
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`CERTIFICATION REGARDING WORD COUNT
`
`Pursuant to 37 C.F.R. § 42.24(d), Patent Owner certifies that there are 2,320
`
`
`
`
`
`words in the paper excluding the portions exempted under 37 C.F.R. § 42.24(a)(1).
`
`/s/ Brett Cooper
`
`
`
`Brett Cooper, Reg. No. 55,085
`Lead counsel for Patent Owner
`
`
`
`
`
`
`
`
`Dated: December 8, 2022
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`IPR2022-00118 (’740 Patent)
`Patent Owner’s Sur-Reply
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the above document was served on
`
`December 8, 2022, by filing this document through the Patent Trial and Appeal Case
`
`Tracking System as well as delivering a copy via electronic mail upon the following
`
`attorneys of record for the Petitioner:
`
`Scott T. Jarratt (Reg No. 70,297)
`scott.jarratt.ipr@haynesboone.com
`Andrew S. Ehmke (Reg No. 50,271)
`andy.ehmke.ipr@haynesboone.com
`Calmann J. Clements (Reg No. 66,910)
`calmann.clements.ipr@haynesboone.com
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`Phone: (972) 739-8663
`Fax: (214) 200-0853
`
`
`
`
`Date: December 8, 2022
`
`BC Law Group, P.C.
`200 Madison Avenue, 24th Floor
`New York, NY 10016
`(212) 951-0100
`
` /s/ Brett Cooper
`
`
`
`
`
`Brett Cooper
`Reg. No. 55,085
`Attorney for Patent Owner
`
`
`
`
`
`
`
`
`
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
