UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`EPIC GAMES, INC.,
`Petitioner,
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`v.
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` INGENIOSHARE, LLC,
` Patent Owner.
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`
`Case No. IPR2022-00294
`Patent No. 10,492,038
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`PATENT OWNER’S PRELIMINARY RESPONSE
`UNDER 37 C.F.R. § 42.107
`_____________________________________________________
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`
`
`Mail Stop PATENT BOARD, PTAB
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`

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`Table of Contents
`INTRODUCTION ............................................................................................... 1
`I.
`II. SUMMARY OF WHY THE PETITION SHOULD BE DENIED ..................... 1
`A. The Board Should Deny Institution Based On The Fintiv Factors .................. 1
`B. The Board Should Deny Institution Based On The Merits .............................. 1
`III. STATEMENT OF FACTS .................................................................................. 2
`A. The Parallel District Court Proceeding ............................................................ 2
`B. The Claims Of The ’038 Patent ........................................................................ 4
`C. The Specification Of The ’038 Patent .............................................................. 4
`D. Petitioner’s Definitions And Prior Art ............................................................. 5
`E. Diacakis (Exhibit 1007) .................................................................................... 5
`IV. THE PETITION SHOULD BE DENIED BASED ON FINTIV ......................... 7
`A. The first factor that the PTAB considers is whether the court granted a stay
`or whether evidence exists that one may be granted if an IPR is instituted ........... 7
`B. The second factor that the PTAB considers is the proximity of the court’s
`trial date to the projected statutory deadline for the PTAB’s final written decision
`8
`C. The third factor that the PTAB considers is the investment in the parallel
`proceeding by the court and the parties .................................................................. 9
`D. The fourth factor that the PTAB considers is the overlap between issues
`raised in the petition and in the parallel proceeding .............................................10
`E. The fifth factor that the PTAB considers is whether the petitioner and the
`defendant in the parallel proceeding are the same party ......................................11
`F. The sixth factor that PTAB considers is whether other circumstances impact
`the PTAB’s exercise of discretion, including the merits ......................................12
`V. THE PETITION SHOULD BE DENIED BASED ON THE MERITS ............12
`A. Claim Construction .........................................................................................12
`B. The Specification Of The ʼ038 Patent Teaches That The “Network-Based
`Portal” Is At The Server-Side Of A Network .......................................................12
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`i
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`C. Diacakis’s Client Terminal And User Interface Are Not A “Network-Based
`Portal” ...................................................................................................................14
`1. Diacakis’s Client Terminal Is Not A “Network-Based Portal” ..................14
`2. Diacakis’s User Interface Is Not A “Network-Based Portal” .....................16
`VI. CONCLUSION ..................................................................................................18
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`ii
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`PATENT OWNER’S EXHIBIT LIST
`
`Complaint
`
`Epic Games Inc.’s Preliminary Invalidity Contentions
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`Order Setting Markman Hearing
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`Epic Games Inc.’s Opening Claim Construction Brief
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`Exhibit 2001
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`Exhibit 2002
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`Exhibit 2003
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`Exhibit 2004
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`iii
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`I.
`
`INTRODUCTION
`Pursuant to 37 C.F.R. § 42.107, the Patent Owner, IngenioShare, LLC
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`hereby submits the following Preliminary Response to the Petition for inter partes
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`review of U.S. Patent No. 10,492,038, Case No. IPR2022-00294. For the reasons
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`explained herein, the Petition should be denied.
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`SUMMARY OF WHY THE PETITION SHOULD BE DENIED
`II.
`A. The Board Should Deny Institution Based On The Fintiv Factors
`The Petition should be denied because Petitioner has raised the same
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`invalidity arguments (and substantially more) in a parallel district court proceeding
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`and the district court’s trial date precedes the Board’s deadline for a final written
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`decision. Moreover, Petitioner is taking inconsistent positions before the district
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`court and the Board that the district court is better suited to address and resolve. As
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`a result, efficiency, fairness, and merits dictate the Board’s discretionary denial of
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`institution in view of the district court’s earlier comprehensive trial date.
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`The Board Should Deny Institution Based On The Merits
`B.
`All proposed grounds of unpatentability rest on a fundamental flaw. Each
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`challenged claim requires a “network-based portal.” Each ground of
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`unpatentability presented in the Petition relies on the assertion that this limitation is
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`satisfied in the cited art by client-side functionality. This is contrary to the use of
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`the term “network-based portal” in the specification, which universally indicates
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`that the network-based portal is at the server-side. Nothing in the ’038 Patent
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`suggests that the network-based portal is a user interface at a client device, as
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`Petitioner asserts. Because all Grounds in the Petition are based on Petitioner’s
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`erroneous construction of “network-based portal,” the asserted prior art-based
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`arguments fail and institution should be denied.
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`III. STATEMENT OF FACTS
`A. The Parallel District Court Proceeding
`The parallel district court proceeding involving the same parties was
`1.
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`filed on June 25, 2021. See Exhibit 2001, Complaint.
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`2.
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`A scheduling order was filed in the parallel district court proceeding
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`on October 6, 2021. See Exhibit 1011, Scheduling Order.
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`3.
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`The district court has not issued a stay in the parallel district court
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`proceeding.
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`4.
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`Petitioner has not sought a stay in the parallel district court
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`proceeding.
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`5.
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`Petitioner served voluminous invalidity contentions in the parallel
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`district court litigation on November 11, 2021. See Exhibit 2002, Epic Games
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`Inc.’s Preliminary Invalidity Contentions. Petitioner’s district court invalidity
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`contentions include all of the prior art cited and relied upon in the IPR Petition
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`including Diacakis (Exhibit 1007), Loveland (Exhibit 1008), and Takahashi
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`(Exhibit 1009). Id. at 18-29.
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`2
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`6.
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`In addition, Petitioner’s/Defendant’s invalidity contentions for the
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`ʼ038 Patent include many other prior art references and invalidity arguments that
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`are not presented in the Petition. Id. at 18-29.
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`7.
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`Petitioner has not stipulated in the parallel district court proceeding
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`that Petitioner will not attempt to invalidate the claims of the ’038 Patent based on
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`Petitioner’s invalidity arguments that are raised in its invalidity contentions even if
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`not raised before the Board. See Id. and Petition at 11-12. As a result,
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`Patentee/Plaintiff could be forced to defend the validity of the ’038 Patent twice,
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`once before the Board and a second time in the parallel district court proceeding.
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`8.
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`Claim construction briefing in the parallel district court proceeding
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`was completed on February 28, 2022. See Exhibit 1011 at 2.
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`9.
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`A claim construction hearing in the parallel district court proceeding
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`is scheduled for March 23, 2022. Exhibit 2003, Order Setting Markman Hearing.
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`10. Petitioner/Defendant Epic Games Inc. has taken inconsistent claim
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`construction positions before the Board and the district court with respect to at
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`least the following four claim terms of the ʼ038 Patent: (1) “network-based portal”
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`(2) “availability”; (3) “text [messaging / message]”; and (4) “indication.”
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`11. Before the Board, Petitioner has not specifically identified any claim
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`term of the ʼ038 Patent to be construed. See Petition at 26 (“Petitioner does not
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`believe that any terms need to be construed to assess the arguments presented
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`herein.”).
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`12. Before the district court, however, Petitioner contends that three of the
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`four claim terms stated above should not be given their plain and ordinary
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`meaning, but the claim term “network-based portal” should be given its plain and
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`ordinary meaning. See Exhibit 2004, Epic Games Inc.’s Opening Claim
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`Construction Brief.
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`13. The estimated trial date in the parallel district court proceeding is
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`April 3, 2023. Exhibit 1011, Scheduling Order at 4.
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`B. The Claims Of The ’038 Patent
`14. Every claim of the ’038 patent includes the claim term “network-
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`based portal.” See Exhibit 1001 at claims 1-70.
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`C. The Specification Of The ’038 Patent
`15. The specification of the ʼ038 Patent uses the term “network-based
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`portal” consistently as being at the server-side of a network. In particular, the
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`specification states:
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`As explained above, based on an embodiment, a message is
`electronically conveyed by a central network server, such as a web
`server based on [an] Internet protocol. A portal or gateway approach
`could provide general Internet access to one or more embodiments of
`the communication management systems so that users can configure
`the system behavior they desire. The portal or gateway can then
`4
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`facilitate download of a database or update thereto to a
`communication device, such as a phone.
`Exhibit 1001, ’038 patent at col. 7, lines 9-17 (emphasis added).
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`16. The specification of the ʼ038 Patent further provides that (i) “a mobile
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`phone” “calls a portal” (Id. Col. 6, lines 33-34) (emphasis added)); (ii) the “portal
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`accesses the personal communication device” (Id. Col. 6, lines 53-54); and (iii)
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`“[o]ne example of a networked server is a gateway computer for a wireless device,
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`such as a mobile telephone.” (Id. at Col. 16, lines 17-19 (emphasis added)).
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`D. Petitioner’s Definitions And Prior Art
`17. Contrary to the claims and specification of the ʼ038 Patent, Petitioner
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`defines a “network-based portal” as being satisfied by a client terminal that
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`contains “a web page or interface that connects clients to a network.” See Petition
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`at 34 (emphasis added).
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`18. Based on Petitioner’s characterization of a “network-based portal,”
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`Petitioner contends that the primary reference relied upon in the Petition, Diacakis
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`(Exhibit 1007) teaches a “network-based portal.”
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`E. Diacakis (Exhibit 1007)
`19. Ground I of the Petition is based solely on Diacakis (Exhibit 1007).
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`All of the other grounds are likewise based on Diacakis as the primary reference.
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`20. While discussing Diacakis, the Petition defines a “network-based
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`portal” as being satisfied by a client terminal containing “a web page or interface
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`that connects clients to a network.” See Petition at 34. Petitioner points to the
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`“client terminal 22” containing the “user interface 112.” See Petition at 33-34:
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`21. Petitioner contends “Diacakis’ client terminal 22” contains “a
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`network-based portal.” See Petition at 34-35 (emphasis added).
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`22. With respect to “client terminal 22,” Diacakis repeatedly teaches that
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`the client terminal is just that, a client terminal at the client side of a network; it is
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`not a server at the server side of a network. See Exhibit 1007 at [0024], [0030],
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`[0034], [0035], and [0056] (Diacakis).
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`23. With respect to the “user interface 112,” Diacakis teaches that the
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`“user interface 112” is provided by the client device and that it “may include, for
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`example, a GUI (Graphical User Interface) or a CUI (Character-based user
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`interface).” Id. at [0063].
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`IV. THE PETITION SHOULD BE DENIED BASED ON FINTIV
`The Board may deny institution of an IPR when the patent at issue is
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`litigated in a parallel proceeding. See NHK Spring Co., Ltd., v. Intri-plex Techs.,
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`Inc., IPR2018-00752, Paper 8 (PTAB Sept. 12, 2018) (precedential). The Board
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`has identified six factors it will consider for exercising its discretion to deny
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`institution of an IPR in view of a parallel proceeding. Apple Inc. v. Fintiv, Inc.,
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`IPR2020-00019, Paper 11 (PTAB Mar. 20, 2020) (precedential). All six factors
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`indicate that the Board should deny the Petition here.
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`A. The first factor that the PTAB considers is whether the court
`granted a stay or whether evidence exists that one may be granted
`if an IPR is instituted
`Fintiv factor 1 favors denial of institution. The district court has not issued a
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`stay in the parallel district court proceeding. And even though Petitioner stated that
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`“Petitioner will move the district court for a stay of the validity issues,” Petitioner
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`has not filed a motion to stay with the district court. See Petition at 8. Thus, the
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`district court litigation is proceeding.
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`Moreover, Petitioner/Defendant submitted voluminous invalidity
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`contentions in the parallel district court litigation. See Exhibit 2002, Epic Games
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`Inc.’s Preliminary Invalidity Contentions. Petitioner’s district court invalidity
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`contentions include all of the prior art cited and relied upon in the IPR Petition,
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`including Diacakis (Exhibit 1007), Loveland (Exhibit 1008), and Takahashi
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`(Exhibit 1009). Id. Petitioner, however, has not stipulated in the parallel district
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`court proceeding that Petitioner will not attempt to invalidate the claims of the ’038
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`Patent based on Petitioner’s invalidity arguments as raised in this IPR or that could
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`have been raised in this IPR. See Ex. 2002 at 18-29 and Petition at 12. As a result,
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`Patentee could be forced to defend the validity of the ’038 Patent before both the
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`Board and the district court.
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`B.
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`The second factor that the PTAB considers is the proximity of the
`court’s trial date to the projected statutory deadline for the
`PTAB’s final written decision
`Fintiv factor 2 favors denial of institution. The district court’s estimated trial
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`date is April 3, 2023. See Exhibit 1001, Scheduling Order at 4. If instituted, the
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`PTAB’s deadline for a final written decision is about two months later on June 13,
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`2023. Thus, the parties will be able to resolve all of Petitioner’s/Defendant’s
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`invalidity arguments before the district court faster than the parties will be able to
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`address a very small subset of Petitioner’s/Defendant’s invalidity arguments
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`regarding only Diacakis, Loveland, and Takahashi in this potential IPR proceeding.
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`C. The third factor that the PTAB considers is the investment in the
`parallel proceeding by the court and the parties
`Fintiv factor 3 favors denial of institution. In the district court proceeding the
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`parties already have exchanged infringement contentions and invalidity
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`contentions. The parties also have completed claim construction briefing with a
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`claim construction hearing scheduled for March 23, 2022, which will result in a
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`claim construction order soon thereafter. See Exhibit 2003, Order Setting Markman
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`Hearing.
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`Thus, if instituted, both the Board and the district court will engage in claim
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`construction, and given Petitioner’s/Defendant’s inconsistent positions with respect
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`to four claim terms of the ʼ038 Patent ((1) “network-based portal” (2)
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`“availability”; (3) “text [messaging / message]”; and (4) “indication”), it is possible
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`that a claim term could be construed inconsistently.
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`Moreover, even if the IPR is instituted, the district court will still have to
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`resolve Petitioner’s/Defendant’s voluminous and overlapping invalidity arguments
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`because the district court’s schedule precedes the IPR’s deadline for a final written
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`decision. As a result, there will be a substantial duplication of efforts with respect
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`to the alleged invalidity of the claims of the ʼ038 Patent.
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`9
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`D. The fourth factor that the PTAB considers is the overlap between
`issues raised in the petition and in the parallel proceeding
`Fintiv factor 4 favors denial of institution. Petitioner submitted voluminous
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`invalidity contentions in the district court litigation. See Exhibit 2002, Epic Games
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`Inc.’s Preliminary Invalidity Contentions. Petitioner’s district court invalidity
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`contentions utilize all of the prior art cited and relied upon in the IPR Petition,
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`including Diacakis (Exhibit 1007), Loveland (Exhibit 1008), and Takahashi
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`(Exhibit 1009). Id. Although the Petition talks of a stipulation that Petitioner may
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`one day make, no such stipulation has been filed. Petition at 11-12. Petitioner also
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`looks to the Board’s Sotera Wireless decision for support, but none is available
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`because here there is no stipulation, and importantly, no details as to the scope of
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`the non-existent stipulation.
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`The parallel district court proceeding has numerous active invalidity
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`challenges beyond those raised in the Petition. Again, Petitioner has not stipulated
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`in the district lawsuit that Petitioner will not attempt to invalidate the claims of the
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`’038 Patent based on Petitioner’s invalidity arguments that are raised before the
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`Board. See Petition at 12. As a result, there is substantial overlap between issues
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`raised in the Petition and those asserted in the parallel district court proceeding. As
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`such, Patentee would unfairly be forced to defend the patentability/validity of the
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`’038 Patent before the Board and in court on the same prior art and related
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`arguments.
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`10
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`Petitioner has also taken inconsistent claim construction positions before the
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`district court as compared to the IPR Petition. First, in the Petition, Petitioner has
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`not specifically presented a claim construction argument for any claim term. See
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`Petition at 26 (“Petitioner does not believe that any terms need to be construed to
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`assess the arguments presented herein.”). Before the district court, however,
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`Petitioner asserts that at least three claim terms ((1) “availability”; (2) “text
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`[messaging / message]”; and (3) “indication”) need to be construed by the district
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`court and should not be given their respective plain and ordinary meanings. See
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`Exhibit 2004, Epic Games Inc. Opening Claim Construction Brief.
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`Second, Petitioner/Defendant did not ask the district court to construe the
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`claim term “network-based portal,” which means that by default it should be given
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`its plain and ordinary meaning. But in the Petition, despite its representation that
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`no terms need to be construed, Petitioner advocates for an interpretation of
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`“network-based portal” that deviates from its ordinary meaning by asserting that it
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`constitutes a client terminal containing a web page or interface that connects
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`clients to a network. See Petition at 34.
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`E.
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`The fifth factor that the PTAB considers is whether the petitioner
`and the defendant in the parallel proceeding are the same party
`Fintiv factor 5 favors denial of institution. The parties are the same in the
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`district court litigation and in the IPR Petition.
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`11
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`F.
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`The sixth factor the PTAB considers is whether other
`circumstances impact the PTAB’s exercise of discretion, including
`the merits
`Fintiv factor 6 favors denial of institution. Patentee does not presently
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`believe that there is any other circumstance that would impact the Board’s exercise
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`of discretion. To the extent there is any merit in Petitioner’s arguments raised in
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`the Petition, Petitioner can present them in district court along with the remainder
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`of Petitioner’s invalidity arguments, resulting in a more efficient resolution of all
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`of Petitioner’s invalidity arguments.
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`As the Fintiv factors favor denial of the Petition, institution should be
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`denied.
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`V.
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`THE PETITION SHOULD BE DENIED BASED ON THE MERITS
`Claim Construction
`A.
`In an IPR claim terms are construed using the standard used in civil actions
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`under 35 U.S.C. § 282(b). See 37 C.F.R. § 42.100(b). The standard used in federal
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`courts is set forth in Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (en
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`banc). Under Phillips, the words of a claim are generally given their “ordinary and
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`customary meaning,” which is the meaning they would have to a person of
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`ordinary skill in the art at the time of the invention, in light of the specification and
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`prosecution history. See Phillips, 415 F.3d at 1312–13.
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`B.
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`The Specification Of The ʼ038 Patent Teaches That The
`“Network-Based Portal” Is At The Server-Side Of A
`Network
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`12
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`The specification of the ʼ038 Patent uses the term “network-based portal”
`
`consistently as being at the server-side of a network. In particular, the specification
`
`states:
`
`As explained above, based on an embodiment, a message is
`electronically conveyed by a central network server, such as a web
`server based on [an] Internet protocol. A portal or gateway approach
`could provide general Internet access to one or more embodiments of
`the communication management systems so that users can configure
`the system behavior they desire. The portal or gateway can then
`facilitate download of a database or update thereto to a
`communication device, such as a phone.
`
`Exhibit 1001, ’038 Patent at 7:9-17 (emphasis added).
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`The specification of the ʼ038 Patent further provides that (i) “a network-
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`based portal based on Internet protocol, receives a message” “from a person’s
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`wireless device” (Id. at Abstract) (emphasis added)); (ii) “a mobile phone” “calls a
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`portal” (Id. Col. 6, lines 33-34) (emphasis added)); (iii) the “portal accesses the
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`personal communication device” (Id. Col. 6, lines 53-55); and (iv) “[o]ne example
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`of a networked server is a gateway computer for a wireless device, such as a
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`mobile telephone.” (Id. at Col. 16, lines 17-19 (emphasis added)).
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`As shown above, the specification teaches that the claimed “network-based
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`portal” is at the server-side of a network. The specification does not teach that the
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`“network-based portal” is at the client-side of a network. The specification
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`13
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`certainly does not support the interpretation that a user interface at a client
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`constitutes a network-based portal.
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`C.
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`Diacakis’s Client Terminal And User Interface Are Not A
`“Network-Based Portal”
`Petitioner incorrectly contends that the claimed “network-based portal” is at
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`the client-side of a network. Indeed, Petitioner contends “Diacakis’ client terminal
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`22” contains “a network-based portal, which is a web page or interface that
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`connects clients to a network.” See Petition at 34 (emphasis added). Similarly,
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`Petitioner’s expert also testified that the claimed “network-based portal” acts as a
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`client, not as a server: “Diacakis further discloses an interface [which Petitioner
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`contends constitutes the claimed network-based portal] that users employ to
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`connect to the server through an Internet Protocol-based connection, which a
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`POSITA would have understood to be a ‘network-based portal.’” See Exhibit 1003
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`at ¶ 116 (Declaration of Almeroth) (emphasis added). Thus, Petitioner is pointing
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`to the client-side interface as allegedly satisfying the term “network-based portal”
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`in the challenged claims.
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`1.
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`Diacakis’s Client Terminal Is Not A “Network-Based
`Portal”
`The portion of Diacakis that the Petition relies upon merely teaches a user
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`interface provided by a client device at the client-side of a network, not at the
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`14
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`server-side of the network. As shown in Figure 1, the client terminal 22 is not at
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`the server side 12 of network 16:
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`Moreover, Diacakis repeatedly teaches that the client terminal, which Petitioner
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`asserts to satisfy the recited “network-based portal,” is just that, a client device at
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`the client-side of the network; it is not at the server-side of the network. Diacakis
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`makes clear that the client terminal communicates with a server. The client
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`terminal is not itself a server:
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`● “server 12 [is] in communication with a client terminal 22 via
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`network 16.” Exhibit 1007, Diacakis at [0024] (emphasis added);
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`● “server 12 detects a change … transmits the appropriate information
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`to the clients 22 ….” Id. at [0034] (emphasis added);
`15
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`● “the server 12 transmits the individual’s updated P&A information
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`to the clients 22 ….” Id. at [0035] (emphasis added);
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`● “server 12 may transmit the availability information to the
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`subscriber at the client terminal 22.” Id. at [0056] (emphasis added).
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`● “FIG. 8 is a screen shot of the information that may be displayed to
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`a subscriber at a client terminal 22 …. The contact information in the left
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`hand window may be updated based on availability information transmitted
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`from the identified individual’s P&A management server 12.” Id. at [0056]
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`(emphasis added).
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`● “The indicator module 110 may receive availability information
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`from one or more P&A management servers 12 and merge the contact
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`information for each individual into a single indicator, as described
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`previously in connection with FIG. 8, for display by the user interface 112.”
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`Id. at [0064].
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`Thus, Diacakis’s client terminal is not a “network-based portal” as the client
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`terminal is at the client-side of the network, not at the server-side.
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`Diacakis’s User Interface Is Not A “Network-Based Portal”
`2.
`Figure 9 of Diacakis further shows that the user interface 112 is provided by
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`the client terminal 22:
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`16
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`With respect to Figure 9, Diacakis states that “[a]s illustrated in FIG. 9, the client
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`terminal includes an indicator module 110 in communication with a user interface
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`112.” Id. at [0063]. User interface 112, which may include a GUI or CUI, displays
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`information at the client terminal 22. Id. at [0063]-[0064]. As a result, the user
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`interface 112 is at a client device; it is not at the server-side of the network. Thus,
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`Diacakis’s user interface is not a “network-based portal” as Petitioner improperly
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`asserts. See Petition at 33-34 (emphasis added).
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`As a result, neither Diacakis’s client terminal 22 or its user interface 112
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`teaches or renders obvious a “network-based portal” at the server-side of a
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`network. And since Diacakis does not teach or suggest the claimed “network-based
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`portal,” none of the challenged claims are rendered obvious by Diacakis. The
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`Board therefore should not institute trial on Ground I of the Petition. Since all
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`grounds of the Petition rely on Diacakis in the same manner, the Board should
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`likewise deny institution on those grounds.
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`17
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`VI. CONCLUSION
`For the above stated reasons, the Petition should be denied.
`
`Respectfully submitted this 13th day of March, 2022.
`
`/Stephen R. Risley/
`
`Stephen R. Risley
`Email: steverisley@kentrisley.com
`Telephone: (404) 585-2101
`Cortney S. Alexander
`Email: cortneyalexander@kentrisley.com
`Telephone: (404) 855-3867
`
`KENT & RISLEY LLC
`5755 North Point Parkway, Suite 57
`Alpharetta, GA 30022
`
`Attorneys for Patent Owner, IngenioShare,
`LLC
`
`18
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`

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`CERTIFICATE OF COMPLIANCE
`
`This Preliminary Response complies with the type-volume limitation as
`
`mandated in 37 C.F.R. § 42.24, totaling 3,447 words. Counsel has relied upon the
`
`word count feature provided by Microsoft Word.
`
`/Stephen R. Risley/
`Stephen R. Risley
`Registration No. 35,659
`
`19
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`

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`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing Patent Owner’s
`
`Preliminary Response Under 37 C.F.R. § 42.107 was served on March 13, 2022,
`
`via email on the following counsel for Petitioners:
`
`W. Todd Baker (No. 45,265)
`todd.baker@kirkland.com
`Postal and Hand-Delivery Address:
`KIRKLAND & ELLIS LLP
`1301 Pennsylvania Ave., N.W.
`Washington, D.C. 20004
`Telephone: (202) 389-5000
`Facsimile: (202) 389-5200
`
`Yimeng Dou (No. 69,770)
`yimeng.dou@kirkland.com
`Postal and Hand-Delivery Address:
`KIRKLAND & ELLIS LLP
`555 South Flower Street, Suite 3700
`Los Angeles, CA 90071
`Telephone: (213) 680-8400
`Facsimile: (213) 680-8500
`
`KENT & RISLEY LLC
`
`/Stephen R. Risley/
`
`20
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`