UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`APPLE INC.,
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`Petitioner,
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`v.
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`AIRE TECHNOLOGY LTD.,
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`Patent Owner.
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`____________
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`Case IPR2022-01137
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`Patent 8,581,70
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`
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`_______________________________________________________________
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`REPLY TO PETITIONER’S OPPOSITION TO PATENT
`OWNER’S MOTION TO AMEND
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`
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`i
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`
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`____________
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`APPLE INC.,
`
`Petitioner,
`
`v.
`
`AIRE TECHNOLOGY LTD.,
`
`Patent Owner.
`
`____________
`
`Case IPR2022-01137
`
`Patent 8,581,70
`
`
`
`_______________________________________________________________
`
`REPLY TO PETITIONER’S OPPOSITION TO PATENT
`OWNER’S MOTION TO AMEND
`
`
`
`i
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`Table of Contents
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`I.
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`INTRODUCTION ............................................................................................... 1
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`II. PROPOSED SUBSTITUTE CLAIMS DO NOT ADD NEW MATTER ......... 1
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`A. Claim Construction. .................................................................................... 1
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`B. Petitioner’s contentions that substitute claims 23-26 add new matter are
`without merit............................................................................................... 4
`i. Claims 23 and 25-26 ........................................................................ 4
`ii. Claim 24 ........................................................................................... 7
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`III. Proposed substitute claims comply with 35 U.S.C. § 112. ................................. 8
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` A. Substitute claims are not indefinite. ........................................................... 8
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`B. The claims are enabled. ................................................................................ 9
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`IV. PETITIONER HAS NOT SHOWN THAT PROPOSED CLAIMS 23-26 ARE
`UNPATENTABLE .............................................................................................. 9
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`A. Guthery in view of Nozawa, etc. do not disclose or render obvious the
`newly recited limitations of proposed substitute claims 23-26. ....................10
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`V. CONCLUSION .................................................................................................13
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`ii
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`
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`Cases
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`Table of Authorities
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`Amgen Inc. v. Sandoz Inc., 923 F.3d 1023 (Fed. Cir. 2019) ...................................... 4
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`Aqua Products Inc. v. Matal, 872 F.3d 1290 (Fed. Cir. 2017) (en banc) .................. 1
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`DePuy Spine, Inc. v. Medtronic Sofamor Danek, Inc., 469 F.3d 1005 (Fed. Cir.
`2006) ....................................................................................................................... 2
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`Eko Brands, LLC v. Adrian Rivera Maynez Enters., Inc., 946 F.3d 1367 (Fed. Cir.
`2020) ....................................................................................................................... 6
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`HTC Corp. v. IPCom GmbH & Co., KG, 667 F.3d 1270 (Fed. Cir. 2012) ............... 9
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`Hunting Titan, Inc. v. DynaEnergetics Europe GmbH., IPR2018-00600, Paper 67
`(PTAB July 6, 2020). .............................................................................................. 2
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`Ortho-McNeil Pharm. v. Mylan Lab’ys, Inc., 520 F.3d 1358 (Fed. Cir. 2008) ......... 6
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`ScriptPro LLC v. Innovation Assocs., Inc., 833 F.3d 1336 (Fed. Cir. 2016) ............ 6
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`Slimfold Mfg. Co. v. Kinkead Indus., Inc, 810 F.2d 1113 (Fed.Cir.1987) ................. 4
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`
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`Statutes/Rules
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`35 U.S.C. § 316(d)(3)................................................................................................. 5
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`35 U.S.C. § 316(e) ...................................................................................................10
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`37 C.F.R. § 42.121(d)(2) ............................................................................................ 1
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`37 C.F.R. § 42.24 .....................................................................................................10
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`37 C.F.R. § 42.6(a)(3) ..............................................................................................10
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`iii
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`IPR2022-01137
`Reply to Opp. to Motion to Amend
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`I.
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`INTRODUCTION
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`Petitioner argues that Patent Owner’s Motion to Amend (“Motion”) for the
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`conditional entry of substitute claims 23-26 should be denied because the substitute
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`claims 1) recite new matter in violation of 35 U.S.C. § 316(d)(3); and 2) are
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`unpatentable (i) under 35 U.S.C. § 112 because they are indefinite hybrid method-
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`apparatus claims and are not enabled, and (ii) under 35 U.S.C. § 103 because they
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`are obvious in view of the prior art combination presented in the petition, i.e., Pat.
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`No. 6,824,064 to Guthery et al. (“Guthery,” Ex.1005) in view of Japanese Patent
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`Application No. 2000-163539 to Nozawa et al. (“Nozawa”) (Ex. 1006)
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`(“Opposition”). Opp. (Paper 19), 1 (citing Paper 16). Petitioner, however, has
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`failed to satisfy its burden of showing that the substitute claims are unpatentable.
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`37 C.F.R. § 42.121(d)(2); Aqua Products Inc. v. Matal, 872 F.3d 1290, 1324 (Fed.
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`Cir. 2017) (en banc).
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`The Board should therefore grant Patent Owner’s contingent Motion to
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`Amend (Paper 16) and substitute proposed claims 23-26 for original claims 11, 12,
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`18, and 20, respectively, of U.S. Patent No. 8,581,706 (“the ’706 Patent”) if the
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`original claims are found unpatentable.
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`II.
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`PROPOSED SUBSTITUTE CLAIMS DO NOT ADD NEW MATTER
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`A. Claim Construction.
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`Claim construction is an essential step to any validity inquiry. MPEP
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`2163(II)(1) (citing In re Katz Interactive Call Processing Patent Litigation, 639
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`F.3d 1303, 1319-1320, 97 USPQ2d 1737, 1750 (Fed. Cir. 2011)). Claim terms are
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`construed with reference to the intrinsic evidence or record, i.e., by “examining the
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`1
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`IPR2022-01137
`Reply to Opp. to Motion to Amend
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`claim language itself, the written description, and the prosecution history, if in
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`evidence.” DePuy Spine, Inc. v. Medtronic Sofamor Danek, Inc., 469 F.3d 1005,
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`1014 (Fed. Cir. 2006) (citation omitted).
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`Petitioner made no attempt to construe any of the terms of the claims at
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`issue. Instead, Petitioner leaves it to the Board to resolve the meaning applied by
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`Petitioner from its arguments, which often offer more than one conflicting
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`interpretation. It is not the Board’s burden to examine the substitute claims at issue
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`when, as is the case here, Petitioner has fully participated in opposing the Motion
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`to Amend. See Hunting Titan, Inc. v. DynaEnergetics Europe GmbH., IPR2018-
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`00600, Paper 67 at 25-26 (PTAB July 6, 2020). Petitioner’s failure to construe any
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`elements of the substitute claims, particularly with respect to elements that are
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`necessary for an understanding of the scope of the claims, is fatal to its Opposition.
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`See Jiawei Tech. (HK) Ltd. v. Richmond, IPR2014-00937, Paper 24 at 7-8 (PTAB
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`Dec. 16, 2014).
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`Notwithstanding the forgoing, Petitioner’s apparent interpretations, as best
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`as can be understood from its arguments, find no support in the intrinsic evidence.
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`The Board should therefore interpret the substitute claims in accordance with the
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`Patent Owner’s proposed constructions that follow.
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` Substitute claim 23 recites a “contactlessly communicating portable data
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`carrier, comprising at least two applications stored thereon and a communication
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`device configured to control communication between a reading device and the at
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`least two applications.” Mot., App. A, 1. Claim 23 thereafter recites three wherein
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`clauses, which define the functionality of the claimed device.
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`2
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`IPR2022-01137
`Reply to Opp. to Motion to Amend
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`The first wherein clause requires the communication device to be “set up to
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`generate communication readiness signals to the reading device which in each
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`case indicate to the reading device a communication readiness for one of the
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`applications.” Id. That is, the communication device generates a readiness signal
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`for each of the plurality of the applications. See Ex. 1002, ¶¶ [0012] (288), [0035-
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`36] (295). The readiness signals include “an identification number assigned to the
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`corresponding communication-readiness application.” Mot., App. A, 1; Ex. 1002,
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`¶¶ [0021] (290), [0035-36] (295).
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`The second wherein clause recites that “after selection of one of the plurality
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`of applications, subsequent communication between the reading device and the
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`selected application takes place without requiring any further steps”. Mot., App.
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`A., 1. This clause defines the functionality of the communication device after
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`selection of one of the applications, which “implies that a ‘selection’ [of one of the
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`applications] has occurred.” Prelim. Guid., 7 (Paper 21). Once selected, the
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`communication device will then control communications between the reading
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`device and the selected application, such that subsequent communication, i.e., after
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`application selection, “takes place without requiring any further steps.” Mot., App.
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`A; Prelim. Guid., 9 (Paper 21); Ex. 1002, ¶¶ [0021] (290) (“When an application
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`has been selected for further communication…, said communication take place
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`subsequently without requiring any further steps.”) (emphasis added), [0035-36]
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`(295).
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`Claim 23 as written, therefore, recites the occurrence of the generation
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`function, followed by the selection function thereafter, which delineates the
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`3
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`IPR2022-01137
`Reply to Opp. to Motion to Amend
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`subsequent communications that occur “without requiring any further steps.” See
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`Amgen Inc. v. Sandoz Inc., 923 F.3d 1023, 1028 (Fed. Cir. 2019) (citation omitted).
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`This interpretation is consistent with the specification, which teaches that
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`communication readiness signals are generated at least initially in each instance
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`before application selection can occur, followed by further communication in
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`accordance with the proposed claims. Slimfold Mfg. Co. v. Kinkead Indus., Inc.,
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`810 F.2d 1113, 1116 (Fed.Cir.1987) (noting that claims are interpreted “in light of
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`the specification”; see Ex. 1002, Fig. 2 and 3 (ref. 400), ¶¶ [0021] (290), [0035-37]
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`(295-296).
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`The third wherein clause of claim 23 recites that “the communication device
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`is set up to store information … about which of the at least two applications last
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`communicated with a reading device.” Mot., App. A., 1. In other words,
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`information indicative of the most recent application selection is stored on the data
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`carrier. Ex. 1002, ¶ [0043] (297-98).
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`Claims 25-26 are directed to portable data carriers with elements similar to
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`those recited in claim 23 and claims 25-26 should therefore be construed similarly.
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`B. Petitioner’s contentions that substitute claims 23-26 add new matter
`are without merit.
`i. Claims 23 and 25-26
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`Petitioner contends that proposed “substitute claims 23 and 25-26 recite new
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`matter by claiming concepts that differ from those described in the specification”,
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`even though Petitioner admits that claim 23 and ¶ [0021] “both describe (i) an
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`application ‘selection’ and (ii) ‘communication’ that takes place “without requiring
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`4
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`IPR2022-01137
`Reply to Opp. to Motion to Amend
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`any further steps.” Opp., 2-3. Petitioner is mistaken. The substitute claims are fully
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`supported by the specification as filed, including at ¶¶ [0021] (290), [0035-37]
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`(295-296), [0043] (297-98) of the specification, as discussed above. Ex. 1002.
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`Petitioner faults Patent Owner for not reciting in the claims “when the
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`selection takes place or which element performs the selection or for what the
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`application is being selected.” Id. Petitioner further argues that the claim “offers no
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`guidance as to when the time period of ‘after selection’ begins.” Id. (citing
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`Ex.1002, 290) (emphasis original). Petitioner concludes thereafter that there “is no
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`indication in the specification that the inventor possessed the idea that all
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`subsequent communication after any selection of an application would take place
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`without requiring any further steps. Id., 3-4.
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`First, Petitioner makes no attempt to construe any of the proposed claims. As
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`such, Petitioner has failed to show that the proposed claims violate of 35 U.S.C. §
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`316(d)(3). Indeed, Petitioner has not provided any basis for its self-imposed
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`requirements for the claims to recite, when selection takes place, which element,
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`and for what the application is being selected. That is because there is no reason.
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`The claims when read in light of the specification, do not require Petitioner’s
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`limitations, as the Board has concluded in its Preliminary Guidance.
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`Second, the claims cannot be interpreted so broadly as to effectively read out
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`any temporal limitations therefrom. As discussed above, the substitute claims
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`imply that a selection is made, which marks the start of when subsequent
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`communications occur “without requiring any further steps…” Prelim. Guid., 7, 9;
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`Ex. 1002, ¶¶ [0021] (290), [0035-36] (295), supra. Additionally, the claims do not
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`5
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`IPR2022-01137
`Reply to Opp. to Motion to Amend
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`apply this requirement to “all subsequent communication after any selection of an
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`application”, as Petitioner suggests. Rather, the express language of the claims
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`provides that this requirement is applied to the selected application and to
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`subsequent communications with the selected application, consistent with the
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`written description. Mot., App. A, 1; Prelim. Guid., 9 (Paper 21). As such, the
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`claims are not “untethered” from the specification, as Petitioner contends. Opp., 4.
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`Petitioner argues further that the claims fail to recite “the assignment of the
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`session number is a step required for communication that happens after selection
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`of the application. Opp., 4-5. Petitioner is mistaken here as well.
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`First, the specification clearly indicates that the use of “session numbers” is
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`not the only process for establishing communications between the reader and the
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`selected applications. Ex. 1002, ¶ [0040] (296) (noting that “in the present example
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`the reading device does not communicate with a plurality of applications by
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`means of different session numbers …”) (emphasis added). Petitioner has not
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`explained why the claims should be interpreted to exclude this embodiment, as
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`Petitioner’s proposal would require. Ex. Opp., 8. Again, there is no reason.
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`Petitioner’s proposal violates several cannons of claim construction, including
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`because it excludes at least the embodiment at ¶ [0040] (296) and would render
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`original claim 4 superfluous. Eko Brands, LLC v. Adrian Rivera Maynez Enters.,
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`Inc., 946 F.3d 1367, 1380 (Fed. Cir. 2020) (citation omitted); Ortho-McNeil
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`Pharm. v. Mylan Lab’ys, Inc., 520 F.3d 1358, 1362 (Fed. Cir. 2008).
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`Second, “selecting an application” as claimed is not a single step, but rather
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`a function that may involve several steps that occur between the generation
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`6
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`IPR2022-01137
`Reply to Opp. to Motion to Amend
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`function and when the reader is engaged in further communications with the
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`application. See Fig. 2-3 (showing ref. 400 (Application Selection) between ref.
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`1010 and 2010). Specifically, the specification explains, at least for the
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`embodiment discussed at para. [0021], that selection is not completed until the
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`identification/session numbers are linked in the data carrier so “that the correct
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`application [can be addressed] upon communication” with the reader. Ex. 1002, ¶
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`[0021] (290); see also, id., ¶¶ [0013] (288), [0018] (289), [0034-370 (294-296).
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`The specification infers thereafter that this is “[w]hen the application has been
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`selected for further communication” and “then engaged in communication with the
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`reading device.” Id.; see Opp., 15 (Petition showing and describing application
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`selection as a process, not a single step.)
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`Accordingly, Petitioner has failed to show that claims 23 and 25-26 add new
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`matter.
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`ii. Claim 24
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`Proposed substitute claim 24 recites “wherein communication between the
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`reading device and the uniquely addressed application takes place subsequently
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`without requiring any further steps after the communication-readiness signals are
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`generated.” Mot., App. A, 1-2. Support for this proposed amendment may be
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`found at least at ¶¶ [0021], [0034-36], and [0043]. Ex. 1002, 290, 294-295, 297-98.
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`Specifically, the specification teaches the use of unique IDs to identify
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`applications and storing information on the data carrier “about which of the
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`application [] last communicated with the reading device.” Id., ¶¶ [0034] (294),
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`[0043] (297). Since selection is a prerequisite to communication, this information
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`7
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`IPR2022-01137
`Reply to Opp. to Motion to Amend
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`also indicates the last application selected for further communications. See Id. ¶¶
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`[0034-36]. The specification explains that this information may be used in
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`instances where the energy supplied to the data carrier is interrupted, for example,
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`to complete communications with the previously selected application. Id. ¶ [0043]
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`(297-98). That is, the communication device may later generate another
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`“communication readiness signal for that application … with which the reading
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`device [] actively communicated last, in order for example, to bring to an end a
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`data communication that was commenced by not completed.” Id. ¶ [0043] (298).
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`Because selection of this application has occurred previously and stored by the
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`communication device on the data carrier (before the second readiness signal), the
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`reader can communicate with the selected application subsequently “without
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`requiring any further steps after the [second] communication-readiness signals are
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`generated”, as recited in claim 24 and as taught in the specification. Ex. 1002, ¶
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`[0021] (290).
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`Petitioner argues here too that “session numbers” are required. Opp. at 8.
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`For the reasons discussed above, these numbers are not required. Accordingly,
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`Petitioner has failed to show that claim 24 adds new matter.
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`III.
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`Proposed substitute claims comply with 35 U.S.C. § 112.
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`A. Substitute claims are not indefinite.
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`Petitioner argues that substitute claims 23-26 are indefinite hybrid method-
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`apparatus claims. Opp., 11. Petitioner is incorrect. The claims at issue are all
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`directed to an apparatus, i.e., a data carrier that includes a communication device.
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`8
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`IPR2022-01137
`Reply to Opp. to Motion to Amend
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`Mot. App. A, 1-3. The wherein clause being added vis-à-vis the substitute claims
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`further defines the functionality of the data carrier and more specifically the
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`communication device, which is tasked to control communication between the
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`reading device and the at least two applications. Id. The added wherein clause
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`therefore ties this added functionality to the apparatus. These claims are unlike
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`those in IPXL and Rembrandt, as the Board concluded in its Preliminary Guidance.
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`Prelim. Guid., 14-16 (citation omitted). Accordingly, Petitioner has failed to show
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`that the claims are indefinite.
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`B. The claims are enabled.
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`Petitioner argues that substitute claims 23-26 are not enabled because they
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`recite a broad negative limitation, which makes it impossible for communications
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`to occur without any further steps, such as formatting and transmitting data. Opp.,
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`11-12. Petitioner is incorrect here as well. When read in light of the specification,
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`the added wherein clause does not preclude the steps necessary for the subsequent
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`communications to occur. Ex. 1002, ¶¶ [0021] (290), [0034-36] (294-295); Prelim.
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`Guid., 16-17. Petitioner’s argument is based on the incorrect assumption for this
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`contention that communication is a single step, which there is no basis for in the
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`record. The claimed communication is a function controlled by the communication
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`device, which may involve several steps and sub-steps, including receiving,
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`transmitting, formatting, etc. Id. Accordingly, Petitioner has failed to show that the
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`claims are not enabled.
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`IV.
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`PETITIONER HAS NOT SHOWN THAT PROPOSED CLAIMS 23-26
`ARE UNPATENTABLE
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`9
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`IPR2022-01137
`Reply to Opp. to Motion to Amend
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`A. Guthery in view of Nozawa, etc. do not disclose or render obvious
`the newly recited limitations of proposed substitute claims 23-26.
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`Petitioner contends that the wherein clauses added in claims 23-26 are taught
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`or rendered obvious by Guthery. Patent Owner disagrees.1
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` As discussed above, the claims at issue are directed to an apparatus that is
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`configured to perform certain functions. In claims 23 and 25-26, the device must
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`be configured to communicate with the reading device, after selection of one of the
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`given applications, “without requiring any further steps.” Mot. App. A, 1.
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`Petitioner argues that Guthery teaches this negative limitation because Guthery is
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`in essence silent with respect to the steps being performed between reference
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`numbers 348 and 350. Opp., 14-15 (citing Ex. 1005, 12:20-52; partially annotated
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`Figs. 15B and 15C). Negative limitations, however, are not taught by the prior art
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`by silence alone. International Business Machines Corporation v. Iancu, 759 Fed.
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`Appx. 1002, 1011 (Fed. Cir. 2019) (“Silence in [with respect to the negative
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`limitation at issue] would not by itself suffice for the Petitioner to meet its burden
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`to prove, by a preponderance of the evidence, that there was no user authentication
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`action in this scenario.”) (citing 35 U.S.C. § 316(e)).
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`1 By referring the Board to the Petition for its arguments with respect to
`obviousness for all limitations except those to be added vis-à-vis substitute claims
`23-26, Petitioner is improperly incorporating by reference the substance of pages
`35-52, 54-63, 73-89 (42 pages) of the Petition, far exceeding the 25 page limit for
`its Opposition. 37 C.F.R. § 42.6(a)(3); 37 C.F.R. § 42.24; Opp. at 13-14. The
`portion of the Opposition incorporated by reference should not be considered. See
`Cisco Sys., Inc. v. C-Cation Techs., LLC, IPR2014-0054, Paper 22 at 9 (PTAB
`Aug. 29, 2014) (informative)
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`10
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`IPR2022-01137
`Reply to Opp. to Motion to Amend
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`Moreover, Petitioner’s arbitrary grouping of reference numbers in one set of
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`diagrams for the selection process and subsequent communications, does not prove
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`that Guthery teaches the negative limitation at issue here. Indeed, Petitioner
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`conveniently ignores all of the intermediate steps required by Guthery between
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`selection and subsequent communication.
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`As discussed above, the claimed selection process includes the steps
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`necessary for the reading device to engage in communications with the selected
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`application, i.e., when the selected application is sufficiently addressed by the
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`reading device to begin communicating with the data carrier. Ex. 1002, ¶¶ [0021]
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`(290), [0035-37] (295-296), supra. This occurs no later than when the reading
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`device receives the identification number assigned to the application, or, when
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`session numbers are used, no later than when the application is addressed uniquely
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`with the session numbers. Id.
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`Guthery’s process, however, requires multiple steps that are not part of the
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`application selection, between selection and further communication. Guthery
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`explains generally that the process starts with the smart card sending an
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`application-ID packet 60 to the host, which includes an index of applications on
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`the smartcard. Ex. 1005, 8:30-39. The host may then send to the smart card a
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`Request-to-Send (RTS) packet in response, which includes a listing of the
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`applications that have packets waiting, which may be followed by a Permission-to-
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`Send (PRS) packet (which Petitioner contends meets the selection function). Id.,
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`8:65-9:17; Opp., 14. Application selection as claimed therefore occurs in Guthery
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`when the host 60 receives the application index in packet 60, not after receiving the
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`11
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`IPR2022-01137
`Reply to Opp. to Motion to Amend
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`PTS packet, as Petitioner contends. Id. The processes by Guthery at least in
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`relation to Figs. 10-13 therefore all include steps that are performed between the
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`equivalent thereof of the selection function and further communication, including
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`steps by Guthery for the “input phase”, “processing phase”, the “output phase”,
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`etc. Ex. 1005, 9:49-52, 10:6-12, 10:26-31. As such, Guthery and the other
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`references of record fail to disclose or otherwise suggest at least this element of
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`claims 23 and 25-26.
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` Claim 24 further requires the communication device to be configured to
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`control communication “between the reading device and the uniquely addressed
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`application takes place subsequently without requiring any further steps after the
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`communication-readiness signals are generated.” Mot. App. A., 2. Petitioner
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`equates Guthery’s PTS packet with the claimed communication-readiness signals.
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`Opp., 18-19 (citing Ex.1005, 12:20-52; Figs. 15B and 15C (partial, annotated)).
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`Petitioner, however, provides no basis for this contention. In the ’706 Patent, the
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`communication-readiness signals are those emitted by the carrier “indicat[ing] its
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`communication readiness to the reading device” when the carrier is placed in
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`operational mode. Ex. 1002, ¶¶ [0003] (285), [0027] (292), [0043] (297).
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`Guthery’s equivalent, therefore, is the application-ID packet 60, which is the
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`packet sent to the host when the smart card is activated. Ex. 1005, 8:30-39. For the
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`reasons discussed above, Guthery and the other references of record do not
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`disclose or otherwise suggest subsequent communications “without requiring any
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`further steps after the communication-readiness signals are generated”, as
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`required by claim 24.
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`12
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`IPR2022-01137
`Reply to Opp. to Motion to Amend
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`V.
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`CONCLUSION
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`For the foregoing reasons, Patent Owner respectfully requests that the Board
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`grant its contingent Revised Motion to Amend should claims the original claims of
`
`the ’706 Patent be found unpatentable.
`
`
`Dated: August 2, 2023
`
`Respectfully submitted,
`/Antonio Papageorgiou/
`Antonio Papageorgiou
` Reg. No. 53,431
`
`LOMBARD & GELIEBTER LLP
`230 Park Avenue, 4th Floor West
`New York, NY 10169
`(212) 520-1172 (telephone)
`(646) 349-5567 (facsimile)
`ap@lombardip.com
`
`Attorney for AIRE TECHNOLOGY
`LTD.
`
`13
`
`
`
`
`
`IPR2022-01137
`Reply to Opp. to Motion to Amend
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(b), the undersigned certifies
`
`that on August 2, 2023, a copy of this REPLY TO PETITIONER’S OPPOSITION
`
`TO PATENT OWNER’S MOTION TO AMEND was served by filing this
`
`document through the Patent Trial and Appeal Case Tracking System (P-TACTS)
`
`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
`
`Dated: August 2, 2023
`
`Respectfully submitted,
`
`
`
`
`
`/Antonio Papageorgiou/
`
`Antonio Papageorgiou
`
` Reg. No. 53,431
`
`
`
`
`
`14
`
`
`
`
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