throbber
Trials@uspto.gov
`571-272-7822
`
`
`Paper No. 11
`Entered: January 22, 2024
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`SHENZHEN APALTEK CO., LTD. And
`COOLER MASTER CO., LTD.,
`Petitioner,
`v.
`ASETEK DANMARK A/S,
`Patent Owner.
`
`IPR2022-01317*
`Patent 8,245,764 B2
`
`
`
`
`
`
`
`
`
`Before WILLIAM V. SAINDON, KEVIN W. CHERRY, and
`JASON W. MELVIN, Administrative Patent Judges.
`MELVIN, Administrative Patent Judge.
`
`
`
`JUDGMENT
`Final Written Decision
`Determining All Challenged Claims Unpatentable
`35 U.S.C. § 318(a)
`
`
`* Cooler Master Co., Ltd., which filed a petition in IPR2023-00668, has been
`joined as a party to this proceeding.
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`
`INTRODUCTION
`I.
`ShenZhen Apaltek Co., Ltd. (“Petitioner”) filed a Petition (Paper 1,
`“Pet.”) requesting institution of inter partes review of claims 1–30 of
`U.S. Patent No. 8,245,764 B2 (Ex. 1001, “the ’764 patent”). Asetek
`Danmark A/S (“Patent Owner”) filed a Preliminary Response. Paper 5. As
`authorized, Petitioner filed a Preliminary Reply. Paper 6. Pursuant to
`35 U.S.C. § 314 and 37 C.F.R. § 42.4(a), we instituted review. Paper 7. We
`joined Cooler Master Co., Ltd., as a Petitioner here pursuant to a motion
`filed in IPR2023-00668. Paper 9. No party filed a paper after institution.
`We have jurisdiction under 35 U.S.C. § 6. This is a Final Written
`Decision under 35 U.S.C. § 318(a) as to the patentability of claims 1–30 of
`the ’764 patent. We hold that Petitioner has demonstrated by a
`preponderance of the evidence that the challenged claims are unpatentable.
`
`A. REAL PARTIES IN INTEREST
`Petitioner ShenZhen Apaltek identifies itself as the real party in
`interest. Pet. 146. Petitioner Cooler Master identifies itself as the real party
`in interest. IPR2023-00668, Paper 3, 146. Patent Owner identifies Asetek
`Danmark A/S, Asetek USA, Inc., Asetek A/S, and Asetek Holdings, Inc. as
`the real parties in interest for Patent Owner. Paper 4, 1 (Patent Owner’s
`Mandatory Notices).
`
`B. RELATED MATTERS
`The parties identify the following related litigations: Asetek Danmark
`A/S v. CoolIT Systems, Inc., No. 3:19-cv-00410 (N.D. Cal.); Cooler Master
`Co., Ltd. v. Asetek Danmark A/S, No. 4:21-cv-04627 (N.D. Cal.); and Asetek
`
`
`
`2
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`Danmark A/S v. Shenzhen Apaltek Co., Ltd., No. 6:21-cv-00501 (W.D. Tex.)
`(transferred to N.D. Cal., May 6, 2022). Pet. 147; Paper 4, 1.
`The parties also identify the following Office proceedings:
`IPR2020-00522, IPR2020-00523, and IPR2020-00524, which were filed in
`February 2020 and concluded in August 2021, IPR2021-01195 against U.S.
`Patent No. 10,613,601 and IPR2021-01196 against U.S. Patent
`No. 10,599,196. Pet. 147; Paper 4, 1–2.
`
`C. THE ’764 PATENT
`The ’764 patent is titled “Cooling System for a Computer System.”
`Ex. 1001, code (54). It issued from an application filed October 7, 2011, as a
`continuation of and claims priority to a PCT application filed May 6, 2005.
`Id. at code (63).
`The ’764 patent relates to a liquid-cooling system for a computer
`system. Id. at Code (57). The specification explains, at the time of the
`invention, air cooling arrangements were the most-used cooling system for
`cooling central processing units (CPUs) in computer systems. Id. at 1:17–31.
`An alternative design known at the time of the invention was to use a
`cooling liquid circulating inside a closed system by means of a pumping unit
`with a heat exchanger past which the cooling liquid circulates. Id. at 1:32–
`36. The specification contends that liquid cooling is generally more efficient
`and quieter than air cooling, but that a liquid cooling design consists of
`“many components,” which increases the total installation time, size, and
`risk of leakage of the cooling liquid from the system. Id. at 1:37–47. Thus,
`one object of the invention is to provide a small and compact liquid-cooling
`solution that is more efficient than existing air-cooling arrangements and can
`be produced at low cost enabling high production volumes, be easy-to-use
`3
`
`
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`and implement, can be used with existing CPU types and computer systems,
`and requires a low level of maintenance or no maintenance at all. Id. at
`1:51–60.
`An illustrative embodiment of such a device is depicted in Figures 7
`and 8, reproduced below.
`
`
`
`Figure 71 is a perspective view of the cooling system showing reservoir
`housing 14 with the heat exchanging surface 5 (shown in Figure 8) and the
`pump 21 (shown in Figure 8) inside the reservoir. Id. at 15:61–16:7. Figure 8
`is a cut-out view into reservoir housing 14, when the reservoir, pump 21, and
`
`
`1 It appears the specification transposes the description of Figure 7 with that
`of Figure 8. We refer to the description of “Figure 8” in the specification in
`our discussion of Figure 7, and we refer to the specification’s discussion of
`“Figure 7” in our discussion of Figure 8.
`4
`
`
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`heat exchanging surface 4 are situated inside the reservoir. Id. at 15:28–30.
`The reservoir has a tube inlet connection (not shown in Figure 8) through
`which the cooling liquid enters the reservoir. Id. at 15:30–32. From the tube
`inlet connection, the cooling liquid flows through the reservoir passing heat
`exchanging surface 4 and enters the inlet of the pump. Id. at 15:32–35. After
`the cooling liquid flows through the pump, the cooling liquid passes out of
`the outlet of the pump and further out through tube outlet connection 16. Id.
`at 15:35–37. As shown in Figure 7, tube inlet connection and tube outlet
`connection 16 are connected to heat radiator 11 by means of connecting
`tubes 24 and 25. Id. at 15:64–67. Cooling liquid flows into and out of the
`reservoir and the heat radiator through connecting tubes 24 and 25,
`respectively. Id. Heat radiator 11 (shown in Figure 7) cools the cooling
`liquid before it passes back into the reservoir. Id. at 15:67–16:4.
`The reservoir may be provided with channels or segments for
`establishing a certain flow-path for the cooling liquid through the reservoir
`to prevent the cooling liquid passing the reservoir too quickly to take up a
`sufficient amount of heat from the heat exchanging surface. Id. at 16:25–42.
`Figures 17 and 20 show the internal structures of a preferred
`embodiment of the reservoir according to the invention and are reproduced
`below. Id. at 21:12–22:59.
`
`
`
`5
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`
`
`
`
`
`Figure 17 is an exploded perspective view of a preferred embodiment of a
`reservoir and a pump and the heat exchanging surface. Id. at 9:62–64.
`Figure 20 is a simplified schematic showing a cross-sectional view of the
`reservoir along plane 20-20 of Figure 17. Id. at 10:4–5. Reservoir housing 14
`as shown in Figures 17 and 20 is in the form of a double-sided chassis
`
`
`
`6
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`having a substantially conical, circular configuration with stiffening ribs 36
`extending axially along the exterior of the reservoir housing and configured
`to mount an electrical motor. Id. at 21:14–21. Reservoir housing 14 has
`recess 40 intended for accommodating stator 37 of an electrical motor
`driving impellor 33 of the pump, which is attached to shaft 38 of rotor 39 of
`the electric motor. Id. at 21:28–40. The specification explains that “a liquid-
`proof division” is made between rotor 39 of the motor, which is submerged
`in the cooling liquid, and the stator 37 of the pump. Id. at 21:41–51.
`The enclosed space between impeller 33 and heating exchanging
`interface 4 is divided into two separate chambers by impeller cover 46A and
`intermediate member 47, as shown in Figure 20. The chamber formed by
`impeller 33 and impeller cover 46A is described as “pump chamber 46” and
`has outlet 34. Id. at 22:26–53.
`
`D. CHALLENGED CLAIMS
`Challenged claim 1 is independent and is reproduced below:
`1. A cooling system for a heat-generating component,
`comprising:
`a double-sided chassis adapted to mount a pump configured
`to circulate a cooling liquid, the pump comprising a
`stator and an impeller, the impeller being positioned on
`the underside of the chassis and the stator being
`positioned on the upper side of the chassis and isolated
`from the cooling liquid;
`a reservoir adapted to pass the cooling liquid therethrough,
`the reservoir including:
`a pump chamber including the impeller and formed
`below the chassis, the pump chamber being defined
`by at least an impeller cover having one or more
`passages for the cooling liquid to pass through;
`
`
`
`7
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`
`a thermal exchange chamber formed below the pump
`chamber and vertically spaced apart from the pump
`chamber, the pump chamber and the thermal
`exchange chamber being separate chambers that are
`fluidly coupled together by the one or more passages;
`and
`a heat-exchanging interface, the heat-exchanging
`interface forming a boundary wall of the thermal
`exchange chamber, and configured to be placed in
`thermal contact with a surface of the heat-generating
`component; and
`a heat radiator fluidly coupled to the reservoir and
`configured to dissipate heat from the cooling liquid.
`Id. at 27:39–64. Claims 10 and 15 are also independent and recite generally
`similar limitations. See id. at 28:27–43, 28:57–29:13. The other challenged
`claims depend, directly or indirectly, from claim 1, 10, or 15. Id. at 27:66–
`30:12; Ex. 1002, 1:18–2:35.
`
`E. PRIOR ART AND ASSERTED GROUNDS
`Petitioner asserts the following grounds of unpatentability:
`Claim(s) Challenged 35 U.S.C. § Reference(s)/Basis
`1–19, 21–27, 29, 30
`103
`Duan2
`
`1–19, 21–27, 29, 30
`
`8
`
`8
`
`103
`
`103
`
`103
`
`Duan, Duan-I3
`
`Duan, Laing4
`
`Duan, Duan-I, Laing
`
`
`2 U.S. Pat. Appl. Pub. No. 2006/0185830 A1, pub. Aug. 24, 2006
`(Ex. 1006).
`3 U.S. Pat. Appl. Pub. No. 2006/0185829 A1, pub. Aug. 24, 2006
`(Ex. 1007).
`4 U.S. Pat. Appl. Pub. No. 2004/0052663 A1, pub. Mar. 18, 2004 (Ex. 1015).
`8
`
`
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`
`Claim(s) Challenged 35 U.S.C. § Reference(s)/Basis
`1–30
`103
`Batchelder5, Duan
`
`8
`
`103
`
`Batchelder, Duan, Laing
`
`Pet. 3. Petitioner also relies on the Declaration of George Karamanis, Ph.D.
`Ex. 1003.
`
`II. ANALYSIS
`A. LEVEL OF ORDINARY SKILL IN THE ART
`Petitioner proposes that a person of ordinary skill
`
`would have been knowledgeable regarding liquid cooling
`systems for computer systems, would have had a Bachelor of
`Science (B.S.) in electrical or mechanical engineering, or
`similar advanced post-graduate education in this area, or would
`have possessed at least 2–3 years of experience in liquid
`cooling systems for computer systems or similar systems. A
`POSITA would be knowledgeable of the concepts, components,
`and their functions described as “prior art” in the ’355 patent
`such as, e.g., pumps, radiators, fans, reservoirs, and other
`techniques of heat dissipation and liquid cooling. (Ex-
`1001,1:11–47.) In addition, a POSITA would be knowledgeable
`about electric motors and their components (e.g.,
`electromagnetic coils, rotors, stators, AC/DC motors, etc.)
`Pet. 5–6 (citing Ex. 1003 ¶¶ 13–18). Patent Owner has not proposed a level
`of ordinary skill in the art. We adopt Petitioner’s proposed level of ordinary
`skill as it appears to be consistent with the level of skill reflected by the
`specification and in the asserted prior art references.
`
`
`5 U.S. Pat. No. 6,019,165, iss. Feb. 1, 2000 (Ex. 1008).
`9
`
`
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`
`B. CLAIM CONSTRUCTION
`For an inter partes review petition filed after November 13, 2018, we
`construe claim terms “using the same claim construction standard that would
`be used to construe the claim in a civil action under 35 U.S.C. 282(b).”
`37 C.F.R. § 42.100(b) (2019).
`Petitioner submits that, in the related litigation, the parties “have
`stipulated to construe the term ‘reservoir’ in the ’764 patent to mean ‘single
`receptacle defining a fluid flow path.’” Pet. 6 (citing Ex. 1005, 2; Ex. 1003
`¶ 19). We apply that definition here.
`Based on our analysis of the proceeding, we conclude that no other
`claim term requires express construction. See Nidec Motor Corp. v.
`Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017).
`
`C. OBVIOUSNESS BASED ON DUAN
`Duan’s system includes a cooling plate module with a cooling plate
`integrally formed with a liquid driving module such that the layout of the
`cooling plate module can be minimized to reduce space. Ex. 1006 ¶ 7.
`Figure 6, reproduced below, is a view of Duan’s “liquid cooling cyclic
`mechanism.” Id. ¶ 17.
`
`
`
`10
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`
`
`
`Duan’s Figure 6 shows liquid cooling cyclic mechanism 100 for cooling
`CPU 200. Id. ¶ 22. Liquid cooling cyclic mechanism 100 comprises cooling
`module 10 and water tank module 20, which is connected with cooling plate
`module 10 through ducts. Id. Cooling plate module 10 includes cooling plate
`1, liquid driving module 2, and heat absorbing interface 11. Id. Heat
`absorbing face 11 is in contact with CPU 200 for dissipating heat generated
`by the CPU. Id. ¶ 26. Water tank 20 includes cooling stage 53. Id. ¶ 25.
`Driven by liquid driving module 2 (a pump), liquid heated by CPU 200
`flows to cooling stage 53, where heat dissipates through heat-dissipating fins
`531, and the resulting cool liquid flows back to cooling plate module 10. Id.
`¶¶ 23–26.
`
`
`
`11
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`
`1. Claim 1
`Petitioner maps the language of independent claim 1 to Duan’s
`disclosures, modified as described below by those of Duan-I. Pet. 26–48.
`Petitioner asserts that, “[g]iven the known ‘compact trend of
`computer[s]’ recognized by Duan [¶0006], a POSITA would have been
`motivated to rotate Duan’s liquid driving module 2 (pump) counterclockwise
`by 90 degrees in Figure 7 to reduce the system’s overall height, in view of
`Duan-I.” Pet. 32 (second alteration in original) (citing Ex. 1003 ¶ 55).
`Petitioner relies on the similar cooling modules disclosed in Duan and
`Duan-I, depicted in Figure 7 of each reference and reproduced below:
`
`
`
`Id. (quoting Ex. 1006, Fig. 7; Ex. 1007, Fig. 7). Duan’s Figure 7 depicts
`cooling plate module 10 comprising liquid driving module 2 located on top
`of cooling plate 1 with impeller stage 223 having a rotational axis along the
`surface of CPU 200 being cooled. Ex. 1006 ¶¶ 22, 23, 27. Duan-I’s Figure 7
`12
`
`
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`depicts liquid-cooling heat dissipation apparatus 100 comprising liquid
`driving unit 2 located on top of cooling plate module 3 with impeller stage
`23 having a rotational axis normal to the surface of CPU 200 being cooled.
`Ex. 1007 ¶¶ 20–22, 28.
`Thus, Petitioner identifies the reservoir of its asserted, modified
`system in an annotated illustration, reproduced below:
`
`
`
`Pet. 37 (quoting Ex. 1003 ¶ 63). Petitioner’s annotated illustration shows
`Duan’s modified cooling plate module with the asserted reservoir outlined in
`orange. Petitioner reasons that skilled artisans had reason to modify Duan’s
`system as taught by Duan-I in light of the “compact trend of computer[s]”
`that Duan recognized. Pet. 32 (quoting Ex. 1006 ¶ 6). Petitioner contends
`that doing so would have provided the benefit of reducing the system’s
`overall height. Id. (citing Ex. 1003 ¶ 55). We agree that Petitioner’s
`contentions support the modification with rational underpinning.
`
`
`
`13
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`
`Patent Owner does not challenge Petitioner’s contentions, as it has
`filed no Patent Owner Response. We have reviewed Petitioner’s contentions
`and conclude that they show by a preponderance of the evidence that
`claim 1’s subject matter would have been obvious over Duan and Duan-I.
`See Pet. 26–87. We adopt Petition’s unchallenged contentions as our
`analysis.
`
`2. Additional claims
`For claims 2–19, 21–27, 29, and 30, Petitioner provides contentions
`showing how the combination of Duan and Duan-I renders the claims
`obvious. Pet. 49–87. For claim 8, Petitioner provides contentions that Laing
`also discloses the additional limitation, and that skilled artisans had reason to
`incorporate Laing’s teachings. Pet. 87–89.
` Patent Owner does not challenge Petitioner’s contentions, as it has
`filed no Patent Owner Response. We have reviewed Petitioner’s contentions
`and conclude that they show by a preponderance of the evidence that the
`subject matter of claims 2–19, 21–27, 29, and 30 would have been obvious
`over Duan and Duan-I, and that the subject matter of claim 8 would have
`been obvious over Duan, Duan-I, and Laing. See Pet. 26–87. We adopt the
`Petition’s unchallenged contentions as our analysis.
`
`D. OBVIOUSNESS BASED ON BATCHELDER
`Batchelder discloses an “apparatus to transfer heat from a heat source
`to a heat absorber” using “an active thermal spreader plate with internal flow
`channels, a recirculating heat transfer fluid, and a means to impel the heat
`transfer fluid using an external moving magnetic field.” Ex. 1008, code (57).
`
`
`
`14
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`
`1. Claim 1
`For the obviousness grounds using Batchelder as the primary
`reference, Petitioner focuses primarily on Batchelder’s Figure 7, reproduced
`below:
`
`Figure 7 shows a heat sink for heat source 2, including bottom sheet 202 of
`an active spreader plate assembly, lower stamped plate 204, medial
`15
`
`
`
`
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`sheet 206, upper stamped plate 208, channel forming sheet 210, impeller 52,
`and top sheet 212. Ex. 1008, 7:23–8:11.
`Petitioner maps the claimed double-sided chassis to Batchelder’s top
`sheet 212. Pet. 90–92. Petitioner asserts that skilled artisans would have
`modified Batchelder’s design such that impeller 52 is driven directly by a
`stator coil, as in Duan, because “control over the impeller is better if driven
`directly by the stator, which can also provide a stronger, more effective
`rotating magnetic field.” Id. at 92 (citing Ex. 1003 ¶ 164).
`Petitioner maps the claimed reservoir to Batchelder’s stack of sheets
`and stamped plates, which form chambers for fluid flow. Id. at 95–98.
`Petitioner contends Batchelder’s reservoir has the claimed pump chamber as
`“the space in the channel forming sheet 210 and the upper stamped plate
`208.” Id. at 98–101. Petitioner contends Batchelder’s reservoir has the
`claimed thermal exchange chamber as “the center space in the lower
`stamped plate 204.” Id. at 101–03. Petitioner contends Batchelder’s reservoir
`has the claimed heat-exchanging interface as “bottom surface 24” in the
`bottom sheet 202. Id. at 104–05. Finally, Petitioner contends that skilled
`artisans would have had reason “to connect Batchelder’s heat spreader plate
`to a radiator, a well-known component used to transfer thermal energy (e.g.,
`heat) from one medium to another, like the one taught in Duan.” Id. at 105–
`12. Petitioner reasons that doing so would “help further cool the heated
`cooling liquid” and “further increase heat management efficiency.” Id. at
`106 (citing Ex. 1003 ¶¶ 180–181). We agree that Petitioner’s contentions
`support the modification with rational underpinning.
`Patent Owner does not challenge Petitioner’s contentions, as it has
`filed no Patent Owner Response. We have reviewed Petitioner’s contentions
`
`
`
`16
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`and conclude that they show by a preponderance of the evidence that
`claim 1’s subject matter would have been obvious over Batchelder and
`Duan. See Pet. 89–112. We adopt the Petition’s unchallenged contentions as
`our analysis.
`
`2. Additional claims
`For claims 2–30, Petitioner provides contentions showing how the
`combination of Batchelder and Duan renders the claims obvious. Pet. 113–
`43. For claim 8, Petitioner provides contentions that Laing also discloses the
`additional limitation and that skilled artisans had reason to incorporate
`Laing’s teachings. Pet. 143–45.
` Patent Owner does not challenge Petitioner’s contentions, as it has
`filed no Patent Owner Response. We have reviewed Petitioner’s contentions
`and conclude that they show by a preponderance of the evidence that the
`subject matter of claims 2–30 would have been obvious over Batchelder and
`Duan, and that the subject matter of claim 8 would have been obvious over
`Batchelder, Duan, and Laing. See Pet. 113–45. We adopt the Petition’s
`unchallenged contentions as our analysis.
`
`III. CONCLUSION6
`We conclude Petitioner has shown the challenged claims are
`unpatentable. In summary
`
`6 Should Patent Owner wish to pursue amendment of the challenged claims
`in a reissue or reexamination proceeding subsequent to the issuance of this
`decision, we draw Patent Owner’s attention to the April 2019 Notice
`Regarding Options for Amendments by Patent Owner Through Reissue or
`Reexamination During a Pending AIA Trial Proceeding. See 84 Fed. Reg.
`16,654 (Apr. 22, 2019). If Patent Owner chooses to file a reissue
`application or a request for reexamination of the challenged patent, we
`17
`
`
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`
`Claim(s)
`
`
`1–19, 21–
`27, 29, 30
`1–19, 21–
`27, 29, 30
`8
`8
`
`1–30
`8
`
`35
`U.S.C.
`§
`103
`
`103
`
`103
`103
`
`103
`103
`
`Reference(s)/Basis
`
`Duan
`
`Duan, Duan-I
`
`Duan, Laing
`Duan, Duan-I,
`Laing
`Batchelder, Duan
`Batchelder, Duan,
`Laing
`
`
`Claims
`Shown
`Unpatentable
`1–19, 21–27,
`29, 30
`1–19, 21–27,
`29, 30
`8
`8
`
`1–30
`8
`
`1–30
`
`IV. ORDER
`
`Claims
`Not Shown
`Unpatentable
`
`
`
`
`
`
`
`
`
`
`
`
`Overall
`Outcome
`
`
`
`Accordingly, it is
`ORDERED that Petitioner has shown by a preponderance of the
`evidence that claims 1–30 of the ’764 patent are unpatentable; and
`FURTHER ORDERED that, because this is a Final Written Decision,
`parties to the proceeding seeking judicial review of the decision must
`comply with the notice and service requirements of 37 C.F.R. § 90.2.
`
`
`remind Patent Owner of its continuing obligation to notify the Board of
`any such related matters in updated mandatory notices. See 37 C.F.R.
`§§ 42.8(a)(3), (b)(2).
`
`
`
`18
`
`

`

`IPR2022-01317
`Patent 8,245,764 B2
`
`For PETITIONER:
`James Ryerson
`Heath Briggs
`GREENBERG TRAURIG, LLP
`ryersonj@gtlaw.com
`briggsh@gtlaw.com
`
`For PATENT OWNER:
`
`Eric P. Raciti
`Arpita Bhattacharyya
`FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER LLP
`eric.raciti@finnegan.com
`arpita.bhattacharyya@finnegan.com
`
`
`
`
`19
`
`

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