United States Patent and Trademark Office
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`Before the Patent Trial and Appeal Board
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`Page 1
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`AVX CORPORATION,
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`Petitioner
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`vs.
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`Case Number PGR2017-00010
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`Patent Number 9,326,381
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`SAMSUNG ELECTRO-MECHANICS CO., LTD.
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`In Re: TELEPHONE CONFERENCE
`
`MAY 25, 2017
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`Margaret M. Perry, MO & IL CSR
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`VERITEXT LEGAL SOLUTIONS
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`515 Olive, Suite 300
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`St. Louis, Missouri 63101
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`Veritext Legal Solutions
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`Exhibit 1028
`PGR2017-00010
`AVX CORPORATION
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`000001
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`

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` TELEPHONE CONFERENCE
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`Page 2
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`TELEPHONE CONFERENCE, on MAY 25, 2017,
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` between the hours of 10:02 a.m. and 10:21 a.m.
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` before Margaret M. Perry, Missouri C.C.R. No.
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` 948, and Notary Public.
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` A P P E A R A N C E S :
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`Page 3
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`F o r A V X C O R P O R A T I O N :
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`M r . M i c h a e l H o u s t o n
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`F o l e y & L a r d n e r
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`3 2 1 N o r t h C l a r k S t r e e t , S u i t e 2 8 0 0
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`C h i c a g o , I l l i n o i s 6 0 6 5 4
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`( 3 1 2 ) 8 3 2 - 4 3 7 8
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`m h o u s t o n @ f o l e y . c o m
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`F O R P A T E N T O W N E R S A M S U N G
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` E L E C T R O - M E C H A N I C S C O . , L T D
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`M r . A l e x a n d e r P . O t t
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`M r . H o s a n g L e e , h l e e @ m w e . c o m
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`M r . B e r n a r d K n i g h t , b k n i g h t @ m w e . c o m
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`M c D e r m o t t W i l l & E m o r y
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`5 0 0 N o r t h C a p i t o l S t r e e t N W
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`W a s h i n g t o n D C 2 0 0 0 1
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`( 2 0 2 ) 7 5 6 - 8 0 0 0
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`a o t t @ m w e . c o m
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`A D M I N I S T R A T I V E P A T E N T J U D G E S :
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`S a l l y C . M e d l e y
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`J o n i Y . C h a n g
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`Page 4
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`PAGE
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`INDEX
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`MR. HOUSTON
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`MR. OTT
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`MR. HOUSTON
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`none
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`EXHIBIT INDEX
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`Page 5
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` (Conference call was joined in progress by the
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`Court Reporter)
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`MR. HOUSTON: -- from the claims spawns
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`two implied or really direct claim construction
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`issues as raised by patent owner in their
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`preliminary response. One is a discussion of what
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`is meant by dielectric grains and then the other is
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`what is meant by single dielectric layer, and so
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`those are the two issues, they both stem from the
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`same limitation. With respect to the dielectric
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`grains issue, well for neither of those, Your
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`Honor, has patent owner proposed formal
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`constructions, but instead as they discussed prior
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`art, they adopt implied constructions for those
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`terms that would, that attempt to distinguish those
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`claim limitations from the prior art. With respect
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`to the first one, dielectric grains --
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`JUDGE MEDLEY: Excuse me just one minute,
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`so to make clear, I'm taking some notes, did
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`petitioner propose a claim construction for either
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`of those two terms in their petition?
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`MR. HOUSTON: We did not propose a formal
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`construction for them, Your Honor, we indicated
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`that they should be given their plain and ordinary
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`meaning as understood by one of ordinary skill in
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`Page 6
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`the art, which at the time we thought was, would be
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`clear.
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`JUDGE MEDLEY: Okay.
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`MR. HOUSTON: Your Honor, what the patent
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`owner has essentially done in its preliminary
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`response by way of argument and distinguishing the
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`prior art is to adopt a negative limitation or a
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`negative construction for the dielectric grains
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`claim term to say that that is not, does not equate
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`to unsintered ceramic particles. The reference
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`that was at issue there was Jeong Reference, which
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`uses the term "ceramic particles", and furthermore,
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`patent owner tries to distinguish around unsintered
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`ceramic particles, we think that negative claim
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`construction is both wrong and misleading, and the
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`reason I mentioned both of those, we think each of
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`those justifies good cause for filing a reply on
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`that issue. We do think that ceramic particles is
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`synonymous with dielectric grains and --
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`JUDGE MEDLEY: Okay. I don't want to get
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`in to the merits of it, what I'm interested in
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`hearing about is why there is a good cause showing
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`as to the sort of belated, you could have put in
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`your construction in your petition and you did not,
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`now having advantage of seeing the patent owner
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`Page 7
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`preliminary response, you want to file a reply, so
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`we just want to find out procedurally why there is
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`a good cause showing for doing so. So if you could
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`keep your comments to procedurally why we should do
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`that as opposed to getting into the merits and what
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`your proposed claim construction would be on the
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`phone.
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` MR. HOUSTON: Sure, Your Honor. So again
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`for the good cause, for patent owner to suggest
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`that dielectric grains, the construction for that,
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`should not include ceramic particles is something
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`that was unanticipated by us, something that we
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`think is factually and scientifically incorrect and
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`we could not have anticipated such a position being
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`taken, there's no expert testimony for patent owner
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`to explain that, but we think the science is clear
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`on that, and it was, I think our first argument
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`would be we couldn't anticipate that position being
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`taken by patent owner because it's inconsistent
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`with the facts and the science. Secondly, Your
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`Honor, what I wanted to mention is that we also
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`think it's misleading to The Board the way the
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`argument has come out, and we understand that
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`misleading factual arguments from a patent owner
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`can also satisfy The Good Cause standard, and
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`this -- the way they have tried to distinguish
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`Jeong is misleading to The Board because they're
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`focusing on unsintered ceramic particles versus
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`what our evidence was and what is in our petition
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`focuses on sintered ceramic particles.
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` JUDGE MEDLEY: Okay. And moving on to the
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`second issue.
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` MR. HOUSTON: Yes, Your Honor. The second
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`issue has to do with the single dielectric layer,
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`and again, they are adopting a claim construction
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`for that that would make that equate to strata or
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`individual -- well, I think the best word for it is
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`strata, that's the word that's used in the
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`reference, they equate, again not formally to a
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`claim construction, but to try to distinguish the
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`prior art, they equate single dielectric layer from
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`the claim to strata within the reference, and
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`again, Your Honor, that is, we think, a claim, a
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`negative claim construction that is way off base,
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`that's unsupported, we don't know how to anticipate
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`that sort of thing. The reference very clearly
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`talks about a dielectric layer that within it has
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`strata and now they have taken in their preliminary
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`response a very different position on claim
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`construction.
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`Page 9
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` JUDGE MEDLEY: So the good cause is what?
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` MR. HOUSTON: For that one, Your Honor, I
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`don't, it's truly an unanticipated claim
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`construction position that they've taken, although
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`again, they haven't taken it formally, they don't
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`have a section where they adopt a claim
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`construction either, but they're doing it in a
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`subtle way by trying to distinguish the prior art,
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`so I suppose --
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` JUDGE MEDLEY: Issue Number 3?
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` MR. HOUSTON: Issue Number 3, Your Honor,
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`is that patent owner has raised three evidentiary
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`issues as part of their preliminary response, lack
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`of authentication, lack of corroboration and
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`hearsay, and Your Honor, we understand under the
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`rules that such evidentiary objections are to be
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`raised after and only if there's an institution
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`decision at which point then petitioner has a
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`chance to follow under the rules, address those
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`evidentiary objections. Instead --
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` JUDGE MEDLEY: We would decide ourselves,
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`I mean, why do you need a reply for that?
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` MR. HOUSTON: Well, yes, Your Honor,
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`you're right. So we actually think the correct
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`position is that there shouldn't be a reply on that
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`and it shouldn't be considered by The Board at this
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`time. We raise it now, Your Honor, because we have
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`seen various decisions from various panels and even
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`a federal circuit that commented on how a given
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`party could have tried to address something by
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`seeking to file a reply and we did not want to be
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`in a position of, you know, that admonition being
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`thrown back at us by not at least offering to
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`address those issues now, Your Honor. However, to
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`be clear, it's certainly our position that they
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`should not be addressed now, they should not be
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`considered but The Board at this time, but because
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`they're in the preliminary response, we wanted to
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`offer to The Board to address them now.
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` JUDGE MEDLEY: Okay, understood. At this
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`time, we would like to hear from patent owner.
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` MR. OTT: Yes, Alex Ott on behalf of
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`patent owner. So on the first two issues of claim
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`construction, I think you are correct to indicate
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`that they did not propose a claim construction for
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`these two terms and they had ample opportunity to
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`do so, and in fact, it was their burden that if
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`they had claim construction, that they could have
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`and should have proposed them. And -- well, one
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`issue they sort of indicated a couple of times was
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`their idea that we're trying to be elusive by
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`implying a claim construction without actually
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`proposing a claim construction, and I think the key
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`issue there is; even if we had proposed a claim
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`construction for terms that they hadn't proposed
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`and proposed constructions for those terms, that
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`still would not be good cause for them to have a
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`reply and that specific issue, that issue where
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`terms are actually proposed for the first time in a
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`preliminary response was raised in IPR Number 2016
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`616 Apple versus Rosetta-Wireless, and there that
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`panel said the mere fact that patent owner seeks
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`construction of a different set of claim terms or
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`that petitioner does not agree with the evidence
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`behind patent owner's proposed construction of
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`these different terms does not strike us as worthy
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`of additional briefing. And another panel came to
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`the same conclusion, that was on Semiconductor
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`versus Power Integrations, IPR Number 2016 Echo 9,
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`the same fact pattern where new terms were proposed
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`for the construction for the first time in a
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`preliminary response and there The Board yet again
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`said the petitioner had an adequate opportunity to
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`present their proposed claim construction. So the
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`same situation here, we do not propose claim
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`Page 12
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`construction, that's right, but even if we had,
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`that still wouldn't have been good cause. And
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`going back to their allegation that our positions
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`were unanticipated, I think they've really missed
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`the requirement here. We, our position, without
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`getting too much into the merits, the term
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`dielectric grains, we took the position that the
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`words of the claim are dielectric grains, the words
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`in the prior art are ceramic particles and the
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`petition doesn't meet its burden to show how the
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`words of the claims are met by different words in
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`the prior art, and the petitioner were the ones
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`that brought up the prior art, so they should have
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`clearly anticipated that different words in the
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`prior art, they're going to have to do some
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`explanation here and they missed that. And the
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`same thing with single dielectric layers, even on
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`this call, when they referenced dielectric layer,
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`they dropped the word "single" out of their
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`discussion, but it says "single", not just
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`dielectric layer, so their petition is the same
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`thing. The words in the claim are single
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`dielectric layer and the petition only addresses
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`the words dielectric layer and doesn't even address
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`single, the word "single", and it was their burden
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`Page 13
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`to do so and they had ample opportunity in the
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`petition to address that term.
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` JUDGE MEDLEY: Okay. And with respect to
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`the third issue, the evidentiary issue?
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` MR. OTT: So we disagree that evidentiary
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`issues are to be punted to post institution --
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` JUDGE MEDLEY: That's what our rule says,
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`though.
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` MR. OTT: Well, we don't think the fact
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`that evidentiary issues can be addressed post
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`institution means that they must be addressed post
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`institution. And in our preliminary response, we
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`cite the ServiceNow vs. HP case, that's Page 22 of
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`our response, IPR Number 2015-716, and there
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`institution was denied because evidence in the
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`petition was held to be inadmissible hearsay
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`evidence. And we've had another case which isn't
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`cited, but we have the number here, it's Apple
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`versus DSS Technology Management, IPR Number
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`2015-369, and there again, the evidence cited in
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`the petition was held to be hearsay and so
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`institution was denied because there wasn't
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`sufficient evidence. And so in addition to board
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`decisions denying institution based often
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`evidentiary grounds, there are also the rules,
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`which 37 CFR 42.62A says the federal rules of
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`evidence apply to proceedings, and rule 42.2
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`defines proceedings to include preliminary
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`proceedings prior to institution, which is where we
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`are now. So the federal rules of evidence by rule
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`apply right now, and the The Board is instructed by
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`the rules to consider evidentiary rules and must
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`consider evidentiary rules, and by failing to
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`address the evidentiary issues in the petition,
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`they miss the boat, they had their opportunity to
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`explain the admissibility of their evidence and
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`they missed it and they shouldn't be able to reply
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`to try to fix their defects.
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` JUDGE MEDLEY: Okay. I'd like to hear --
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`do you have anything else?
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` MR. OTT: Well, I have one, not quite on
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`point, but I wasn't sure what their reply would
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`look like, but I think even if they sought the
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`reply to sort of make up for their lack of
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`addressing evidence, what would be in the reply
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`would also be improper because, A, they're not
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`allowed to add any new evidence at this stage
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`because the statute 324A says institution must be
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`based on quote "the information presented in the
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`petition", they're not adding new evidence, they
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`shouldn't be going back and trying to re-present
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`what is in the petition in a way that makes, that
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`would supposedly make it look more admissible, and
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`I have a board decision there IPR Number 2016 1079
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`Air Laclede versus Press Air, where a preliminary
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`response disputed the prior art status, I think it
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`was a publication, and the petitioner asked for a
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`reply to sort of identify where in their petition
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`they supposedly showed that it was prior art and
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`they were rejected because The Board said they had
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`ample opportunity to do that in the petition. And
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`then finally, and this is sort of a statement that
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`comes in a lot of board decisions on reply briefs,
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`it says The Board, and this is a statement in IPR
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`2016 1529, where they denied the reply brief
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`because they said assessment of the evidence and
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`application of the law to the facts of the case are
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`core functions of The Board, and you don't need the
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`petitioner to come back and do that job, that's is
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`The Board's job.
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` JUDGE MEDLEY: Thank you. I would like to
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`hear briefly and then we will go off-line for a few
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`minutes and decide what to do.
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` MR. HOUSTON: Sure, thank you, Your Honor.
`
`Mike Houston for petitioner. Your Honor, I'm sure
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`Page 16
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`that there are examples of the board denying
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`replies, for example, to address claim construction
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`issues, however, I hope and would assume The Board
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`is likewise aware there are many examples of The
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`Board allowing replies to address claim
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`construction issues and the standard, I can cite
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`some of those to The Board if it would be helpful,
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`but the standard has generally been expressed as
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`whether or not it would be helpful to the panel to
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`hear an additional briefing on those particular
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`issues, and so it's our position, Your Honor, that
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`we think it would be helpful to the panel to
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`receive the additional reply briefing to address
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`the three issues, or at least the first two issues
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`that we raised, and so that is the reason we're
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`seeking a reply, and again we don't want to be in a
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`situation later where we are told that we should
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`have sought a reply and we didn't, we have seen
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`that on numerous decisions, so that is the reason
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`we're seeking a reply here. As to the evidentiary
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`issues, Your Honor, to me the rules are very clear
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`on how those are supposed to be handled. This is
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`not a, I don't think there's anything different
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`here than what would arise in any other proceeding
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`where the rules clearly provide for evidentiary
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`Page 17
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`objections to being made and raised after the
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`institution decision and then addressed by the
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`proponent of the evidence within the allotted time
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`frame, which includes, Your Honor, the ability to
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`serve and potentially ultimately submit
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`supplemental evidence, and it's to cure such
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`evidentiary objections that are raised under the
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`federal rules of evidence. We've gone through that
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`procedure many times in many proceedings and have
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`never been faced with a situation where we'd be
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`asked to do that at this stage of the proceeding,
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`however, we think we can cure those, that is why we
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`wanted to have this conversation with The Board and
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`offer to do that now if The Board wants to go that
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`direction.
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`JUDGE MEDLEY: Okay. Thank you for your
`
`presentations. We will go off-line just for a few
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`minutes. Please do not hang up. We'll be right
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`back.
`
`(Off the record)
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`JUDGE MEDLEY: Thank you for your patience
`
`and waiting for us to deliberate. We conferred and
`
`we've decided that we do not need a reply, so no
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`reply will be authorized and we will go out with a
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`short order memorializing today's call. Any
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`questions, comments?
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` MR. HOUSTON: None for the petitioner,
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`Your Honor.
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` MR. OTT: None for the patent owner.
`
` JUDGE MEDLEY: We are adjourned.
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`Page 19
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` STATE OF MISSOURI
`
` SS.
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` CITY OF ST. LOUIS
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` I, Margaret M. Perry, a Notary Public in
`
`and for the State of Missouri, duly commissioned,
`
`qualified and authorized to administer oaths and to
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`certify to depositions, do hereby certify that
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`pursuant to Agreement, I attended a telephonic
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`conference on MAY 25, 2017.
`
` That the said conference being by me
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`reported in stenotype and caused to be transcribed
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`into typewriting, and that the foregoing pages
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`correctly set forth the telephonic conference and
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`is in all respects a full, true, correct and
`
`complete transcript.
`
` I further certify that I am not of
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` counsel or attorney for either of the parties to
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` said suit, not related to nor interested in any
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` of the parties or their attorneys.
`
` Witness my hand and notarial seal at
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`St. Louis, Missouri, this 25th day of May, 2017.
`
` My Commission expires September 26, 2017.
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`Page 20
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` < % S i g n a t u r e % >
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` N o t a r y P u b l i c i n a n d f o r t h e
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` S t a t e o f M i s s o u r i
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`[& - cause]
`
`&
`& 1:16 3:4,15
`1
`
`10 4:7
`1079 15:4
`10:02 2:4
`10:21 2:4
`15 4:8
`1529 15:15
`2
`20001 3:17
`2015-369 13:20
`2015-716 13:14
`2016 11:10,19 15:4
`15:15
`2017 1:13 2:3
`19:11,23,24
`202 3:18
`22 13:13
`25 1:13 2:3 19:11
`25th 19:23
`26 19:24
`2800 3:5
`3
`3 9:10,11
`300 1:18
`312 3:7
`321 3:5
`324a 14:23
`37 14:1
`
`4
`42.2 14:2
`42.62a 14:1
`5
`
`5 4:6
`500 3:16
`515 1:18
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`6
`60654 3:6
`616 11:11
`63101 1:19
`7
`756-8000 3:18
`8
`832-4378 3:7
`9
`
`9 11:19
`9,326,381 1:8
`948 2:6
`
`a
`a.m. 2:4,4
`ability 17:4
`able 14:12
`add 14:22
`adding 14:25
`addition 13:23
`additional 11:17
`16:10,13
`address 9:19 10:5
`10:9,14 12:24
`13:2 14:9 16:2,5
`16:13
`addressed 10:11
`13:10,11 17:2
`addresses 12:23
`addressing 14:20
`adequate 11:23
`adjourned 18:5
`administer 19:8
`administrative
`3:21
`admissibility
`14:11
`admissible 15:3
`admonition 10:7
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`adopt 5:14 6:7 9:6
`adopting 8:10
`advantage 6:25
`agree 11:14
`agreement 19:10
`air 15:5,5
`alex 10:17
`alexander 3:12
`allegation 12:3
`allotted 17:3
`allowed 14:22
`allowing 16:5
`ample 10:21 13:1
`15:11
`anticipate 7:18
`8:20
`anticipated 7:14
`12:14
`aott 3:19
`appeal 1:2
`appearances 3:1
`apple 11:11 13:18
`application 15:17
`apply 14:2,6
`argument 6:6 7:17
`7:23
`arguments 7:24
`art 5:14,16 6:1,7
`8:16 9:8 12:9,12
`12:13,15 15:6,9
`asked 15:7 17:11
`assessment 15:16
`assume 16:3
`attempt 5:15
`attended 19:10
`attorney 19:19
`attorneys 19:21
`authentication
`9:14
`authorized 17:24
`19:8
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`Veritext Legal Solutions
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`Page 1
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`avx 1:4 3:2
`aware 16:4
`b
`back 10:8 12:3
`15:1,19 17:19
`base 8:19
`based 13:24 14:24
`behalf 10:17
`belated 6:23
`bernard 3:14
`best 8:12
`bknight 3:14
`board 1:2 7:22 8:2
`10:1,12,14 11:22
`13:23 14:6 15:4
`15:10,13,14,18
`16:1,3,5,7 17:13
`17:14
`board's 15:20
`boat 14:10
`brief 15:15
`briefing 11:17
`16:10,13
`briefly 15:22
`briefs 15:13
`brought 12:13
`burden 10:22
`12:10,25
`c
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`c 3:22
`c.c.r. 2:5
`call 5:1 12:18
`17:25
`capitol 3:16
`case 1:7 13:13,17
`15:17
`cause 6:17,22 7:3
`7:9,25 9:1 11:7
`12:2
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`[caused - functions]
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`caused 19:13
`ceramic 6:10,12
`6:14,18 7:11 8:3,5
`12:9
`certainly 10:10
`certify 19:9,9,18
`cfr 14:1
`chance 9:19
`chang 3:23
`chicago 3:6
`circuit 10:4
`cite 13:13 16:6
`cited 13:18,20
`city 19:4
`claim 5:4,16,20
`6:9,14 7:6 8:10,15
`8:17,18,19,24 9:3
`9:6 10:18,20,23
`11:2,3,4,13,24,25
`12:8,22 16:2,5
`claims 5:3 12:11
`clark 3:5
`clear 5:19 6:2 7:16
`10:10 16:21
`clearly 8:21 12:14
`16:25
`come 7:23 15:19
`comes 15:13
`commented 10:4
`comments 7:4
`18:1
`commission 19:24
`commissioned
`19:7
`complete 19:17
`conclusion 11:18
`conference 1:12
`2:1,3 5:1 19:11,12
`19:15
`conferred 17:22
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`www.veritext.com
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`consider 14:7,8
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`construction 5:4
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`constructions 5:13
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`conversation
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`core 15:18
`corporation 1:4
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`correct 9:24 10:19
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`correctly 19:15
`corroboration
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`counsel 19:19
`couple 10:25
`court 5:2
`csr 1:16
`cure 17:6,12
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`day 19:23
`dc 3:17
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`decisions 10:3
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`dielectric 5:7,8,10
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`equate 6:9 8:11,14
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`essentially 6:5
`evidence 8:4 11:14
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`evidentiary 9:12
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`examples 16:1,4
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`expires 19:24
`explain 7:16 14:11
`explanation 12:16
`expressed 16:8
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`faced 17:10
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`factual 7:24
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`failing 14:8
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`find 7:2
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`focuses 8:5
`focusing 8:3
`foley 3:4
`foley.com 3:8
`follow 9:19
`foregoing 19:14
`formal 5:12,22
`formally 8:14 9:5
`forth 19:15
`frame 17:4
`full 19:16
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`[further - need]
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`further 19:18
`furthermore 6:12
`g
`generally 16:8
`getting 7:5 12:6
`given 5:24 10:4
`go 15:22 17:14,17
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`going 12:3,15 15:1
`good 6:17,22 7:3,9
`7:25 9:1 11:7 12:2
`grains 5:7,11,17
`6:8,19 7:10 12:7,8
`grounds 13:25
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`hand 19:22
`handled 16:22
`hang 17:18
`hear 10:16 14:14
`15:22 16:10
`hearing 6:22
`hearsay 9:15
`13:16,21
`held 13:16,21
`helpful 16:7,9,12
`hlee 3:13
`honor 5:12,23 6:4
`7:8,21 8:8,18 9:2
`9:11,15,23 10:2,9
`15:24,25 16:11,21
`17:4 18:3
`hope 16:3
`hosang 3:13
`hours 2:4
`houston 3:3 4:6,8
`5:3,22 6:4 7:8 8:8
`9:2,11,23 15:24,25
`18:2
`hp 13:13
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`idea 11:1
`identify 15:8
`il 1:16
`illinois 3:6
`implied 5:4,14
`implying 11:2
`improper 14:21
`inadmissible
`13:16
`include 7:11 14:3
`includes 17:4
`inconsistent 7:19
`incorrect 7:13
`index 4:2,10
`indicate 10:19
`indicated 5:23
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`individual 8:12
`information 14:24
`institution 9:17
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`instructed 14:6
`integrations 11:19
`interested 6:21
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`ipr 11:10,19 13:14
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`issue 5:11 6:11,18
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`jeong 6:11 8:2
`job 15:19,20
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`joni 3:23
`judge 5:18 6:3,20
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`judges 3:21
`justifies 6:17
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`keep 7:4
`key 11:3
`knight 3:14
`know 8:20 10:7
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`lack 9:13,14 14:19
`laclede 15:5
`lardner 3:4
`law 15:17
`layer 5:8 8:9,16,22
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`lee 3:13
`legal 1:17
`likewise 16:4
`limitation 5:10 6:7
`limitations 5:16
`line 15:22 17:17
`look 14:18 15:3
`lot 15:13
`louis 1:19 19:4,23
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`m 1:16 2:5 19:6
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`13:19
`margaret 1:16 2:5
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`meaning 5:25
`means 13:11
`meant 5:7,8
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`meet 12:10
`memorializing
`17:25
`mention 7:21
`mentioned 6:16
`mere 11:12
`merits 6:21 7:5
`12:6
`met 12:11
`mhouston 3:8
`michael 3:3
`mike 15:25
`minute 5:18
`minutes 15:23
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`misleading 6:15
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`missed 12:4,16
`14:12
`missouri 1:19 2:5
`19:1,7,23 20:4
`mo 1:16
`moving 8:6
`mwe.com 3:13,14
`3:19
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`n
`need 9:22 15:18
`17:23
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`[negative - right]
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`negative 6:7,8,14
`8:19
`neither 5:11
`never 17:10
`new 11:20 14:22
`14:25
`north 3:5,16
`notarial 19:22
`notary 2:6 19:6
`20:3
`notes 5:19
`number 1:7,8 9:10
`9:11 11:10,19
`13:14,18,19 15:4
`numerous 16:19
`nw 3:16
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`o
`oaths 19:8
`objections 9:16,20
`17:1,7
`offer 10:14 17:14
`offering 10:8
`office 1:1
`okay 6:3,20 8:6
`10:15 13:3 14:14
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`olive 1:18
`ones 12:12
`opportunity 10:21
`11:23 13:1 14:10
`15:11
`opposed 7:5
`order 17:25
`ordinary 5:24,25
`ott 3:12 4:7 10:17
`10:17 13:5,9
`14:16 18:4
`owner 3:10 5:5,12
`6:5,13,25 7:9,15
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`10:16,18 11:12
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`owner's 11:15
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`positions 12:3
`post 13:6,10,11
`potentially 17:5
`power 11:19
`preliminary 5:6
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`present 11:24 15:1
`presentations
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`press 15:5
`prior 5:13,16 6:7
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`procedurally 7:2,4
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`proponent 17:3
`propose 5:20,22
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`proposed 5:12 7:6
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`proposing 11:3
`provide 16:25
`public 2:6 19:6
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`publication 15:7
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`pursuant 19:10
`put 6:23
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`p 3:12
`page 4:4 13:13
`pages 19:14
`panel 11:12,17
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`panels 10:3
`part 9:13
`particles 6:10,12
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`[rosetta - way]
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`rosetta 11:11
`rule 13:7 14:2,5
`rules 9:16,19
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`solutions 1:17
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