Trials@uspto.gov -
`571-272-7822
`
`.
`
`Paper 19
`Entered: May 13, 2014
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GOOGLEINC.,
`Petitioner,
`
`V.
`
`SIMPLEAIR, INC.,
`Patent Owner.
`
`Case CBM2014-00054
`Patent 7,035,914 Bl
`
`Before MICHAEL R. ZECHER, STACEY G. WHITE,and
`TINA E. HULSE,Administrative Patent Judges.
`HULSE,Administrative Patent Judge.
`|
`
`DECISION
`DenyingInstitution of Covered Business Method Patent Review
`37 CFR. § 42.208
`
`
`571-272-7822
`
`.
`
`Paper 19
`Entered: May 13, 2014
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GOOGLEINC.,
`Petitioner,
`
`V.
`
`SIMPLEAIR, INC.,
`Patent Owner.
`
`Case CBM2014-00054
`Patent 7,035,914 Bl
`
`Before MICHAEL R. ZECHER, STACEY G. WHITE,and
`TINA E. HULSE,Administrative Patent Judges.
`HULSE,Administrative Patent Judge.
`|
`
`DECISION
`DenyingInstitution of Covered Business Method Patent Review
`37 CFR. § 42.208
`
`
`
`Case CBM2014-00054
`Patent 7,035,914 Bl
`
`I.
`
`INTRODUCTION
`
`Petitioner, Google Inc., filed an amendedPetition requesting a
`
`covered business method patent review of claims 1-3, 7, 22-24, 69, and 70
`(“the challenged claims”) of U.S. Patent No. 7,035,914 BI (“the ’914
`patent”). Paper 5 (“Pet.”). Patent Owner, SimpleAir, Inc., timely filed a
`Preliminary Responseto the Petition. Paper 14 (“Prelim. Resp.”). We have
`jurisdiction under 35 U.S.C. § 324.
`The standard for instituting a covered business method patent review
`is set forth in 35 U.S.C. § 324(a):
`
`THRESHOLD. — The Director may not authorize a post-grant
`review to be instituted unless the Director determines that the -
`information presented in the petition filed under section 321, if
`such information is not rebutted, would demonstrate thatit is
`morelikely than not that at least 1 of the claims challenged in
`the petition is unpatentable.
`
`Upon considering the Petition and Preliminary Response, we
`
`determine that the information presented in the Petition does not
`
`demonstrate that the challenged claims are more likely than not
`unpatentable. We, therefore, deny the Petition.
`
`. A._Petitioner’s Standing
`
`Section 18 of the Leahy-Smith America Invents Act (“AIA”)
`governsthetransitional program for covered business method patent
`reviews.’ Section 18(a)(1)(B) of the AIA limits such reviewsto persons,or
`
`' See Section 18(a) ofthe Leahy-Smith America Invents Act, Pub. L.
`No. 112-29, 125 Stat. 284, 329 (2011).
`2
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`Case CBM2014-00054
`Patent 7,035,914 BI
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`their privies, that have been sued or charged with infringement of a covered
`
`business method patent.
`Petitioner asserts that it has been sued forinfringement of the 914
`patent in a relatedlitigationtitled SimpleAir, Inc. v. Microsoft Corp.,
`No. 2:11-cv-00416 (E.D. Tex.). Pet. 1.
`
`The ’914 Patent (Ex. 1001)
`B.
`The °914 patent relates to wired and non-wired data transmission
`communication systems. Ex. 1001, 1:24-26. Wireless communication
`
`technology allowsusers to be notified of information anywhere and at any
`
`time. /d. at 1:52-53. Moreover, online services have made endless amounts
`
`of information available to individuals throughout the world. Jd. at 1:58-61.
`
`According to the ’914 patent, however, these technologies suffer
`
`from numerous disadvantages. For example, the benefits of wireless
`
`technology only have been utilized for personal messaging with limited
`
`message length. /d. at 1:65-2:3. Moreover, immediate notification of
`informationis not available. Jd. at 2:22-26. Another problem, according to
`
`the °914 patent, is that data transmitted over existing wireless broadcast
`networks suffer from inevitable degradation of data. Id. at 2:27-40.
`
`To address these issues, the °914 patent describes a system that
`
`allows for broadcast of up-to-the-minute notification centric information
`that provides an instant call to action for users who are provided with the
`
`ability to retrieve further detailed information instantaneously. Jd. at 2:50-
`
`58.
`
`
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`Case CBM2014-00054
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`C.
`
`Illustrative Claim
`
`Claim 1 is the only independent claim challengedin this proceeding.
`
`Claims2, 3, 7, 22-24, 69, and 70 all dependdirectly or indirectly from
`claim 1.
`
`Claim1is illustrative of the subject matter of the challenged claims
`and is reproduced below:
`
`1. A method for transmitting data to selected remote devices,
`comprising the steps of:
`transmitting data from an information source to a central
`broadcast server;
`preprocessing said data at said central broadcast server,
`further comprisingthestepof:
`parsing said data with parsers corresponding to said central
`broadcast server;
`transmitting said data to an information gateway for building
`data blocks and assigning addresses to said data blocks;
`transmitting said data blocks from said information gateway
`to a transmission gateway for preparing said data blocks
`for transmissionto receivers;
`transmitting preprocessed data to receivers communicating
`with said devices; and
`instantaneously notifying said devices of receipt of said
`preprocessed data whether said devices are online or
`offline from a data channel associated with each device.
`
`‘
`
`D.
`
`Covered Business Method Patent
`
`Undersection 18(a)(1)(E) of the AIA, the Board mayinstitute a
`
`transitional proceeding only for a patent that is a covered business method
`
`patent. A “covered business method patent”is a patent that “claims a
`
`methodor corresponding apparatus for performing data processing or other
`
`operations usedin the practice, administration, or management of a
`
`financial product or service, except that the term does notinclude patents
`
`
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`Case CBM2014-00054
`Patent 7,035,914 Bl
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`for technological inventions.” AIA § 18(d)(1); 37 C.F.R. § 42.301(a). For
`purposes ofdetermining whethera patentis eligible for a covered business
`methodpatent review, the focus is on the claims. See Transitional Program
`
`for Covered Business Method Patents—Definitions of Covered Business
`Method Patent and Technological Invention, 77 Fed. Reg. 48,734, 48,736
`(Aug. 14, 2012). A patent need have only one claim directed to a covered
`business methodto beeligible for review. Id.
`
`1.
`
`Financial Product or Service
`
`In promulgating rules for covered business method patent reviews,
`
`the Office considered the legislative intent and history behind the AIA’s
`
`definition of “covered business method patent.” Jd. at 48,735-36. The
`
`“legislative history explains that the definition of covered business method
`
`patent was drafted to encompasspatents ‘claiming activities that are
`financial in nature, incidentalto a financial activity or complementary to a
`financial activity.’” Id. at 48,735 (citing 157 Cong. Rec. $5432 (daily ed.
`Sept. 8, 2011) (statement of Sen. Schumer)). Thelegislative history
`indicatesthat “financial productor service” should be interpreted broadly.
`77 Fed. Reg.at 48,735-36.
`Claim 1 recites a method of transmitting data to selected remote
`
`devices. Ex. 1001, 33:16-17. Referring to Figure 2 of the ’914 patent, the
`
`Specification teaches that “the data, which can include .
`
`.
`
`. stock quotes, .
`
`.
`
`.
`
`lotto, ... etc. is then respectively parsed by parsers, such as the stock quote
`
`parser 106, ... lotto parser 110... and then transmitted to the content
`
`manager 114 located in the central broadcast server 34.” Ex. 1001, 8:11-16.
`Claim 1, therefore, encompasses a method usedin the managementof a
`financial product or service—thatis, the disclosure of stock.quotes andlotto
`
`5
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`results. Thus, we determine that claim 1 of the ’914 patent recites “a
`
`method .. . for performing data processing or other operations used in the
`
`practice, administration, or managementofa financial product orservice.”
`
`See AIA § 18(d)(1); 37 C.F.R. § 42.301(a).
`
`Technological Invention
`2.
`The definition of a “covered business method patent” in § 18(d)(1) of
`the AIA does not include patents for “technological inventions.”
`When determining whethera patent is for a technological invention, we
`
`consider “whether the claimed subject matter as a wholerecites a
`
`technological feature that is novel and unobviousover the prior art; and
`
`solves a technical problem using a technical solution.” 37 C.F.R.
`
`§ 42.301(b).
`The following claim drafting techniques, for example, typically do
`
`not render a patent a “technological invention”:
`
`(a) Mererecitation of knowntechnologies, such as computer
`hardware, communication or computer networks, software,
`memory, computer-readable storage medium, scanners, display
`devices or databases, or specialized machines, such as an ATM
`or point of sale device.
`(b) Reciting the use of knownpriorart technology to
`accomplish a process or method, even if that process or method
`is novel and non-obvious.
`(c) Combiningprior art structures to achieve the normal,
`expected, or predictable result of that combination.
`
`Office Patent Trial Practice Guide, 77 Fed. Reg. 48,756, 48,763-64 (Aug.
`14, 2012).
`|
`
`Evenif the problems solved andthe solutions claimed by the °914
`
`patent were technical, as Patent Ownerasserts (Prelim. Resp. 19-25), we are
`
`persuadedthat claim 1, as a whole, doesnot recite a technological feature
`
`6
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`that is novel and unobviousoverthepriorart. In particular, claim 1 only
`
`recites the presence of well-known technologies to accomplish the claimed
`method. For example, the 914 patent concedes that “information sources,”
`such as internet providers, were known (Ex. 1001, 6:5-14), and that one of
`skill in the art would have understoodthat a “central broadcast server”
`
`“operates effectively as a network operations center,” which was well
`
`knownin the art (id. at 6:20-22; Ex. 1047 § 9.2.5.2).
`
`In its Preliminary Response, Patent Ownerarguesthat the Petition
`
`fails to address whetherthe step of “instantaneously notifying said devices
`of receipt of said preprocessed data whethersaid computing devices are
`online or offline from a data channel associated with each device” was
`novel and unobvious overthe prior art. Prelim. Resp. 28. But whether the
`step of “instantaneously notifying” is novel and unobviousis irrelevantif
`
`the prior art technology used to accomplish that step was known. See
`
`Office Patent Trial Practice Guide, 77 Fed. Reg. at 48,763-64. Because
`
`Patent Ownerdid not rebut Petitioner’s assertion that the prior art
`
`technology used in claim 1 was knownin the art, we determinethat claim 1
`
`does not recite a technological feature that is novel and unobviousoverthe
`
`prior art. See 37 C.F.R. § 42.301(b).
`
`E.
`
`The Prior Art Relied Upon
`
`Tso
`
`Petitioner relies upon the following prior art references:
`US6,047,327
`Apr. 4, 2000-
`(filed Feb. 16, 1996)
`
`.
`
`May
`
`US 5,043,721
`
`Aug. 27, 1991
`
`Palmer
`
`US 5,905,965
`
`May 18, 1999
`(effectively filed Oct. 30, 1995)
`
`Ex. 1040
`
`Ex. 1041
`
`Ex. 1042
`
`
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`Case CBM2014-00054
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`Bezaire
`
`US 5,758,088
`
`Dasan
`
`US 5,761,662
`
`May26, 1998
`(effectively filed May 8, 1995)
`
`June 2, 1998
`(effectively filed Dec. 20, 1994)
`
`Dai
`
`US 5,307,399
`
`Apr. 26, 1994
`
`DeLuca
`
`US 5,663,717.
`
`Sept. 2, 1997
`(effectively filed Aug. 1, 1994)
`
`“SkyTel,” as discussed in Exs. 1009-1035.
`
`F.
`
`The Asserted Grounds of Unpatentability
`
`Ex. 1043
`
`Ex. 1044
`
`Ex. 1045
`
`Ex. 1046
`
`Petitioner challenges the patentability of claims 1-3, 7, 22-24, 69, and
`
`70 of the ’914 patent based on the following groundsset forth in the table
`
`below:
` eee
`7
`%
`4 ee
`
`ee
`e
`SOs
`
`gies
`
`Re
`
`
`
`
`SkyTel
`1-3, 7, 22-24, and 69
`§ 102(b) / § 103
`| § 102(e)/§ 103|1-3, 7, 22- 24, and 69
`
`
`
`§ 102(e)/ § 103|1-3, 7, 22- 24, and 69
`
`
`
`Tso and May
`
`§ 103
`
`1-3, 7, 22- 24, and 69
`
`
`
`
`
`
`
`
`
`
`
`SkyTel and Tso and/or May|§ 103 1-3, 7, 22- 24, and 69
`
`Palmerand Tso and/or May
`
`Bezaire and/or Dasan
`
`Dai and one or more ofthe
`above-identified references
`DeLuca and one or more of
`the above-identified
`
`references
`
`§ 103
`
`§ 103
`
`§ 103
`
`§ 103
`.
`
`1-3, 7, 22- 24, and 69
`
`1-3, 7, 22- 24, and 69
`
`1-3, 7, 22- 24, and 69
`
`1-3, 7, 22- 24, 69, and
`70
`.
`
`
`
`
`
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`II.
`
`ANALYSIS
`
`A.
`
`Claim Construction
`
`In a covered business method patent review, we interpret claim terms
`in an unexpired patent according to the broadest reasonable construction in
`light of the specification of the patent in which they appear. 37 C.F.R.
`§ 42.200(b). Under that standard and absent a special definition, we give
`claim terms their ordinary and customary meaning, as would be understood
`by one of ordinary skill in the art at the time of the invention. Jn re
`Translogic Tech., Inc., 504 F.3d 1249, 1257 (Fed. Cir. 2007). Any special
`definitions for claim terms mustbe set forth with reasonable clarity,
`deliberateness, and precision. Jn re Paulsen, 30 F.3d 1475, 1480 (Fed.Cir.
`1994).
`
`In the co-pendinglitigation, the district court construed several terms
`
`of the °914 patent. Ex. 2001. Both parties suggest that the Board adoptthe
`district court’s constructions,at least for purposes ofthis Decision to
`Institute. Pet. 19; Prelim. Resp. 7. For convenience,the district court’s
`
`constructions of the ’914 patent claim terms are reproducedin the table
`
`below:
`
`Construction
`
`
`Claim term “data channel”
`
`
`“one or more communication
`
`
`channels or paths for accessing or
`viewing a category or subcategory of
`
`information that is provided by an
`information source over a
`
`
`communications network”
`
`
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`Case CBM2014-00054
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`“whether said computing devices are
`online or offline from a data channel
`associated with each device”
`
`Construction
`
`“whether the remote.computing —
`devices are or are not connected via
`the Internet or another online service
`to a data channel associated with
`each computing deviceat the time
`the preprocessed data is received by
`
`
`
`
`
`
`
`
`
`“whether said computing devices are
`“whether said computing devices are
`on or off”
`powered on or poweredoff”
`
`
`
`
` “one or more contentor online
`
`“information source”
`
`serviceproviders that provide data to
`the central broadcast server, such as
`
`an online source of news, weather,
`sports, financial information, games,
`
`personal messages, or e-mails”
`
`“parsing said data with parsers”
`
`“using multiple computer software
`programs,routines, or functions to
`
`
`break or divide data received from
`an information source into
`components whose content or format
`can be analyzed, processed or acted
`
`
`
`
`“an information gateway for
`“one or more software programs(or .
`
`building data blocks and assigning
`a portion of a program)that build
`
`
`addressesto said data blocks”
`data blocks and assign addresses to —
`
`
`
`
`
`“a transmission gateway for
`
`preparing said data blocks for
`
`
`transmission to receivers”
`
`
`
`
`
`
`
`“one or more software programs(or
`a portion of a program) that prepare
`the data blocks for their transmission
`to receivers and interface with other
`resources used to transmit the
`preprocessed data”
`
`10
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`“central broadcast server’
`
`Construction
`
`“one or moreservers that are
`configured to receive data [from] a
`plurality of information sources and
`| process the dataprior to its
`transmission to one or moreselected
`remote computing device”
`
`
`
`
`
`“contextual graphics”
`
`
`
`“graphics relating to the context of
`the preprocessed data that has been
`received”
`
`Uponconsidering the district court’s claim construction order, we
`determine that the constructions of each claim term are consistent with their
`
`broadest reasonable interpretation in light of the specification.
`
`Accordingly, for purposes of this Decisionto Institute, we adopt the district
`court’s constructionsofthe claim terms reproduced in the table above. See
`Ex. 2001 at 8-46.
`.
`|
`B.
`Unpatentability over § 102(e) Prior Art
`Section 18(a)(1)(C) of the AIA states that a petitioner who challenges
`the patentability of one or more claims ina covered business patent may
`support such groundonly onthebasisof:
`
`(i)
`(ii)
`
`prior art that is described by pre-AJA section 102(a); or
`prior art that—
`(I)
`discloses the invention more than | year before the date
`of the application for patent in the United States; and
`(II) would be described by pre-AJA section 102(a) if the
`disclosure had been made by anotherbefore the
`invention thereof by the applicant for patent.
`
`Certain referencescited in the Petition are prior art to the challenged
`claims only under 35 U.S.C. § 102(e). Section 102(e) references, however,
`
`1]
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`are not available for consideration in a covered business method patent
`
`review proceeding. See Gillman v. StoneEagle Servs., Inc., CBM2013-
`
`00047, slip op. at 9-10 (PTAB Feb. 18, 2014) (Paper 11); MasterCard Int'l
`
`Inc. v. D’Agostino, CBM2013-00058, slip op. at 8-9 (PTAB Mar. 7, 2014)
`
`(Paper 10).
`
`Petitioner has concededin the Petition that Dasan and DeLucaare
`
`prior art under § 102(e). Pet. 68, 78. In a notice filed after the Petition,
`
`Petitioner conceded that Tso, Palmer, and Bezaire are § 102(e)art, as well.
`Paper 13 at 1. Accordingly, we decline to institute a covered business
`
`method patent review on any groundsthat rely on these § 102(e)priorart
`references.
`
`Unpatentability over SkyTel
`C.
`The remaining patentability challenges that do not rely on § 102(e)
`art each rely on “SkyTel.” Petitioner asserts that claims 1-3, 7, 22-24, and
`69 are anticipated, or rendered obvious, by SkyTel, either alone orin
`combination with other prior art. Pet. 20-42; 66-67; 73-77. Patent Owner
`asserts that SkyTel does not qualify as a prior art system. Prelim. Resp. 32-
`
`42. Weare persuaded by Patent Owner’s argument.
`
`1.
`Summary ofSkyTel (Exs. 1009-1035)
`SkyTel provides wireless messaging services via SkyTel’s ground-
`based transmitter system, leased satellite facilities, and proprietary |
`messaging technology. Ex. 1021 at 3.” SkyTel subscribers receive numeric
`
`* Citations to specific pages of each exhibit discussed in our summary of
`SkyTel, as well as the analysis of the grounds based, in wholeorin part, on
`SkyTel, are to the page numbersassigned byPetitioner, rather than the
`original page numbersidentified in the document.
`12
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`pages and alphanumeric messages ontheir mobile devices. Jd. According
`
`to William Hays, who oversaw thecreation of SkyTel, many different
`
`content providers, such as Compuserve, AT&T, PersonalLink, and MCI
`
`Mail, used SkyTel’s messaging system to provide content to users.
`Ex. 1011 9 29. Moreover, SkyTel users could use a wide variety of devices
`with the SkyTel system, including the AT&T Safari computer, various
`
`Hewlett-Packard (““HP”) devices (e.g., OmniGo 100), MailScout, Apple
`Newton,various Motorola devices (e.g., Envoy and Tango), and the Sony
`MagicLink. Id. 30; Ex. 1047
`8.2.2.
`|
`2.
`Analysis
`Petitioner contends that SkyTel anticipates, or renders obvious, the
`challenged claims. In doing so, however, Petitioner relies on 27 exhibits
`
`(Exs. 1009-1035) as support for the SkyTel system. Pet. 20. These various
`
`exhibits include a published PCTapplication (Ex. 1009), which Hays, one
`
`of the namedinventors, admits is illustrative of only “many ofthe features
`
`in the commercial implementation of the SkyTel messaging service,” but
`
`not all. Ex. 1011 § 12 (emphasis added); see also id. {J 23, 27 (describing
`embodiments of the PCT application that were not implemented in the
`SkyTel system). The SkyTel exhibits relied upon, andcited to, by
`Petitioner also describe various embodiments of the SkyTel system that are
`used with different mobile devices, including a system used with the Sony |
`MagicLink device (e.g., Exs. 1012, 1013, 1018, and 1022), and a system
`used with HP devices (e.g., Exs. 1026 and 1027). Finally, SkyTel’s 10-K
`filing describes two different SkyTel services, a one-way messaging service
`
`and a two-way messaging service. Ex. 1021 at 3, 5.
`
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`To anticipate a claim,a single prior art reference must disclose each
`claim limitation. Finisar Corp. v. DirecTV Group,Inc., 523 F.3d 1323,
`| 1334 (Fed. Cir. 2008). Multiple secondary references may be used to
`support an anticipation challenge by a primary reference to establish that
`
`the primary reference is enabling. See In re Elsner, 381 F.3d 1125, 1129
`
`(Fed. Cir. 2004) (finding use of secondary references to show that a primary
`
`§ 102(b) reference was enabled was proper). But multiple references may —
`
`not be used to support an anticipation challenge where those references do
`
`not describe a single system. See Kyocera Wireless Corp. v. Int'l Trade
`Comm’n, 545 F.3d 1340, 1351 (Fed.Cir. 2008) (finding eleven different
`references with separate dates of creation describing the GSM standard did
`not constitute a “single prior art reference”).
`|
`Here, by relying on different documents describing different
`embodiments of SkyTel, Petitioner does not rely on a single embodimentor
`“system” of SkyTel to support its anticipation challenge. Instead, Petitioner
`~ cobbles togetherits anticipation challenge, picking and choosing teachings
`from the various embodiments of SkyTel as support for each limitation.
`
`See, é.g., Pet. 33-34 (relying on disclosures regarding PersonaLink and HP
`
`devices, as well as the published PCT application as anticipating element F
`
`of claim 1); compareid. at 37 with id. at 24 (relying on SkyTel’s two-way
`messaging system for dependentclaim 7, while relying on disclosure
`regarding SkyTel’s one-way messaging system for independentclaim 1).
`Although Petitioner seemsto rely heavily on the SkyTel system used with
`
`the PersonaLink device, we decline to go throughthe entirety of
`
`Petitioner’s challenges to parse out which limitations Petitioner contends
`
`are disclosed by which embodimentto determine whether Petitioner has
`
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`established anticipation with a single embodiment. Petitioner should have
`
`done this wheninitially presenting its arguments, and we decline to make
`
`Petitioner’s anticipation case sua sponte.
`
`Asfor obviousness, although Petitioner may rely on multiple systems
`
`and references pertaining to SkyTel to support its challenge, Petitioneris
`
`not excused from explaining its obviousness case and providing the proper
`analysis. Simply asserting in a conclusory mannerthat the subject matter of
`
`~
`
`the claims is obviousin light of “SkyTel”is insufficient given the various
`
`SkyTel embodiments. See id. at 22. Petitioner must explain, for example,
`
`the scope and contentofthe prior art and the differences between theprior:
`
`art and the claimsat issue. See Graham v. John Deere Co., 383 U.S. 1, 17
`(1966). Moreover, there must be an articulated reason with arational
`underpinning to justifythe legal conclusion of obviousness. See KSR Int’]
`Co. v. Teleflex Inc., 550 U.S. 398, 418 (2007). Petitioner did not address
`these issues with respect to the various SkyTel embodiments, andhas,
`therefore, failed to establish that the subject matter of the challenged claims
`
`are more likely than not obvious over “SkyTel.”
`
`15
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`
`
`Case CBM2014-00054
`Patent 7,035,914 Bl
`
`I.|CONCLUSION
`
`Wedeterminethat the information presented in the Petition does not
`
`establish that it is more likely than-not that Petitioner would prevailin
`
`establishing the unpatentability of any challenged claims of the ’914 patent.
`
`ORDER ©
`IV.
`|
`In consideration of the foregoing,it is hereby:
`
`ORDEREDthatthe Petition is denied as to all challenged claims of
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`the °914 patent; and
`
`. FURTHER ORDEREDthat no covered business methodreviewis
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`instituted.
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`PETITIONER:
`
`Vaibhav P. Kadaba
`Michael S. Pavento
`Kilpatrick Townsend & Stockton LLP
`wkadaba@kilpatricktownsend.com
`mpavento@kilpatricktownsend.com
`
`
`
`icotrailedoych
`
`PATENT OWNER: ©
`
`Steven Sereboff
`Jonathan Pearce
`SoCal IP Law Group LLP
`ssereboff@socalip.com
`jpearce@socalip.com
`uspto@socalip.com
`
`16
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