Trials@uspto.gov
`Tel: 571-272-7822
`
`Paper 21
`Entered: July 14, 2015
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`EIZO CORPORATION,
`Petitioner,
`
`Vv.
`
`BARCON.V.,
`Patent Owner.
`
`Case IPR2014-00358
`Patent RE43,707 E
`
`Before KALYAN K. DESHPANDE, JAMESB. ARPIN,and
`DAVID C. McKONE,Administrative Patent Judges.
`
`DESHPANDE,Administrative Patent Judge.
`
`FINAL WRITTEN DECISION
`35 US.C. § 318(a); 37 CFR. § 42.73
`
`
`Tel: 571-272-7822
`
`Paper 21
`Entered: July 14, 2015
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`EIZO CORPORATION,
`Petitioner,
`
`Vv.
`
`BARCON.V.,
`Patent Owner.
`
`Case IPR2014-00358
`Patent RE43,707 E
`
`Before KALYAN K. DESHPANDE, JAMESB. ARPIN,and
`DAVID C. McKONE,Administrative Patent Judges.
`
`DESHPANDE,Administrative Patent Judge.
`
`FINAL WRITTEN DECISION
`35 US.C. § 318(a); 37 CFR. § 42.73
`
`
`
`IPR2014-00358
`Patent RE43,707 E
`
`I.
`
`INTRODUCTION
`
`A. Background
`
`Eizo Corporation (‘Petitioner’) filed a corrected Petition requesting
`
`an inter partes review of claims 36, 46, 54, 64, 65, 77-79, 93, 94, 101-104,
`
`and 107 of U.S. Patent No. RE43,707 E (Ex. 1001; “the ’707 patent”).
`
`Paper4 (‘‘Pet.””). Barco N.V. (“Patent Owner”) timely filed a Preliminary
`
`Response. Paper 9 (“Prelim. Resp.”). Pursuant to 35 U.S.C. § 314, we
`
`instituted inter partes review on July 23, 2014, as to claims 101-104 of the
`707 patent under 35 U.S.C. § 103(a) as obvious over Greene’ and Kamada.”
`
`Paper 11 (“Dec.”).
`
`Patent Ownerfiled a Response (Paper 16, “PO Resp.”), and Petitioner
`
`filed a Reply (Paper 17, “Pet. Reply’’).
`Oral hearing was held on April 1, 2015, and the hearing transcript has
`_ been entered in the record (Paper20, “Tr.”).
`The Board has jurisdiction under 35 U.S.C. § 6(c). This Final Written
`
`Decision is issued pursuant to 35 U.S.C. § 318(a) and 37 C.F.R. § 42.73.
`
`For the reasons discussed below, we are not persuadedthat Petitioner has
`
`shownby a preponderance ofthe evidence that claims 101—104 of the ’707
`
`patent are unpatentable.
`
`B. Related Proceedings
`
`Petitioner indicates that the ’707 patent is the subject of a Federal
`
`district court case: Barco, N.V. v. Eizo Nanao Corp., 11-cv-00258 (N.D.
`
`Ga). Pet. 1.
`
`' U.S. Patent No. 6,271,825 B1 (Ex. 1008, “Greene”).
`? U.S. Patent Publication No. 2005/0093798 Al (Ex. 1004, “Kamada”).
`
`
`
`IPR2014-00358
`Patent RE43,707 E
`
`Additionally, the ’707 patent is the subject ofInter Partes
`
`Reexamination No. 95/002,047 and was the subject of Ex Parte
`Reexamination No. 90/020,037 (“the 037 Reexam.”).° Pet.1.
`
`C. The ’707 Patent
`
`The ’707 patent is directed to a system and methodfor noise reduction
`
`in medical images being viewed on display systems. Ex. 1001, 4:14—16.
`
`Scientific studies indicate that even a “slight increase of noise in medical
`
`images can havea significant negative impact on the accuracy and quality of
`
`medical diagnosis.” Jd. at 1:30—-33. Accordingly, the ’707 patent provides a
`
`noise reduction system and method that addresses non-uniformity of pixel
`
`behavior present in matrix-addressed electronic display devices. Id. at 4:36—
`
`4],
`
`The ’707 patent includes a range of embodiments, including a vision
`
`measurement system — a Set-up for automated, electronic vision of
`
`individual pixels of a matrix-addressed display. Jd. at 6:10-17. The vision
`
`measurement system includes an image capturing device, a movement
`
`device for moving the image capturing device, and/or a display.
`/d. at 6:17—
`20. Each of the embodiments reachesthe sameresult of outputting an
`
`electronic image of pixels. Jd. at 6:20—23. “[A] process is run to extract
`pixel characterization data from the electronic image.” Id. at 7:4—7.
`
`Algorithms are used to assign a luminance value to each pixel, where the
`
`algorithm includesa first task of identifying a location of each of the matrix
`
`display pixels andrelating the pixels to the pixels of the electronic image,
`
`and a secondtask of calculating and assigning one light-output value for
`
`3 The Office issued a reexaminationcertificate, U.S. Reexamination
`Certificate No. RE43,707 Cl, on March 31, 2014. Ex. 2005.
`
`
`
`IPR2014-00358
`Patent RE43,707 E
`
`each pixel. Jd. at 7:8-13, 8:52—54. A test image may be generated by
`driving each ofthe pixels with the same drive signal or drive level, and the
`light-output of each pixel can be calculated from the test image. Id. at 9:25—
`39. The next task of the algorithm is to define a drive function, thereby
`
`providing a correction principle to generate a required light-output response
`
`curve for an individual pixel and, thus, equalizing the responseofall of the
`
`pixels in a display. Jd. at 10:29-42.
`
`An exampleof equalizing the behaviorof the pixels is illustrated in
`
`Figure 10 as follows:
`
`
`
`Fig. 10
`
`Figure 10 illustrates that pixels with curves A-C are equalized to that
`
`of curve D. Jd. at 12:3-5. A specific transfer curve for each pixel may be _
`used to compensate for the behavior of each pixel’s characteristic luminance
`
`response, thereby modifying or curing any unequal luminance behavior over
`
`a display area. Jd. at 12:19-28.
`
`D.Illustrative Claims
`
`Weinstituted inter partes review, on July 23, 2014, as to claims 101-
`104 of the ’707 patent. Subsequentto the filing of the Petition, a
`
`Reexamination Certificate issued in the 037 Reexam., amending claim 101.
`
`See Ex. 2005. Claim 101, which depended from independentclaim 100,
`
`
`
`IPR2014-00358
`Patent RE43,707 E
`
`now is written in independent form to includeall of the limitations of
`
`cancelled claim 100. Jd. Claims 102—104 depend, directly or indirectly,
`
`from independentclaim 101.
`
`Independentclaim 101 is illustrative of the claims at issue and is
`
`reproduced below:
`
`101. An image processing apparatus comprising:
`
`an array of logic elements configured to generate a
`display signal based on a map and an image signal
`that
`represents at least one physical and tangible object
`
`is configured to cause a
`wherein the display signal
`display to depict a display image of the at least one physical
`and tangible object, and
`wherein the map comprises correction data configured to
`correct
`for pixel non-uniformity only when the pixel non-
`uniformity is outside of a tolerance level, and
`
`wherein the tolerance level varies among pixels of the
`display.
`
`FE. Claim Construction
`
`The Board interprets claims of an unexpired patent using the broadest
`reasonable interpretation in light ofthe specification ofthe patent in which
`they appear. See 37 C.F.R. § 42.100(b); see also In re Cuozzo Speed Techs.,
`
`LLC, No. 2014-1301, slip op. at 16-19 (Fed. Cir. July 8, 2015) (“Congress
`implicitly approved the broadest reasonable interpretation standard in
`enacting the AIA,” and “the standard was properly adopted by PTO
`
`regulation.”). Under the broadest reasonable interpretation standard, claim
`
`terms are given their ordinary and customary meaning, as would be
`
`understood by oneof ordinary skill in the art in the context of the entire
`
`
`
`IPR2014-00358
`Patent RE43,707 E
`
`disclosure. In re Translogic Tech. Inc., 504 F.3d 1249, 1257 (Fed. Cir.
`
`2007).
`
`|
`
`I. “tolerance level”
`
`Independentclaim 101 recites the term “tolerance level” with respect
`
`to pixel non-uniformity. Ex. 2005, 2:55—3:2. Neither Petitioner nor Patent
`
`Ownersets forth a construction for “tolerance level.” See Tr. 7:22-8:2,
`
`11:18-21, 24:10-12; Pet. 10. The ’707 patent does not provide a specific
`
`definition for “tolerance level,” but discloses that in measuring a color shift
`
`“small deviations in color go unnoticed. This meansthatthere is a certain
`tolerance on differences in luminosity relationships of sub-pixel elements
`
`whichstill provide an apparently uniform display.” Ex. 1001, 12:65-13:1.
`
`The ordinary and customary definition for “tolerance”is “[l]Jeeway for
`
`variation from a standard” and “[t]he permissible deviation from a specified
`value ofa structural dimension, often expressed as a percent,”* and the
`
`ordinary and customary definition for “level”is “[rJelative position or rank
`ona scale.”” Accordingly, we determine that the ordinary and customary
`meaningof“tolerance level” is a permissible deviation or variation from a
`
`position on a scale. This meaningof“tolerance level” is consistent with its
`
`usage in the ’707 patent specification. See Ex. 1001, 12:65—-13:1.
`
`Accordingly, based on its ordinary and customary meaningandits usage in
`
`the ’707 patent specification and claims, we construe “tolerance level” to
`
`* See tolerance, THE AMERICAN HERITAGE DICTIONARY OF THE ENGLISH
`LANGUAGE(2011) (available at
`http://search.credoreference.com/content/entry/hmdictenglang/tolerance/0).
`> See level, THE AMERICAN HERITAGE DICTIONARY OF THE ENGLISH
`LANGUAGE(2011) (available at
`http://search.credoreference.com/content/entry/hmdictenglang/level/0).
`
`-
`
`
`
`
`
`IPR2014-00358
`Patent RE43,707 E
`
`mean the permissible amountof deviation in luminosity thatstill provides an
`
`apparently uniform display.
`
`Il.
`
`ANALYSIS
`
`A. Timeliness ofPetition
`
`Patent Ownercontendsthat the Petition is time-barred under 35
`
`U.S.C. § 315(b) because the Petition was filed more than one year after the
`date on which Petitioner was served a complaintalleging infringement of the
`
`patent. PO Resp. 10-25; Prelim. Resp. 2-15. Patent Ownerspecifically
`argues that it served a complaintalleging infringement of U.S. Patent No.
`
`7,639,849 B2 (“the ’849 patent”) upon Petitioner on October 7, 2011. PO
`
`Resp. 10—11; Prelim. Resp. 2; see Ex. 2002. Subsequentto this service, the
`
`°849 patent was reissued on October 2, 2012, as the ’707 patent. PO Resp.
`
`11; Prelim. Resp. 2. The instant Petition was filed on January 17, 2014,
`
`more than two years after the date of service of the complaint. Jd.
`
`Accordingly, Patent Owner arguesthat the Petition is untimely under
`
`Section 315(b). PO Resp. 10-25; Prelim. Resp. 2-15.
`
`Weare not persuaded by Patent Owner’s arguments. 35 U.S.C.
`
`§§ 251, 252 recite, respectively, that
`
`through error, deemed wholly or
`is,
`[w]henever any patent
`partly inoperative or invalid,
`.
`.
`. the Director shall, on the
`surrender of such patent
`. .. ,
`reissue the patent for the
`invention disclosed in the original patent” and that “[t]he
`surrenderof the original patent shall take effect upon the issue
`of the reissued patent” (emphasis added).
`
`The reissue patentis a distinct property right that “does not simply replace
`
`an original patent nunc pro tunc.” Intel Corp. v. Negotiated Data Solutions,
`
`Inc., 703 F.3d 1360, 1364 (Fed. Cir. 2012) (citing Spectronics Corp. v. HB.
`
`
`
`IPR2014-00358
`Patent RE43,707 E
`
`Fuller Co., 940 F.2d 631, 637—38 (Fed. Cir. 1991)). 35 U.S.C. § 315(b)
`
`recites that
`
`[a]n inter partes review may not be instituted if the petition
`requesting the proceeding is filed more than 1 year after the
`date on which the petitioner, real party of interest, or privy of
`the petitioner is served with a complaint alleging infringement
`ofthe patent (emphasis added).
`
`Here, Patent Ownerserved upon Petitioner a complaint alleging
`
`infringementof the 7849 patent. See Ex. 2002. Patent Owner acknowledges
`
`that this original complaint doesnot allege infringement of the ’707 patent.
`
`Tr. 35:22-23. The reissuance ofthe 849 patent as the ’707 patent did not
`continue the 849 patent, but rather resulted in the surrenderofthe 849
`
`patent and the issuance of a new patent, the ’707 patent. Patent Owner
`
`served Petitioner with an amended complaintalleging infringementof the
`°707 patent on January 17, 2013. See Ex. 2004. The Board accorded the
`instant Petition a filing date of January 17, 2014. See Paper 3. Patent
`
`Owneracknowledgesthat the claims challengedin the Petition were not in
`
`the original ’849 patent. Tr. 36:18—20. Accordingly, Section 315(b) is not
`
`applicable here because the Petition was not filed more than one yearafter
`
`Petitioner was served with the amended complaintfirst alleging
`
`infringement of the ’707 patent.
`
`Wealso are not persuaded by Patent Owner’s argumentthat the
`claims of the ’849 patent are substantially identical to the claims of the ’707
`
`patent. Therefore, under Section 252, the ’849 patent is not the same as the
`
`°707 patent for the purposes of Section 315(b). Prelim. Resp. 6-8, 12-14.
`
`35 U.S.C. § 315(b) requires that “the petitioner .
`
`.
`
`. is served with a
`
`complaint alleging infringementofthe patent” (emphasis added).
`
`
`
`IPR2014-00358
`Patent RE43,707 E
`
`Accordingly, we are not persuaded by Patent Owner’s argument and
`
`determinethat the Petition is not barred under Section 315(b).
`
`B. Obviousness ofClaims 101-104 over Greene and Kamada
`
`I. Overview
`
`Petitioner argues that Greene and Kamada render obviousclaims 101-
`
`104 of the ’707 patent. A patent claim is obvious under 35 U.S.C. § 103(a)
`
`if the differences between the claimed subject matter and the priorart are
`
`“such that the subject matter[,] as a whole[,] would have been obviousat the
`
`time the invention was madeto a person having ordinary skill in the art to
`
`which said subject matter pertains.” KSR Int’] Co. v. Teleflex Inc., 550 US.
`
`398, 406 (2007). The question of obviousness is resolved on the basis of
`
`underlying factual determinations, including: (1) the scope and content of
`
`the priorart; (2) any differences between the claimed subject matter and the
`prior art; (3) the level of skill in the art; and (4) objective evidence of
`nonobviousness,i.e., secondary considerations. See Graham v. John Deere
`Co., 383 U.S. 1, 17-18 (1966).
`
`2. Greene (Ex. 1008)
`Greene teaches methodsfor correcting spatial non-uniformities in the
`brightness of electronic displays. Ex. 1008, 1:8-13. Greene describes
`
`“several methods for keeping a resultant luminancesubstantially constant
`
`using active control means.” Jd. at 8:45—47. “The correction methods
`
`incorporate the measurement of brightness characteristics of the display” and
`
`“can be applied to selected pixels orall of the pixels.” Jd. at 4:34-36. The
`
`measureddata is stored.and then “selectively retrieved during the operation
`
`of the display and usedto scale and/orinterpolate drive signals in real-time.”
`
`Id. at 4:39-44. Corrections are made with respect to a chosen reference
`
`
`
`IPR2014-00358
`Patent RE43,707 E
`system such that any remaining gradual and abrupt brightness non-
`uniformities over the selected pixels fall below the human eye’s detectable
`
`luminance threshold under intended viewing conditions. /d. at 4:51-55.
`
`The luminancecorrection methodis illustrated in Figure 4, reproduced
`
`below:
`
`Figure 4 is a block diagram of the luminance correction method,
`whichincludes data input, luminancescaler/adder 56, central random access
`
`memory 54, display controller 52, row drivers 52a, and column drivers 52b.
`
`’ Ex. 1008, 10:48-58. Luminancescaler/adder 56 receives data input, such as
`
`video data, and recomputesthe color coordinates of the received data input
`
`based on luminanceratios stored in central random access memory 54. Jd. at
`
`10:53-58. Asa result of this recomputing, the color coordinates are
`
`normalized for the intended light display. Jd. at 10:59-61. Then, display
`
`controller 52, which is operatively connected to row drivers 52a and column
`
`drivers 52b, receives the normalized data. Jd. at 10:53-56. A modified pixel
`
`stream then is output to drivers 52a and 52b. Jd. at 11:8-11.
`
`10
`
`
`
`IPR2014-00358
`Patent RE43,707 E
`
`3. Kamada (Ex. 1004)
`
`Kamadateachesa display correction circuit and a display apparatus
`
`that correct uneven image appearance causedby the display apparatus.
`Ex. 1004 § 2. Kamada describes a memory thatstoresfirst data indicative of
`
`size and position of a rectangular region on the display screen and second
`
`data indicative of gray level changesin a surrounding region around the
`rectangular region in an isometric mannerwith respect to a horizontal and
`vertical direction. Jd. ¢ 19. An image processing unit adjusts gray level of
`
`image data in responseto the first data and second data. Id. The image
`
`processing apparatusis illustrated in Figure 1, reproduced below:
`FIG.1
`
`
`
`Figure 1 is a diagram ofthe liquid crystal display apparatus that
`includes image processing apparatus 11, memory 12, signal source 13, and
`
`LIQUID CRYSTAL
`DISPLAY PANEL
`
`liquid crystal display panel 14. Ex. 1004 4] 41-42. Signal source 13
`supplies image data signals for display on liquid crystal display panel 14.
`Id. 4 42. Image processing apparatus 11 corrects the image data signals
`based on correction data stored by memory 12 and supplies the corrected
`
`image data signals to liquid crystal display panel 14. /d.
`
`An areato be corrected is specified by two points correspondingto the
`
`top left corner and the bottom right corner of a rectangular region. Jd. | 45.
`
`11
`
`
`
`IPR2014-00358
`Patent RE43,707 E
`
`Constant correction value k, which corresponds to an amountofshift by
`
`whicha graylevel is changed,is applied to the rectangular region. Id.
`
`_
`
`Constant correction value k is decreased gradually in a region surrounding
`the rectangular region, where the surrounding region has a specified width
`
`surroundingthe rectangular region. Jd. Thus, the correction valueis k at the
`
`edge of the rectangular region and decreasesto zero at the edge ofthe
`
`surrounding region. Jd.
`
`4. Analysis
`
`Petitioner argues that Greeneteachesall of the limitations of
`
`independentclaim 101, except for the limitation “wherein the tolerance level
`varies among pixels ofthe display.” Pet. 38-42. Petitioner argues that
`
`Kamadateachesthat a constant correction value is applied to a rectangular
`
`region, and the correction value gradually decreases in the surrounding
`
`region until it becomeszero. Pet. 40 (citing Ex. 1004 445). Petitioner
`
`further argues that both Greene and Kamadaare directed to suppressing non-
`
`uniformity or unevennessoflight-output in pixel displays and that a person
`
`with ordinary skill in the art would have had reason to combine the teachings
`
`of Greene and Kamadain orderto reducethe size of correction data that
`
`needsto be stored, an advantage taught by Kamada. Pet. 40-41 (citing
`
`Ex. 1004 7 47).
`
`.
`
`Patent Ownercontends that Kamadafails to teach that “the tolerance
`
`level varies among pixels of the display.” PO Resp. 6-9. Patent Owner
`
`specifically argues that Kamada teaches correcting an uneven appearance,
`
`but fails to teach a “different ‘tolerance level’ of one pixel versus another.”
`
`PO Resp.6.
`
`
`
`IPR2014-00358
`Patent RE43,707 E
`
`Weare persuaded by Patent Ownerthat Kamadafails to teach that
`
`“the tolerance level varies among pixels of the display.” As discussed
`
`above, we construe the term “tolerance level” to mean the permissible
`
`amountof deviation in luminosity thatstill provides an apparently uniform
`
`display. See supra Section I.E.1. As argued by Petitioner, Kamada teaches
`
`the application of a constant correction value in a specified region and the
`
`decrease of the constant correction value in the region surrounding the
`
`specified region. See Pet. 40 (citing Ex. 1004 4 45). The correction value
`
`corresponds to an amountof shift by whicha gray level is changed.
`Ex. 1004 9 45. Thatis, the correction value defines the amountofgray level
`
`shift applied to each pixel. See Tr. 12:17-24. Therefore, the correction
`
`value and “tolerance level” are independent values, and, accordingly, we are
`
`not persuaded that Kamada’s teaching of a correction value meets the
`
`limitation “the tolerance level varies among pixels of the display.”
`
`Petitioner acknowledgesthat the constant correction value and
`tolerance levels are not the same values. Tr. 12:10-16. Petitioner, however,
`
`contendsthat the correction value andtolerance level are related, such that,
`
`for example, the lower the tolerance, the more correction that will be
`
`applied. /d. Petitioner also argues that “reducing the correction for pixels
`
`located in the surrounding region at the edge of the display implicitly
`
`recognizes that the threshold or tolerance level for pixels depends on the
`
`position of the pixei in the display.” Pet. 40. We are not persuadedthat this _
`
`can be inferred from Kamada. As discussed above, Kamada teaches the
`
`application of a constant correction value to pixels, and Kamadaissilent as
`
`to the application of the correction value based on a “tolerance level.” See
`
`Ex. 1004 745. Although Kamadateachesthe application of the constant
`
`13
`
`
`
`IPR2014-00358
`Patent RE43,707 E
`
`correction value based onthe location of the pixel, Kamada applies the same
`
`correction value regardless of the luminosity of the pixel. Ex. 1004 { 45; see
`
`Tr. 12:17-24. As such, Kamada’s constantcorrection value is applied
`
`regardless of any “tolerance value,” and, therefore, we do not infer that an
`
`increase or decrease in the correction value would be based on a “tolerance
`
`value.”
`In addition, Patent Ownerobjects to Petitioner’s discussion of
`paragraph 69° of Kamadawith respectto the limitation “wherein the
`
`tolerance level varies among pixels of the display” because Patent Owner
`
`argues that Petitioner raises this argumentforthefirst time at the hearing,
`
`and did not presentthis rationale in the Petition. Tr. 25:19—23; see PO
`
`Resp.3; Tr. 19:21-25, 20:6—8. We have reviewed Petitioner’s arguments
`
`with respect to claim 101 in the Petition, and we agree with Patent Owner
`
`that Petitioner did not present an analysis in the Petition that relies on
`
`paragraph 69 of Kamadaas teaching “wherein the tolerance level varies
`among pixels of the display.” Instead, the Petition focused on the
`applicability of paragraphs 45 and 47 of Kamadato the limitation “wherein
`
`the tolerance level varies amongpixels of the display.” See Pet. 39-40.
`
`Accordingly, Petitioner’s argument that paragraph 69 teachesthis limitation
`
`is anew argument, and wewill not considerit for the purposesofthis
`
`Decision. See Office Patent Trial Practice Guide, 77 Fed. Reg. 48,756,
`
`° Paper 20 identifies Patent Owner’s objection as to paragraph 49.
`Tr. 25:19-23. However, we recognize this to be a typographicalerror.
`Duringoral hearing, Patent Ownerclearly identified paragraph 69, and,
`therefore, we address Patent Owner’s objection as to paragraph 69.
`
`14
`
`
`
`IPR2014-00358
`Patent RE43,707 E
`
`48,768 (Aug. 14, 2014) (“No new evidence or arguments may be presented
`
`at oral argument.”).
`
`Il.
`
`CONCLUSION
`Weare not persuadedthat Petitionerhas demonstrated bya
`preponderanceofthe evidence that claims 101—104 would have been
`
`obvious over Greene and Kamada.
`
`IV. ORDER
`
`Accordingly,it is hereby:
`
`ORDEREDthat, based on the grounds underreview, claims 101-104
`
`of U.S. Patent No. RE43,707 E have not been shown by a preponderance of
`
`.
`the evidence to be unpatentable; and
`FURTHER ORDEREDthatthis is a Final Written Decision ofthe
`
`Board under 35 U.S.C. § 318(a), and parties to the proceeding seeking
`
`judicial review of this decision must comply with the notice and service
`
`requirements of 37 C.F.R. § 90.2.
`
`
`
`IPR2014-00358
`Patent RE43,707 E
`
`For PETITIONER:
`
`Lead Counsel
`Marc Weinstein
`QUINN EMANUEL URQUHART& SULLIVAN LLP
`marcweinstein@quinnemanuel.com
`
`FOR PATENT OWNER:
`
`Lead Counsel
`Kerry T. Hartman
`HARTMAN PATENTS PLLC
`khartman@hartmanpatents.com
`
`Back-up Counsel
`Jeffrey Morgan
`BARNES & THORNBURG LLP
`- jeff.morgan@BTlaw.com
`
`16
`
`
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