`
`
`
`
`
`Case IPR2016-01622
`Patent 6,850,414
`Attorney Docket No. 160831-002USIPR
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`KINGSTON TECHNOLOGY COMPANY, INC.,
`
`Petitioner
`
`v.
`
`POLARIS INNOVATIONS LTD.,
`
`Patent Owner
`____________
`
`Case IPR2016-01622
`
`Patent 6,850,414 B2
`Priority July 2, 2001
`Issued February 1, 2005
`Title: ELECTRONIC PRINTED CIRCUIT BOARD HAVING A PLURALITY
`OF IDENTICALLY DESIGNED, HOUSING-ENCAPSULATED
`SEMICONDUCTOR MEMORIES
`____________
`
`
`PATENT OWNER’S REPLY
`TO PETITIONER’S OPPOSITION
`TO MOTION TO AMEND
`
`
`
`
`
`
`
`
`
`
`TABLE OF CONTENTS
`
`Page
`THE BOARD HAS ALREADY DECLINED TO TRY CLAIM 4 ISSUES. .. 1
`
`I.
`
`II. THE BOARD HAS ALREADY REJECTED THE PREMISE THAT
`A MOTION TO AMEND REOPENS ALREADY DECIDED
`QUESTIONS. .................................................................................................... 3
`
`III. PETITIONER’S NEW ARGUMENTS ARE UNTIMELY AND WRONG.... 9
`
`
`
` i
`
`
`
`
`
`
`STATUTES
`
`TABLE OF AUTHORITIES
`
`Page(s)
`
`35 U.S.C. § 316(d)(2)................................................................................................. 5
`
`35 U.S.C. § 316(d)(3)................................................................................................. 5
`
`35 U.S.C. § 318(c) ..................................................................................................... 5
`
`REGULATIONS
`
`37 C.F.R. § 42.121(a)(2) ............................................................................................ 5
`
`37 C.F.R. § 42.121(b) ................................................................................................ 5
`
`ADMINISTRATIVE DECISIONS
`
`Amerigen Pharms. Ltd. v. Shire LLC, IPR2015-02009,
`Paper 8 (PTAB Apr. 18, 2016) ............................................................................. 6
`
`Amerigen Pharms. Ltd. v. Shire LLC, IPR2015-02009,
`Paper 36 (PTAB Jan. 10, 2017) ............................................................................ 7
`
`Amerigen Pharms. Ltd. v. Shire LLC, IPR2015-02009,
`Paper 38 (PTAB Mar. 31, 2017) .............................................................. 1, 6, 7, 8
`
`Idle Free Systems v. Berstrom, Inc., IPR2012-00027,
`Paper 26 (PTAB June 11, 2013) ........................................................................... 7
`
`Kingston Tech. Co., Inc. v. Polaris Innovations Ltd., IPR2016-01623,
`Paper 7 (PTAB Feb. 15, 2017) ............................................................................. 2
`
`Kingston Tech. Co., Inc. v. Polaris Innovations Ltd., IPR2016-01623,
`Paper 16 (PTAB Apr. 6, 2017) ............................................................................. 2
`
`Kingston Tech. Co., Inc. v. Polaris Innovations Ltd., IPR2017-00974,
`Paper 8 (PTAB Aug. 14, 2017) ............................................................................ 2
`
`
`
` ii
`
`
`
`
`
`EXHIBIT LIST
`
`Exhibit 2001
`
`Exhibit 2002
`
`Exhibit 2003
`
`Exhibit 2004
`
`Cara Garretson. “More DRAM vendors involved in Justice
`Department probe.” IDG News Service July 21, 2002.
`Computer World, Inc. November 21, 2016.
`“Error Correction Code in SoC FPGA-Based Memory
`Systems.” Altera Corporation April 2012.
`“133 MHz PC SDRAM 64-Bit Non-ECC/Parity 144 Pin
`UNBUFFERED SO-DIMM SPECIFICATION.” Intel, Revision
`1.0C. August 2000
`“PC SDRAM Serial Presence Detect (SPD) Specification.”
`Intel, Revision 1.2B. November 1999.
`Exhibit 2005 Declaration of Nathan Nobu Lowenstein in support of Motion
`for Admission Pro Hac Vice
`Institution Decision, Amerigen Pharms. Ltd. v. Shire LLC,
`IPR2015-02009, Paper 8 (PTAB Apr. 18, 2016)
`Patent Owner’s Motion To Amend, Amerigen Pharms. Ltd. v.
`Shire LLC, IPR2015-02009, Paper 14 (PTAB Jul. 18, 2016)
`Petitioner’s Opposition To Motion To Amend, Amerigen
`Pharms. Ltd. v. Shire LLC, IPR2015-02009, Paper 17 (PTAB
`Oct. 18, 2016)
`Patent Owner Reply To Petitioner’s Opposition, Amerigen
`Pharms. Ltd. v. Shire LLC, IPR2015-02009, Paper 21 (PTAB
`Nov. 17, 2016)
`Petitioner’s Request For Oral Argument, Amerigen Pharms.
`Ltd. v. Shire LLC, IPR2015-02009, Paper 27 (PTAB Dec. 9,
`2017)
`Final Written Decision, Amerigen Pharms. Ltd. v. Shire LLC,
`IPR2015-02009, Paper 38 (PTAB Mar. 31, 2017)
`Exhibit 2012 Deposition Transcript Of Vivek Subramanian (Apr. 19, 2017)
`
`Exhibit 2006
`
`Exhibit 2007
`
`Exhibit 2008
`
`Exhibit 2009
`
`Exhibit 2010
`
`Exhibit 2011
`
`Exhibit 2013
`
`Exhibit 1 To Deposition Transcript Of Vivek Subramanian
`(Apr. 19, 2017)
`
` iii
`
`
`
`
`
`Petitioner’s Opposition to Patent Owner’s Motion does not merely refuse to
`
`accept that the Board has already rejected its positions on the merits at least three
`
`times, in three separate orders across two IPRs. It also ignores a more fundamental
`
`problem. The Opposition relies from beginning to end on the false premise that the
`
`filing of a motion to amend reopens the Board’s non-institution determinations
`
`constraining the scope of the trial. But Petitioner once again ignores past rulings
`
`by the Board, where the Board already considered and rejected this premise—and
`
`held that a motion to amend triggers no requirement to prove, let alone re-prove,
`
`patentability of subject matter already recited in original non-amended claims—
`
`“especially” claims challenged and denied institution. Amerigen Pharms. Ltd. v.
`
`Shire LLC, IPR2015-02009, Paper 38 at 6 (PTAB Mar. 31, 2017) [Ex. 2011].
`
`The Board has thus already thrice rejected Petitioner’s merits positions as to
`
`the subject matter of the substitute claim. Petitioner asks the Board to revisit these
`
`questions for at least a fourth time, improperly leveraging its past failures to once
`
`again re-sculpt its arguments. The Board should reject Petitioner’s latest “‘nothing
`
`to lose’ ploy . . . to restate its disagreement with the Board’s Institution Decision in
`
`an improper new brief,” id., Paper 21 [Ex. 2010] at 12, and grant the Motion.
`
`I. THE BOARD HAS ALREADY DECLINED TO TRY CLAIM 4 ISSUES.
`
`The Petition in this case sought review of Claims 1-8 of the ’414 Patent
`
`relying on two references: Simpson and the Intel Specification. Paper 1 at 9. The
`
` 1
`
`
`
`
`
`Board denied institution on Claims 2-4 because Petitioner failed to show that any
`
`combination of asserted references was reasonably likely to render the claims
`
`obvious. Paper 7 at 14-18, 22. Dissatisfied with this outcome, Petitioner sought
`
`rehearing as to Claim 4. Paper 11. After careful consideration and explanation,
`
`the Board reaffirmed on the merits. Paper 16.
`
`Petitioner then filed a second Petition attacking Claim 4. Kingston Tech.
`
`Co., Inc. v. Polaris Innovations Ltd., IPR2017-00974, Paper 1. It raised the same
`
`references as the first Petition (Simpson and the Intel Specification1) plus three
`
`others. Id. at 9-10. The Board again denied institution, explaining that the second
`
`Petition’s arguments and references, including its new references, still failed to
`
`raise a probability of unpatentability, and indeed were “‘substantially the same” as
`
`those in the first petition.” Id., Paper 8 at 13 (PTAB Aug. 14, 2017).2
`
`
`1 Petitioner called the Intel Specification a different name this time, and said
`
`it was a new reference, but it was the same reference. Id. Paper 6 at 15-17 (POPR).
`
`2 Petitioner’s August 18 Opposition to the Motion to Amend contumaciously
`
`ignores the Board’s denial of institution in -00974. Instead, Petitioner continues to
`
`insist that the Motion should be denied, for, inter alia, “the reasons set forth . . . in
`
`Petitioner’s IPR2017-00974 Petition.” Opposition at 17. By that logic, the Motion
`
`should be granted, for, inter alia, the reasons that the -00974 Petition was denied.
`
` 2
`
`
`
`
`
`Patent Owner’s Motion to Amend in the present case is thus supported by at
`
`least three decisions of the Board. It seeks to cancel instituted Claims 1 and 5-8
`
`and add one substitute claim 9. Claim 9 simply adds to the limitations of instituted
`
`Claim 8 the limitation of Claim 4—the exact same limitation that the Board has
`
`found, three times, not disclosed by Petitioner’s references and arguments:
`
`9. The printed circuit board according to claim 1, wherein: said
`printed circuit board has a width of 5.25 inches and has a height of 1
`to 1.2 inches perpendicular to said contact strip.
`
`Patent Owner’s Motion to Amend raises no new patentability issues and adds
`
`no newly drafted limitations. The Board’s prior decisions as to this subject matter,
`
`including the Board’s determinations in the Institution Decision and Decision on
`
`Request for Rehearing, cannot be revisited by Petitioner yet again now. And even
`
`if they could, Petitioner’s Opposition ultimately raises, yet again, materially the
`
`same arguments based on materially the same references that it made before.
`
`II. THE BOARD HAS ALREADY REJECTED THE PREMISE THAT A
`MOTION TO AMEND REOPENS ALREADY DECIDED QUESTIONS.
`
`Patent Owner’s Motion adds a substitute claim, Claim 9, that has a limitation
`
`the Board has already repeatedly found was not in the references raised by
`
`Petitioner. Patent Owner is entitled to rely on those prior rulings for purposes of
`
`its Motion to Amend. Any other result would frustrate the statutory framework,
`
`create complicated procedural problems, and contradict the Board’s past rulings.
`
` 3
`
`
`
`
`
`Petitioner argues that the Motion reopens already-decided issues in this case.
`
`That cannot be true, unless it is impossible for a motion to amend to rely upon the
`
`Board’s institution decision. This Motion is specifically drafted to not raise any
`
`new issues. Its proposed claim addresses only a limitation in a claim already
`
`issued, already challenged, already denied review twice, and already denied
`
`reconsideration. If this Motion opens up new issues for decision, all new claims
`
`necessarily do so. Thus, Petitioner’s theory has to be that any motion to amend
`
`must open up the patent owner to attack based on anything already decided against
`
`Petitioner. But no statute or rule suggests that the act of filing a motion to amend
`
`deletes—or even affects—the Board’s prior decision on Institution, grants
`
`Petitioner a do-over on its failures to meet its burden that the Board has already
`
`decided, or reopens any issues already adjudicated. Such a conclusion would
`
`ignore, not only the statutory assignment of the burden to Petitioner, and
`
`Petitioner’s prior failure to comply with the rules, but also the Board’s existing
`
`decisions in the case. It would render the preliminary proceeding in the IPR a
`
`nullity. What is more, it would create a perverse disincentive for patent owners to
`
`eschew their right to seek to amend their patent—or perhaps even create a perverse
`
`incentive for them to inject new issues in their amendments and avoid old ones.
`
`The proposed amendment clearly distinguishes the substitute claim from
`
`every ground of invalidity. New grounds of unpatentability could not be raised
`
` 4
`
`
`
`
`
`against this subject matter without also, in effect, being raised against non-
`
`instituted claims.3 For this reason, the Motion cannot be denied on any basis that
`
`would substantively contradict the Board’s rulings in the Institution Decision and
`
`the limits that it set on the scope of trial in this case. Doing so would effectively
`
`adopt an untimely new challenge to the patentability of non-instituted Claim 4.4
`
`Nor do policy considerations (Opposition at 1-2) support Petitioner’s theory.
`
`IPRs can never examine claims but only adjudicate them—and IPRs confine all
`
`new claims to be within the scope of existing, uncanceled claims of the patent. 35
`
`U.S.C. §§ 316(d)(3), 318(c); 37 C.F.R. §§ 42.121(a)(2), (b). There is therefore not
`
`even a theoretical danger of granting Patent Owner any additional, undeserved
`
`scope of patent protection in this case. Petitioner’s own failure, in three tries, to
`
`mount a challenge to this patented subject matter before the Board does not prevent
`
`any other person, not in privity or otherwise barred, from challenging the new or
`
`old claims in the future. Nor is Petitioner barred from continuing to do so in court.
`
`Unsurprisingly, Petitioner cites no Board decision supporting its startling
`
`
`3 That would also contradict the AIA’s structure, which contemplates using
`
`motions to amend as tools to eliminate disputes in IPR. See 35 U.S.C. § 316(d)(2).
`
`4 Thus, the Motion may be denied only on bases (e.g., procedure or burden
`
`issues) that do not conflict with the Board’s reason for partially denying institution.
`
` 5
`
`
`
`
`
`insistence that the Motion allows it to circumvent the shortcomings of its Petitions.
`
`Yet Petitioner ignores the only decision on point: Amerigen, in Case No. IPR2015-
`
`02009. In that decision, the Board has already rejected Petitioner’s premise.
`
`In Amerigen, as in this case, the Board denied institution on some, but not
`
`all, challenged claims. Id., Paper 8 [Ex. 2006] at 1. The patent owner, as in this
`
`case, filed no response, but only filed a motion to amend, seeking to cancel all
`
`instituted claims and add a substitute claim that confined its limitations only to
`
`those of unchallenged or non-instituted claims. Id., Paper 14 [Ex. 2007] at 1.
`
`In opposition, the Amerigen petitioner, like Petitioner here, argued that
`
`because the patent owner had moved to add a substitute claim, the patent owner
`
`now had to prove patentability of the substitute claim over all known prior art,
`
`irrespective of the art and arguments raised in the petition, and irrespective of
`
`whether the claim was limited to subject matter on which institution had already
`
`been denied. Id., Paper 17 [Ex. 2008] at 3-5. And, like Petitioner here, the
`
`Amerigen petitioner (i) raised a multiplicity of other references and unpatentability
`
`arguments that had been allegedly raised against the non-instituted claims in other
`
`cases but not in the petition, and (ii) raised numerous policy arguments against
`
`adding the substitute claim to the patent without sufficient scrutiny. Id. at 5-8.
`
`The Board rejected the petitioner’s contentions, cancelled the hearing, and
`
`granted the motion to amend. Id., Paper 38 [Ex. 2011] at 7; see also id., Paper 27
`
` 6
`
`
`
`
`
`[Ex. 2010] at 3-4; id., Paper 36 at 1. The Board declined the petitioner’s invitation
`
`to reconsider whether its initial institution decision was correct based on the new
`
`merits arguments raised in the opposition to the motion to amend, and its invitation
`
`to consider whether or not the patent owner candidly addressed the new references.
`
`Instead, the Board “agree[d] with Patent Owner that ‘there is no requirement for
`
`[the patent owner] to prove, after the Institution Decision, that original non-
`
`amended claims are patentable over all potential prior art, especially non-instituted
`
`claims.’” Ex. 2011 at 6 (alteration marks omitted). The Board noted that the
`
`substitute claim’s limitations were not “‘newly drafted’” like the claims in Idle
`
`Free Systems v. Berstrom, Inc., IPR2012-00027, Paper 26 (PTAB June 11, 2013),
`
`but, instead, included only limitations of non-instituted or non-challenged claims,
`
`Ex. 2011 at 4-5. Accordingly, the Board found that the patent owner’s filing of a
`
`motion to amend did not impose a “burden of showing the substitute claim’s
`
`patentable distinction over not only the prior art asserted in the petition, but also all
`
`prior art of record in the initial patent prosecution, reissue proceeding, prior
`
`litigations and other prior art known to patent owner.” Ex. 2011 at 6.
`
`The Board’s decision in Amerigen was correct. And the same result is
`
`correct here. Here, as in Amerigen, the Motion to Amend does not raise any new
`
`“newly drafted” claim limitations, or any patentability issues except those already
`
`resolved as to non-instituted claims. It merely adds a limitation already considered
`
` 7
`
`
`
`
`
`and analyzed by the Board. Here, as in Amerigen, Petitioner’s demand that Patent
`
`Owner show substitute Claim 9’s patentability over not only the prior art in the
`
`Petition, Opposition at 3, but all prior art known or of record in other proceedings,
`
`id. at 6, is inapposite. As in Amerigen, the Motion to Amend should be granted.
`
`Amerigen’s facts are, unsurprisingly, not absolutely identical to this case.
`
`The substitute claim in Amerigen was the same as an instituted claim except that it
`
`deleted from its multiple dependencies the dependencies on instituted claims, Ex.
`
`2006 at 2, whereas by comparison substitute Claim 9 in this case is the same as an
`
`instituted claim except that it adds a limitation found in a non-instituted claim. It is
`
`a distinction without a difference. The fact that the new claim in Amerigen was
`
`multiply dependent does not distinguish it in any way from the claim here. As the
`
`Board pointed out in Amerigen, a “‘multiple dependent claim is considered in the
`
`same manner as a plurality of single dependent claims.” Ex. 2011 at 4 (emphasis
`
`added) (quoting MPEP 608.01(n)). No rule distinguishes multiple dependent
`
`claims from other claims for this purpose. And the Board’s ultimate reasoning in
`
`granting the motion to amend in Amerigen rested, not on the fact that the canceled
`
`and substitute claims happened to be multiply dependent, but on the determination
`
`that the patent owner’s motion to amend triggered no requirement for the patent
`
`owner to revisit the patentability of the subject matter of non-amended claims,
`
`“especially non-instituted claims.” Id. at 6. The same principle governs here.
`
` 8
`
`
`
`
`
`III.
`
`PETITIONER’S NEW ARGUMENTS ARE UNTIMELY AND WRONG.
`
`Petitioner submits new arguments and exhibits with its Opposition. But
`
`these arguments are procedurally improper, grossly untimely, and unpersuasive.
`
`Claim 4 recites “the printed circuit board according to Claim 1, wherein:
`
`said printed circuit board has a height of 1 to 1.2 inches perpendicular to said
`
`contact strip.” Ex. 1001 [’414 Pat.] Cl. 4. Petitioner’s Petitions already challenged
`
`the height limitation of Claim 4. Both Petitions failed to show unpatentability of
`
`this limitation. Petitioner now attempts to use its Opposition as an untimely
`
`backdoor attempt to again re-litigate that limitation. Because both Patent Owner
`
`and the Board have already refuted Petitioner’s references and arguments in the
`
`Patent Owner Preliminary Responses and Institution Decisions in the two IPRs,
`
`Patent Owner cannot be required to re-litigate these issues with Petitioner again.
`
`For example, Simpson is the primary reference that Petitioner relied upon in
`
`both Petitions. The Board already ruled three times that Petitioner has failed to
`
`show unpatentability based on Simpson in combination with any other reference.
`
`In its Opposition, Petitioner relies again primarily on Simpson. Opposition 4-17.
`
`These new arguments and evidence are no more timely here, with the Opposition,
`
`than they would have been with Petitioner’s Request for Rehearing, Papers 11, 16.
`
`Nor is Petitioner’s “new” expert testimony (Exs. 1016, 1022) timely. It
`
`purports to addresses patentability issues applicable to non-instituted Claim 4, so it
`
` 9
`
`
`
`
`
`can hardly be timely now. It is not responsive to any new evidence, for none was
`
`submitted with the Motion. And much of it (Ex. 2016) is the same testimony
`
`Petitioner already filed in -00974, in which the Board already denied institution.
`
`The IPR statute and rules simply do not allow this “try, try again” gamesmanship.
`
`But even if Petitioner’s premise that the Motion re-opened the doors the
`
`Institution Decision closed were correct, and even if its “new” evidence and
`
`arguments were timely, there are still further reasons—in addition to those that
`
`Patent Owner already argued in two POPRs and the Board already found in two
`
`institution denials—why Petitioner’s references fail to disclose the Claims. For
`
`example, Claim 1, from which substitute Claim 9 depends, requires the “housing of
`
`each one of said semiconductor memories . . . being individually connected to said
`
`printed circuit board.” Ex. 1001 at Cl. 1. Simpson’s alleged memory chips are
`
`connected to sockets, that are in turn connected to its printed circuit board. E.g.,
`
`Pet. at 20; Ex. 1002 [Simpson] at Fig. 1, 13:18-28. Petitioner’s expert admitted in
`
`cross-examination that, where a memory chip is not directly connected to a printed
`
`circuit board but is instead connected through an intermediary with receptacles, the
`
`housing of the chip “is not individually connected to the printed circuit board” as
`
`that phrase is used in the Patent. Ex. 2012 at, e.g., 234:6-237:22. In connection
`
`with the drawing reproduced below (Ex. 2013, marked as deposition Exhibit 1), on
`
`which the upper housing is a memory chip, connected to receptacles on the lower
`
` 10
`
`
`
`
`
`housing, which is a
`
`second memory chip
`
`and, in turn, is connected
`
`to the printed circuit
`
`board, Dr. Subramanian
`
`testified that the housing of the upper memory chip pictured is not “individually
`
`connected to the printed circuit board,” as that phrase is used in the Patent. Id.
`
`The drawing, however, is no different in this respect from Simpson, whose “chip”
`
`is connected to the PCB through a socket with receptacles. Ex. 1002 at 13:18-28.
`
`Nor was there motivation to utilize or modify Simpson’s socketed invention
`
`as claimed. Unlike the Patent (Ex. 1001 [’414 Pat.] at, e.g., Fig. 1; 2:37-42; 2:51-
`
`53; 4:7-8), Simpson teaches no reason or benefit for the claimed layout of sockets
`
`on the PCB. Further, Simpson is from an ancient epoch of computer DRAM
`
`relative to the Patent’s priority date, and the intervening time rendered Simpson’s
`
`problem, solution and rationale obsolete. Simpson’s raison d’être was that, at the
`
`time, “a 16Mb module may cost as much as a whole computer,” Ex. 1002 at 11:28-
`
`31, so Simpson disclosed an upgradable memory module with sockets that could
`
`be filled in later to eliminate the need to replace the module. Id. at 11:25-28; 11:3-
`
`6; 8:22-24; 11:8-10. These needs were not present by the time of the 2001 Patent.
`
`Nor does Bechtolsheim—also already rejected by this Board in the -00974
`
` 11
`
`
`
`
`
`IPR—help Petitioner. Bechtolsheim is not concerned with orientation of DRAM
`
`memory chips on a DRAM PCB; instead, like the prior art the Patent improved, it
`
`places all chips in the same direction without comment. Ex. 1004 [Bechtolsheim]
`
`at 3:32-39; Figs. 1a, 2a. Nor does Bechtolsheim even discuss trying to reduce
`
`height. On the contrary, where the Patent’s preferred embodiments teach one
`
`horizontal row of chips, Bechtolsheim teaches three, which is necessarily taller.
`
`Id. Figs. 1a, 1b; 4:61-5:6. Bechtolsheim does not even hint that one memory chip
`
`(the error correction chip) be vertical and the rest horizontal, as claimed.
`
`The Opposition suggests that, because Bechtolsheim shows a vertical driver
`
`chip 15 (not a memory chip), artisans would put an error correction memory chip
`
`in its place, move driver 15 under one of the horizontally oriented memory devices,
`
`or simply add a vertically oriented error correction chip—but offers no reason why,
`
`and ignores the Patent’s disclosure showing why that is not a simple design choice,
`
`in combination with Simpson or not. Compare Opposition at 20-22 with POPR 12.
`
`The Opposition, at 7-8, 15, also raises Kiehl (Exs. 1020, 1021), and attacks
`
`Patent Owner for lack of candor in not disclosing and “showing patentability over
`
`it.” But Petitioner fails to notice that Kiehl is not prior art to the Patent. Ex. 1001.
`
`The Motion was not required to raise further patentability arguments such as
`
`these, and this Reply is not the time or place to fully develop them. Petitioner’s
`
`arguments are untimely. As a matter of law and discretion, they should be rejected.
`
` 12
`
`
`
`
`
`Date: September 18, 2017
`
`Respectfully submitted,
` / Kenneth J. Weatherwax /
`Kenneth J. Weatherwax, Reg. No. 54,528
`Lowenstein & Weatherwax LLP
`
`
`
`
`
`
`
`Case IPR2016-01622
`Patent 6,850,414
`Attorney Docket No. 160831-002USIPR
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the following documents were served
`by electronic service, by agreement between the parties, on the date signed below:
`
`
`PATENT OWNER’S REPLY
`TO PETITIONER’S OPPOSITION
`TO MOTION TO AMEND
`
`Exhibits 2006-2013
`
`The names and address of the parties being served are as follows:
`
`IPR37307-0007IP1@fr.com (David Hoffman)
`IPR@sjclawpc.com (Martha Hopkins)
`
`
`
`Respectfully submitted,
`
` / Shawn Chi /
`
`Date: September 18, 2017
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
