UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`SHOPIFY, INC., PRICELINE.COM LLC, and BOOKING.COM B.V.,
`Petitioners,
`
`v.
`
`DDR HOLDINGS, LLC,
`Patent Owner.
`____________
`
`Case No.: IPR2018-010111
`U.S. Patent 9,639,876
`________________
`
`PETITIONERS’ CONSOLIDATED REQUEST FOR REHEARING
`PURSUANT TO 37 C.F.R. § 42.71(D)
`
`1 Priceline.com LLC and Booking.com B.V. filed a petition in IPR2019-00438 and
`have been joined as petitioners in this proceeding.
`
`
`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`SHOPIFY, INC., PRICELINE.COM LLC, and BOOKING.COM B.V.,
`Petitioners,
`
`v.
`
`DDR HOLDINGS, LLC,
`Patent Owner.
`____________
`
`Case No.: IPR2018-010111
`U.S. Patent 9,639,876
`________________
`
`PETITIONERS’ CONSOLIDATED REQUEST FOR REHEARING
`PURSUANT TO 37 C.F.R. § 42.71(D)
`
`1 Priceline.com LLC and Booking.com B.V. filed a petition in IPR2019-00438 and
`have been joined as petitioners in this proceeding.
`
`
`
`TABLE OF CONTENTS
`
`Case No. IPR2018-01011
`Patent No. 9,639,876
`
`Page(s)
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`APPLICABLE STANDARDS ........................................................................ 1
`I.
`II. ARGUMENT ................................................................................................... 2
`A.
`The FWD Correctly Determined that Claims 1-3, 5, 11-13 and 15 of the
`’876 Patent are Unpatentable in View of the Digital River Publications
`and Petitioners Demonstrated that Dependent Claims 7 and 17 are Also
`Unpatentable ................................................................................................ 2
`Ground 1 of the Petition Demonstrated that the Digital River
`Publications Satisfy the “Hierarchical Set of Additional Web Pages”
`Limitation of Claims 7 and 17 ................................................................. 3
`APJ DeFranco’s Dissenting-in-Part Opinion Confirms that Dependent
`Claims 7 and 17 are Unpatentable ......................................................... 11
`Petitioners Further Demonstrated that Claims 8 and 18, Which Depend
`From Claims 7 and 17, Are Unpatentable in View of the Digital River
`Publications, Which is Confirmed by APJ DeFranco’s Opinion .............. 13
`III. CONCLUSION .............................................................................................. 15
`
`1.
`
`2.
`
`B.
`
`i
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`Case No. IPR2018-01011
`Patent No. 9,639,876
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`Pursuant to 37 C.F.R. § 42.71(d), Petitioners Shopify, Inc., Priceline.com LLC
`
`and Booking.com B.V. (“Petitioners”) respectfully request rehearing of the limited
`
`portion of the Patent Trial and Appeal Board’s (“Board”) February 14, 2020 Final
`
`Written Decision (“FWD”) (Paper 34) finding that Petitioners failed to prove that
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`dependent claims 7, 8, 17 and 18 of U.S. Patent No. 9,639,876 (“the ’876 patent”)
`
`are unpatentable in view of the Digital River Publications.2 Petitioners do not seek
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`rehearing of the Board’s other findings, including with regard to dependent claims 4
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`and 14 or other prior art. Petitioners agree with the Board’s finding that claims 1-3,
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`5, 11-13 and 15 are unpatentable in view of the Digital River Publications.
`
`I.
`
`APPLICABLE STANDARDS
`Pursuant to 37 C.F.R. § 42.71(d), a party may request rehearing of a final
`
`written decision by the Board. The party requesting rehearing has the burden of
`
`showing that the decision from which rehearing is sought should be modified, and
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`“[t]he request must specifically identify all matters the party believes the Board
`
`misapprehended or overlooked, and the place where each matter was previously
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`addressed in a motion, an opposition, or a reply.” 37 C.F.R. § 42.71(d); Apple Inc.,
`
`et al. v. Uniloc Luxembourg S.A., IPR2017-00225, Paper 31, at 2 (P.T.A.B. Sept. 6,
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`2 “Digital River Publications” refers collectively to Exhibits 1004-1009. (See FWD,
`
`at 7.)
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`1
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`Patent No. 9,639,876
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`2018) (“The burden here, therefore, lies with [the requester] to show we
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`misapprehended or overlooked the matters it requests that we review.”).
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`II.
`
`ARGUMENT
`Petitioners request that the Board reconsider the FWD, in part, and find that
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`dependent claims 7, 8, 17 and 18 of the ’876 patent are unpatentable in view of the
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`Digital River Publications. Petitioners respectfully submit that the panel majority
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`misapprehended or overlooked Petitioners’ showing of unpatentability of these
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`claims in the Petition3 and accompanying expert declaration, which was unrebutted
`
`by Patent Owner. Indeed, Administrative Patent Judge (“APJ”) DeFranco’s
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`dissenting-in-part opinion states that claims 7 and 17 are unpatentable in view of the
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`Digital River Publications in light of “Petitioner’s actual argument and evidence” in
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`the Petition and accompanying expert declaration. (FWD, dissenting-in-part
`
`opinion, at 8 (italics in original); see also id., at 10 (“I am uncertain as to what more
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`the majority might expect from Petitioner to satisfy claim 7’s ‘hierarchical’
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`limitation.”) and 11 (finding that Petitioners demonstrated that dependent claims 8,
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`17 and 18 are unpatentable).)
`
`A.
`
`The FWD Correctly Determined that Claims 1-3, 5, 11-13 and 15
`of the ’876 Patent are Unpatentable in View of the Digital River
`Publications and Petitioners Demonstrated that Dependent
`Claims 7 and 17 are Also Unpatentable
`
`3 All references herein to the “Petition” are to the Corrected Petition (Paper 8).
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`2
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`Patent No. 9,639,876
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`The FWD correctly determined that claims 1-3, 5, 11-13 and 15 of the ’876
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`patent are unpatentable in view of the Digital River Publications. (FWD, at 17-31
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`and 42.) The FWD held, however, that “Petitioner does not sufficiently address the
`
`claim’s requirement that the selectable URLs connect ‘a hierarchical set of
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`additional web pages of the outsource provider website’” as claimed in dependent
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`claims 7 and 17. (Id., at 30-31.)
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`Contrary to the FWD’s latter holding, and consistent with APJ DeFranco’s
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`dissenting-in-part opinion, Petitioners submit that the Petition and accompanying
`
`expert declaration also demonstrate that dependent claims 7 and 17 are unpatentable
`
`in view of the Digital River Publications.
`
`1.
`
`Ground 1 of the Petition Demonstrated that the Digital
`River Publications Satisfy the “Hierarchical Set of
`Additional Web Pages” Limitation of Claims 7 and 17
`The FWD held that the Digital River Publications satisfy all of the limitations
`
`of claim 1, including that “the Digital River Publications describe that the DR SSS
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`brought together manufacturers and dealers to enable them to sell products via the
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`Internet, with DR SSS acting as the recited ‘outsource provider’ by providing an
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`integrated back-end commerce system.” (FWD, at 19-20; id. at 21 (holding that
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`“Web pages are served by a server belonging to Digital River,” which was “not
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`disputed by Patent Owner”); id. at 26-27 (identifying a Digital River buy page that
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`contains shopping cart functionality (Ex. 1009) as a “composite web page”).) The
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`3
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`FWD also held that the Digital River Publications teach that the DR DSS “outsource
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`provider” causes the display of “commerce object information associated with the
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`commerce object . . . . which commerce object includes at least one product
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`available for sale through the computer system of the outsource provider,” including
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`because “the Digital River Publications teach generation and transmission of a
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`second web page to a user in allowing the user to shop for products of another
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`merchant.” (Id. at 21-23.)
`
`Claim 7 depends from claim 1 and recites that “the commerce object
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`correlated with the source web page is an electronic catalog listing a multitude of
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`products offered by sale by the merchant through a website of an outsource provider,
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`and wherein the composite web page contains one or more selectable URLs
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`connecting a hierarchical set of additional web pages of the outsource provider
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`website, each pertaining to a subset of the product offerings in the electronic
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`catalog.” (Ex. 1001, at 28:33-41.) Claim 17 depends from claim 11 and recites the
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`same subject matter as dependent claim 7. (Id. at 30:15-23.)
`
`The Petition organized its showing of invalidity of claim 7 into two parts
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`corresponding to the claim’s two separate “wherein” clauses. First, the Petition
`
`demonstrated that the Digital River Publications satisfy the first wherein clause:
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`“wherein the commerce object correlated with the source web page is an electronic
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`catalog listing a multitude of products offered for sale by the merchant through a
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`4
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`website of an outsource provider.” The Petition demonstrated that the Digital River
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`Publications teach web pages that present product listings (“commerce object
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`information”) and that “complimentary products can be bundled.” (Pet., at 24 (citing
`
`Ex. 1002, ¶ 106 (expert declaration of Dr. Michael Shamos) and Ex. 1004, at 2-3).)
`
`This teaches an “electronic catalog listing a multitude of products offered for sale by
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`the merchant.” Indeed, the FWD’s finding that “the Digital River Publications teach
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`generation and transmission of a second web page to a user in allowing the user to
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`shop for products of another merchant” confirms that the Digital River Publications
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`satisfy this element. (FWD, at 21 (italics added) (citing Pet., at 19).) The Petition
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`and accompanying expert declaration next demonstrated that these products are sold
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`“through a website of the outsource provider,” i.e., the Digital River DR SSS
`
`website. (Pet., at 24 (citing Ex. 1002, ¶ 106 and Ex. 1004, at 2-3).) As referenced
`
`supra, the FWD correctly determined that the “DR SSS act[s] as the recited
`
`‘outsource provider.’” (FWD, at 19-20.) Patent Owner ignored Petitioners’ showing
`
`regarding the first “wherein” clause of claim 7 (see Paper 20, at 41-42), and as noted
`
`in APJ DeFranco’s dissenting-in-part opinion, “[a]s for the first ‘wherein’ clause,
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`the majority appears to find Petitioner’s showing is sufficient.” (FWD, dissenting-
`
`in-part opinion, at 7.)
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`Notably, Petitioners demonstrated that the Digital River Publications teach
`
`that its composite web page could itself include multiple product listings of an
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`5
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`electronic catalog, which showing was unrebutted by Patent Owner. (E.g., Pet., at
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`24 (citing Ex. 1002, ¶ 106 and Ex. 1004, at 2-3).) In any event, it is unnecessary for
`
`a single composite web page to include multiple product listings from the catalog to
`
`demonstrate that claim 7 is unpatentable. Rather, as demonstrated in the Petition
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`and discussed above, what is required is that the outsource provider’s website offers
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`an electronic catalog of products for sale (e.g., claims 7 and 17: “electronic catalog
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`listing a multitude of products offered for sale by the merchant through a website of
`
`an outsource provider), and that the composite web page includes “commerce object
`
`information associated with . . . at least one product available for sale” from the
`
`electronic catalog (e.g., claims 1 and 11: “the commerce object information is
`
`displayed . . . on a composite web page” and is “associated with the commerce
`
`object,” where “the commerce object includes at least one product available for
`
`sale”). (Pet., at 24-25 (citing Ex. 1002, ¶¶ 106 and 107).) To satisfy the added
`
`elements of claims 7 and 17, therefore, the outsource provider’s website (which may
`
`include multiple web pages) must offer for sale “a multitude of products” of an
`
`electronic catalog, but there is no requirement in claims 7 and 17 that all of such
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`products must be listed and offered for sale through the same composite web page.
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`(Id.) The composite web page instead displays “commerce object information
`
`associated with the commerce object” or electronic catalog and need not list or
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`6
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`identify all of the products in the catalog on the same page.4 To the extent the panel
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`majority held otherwise by implicitly adopting a special claim construction not
`
`proposed by any party, the majority panel erred by overlooking or misapprehending
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`Petitioners’ showing of invalidity cited above and plain language of the claims. (Id.)
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`In any event, as explained above, the Digital River Publications satisfy claims 7 and
`
`17 because the Digital River Publications teach that the Digital River composite web
`
`page can itself list and offer for sale multiple products of an electronic catalog. (Pet.,
`
`at 24 (citing Ex. 1002, ¶ 106 and Ex. 1004, at 2-3).)
`
`Second, the Petition also demonstrated that the Digital River Publications
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`satisfy the second wherein clause of claim 7: “wherein the composite web page
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`contains one or more selectable URLs connecting a hierarchical set of additional
`
`web pages of the outsource provider website, each pertaining to a subset of the
`
`product offerings in the electronic catalog.” The Petition and accompanying expert
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`declaration demonstrated that the Digital River Publications teach a composite web
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`4 The ’876 patent’s specification confirms this. (E.g., Ex. 1001, at 18:16-27
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`(disclosing that the outsource provider’s website may include multiple shopping web
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`pages and that the “main shopping page” can include “a specific product, a category
`
`of products . . . [or] a complete catalog” and “no matter what entry point was chosen,
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`the customer can navigate to every item contained in the merchant catalog . . . .”).)
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`7
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`page that displays commerce object information associated with one or more
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`products of the electronic catalog, as discussed supra at 3-7. The Petition further
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`demonstrated that the Digital River Publications disclose that the composite web
`
`page can be a buy page, which is shown in Exhibit 1009 and reproduced below:
`
`(Pet., at 25 (citing Ex. 1009, at 1).) Indeed, as described above, the FWD found that
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`this Digital River buy page is a “composite web page.” (FWD, at 26 (citing Ex.
`
`1009, at 1).)
`
`Petitioners respectfully submit that the panel majority overlooked or
`
`misapprehended Petitioners’ further showing that the Digital River Publications’
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`buy page identified above satisfies all of the added elements of the second “wherein”
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`clause of claim 7. As for the requirement for “one or more selectable URLs
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`8
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`connecting a hierarchical set of additional web pages of the outsource provider
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`website,” the Petition and accompanying expert declaration identified multiple links
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`of the buy page that allow the user to serially interact with a shopping cart to “add”
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`products to the shopping cart, “view” the shopping cart, “modify” the shopping cart
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`and “check out.” (Pet., at 25 (citing Ex. 1009, at 1, Ex. 1002, ¶ 107, and Ex. 1006,
`
`at 3-6).) The FWD in fact refers to these “add to cart,” “view cart,” “modify cart”
`
`and “check out” links when discussing the content of the composite web page.
`
`(FWD, at 26.) The panel majority states, however, that “it is not apparent that
`
`movement of bundled products to a shopping cart requires a hierarchical set of
`
`additional web pages of the outsource provider website.” (Id., at 30.) In making this
`
`latter statement, however, the panel majority overlooked or misapprehended that it
`
`is not the movement of these products that required the hierarchical set of additional
`
`web pages, but the presence of the “add to cart,” “view cart,” “modify cart,” and
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`“check out” links that requires the hierarchical set of additional web pages. The
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`links do connect a hierarchical set of additional pages, namely, pages that are
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`accessed serially by selecting these progressive links within a buy sequence to “add,”
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`“view,” “modify” and “check out,” where each page visited by selecting these links
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`pertains to a subset (e.g., one or more) of the product offerings in the electronic
`
`catalog that the user has selected for purchase. (Pet., at 25 (citing Ex. 1009, at 1, Ex.
`
`1002, ¶ 107, and Ex. 1006, at 3-6).) And, as with the first “wherein” clause of claim
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`9
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`7, Petitioners’ showing of unpatentability regarding these claim elements is virtually
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`uncontested because Patent Owner again ignored Petitioners’ showing and did not
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`rebut Petitioners’ detailed showing or Petitioner expert’s statement that a POSITA
`
`would have known that the “check out” link would “require[] a number of additional
`
`web pages.” (See Paper 20, at 41-42 and Ex. 1002 at para. 107.)
`
`The Petition and accompanying expert declaration demonstrated that the
`
`composite web page included “one or more selectable URLs connecting a
`
`hierarchical set of additional web pages of the outsource provider website, each
`
`pertaining to a subset of the product offerings in the electronic catalog.” The
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`selectable URLs identified above are “view cart,” “modify cart,” or “check out”
`
`links, which cause display of additional web pages. See Pet., at 24-25; see also Ex.
`
`1002, at 107. A POSITA would recognize that the “view cart” or “modify cart” link
`
`allows a user to navigate from the composite page to a different shopping cart web
`
`page that displays the contents of the shopping cart, i.e., multiple products from the
`
`electronic catalog. Id. Accordingly, the Petition demonstrated that the “view cart”
`
`or “modify cart” links connect the composite web page, i.e., the buy page of Ex.
`
`1009 (shown above), to a different web page, i.e., the shopping cart web page served
`
`by the DR SSS that displays the products from the product catalog that have been
`
`added to the shopping cart. See Pet., at 24-25; see also Ex. 1002, at 107.
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`Additionally, a POSITA would recognize that selection of the “check out” link
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`10
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`allows the user to navigate from the composite web page, the buy page of Ex. 1009
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`(shown above), to a checkout web page that requires a purchase process that requires
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`a number of additional web pages. See Pet., at 24-25; see also Ex. 1002, at 107.
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`Patent Owner does not rebut the assertion that the purchase process requires a
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`number of additional web pages. See Paper 20, at 41-42. Accordingly, the Petition
`
`demonstrated that the “view cart,” “modify cart,” and “checkout” links satisfy the
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`second “wherein” clause of claims 7 and 17.
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`Accordingly, Petitioners demonstrated that claim 7 is unpatentable in view of
`
`the Digital River Publications. Claim 17 recites the same subject matter as claim 7
`
`and is unpatentable for the same reasons.
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`2.
`
`APJ DeFranco’s Dissenting-in-Part Opinion Confirms that
`Dependent Claims 7 and 17 are Unpatentable
`APJ DeFranco’s thorough analysis in his dissenting-in-part opinion further
`
`demonstrates that the above-identified portions of the Digital River Publications—
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`which were identified in the Petition and ignored by Patent Owner—satisfy the
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`limitations of dependent claims 7 and 17. (FWD, dissenting-in-part opinion, at 7-
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`11.) APJ DeFranco’s opinion is summarized as follows:
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` Petitioners’ showing in the Petition and accompanying expert
`
`declaration demonstrates that the Digital River Publications satisfy the
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`first “wherein” clause of claim 7 and “[a]s for the first ‘wherein’ clause,
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`11
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`the majority panel appears to find that Petitioner’s showing is
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`sufficient.” (Id. at 7.)
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` Petitioners’ showing also demonstrates that the Digital River
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`Publications satisfy the second “wherein” clause of claim 7, “the
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`majority’s analysis . . . fails to account for Petitioner’s actual argument
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`and evidence that the Digital River Publications meet the ‘hierarchical’
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`limitation of claim 7,” and “I am uncertain as to what more the majority
`
`might expect from Petitioner to satisfy claim 7’s ‘hierarchical’
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`limitation.” (Id. at 8, 10.)
`
`Importantly, APJ DeFranco’s opinion that the Digital River Publications’ buy
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`page identified by Petitioners “is a composite web page” mirrors the majority panel’s
`
`holding. (FWD, at 26 (“We agree”).) In addition, APJ DeFranco’s opinion that this
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`buy page also satisfies the final requirement in claim 7 for “one or more selectable
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`URLs connecting a hierarchical set of additional web pages of the outsource provider
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`website” is exactly correct. APJ DeFranco’s opinion states:
`
` The Digital River Publications’ buy page (i.e., the “composite web
`
`page”) includes links to “add,” “view,” “modify” and “check out” with
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`regard to a shopping cart and the additional pages accessed via these
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`links are a “‘hierarchical set of additional pages,’ as required by
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`claim 7” because these “selectable URLs [are] arranged to operate
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`12
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`serially such that each URL link is subordinate to the one before it.
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`That is the case with the buy page taught by the Digital River
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`Publications. Certainly a shopper cannot ‘check out’ until they
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`‘view’ and ‘modify’ the products in their cart; similarly, a shopper
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`cannot ‘view’ and ‘modify’ the products in their cart until they ‘add’
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`products to their cart; and, finally, a shopper cannot ‘add’ products
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`to their cart until they choose from the list of product offerings. The
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`second wherein clause of claim 7 requires nothing more.” (Id. at 9-
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`10 (emphasis added).)
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`APJ DeFranco’s opinion is that claim 17, which recites the same subject
`
`matter as claim 7, is unpatentable in view of the Digital River Publications for the
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`same reasons. (Id. at 11.)
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`Accordingly, APJ DeFranco’s opinion provides strong confirmation that
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`Petitioners demonstrated that claims 7 and 17 are unpatentable in view of the Digital
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`River Publications, and the Board should thus modify the FWD, in part, to hold
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`dependent claims 7 and 17 unpatentable on this basis.
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`B.
`
`Petitioners Further Demonstrated that Claims 8 and 18, Which
`Depend From Claims 7 and 17, Are Unpatentable in View of the
`Digital River Publications, Which is Confirmed by APJ
`DeFranco’s Opinion
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`13
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`Dependent claim 8 recites “[t]he method of claim 7 further comprising,
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`automatically with the computer system, (i) using search parameters inputted at the
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`visitor computing device to search for specific products within the catalog, and (ii)
`
`serving to the visitor computing device additional instructions directing the visitor
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`computing device to display the results of the search.” Claim 18 depends from claim
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`17 and recites the same subject matter as dependent claim 8.
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`The Petition demonstrated that dependent claims 8 and 18, which depend from
`
`claims 7 and 17, are unpatentable in view of the Digital River Publications. (Pet., at
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`25-26 (citing Ex. 1002, ¶ 108, Ex. 1007, at 1, and Ex. 1008, at 1).) For example, the
`
`Digital River websites utilize search engines that allow a user to search for software
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`by product, platform, or program, and the search engine provides search results as
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`claimed in the second clause of claims 8 and 18. (Id.) Petitioners’ showing with
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`regard to claims 8 and 18 was unrebutted by Patent Owner. (See Paper 20, at 41-
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`42.)
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`The majority panel did not reach the merits of claims 8 and 18 in light of the
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`panel’s determination that claims 7 and 17, from which claims 8 and 18 depend,
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`were not shown to be unpatentable. (FWD, at 31.)
`
`Now, in light of Petitioners’ request for rehearing with regard to claims 7 and
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`17 and Petitioners’ showing that claims 7 and 17 are unpatentable in view of the
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`Digital River Publications, Petitioners respectfully request the panel to consider the
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`14
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`merits of Petitioners’ showing of invalidity of dependent claims 8 and 18. For the
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`reasons set forth in the Petition and accompanying expert declaration, claims 8 and
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`18 are unpatentable in view of the Digital River Publications. Indeed, APJ DeFranco
`
`found that Petitioners’ showing with regard to the added elements of claims 8 and
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`18 is “persuasive” and would find claims 8 and 18 unpatentable in view of the Digital
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`River Publications. (FWD, dissenting-in-part opinion, at 11.) This again provides
`
`confirmation that Petitioners have demonstrated claims 8 and 18 unpatentable.
`
`The Board should also find claims 8 and 18 unpatentable in view of the Digital
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`River Publications in light of the Board’s holding that claim 7 of the related ’228
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`patent, which recites the same or similar features, is unpatentable. (IPR2018-01012,
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`Paper 33, FWD, at 26-27.) Specifically, the Board held that the claimed “search”
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`feature is unpatentable in view of the Digital River Publications and claims 8 and 18
`
`of the ’876 patent should be held unpatentable for the same reasons.
`
`III. CONCLUSION
`For the foregoing reasons, the Board should reconsider its Final Written
`
`Decision, in part, and find that dependent claims 7, 8, 17 and 18 of the ’876 patent
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`have also been shown to be unpatentable in view of the Digital River Publications.
`
`15
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`Dated: March 16, 2020
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`Case No. IPR2018-01011
`Patent No. 9,639,876
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`
`/Michael J. McNamara/
`Michael J. McNamara (Reg. No. 52,017)
`William A. Meunier (Reg. No. 41,193)
`Michael Renaud (Reg. No. 44,299)
`Mintz, Levin, Cohn, Ferris, Glovsky
`and Popeo, P.C.
`One Financial Center
`Boston, MA 02111
`Telephone: (617) 348-1884
`E-mails: MMcNamara@mintz.com
`WAMeunier@mintz.com
`MTRenaud@mintz.com
`DDR_IPR_Service@mintz.com
`
`Peter F. Snell (Reg. No. 52,235)
`Mintz, Levin, Cohn, Ferris, Glovsky
`and Popeo, P.C.
`Chrysler Center
`666 Third Avenue
`New York, NY 10017
`Telephone: (212) 692-6850
`E-mail: PFSnell@mintz.com
`
`16
`
`
`
`Case No. IPR2018-01011
`Patent No. 9,639,876
`
`CERTIFICATE OF SERVICE
`
`I certify that a copy of Petitioners’ Consolidated Request for Rehearing is being
`
`served by electronic mail on the following counsel of record for the Patent Owner and
`
`consolidated Petitioners:
`
`Lead Counsel for DDR Holdings, LLC
`
`Louis J. Hoffman (Reg. No. 38,918)
`Louis J. Hoffman, P.C.
`7689 East Paradise Lane, Suite 2
`Scottsdale, Arizona 85260
`Telephone: (480) 948-3295
`Emails: louis@valuablepatents.com;
`DDR_IPR@valuablepatents.com
`
`Back Up Counsel for DDR Holdings,
`LLC
`
`Justin J. Lesko (Reg. No. 69,643)
`Louis J. Hoffman, P.C.
`7689 East Paradise Lane, Suite 2
`Scottsdale, Arizona 85260
`Telephone: (480) 948-3295
`Email: justinlesko@patentit.com
`
`Lead Counsel for Priceline.com LLC and
`Booking.com B.V.
`
`Back Up Counsel for Priceline.com LLC
`and Booking.com B.V.
`
`Nathan J. Rees (Reg. No. 63,820)
`NORTON ROSE FULBRIGHT US LLP
`2200 Ross Avenue, Suite 3600
`Dallas, Texas 75201-7932
`Telephone: (214) 855-7164
`Facsimile: (214) 855-8200
`Emails:
`nate.rees@nortonrosefulbright.com;
`DDR_IPR_Service@nortonrosefulbright.com
`
`Dated: March 16, 2020
`
`Allan Braxdale (Reg. No. 64,276)
`allan.braxdale@nortonrosefulbright.com
`R. Ross Viguet (Reg. No. 42,203)
`Ross.viguet@nortonrosefulbright.com
`Brett C. Govett (Reg. No. 45,492)
`Brett.govett@nortonrosefulbright.com
`NORTON ROSE FULBRIGHT US
`LLP
`2200 Ross Avenue, Suite 3600
`Dallas, Texas 75201-7932
`Telephone: (214) 855-8000
`Facsimile: (214) 855-8200
`
`/Michael J. McNamara/
`Michael J. McNamara (Reg. No. 52,017)
`
`17
`
`
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