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`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`FACEBOOK, INC., INSTAGRAM, LLC, and WHATSAPP INC.,
`Petitioners,
`
`v.
`
`BLACKBERRY LIMITED,
`Patent Owner
`________________
`
`IPR2019-00516
`U.S. Patent No. 8,279,173
`________________
`
`PATENT OWNER’S SUR-REPLY
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`
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`TABLE OF CONTENTS
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`IPR2019-00516
`U.S. Patent No. 8,279,173
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`Page
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`I.
`
`II.
`
`INTRODUCTION ........................................................................................ 1
`
`RESPONSE TO ARGUMENTS ................................................................... 1
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`A. Grounds 2-5: No Prior Art Reference Discloses “Displaying a
`Tag Type Indicator . . . Indicative of a Tag Source” ............................ 1
`
`B.
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`Grounds 2-7: No Prior Art Reference Discloses Multiple “Tag
`Sources” ............................................................................................. 3
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`1.
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`2.
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`Background on the Dispute ....................................................... 4
`
`The Board Should Adopt BlackBerry’s Proposed
`Construction of “Tag Source” ................................................... 6
`
`C.
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`Grounds 2-5: Petitioners Fail to Identify a Motivation to
`Combine the Prior Art References .................................................... 12
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`1.
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`Petitioners’ “Additional Flexibility” Argument Rests on
`Impermissible Hindsight Bias ................................................. 12
`
`2. MacLaurin Does Not Provide Any Express Motivation to
`Combine ................................................................................. 13
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`III. CONCLUSION .......................................................................................... 14
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`i
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`TABLE OF AUTHORITIES
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`IPR2019-00516
`U.S. Patent No. 8,279,173
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`Page
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`CASES
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`Akzo Nobel Coatings, Inc. v. Dow Chem. Co.,
`811 F.3d 1334 (Fed. Cir. 2016) ...................................................................10
`
`Amazon.com, Inc. v. ZitoVault, LLC,
`754 Fed. App’x 965 (Fed. Cir. 2018) ........................................................ 7, 8
`
`K/S Himpp v. Hear-Wear Techs., LLC,
`751 F.3d 1362 (Fed. Cir. 2014) .................................................................... 3
`
`Merck & Co. v. Teva Pharma. USA, Inc.,
`395 F.3d 1364 (Fed. Cir. 2005) ...................................................................10
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`
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`ii
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`IPR2019-00516
`U.S. Patent No. 8,279,173
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`LIST OF EXHIBITS
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`Exhibit #
`
`Description
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`2001
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`2002
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`2003
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`2004
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`2005
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`2006
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`2007
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`2008
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`2009
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`2010
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`2011
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`2012
`
`Declaration of Rajeev Surati, Ph.D.
`
`Excerpts from the American Heritage College
`Dictionary, 4th ed. (2002)
`
`Excerpts from Webster’s New World College Dictionary,
`4th ed. (2008)
`
`Excerpts from Merriam-Webster’s Collegiate Dictionary,
`11th ed. (2003)
`
`Exhibit 9 from the Deposition of Sandeep Chatterjee,
`Ph.D.
`
`Petitioners’ Opposition to BlackBerry’s Motion for
`Partial Summary Judgment of Infringement in the
`District Court Litigation
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`Facebook Design Principles
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`Prosecution History of U.S. Patent No. 9,495,335
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`U.S. Patent Application No. 13/252,807
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`U.S. Patent Application No. 11/746,285
`
`Redline comparison of ’807 and ’285 Applications
`
`Transcript of November 7, 2019 Deposition of Sandeep
`Chatterjee, Ph.D.
`
`
`
`
`
`iii
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`IPR2019-00516
`U.S. Patent No. 8,279,173
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`I.
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`INTRODUCTION
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`Petitioners’ invalidity theories continue to suffer three basic deficiencies.
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`First, Grounds 2-51 fail because no prior art reference discloses “displaying a tag
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`type indicator . . . indicative of a tag source.” Second, Grounds 2-7 fail because no
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`prior art reference discloses multiple “tag sources” under BlackBerry’s correct
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`construction of that term. Petitioners only apply their own, incorrect construction
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`of “tag sources,” which effectively renders the term “tag sources” meaningless.
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`Third, Grounds 2-5 rely on impermissible hindsight and lack any valid motivation
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`to combine the prior art references.
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`The Board should, therefore, affirm the validity of the Challenged Claims.
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`II. RESPONSE TO ARGUMENTS
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`A. Grounds 2-5: No Prior Art Reference Discloses “Displaying a Tag
`Type Indicator . . . Indicative of a Tag Source”
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`The Board concluded in its institution decision that Zuckerberg’s horizontal
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`line is not “indicative of a tag source” since it “does not convey any information
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`about the lists it separates beyond the fact that they are separate.” Institution
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`Decision at 23-24. Petitioners do not contest this conclusion in their Reply. Ex.
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`1 This sur-reply only references grounds 2-5 or 2-7 because “Petitioner is no
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`longer pursuing Ground 1.” See Reply at 11 n.3. The first two deficiencies
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`outlined herein, however, also apply with equal force to Ground 1.
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`1
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`1023 (Chatterjee Reply Decl.) ¶ 31 (“I understand Petitioner is no longer arguing
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`in this proceeding that the dividing line of Zuckerberg alone qualifies as a ‘tag type
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`indicator’ . . . .”). Thus, for the reasons set forth in Section VII.A.1.a of
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`BlackBerry’s Patent Owner Response, Zuckerberg does not disclose “a tag type
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`indicator . . . indicative of a tag source,” as claimed. This is no longer disputed.
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`Petitioners cannot rely on Rothmuller or Plotkin to cure this deficiency in
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`Zuckerberg. Petitioners acknowledge “Grounds 2-5 . . . did not rely on Rothmuller
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`or Plotkin for the claimed ‘tag sources’” and contend it is “irrelevant to Grounds 2-
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`5” whether “Rothmuller or Plotkin disclose distinct ‘tag sources.’” Id. But if
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`Rothmuller and Plotkin’s categories are not “tag sources,” then Rothmuller and
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`Plotkin’s category icons cannot be “indicative of a tag source.” Accordingly,
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`Rothmuller and Plotkin also fail to disclose “a tag type indicator . . . indicative of
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`a tag source,” as claimed.
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`Petitioners are thus left with no allegation in Grounds 2-5 that any prior art
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`reference discloses “a tag type indicator . . . indicative of a tag source,” as
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`claimed. Petitioners do not contest the Board’s finding this limitation is missing
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`from Zuckerberg, and they never argued for Grounds 2-5 that this limitation was
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`disclosed by Rothmuller or Plotkin. Moreover, the claimed “tag type indicator . . .
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`indicative of a tag source” is not a minor claim limitation that can be addressed via
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`reliance on common sense, but goes to the very core of the innovation claimed by
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`2
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`U.S. Patent No. 8,279,173
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`the ’173 Patent. Petitioners cannot prevail on obviousness without identifying this
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`claim limitation in some prior art reference. See K/S Himpp v. Hear-Wear Techs.,
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`LLC, 751 F.3d 1362, 1365 (Fed. Cir. 2014) (explaining that “obviousness”
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`“require[s] record evidence to support an assertion that [the claimed] structural
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`features . . . were known prior art elements”). For example, even if one of ordinary
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`skill were to insert Rothmuller or Plotkin’s category icons into Zuckerberg’s user
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`interface, the combination would still fail to render obvious the Challenged
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`Claims—the icons would continue to indicate the tag categories and not any “tag
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`source.”
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`Accordingly, even if the Board were to accept all of Petitioners’ remaining
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`contentions, Petitioners are left without a viable argument that the Challenged
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`Claims are invalid over the prior art disclosure identified for Grounds 2-5.
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`B. Grounds 2-7: No Prior Art Reference Discloses Multiple “Tag
`Sources”
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`No prior art reference cited by Petitioners in Grounds 2-7 discloses “a tag
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`type indicator . . . indicative of a tag source.” Because these references lack
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`multiple “tag sources,” the user interface elements cited by Petitioners for the
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`claimed “tag type indicator[s]” cannot be “indicative of a tag source.”
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`The parties’ dispute boils down to claim construction: should the term “tag
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`source” be construed as “a separately searchable collection of tags” (BlackBerry’s
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`proposal) or as “a recognizable collection of tags” (Petitioners’ new proposal on
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`3
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`U.S. Patent No. 8,279,173
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`reply). Petitioners’ Reply does not dispute that Zuckerberg (for Grounds 2-5) and
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`Rothmuller (for Grounds 6-7) lack multiple “tag sources” under BlackBerry’s
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`proposed construction. Since BlackBerry’s construction is correct, Grounds 2-7
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`fail.
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`1.
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`Background on the Dispute
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`In Grounds 2-5, Petitioners allege the “displaying a tag type indicator for
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`each tag appearing in the tag list, said tag type being indicative of a tag source
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`associated with the tag” limitation is met by a combination of Zuckerberg and
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`Rothmuller or Plotkin. In particular, Petitioners contend this limitation is met by
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`indicating if each tag is from Zuckerberg’s “text list” or “friend list.” As explained
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`in Section VII.A.1.b of BlackBerry’s Patent Owner Response, both of these lists
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`are part of the same “list of previously used tags” and from the same “tag source.”
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`Indicating if each tag is from Zuckerberg’s “text list” or its “friend list” is not,
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`therefore, “indicative of a tag source,” as claimed.
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`Similarly, in Grounds 6-7, Petitioners allege Rothmuller’s category icons are
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`“indicative of a tag source,” as claimed. As explained in Section VII.A.2.b.i of
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`BlackBerry’s Patent Owner Response, Rothmuller also lacks separate “tag
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`source[s]” and all of its tags corresponding to categories are actually from the same
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`“tag source.” For that reason, Rothmuller’s category icons are not “indicative of a
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`tag source,” as required by the claims.
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`4
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`Petitioners do not dispute the basic premise of BlackBerry’s argument—that
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`Grounds 2-7 fail if Zuckerberg and Rothmuller lack multiple tag sources—and
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`instead argue that these prior art references do, in fact, disclose multiple sources.
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`See Reply at 10-15 (arguing “Zuckerberg Discloses Distinct Tag Sources”); id. at
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`21-24 (arguing “Rothmuller thus discloses separate ‘tag sources’”). Moreover,
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`Petitioners’ Reply makes clear that Zuckerberg and Rothmuller stand and fall
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`together, arguing that Rothmuller’s “drop-down menu . . . is similar to Zuckerberg
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`in that it can present separated lists each containing tags of a particular type (e.g.,
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`people, events).” Id. at 23.
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`Thus, Grounds 2-7 fail if Zuckerberg and Rothmuller do not disclose
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`multiple ‘tag sources.” And the question of whether Zuckerberg and Rothmuller
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`disclose multiple “tag source[s]” is an issue of claim construction. Petitioners only
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`apply their proposed construction for “tag sources.” See Reply at 15 (“This is
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`more than sufficient to confirm the existence of two recognizable tag collections,
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`and thus, distinct ‘tag sources.’”); id. at 22 (“These categories properly qualify as
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`tag sources because the system in Rothmuller can recognize and distinguish the
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`collections, and identify which tags belong to which categories.”). Petitioners do
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`not dispute that Zuckerberg and Rothmuller lack multiple “tag source[s]” under
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`BlackBerry’s construction. See id. at 11 (“To the extent Patent Owner’s arguments
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`rely on the position that the term “tag sources” requires separate searchability,
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`5
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`those arguments fail because its claim construction position is incorrect as
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`explained above.”). Accordingly, under BlackBerry’s proposed construction of
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`‘tag source,” Petitioners’ Grounds 2-7 cannot stand.
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`2.
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`The Board Should Adopt BlackBerry’s Proposed
`Construction of “Tag Source”
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`As explained in Section VI.A of BlackBerry’s Patent Owner Response, the
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`Board should construe the term “tag source” as a “separately searchable collection
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`of tags.” “[S]eparately searchable” is grounded in the intrinsic record and correctly
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`focuses on how “tags” are obtained, and not just their subject matter. Petitioners’
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`proposal—“a recognizable collection of tags”—is a continuation of their effort to
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`remove any substantive meaning from the claimed “tag source,” allowing
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`Petitioners to identify multiple “tag source[s]” even where there is just a single
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`“source.”
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`In its Reply, Petitioners contend that BlackBerry’s proposed construction is
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`ambiguous. Reply at 1-3. But in that same section, Petitioners correctly explain
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`“separately searchable” means each tag source is “capable of being searched
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`without having to search another tag source.” Reply at 2. The ’173 Patent
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`specification thus teaches that it is possible to search “one” tag source or multiple
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`tag sources. ’173 Patent at 5:39-4. This also means that it must be possible to
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`search just one tag source without searching the others, which leads to the
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`conclusion that “tag sources” are “separately searchable,” as reflected in
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`6
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`BlackBerry’s proposal. See Amazon.com, Inc. v. ZitoVault, LLC, 754 Fed. App’x
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`965, 970 (Fed. Cir. 2018) (finding that, because the claims require “multiple
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`‘sessions,’” this “suggest[s] that the system recognizes distinct sessions”).
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`Petitioners also argue BlackBerry is importing a “separately searchable”
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`requirement into the claims. Reply at 3-8. This is incorrect. BlackBerry is
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`applying the plain meaning to the term “tag source.” The fact that the claims recite
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`“one or more tag sources” means that there must be a difference between a
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`collection of tags that is from just “one” tag source and a collection of tags that is
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`from multiple tag sources. The correct focus in this analysis is on how tags are
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`obtained—that is, whether they are “from” different sources, as recited in the
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`claims. This is confirmed by the ’173 Patent’s specification, where tags from
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`different “sources” can, e.g., be obtained from different applications. See ’173
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`Patent at 3:40-55, 5:39-47, 5:56-61, 6:27-52; see also id. at Fig. 1.
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`Petitioners’ criticism of the ’173 Patent’s specification is misplaced and
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`irrelevant. Petitioners contend “[n]othing in the specification describes how any
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`search of the tag sources is carried out.” Reply at 4-5. Their own expert undercuts
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`this argument, however, with his admission that the specification discloses “the
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`ability to search just one tag source” and “the ability to search multiple tag
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`sources.” Ex. 2012 (Chatterjee Tr.) at 55:13-21. Next, Petitioners argue the
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`sources in the specification are exemplary (Reply at 5-6), but that renders them no
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`7
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`U.S. Patent No. 8,279,173
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`less useful in understanding the plain meaning of “tag sources.” Finally,
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`Petitioners contend that nothing in the specification precludes data from being
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`stored in different locations (e.g., locally vs. at a server) (Reply at 6-8), but the
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`physical location does not control whether two collections of tags are from
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`different sources. See, e.g., ’173 Patent at 1 (“Internet Browser 138” and “Address
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`Book 142” are two “tag sources” even though both are local to communication
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`device 100).
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`Not only is BlackBerry’s proposed construction correct, but Petitioners have
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`failed to present any workable alternative. Effectively acknowledging there must
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`be some manner for distinguishing tags from different sources, Petitioners contend
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`“[a] construction more consistent with ZitoVault would have been ‘a recognizable
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`collection of tags,’ which Petitioner[s] believe[] is already implicit in [their]
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`proposed construction.” Reply. at 9 (emphasis in original).2 Petitioners provide no
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`2 While Petitioners’ proposed construction uses the same word (“recognizable”)
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`also found in the construction approved in ZitoVault, this similarity is superficial at
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`best. The claim term “session” in ZitoVault had a temporal aspect that allowed
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`different “sessions” to be distinguished based on their “recognizable” beginnings
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`and ends. In contrast, the word “recognizable” does not modify any concrete
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`characteristic that can be used to distinguish different “tag sources.”
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`8
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`U.S. Patent No. 8,279,173
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`objective criteria for what qualifies as “recognizable,” however, allowing
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`Petitioners to argue any arbitrary collection of tags qualifies as a “tag source.” For
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`example, Petitioners provide no explanation how their proposed construction
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`would allow one of ordinary skill to determine how many “tag sources” are present
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`in Rothmuller. Compare Ex. 2012 (Chatterjee Tr.) at 86:25-88:15 (testifying he
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`was “not really sure how to answer” the question of “[h]ow many different tag
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`sources are illustrated in [a] figure” summarizing Rothmuller’s categories and
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`types) with Ex. 1023 (Chatterjee Reply Decl.) ¶ 51 (maintaining that either
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`categories or types in Rothmuller can “qualify as tag sources”). Thus, Petitioners’
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`proposed construction of “a recognizable collection of tags” fails to address the
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`deficiencies in Petitioners’ original interpretation of this term.
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`Indeed, Petitioners’ proposed construction of “tag source” renders the claim
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`limitation “said tag type being indicative of a tag source associated with the tag”
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`superfluous. Under Petitioners’ interpretation, the mere ability to “display[] a tag
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`type indicator” for a collection of tags (or otherwise distinguish them) renders that
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`collection of tags “recognizable” and thus a “tag source.” See, e.g., Reply at 15
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`(emphasis added):
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`[I]n the end, the storage and organization of the ‘list of
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`previously used tags’ simply does not matter. Figure 5 of
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`Zuckerberg confirms
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`that
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`the system can readily
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`recognize and distinguish tags corresponding to the “text
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`9
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`U.S. Patent No. 8,279,173
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`list” from tags corresponding to the “friends list” – and
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`display each of them within one of two distinct lists as
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`shown in Figure 5. This is more than sufficient to
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`confirm the existence of two recognizable tag collections,
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`and thus, distinct “tag sources.”
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`Accordingly, if Petitioners’ interpretation were adopted, any “tag type
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`indicator” would automatically designate “tag source”—the additional claim
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`requirement that “the tag type” is “indicative of a tag source” would be redundant
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`and devoid of meaning. Petitioners’ proposed construction for “tag source,”
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`therefore, cannot be correct. See Merck & Co. v. Teva Pharma. USA, Inc., 395
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`F.3d 1364, 1372 (Fed. Cir. 2005) (“A construction that gives meaning to all the
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`terms of the claim is preferred over one that does not do so.”); Akzo Nobel
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`Coatings, Inc. v. Dow Chem. Co., 811 F.3d 1334, 1339-40 (Fed. Cir. 2016)
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`(rejecting broad construction of “pressurized collection vessel” because it “would
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`render ‘collection’ entirely superfluous and allow any pressurized vessel to
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`constitute a ‘pressurized collection vessel”).
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`Finally, Petitioners’ non-infringement position in district court litigation is
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`fatal to its claim construction argument here. In district court, Petitioners argued
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`the “tag type indicator . . . indicative of a tag source” limitation is not met because
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`“[t]he supposed ‘tag type indicators’ identified by BlackBerry, at best, correspond
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`to categories of tag suggestions – not their sources.” Ex. 2006 at 13. Petitioners
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`10
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`thus argued that “categories of tag suggestions”—which Petitioners do not dispute
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`would qualify as “recognizable collection[s] of tags”—are distinguishable from tag
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`“sources.” Petitioners now contend they made this litigation statement in a
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`different context (Reply at 9-10), but they cannot escape their admission that tag
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`“categories” and “sources” are different concepts. Petitioners’ district court
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`argument thus demonstrates the incorrectness of their IPR construction—even
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`Petitioners themselves disagreed with this construction when arguing non-
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`infringement.3
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`Accordingly, BlackBerry’s proposed construction of “tag source” to mean a
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`“separately searchable collection of tags” should be adopted. And once
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`BlackBerry’s proposed construction is adopted, there is no dispute Facebook’s
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`prior art references lack multiple “tag sources” and fail to disclose “a tag type
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`indicator . . . indicative of a tag source,” as claimed.
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`3 In contrast, BlackBerry’s position is consistent: the term “tag sources” should be
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`construed according to its plain meaning. In this IPR, it is necessary to construe
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`that plain meaning to resolve a dispute between the parties. Petitioners have not
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`identified any equivalent dispute in district court litigation that would need to be
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`resolved by expressly construing “tag sources.”
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`11
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`C. Grounds 2-5: Petitioners Fail to Identify a Motivation to Combine
`the Prior Art References
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`Petitioners no longer dispute that Zuckerberg alone fails to disclose or render
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`obvious “displaying a tag type indicator for each tag appearing in the tag list,” as
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`claimed. See Reply at 11 n.3. Instead, Petitioners rely on Rothmuller or Plotkin to
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`cure Zuckerberg’s admitted deficiencies. Petitioners fail, however, to identify a
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`valid motivation for combining Zuckerberg with either Rothmuller or Plotkin.
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`Petitioners’ Reply has now narrowed the alleged motivation to just two
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`explanations—“additional flexibility” and an alleged express motivation in
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`MacLaurin—but even those two remaining alleged motivations are deficient.
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`1.
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`Petitioners’ “Additional Flexibility” Argument Rests on
`Impermissible Hindsight Bias
`
`Petitioners contend one of ordinary skill would have been motivated to
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`modify Zuckerberg based on Rothmuller or Plotkin to “provide[] additional
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`flexibility in how the tag list of Zuckerberg can be organized for display.” Reply
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`at 16-18. The benefit of this “additional flexibility,” however, is only taught by the
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`’173 Patent. See Ex. 1001 (’173 Patent) at 4B. No prior art reference identified by
`
`Petitioners allows tags from different tag sources to be interspersed within a tag
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`list. In Zuckerberg, tags from different alleged sources are expressly separated by
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`a line. Ex. 1003 (Zuckerberg) at Fig. 5. MacLaurin is silent regarding how its tags
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`are organized; indeed, MacLaurin’s figures show only one tag being displayed at a
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`12
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`time. Ex. 1006 (MacLaurin) at Fig. 8. Petitioners do not contend for purposes of
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`Grounds 2-6 that Rothmuller or Plotkin disclose multiple tag sources (they do not),
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`and those references thus also cannot disclose interspersing tags from different
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`sources in a tag list.
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`Petitioners thus used a benefit only taught in the ’173 Patent as a roadmap to
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`their obviousness combination. Petitioners’ combinations, therefore, improperly
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`relies on impermissible hindsight.
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`2. MacLaurin Does Not Provide Any Express Motivation to
`Combine
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`Petitioners also contend MacLaurin provides express motivation to combine
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`Zuckerberg with Rothmuller or Plotkin because MacLaurin allegedly “confirms the
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`general desirability of providing a separate type indicator for each displayed tag –
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`in any context.” Reply at 19. This is incorrect. As explained in Section
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`VII.B.2.b.i of BlackBerry Patent Owner Response, MacLaurin only visually
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`distinguishes between tags in its recall mode. MacLaurin cannot confirm[] the
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`general desirability of providing a separate indicator for each display tag” in a user
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`interface for tagging photos—such as Zuckerberg’s Figure 5—at least because
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`MacLaurin does not, itself, provide any indicators in its tagging mode. Instead,
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`MacLaurin made the decision to display all tags in plain text in its tagging mode,
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`and it thus cannot provide express motivation to one of ordinary skill to depart
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`from MacLaurin’s own teachings and instead display indicators.
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`13
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`Accordingly, Petitioners have failed to identify any motivation to justify
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`departing from Zuckerberg’s own teachings and display “a tag type indicator for
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`each tag appearing in the tag list.”
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`III. CONCLUSION
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`In view of the foregoing, BlackBerry respectfully requests that the Board
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`find the Challenged Claims of the ’173 Patent valid.
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`
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`Date: March 16, 2020
`
` By: /Jim Glass/
`James M. Glass (Reg. No. 46,729)
`QUINN EMANUEL URQUHART &
`SULLIVAN LLP
`51 Madison Avenue, 22nd Floor
`New York, NY 10010
`Email: jimglass@quinnemanuel.com
`Phone: 212-849-7142
`Fax: 212-849-7100
`
`Counsel for Patent Owner
`BlackBerry Limited
`
`
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`14
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`IPR2019-00516
`U.S. Patent No. 8,279,173
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`CERTIFICATE OF LENGTH (37 C.F.R. §§ 42.24(D))
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`The undersigned hereby certifies that, according to the word-processing
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`system used to prepare the foregoing document, this document has 2,978 words and
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`thus complies with the applicable word limit.
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`Date: March 16, 2020
`
` By: /Jim Glass/
`James M. Glass (Reg. No. 46,729)
`QUINN EMANUEL URQUHART &
`SULLIVAN LLP
`51 Madison Avenue, 22nd Floor
`New York, NY 10010
`Email: jimglass@quinnemanuel.com
`Phone: 212-849-7142
`Fax: 212-849-7100
`
`Counsel for Patent Owner
`BlackBerry Limited
`
`
`
`
`15
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`IPR2019-00516
`U.S. Patent No. 8,279,173
`
`CERTIFICATE OF SERVICE (37 C.F.R. §§ 42.6(E), 42.105(A))
`
`
`
`The undersigned hereby certifies that the foregoing document was served in
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`its entirety on March 16, 2020 upon the following parties via Electronic Mail.
`
`Heidi L. Keefe
`Andrew C. Mace
`Mark R. Weinstein
`Yuan Liang
`
`Cooley LLP
`Attn: Patent Group
`1299 Pennsylvania Ave, NW, Suite 700
`Washington, DC 20004
`
`Email: hkeefe@cooley.com
`Email: amace@cooley.com
`Email: mweinstein@cooley.com
`Email: yliang@cooley.com
`
`Date: March 16, 2020
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`
`
`
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`
`
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`
`
`
`
`
` By: /Jim Glass/
`James M. Glass (Reg. No. 46,729)
`QUINN EMANUEL URQUHART &
`SULLIVAN LLP
`51 Madison Avenue, 22nd Floor
`New York, NY 10010
`Email: jimglass@quinnemanuel.com
`Phone: 212-849-7142
`Fax: 212-849-7100
`
`Counsel for Patent Owner
`BlackBerry Limited
`
`
`16
`
`
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