throbber
PATENT
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`GARMIN INTERNATIONAL, INC. ET AL.
`Petitioner
`
`v.
`
`Patent of CUOZZO SPEED TECHNOLOGIES LLC
`Patent Owner
`____________
`
`
`
`IPR2012-00001
`
`Case:
`
`
`
`Patent No.:
`
`6,778,074
`
`
`
`
`
`
`
`Filed:
`
`Issued:
`
`Inventors:
`
`Title:
`
`March 18, 2002
`
`August 17, 2004
`
`Giuseppe A. Cuozzo
`
`Speed Limit Indicator and Method for Displaying Speed and
`the Relevant Speed Limit
`
`Docket No.:
`
`CUO0001-RE
`
`____________
`
`PATENT OWNER’S MOTION TO AMEND
`
`Cuozzo Speed Technologies LLC (“Patent Owner”) hereby moves pursuant
`
`to the Board’s March 4 Order, Paper 27, and 37 C.F.R. § 42.121 to cancel claims
`
`10, 14 and 17 of U.S. Patent No. 6,778,074 (the “’074 Patent”) and submit proposed
`
`1
`
`

`

`Attorney’s Docket No.: CUO0001-RE
`
`Case No.: IPR2012-00001
`Page 2
`
`Patent No: 6,778,074
`substitute claims 21-23 in their place. Substitute claims 21-23 are fully supported by
`
`
`
`the ‘074 Patent and are patentable over the references at issue.
`
`In addition, should the Board confirm the patentability of claims 10, 14 and
`
`17, Patent Owner respectfully submits that good cause exists for entry of proposed
`
`claims 21-23, because such claims are necessary to further define the invention.
`
`I. BACKGROUND
`
`On September 16, 2012, Garmin International, Inc., et al. (“Petitioner”) filed
`
`a Petition for Inter Partes Review under 37 C.F.R. § 42.100 (“Petition”),
`
`requesting inter partes review of claims 1-20 of the ‘074 Patent. On January 9,
`
`2013, the Patent Trial and Appeal Board (the “Board”) issued a Decision to Initiate
`
`Trial for Inter Partes Review (“Order”) solely as to claims 10, 14 and 17 of the
`
`‘074 Patent under 35 U.S.C. § 103(a) in view of (1) U.S. Patent No. 6,633,811
`
`(“Aumayer”), U.S. Patent No. 3,980,041 (“Evans”), and U.S. Patent No. 2,711,153
`
`(“Wendt”), and DE 19755470 A1 (“Tegethoff”), U.S. Patent No. 6,515,596
`
`(“Awada “), Evans, and Wendt. Paper 15 at 26.
`
`II. SUMMARY OF MOTION TO AMEND
`
`By this motion to amend, Patent Owner requests to cancel claims 10, 14 and
`
`17, and replace these cancelled claims with proposed substitute claims 21-23.
`
`Proposed substitute claim 21 incorporates all of the limitations of claims 10, 12
`
`and 18. Proposed substitute claims 22 and 23 depend from proposed claim 21 and
`
`2
`
`

`

`Attorney’s Docket No.: CUO0001-RE
`
`Case No.: IPR2012-00001
`Page 3
`
`Patent No: 6,778,074
`further define the invention. As explained below, the subject matters of proposed
`
`
`
`substitute claims 21-23 are supported by the original disclosure of the ’074 Patent
`
`and are patentable in view of the references cited in the Order.
`
`This motion responds to the alleged grounds of unpatentability set forth in
`
`the Order and does not seek to enlarge the scope of the claims of the ’074 Patent or
`
`introduce new subject matter. Because none of the references at issue in this
`
`proceeding disclose or suggest, either alone or in combination, the subject matter
`
`of proposed substitute claims 21-23, Patent Owner respectfully requests that the
`
`Board confirm the patentability of proposed substitute claims 21-23.
`
`III. CLAIM LISTING
`
`10.
`
`(Replaced by proposed substitute claim 21)
`
`14.
`
`(Replaced by proposed substitute claim 22)
`
`17.
`
`(Replaced by proposed substitute claim 23)
`
`21.
`
`(Proposed substitute for original claim 10): A speed limit indicator
`
`comprising:
`
`a global positioning system receiver determining a vehicle’s present
`
`location, a vehicle’s present speed and a speed limit at the vehicle’s present
`
`location;
`
`a display controller connected to said global positioning system receiver,
`
`wherein said display controller adjusts a colored display in response to signals
`
`3
`
`

`

`Attorney’s Docket No.: CUO0001-RE
`
`Case No.: IPR2012-00001
`Page 4
`
`Patent No: 6,778,074
`indicative of the speed limit at the vehicle’s present location from said global
`
`
`
`positioning system receiver to continuously update the delineation of which speed
`
`readings determined by the global positioning system receiver are in violation of
`
`the speed limit at [[a]] the vehicle’s present location; and
`
`a speedometer integrally attached to said colored display,
`
`wherein the speedometer comprises a liquid crystal display, and
`
`wherein the colored display is the liquid crystal display.
`
`22. (Proposed substitute for original claim 14): The speed limit indicator as
`
`defined in claim 21, wherein said global positioning system receiver compares the
`
`vehicle’s present speed and the speed limit.
`
`23. (Proposed substitute for original claim 17): The speed limit indicator as
`
`defined in claim 21, wherein the display controller continuously adjusts the liquid
`
`crystal display to show speed readings in a first color or colored region when the
`
`vehicle’s present speed exceeds the speed limit at the vehicle’s present location
`
`and a color or colored region different from the first color when the vehicle’s
`
`present speed is less than the speed limit at the vehicle’s present location.
`
`IV. DISCUSSION OF PROPOSED SUBSTITUTE CLAIMS
`
`Proposed substitute claim 21 includes all of the limitations of claim 10, and
`
`the limitations of claims 12 and 18 (underlined above) and additional features of
`
`the invention (underlined above). Such additional features require that the global
`
`4
`
`

`

`Attorney’s Docket No.: CUO0001-RE
`
`Case No.: IPR2012-00001
`Page 5
`
`Patent No: 6,778,074
`positioning system receiver determines a vehicle’s present location, a vehicle’s
`
`
`
`present speed and a speed limit at the vehicle’s present location. The additional
`
`features further require that the display controller adjusts a colored display in
`
`response to signals indicative of the speed limit at the vehicle’s present location
`
`from said global positioning system receiver to continuously update the delineation
`
`of which speed readings determined by the global positioning system receiver are
`
`in violation of the speed limit at the vehicle’s present location.
`
`Proposed substitute claim 22 further defines the invention of proposed new
`
`claim 21 by requiring that the global positioning system receiver performs a
`
`comparison of the vehicle’s present speed and the speed limit.
`
`Proposed substitute claim 23 further defines the invention of proposed new
`
`claim 21 by requiring that the display controller continuously adjusts the liquid
`
`crystal display to show speed readings in a first color or colored region when the
`
`vehicle’s present speed exceeds the speed limit at the vehicle’s present location
`
`and a color or colored region different from the first color when the vehicle’s
`
`present speed is less than the speed limit at the vehicle’s present location.
`
`V. SUPPORT FOR CLAIMED SUBJECT MATTER
`
`A. Support for Subject Matter of Proposed Substitute Claim 21.
`
`Proposed substitute claim 21 is based on original claim 10. The added,
`
`underlined limitation requiring “a global positioning system receiver determining a
`
`5
`
`

`

`
`Case No.: IPR2012-00001
`
`Patent No: 6,778,074
`vehicle’s present location, a vehicle’s present speed and a speed limit at the
`
`Attorney’s Docket No.: CUO0001-RE
`Page 6
`
`
`
`vehicle’s present location,” is described in the original disclosure of the application
`
`which issued as the ’074 Patent. For example, col. 2, lines 58-61, describe an
`
`exemplary embodiment of the invention in which the vehicle’s location and speed
`
`are determined using a global positioning system receiver, and the speed limit for
`
`the vehicle’s current location is obtained from a database. Further, col. 5, lines 27-
`
`29 and Figure 2, describe an exemplary embodiment of the invention in which the
`
`global positioning receiver tracks the vehicle’s location and speed, and identifies
`
`the relevant speed limit from the database for that location.
`
`The added, underlined limitation requiring “a display controller connected to
`
`said global positioning system receiver, wherein said display controller adjusts a
`
`colored display in response to signals indicative of the speed limit at the vehicle’s
`
`present location from said global positioning system receiver to continuously
`
`update the delineation of which speed readings determined by the global
`
`positioning system receiver are in violation of the speed limit at [[a]] the vehicle’s
`
`present location,” is described in the original disclosure of the application which
`
`issued as the ‘074 Patent. In addition to the support for the limitations identified
`
`above, col. 2, lines 62-63, for example, describes an exemplary embodiment of the
`
`invention in which the global positioning system receiver sends the speed limit to
`
`the display control unit. Further, col. 5, lines 33-34 and Figure 2, describe an
`
`6
`
`

`

`Attorney’s Docket No.: CUO0001-RE
`
`Case No.: IPR2012-00001
`Page 7
`
`Patent No: 6,778,074
`exemplary embodiment of the invention in which the speed limit information is
`
`
`
`sent from the global positioning system receiver to a filter control unit.
`
`The added, underlined limitation requiring “wherein the speedometer
`
`comprises a liquid crystal display,” is described in the original disclosure of the
`
`application which issued as the ‘074 Patent. For example, original claim 18
`
`depended directly from independent claim 10 and was directed to an exemplary
`
`embodiment of the invention which required, “wherein the speedometer comprises
`
`a liquid crystal display.”
`
`The added, underlined limitation requiring “wherein the colored display is
`
`the liquid crystal display” is described in the original disclosure of the application
`
`which issued as the ‘074 Patent. For example, original claim 12 depended directly
`
`from independent claim 10 and was directed to an exemplary embodiment of the
`
`invention which required, “wherein the colored display is a liquid crystal display.”
`
`Further, col. 3, lines 3-6 and col. 6, lines 11-14,describe an embodiment of the
`
`invention in which the color display may take the form of a liquid crystal display.
`
`B. Support for Subject Matter of Proposed Substitute Claim 22.
`
`Proposed substitute claim 22 further defines the invention claimed in
`
`proposed substitute claim 21 by requiring that the global positioning system
`
`receiver compares the vehicle’s present speed and the speed limit, which is
`
`described in the original disclosure of the application which issued as the ‘074
`
`7
`
`

`

`Attorney’s Docket No.: CUO0001-RE
`
`Case No.: IPR2012-00001
`Page 8
`
`Patent No: 6,778,074
`Patent. For example, col. 5, lines 35-39 describes an exemplary embodiment of the
`
`
`
`invention in which, “[t]he global positioning system receiver compares the
`
`vehicle's speed and the relevant speed limit 44.”
`
`C. Support for Subject Matter of Proposed Substitute Claim 23.
`
`Proposed substitute claim 23 further defines the invention claimed in new
`
`claim 21 by requiring that the display controller continuously adjusts the liquid
`
`crystal display to show speed readings in a first color or colored region when the
`
`vehicle’s present speed exceeds the speed limit at the vehicle’s present location
`
`and a color or colored region different from the first color when the vehicle’s
`
`present speed is less than the speed limit at the vehicle’s present location, which is
`
`described in the original disclosure of the application which issued as the ‘074
`
`Patent. For example, col. 5, lines 35-39 describe an exemplary embodiment of the
`
`invention in which “speeds above the legal speed limit are displayed in red 50
`
`while the legal speeds are displayed in white 52.” Figure 2 shows an exemplary
`
`embodiment of the invention in which “vehicle speed up to speed limit is displayed
`
`on white speedometer region” and “vehicle speed above posted speed limit is
`
`displayed on red speedometer region.”
`
`VI. PROPOSED SUBSTITUTE CLAIMS 21-23 ARE ALLOWABLE
`OVER ALL GROUNDS OF UNPATENATABILITY
`
`
`
`The Board granted the Petition with respect to claim 10 on the alleged
`
`ground of obviousness under 35 U.S.C. § 103(a) in view of (1) the combination of
`
`8
`
`

`

`Attorney’s Docket No.: CUO0001-RE
`
`Case No.: IPR2012-00001
`Page 9
`
`Patent No: 6,778,074
`Aumayer, Evans and Wendt, and (2) the combination of Tegethoff, Awada, Evans
`
`
`
`and Wendt. Paper 15 at 26. Proposed substitute claims 21-23 include all of the
`
`limitations of original claim 10, and thus, even if original claim 10 is confirmed,
`
`proposed substitute claims 21-23 should also be entered and allowed for good
`
`cause. The proposed substitute claims further define the invention and are, without
`
`reference to the limitations of original claim 10, patentable over the cited
`
`references. Patent Owner respectfully submits that proposed substitute claims 21-
`
`23 are also allowable for the reasons set forth below.
`
`
`
`Initially, it is noted that the Aumayer and Awada references do not qualify
`
`as prior art under 35 USC § 102, because the invention of the ‘074 Patent was
`
`conceived prior to the effective date of each reference and was diligently reduced
`
`practice by the filing of the application which issued as the ‘074 Patent. See
`
`Declaration of Giuseppe Cuozzo under 37 CFR 1.1.31 (Exhibit 4001).
`
`A. Proposed Substitute Claim 21 is Patentable Over Cited References
`
`Proposed substitute claim 21 requires, “a global positioning system receiver
`
`determining a vehicle’s present location, a vehicle’s present speed and a speed
`
`limit at the vehicle’s present location.” First, Evans and Wendt discuss completely
`
`analog components and never discuss or suggest a global positioning system
`
`receiver, as recited in proposed substitute claim 21.
`
`9
`
`

`

`Attorney’s Docket No.: CUO0001-RE
`
`Case No.: IPR2012-00001
`Page 10
`
`Patent No: 6,778,074
`Aumayer does not disclose or suggest “a global positioning system receiver
`
`
`
`determining…a vehicle’s present speed and a speed limit at a vehicle’s present
`
`location,” as recited in proposed substitute claim 21. Aumayer discusses a vehicle
`
`locating device 201 that consists of a vehicle position determining device 202 that
`
`calculates the geographic position of the vehicle. However, there is no discussion
`
`or suggestion that the position determining device 202 determines vehicle speed.
`
`In fact, there is no description of any device in Aumayer which determines vehicle
`
`speed. Further, Aumayer expressly states that a “main processor 203 determines
`
`the speed limits for the individual classes of street and roads in the region in which
`
`the vehicle is located, i.e., the speed limits for the express way or freeway, high
`
`speed highway, country road, residential street, or inner city street.” Aumayer, col.
`
`7, lines 21-26. Thus, the main processor 203, not the position determining device
`
`202 determines a speed limit, and that speed limit is not “a speed limit at a
`
`vehicle’s present location,” as recited in proposed substitute claim 21. The speed
`
`limit determined by the main processor 203 in Aumayer relates to the type of road
`
`on which the vehicle is traveling regardless of the vehicle’s present location.
`
`Therefore, Aumayer neither discloses nor suggests, “a global positioning system
`
`receiver determining…a vehicle’s present speed and a speed limit at a vehicle’s
`
`present location,” as recited in proposed substitute claim 21.
`
`10
`
`

`

`Attorney’s Docket No.: CUO0001-RE
`
`Case No.: IPR2012-00001
`Page 11
`
`Patent No: 6,778,074
`Tegethoff does not disclose or suggest “a global positioning system receiver
`
`
`
`determining…a vehicle’s present speed and a speed limit at a vehicle’s present
`
`location,” as recited in proposed substitute claim 21. Tegethoff discusses a display
`
`system 1 consisting of a screen 37 and an image generating computer 33 which is
`
`connected to information providing elements 31. Among the information
`
`providing elements are separate elements for navigation and measuring speed.
`
`Thus, the element for navigation does not determine a vehicle’s present speed
`
`given the presence of the element for measuring speed. The element for navigation
`
`also does not determine the speed limit at the vehicle’s present location, because
`
`the element for navigation in Tegethoff is used in conjunction with a database of
`
`traffic control information as one way of determining a “maximum permissible
`
`speed,” which Tegethoff states is not equivalent to the legal speed limit, because
`
`the other discussed ways of determining the “maximum permissible speed” are
`
`manually and by an element for receiving transmitters outside the vehicle for
`
`traffic control. Therefore, Tegethoff neither discloses nor suggests, “a global
`
`positioning system receiver determining…a vehicle’s present speed and a speed
`
`limit at a vehicle’s present location,” as recited in proposed substitute claim 21.
`
`Awada does not disclose or suggest “a global positioning system receiver
`
`determining…a vehicle’s present speed and a speed limit at a vehicle’s present
`
`location,” as recited in proposed substitute claim 21. Awada discusses a system for
`
`11
`
`

`

`
`Case No.: IPR2012-00001
`
`Patent No: 6,778,074
`reporting a posted speed limit to a driver consisting of a GPS receiver that
`
`Attorney’s Docket No.: CUO0001-RE
`Page 12
`
`
`
`determines a position of a vehicle. The only reference in Awada to a device for
`
`determining the vehicle’s speed is, “information about the vehicle’s current speed
`
`may be obtained through a speedometer interface 264 and reported to the CPU
`
`254.” Awada, col. 4, lines 33-36. Therefore, Awada neither discloses nor
`
`suggests, “a global positioning system receiver determining…a vehicle’s present
`
`speed and a speed limit at a vehicle’s present location,” as recited in proposed
`
`substitute claim 21.
`
`Therefore, Patent Owner respectfully submits that proposed substitute claim
`
`21 is allowable, because neither Aumayer, Tegethoff, Awada, Evans nor Wendt,
`
`either alone or in combination, disclose or suggest, “a global positioning system
`
`receiver determining…a vehicle’s present speed and a speed limit at a vehicle’s
`
`present location.”
`
`B. Proposed Substitute Claim 22 is Patentable Over Cited References
`
`Proposed substitute claim 22 depends from proposed substitute claim 21 and
`
`further requires, “wherein said global positioning system receiver compares the
`
`vehicle’s present speed and the speed limit.” First, because proposed substitute
`
`claim 22 depends from, and therefore includes all of the limitations of, claim 21,
`
`claim 22 is allowable for at least the reasons discussed above with respect to claim
`
`21. Second, Evans and Wendt discuss completely analog components and never
`
`12
`
`

`

`Attorney’s Docket No.: CUO0001-RE
`
`Case No.: IPR2012-00001
`Page 13
`
`Patent No: 6,778,074
`discuss or suggest a global positioning system receiver, as recited in proposed
`
`
`
`substitute claim 22.
`
`Neither Aumayer, Tegethoff nor Awada discloses or suggests, either alone
`
`or in combination, “wherein said global positioning system receiver compares the
`
`vehicle’s present speed and the speed limit,” as recited in proposed substitute claim
`
`22. The “speed limit” determined by the main processor 203 in Aumayer relates to
`
`the type of road on which the vehicle is traveling regardless of the vehicle’s
`
`present location. Thus, there is no comparison in Aumayer of the vehicle’s present
`
`speed and the speed limit at the vehicle’s present location. Simiarly, in Tegethoff,
`
`the “maximum permissible speed” is not the legal speed limit at the vehicle’s
`
`present location, because the “maximum permissible speed” is either set manually
`
`or in conjunction with traffic information. Finally, Awada does not disclose or
`
`suggest that the vehicle’s speed, as determined by the GPS receiver, is compared to
`
`the speed limit. There is no reference in Awada to any device which determines
`
`the vehicle’s present speed.
`
`Therefore, Patent Owner respectfully submits that proposed substitute claim
`
`22 is allowable, because neither Aumayer, Tegethoff, Awada, Evans nor Wendt,
`
`alone or in combination, disclose or suggest, “wherein said global positioning
`
`system receiver compares the vehicle’s present speed and the speed limit.”
`
`C. Proposed Substitute Claim 23 is Patentable Over Cited References
`
`13
`
`

`

`Attorney’s Docket No.: CUO0001-RE
`
`Case No.: IPR2012-00001
`Page 14
`
`Patent No: 6,778,074
`Proposed substitute claim 23 depends from proposed substitute claim 21 and
`
`
`
`further requires, “wherein the display controller continuously adjusts the liquid
`
`crystal display to show speed readings in a first color or colored region when the
`
`vehicle’s present speed exceeds the speed limit at the vehicle’s present location
`
`and a color or colored region different from the first color when the vehicle’s
`
`present speed is less than the speed limit at the vehicle’s present location.” First,
`
`because proposed substitute claim 23 depends from, and therefore includes all of
`
`the limitations of, claim 21, claim 23 is allowable for at least the reasons discussed
`
`above with respect to claim 21. Second, Evans and Wendt discuss completely
`
`analog components and never discuss or suggest a display controller that
`
`“continuously adjusts [a] liquid crystal display,” as recited in substitute claim 23.
`
`Neither Aumayer, Tegethoff nor Awada discloses or suggests, either alone
`
`or in combination, “wherein the display controller continuously adjusts the liquid
`
`crystal display to show speed readings in a first color or colored region when the
`
`vehicle’s present speed exceeds the speed limit at the vehicle’s present location
`
`and a color or colored region different from the first color when the vehicle’s
`
`present speed is less than the speed limit at the vehicle’s present location,” as
`
`recited in proposed substitute claim 23. Aumayer discusses a speed display device
`
`101 that consists of a speed limit symbol 105 and a second scale mark 107 which
`
`indicate a speed limit for a type of road. There is no discussion of any color
`
`14
`
`

`

`Attorney’s Docket No.: CUO0001-RE
`
`Case No.: IPR2012-00001
`Page 15
`
`Patent No: 6,778,074
`associated with the speed limit symbol 105. Aumayer discusses a color associated
`
`
`
`with the second scale mark 107 alone. Thus, speed readings below and above the
`
`second scale mark 107 are shown in the same color. Tegethoff shows a “maximum
`
`permissible speed” (not a legal speed limit) with a mark 5. Similar to Aumayer,
`
`the speed readings below and above the mark 5 are shown in the same color.
`
`Compare Fig. 2a of Aumayer and Fig. 2 of Tegethoff. Finally, Awada discusses a
`
`numerical display 110 to show a speed limit and a warning light 120 that shines
`
`when the speed limit is exceeded. However, Awade never discusses or suggest a
`
`display showing speed readings of the vehicle or any colors associated with such a
`
`display or the warning light 120. See Fig. 1 of Awada.
`
`Therefore, Patent Owner respectfully submits that proposed substitute claim
`
`23 is allowable, because neither Aumayer, Tegethoff, Awada, Evans nor Wendt,
`
`either alone or in combination, disclose or suggest, “wherein the display controller
`
`continuously adjusts the liquid crystal display to show speed readings in a first
`
`color or colored region when the vehicle’s present speed exceeds the speed limit at
`
`the vehicle’s present location and a color or colored region different from the first
`
`color when the vehicle’s present speed is less than the speed limit at the vehicle’s
`
`present location.”
`
`15
`
`

`

`Case No.: IPR2012-00001
`Patent No: 6,778,074
`
`
`
`
`
`CONCLUSION
`
`Attorney’s Docket No.: CUO0001-RE
`Page 16
`
`In light of the remarks herein, Patent Owner respectfully requests that the
`
`Board grant this Motion to Amend. If the Board has any questions, comments, or
`
`suggestions, the undersigned attorney earnestly requests a telephone conference.
`
`No fees are required for filing this amendment; however, the Commissioner
`
`is authorized to charge any additional fees which may be required, or credit any
`
`overpayment, to Kasha Law LLC, Deposit Account No. 50-4075.
`
`
`
`
`
`
`
`Customer No. 67050
`Date: March 11, 2013
`
`Respectfully submitted,
`
`/John R. Kasha/
`John R. Kasha
`Reg. No. 53,100
`Attorney for the Patent Owner
`
`
`
`
`
`16
`
`

`

`Case No.: IPR2012-00001
`Patent No: 6,778,074
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Attorney’s Docket No.: CUO0001-RE
`Page 17
`
`In accordance with 37 C.F.R § 1.550(f), a copy of the Patent Owner’s
`Motion to Amend filed by the Cuozzo Speed Technologies LLC on March 11,
`2013 including Exhibits 4000-4001, which include the Declaration of Giuseppe A.
`Cuozzo, was duly served on the Inter Partes Requester via e-mail on March 11,
`2013 to the following e-mail addresses:
`
`jbailey@hoveywilliams.com (Jennifer C. Bailey, Lead Counsel)
`sbrown@hoveywilliams.com (Scott R. Brown, Back-Up Counsel)
`jcrawford@hoveywilliams.com (Justin Crawford, Paralegal)
`
`
`Respectfully submitted,
`
`/John R. Kasha/
`Registration No. 53,100
`Attorney for Cuozzo Speed Technologies
`LLC
`
`
`
`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(703) 867-1886, telephone
`(301) 340-3022, facsimile
`Email: john.kasha@kashalaw.com
`
`
`
`
`
`
` 
`
`

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