Petitioner’s Reply in Support of Petition
`IPR 2014‐00415
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Facebook, Inc.
`Petitioner
`
`v.
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`Rembrandt Social Media, L.P.,
`Patent Owner
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`U.S. Patent No. 6,415,316 B1
`Filing Date: September 1, 1998
`Issue Date: July 2, 2002
`
`Title: METHOD AND APPARATUS FOR IMPLEMENTING A WEB PAGE DIARY
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`
`PETITIONER’S REPLY IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
`
`Inter Partes Review No. 2014‐00415
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`IPR 2014‐00415
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`Facebook, Inc.
`Petitioner
`
`v.
`
`Rembrandt Social Media, L.P.,
`Patent Owner
`
`U.S. Patent No. 6,415,316 B1
`Filing Date: September 1, 1998
`Issue Date: July 2, 2002
`
`Title: METHOD AND APPARATUS FOR IMPLEMENTING A WEB PAGE DIARY
`
`
`PETITIONER’S REPLY IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
`
`Inter Partes Review No. 2014‐00415
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`Table of Contents
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`Page
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`B.
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`B.
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`C.
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`INTRODUCTION ............................................................................................. 1
`CONSTRUCTION OF “PRIVACY LEVEL INFORMATION” .................................. 1
`A.
` “Privacy Level Information” Need Not Specify a “Universe” of
`Users ................................................................................................... 1
`“Privacy Level Information” Does Not Require Client‐Side
`Filtering ............................................................................................... 4
`SALAS AND PARKER DISCLOSE SENDING “PRIVACY LEVEL
`INFORMATION” TO THE USER SYSTEM AND ASSEMBLING A COHESIVE
`DIARY PAGE ................................................................................................... 5
`A.
`Brief Summary of How Salas & Parker Disclose Privacy
`Information ......................................................................................... 5
`The Server in Salas Sends “Privacy Level Information” to the
`Client ................................................................................................... 7
`Parker Also Sends “Privacy Level Information” to the Client,
`and Assembles the Page “In Accordance With” that
`Information ....................................................................................... 11
`The Patent Owner’s Attempt to Confuse the Displayed Content
`Data with Data in the Underlying Files Should Be Rejected ............. 12
`SALAS AND PARKER ARE PROPERLY COMBINABLE ..................................... 13
`CONCLUSION .............................................................................................. 15
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`D.
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`‐i‐
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`I.
`II.
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`III.
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`IV.
`V.
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`Petitioner’s Reply, IPR 2014‐00415
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`Exhibit No.
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`List of Petitioner’s Exhibits
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`Description of Document
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`1001
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`1002
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`1003
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`1004
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`1005
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`1006
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`1007
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`U.S. Patent No. 6,415,316 to Joannes Van Der Meer
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`Declaration of Edward R. (“Ed”) Tittel
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`Rulings pertaining to claim construction in Rembrandt Social Media,
`L.P. v. Facebook, Inc., No. 13‐CV‐00158 TSE (E.D. Va.)
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`Transcript of Court Hearing dated June 6, 2013 in Rembrandt Social
`Media, L.P. v. Facebook, Inc., No. 13‐CV‐00158 TSE (E.D. Va.)
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`U.S. Patent No. 6,233,600 to Pito Salas et al.
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`Ed Tittel et al., More HTML for Dummies (2d ed 1997), pp. xv‐xxv,
`57‐84, 153‐180, 341‐364
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`Ed Tittel et al., Foundations of World Wide Programming with
`HTML and CGI (1995), pp. xxi‐xxxvi, 125‐144
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`1008 William Martiner, Visual Basic Programmer’s Guide to Web
`Development (1997), pp. vii‐xiii, 47‐97
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`1009
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`David Fox et al., Web Publisher’s Construction Kit with HTML 3.2
`(1996), pp. vii‐xxv, 5‐47, 51‐61, 629‐655
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`1010 M. Frans Kaashoek et al., Dynamic Documents: Mobile Wireless
`Access to the WWW (1995)
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`1011
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`1012
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`1013
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`U.S. Patent No. 5,729,734 to Robert D. Parker et al.
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`U.S. Patent No. 5,933,811 to Paul Angles et al.
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`U.S. Patent No. 6,289,362 to Joannes Van Der Meer
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`1014 Mark R. Weinstein Bio
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`1015
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`1016
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`Second Declaration of Edward R. (“Ed”) Tittel
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`Transcript of 01/16/2015 Deposition of Mark T. Jones, Ph.D.
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`ii
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`Petitioner’s Reply, IPR 2014‐00415
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`List of Petitioner’s Exhibits
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`Description of Document
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`Exhibit No.
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`1017
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`Excerpts from Rembrandt’s Opening Claim Construction Brief in
`Rembrandt Social Media, L.P. v. Facebook, Inc., No. 13‐CV‐00158
`TSE (E.D. Va.)
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`iii
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`Petitioner’s Reply, IPR 2014‐00415
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`I.
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`INTRODUCTION
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`With the exception of the “privacy level information” limitations in
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`independent claims 1 and 17, the patent owner does not dispute that the prior art
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`discloses every limitation of every challenged claim. The patent owner’s
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`arguments should be rejected because they are based on the narrow construction
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`of “privacy level information” that the Board properly rejected. Because Salas
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`and Parker fully disclose the “privacy level information” limitations properly
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`construed, and the patent owner provides no arguments about any other claim
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`limitations, the Board should find claims 1, 4, 17, 18, 20 and 26 invalid.
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`II.
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`CONSTRUCTION OF “PRIVACY LEVEL INFORMATION”
`A.
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`“Privacy Level Information” Need Not Specify a “Universe” of Users
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`The patent owner asks the Board to narrow its construction of “privacy
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`level information” to require that it describe “the universe of one or more users
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`or categories of users permitted to view particular content on a cohesive diary
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`page.” (Resp. at 48‐49.) This proposal should be rejected for several reasons.
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`The specification does not use the word “universe” (or any variant of that
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`word) in its discussion of privacy level features. The specification instead
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`discusses the “privacy level” features in broad terms, and in displaying a page, by
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`reference to a single individual. (’316, Ex. 1001, 5:55‐67.) “If a user does not have
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`1
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`Petitioner’s Reply, IPR 2014‐00415
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`sufficient permission to view an object in a diary,” the patent explains, “the diary
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`may not make the object visible to the user, i.e., the user does not even know
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`that the object exists, or
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`it may present the object using an alternate
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`representation.” (’316, 5:63‐67 (emphasis added).) Nothing in the specification
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`requires that the claimed “privacy level information” specify a “universe” of users.
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`In fact, the claims themselves are specifically written from the perspective
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`of a single “user system” – the one for which the cohesive diary page is being
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`assembled. (’316, claims 1 and 17 (assembling a cohesive diary page for a single
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`“user system”).) For example, if “User X” is attempting to access a diary page, the
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`diary server sends “privacy level information” relating to that “User X” so that the
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`diary program on the user system can assemble the diary page on that user
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`system. Nothing in the claims suggests that the diary server sends “privacy level
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`information” about other users. (Tittel Reply Decl., Ex. 1015, ¶¶ 6‐8.) And there
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`would be no reason the diary server would ever send “privacy level information”
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`about other users – the claim is concerned only with assembling a cohesive diary
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`page for the particular “user system” recited in the claim. (Id. ¶¶ 9‐10.)
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`The patent owner relies heavily on Figure 4(d) of the ’316 patent, which
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`shows a user interface for a diary owner to set a privacy level with respect to a
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`diary page. (Resp. at 50‐51.) But Figure 4(d) describes an unclaimed feature in
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`Petitioner’s Reply, IPR 2014‐00415
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`which a diary owner sets privacy levels for a diary page. (Id. (citing ’316, 10:28‐
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`54).) That process occurs (if at all) well before the steps of claim 1 occur. By the
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`time the steps of claim 1 occur, the privacy levels have already been set by the
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`diary page owner. Figure 4(d) is therefore not informative on the meaning of
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`“privacy level information” as it pertains to the subsequent assembly and display
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`of a cohesive diary page on a particular “user system,” as recited in the claims.
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`The patent owner rests its argument on the word “level” and argues that it
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`implies some sort of “gradation” of multiple privacy levels. (Resp. at 52‐53.)1 But
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`the claim does not require “privacy levels” – it merely recites sending “privacy
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`level information,” using “level” in singular form. Information about only one
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`user falls squarely within the broadest reasonable construction of “privacy level
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`information,” and is entirely consistent with the claim language’s focus on the
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` 1
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` The patent owner cites Mr. Tittel’s deposition testimony for its “gradation”
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`argument, but that testimony was in the context of Figure 4(d) and initial setting
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`of privacy levels by the diary page owner. (Resp. at 53‐54.) As explained in the
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`text, this process is irrelevant to the “privacy level information” sent to a user
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`system when a diary page is later assembled. (Tittel Reply Decl., Ex. 1015, ¶¶ 7‐8.)
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`Petitioner’s Reply, IPR 2014‐00415
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`singular user system for which the cohesive diary page is being assembled.
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`B.
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`“Privacy Level Information” Does Not Require Client‐Side Filtering
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`Another suggestion appearing throughout the Response is that the claims
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`require “privacy level information” to be used at the user system – not the
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`server – to perform the actual filtering of content, i.e. preventing the user from
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`viewing content it is not permitted to view. (Resp., at 3 (“Like Salas, Parker’s
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`access control takes place at the server, not at the user system.”), 24‐30, 43‐44.)2
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`This suggestion should be rejected because the claims under their broadest
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`reasonable construction allow content filtering to occur at the server with no
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` 2
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` The patent owner specifically argued in the district court litigation that the
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`claims do not require client‐side content filtering. (Ex. 1017, Patent Owner’s
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`Claim Construction Brief, at p. 10 (“Rembrandt disputes the imposition of such a
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`restriction and proposes a construction that permits the filtering to happen at the
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`user system or at the server.”).) The district court agreed with the patent owner.
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`(Ex. 1004, at 13:1‐9, 26:8‐27:2.) Having convinced the district court to adopt a
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`construction that does not require client‐side content filtering, the patent owner
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`should be estopped from advocating an irreconcilably narrower position here.
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`involvement by the client. Claim 1 on its face requires only that (1) the diary
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`server send “privacy level information” to the user system, and that (2) the user
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`system assemble a cohesive diary page “in accordance with” that information.
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`This language under its broadest reasonable construction only requires the user
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`system to assemble a diary page that is consistent with the privacy level
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`information sent by the server – it does not require use of the privacy level
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`information at the user system to select and filter content. The patent owner’s
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`expert agreed at his deposition. (Jones Depo., Ex. 1016, at 11:25‐12:7.)
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`III.
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`SALAS AND PARKER DISCLOSE SENDING “PRIVACY LEVEL INFORMATION”
`TO THE USER SYSTEM AND ASSEMBLING A COHESIVE DIARY PAGE
`A.
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`Brief Summary of How Salas & Parker Disclose Privacy Information
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`Salas discloses a “cohesive diary
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`page” in the form of an eRoom page such
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`as the one in Figure 4 (at right). The
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`“content data” comprises (among other
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`things) objects in the item box (408)
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`including “Brainstorms”
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`(482), “Press
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`Notes” (486), “Budget Projections” (488)
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`and “Staff Plan” (490). The buttons on the bottom right of the item box allow the
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`content items to be shown as icons (494), in a list (496), or in report view (498),
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`the latter modes causing additional metadata information about the items (such
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`as dates) to be displayed on the page. (Petition at 36‐37, 40.) Salas discloses
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`“privacy level information” in the form of file metadata that includes “access
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`information such as which users may open, view, and edit the file.” (Salas, 13:52‐
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`57.) As explained in detail in Part III.B below, Salas makes clear that this access
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`information is transmitted from the eRoom server to the client computer.
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`Parker describes a network‐based file access system similar to Salas that
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`adds the ability to display items in a way that visually indicates the access or
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`privilege level granted to the viewing user.
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`This is shown in Figure 7 (shown in relevant
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`part at right), which shows how “User C” will
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`see two content items – folders 417 and 419.
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`The
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`item “test
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`folder‐1”
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`(417) appears
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`unobstructed with a “lock open” icon (487) because the “User C” was given access
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`that folder. But for “test folder‐2” (419), because the administrator did not grant
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`“User C” rights to that folder, the user sees the folder name greyed out and with a
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`“lock closed” icon (488). (Parker, 11:32‐35, 11: 40‐47.) Other icons could appear,
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`such as an “eye glasses” icon to indicate that the user has read access, and a
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`Petitioner’s Reply, IPR 2014‐00415
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`“writing instrument” indicating the right to modify the document. (Id., 11:50‐64.)
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`Parker mirrors the language of claim 1 by describing Figure 7 as showing a
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`display “from user C's perspective (i.e., in accordance with user C's access
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`privileges as if the administrator was sitting at user C's client terminal).” (Parker,
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`11:32‐35 (emphasis added).) As explained below, it is undisputed that the server
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`in Parker sends access privilege information to the user system – even the patent
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`owner’s expert agreed at his deposition. (Jones Depo., Ex. 1016, at 21:23‐23:12.)
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`B.
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`The Server in Salas Sends “Privacy Level Information” to the Client
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`The crux of the patent owner’s argument is that Salas and Parker do not
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`disclose sending “privacy level information” to the user system, and therefore, do
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`not disclose assembly of the diary page “in accordance with” that information.
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`With respect to Salas, the patent owner spends a large number of pages pointing
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`out various ways in which the server in Salas controls access to eRooms and their
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`contents. But the server’s involvement in these processes does not show that the
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`server does not also send privacy level information to the user system.
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`Salas discloses “configuration information” and “privacy level information”
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`in the form of file metadata, described in Salas as follows:
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`File metadata may include: the name of the file; the size of the file;
`the date the file was created; the date the file was last modified;
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`access information such as which users may open, view, and edit the
`file; and information regarding the edit status of the file, such as
`whether an edit lock has been set by a user.
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`(Salas, 13:52‐57 (underlining added).) As explained in the Petition and correctly
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`observed by the Board, Salas makes clear that the server sends this file metadata
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`to the user system. (Petition at 40‐41; Decision at 17‐18.) The Board recognized
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`in its Decision that the eRoom page displayed on the user system (such as Figure
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`4) can specifically display file metadata, “such as filename, creation date,
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`modified date, and which application should be used to open and edit the file.”
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`(Id. at 17.) The user system simply could not present the eRoom page with file
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`names, dates, and other file metadata if the server did not send that metadata
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`before the page was generated at the client. (Tittel Reply Decl., Ex. 1015, ¶ 18.)
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`For this reason, the patent owner wisely does not dispute that the server in
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`Salas sends some of the file metadata to the user system. The patent owner
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`instead asserts that the server excludes the “access information” from the
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`metadata it sends to the client. But there is no support in Salas for this position.
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`Salas specifically discloses a “local database metadata” synchronization
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`process in Columns 11 and 12 that results in the server sending metadata to the
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`user system for local storage. (Petition at 40‐41; Salas, 11:42‐12:6.) The patent
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`Petitioner’s Reply, IPR 2014‐00415
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`owner speculates that the synchronized “local database metadata” does not
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`include the “access information” in Salas, but offers no support. As the Board
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`observed, the patent owner “cites nothing in Salas to suggest that file metadata
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`does not include access information.” (Decision at 17 (italics in original).)
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`The patent owner rests its speculation on the fact that the passages in Salas
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`describing local metadata synchronization do not specifically mention the “access
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`information” metadata. (Resp. at 20‐25.) But this is irrelevant. Salas’s discussion
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`of metadata synchronization also does not mention synchronizing the file name,
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`file creation and modification date and application type – but this file metadata is
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`indisputably sent to the client and appears on the eRoom page. Nothing in Salas
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`suggests that the eRoom server specifically removes “access information” from
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`the metadata it sends to the client in the synchronization process.
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`The gist of the patent owner’s argument appears to be that the server in
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`Salas does not send the access information because, according to the patent
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`owner, the client does not use it to control access. But the access information is
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`certainly used at the client. It specifies “which users may open, view, and edit the
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`file” (Salas, 13:54‐55), and is checked when a user attempts to download a file:
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`If no edit lock has been set for a requested file, the access rights of
`the requesting user are checked. If the user has appropriate access
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`rights, i.e., “can edit” if the user has indicated editing will occur or
`“can view” if the user has indicated only viewing will occur, the user
`will be allowed to retrieve the file. In the case of a user that indicated
`editing will occur, an edit lock is set before the file is downloaded.
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`(Salas, 12:34‐39 (underlining added).) The patent owner fixates on where this
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`particular access check takes place, but the claim language does not require that
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`the check occur on the client as explained in Part II.B above. The issue is whether
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`the access information is sent from the server to the client system. And it is.
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`As the above‐quoted passage makes clear, when a file is downloaded to a
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`client, there may be restrictions on how it may be used at the client after it is
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`downloaded. Once the file is downloaded, the client launches the appropriate
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`software application. (Salas, 2:42‐43 (“An application capable of viewing the file
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`is invoked.”).) If the user’s access privileges include “can view” but do not include
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`“can edit,” for example, the file will be downloaded and viewable but the user will
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`not be allowed to modify its contents. (Tittel Reply Decl., Ex. 1105, ¶¶ 21‐22.)
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`The patent owner’s expert conceded that the user’s local computer must
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`enforce these access privileges when a selected file is downloaded to the user’s
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`system. (Jones Depo., Ex. 1016, at 12:24‐14:18.) This is common sense – a user
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`computer obviously cannot enforce access restrictions (such as “read only”)
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`unless it knows what those restrictions are. (Id.; Tittel Reply Decl., Ex. 1015, ¶
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`23.) The patent owner has no reasonable basis to dispute that the server in Salas
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`sends the access control file metadata to the user system.
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`C.
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`Parker Also Sends “Privacy Level Information” to the Client, and
`Assembles the Page “In Accordance With” that Information
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`Even if there was some question as to whether Salas sends “privacy level
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`information” to the user system, this step is also disclosed by Parker. Parker
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`further discloses displaying content data “in accordance with” received privacy
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`level information and renders the claims obvious in combination with Salas.
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`As explained above, Figure 7 of Parker
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`shows folders in a way that visually indicates the
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`privilege
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`level granted to the viewing user.
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`(Parker, 11:32‐35.) One of ordinary skill in the art
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`would have understood that in Parker, like Salas, the server sends the access
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`privilege information to the user system. This is because in order to show “test
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`folder‐1” and “test folder‐2” to the user “in accordance with” (i.e. consistent with)
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`the user’s access privileges, the server must have sent those access privileges to
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`the user computer. Both sides’ experts are in full agreement on this point. (Jones
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`Depo., Ex. 1016, at 21:23‐23:12; Tittel Reply Decl., Ex. 1015, ¶¶ 23, 29‐30.) The
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`fact that Parker expressly states that it displays the files and folders “in
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`accordance with user C's access privileges” (Parker, 11:32‐35) conclusively shows
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`that those access privileges were transmitted from the server to the user system.
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`D.
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`The Patent Owner’s Attempt to Confuse the Displayed Content
`Data with Data in the Underlying Files Should Be Rejected
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`The patent owner argues that, even if the access privilege information Salas
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`and Parker is sent to the user system, that information still does not qualify as
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`“privacy level information.” This is because, according to the patent owner, the
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`access information in Salas and Parker is about access to underlying files or
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`folders themselves, not the icons and other file information displayed to the user
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`that correspond to the claimed “content data.” (Resp. at 8‐9, 15‐16, 43‐46.)
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`The problem with this argument is that it assumes limitations not recited in
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`the claims. “Privacy level information” specifies at least one user who is
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`permitted to view particular content on a cohesive diary page – it need not
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`specify users who are not permitted. In Salas and Parker, the access information
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`specifies that the viewing user is permitted to view the content items such as the
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`file names and other file information. Parker further discloses that the visual
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`appearance of those items may change based on the viewing user’s access
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`privileges. The use of the access information in this manner clearly satisfies the
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`“privacy level information” claim limitations, regardless of whether the access
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`information also controls access to the underlying files.
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`The ’316 patent does not require that “privacy level information” be used
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`to hide information from display. For example, the specification explains that
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`depending on the user’s permissions, an object may be concealed or the browser
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`“may present the object using an alternate representation.” (’316, 5:63‐67
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`(emphasis added).) This is precisely what Parker discloses. (Parker, 11:50‐64.)
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`This satisfies the claim language because the combination of Salas and Parker
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`discloses generation of a diary page at the user system “in accordance with,” i.e.
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`consistent with, the access privilege information sent from the server. Nothing
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`more is required by the claims under their broadest reasonable construction.
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`IV.
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`SALAS AND PARKER ARE PROPERLY COMBINABLE
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`Finally, the patent owner argues that Salas and Parker cannot be combined.
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`(Resp. at 56‐60.) This argument is based on a gross mischaracterization of Salas.
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`The patent owner quotes a passage at Column 14, lines 42‐50 of Salas
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`describing how eRoom members can be assigned different roles (e.g. coordinator,
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`reader), each role specifying a different level of access. (Resp. at 56‐57.) There is
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`no reason to combine Salas with Parker, according to the patent owner, because
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`a user’s access rights in Salas are determined by its assigned role, and thus, there
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`would be no need to show different access privileges among the displayed items,
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`as described in Parker. (Id.)
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`But Salas makes clear that deriving access rights based on roles is simply
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`one embodiment. In fact, an earlier sentence of the passage cited by patent
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`owner, but not quoted in its Response, states that access levels can be assigned to
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`each individual object. (Salas, 14:37‐39.) Another passage in Salas makes clear
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`that assignment of “access rights” based on roles is just an “alternative” to
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`assigning access rights separately to each file on a user‐by‐user basis:
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`Access rights may be checked over the network in many ways. For example,
`each object may be provided with a field or fields which identify users that
`may open, view, and edit the object. Alternatively, an object may assign a
`pre‐defined value to a field which controls access to the object. For
`example, a “coordinator” role may be defined and an object may identify
`that any coordinator may edit, open or view it.
`
`(Salas, 13:31‐37 (emphasis added); see also id., 13:52‐57 (“File metadata may
`
`include: . . . access information such as which users may open, view, and edit the
`
`file…”) (emphasis added).) Because assignment of access rights based on the
`
`“role” of a member is simply an “alternative” to assigning them separately for
`
`each file, the patent owner’s arguments about combining Salas and Parker lack
`
`merit. Federal Circuit law is clear that “mere disclosure of alternative designs
`
`14
`
`
`
`Petitioner’s Reply, IPR 2014‐00415
`
`
`does not teach away.” In re Fulton, 391 F.3d 1195, 1201 (Fed. Cir. 2004).
`
`As the Board recognized, a person of ordinary skill in the art would have
`
`been motivated to combine Salas and Parker so that a user of Salas could visually
`
`ascertain which actions it is allowed to perform on the displayed files and folders.
`
`(Decision at 18; Petition at 47.) For example, Salas discloses that a user may, for a
`
`particular file, be able to view the file but may lack permission to edit it. (Salas,
`
`12:34‐39, 13:52‐57.) Parker explains that files can be displayed to users with an
`
`“eye glasses” icon indicating read privileges, and if the user has write privileges,
`
`with a “writing instrument” icon. (Parker, 11:60‐64.) Parker expressly discloses
`
`the advantage of this feature – allowing users to distinguish their access privileges
`
`based on how the items appear on their display. (Id., 11:50‐54; Tittel Reply Decl.,
`
`Ex. 1015, ¶¶ 35‐36.) A person of ordinary skill would have had ample motivation
`
`to combine Salas and Parker to produce a system that assembles and displays an
`
`eRoom page in accordance with the user’s access privileges.
`
`V.
`
`CONCLUSION
`
`For all of the foregoing reasons, the Board should reject the patent owner’s
`
`arguments and enter a final decision finding claims 1, 4, 17, 18, 20 and 26 invalid
`
`under 35 U.S.C. § 103 based on the prior art cited in the Petition.
`
`15
`
`
`
`Petitioner’s Reply, IPR 2014‐00415
`
`
`Dated: January 20, 2015
`
`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Ave., NW, Suite 700
`Washington, DC 20004
`Tel: (650) 843‐5007
`Fax: (650) 849‐7400
`
`
`
`
`By:
`
`
`
`
`Respectfully submitted,
`
`
`/Mark R. Weinstein/
`Mark R. Weinstein
`Pro Hac Vice
`Counsel for Petitioner
`Facebook, Inc.
`
`16
`
`
`
`Petitioner’s Reply, IPR 2014‐00415
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify, pursuant to 37 C.F.R. section 42.6, that a complete
`
`copy of the attached PETITIONER’S REPLY IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW and Exhibit Nos. 1015‐1017, are being served via
`electronic mail on the 20th day of January, 2015, the same day as the filing
`of the above‐identified document
`in the United States Patent and
`Trademark Office/Patent Trial and Appeal Board, upon the patent owner’s
`attorneys of record:
`
`LEAD COUNSEL
`Robert H. Hillman
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`hillman@fr.com
`IPR2014‐00415@fr.com
`[Ref. No. 37115‐0002IP1]
`
`BACK‐UP COUNSEL
`Lawrence K. Kolodney
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`kolodney@fr.com
`
`John S. Goetz
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`goetz@fr.com
`
`
`
`
`
`/Mark R. Weinstein/
`Mark R. Weinstein
`Pro Hac Vice
`
`
`Cooley LLP
`ATTN: Patent Group
`1299 Pennsylvania Ave., NW, Suite 700
`Washington, DC 20004
`Tel: (650) 843‐5007
`Fax: (650) 849‐7400
`
`1
`
`
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