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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________
`
`PARROT S.A. and PARROT, INC.
`Petitioners
`v.
`DRONE TECHNOLOGIES, INC.
`Patent Owner
`____________
`
`Case IPR2014-00732
`Patent 8,106,748
`____________
`
`
`
`
`PATENT OWNER’S RESPONSE TO PETITION FOR
`INTER PARTES REVIEW OF U.S. PATENT NO. 8,106,748
`CASE IPR2014-00732
`
`
`
` 
`
`

`

`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`
`TABLE OF CONTENTS
`
`
` SPIROV FAILS AS A PRIMARY REFERENCE ............................................. 4
`I.
`A. Petitioners’ Citations to Spirov Do Not Support Their Contentions................ 4
`B. Petitioners’ Citations to Spirov Describe Components of One System ........... 8
`II. NEITHER BATHICHE NOR SHKOLNIKOV IS ANALOGOUS ART ..... 10
`III. PETITIONERS’ DECLARANT’S TESTIMONY SHOULD BE GIVEN
`LITTLE OR NO WEIGHT ............................................................................ 13
`IV. PATENT OWNER PRESERVES ITS OBJECTIONS TO PETITIONERS’
`UNSIGNED DECLARATION ...................................................................... 14
`V. CONCLUSION ............................................................................................... 15
`VI. CERTIFICATE OF SERVICE ....................................................................... 17
`
`
`
`
`
` 
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`2 
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`

`

`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`
`EXHIBIT LIST
`
`Description
`
`
`Exhibit No.
`U.S. Patent 8,106,748
`1001
`U.S. Patent 5,043,646
`1002
`French Patent No. 2789765
`1003
`Certified Translation of French Patent No. 2789765
`1004
`U.S. Publication No. 2006/0144994
`1005
`1006
`Exhibit Intentionally Left Blank
`U.S. Patent No. 7,219,861
`1007
`U.S. Patent No. 6,751,529
`1008
`U.S. Patent No. 7,145,551
`1009
`U.S. Publication No. 2004/263479
`1010
`Declaration of Dr. Raffaello D’Andrea (Attachments A-C)
`1011
`U.S. Patent No. 613,809 to Tesla (“Tesla”)
`1011, Att. A
`U.S. Patent No. 3,101,569 to Giardina (“Giardina”)
`1011, Att. B
`U.S. Patent No. 8,072,417 (“Jouanet”)
`1011, Att. C
`1011 (corrected) Corrected Declaration of Dr. Raffaello D’Andrea
`1012
`Claim Chart
`1013
`Declaration of Deborah Skolaski
`1014
`Declaration of James Hopenfeld
`1015
`Declaration of Dr. Raffaello D’Andrea
`2001
`D’Andrea Deposition Exhibit – Declaration Signature
`Page, ‘071
`D’Andrea Deposition Exhibit – Appendix A, Materials
`Considered by Dr. Raffaello D’Andrea
`D’Andrea Deposition Exhibit – Smith Patent
`D’Andrea Deposition Exhibit – Potiron Patent, French
`D’Andrea Deposition Exhibit – Translations Certification
`D’Andrea Deposition Exhibit – Declaration, ‘071
`D’Andrea Deposition Exhibit – Lee Patent, ‘071
`D’Andrea Deposition Exhibit – Bathiche Patent
`D’Andrea Deposition Exhibit – Declaration, ‘748
`D’Andrea Deposition Exhibit – Parrot Exhibits 1011 and
`1010
`D’Andrea Deposition Exhibit – Lee Patent, ‘748
`Transcript of Dr. Raffaello D’Andrea Deposition
`Declaration of Robert Sturges
`
`2002
`
`2003
`2004
`2005
`2006
`2007
`2008
`2009
`2010
`
`2011
`2012
`2013
`
`
`
`
` 
` 
`
`
`
`3 
`
`
`Date Filed
`5/6/2014
`5/6/2014
`5/6/2014
`5/6/2014
`5/6/2014
`n/a
`5/6/2014
`5/6/2014
`5/6/2014
`5/6/2014
`5/6/2014
`5/6/2014
`5/6/2014
`5/6/2014
`2/9/2015
`5/6/2014
`2/9/2015
`2/9/2015
`2/9/2015
`Not filed
`
`Not filed
`
`Not filed
`Not filed
`Not filed
`Not filed
`Not filed
`Not filed
`Not filed
`Not filed
`
`Not filed
`2/11/2015
`2/11/2015
`
`

`

`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`I.
`
`SPIROV FAILS AS A PRIMARY REFERENCE
`
`Spirov fails as the primary reference because, contrary to Petitioners’
`
`representation, it does not disclose “two configurations, each implemented using
`
`the same remote controller.” Paper No. 1, at 20; Ex. 1011, ¶ 77.
`
`The absence in Spirov of two configurations in the same controller is critical
`
`because, without multiple configurations, there is no need for a “configuration
`
`switch” mandated by claim 1 of the ‘748 Patent. Ex. 1001, col. 7, l. 54. After all,
`
`there is nothing to switch between.
`
`This also explains why Petitioners could not identify any such switch in
`
`Spirov, and resorted to claiming that it was “inherently disclosed.” Ex. 1011, ¶ 78.
`
`Without multiple configurations in the same controller, no person of
`
`ordinary skill in the art would have any reason (or way) to add a configuration
`
`switch to Spirov. Spirov thus fails as the primary reference, and the obviousness
`
`rejections based on Spirov therefore fail as well.
`
`Petitioners’ Citations to Spirov Do Not Support Their Contentions
`
`A.
` 
`
`To support their argument, Petitioners were forced to claim that Spirov
`
`describes two configurations, each implemented using the same remote controller.
`
`Petitioners’ declarant provided the necessary proffer:
`
`77. Spirov necessarily discloses a switch module to select
`between configurations. Spirov describes two
`configurations, each implemented using the same remote
`4 
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`

`

`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`
`controller. Each configuration corresponds to a module
`as described in claim 1. In the first configuration, the
`yaw, roll, and pitch are determined by a sensor
`arrangement (i.e., sensing module), which in turn is
`comprised of accelerometers and other sensing devices.
`Pet. Ex. 1005 at ¶¶ 0077 and 0087. In the second
`configuration, the yaw is determined by a thumb-
`activated yaw control (i.e., a manual input module),
`while roll and pitch are determined by the sensor
`arrangement (i.e., a combination of the first acceleration
`sensing module and the manual input module). Pet. Ex.
`1005 at ¶¶ 0070 and 0082. A switch necessarily exists
`because the remote controller includes both thumb
`activated yaw control (Figs. 3 and 22a) and sensed yaw
`control (Figs. 29 and 31).
`Ex. 1011, ¶ 77 (emphasis added). Spirov, however, does not “describe[] two
`
`configurations, each implemented using the same remote controller,” and a review
`
`of Petitioners’ citations demonstrates that fact.
`
`To begin with, the word “configuration” is not used in Spirov in any context
`
`that would suggest the “two configurations, each implemented using the same
`
`remote controller.”1 Ex. 1005.
`
`Petitioners’ own citations similarly fail to support the notion that Spirov
`
`describes two configurations. The first citation (quoted above) is to paragraph
`
`0077 of Spirov. Ex. 1005. That paragraph is a continuation of the discussion that
`
`Spirov begins at paragraph 0073 relating to the remote-controlled aircraft, not the
`
`                                                            
`Similarly, Spirov does not use the word “mode” and only uses the term
`1  
`“switch” in connection with the phrases “tilt switch,” “switching frequency
`of the duty cycle,” and “switching magnetic flux.” Ex. 1005. 
`5 
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`

`

`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`remote controller. The discussion expressly begins, “[t]he RC [radio controlled]
`
`aircraft includes . . .” Ex. 1005, ¶ 0073.
`
`Each subsequent paragraph, including the cited paragraph 0077 also relates
`
`to the remote-controlled aircraft, and not the remote controller: ¶ 0074 (“ducted fan
`
`assembly . . . of the homeostatic flying hovercraft. . .”); ¶ 0075 (“at least six fan
`
`blades . . .”); and ¶ 0076 (repeated mention of “thrusters”). Ex. 2013 (Sturges
`
`Decl.), ¶36.
`
`In paragraph 0076, Spirov begins a discussion of the “XYZ sensor
`
`arrangement 302,” clearly in the context of the remote controlled-aircraft and not
`
`the remote controller (as confirmed by the discussion of thrusters, which are on the
`
`remote-controlled aircraft and not on the remote controller). Ex. 2013 (Sturges
`
`Decl.), ¶ 36. Spirov’s discussion of the XYZ sensor arrangement continues
`
`through paragraphs 0077, 0078, 0079, and 0080. Ex. 1005; Ex. 2013 (Sturges
`
`Decl.), ¶¶ 36-37.
`
`It is clear from the discussion that the XYZ sensor arrangement refers to the
`
`sensors on the remote-controlled aircraft, and not to any sensors in the remote
`
`controller. There is no mention of the remote controller at all in any of these
`
`paragraphs (only once the topic changes, in paragraph 0082). So it is quite
`
`surprising that Petitioners cite to paragraph 0077 of Spirov as support for their
`
` 
` 
`
`6 
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`

`

`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`claim that this is the first of “two configurations, each implemented using the same
`
`remote controller.” Paper No. 1, at 20; Ex. 1011, ¶ 77.
`
`Petitioners also cite to paragraph 0087, which admittedly references the
`
`remote controller described in FIG. 3. Ex. 1005. However, while paragraph 0087
`
`and FIG. 3 reference the remote controller, there is absolutely no mention of
`
`anything suggesting the presence of “two configurations, each implemented using
`
`the same remote controller.” Paper No. 1, at 20; Ex. 1011, ¶ 77.
`
`Significantly, paragraph 0087 makes no mention of “yaw control”— it
`
`simply is not there. Thus paragraph 0087 cannot support Petitioners’ contention
`
`that “[i]n the first configuration, the yaw, roll, and pitch are determined by a sensor
`
`arrangement.” Ex. 1011, ¶ 77. Without yaw “determined by a sensor
`
`arrangement,” Petitioners’ claim of “two configurations” fails.
`
`In an apparent act of desperation, Petitioners cite to paragraph 0077 (Ex.
`
`1005) for that support. After all, paragraph 0077 does mention the term yaw (“at
`
`least one sensor that senses yaw in the Z plane”), albeit only in the context of the
`
`remote-controlled aircraft and not in describing the remote controller. Petitioners
`
`are nevertheless forced to make this leap because they have no other option.2
`
`                                                            
`2
`Petitioners and their declarant rely on similarly flawed citations in other
`instances. For example, they each cite to Figure 28 and paragraph 63 of
`Spirov as disclosing “a first acceleration module” of the remote controller
`from claim 1. Ex. 1012 at 1-3. They subsequently cite to the very same
`disclosure for the “second acceleration sensing module” of the remote-
`7 
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`

`

`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`Petitioners’ have no support for their contention that “[i]n the first configuration,
`
`the yaw, roll, and pitch are determined by a sensor arrangement.” Ex. 1011, ¶ 77.
`
`Having a separate and independent configuration in which “yaw . . . [is]
`
`determined by a sensor arrangement” is critical for Petitioners’ argument because
`
`Spirov does disclose manually controlling yaw. For what Petitioners present as the
`
`“second configuration,” i.e., manually controlling yaw, Petitioners cite to
`
`paragraph 0070 as disclosing a “control stick 222” for “thumb control,” and
`
`paragraph 0082 as disclosing “a thumb-activated throttle and yaw control.”
`
`Ex. 1005, ¶ 0082. This citation does support Petitioners’ description of a manually
`
`controlled yaw, but that provides the one and only configuration disclosed by
`
`Spirov that is “implemented using the same remote controller.” Ex. 1011, ¶ 77.
`
`B.
`
`Petitioners’ Citations to Spirov Describe Components of One System
`
`Petitioners fail to acknowledge that Spirov is merely describing the
`
`components of its system, not two configurations. Figure 29 of Spirov (also cited
`
`by Petitioners, Ex. 1011, ¶ 77) shows X and Y accelerometers (left stack of boxes),
`
`the thumb control stick (central box titled “yaw”), and XYZ gyros all feeding their
`
`                                                                                                                                                                                                
`controlled vehicle of claim 1. Id. at 9-10. This was not just a clerical error
`because Petitioners repeat the same flawed analysis in the Petition. Paper
`No. 1 at 27, 34. Petitioners repeated misattribution of the flying saucer
`systems to the remote controller demonstrate, at best, a fundamental
`misunderstanding of Spirov.
`
` 
`
` 
` 
`
`8 
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`

`

`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`signals into the same multiplexer (“MUX”) and analog-to-digital converter (“12 bit
`
`A/D”). Ex. 1005, FIG. 29. Spirov operates using this entire range of input. This is
`
`a single, lone configuration, and there is no indication of additional components
`
`that would enable switching between any alleged configurations. Ex. 2013 (Sturges
`
`Decl.), ¶¶ 38-39.
`
`Additionally, paragraph 0093 of Spirov describes the operation of the
`
`hovercraft. Ex. 1005, ¶ 0093; Ex. 2013 (Sturges Decl.), ¶ 31. There, Spirov
`
`describes how “XY axis mercury tilt switch transducers” work in tandem with
`
`“XYZ piezo gyros” and “any other I/O devices.” Ex. 1005, ¶ 0093. This further
`
`demonstrates that that Spirov simply does not operate in two modes. Petitioners’
`
`first alleged mode utilizes “accelerometers and other devices,” (XYZ sensors; Ex.
`
`1012 at 1) while the second alleged mode employs “sensed motion of the remote
`
`and manipulation of the joystick” (XY sensors + thumb control stick). Paper No. 1
`
`at 19-20. Figure 29 and paragraph 0093 of Spirov demonstrate that there is no
`
`such division. Instead, the various systems disclosed in Spirov work together to
`
`achieve control of the hovercraft. Ex. 2013 (Sturges Decl.), ¶¶ 31, 38-39.
`
`Petitioners’ citation to Spirov’s disclosure of different functional
`
`components does not prove that those components operate independently of one
`
`another in different configurations or modes. Petitioners’ inaccurate and flawed
`
`characterization of Spirov indicates just how difficult it is to find multiple
`
` 
` 
`
`9 
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`

`

`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`configurations or modes of operation where only one configuration exists. See also
`
`id. at ¶¶ 40-42.
`
`It is clear that Spirov discloses neither “two configurations, each
`
`implemented using the same remote controller” nor an “inherently disclosed”
`
`configuration switch. The obviousness rejections should be withdrawn and all
`
`claims confirmed.
`
`II. NEITHER BATHICHE NOR SHKOLNIKOV IS ANALOGOUS ART
`
`To be used in an obviousness rejection, as Bathiche and Shkolnikov are, a
`
`reference must be analogous to the claimed invention. This consideration assesses
`
`“whether the art is ‘too remote to be considered prior art.’” In re Clay, 966 F.2d
`
`656, 658 (Fed. Cir. 1992) (quoting In re Sovish, 769 F.2d 738, 721 (Fed. Cir.
`
`1985)). This assessment requires evaluation of two criteria: “(1) whether the art is
`
`from the same field of endeavor, regardless of the problem addressed, and (2) if the
`
`reference is not within the field of the inventor’s endeavor, whether the reference
`
`still is reasonably pertinent to the particular problem with which the inventor is
`
`involved.” Id. at 659. The doctrine of analogous art serves to limit the scope of
`
`obviousness, in that “[t]he combination of elements from non-analogous sources,
`
`in a manner that reconstructs the applicant’s invention only with the benefit of
`
` 
` 
`
`10 
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`

`

`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`hindsight, is insufficient to present a prima facie case of obviousness.” In re
`
`Oetiker, 977 F.2d 1443, 1447 (Fed. Cir. 1992).
`
`Neither Bathiche nor Shkolnikov is analogous prior art and the use of these
`
`references in an obviousness rejection of any claim is inappropriate. Bathiche is
`
`directed to a hand held computer input device. Ex. 1009, abstract. As defined by
`
`the Petitioners’ declarant, the ‘748 Patent relates “to controlling dynamic systems,
`
`and specifically how they relate to flying things:”
`
`Q: Meaning that the ‘071 and ‘748 patents are related to
`controlling dynamic systems?
`That is correct.
`A:
`Q: Are they also related to controlling dynamic systems, and
`specifically how they relate to flying things, such as airplanes
`and drones?
`I would say that they are.
`A:
`Ex. 2012, p. 13, ll. 10-16.
`Petitioner’s declarant further explained that the problem being addressed by
`
`the ‘748 Patent “was to be able to control these vehicles in a[n] as-claimed easier
`
`way:”
`
`A:
`
`Q: What was the problem that you determined was being
`addressed by the respective patents?
`The problem being addressed was to be able to control these
`vehicles in a[n] as-claimed easier way.
`Easier than what?
`Easier than what had been done before.
`
`Q:
`A:
`
` 
` 
`
`11 
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`

`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`
`Q: Okay. And what had been done before?
`A:
`Jeeze.
`MR. HOPENFELD: Objection. Vague and ambiguous.
`A: What is the question? What has been done before in what? In
`the sense of controlling vehicles? How much time do we have?
`Ex. 2012, p. 96, ll. 1-13.
`Significantly, prior to being given the prior art references by Petitioners’
`
`counsel, Petitioners’ declarant had never seen the Bathiche or Shkolnikov
`
`references, had never heard of their names, and had never crossed paths with them
`
`at a show or a conference. Id. at 247:9-17. They are from non-analogous arts.
`
`Neither Petitioners’ declarant, nor anyone of ordinary skill in the art of
`
`control systems would turn to computer input devices to modify a reference about
`
`remotely controlled vehicles. Bathiche is not in the ‘748 Patent’s field of
`
`endeavor, nor reasonably pertinent to the particular problem with which the ‘748
`
`Patent is concerned. See Clay, 966 F.2d at 659.
`
`Similarly, Shkolnikov (Ex. 1010) is an active keyboard system for hand-held
`
`electronic devices. Id.at ¶ 20. Shkolnikov discloses entering alphanumeric text and
`
`data into the system using only one hand. Id. In no way is this technology
`
`analogous to the ‘748 Patent.
`
`Just as with Bathiche, Shkolnikov is not in the ‘748 Patent’s field of
`
`endeavor, nor reasonably pertinent to the particular problem with which the ‘748
`
` 
` 
`
`12 
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`

`

`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`Patent is concerned (i.e., easier control of remotely controlled “flying things”). See
`
`Clay, 966 F.2d at 659. Its use is wholly inappropriate. Ex. 2013 (Sturges Decl.), ¶¶
`
`32-33, 40.
`
`Accordingly, the rejection of all claims should be withdrawn.
`
`III. PETITIONERS’ DECLARANT’S TESTIMONY SHOULD BE GIVEN
`LITTLE OR NO WEIGHT
`
` 
`
`In his testimony, Petitioners’ declarant, Dr. D’Andrea, gave ample reasons
`
`why his opinion should be given little or no weight:
`
` This is his first invalidity opinion: “I’m a novice.” Ex. 2012, p. 7, ll. 8-15;
` His only interaction has been with Petitioners’ lawyers, not with any
`technical or business people at Petitioners, id., p. 13, l. 22 – p. 14, l. 11;
` He had been paid for 40 hours of work, id., p. 15, ll. 5-8, at 750 Swiss francs
`per hour (Ex. 1010, ¶5), for approximately $32,000 (prior to deposition);
` Petitioners’ lawyers provided him with the prior art he was to rely on, id., p.
`21, ll. 2-5, and also provided their view of the prior art: “Their opinions were
`made known to me so that I could have all the information available so the
`declaration could be created.” Id., p. 23, ll. 2-4;
` D’Andrea and Petitioners’ two lawyers “worked as a team, the three of
`[them], to prepare the declarations.” Id., p. 69, ll. 1-3; and
` D’Andrea refused to estimate how much (if any) of his declaration was his
`analysis and how much had been provided by Petitioners’ lawyers. Id., p. 23,
`l. 22 – p. 24, l. 7.
`Clearly Petitioners’ declarant, Dr. D’Andrea, does not understand what is
`
`required for a competent validity analysis and cannot be trusted to fairly apply his
`
`technical expertise to the claims at issue. Rather, by all appearances, Petitioners’
`13 
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`

`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`took advantage of his naiveté, paying him well over $30,000 to add his signature
`
`and imprimatur to counsel’s arguments (in the form of his declaration), using
`
`counsel’s chosen prior art, and their misinterpretation of that art (e.g., Spirov), in
`
`the hopes of making the arguments more credible to this Honorable Board.
`
`IV. PATENT OWNER PRESERVES ITS OBJECTIONS TO
`PETITIONERS’ UNSIGNED DECLARATION
`
` 
`
`Patent Owner has objected to, and at the proper time will move to exclude,
`
`the Declaration of Dr. D’Andrea, Ex. 1011.
`
`At his deposition, Dr. D’Andrea noted that the signature page filed with his
`
`declaration was for a different declaration, actually a duplicate of the signature
`
`page submitted in IPR 20014-00730 with Ex. 1010. Dr. D’Andrea testified that he
`
`had no recollection of signing his declaration (Ex. 2012, p. 71, ll. 15-17), admitted
`
`that he may have never signed the declaration (id., p. 73, ll. 9-10), and that he did
`
`not know where to find the original signature page (if it existed). Id., p. 80, ll. 9-12.
`
`Presently before this Honorable Board is a request by Petitioners to file a
`
`replacement declaration, nine months after the fact, and more than three months
`
`after this Honorable Board relied on the declaration in deciding to institute trial, to
`
`allegedly correct what they claim were “clerical errors.” The Board has ordered
`
`briefing on the issue, which is in process.
`
` 
` 
`
`14 
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`

`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`
`Nothing in this response, including any references or citations to
`
`Dr. D’Andrea’s unsigned declaration (Ex. 1011), should be taken as a waiver of
`
`Patent Owner’s objections, or acquiescence to Petitioners submitting and relying
`
`on an unsigned declaration.
`
`V. CONCLUSION
`
`Spirov does not disclose what Petitioners represented. Claim elements
`
`including, but not limited to, the configuration switch, are not disclosed, and any
`
`proffered reason to combine references has evaporated. Accordingly, Patent
`
`Owner respectfully requests that this Honorable Board withdraw its rejections and
`
`confirm the validity of all claims.
`
`
`
`While the Patent Owner believes that no fee is due, the Patent Owner
`
`authorizes the Board to charge any deficiencies in fees and credit any overpayment
`
`of fees to deposit account no. # 502395/2664.
`
`
`
`The Patent Owner consents to electronic service of process and receipt of
`
`any other correspondence when sent to all of these email addresses:
`
`gtabachnick@beckthomas.com;
`jdilmore@beckthomas.com; and
`docket@beckthomas.com.
`
`
` 
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`15 
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`

`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`
`
`Respectfully submitted,
`
`/s/ Gene A. Tabachnick
`
`Gene Tabachnick; Reg. No. 33,801
`James Dilmore; Reg. No. 51,618
`BECK & THOMAS, P.C.
`Pittsburgh, PA 15216-1808
`(412) 343-9700
`
`
`Date of Deposit: February 11, 2015
`
`
`
` 
`
`
`
` 
` 
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`16 
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`Patent Owner’s Response to the Petition for Inter Partes Review of U.S. Patent No. 8,106,748
`Case IPR2014-00732
` 
`VI. CERTIFICATE OF SERVICE
`
`
`
`Pursuant to 37 C.F.R. § 42.6, the undersigned certifies that on February 11,
`
`2015, a copy of the foregoing document was served by email upon the following:
`
`James E. Hopenfeld (hopenfeld@oshaliang.com)
`Tammy J. Terry (terry@oshaliang.com) 
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`and via FedEx:
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`James E. Hopenfeld
`Tammy J. Terry
`Osha Liang LLP
`909 Fannin Street, Suite 3500
`Houston, Texas 77010
`
`/Gene A. Tabachnick /
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`
`17 
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