IN THE 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
`U.S. Patent No. 8,106,748
`______________
`
`
`Before HOWARD B. BLANKENSHIP, MATTHEW R. CLEMENTS, and
`CHRISTOPHER M. KAISER, Administrative Patent Judges.
`
`
`
`PETITIONER’S REQUEST FOR REHEARING OF THE FINAL WRITTEN
`DECISION OF OCTOBER 20, 2015, PAPER 29
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Parrot S.A. and Parrot, Inc.
`
`Petitioners,
`
`v.
`
`Drone Technologies, Inc.
`
`Patent Owner
`
`_______________
`
`Case IPR2014-00732
`U.S. Patent No. 8,106,748
`______________
`
`
`Before HOWARD B. BLANKENSHIP, MATTHEW R. CLEMENTS, and
`CHRISTOPHER M. KAISER, Administrative Patent Judges.
`
`
`
`PETITIONER’S REQUEST FOR REHEARING OF THE FINAL WRITTEN
`DECISION OF OCTOBER 20, 2015, PAPER 29
`
`
`
`
`
`Case IPR2014-00732
`Petitioner’s Request for Rehearing
`
`Petitioner respectfully requests reconsideration of the Board’s Final Written
`
`Decision of October 20, 2015 (Paper 29) finding claims 1-12 of U.S. Patent No.
`
`8,106,748 (the ’748 Patent) not unpatentable.
`
`Pursuant to 37 C.F.R. § 42.71(d), Petitioner specifically identifies “all
`
`matters [Petitioner] believes the Board misapprehended or overlooked, and the
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`place where each matter was previously addressed in a motion, an opposition, or a
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`reply.” As discussed in more detail below, rehearing is warranted because the
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`Board overlooked record evidence showing that Shkolnikov (Ex. 1010) is
`
`analogous art and that all claims are obvious even if Shkolnikov is not considered
`
`analogous, and because the Board misapplied the burdens of production and proof.
`
`I.
`
`FACTUAL BACKGROUND
`
`A. The “Configuration Switch”
`
`The ’748 Patent purports to address problems associated with prior art
`
`manual (i.e., joystick based) remote control of devices such as model airplanes.
`
`Ex. 1001, 2:17-58. The purported solution is to deploy accelerometers in the
`
`remote controller and remote-controlled device to sense their movement. Ex.
`
`1001, 2:18-22. The system purports to “synchronize” the user’s movement of the
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`remote-controller with the movement of the remotely-controlled device. Ex. 1001,
`
`2:53-60; Ex. 1011 ¶¶ 49-50, 54.
`
`1
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`
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`Case IPR2014-00732
`Petitioner’s Request for Rehearing
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`Claim 1 originally was directed broadly to a system using accelerometers to
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`control devices remotely, but when the Examiner rejected that claim, the applicant
`
`amended it to include a dependent claim limitation requiring a “configuration
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`switch.” The “configuration switch” selects between three modes of operating the
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`remote controller: (1) manual control; (2) control using the accelerometer to sense
`
`motion only; or, (3) a combination of the two. Ex. 1001, 6:33-36; Fig. 5.
`
`B.
`
`The Prior Art
`
`Petitioner challenged claim 1 as obvious over Spirov in view of Bathiche
`
`and/or Shkolnikov. Spirov expressly discloses the same accelerometer-based
`
`system for remotely-controlling aircraft as does claim 1. See Paper 1, 19; Ex.
`
`1011, ¶¶ 66, 74. Because Spirov also teaches two modes of operation in the same
`
`remote-controller, which means there must be a switch to select the chosen mode,
`
`Spirov also necessarily discloses a “configuration switch.” Ex. 1011, ¶¶ 77-78.
`
`The only element Spirov does not expressly or inherently disclose is the third
`
`switch-selectable mode—the prior art “manual only” mode. Both Bathiche and
`
`Shkolnikov teach a manual only mode. Paper 1, 22; Ex. 1011, ¶¶ 69-70.
`
`Shkolnikov teaches an “active keyboard system” for hand-held devices such
`
`as a phone, PDA, or remote controller. Ex. 1010, ¶¶ [0086]-[0087], [0094]; Ex.
`
`1011, ¶ 70. As in Bathiche, Shkolnikov uses motion detectors such as
`
`accelerometers to detect the motion of the handheld device. Shkolnikov teaches
`
`2
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`Case IPR2014-00732
`Petitioner’s Request for Rehearing
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`three modes of operation: (1) manual input only; (2) sensed motion; and, (3) a
`
`combination of sensed and manual motion. Ex. 1010, ¶¶ [0024]-[0025]; Ex. 1011,
`
`¶ 70.
`
`Shkolnikov expressly teaches uses of motion-sensing and manual remote
`
`control beyond entry of alphanumeric text entry, such as for gaming. Figure 46
`
`shows a video game in which a gunsight can be controlled with a manually
`
`operated joystick together with motion by tilt (e.g., accelerometer). Ex. 1010, ¶
`
`[0136].
`
`C. The Board’s Decision
`
`The Board rejected Petitioner’s obviousness challenge to the ’748 Patent
`
`based on one—and only one—reason: that Shkolnikov is not “analogous art.”
`
`The Board further found that Shkolnikov is “critical to the asserted ground
`
`of unpatentability because that reference provides the teaching of three modes of
`
`operation including ‘the combination of the first acceleration sensing module and
`
`the manual input module.’” Paper 29, 13. The Board stated that it could “find no
`
`fault” with Patent Owner’s argument that Shkolnikov is non-analogous art, stating
`
`that it teaches an active keyboard system for handheld electronic or data entry
`
`devices. Id., 12. The Board “[found] little in Shkolnikov that would be reasonably
`
`pertinent to an artisan seeking to improve upon control of the motion of a remotely
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`controlled device.” Id., 13.
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`3
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`
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`Case IPR2014-00732
`Petitioner’s Request for Rehearing
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`In contrast, the Board found that Bathiche is analogous art. Paper 29, 8 n.2.
`
`II. ARGUMENT
`
`A.
`
`Shkolnikov Is Analogous Art
`
`A claim is unpatentable under 35 U.S.C. § 103(a) if the differences between
`
`the subject matter sought to be patented and the prior art are such that the subject
`
`matter as a whole would have been obvious at the time the invention was made to a
`
`person having ordinary skill in the art to which said subject matter pertains. KSR
`
`Int’l Co. v. Teleflex Inc., 550 U.S. 398, 406 (2007). A reference qualifies as prior
`
`art for an obviousness determination under § 103 only when it is analogous to the
`
`claimed invention. In re Klein, 647 F.3d 1343, 1348 (Fed. Cir. 2011).1
`
`A reference is considered analogous if: (1) it is from the same field of
`
`endeavor as the claimed subjected matter, regardless of the problem addressed; or
`
`(2) it “still is reasonably pertinent to the particular problem with which the inventor
`
`is involved,” even though the reference is not within the inventor’s field of
`
`
`
`1 Neither the Patent Act nor KSR recognizes a separate analogous-art inquiry.
`
`Field of endeavor and the pertinence of the prior art, like common sense, are at
`
`most considerations in the general obviousness inquiry. The vitality of a “non-
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`analogous art” subtest in view of KSR, however, is an issue for the Federal Circuit
`
`to consider in the first instance.
`
`4
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`Case IPR2014-00732
`Petitioner’s Request for Rehearing
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`endeavor. Scientific Plastic Prods., Inc. v. Biotage AB, 766 F.3d 1355, 1359 (Fed.
`
`Cir. 2014). The Federal Circuit has explained:
`
`A reference is reasonably pertinent if, even though it may be in a
`
`different field from that of the inventor’s endeavor, it…logically
`
`would have commended itself to an inventor’s attention in considering
`
`his problem. Thus, the purposes of both the invention and the prior
`
`art are important…If a reference disclosure has the same purpose as
`
`the claimed invention, the reference relates to the same problem, and
`
`that fact supports use of that reference in an obviousness rejection…If
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`it is directed to a different purpose, the inventor would accordingly
`
`have had less motivation or occasion to consider it.
`
`In re Clay, 966 F.2d 656, 659 (Fed. Cir. 1992).
`
`The Board’s final decision found Petitioner had not set forth evidence that
`
`Shkolnikov is analogous art. That finding is incorrect. It overlooks Prof.
`
`D’Andrea’s Declaration and Federal Circuit precedent, as well as the ’748 Patent’s
`
`prosecution history.
`
`First, Shkolnikov is in the same field as the ’748 Patent: remote controls.
`
`Paper 1, 22, 24. As Figure 46 demonstrates, Shkolnikov teaches a system that may
`
`be configured in a “remote control” that can be used, for example, to move a cursor
`
`on a screen or play a video game. Ex. 1010, ¶¶ [0094], [0136]. For purposes of
`
`the analogous-art inquiry, it makes no difference whether that handheld remote
`
`moves a cursor or object on screen or in real space.
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`5
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`Case IPR2014-00732
`Petitioner’s Request for Rehearing
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`Second, Shkolnikov is “reasonably pertinent” to the problem the inventor
`
`was addressing. As Prof. D’Andrea explained, the relevant art is that of “control
`
`systems.” Ex. 1011, ¶¶ 20-21. Patent Owner did not dispute that in its Patent
`
`Owner Response (“POR”), and with good reason: remote controllers capable of
`
`directing an object, such as a cursor or gunsight, in virtual space also are useful in
`
`controlling objects in physical space. See Innovention Toys, LLC v. MGA Ent., 637
`
`F.3d 1314, 1321-22 (Fed. Cir. 2011) (court erred as a matter of law in finding
`
`“electronic, laser-based strategy game” non-analogous to “physical laser-based
`
`strategy game” even “if not in the same field of endeavor”).
`
`Prof. D’Andrea explained that a person of ordinary skill in the art logically
`
`would look to remote controller art directed to configuration switches:
`
`Remote controllers and their remotely controlled devices often operate
`
`in multiple modes of operation. To choose among multiple modes of
`
`operation for a single device, a switch must be deployed. Such
`
`switches have long been deployed in the art. See, e.g., U.S. Patent
`
`No. 7,145,551 (“Bathiche”…) (video game controller including
`
`configuration or mode switch to switch between sensed orientation
`
`based control and joystick control) and U.S. Patent Publication No.
`
`2004/0263479 (“Shkolnikov”…) (device, including remote control
`
`device, configured to use sensed movement of the remote control,
`
`manual control, or both).
`
`Ex. 1011, ¶ 48.
`
`6
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`Case IPR2014-00732
`Petitioner’s Request for Rehearing
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`Prof. D’Andrea also explained why a person of ordinary skill in the art
`
`would have been motivated to incorporate prior-art configuration switches,
`
`including manual-only modes, along with sensed-control modes. Additional
`
`operating modes would have been a “routine design choice” (Ex. 1011, ¶ 79), and
`
`incorporating configuration switches would have been easy to accomplish (Id., ¶
`
`80). Such combinations of different remote-control modes using configuration
`
`switches are commonly deployed and expressly suggested in the prior art. Id., ¶¶
`
`81-82.
`
`Prof. D’Andrea’s testimony showing that Bathiche and Shkolnikov would
`
`have logically commended themselves to the person of ordinary skill was not
`
`rebutted either by Patent Owner or Prof. Sturges. Patent Owner’s Response made
`
`three arguments on analogous art. First, Patent Owner argued that neither Bathiche
`
`nor Shkolnikov addressed the problem of remotely controlled vehicles. Paper 15,
`
`11-13. But the Board concluded that the patent is not limited to the remote control
`
`of vehicles. Paper 29, 10. Besides, Patent Owner nowhere explains why
`
`controlling a cursor or a gun in virtual reality is not pertinent to controlling an
`
`object in true reality. Second, Patent Owner argued that Prof. D’Andrea had never
`
`heard of these references. Paper 15, 12. The Board properly rejected that
`
`argument too. Paper 29, 11. Finally, Patent Owner argued that Shkolnikov also
`
`discloses entering alphanumeric text and data using one hand. Paper 15, 12. That
`
`7
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`Case IPR2014-00732
`Petitioner’s Request for Rehearing
`
`fact has nothing to do with the presence of a “configuration switch”; nor does it
`
`otherwise rebut Petitioner’s prima facie showing of Shkolnikov’s pertinence.
`
`Patent Owner’s reliance on three paragraphs in Prof. Sturges’ declaration
`
`fails for the same reasons. In paragraphs 32 and 33, Prof. Sturges states that
`
`although Shkolnikov teaches an “alphanumeric” text-entry remote controller, it
`
`does not teach its use with “model vehicles” and that he would not have used such
`
`a remote controller in his own research with model vehicles. Ex. 2013, ¶¶ 32, 33.
`
`But the ’748 Patent is not limited to “model vehicles,” and whether Prof. Sturges
`
`would have used such a remote controller in his own research is irrelevant.
`
`Besides, these paragraphs do not address whether Shkolnikov would have been
`
`“reasonably pertinent” with respect to a configuration switch to select between
`
`modes. At most, they address the “field of endeavor” prong of the analogous-art
`
`test. And paragraph 40 says nothing about Shkolnikov at all; it addresses only
`
`Spirov which is undisputedly analogous art. Id., ¶ 40.
`
`In paragraph 42—not cited in the POR—Prof. Sturges does state that a
`
`person of ordinary skill in the art would not have used Shkolnikov to modify
`
`Spirov, as Shkolnikov is directed to entry of alphanumeric text. Ex. 2013, ¶ 42.
`
`But that does not address pertinence.
`
`Shkolnikov is not, moreover, limited to alphanumeric text entry. Shkolnikov
`
`expressly discloses use of manual and sensed-motion remote-control applications
`
`8
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`Case IPR2014-00732
`Petitioner’s Request for Rehearing
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`to manipulate objects for purposes of gaming—including Fig. 46. See, e.g., Ex.
`
`1010, ¶¶ [0024]-[0025], [0136]-[0137]. It also lists other sensed-motion remote
`
`controls as related art. Id., ¶¶ [0013], [0017]. Patent Owner ignores these express
`
`disclosures, which the Board overlooked as well. See Belden Inc. v. Berk-Tek
`
`LLC, No. 2014-1575, 1576, 2015 U.S. App. LEXIS 19307, *22-23 (Fed. Cir. Nov.
`
`5, 2015) (reversing PTAB non-obviousness finding because reference must be
`
`considered for everything it teaches and not just the invention it claims). And
`
`Shkolnikov is particularly analogous given Patent Owner’s position in litigation:
`
`Patent Owner has claimed that Petitioner induces infringement of all claims of the
`
`’748 Patent when iPhones and the like are used as remote controllers. See Paper
`
`7, 3-4 and n.1 (referring to Complaint). That Shkolnikov discloses text entry thus
`
`makes it more on point rather than less.
`
`The Board also disregarded Patent Owner’s concession (Paper 26, 59-60),
`
`and the Board’s own finding (Paper 29, 8 and n.2), that Bathiche is “analogous
`
`art.” If Bathiche is analogous art, then Shkolnikov must be too. Both Bathiche
`
`and Shkolnikov logically would have commended themselves to the inventor’s
`
`attention for the same reasons. Like Shkolnikov, Bathiche is directed to a remote
`
`controller, but does not expressly mention use of such a controller to direct
`
`vehicles. Like Bathiche, Shkolnikov expressly states that its system can be used
`
`for gaming applications. Compare Shkolnikov, Ex. 1010, ¶¶ [0136]-[0137], with
`
`9
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`Case IPR2014-00732
`Petitioner’s Request for Rehearing
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`Bathiche, Ex. 1009, 4:60-5:13. And, like the ’748 Patent, Shkolnikov asserts that
`
`its system improves ease of use. Compare Ex. 1001, 1:46-58; 2:53-60 with Ex.
`
`1010, ¶¶ [0137]-[0139].
`
`The effort to exclude Shkolnikov because it does not “control [] the motion
`
`of a remotely controlled device” (Paper 29, 13) also is inconsistent with ’748
`
`Patent’s prosecution history. In rejecting the original claim 1, the Examiner
`
`combined a prior art reference for a remotely controlled airplane (Barr) with prior
`
`art reference (Ikeda) directed to a remote controller for a game including a sensor
`
`to detect the remote controller’s motion. Like Shkolnikov, Ikeda does not
`
`expressly teach using the remote controller to control a vehicle. If Ikeda is proper
`
`“analogous art,” so is Shkolnikov. During prosecution the applicant never denied
`
`that Ikeda is analogous art.
`
`The Board’s finding that Shkolnikov is non-analogous art cannot be squared
`
`with recent Federal Circuit precedent, which routinely finds far more distant art
`
`analogous. See, e.g., Scientific Plastic, 766 F.3d at 1358 (caps used to seal
`
`“beverage containers” analogous art for detachable cartridge with tube and cap for
`
`use in field of liquid chromatography systems); In re Ontjes, 587 F. App’x 641,
`
`643-45 (Fed. Cir. 2014) (beer koozie analogous art for propane tank); In re Icon
`
`Health & Fitness, Inc., 496 F.3d 1374, 1379-80 (Fed Cir. 2007) (folding bed
`
`analogous art for folding treadmill); In re Bigio, 381 F.3d 1320, 1325-26 (Fed. Cir.
`
`10
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`
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`Case IPR2014-00732
`Petitioner’s Request for Rehearing
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`2004) (toothbrush analogous art for hairbrush). The remote control of Shkolnikov,
`
`and in particular its use in gaming systems, bears a closer connection to the field of
`
`the claimed invention than the “beverage cap” bore to the liquid chromatography
`
`field in Scientific Plastic (or a beer koozie bears to propane tanks, or folding beds
`
`bear to treadmills). All of the prior art here indisputably lies within the broader
`
`field of “control systems.” In Scientific Plastic, moreover, the diverse references
`
`were combined to meet a key limitation in the claims (one required for the claimed
`
`invention to function). Here, the prior art references address a pedestrian
`
`“configuration switch” with no meaningful role in solving the problem the ’748
`
`Patent purportedly addresses.
`
`B.
`
`The Board Improperly Allocated Burdens
`
`In finding that Shkolnikov is non-analogous art, the Board stated: “When
`
`the analogous-art issue was raised by Patent Owner in its POR, it was incumbent
`
`upon Petitioner to demonstrate that Shkolnikov is analogous art.” Paper 29, 11.
`
`The Board also stated that “Petitioner’s only reply” on “why Shkolnikov is non-
`
`analogous art, other than the unfounded reliance on the Decision on Institution, is
`
`the observation that the fact D’Andrea had not heard of Bathiche or Shkolnikov
`
`prior to this case is irrelevant to the analogous art inquiry.” Id. The Board then
`
`concluded that it could find “no fault” with the Patent Owner’s position that
`
`Shkolnikov is non-analogous. Id., 12.
`
`11
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`
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`Case IPR2014-00732
`Petitioner’s Request for Rehearing
`
`In doing so, the Board incorrectly allocated the burden of production,
`
`effectively requiring Petitioner to meet its burden twice: once in its petition
`
`requesting IPR, and a second time on reply after the Patent Owner has filed its
`
`response. The law requires Petitioner to meet its burden of production only once.
`
`Once Petitioner had made a prima facie showing that the art was analogous—and
`
`there can be no reasonable dispute that Petitioner had made such a showing—it
`
`was Patent Owner’s burden to rebut the prima facie case with evidence of its own.
`
`In re Applied Materials, Inc., 692 F.3d 1289, 1295-97 (Fed. Cir. 2012). The POR
`
`did not wipe the slate clean and require Petitioner to re-submit its evidence
`
`showing that Shkolnikov is analogous art. The issue before the Board thus was not
`
`whether the Board could “find fault” in Patent Owner’s argument about
`
`Shkolnikov. The Board should have considered whether—now that the issue was
`
`joined—Shkolnikov is analogous or not.
`
`As explained above, Petitioner made a prima facie case that Shkolnikov was
`
`analogous art. The important testimony of Prof. D’Andrea on that issue was left
`
`unrebutted by Patent Owner in its Response. Patent Owner failed even to
`
`challenge Prof. D’Andrea’s testimony in his deposition, and again with its Patent
`
`Owner Response. What Patent Owner did submit in its response—beyond
`
`conclusory argument—was not legally pertinent to the “analogous art” inquiry.
`
`12
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`
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`Case IPR2014-00732
`Petitioner’s Request for Rehearing
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`See Paper 15, 13-15. Accordingly, the Board had no valid reason for finding
`
`Shkolnikov non-analogous.
`
`C. The Board Did Not Consider Alternative Grounds and Evidence
`Demonstrating Obviousness
`
`The Board’s decision states that “Shkolnikov is critical to the asserted
`
`ground of unpatentability because that reference provides the teaching of three
`
`modes of operation, including ‘the combination of the first acceleration sensing
`
`module and the manual input module,’ as recited in illustrative claim 1.” Paper 29,
`
`13. The Board’s statement incorrectly assumes that Petitioner’s demonstration of
`
`obviousness of claim 1 is dependent on Shkolnikov, and overlooks independent
`
`grounds set forth by Petitioner.
`
`The Petition, supported by Prof. D’Andrea, provided two demonstrations of
`
`obviousness of claim 1 independent of Shkolnikov. First, Prof. D’Andrea
`
`demonstrated that Spirov inherently discloses a two-mode configuration switch,
`
`including an “accelerometer only” mode and an “accelerometer plus manual”
`
`mode. Ex. 1011, ¶ 78. The only mode expressly missing from Spirov is a “manual
`
`only” mode. Prof. D’Andrea then explained that it would be obvious to add the
`
`extra mode based on the knowledge of a person of ordinary skill in the art, as
`
`adding an additional manual-operation mode would have been a “routine design
`
`choice.” Ex. 1011, ¶ 79. In addition, Bathiche, which is concededly analogous art,
`
`13
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`Case IPR2014-00732
`Petitioner’s Request for Rehearing
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`teaches the “manual only” mode; Bathiche indisputably discloses a “manual only”
`
`mode of operation and a configuration switch. Ex. 1011, ¶ 69. The combination of
`
`Bathiche and Spirov alone thus teaches every element of claim 1. See Paper 18, 2.
`
`Patent Owner did not dispute that the addition of a third mode of operation
`
`or a switch to allow for three-mode operation would have been a routine design
`
`choice. Patent Owner urged that Spirov teaches only one mode of operation and
`
`thus does not inherently disclose a “configuration switch.” Paper 15, 4-10. As
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`demonstrated in Petitioner’s Reply (Paper 18, 5-6) and confirmed at oral argument
`
`(Paper 26, 74), this argument is plainly incorrect: A switch must exist to allow the
`
`use of both modes of operation taught in Spirov. Patent Owner thus has not
`
`rebutted the showing of obviousness wholly apart from Shkolnikov.
`
`Petitioner and Prof. D’Andrea independently showed that “[c]ombinations
`
`including Bathiche and Spirov yield the remote control system of claim 1 even if
`
`Spirov were to be interpreted as not inherently disclosing the configuration
`
`switch.” Ex. 1011, ¶ 79; see also ¶¶ 80-82. Neither Patent Owner nor Prof.
`
`Sturges addressed or rebutted these arguments, basing their argument entirely on
`
`the assumption that Shkolnikov must be combined with Spirov to yield the claimed
`
`invention. See Paper 15, 4-13. The Board’s decision also does not address these
`
`unrebutted arguments.
`
`14
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`Case IPR2014-00732
`Petitioner’s Request for Rehearing
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`III. CONCLUSION
`
`For the above reasons, Parrot requests rehearing of the Board’s Final
`
`Written Decision (Paper 29) and requests the Board find all claims of the ’748
`
`Patent unpatentable.
`
`Dated: November 19, 2015
`
`Respectfully submitted,
`
`/James E. Hopenfeld/
`James E. Hopenfeld (Reg No. 47,661)
`Hopenfeld@oshaliang.com
`Tammy J. Terry (Reg No. 69,167)
`Terry@oshaliang.com
`OSHA LIANG LLP
`909 Fannin Street, Suite 3500
`Houston, Texas 77010
`Tel: 713-228-8600/Fax: 713-228-8778
`Counsel for Petitioner
`
`
`
`
`
`15
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`
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`Case IPR2014-00732
`Petitioner’s Request for Rehearing
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies service pursuant to 37 C.F.R. § 42.6(e) on the
`
`Patent Owner by email and U.S. Mail a copy of the Petitioner’s Request for
`
`Rehearing of Final Written Decision as follows:
`
`Gene Tabachnick
`James Dilmore
`gtabachnick@beckthomas.com
`jdilmore@beckthomas.com
`docket@beckthomas.com
`BECK & THOMAS, P.C.
`1575 McFarland Road, Suite 100
`Pittsburgh, PA 15216-1808
`
`Respectfully submitted,
`
`Dated: November 19, 2015
`
`/James E. Hopenfeld/
`James E. Hopenfeld (Reg No. 47,661)
`Hopenfeld@oshaliang.com
`Tammy J. Terry (Reg No. 69,167)
`Terry@oshaliang.com
`OSHA LIANG LLP
`909 Fannin Street, Suite 3500
`Houston, Texas 77010
`Tel: 713-228-8600/Fax: 713-228-8778
`Counsel for Petitioner
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