UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
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`INTELLECTUAL INTEGRITY, LLC,
`Petitioner
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`v.
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`APPLE INC.,
`Patent Owner
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`Patent No. 7,864,163
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`____________
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`Inter Partes Review No. IPR2016-00500
`____________________________________________________________
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`PATENT OWNER’S PRELIMINARY RESPONSE
`PURSUANT TO 37 C.F.R. § 42.107
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`sf-3645696
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`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
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`INTELLECTUAL INTEGRITY, LLC,
`Petitioner
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`v.
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`APPLE INC.,
`Patent Owner
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`
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`Patent No. 7,864,163
`
`____________
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`Inter Partes Review No. IPR2016-00500
`____________________________________________________________
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`PATENT OWNER’S PRELIMINARY RESPONSE
`PURSUANT TO 37 C.F.R. § 42.107
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`TABLE OF CONTENTS
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`Page
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`I.
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`INTRODUCTION .......................................................................................... 1
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`II.
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`FACTUAL BACKGROUND......................................................................... 2
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`A.
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`B.
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`C.
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`The ’163 Patent .................................................................................... 2
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`The “Translation” Limitations of Claims 2, 50, and 52 ....................... 3
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`Allowance of the Claims in Light of the “Translation”
`Limitations ............................................................................................ 6
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`D. Harada’s Separate Screens and Lack of Translation .......................... 10
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`III. ARGUMENT ................................................................................................ 13
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`A.
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`Intellectual Integrity Fails to Show that Harada Satisfies the
`“Translating” Limitations ................................................................... 14
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`B.
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`Harada Does Not Satisfy the “Translating” Limitations .................... 16
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`1.
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`2.
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`3.
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`Harada Does Not Disclose “Translating the Structured
`Electronic Document” in Response to a First Gesture ............ 16
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`Harada Does Not Disclose “Translating The Structured
`Electronic Document” in Response to a Second Gesture ........ 18
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`Harada’s Disclosures Are No Different than the “Closest
`Available Prior Art References” During Prosecution .............. 19
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`IV. CONCLUSION ............................................................................................. 22
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`TABLE OF AUTHORITIES
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`Page
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`CASES
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`Eli Lilly & Co. v. Zenith Goldline Pharms., Inc.,
`471 F.3d 1369 (Fed. Cir. 2006) ............................................................................ 1
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`Whitserve, LLC v. Computer Packages, Inc.,
`694 F.3d 10 (Fed. Cir. 2012) ................................................................................ 1
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`STATUTES
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`35 U.S.C. § 314(a) ................................................................................................... 13
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`REGULATIONS
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`37 C.F.R. § 42.104(b)(3) .................................................................................... 13, 14
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`37 C.F.R. § 42.104(b)(4) .............................................................................. 13, 15, 16
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`37 C.F.R. § 42.108 ................................................................................................... 13
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`EXHIBIT LIST
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`Title
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`U.S. Patent Appl. No. 11/850,013, filed on Sept. 4, 2007
`(Original Claims)
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`Non-Final Rejection, dated June 11, 2010
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`Exhibit
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`No.
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`2001
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`2002
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`Response to Office Action and Interview Summary, dated Sept. 13, 2010
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`2003
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`Notice of Allowability, dated Oct. 20, 2010
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`U.S. Patent Application No. 2004/0103371 to Chen et al.
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`U.S. Patent Application No. 2007/0250768 to Funakami et al.
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`2004
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`2005
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`2006
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`I.
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`INTRODUCTION
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`Docket No. 106840000554
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`To anticipate a claim, a prior art reference must disclose each and every
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`claim limitation expressly or inherently.1
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`In its petition for inter partes review, Intellectual Property fails to
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`demonstrate that the Harada reference2 satisfies the “translation” limitations of all
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`challenged claims of the ’163 patent.3 Intellectual Integrity focuses only on the
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`“enlargement” and “substantially centered” limitations of claims 2, 50, and 52,
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`ignoring their “translation” limitations entirely.
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`1 See, e.g., Whitserve, LLC v. Computer Packages, Inc., 694 F.3d 10, 21 (Fed. Cir.
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`2012) (“[A] claim is anticipated if each and every limitation is found either
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`expressly or inherently in a single prior art reference.”) (internal quotation marks
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`omitted); Eli Lilly & Co. v. Zenith Goldline Pharms., Inc., 471 F.3d 1369, 1375-76
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`(Fed. Cir. 2006) (to anticipate, a “prior art reference must disclose each and every
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`feature of the claimed invention, either explicitly or inherently”).
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`2 S. Harada et al., “Lost in Memories: Interacting with Photo Collections on
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`PDAs,” Proceedings of the Fourth ACM/IEEE-CS Joint Conference on Digital
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`Libraries (2004) (Ex. 1008).
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`3 U.S. Patent No. 7,864,163 (filed Jan. 4, 2011) (Ex. 1001).
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`Because the petition is deficient on its face—and Harada, the sole reference
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`offered for anticipation, does not disclose “translation” in any event—the Board
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`should deny Intellectual Property’s petition and decline to institute a trial.
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`II.
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`FACTUAL BACKGROUND
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`A. The ’163 Patent
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`The ’163 patent relates to a novel way for users to interact with a structured
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`electronic document (e.g., the New York Times webpage) having a plurality of
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`content boxes on a touch-screen display.4 An exemplary structured electronic
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`document is depicted in Figures 5A and 5C below.
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`4 See ’163 Patent col. 2:28-3:43 (Ex. 1001).
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`Using gestures, a user can interact with the document. For example, a user
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`can use a double-tap gesture to zoom in on a specific content box (e.g., the content
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`in Block 5 of Figure 5A, above).5 The result is that the box is enlarged and
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`substantially centered on the touch screen display (as in Figure 5C, above).6
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`The user then can use an additional gesture (e.g., another double-tap) on
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`another content box (e.g., an adjacent article in Block 4) in the same structured
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`electronic document to center that box on the screen.7
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`B.
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`The “Translation” Limitations of Claims 2, 50, and 52
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`The specification explains that, when enlarging and re-centering a content
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`box from the structured electronic document, the box also may be “translated.”
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`This translation may be accomplished via “movement of the structured electronic
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`document on the touch screen display.”8 The specification further describes
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`5 See id. at col. 19:6-37.
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`6 See id. at col. 19:30-31.
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`7 See id. at col. 20:38-51.
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`8 Id. at col. 20:56-59 (“In some embodiments, the translating comprises vertical,
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`horizontal, or diagonal movement of the structured electronic document on the
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`touch screen display (6048).”) (emphasis added).
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`embodiments in which “enlarging and substantially centering comprises
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`simultaneously zooming and translating [a] box on the touch screen display
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`(6022).” 9
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`All three challenged claims (i.e., 2, 50, and 52) require this “translation,”
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`which is in addition to the document’s enlargement and centering. For example,
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`claim 50 recites:
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`instructions for detecting a first gesture at a location on the
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`displayed portion of the structured electronic document;
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`instructions for determining a first box in the plurality of boxes
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`at the location of the first gesture;
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`instructions for enlarging and translating the structured
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`electronic document so that the first box is substantially
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`centered on the touch screen display;
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`instruction for, while the first box is enlarged, detecting a
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`second gesture on a second box other than the first box; and
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`instructions for, in response to detecting the second gesture,
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`translating the structured electronic document so that the
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`9 Id. at col. 19:32-34 (emphasis added).
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`second box is substantially centered on the touch screen
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`display.10
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`Critically, in all three challenged claims, the “structured electronic
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`document” that is translated must be the same structured electronic document on
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`which the first gesture was detected.11
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`10 See, e.g., id. claim 50 (emphasis added); accord claims 2 and 52. In its petition,
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`Intellectual Integrity improperly quotes and relies upon the uncorrected version of
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`the ’163 patent claims. (See Petition for Inter Partes Review of U.S. Patent No.
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`7,864,163 (“Pet.”) at 17 (“a second gesture is detected . . . the structured electronic
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`document is translated”).) In its preliminary response, Apple refers to the claims
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`as corrected via the March 15, 2011 Certificate of Correction (attached as the last
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`two pages of Exhibit 1001).
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`11 See, e.g., id. claim 50 (reciting instructions for “detecting a first gesture at a
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`location on the displayed portion of the structured electronic document,” and
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`subsequently reciting instructions for “enlarging and translating the structured
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`electronic document so that the first box is substantially centered on the touch
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`screen display” and for, “in response to detecting the second gesture, translating
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`C. Allowance of the Claims in Light of the “Translation” Limitations
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`The “translation” limitations did not appear in the challenged claims as
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`originally filed.12 Instead, the original corresponding claims required only
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`“enlarging and substantially centering the first box on the touch screen display.” 13
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`In the first Office Action, the Examiner rejected the corresponding claims as
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`obvious in light of WO 02/093542 to Gillespie et al. (“Gillespie”) and WO
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`2005/106684 to Funakami et al. (“Funakami”).14 The Examiner contended that
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`Funakami, but not Gillespie, disclosed “enlarging and substantially centering the
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`the structured electronic document so that the second box is substantially centered
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`on the touch screen display”) (emphasis added); accord claims 2 and 52.
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`12 See U.S. Patent Appl. No. 11/850,013, Original Claims (filed Sept. 4, 2007) (Ex.
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`2001).
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`13 See id. at 39, 44-46 (application claims 2, 51, and 53, corresponding to issued
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`claims 2, 50, and 52).
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`14 See Non-Final Rejection, dated June 11, 2010 at 7 (Ex. 2002). Although the
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`Examiner cited WO 2005/106684, he relied upon the translated version of the
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`application, U.S. Patent Application No. 2007/0250768 (filed Oct. 25, 2007) (Ex.
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`2006), for convenience. In this preliminary response, Apple does as well.
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`first box on the display.” In particular, the Examiner relied on Figure 12 of
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`Funakami (below) as “show[ing] that the box for image A1 is enlarged and
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`‘substantially’ centered” on a terminal device such as a cellular phone or PDA:15
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`During a subsequent interview, the Examiner agreed that Funakami did not
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`disclose “enlarging and translating the structured electronic document so that the
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`first box is substantially centered on the touch screen display.” 16 The applicants
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`therefore amended the claims accordingly,17 and the Examiner allowed the claims
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`as amended.
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`In doing so, the Examiner proposed a further amendment to add the final
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`15 Non-Final Rejection at 11 (Ex. 2002); Funakami at fig. 12, ¶ [0143] (Ex. 2006).
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`16 Response to Office Action and Interview Summary, dated Sept. 13, 2010 at 12
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`(Ex. 2003).
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`17 See id. at 2, 8, 9.
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`two clauses of the challenged claims, i.e.:
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`(i) “while the first box is enlarged, detecting a second gesture
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`on a second box other than the first box”; and
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`(ii) “in response to detecting the second gesture, translating the
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`structured electronic document so that the second box is
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`substantially centered on the touch screen display.” 18
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`The Examiner underscored that he was allowing the claims, at least in part,
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`based on their “translation” limitations. He explained:
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`The primary reason for [for allowing issued claims 2, 50, and
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`52] is [that their] inclusion of . . . similar limitations stating ‘. . .
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`enlarging and translating the structured electronic document so
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`that the first box is substantially centered on the touch screen
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`display . . . [and] while the first box is enlarged, detecting a
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`second gesture on a second box other than the first box; and in
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`response to detecting the second gesture, translating the
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`structured electronic document so that the second box is
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`substantially centered on the touch screen display[,]’ in
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`combination with the other recited features of the claims, . . .
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`18 Notice of Allowability, dated Oct. 20, 2010 at 2-3, 7-9 (Ex. 2004).
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`are not found singularly or in combination with the prior
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`art.19
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`The Examiner further emphasized that the “closest available prior art
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`references”—“particularly” U.S. Patent Application No. 2004/0103371 to Chen et
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`al. (“Chen”), and also including Funakami—disclosed only “displaying the content
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`of one of [a plurality of] boxes enlarged and centered on [a] display in response
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`[to] a selection.” 20 But “none of the prior art [taught], while the first box is
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`enlarged, translating the webpage/structure[d] document such that the second box
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`is substantially centered.”21
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`Chen, for example, describes partitioning a large webpage into smaller “sub-
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`pages” to help the user view content on devices with small screens.22 Specifically,
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`the user may be presented with multiple thumbnail images representing sub-pages
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`that the user might wish to view. The user then can “click on one of the sub-page
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`19 Id. at 13-14 (emphasis added).
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`20 Id. at 14.
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`21 Id. (emphasis added).
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`22 Chen at Abstract (Ex. 2005); see also Fig. 9, ¶ [0115].
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`icons to browse an enlarged image of the corresponding sub-page.”23
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`D. Harada’s Separate Screens and Lack of Translation
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`Harada discloses a “baseline manual browser” for interacting with a photo
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`collection and viewing images. The browser involves three screens—an “opening-
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`game screen,” a “middle-game screen,” and an “end-game” screen:24
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`The “opening-game screen” depicts subfolder “button controls” and photos
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`within a given folder.25 Each subfolder button control depicts three sample photos
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`23 Id. at ¶ [0115].
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`24 Harada at 327 (Ex. 1008).
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`25 Id.
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`that are within the subfolder.26 Each subfolder button control also identifies the
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`subfolder’s name, any further subfolders, and the total number of photos within
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`that subfolder.27 Tapping on a subfolder button control “will drill down into it.”28
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`The opening-game screen also displays “a grid of thumbnails of all photos within
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`the current folder” below the subfolder button controls.29
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`The “middle-game opening screen” is “just a special case of the opening
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`game, where there are no more subfolders in the current folder.” 30 For this reason,
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`in Figure 2, “only [a] grid of [photo] thumbnails is shown.”31
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`The final screen, the “end-game” or “preview” screen, appears when the
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`user “tap[s] on one of the photos” in a grid, whether the opening-game screen or
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`the middle-game screen.32 “[T]he selected photo [from the grid in the prior screen]
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`is enlarged” in the end-game screen, and “[f]our other photos appear in a row at the
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`26 See id.
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`27 See id.
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`28 Id.
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`29 Id.
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`30 Id.
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`31 Id.
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`32 Id.
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`top.”33 “These are the next and previous two photos,” which are “included for
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`context and quicker navigation.”34 “Tapping any of the four [photos] replaces the
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`enlarged photo with an enlargement of the tapped photo.”35
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`Three things are apparent upon review of Harada. First, the end-game
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`screen is not an enlargement or translation of the opening-game screen or the
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`middle-game screen. Instead, the user is “take[n]” to the end-game screen by
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`“tapping on one of the photos in the grid” of the prior opening or middle-game
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`screen. Second, a different end-game screen is presented to the user each time he
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`or she taps on one of the four photos above the currently enlarged photo. When a
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`user taps one of those photos, “[t]he context changes accordingly,”36 with new
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`“next” and “previous” photo thumbnails appearing above the new enlarged image.
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`Third, the enlarged photo depicted in the end-game screen is not translated from
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`one of the four photos on a previous end-game screen. Instead, the enlarged photo
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`33 Id.
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`34 Id.
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`35 Id.
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`36 Id.
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`simply “replaces” the prior enlarged photo.37
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`III. ARGUMENT
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`Docket No. 106840000554
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`Under 37 C.F.R. § 42.104(b)(3), a petition for inter partes review “must
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`identify . . . how the challenged claim is to be construed.” Under 37 C.F.R. §
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`42.104(b)(4), the petition also “must specify where each element of the claim is
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`found in the prior art patents or printed publications relied upon.” Finally, under
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`37 C.F.R. § 42.108, the petition must “demonstrate that there is a reasonable
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`likelihood that at least one of the claims challenged in the petition is
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`unpatentable.”38
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`Intellectual Integrity’s petition fails all three of these requirements.
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`Intellectual Integrity does not offer a construction of the “translation” limitations.
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`Nor does it explain how the lone identified reference, Harada, discloses the
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`“translation” limitations. Accordingly, Intellectual Integrity has failed to carry its
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`burden of showing that the three challenged claims are unpatentable.
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`A cursory review of the Harada reference confirms that it does not anticipate
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`the challenged claims. Harada describes neither (i) “translating” content nor (ii)
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`37 Id.
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`38 Accord 35 U.S.C. § 314(a).
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`translations involving the same “structured electronic document.” For at least
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`these reasons,39 the Board should deny the petition.
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`A.
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`Intellectual Integrity Fails to Show that Harada Satisfies the
`“Translating” Limitations
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`All three challenged claims require “translating the structured electronic
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`document” in response to a gesture so that a selected content box is substantially
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`centered on the touch screen display. But Intellectual Integrity offers no evidence
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`or argument as to how Harada allegedly satisfies these “translation” limitations.
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`First, in contrast to its proposed constructions of “box[es] of content,”
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`“structured electronic document,” and “gesture,”40 Intellectual Integrity does not
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`offer a construction of the “translating” requirement at all under 37 C.F.R. §
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`42.104(b)(3).
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`Second, the sum total of Intellectual Integrity’s explanation for how the
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`39 In light of the many deficiencies in Intellectual Integrity’s petition, Apple has
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`focused on the most glaring of these issues in this preliminary response. Apple
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`does not concede, however, that any of Intellectual Integrity’s positions have merit.
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`Should the Board institute a trial, Apple reserves the right to raise additional
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`arguments, including claim construction positions.
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`40 Pet. at 7-10.
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`Harada reference allegedly discloses “enlarging and translating the structured
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`electronic document so that the first box is substantially centered on the touch
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`screen display” is the following:
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`Harada discloses that the photo from the grid [in the end-game
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`screen] that was tapped is enlarged and centered upon the
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`display screen.41
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`This merely establishes that something is enlarged and centered on the
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`display screen, but does not establish that Harada discloses translating. Nor does
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`it establish that what allegedly is being enlarged and translated is the same
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`structured electronic document containing the box on which the first gesture was
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`performed.42 Intellectual Integrity thus has not satisfied 37 C.F.R. § 42.104(b)(4).
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`Third, the sum total of Intellectual Integrity’s explanation for how the
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`Harada reference allegedly discloses “in response to detecting the second gesture,
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`translating the structured electronic document so that the second box is
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`substantially centered on the display” is the following:
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`As noted above, Harada discloses that ‘other photos appear in a
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`row at the top . . . [t]apping any of the four replaces the
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`41 Id. at 16 (emphasis added).
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`42 Compare with, e.g., ’163 Patent at figs. 5A, 5C (Ex. 1001).
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`enlarged photo with an enlargement of the tapped photo. The
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`context changes accordingly.’43
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`This simply states that an enlarged photo is replaced with another enlarged
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`photo on the display screen. Intellectual Integrity’s sparse explanation does not
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`establish that the newly enlarged photo is translated and centered. It also does not
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`establish that what allegedly is being enlarged, translated, and centered is the same
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`structured electronic document containing the box on which the first gesture was
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`performed. By contrast, the enlarging and translating limitations of the ’163 patent
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`claims occur within a single “structured electronic document.”44 For this reason, as
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`well, Intellectual Integrity has not satisfied 37 C.F.R. § 42.104(b)(4).
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`B. Harada Does Not Satisfy the “Translating” Limitations
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`Harada’s disclosures affirmatively show that it does not disclose “translating
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`the structured electronic document” in response to detecting a first or second
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`gesture.
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`1. Harada Does Not Disclose “Translating the Structured
`Electronic Document” in Response to a First Gesture
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`Harada explains that a “grid of thumbnails is shown” in the “middle-game
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`43 Pet. at 17 (emphasis added).
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`44 See, e.g.,’163 Patent at figs. 5A, 5C (Ex. 1001).
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`screen” in Figure 2.45 “[T]apping on one of the photos in the grid will take the user
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`into the end game (Figure 3).”46 “In this screen (‘preview screen’), the selected
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`photo is enlarged.” 47 Four other photos appear in a row at the top.”48
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`First, these excerpts confirm that Harada does not disclose “translation” at
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`all. The user’s selection of a photo thumbnail in Figure 2 merely causes the
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`45 Harada at 327 (Ex. 1008).
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`46 Id.
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`47 Id.
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`48 Id.
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`program to display an entirely different screen. The user’s selection does not result
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`in translation of any kind such as, e.g., movement of a structured electronic
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`document so that the thumbnail is substantially centered on the screen.
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` Second, even assuming that the thumbnail photo of Figure 2 was “enlarged
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`and translated” in Figure 3, Figures 2 and 3 do not involve the same structured
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`electronic document. Tapping on a thumbnail image in Figure 2’s “middle-game”
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`screen takes the user to Figure 3—an entirely different screen on which the
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`enlarged image is displayed. The fact that “[f]our other photos appear in a row at
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`the top” of Figure 3, but not Figure 2, confirms that the “middle game” and “end
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`game” screens are not part of the same structured electronic document.
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`Thus, Harada does not disclose “enlarging and translating the structured
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`electronic document so that the first box is substantially centered on the touch
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`display screen,” as all three challenged claims require.
`
`2. Harada Does Not Disclose “Translating The Structured
`Electronic Document” in Response to a Second Gesture
`
`For similar reasons, Harada does not disclose “while the first box is
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`enlarged, detecting a second gesture” and then “translating the structured electronic
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`document so that the second box is substantially centered on the touch screen
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`display.”
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`Once a user enters the “end game” screen in Figure 3, the selected photo is
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`enlarged” and “[f]our other photos appear in a row at the top.” 49 The user then can
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`tap one of those four thumbnail images to “replace” the enlarged photo at the
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`center of the screen with the selected photo.50
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`Harada therefore does not disclose that tapping a thumbnail image will result
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`in “translating” the end-game screen so that the selected thumbnail is substantially
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`centered on the display. As before, tapping a thumbnail results in a different “end-
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`game” screen being presented to the user—one in which the currently enlarged
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`photo is replaced with a newly enlarged photo of the selected thumbnail. Harada
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`explains that “[t]he context changes accordingly” in the thumbnail array at the top
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`of the screen, confirming that no translating of the same structured electronic
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`document occurs.
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`3.
`
`Harada’s Disclosures Are No Different than the “Closest
`Available Prior Art References” During Prosecution
`
`With respect to the “translation” limitations, Harada discloses no more than
`
`the Funakami or Chen references that the Examiner considered during prosecution.
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`Like Harada, Figure 12 of Funakami depicted a state in which “the whole of an
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`49 Id.
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`50 Id. (“Tapping any of the four replaces the enlarged photo with an enlargement of
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`the tapped photo.”) (emphasis added).
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`image [is] displayed on the display screen by a dynamic enlargement/reduction
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`process. . . .”51 The Examiner agreed, however, that Funakami did not satisfy the
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`“translation” requirement.52
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`As for Chen, “the closest available prior art reference[],” the Examiner noted
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`that it discloses “a plurality of boxes and displaying the content of one of the boxes
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`enlarged and centered on the display in response [to] a selection.”53 But this
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`disclosure is no different than Intellectual Integrity’s description of Harada.
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`Specifically, Intellectual Integrity asserts that in Harada, “the photo from the grid
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`that was tapped is enlarged and centered upon the display screen.”54 Just as the
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`Examiner found that Chen failed to disclose “while the first box is enlarged,
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`51 Funakami at ¶ [0088] (Ex. 2006).
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`52 See Response to Office Action and Interview Summary at 12 (Ex. 2003) (“[T]he
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`Examiner agreed that amending claim 2 to recite ‘enlarging and translating the
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`structured electronic document so that the first box is substantially centered on the
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`touch screen display’ (as well as the other corresponding independent claims) . . .
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`would overcome the current rejections [over Gillespie and Funakami] . . . .”).
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`53 Notice of Allowability at 14 (Ex. 2004) (emphasis added).
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`54 Pet. at 16 (emphasis added).
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`translating the webpage/structured document such that the second box is
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`substantially centered,”55 Harada similarly fails to disclose this.
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`55 Notice of Allowability at 14 (Ex. 2004).
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`IV. CONCLUSION
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`Docket No. 106840000554
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`Intellectual Integrity’s failure to demonstrate how the Harada reference
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`satisfies the “translating” limitations of claims 2, 50, and 52 dooms its petition.
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`But even if Intellectual Integrity had attempted to make such a showing, Harada
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`still would not disclose translating the same structured electronic document.
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`Because Intellectual Integrity has not presented a reasonable likelihood that Harada
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`anticipates at least one challenged claim of the ’163 patent, Apple respectfully asks
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`the Board to deny the petition.
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`* * * * *
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`Apple authorizes the Board to charge any fees associated with these
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`proceedings to Deposit Account 03-1952.
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`Dated: April 29, 2016
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`Respectfully submitted,
`
`
`
`By: /Matthew Kreeger/
`Matthew I. Kreeger
` Registration No. 56,398
`MORRISON & FOERSTER LLP
`425 Market Street
`San Francisco, California 94105-2482
`Tel: (415) 268-6468
`Fax: (415) 268-7522
`
`Attorneys for Patent Owner Apple Inc.
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`IPR2014-01402
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`Docket No. 156812800300
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`Certificate of Service (37 C.F.R. § 42.6(e)(4))
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`I hereby certify that a copy of the attached Patent Owner’s Preliminary
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`Response was served as of the below date via electronic mail on the Petitioner at
`
`Respectfully submitted,
`
`By: /Matthew Kreeger/
`Matthew I. Kreeger
` Registration No. 56,398
`MORRISON & FOERSTER LLP
`425 Market Street
`San Francisco, California 94015-2482
`Tel.:
`(415) 268-6468
`Facsimile: (415) 268-7522
`
`Counsel for Patent Owner Apple Inc.
`
`the following correspondence address:
`
`Ronald W. Burns
`15139 Woodbluff Drive
`Frisco, Texas 75035
`(972) 632-9009
`rwburns@intellectualintegrity.net
`
`Kenneth Emanuelson
`Ross IP Group PLLC
`1700 Pacific Avenue, Suite 3750
`Dallas, Texas 75201
`(469) 363-5808
`kemanuelson@rossipg.com
`
`Dated: April 29, 2016
`
`
`
`
`
`
`
`
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`sf-3645696
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