UNITED STATES PATENT AND TRADEMARK OFFICE
`
`______________________
`
`
`IN THE UNITED STATES PATENT TRIAL AND APPEAL BOARD
`
`______________________
`
`DIGITAL CHECK CORP. d/b/a ST IMAGING
`Petitioner
`
`v.
`
`E-IMAGEDATA CORP.
`Patent Owner
`
`______________________
`
`CASE NO. IPR2017-00178
`U.S. PATENT NO. 9,179,019
`______________________
`
`
`
`PETITIONER’S RESPONSE IN OPPOSITION TO PATENT OWNER’S
`MOTION TO EXCLUDE
`
`
`
`
`
`
`
`
`
`______________________
`
`
`IN THE UNITED STATES PATENT TRIAL AND APPEAL BOARD
`
`______________________
`
`DIGITAL CHECK CORP. d/b/a ST IMAGING
`Petitioner
`
`v.
`
`E-IMAGEDATA CORP.
`Patent Owner
`
`______________________
`
`CASE NO. IPR2017-00178
`U.S. PATENT NO. 9,179,019
`______________________
`
`
`
`PETITIONER’S RESPONSE IN OPPOSITION TO PATENT OWNER’S
`MOTION TO EXCLUDE
`
`
`
`
`
`
`
`
`
`Table of Contents
`
`I.
`II.
`
`INTRODUCTION ........................................................................................... 1
`ARGUMENT ................................................................................................... 2
`A. Drawings and Figures in the Petition Used to Illustrate
`Petitioner’s Invalidity Theories are Admissible .................................... 2
`B.
`Admissible ............................................................................................. 4
`C.
`Admissible ............................................................................................. 5
`D.
`Requirements of the Federal Rules of Evidence ................................... 6
`1.
`is Not Hearsay ............................................................................. 7
`2.
`902(6) and is Not Hearsay .......................................................... 9
`3.
`Not Hearsay ............................................................................... 11
`III. CONCLUSION .............................................................................................. 12
`
`The Senn Declaration (Exhibit 1002)
`
`is Relevant and
`
`Exhibits 1006, 1007, 1008, 1009, and 1010 are Relevant and
`
`Exhibits 1007, 1008 and 1009 Satisfy the Admissibility
`
`Exhibit 1007 is Authenticated Under FRE 901(b)(4) and
`
`Exhibit 1008 is Authenticated Under FRE 901(b)(4) and
`
`Exhibit 1009 is Authenticated Under FRE 902(11) and is
`
`
`
`
`
`
`
`
`
`
`
`Case No. IPR2017-00178
`Patent No. 9,179,019
`
`Petitioner’s Updated List of Exhibits
`
`Ex. 1001: U.S. Patent No. 9,179,019 (“‘019 Patent”)
`
`Ex. 1002: Declaration of Anthony J. Senn
`
`Ex. 1003: Curriculum vitae of Anthony J. Senn
`
`Ex. 1004: U.S. Publication No. 2004/0012827 (“Fujinawa”)
`
`Ex. 1005: U.S. Patent No. 5,585,937 (“Kokubo”)
`
`Ex. 1006: U.S. Patent No. 5,061,955 (“Watanabe”)
`
`Ex. 1007: 5100 FICHE SCANSTATION, Field Service Manual
`
`Ex. 1008: Minolta UC-1 Universal Film Carrier (“Minolta”)
`
`Ex. 1009: Parts Manual for UC-6E, EC, ECM Motorized Combo Squared Corner
`
`Parts Numbers 210000-01,02,03 (“Minolta”)
`
`Ex. 1010: Declaration of Philip G. Barboni
`
`Ex. 1011: Excerpt of Fundamentals of Machine Design textbook
`
`Ex. 1012: Deposition Transcript of Jonathan Ellis
`
`Ex. 1013: Excerpt of Illustrated Sourcebook of Mechanical Components textbook
`
`
`
`ii
`
`
`
`Case No. IPR2017-00178
`Patent No. 9,179,019
`
`I.
`
`INTRODUCTION
`
`Petitioner submits this Opposition to Patent Owner’s (“PO”) Motion to
`
`Exclude (Paper 17). It is the opponent who bears the burden of establishing
`
`inadmissibility of an exhibit. 37 C.F.R. § 42.20(c). Far from meeting this burden,
`
`PO’s motion makes a laundry list of objections under the Federal Rules of
`
`Evidence (“FRE”) but fails to provide any explanation of how they apply or why
`
`the particular evidence is inadmissible.
`
`The Board has made its position clear: “There is a strong public policy for
`
`making all information filed in a non-jury, quasi-judicial administrative proceeding
`
`available to the public, especially in an inter partes review which determines the
`
`patentability of claims in an issued patent. It is better to have a complete record of
`
`the evidence submitted by the parties than to exclude particular pieces.” Nichia
`
`Corp. v. Emcore Corp., IPR2012-00005, Paper 68, at 59 (PTAB Feb. 11, 2014).
`
`The Board has further clarified that a motion to exclude is not the forum to
`
`challenge the sufficiency of evidence. Biomarin Pharm. Inc. v. Genzyme
`
`Therapeutic Prods. Ltd. P’ship, IPR2013-00537, Paper 79, at 24-25 (PTAB Feb.
`
`23, 2015). Against this backdrop, PO now moves to exclude annotated figures
`
`from the prior art, evidence that pertains to non-instituted grounds, and evidence
`
`that falls squarely within the bounds of admissibility under the FRE. As detailed
`
`below, PO’s motion should be denied in its entirety.
`
`
`
`1
`
`
`
`Case No. IPR2017-00178
`Patent No. 9,179,019
`
`II. ARGUMENT
`
`A. Drawings and Figures
`in the Petition Used to Illustrate
`Petitioner’s Invalidity Theories are Admissible
`
`PO seeks to exclude the “illustration” on page 9 of the petition and the
`
`“annotated figure” on page 51 of the petition.1 (Paper 17 at 4). Petitioner’s expert,
`
`Tony Senn, laid the foundation for the illustration as “a schematic representation of
`
`the Fujinawa microform
`
`imaging apparatus
`
`(e.g., Ex. 1004 at Fig.
`
`4)…representative of the well known features of microform imaging apparatuses.”
`
`(Ex. 1002 at ¶28; see also Paper 2 at 9, 10; Ex. 1004 at Fig. 4). Mr. Senn, likewise,
`
`laid the foundation for the annotated figure in paragraph 104 of his declaration by
`
`detailing the substitution of the Fujinawa drive mechanism with a Kokubo-type
`
`drive mechanism as depicted in the annotated figure. (Ex. 1002 at ¶104). The
`
`illustration and annotated figure are used by Petitioner to help illustrate its
`
`invalidity theory. (Paper 2 at 9, 50-51; Ex. 1002 at ¶¶28, 104; Ex. 1004 at Fig. 4).
`
`Mr. Senn is a mechanical engineer with over 25 years of experience in the field,
`
`including at least 10 years of design work on microform scanning equipment. (Ex.
`
`1002 at ¶¶7-19). PO has not questioned Mr. Senn’s credentials as one of skill in
`
`
`1 For consistency, Petitioner has used the same nomenclature as PO’s motion to
`
`exclude—“illustration” for the figure on page 9 and “annotated figure” for the
`
`figure on page 51.
`
`
`
`2
`
`
`
`Case No. IPR2017-00178
`Patent No. 9,179,019
`
`the art or his ability to opine on the prior art.
`
`PO’s assertion that these are “nothing more than a one-sided interpretation
`
`and representation of a figure disclosed in Fujinawa” (Paper 17 at 4) goes to
`
`weight, not admissibility. As laid out in Corning Inc. v. DSMIP Assets B.V., the
`
`Board’s approach to considering the admissibility of evidence is “[s]imilar to a
`
`district court in a bench trial, the Board, sitting as a non-jury tribunal with
`
`administrative expertise, is well-positioned to determine and assign appropriate
`
`weight to evidence presented.” IPR2013-00053, Paper 66, at 19 (PTAB May 1,
`
`2014); Symantec Corp. and Blue Coat Sys. LLC v. Finjan, Inc., IPR2015-01892,
`
`Paper 58, at 64 (Mar. 15, 2017) (same).
`
`Here, the illustration is plainly presented in the Petition and by Petitioner’s
`
`expert as what it is—“a schematic representation” of the prior art and
`
`“representative of the well known features of microform imaging apparatuses.”
`
`(Paper 1 at 9; Ex. 1002 at ¶28). Likewise, the figure is described as a “modified
`
`figure 4” of Fujinawa. (Paper 1 at 50-51). As such, there is simply no risk of
`
`Board confusion. Intri-Plex Techs., Inc. v. Saint-Gobain Perf. Plastics Rencol
`
`Ltd., IPR2014-00309, Paper 83, at 17-18 (PTAB Mar. 23, 2014) (denying motion
`
`to exclude annotated figures because there was no danger that the Board would be
`
`confused). The Board is capable of analyzing the prior art figure from which the
`
`illustration and figure were created (e.g., Figure 4 of Ex. 1004) and reaching its
`
`
`
`3
`
`
`
`Case No. IPR2017-00178
`Patent No. 9,179,019
`
`own conclusions. Accordingly, exclusion is improper, as the Board can ascribe the
`
`weight it deems appropriate. Apple Inc. v. DSS Tech. Management, Inc., IPR2015-
`
`00369, 2016 WL 3382361, at *17 (PTAB June 17, 2016) (“a motion to
`
`exclude…is not an appropriate mechanism for challenging the sufficiency of
`
`evidence or the proper weight that should be afforded an argument.”).2
`
`B.
`
`The Senn Declaration (Exhibit 1002) is Relevant and Admissible
`
`PO seeks to exclude portions of the Senn Declaration (Ex. 1002) “to the
`
`extent it relates to claims on which the Board did not institute review.” (Paper 17
`
`at 5). As a preliminary matter, PO’s request is unnecessary. To the extent these
`
`paragraphs relate to non-instituted grounds, PO’s request is moot. Curt G. Joa,
`
`Inc. v. Fameccanica.Data S.p.A, IPR2016-00906, 2017 WL 4570515, at *15
`
`(PTAB Oct. 11, 2017) (“Patent Owner’s Motion to Exclude portions of Exhibit
`
`
`
`2 PO’s motion purports to argue all drawings in Exhibit 1002 that are “modified
`
`and/or annotated drawings present in the prior art…should also be excluded as
`
`unduly prejudicial.” (Paper 17 at 5). Notwithstanding PO’s failure to follow
`
`the Boards ascribed procedures for properly objecting to evidence and failing to
`
`provide any meaningful analysis aside from this blanket assertion—this exact
`
`issue has already been addressed, and rejected, by the Board. Apple Inc., 2016
`
`WL 3382361, at *17.
`
`
`
`4
`
`
`
`Case No. IPR2017-00178
`Patent No. 9,179,019
`
`1003 addressing non-instituted prior art references is dismissed as moot.”).
`
`As to substance, PO fails to articulate how the paragraphs are “irrelevant” or
`
`“inadmissible” merely because they relate to claims on which the Board did not
`
`institute review.
`
` To the contrary, the cited paragraphs provide detailed
`
`explanations of the prior art, the disclosures therein, and the knowledge of one of
`
`skill in the art at the time of the invention. (Ex. 1002 at ¶¶61, 66–71, 78, 85–98,
`
`and 108–117). For example, paragraph 78 explains how Kokubo discloses a motor
`
`and a rotational shaft that engages a drive mechanism—evidence directly relevant
`
`to the instituted grounds. (Ex. 1002 at ¶78). PO’s argument ignores the Board’s
`
`basic preference for maintaining a complete record of evidence submitted. Nichia
`
`Corp. v. Emcore Corp., IPR2012-00005, Paper 68, at 59 (PTAB Feb. 11, 2014) (“It
`
`is better to have a complete record of the evidence submitted by the parties than to
`
`exclude particular pieces.”).
`
`C. Exhibits 1006, 1007, 1008, 1009, and 1010 are Relevant and
`Admissible
`
`
`
`PO impermissibly seeks to exclude Exhibits 1006, 1007, 1008, 1009, and
`
`1010 because they “relate solely to claims on which the Board did not institute
`
`review.” (Paper 17 at 6). For the reasons discussed supra, this is unnecessary.
`
`More importantly, this is improper. With the exception of Exhibit 1010, the
`
`exhibits are prior art references and directly relevant to the ultimate issue of what
`
`was known by those of skill in the art at the time of the invention. Indeed, the
`
`5
`
`
`
`Case No. IPR2017-00178
`Patent No. 9,179,019
`
`Federal Circuit has flatly rejected PO’s argument that a reference is not relevant
`
`because it does not form the basis of the instituted grounds of review. Ariosa
`
`Diagnostics v. Verinata Health, Inc., 805 F.3d 1359, 1365 (Fed. Cir. 2015)
`
`(finding prior art does not have to be part of the ground of rejection to be relevant).
`
`D. Exhibits 1007, 1008 and 1009 Satisfy
`the Admissibility
`Requirements of the Federal Rules of Evidence
`
`Finally, PO seeks to exclude the entirety of exhibits 1007, 1008, and 1009 as
`
`lacking authenticity and hearsay. PO makes its request despite failing to identify
`
`anything about the evidence that would indicate unreliability. SDI Tech., Inc. v.
`
`Bose Corp., IPR2013-00350, 2015 WL 3749669, at *8-9 (November 7, 2014)
`
`(finding patent owner could point to no evidence that the evidence was unreliable).
`
`PO’s hearsay objections further fail to identify specific portions of the evidence
`
`that are being offered for the truth of the matter asserted. “The burden should not
`
`be placed on the Petitioner or Board to sort through the entirety of each exhibit and
`
`determine which portion [PO] believes to be hearsay.” EMC Corp. v. Personal
`
`Web Technologies, LLC, IPR2013-00085, Paper 73, at 68 (PTAB May 15, 2014)
`
`(finding PO failed to “identif[y], in its motion, the specific portions of the evidence
`
`and provide[] sufficient explanations as to why they constitute hearsay.”). PO’s
`
`argument is premised on the mistaken assumption that it is Petitioner’s burden to
`
`show the admissibility of the evidence. (Paper 17 at 6) (“Petitioner has failed to
`
`provide any evidence [to show] that Ex. 1007 is indeed the item the Petitioner
`
`6
`
`
`
`Case No. IPR2017-00178
`Patent No. 9,179,019
`
`claims it is.”). In an inter partes review proceeding, however, it is the opponent
`
`who bears the burden of establishing inadmissibility of an exhibit. 37 C.F.R. §
`
`42.20(c); see also FLIR Systems, Inc. v. Leak Suveys, Inc., IPR2014-00411, Paper
`
`113, at 5 (PTAB Sept. 3, 2015) (“In a civil action in a U.S. district court the
`
`proponent bears the burden of establishing the admissibility of its evidence. In our
`
`proceedings it is the opponent who bears the burden of establishing inadmissibility
`
`of an exhibit.”). PO’s lack of an articulated rationale alone is sufficient grounds to
`
`deny its motion to exclude. SDI Techs., Inc., 2015 WL 3749669, at *6 (finding PO
`
`could not articulate any reason to suspect the date stamp was unreliable).
`
`Nonetheless, the specific admissibility of each document is now addressed in turn.
`
`1.
`
`Exhibit 1007 is Authenticated Under FRE 901(b)(4) and is
`Not Hearsay
`
`As PO admits “Exhibit 1007 is Field Service Manual for a device called
`
`Fiche Scanstation.” (Paper 17 at 6). Without elaboration, PO alleges Petitioner
`
`has failed to provide any evidence to show the item is what Petitioner claims it is.
`
`(Paper 17 at 6-7). The standard for admissibility under the FRE is “slight.” States
`
`v. Turner, 718 F.3d 226, 232 (3rd Cir. 2013) (noting conclusive proof of a
`
`document’s authenticity is not required under FRE 901). A document may be
`
`authenticated by “the appearance, contents, substance, internal patterns, or other
`
`distinctive characteristics of the item, taken together with all the circumstances.”
`
`FRE 901(b)(4). Here, page one of Exhibit 1007 makes clear the document is a
`
`7
`
`
`
`Case No. IPR2017-00178
`Patent No. 9,179,019
`
`“5100 Fiche Scanstation Field Service Manual.” (Ex. 1007 at 1). The title page
`
`further includes a part number and revision information for the manual. (Ex. 1007
`
`at 1). Copyright information is listed on page three of the exhibit. (Ex. 1007 at 3).
`
`The document goes on to provide detailed instructions for operating the 5100
`
`Scanstation and the SCANFICHE operating software. (Ex. 1007). PO fails to
`
`show how this is insufficient under FRE 901(b)(4) or how this document is “not
`
`what Petitioner claims it is.” Actifio, Inc. v. Delphix Corp., IPR2015-00052, 2016
`
`WL 1393513, at *3 (Mar. 31, 2016) (“On this record, we accept Exhibit 1103 for
`
`what it purports and is alleged to be: “a user manual for a NetApp product.”).
`
`Indeed, PO provides no evidence that calls into question the authenticity of Exhibit
`
`1007. (See generally, Paper 17).
`
`With regard to PO’s boilerplate “Exhibit 1007 should also be excluded as
`
`hearsay” argument, Exhibit 1007 is used to provide background regarding the
`
`technology at issue. It is well established that “a prior art document…is offered
`
`simply as evidence of what it described, not for proving the truth of the matters
`
`addressed in the document.” EMC Corp. v. Personal Web Technologies, LLC,
`
`IPR2013-00085, Paper 73, at 66 (PTAB May 15, 2014) (citing Joy Techs., Inc. v.
`
`Manbeck, 751 F. Supp. 225, 233 n.2 (D.D.C. 1990), judgment aff’d, 959 F.2d 226
`
`(Fed. Cir. 1992)); Biomarin Pharm. Inc., v. Genzyme Therapeutic Products Ltd.
`
`P’ship, IPR2013-00537, Paper 79, at 25 (PTAB Feb. 23, 2015). Even if any
`
`
`
`8
`
`
`
`Case No. IPR2017-00178
`Patent No. 9,179,019
`
`portion of Exhibit 1007 were considered hearsay, it would fall under the residual
`
`exception to hearsay as PO has failed to articulate a single reason why Exhibit
`
`1007 is suspect. SDI Techs., Inc., 2015 WL 3749669, at *6 (finding PO could not
`
`articulate any reason to suspect the date stamp was unreliable).
`
`2.
`
`Exhibit 1008 is Authenticated Under FRE 901(b)(4) and
`902(6) and is Not Hearsay
`
`Exhibit 1008 is an article from Library Technology Reports and as such is a
`
`self-authenticating periodical. Palo Alto Networks, Inc., IPR2015-01979, 2017
`
`WL 1040259, at *26 (“The Sirer reference is self-authenticating because it
`
`contains indicia sufficient to show that it is an ACM article.”). PO admits “Exhibit
`
`1008 is a report on the UC-1 Universal Film Carrier.” (Paper 17 at 7). Again,
`
`without elaboration, PO alleges Petitioner has failed to provide any evidence to
`
`show the item is what Petitioner claims it is. The cover page of Exhibit 1008
`
`shows the report published in the September/October 1992, Volume 28, No. 5 of
`
`“Library Technology Reports” by the American Library Association. (Ex. 1008 at
`
`1). The Cover page lists an ISSN 3 number and displays a “University of
`
`
`3 An ISSN is an 8-digit code used to identify newspapers, journals, magazines
`
`and periodicals. The ISSN is associated with the title of the publication, in this
`
`case
`
`the Library Technology Reports. See
`
`ISSN database
`
`search,
`
`http://www.issn.cc/0024-2586.
`
`
`
`9
`
`
`
`Case No. IPR2017-00178
`Patent No. 9,179,019
`
`Washington” library stamp dated April 16, 1993. (Ex. 1008 at 1). PO fails to meet
`
`its burden to show this is insufficient under the FRE. Actifio, Inc., 2016 WL
`
`1393513, at *3 (Mar. 31, 2016).
`
`For the same reasons discussed above, Exhibit 1008 is not hearsay because
`
`as a prior art document it is being offered as evidence of what it describes, not for
`
`proving the truth of the matters addressed in the document. EMC Corp., IPR2013-
`
`00085, Paper 73 at 66. To the extent any portion of Exhibit 1008 is considered
`
`hearsay, it plainly falls under the residual hearsay exception. Merck Sharp &
`
`Dohme Corp. v. Mayne Pharma International Pty Ltd., IPR2016–01186, 2016 WL
`
`7999581, at *6 (PTAB Dec. 19, 2016) (finding journal article met the residual
`
`exception to hearsay because “the masthead on the first page of each journal
`
`article, which includes the name of the journal, the volume number, publication
`
`date, and other indicia, provides circumstantial guarantees of trustworthiness.
`
`Moreover, the date printed on the first page of each journal article is offered as
`
`evidence of a material fact: the date of publication. Additionally, under the
`
`circumstances, we are persuaded that admitting the statements as evidence of the
`
`date of publication at this stage of the proceeding serves the interests of justice.”);
`
`see also Ericsson Inc. v. Intellectual Ventures I LLC, IPR2014-00527, Paper 41, at
`
`10-11 (PTAB May 18, 2015) (admitting evidence of an IEEE publication’s
`
`copyright date under the residual exception because “IEEE is a well-known,
`
`
`
`10
`
`
`
`Case No. IPR2017-00178
`Patent No. 9,179,019
`
`reputable compiler and publisher of scientific and technical publications.”). The
`
`interests of justice favor not excluding Exhibit 1008.
`
`3.
`
`Exhibit 1009 is Authenticated Under FRE 902(11) and is
`Not Hearsay
`
`Lastly, PO moves to exclude Exhibit 1009 as lacking authenticity and
`
`inadmissible hearsay. (Paper 17 at 8). Exhibit 1009 is a parts manual for the UC-6
`
`motorized carrier. (Ex. 1009 at 1). In support of the manual’s authenticity,
`
`Petitioner submitted the declaration of Mr. Philip Barboni, the author of the
`
`manual. (Ex. 1010). Google, Inc. v. Zuili, CBM2016-00008, Paper 55, at 6-7
`
`(PTAB Apr. 24, 2017) (finding affidavits that verify that a certain exhibit is
`
`published “as part of its regular course of business…provide[] proper admissible
`
`evidence that [exhibits] were documents that would have been published…inits
`
`usual course of business.”). Mr. Barboni testified, with his personal knowledge of
`
`Exhibit 1009, that it “was prepared and maintained in the ordinary course of ICT
`
`business” and that “[i]n the ordinary course of ICT business, Ex. 1009 was
`
`published to ICT’s distributors for the UC-6 product.” (Ex. 1010 at ¶6). PO’s
`
`argument fails to acknowledge Mr. Barboni’s declaration, let alone point to any
`
`lack of credibility in his testimony. EMC Corp., IPR2013-00085, Paper 73, at 68.
`
`Indeed, PO did not even take the deposition of Mr. Barboni regarding his
`
`declaration despite having the opportunity to do so.
`
`With regard to PO’s boilerplate hearsay argument, Exhibit 1009, as prior art,
`11
`
`
`
`
`
`Case No. IPR2017-00178
`Patent No. 9,179,019
`
`is being offered for what it describes, not for the truth of the matter asserted. Id.
`
`66). To the extent any portion of Exhibit 1009 is considered hearsay, the
`
`unrebutted testimony of Mr. Barboni establishes Exhibit 1009 falls under the
`
`business record exception to hearsay. (Ex. 1010 at ¶¶6-7); see Google, Inc.,
`
`CBM2016-00008, Paper 55, at 7. Again, PO elected not to take the deposition of
`
`Mr. Barboni, so his testimony remains unrefuted.
`
`III. CONCLUSION
`
`PO’s Motion to Exclude fails to show how any of the evidence provided by
`
`Petitioner is inadmissible and should be denied in its entirety.
`
`
`
`Dated January 12, 2018
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`By:
`
`
`
`
`
`
`
`/Jason A. Engel/
`Jason A. Engel
`Reg. No. 51,654
`Counsel for Petitioner
`Dated: January 12, 2018
`
`
`
`
`
`
`
`12
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on January 12, 2018, a true and correct copy of the
`
`foregoing was caused to be served electronically on the following counsel of
`
`record for Patent Owner at the following email addresses:
`
`
`
`Johanna M. Wilbert
`Joel A. Austin
`Michael T. Piery
`QUARLES & BRADY LLP
`411 East Wisconsin Avenue
`Suite 2350
`Milwaukee, Wisconsin 53202
`johanna.wilbert@quarles.com
`joel.austin@quarles.com
`michael.piery@quarles.com
`
`
`
`/Jason A. Engel/
`Jason A. Engel
`Reg. No. 51,654
`
`
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
