Trials@uspto.gov
`571-272-7822
`
`Paper No. 39
`
` Mailed August 16, 2018
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`SONY CORPORATION,
`Petitioner,
`
`v.
`
`FUJIFILM CORPORATION,
`Patent Owner.
`____________
`
`Case IPR2017-00809
`Patent 6,703,106 B2
`____________
`
`
`Before JO-ANNE M. KOKOSKI, JEFFREY W. ABRAHAM, and
`MICHELLE N. ANKENBRAND, Administrative Patent Judges.
`
`ABRAHAM, Administrative Patent Judge.
`
`
`
`FINAL WRITTEN DECISION
`35 U.S.C. § 318(a) and 37 C.F.R. § 42.73
`
`ORDER ON MOTION TO AMEND
`35 U.S.C. § 316(d) and 37 C.F.R § 42.121
`
`
`571-272-7822
`
`Paper No. 39
`
` Mailed August 16, 2018
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`SONY CORPORATION,
`Petitioner,
`
`v.
`
`FUJIFILM CORPORATION,
`Patent Owner.
`____________
`
`Case IPR2017-00809
`Patent 6,703,106 B2
`____________
`
`
`Before JO-ANNE M. KOKOSKI, JEFFREY W. ABRAHAM, and
`MICHELLE N. ANKENBRAND, Administrative Patent Judges.
`
`ABRAHAM, Administrative Patent Judge.
`
`
`
`FINAL WRITTEN DECISION
`35 U.S.C. § 318(a) and 37 C.F.R. § 42.73
`
`ORDER ON MOTION TO AMEND
`35 U.S.C. § 316(d) and 37 C.F.R § 42.121
`
`
`
`IPR2017-00809
`Patent 6,703,106 B2
`
`
`I. INTRODUCTION
`In this inter partes review, Sony Corporation (“Petitioner”) filed a
`Petition challenging claims 1–6 of U.S. Patent No. 6,703,106 B2 (Ex. 1001,
`“the ’106 patent”). After we instituted an inter partes review of claims 1–6,
`Fujifilm Corporation (“Patent Owner”) filed a non-contingent Motion to
`Amend seeking cancellation of the challenged claims and proposing
`substitute claims 7–12.
`We have jurisdiction to conduct this inter partes review under
`35 U.S.C. § 6. This Final Written Decision is entered pursuant to 35 U.S.C.
`§ 318(a) and 37 C.F.R. § 42.73. For the reasons discussed below, Patent
`Owner’s Motion to Amend is granted with respect to cancellation of claims
`1–6, and denied with respect to proposed substitute claims 7–12.
`A. Procedural History
`Petitioner filed a Petition seeking inter partes review of claims 1–6 of
`the ’106 patent. Paper 2 (“Pet.”). Patent Owner filed a Patent Owner
`Preliminary Response to the Petition. Paper 12 (“Prelim. Resp.”). Applying
`the standard set forth in 35 U.S.C. § 314(a), which requires demonstration of
`a reasonable likelihood that Petitioner would prevail with respect to at least
`one challenged claim, we instituted an inter partes review of claims 1–6
`with regard to the questions of whether claims 1–6 of the ’106 patent are
`unpatentable under 35 U.S.C. § 103 as obvious in view of the combined
`
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`2
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`Patent 6,703,106 B2
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`teachings of Yamazaki1 and Endo2 or Yamazaki and Araki.3 Paper 13
`(“Inst. Dec.”), 26.4
`Following institution, Patent Owner did not file a Response to the
`Petition pursuant to 37 C.F.R. § 42.120. Instead, pursuant to 35 U.S.C.
`§ 316(d) and 37 C.F.R. § 42.121, Patent Owner filed a Motion to Amend
`that was not contingent on a determination that the original claims are
`unpatentable. Paper 26 (“Mot.”). In its Motion to Amend, Patent Owner
`requested that we cancel claims 1–6 and replace them with proposed
`substitute claims 7–12. Mot. 1. Petitioner filed an Opposition to the Motion
`to Amend (Paper 28, “Opp.”), and Patent Owner filed a Reply to Petitioner’s
`Opposition (Paper 29, “Reply”).
`An oral hearing was held on May 17, 2018, and an official transcript
`has been entered into the record. Paper 38 (“Tr.”).
`B. Related Proceedings
`The parties indicate that the ’106 patent is involved in Certain
`Magnetic Data Storage Tapes and Cartridges Containing the Same (ITC
`Investigation No. 337-TA-1012). Pet. vii; Paper 3, 2. Petitioner further
`identifies the following litigation as related: Sony Corporation v. Fujifilm
`Holdings Corporation, Civil Action No. 1:16-cv-05988-PGG (S.D.N.Y).
`Pet. vii.
`
`
`1 U.S. Patent No. 6,017,605, issued Jan. 25, 2000 (Ex. 1004).
`2 JP 2000-40218A, published Feb. 8, 2000 (Ex. 1005).
`3 U.S. Patent No. 6,149,989, issued Nov. 21, 2000 (Ex. 1006).
`4 On April 26, 2018, we modified our Institution Decision to institute on all
`of the challenged claims and all of the grounds presented in the Petition.
`Paper 33.
`
`
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`3
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`IPR2017-00809
`Patent 6,703,106 B2
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`
`C. The ’106 Patent
`The ’106 patent, titled “Magnetic Recording and Reproducing Method
`and Magnetic Recording Medium for Use in the Method,” issued on March
`9, 2004. Ex. 1001, [54], [45]. The ’106 patent is directed to a high-density
`magnetic recording and reproducing method that does not generate noise.
`Id. at 2:16–18. In discussing prior art magnetic recording media, the ’106
`patent states that when “higher density recording is done by further lessening
`a track width or thinning the magnetic layer thickness, a sufficient S/N
`[signal-to-noise] ratio cannot be obtained at reproduction. In particular, the
`influence of the abrasive becomes large when an MR [magneto-resistive]
`head is used, which causes the degradation of S/N ratio.” Id. at 2:11–15.
`The ’106 patent teaches recording and producing a signal in a track
`width (A) of less than 5µm on a magnetic recording medium. Id. at 2:32–
`35. The magnetic recording medium used in the recording and reproducing
`method of the ’106 patent includes a support, a substantially nonmagnetic
`lower layer provided on the support, and a magnetic layer containing a
`ferromagnetic metal powder, an abrasive, and a binder provided on the
`nonmagnetic lower layer, “wherein the average longer size (B) of the
`abrasive particle(s) on the magnetic layer surface is ⅓ or less of the track
`width (A).” Id. at 2:33–39. According to the ’106 patent, maintaining this
`relationship between the average longer size of the abrasive particle(s)
`present on the magnetic layer surface and track width provides a magnetic
`recording and reproducing system and method that is “optimal for digital
`recording” and reproduction with an MR head, and has “excellent”
`electromagnetic characteristics. Id. at 2:25–29, 3:11–17.
`
`
`
`4
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`IPR2017-00809
`Patent 6,703,106 B2
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`
`With regard to abrasives, the ’106 patent states that “[w]ell-known
`materials essentially having a Mohs’ hardness of 6 or more” can be used,
`and indicates a preference for abrasives having a particle size from 0.01 to
`2 µm. Id. at 12:5–23. The ’106 patent also discloses a process for preparing
`the magnetic coating solution for use in the magnetic recording medium,
`which includes at least a kneading step and a dispersing step, and optionally
`a blending step. Id. at 18:39–54. According to the ’106 patent, “even when
`the same abrasive is used, the average longer size of the abrasive becomes
`large depending upon the dispersion condition of the abrasive.” Id. at
`25:10–13.
`The ’106 patent also provides a method for determining the average
`longer size of the abrasive particles that includes subjecting a magnetic layer
`surface to plasma treatment, drying the surface, observing the particles using
`an electron microscope, “measuring the largest value of the width (i.e., the
`longer size), and taking the average value of 50 abrasive particles and/or
`cluster mainly comprising abrasives as the average longer size.” Id. at 3:20–
`40.
`
`The ’106 patent describes several embodiments of the invention
`disclosed therein, as well as comparative examples, and provides a table
`comparing measured properties of each. Id. at 21:25–24:22, Table 1. These
`properties include the average longer size of the abrasive, track width, and
`S/N ratio. Id. at Table 1.
`
`
`
`5
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`IPR2017-00809
`Patent 6,703,106 B2
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`
`D. Originally Challenged Claims
`Claim 1, reproduced below, is illustrative of the subject matter of
`originally challenged claims 1–6:
`reproducing method
`recording and
`1. A magnetic
`comprising recording and reproducing a signal with a
`magnetic head in a track width (A) of less than 5 μm on
`a magnetic recording medium comprising a support
`having provided thereon a magnetic layer containing at
`least a ferromagnetic powder, an abrasive and a binder,
`wherein the average longer size (B) of the abrasive
`particle(s) which are present on the magnetic layer
`surface is ⅓ or less of the track width (A).
`Ex. 1001, 26:5–14.
`
`
`E. Proposed Substitute Claims
`In its Motion to Amend, Patent Owner proposes claims 7–12 as
`substitutes for original claims 1–6. Proposed claim 7 is reproduced below,
`with the language deleted from claim 1 crossed out, and with underlining
`indicating inserted text:
`7. (Substitute for claim 1) A magnetic recording and
`reproducing method comprising recording and reproducing a
`signal with a magnetic head in having a track read head width
`(A) of less than 5 μm on a magnetic recording medium
`comprising a support having provided thereon a magnetic layer
`containing at least a ferromagnetic powder, an abrasive and a
`binder, and abrasive particles present on the magnetic layer
`surface, wherein at least some of said abrasive particles
`coalesce into one or more clusters mainly comprising abrasives,
`wherein the average longer size (B) of
`wherein the abrasive particle(s) which are abrasive
`particles and said one or more clusters mainly comprising
`abrasives present on the magnetic layer surface is ⅓ or less of
`the track width (A) have an average longer size (B),
`
`
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`6
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`IPR2017-00809
`Patent 6,703,106 B2
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`
`wherein the average longer size (B) is the average of the
`largest value of the width of the abrasive particles and said one
`or more clusters mainly comprising abrasives present on the
`magnetic layer surface, wherein each of said one or more
`clusters as a whole is taken as one, and
`wherein (B)/(A) defines a ratio α, and wherein α is ⅓ or less.
`Mot., Claim Listing Appendix.
`II. DISCUSSION
`A. Cancellation of Claims 1–6
`In its Motion to Amend, Patent Owner requests cancellation of claims
`1–6. Mot. 1. Petitioner agrees that these claims should be canceled
`irrespective of the outcome of Patent Owner’s Motion. Opp. 25.
`Accordingly, we grant Patent Owner’s Motion to Amend with respect to
`the request to cancel claims 1–6.
`B. Scope of the Substitute Claims
`Before considering the patentability of any substitute claims, we first
`must determine whether the motion to amend meets the statutory and
`regulatory requirements set forth in 35 U.S.C. § 316(d) and 37 C.F.R.
`§ 42.121. Pursuant to 35 U.S.C. § 316(d)(3), a motion to amend may not
`present substitute claims that enlarge the scope of the claims of the
`challenged patent. Furthermore, our rules provide that “[a] motion to amend
`may be denied where . . . [t]he amendment seeks to enlarge the scope of the
`claims.” 37 C.F.R. § 41.121(a)(2)(ii).
`In the Federal Circuit’s en banc decision in Aqua Products, Inc. v.
`Matal, 872 F.3d 1290 (Fed. Cir. 2017), the lead plurality opinion explains
`that “the patent owner must satisfy the Board that the statutory criteria in
`§ 316(d)(1)(a)–(b) and § 316(d)(3) are met and that any reasonable
`
`
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`7
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`IPR2017-00809
`Patent 6,703,106 B2
`
`procedural obligations imposed by the Director are satisfied.” Id. at 1305–
`06. Citing this portion of Aqua Products, Petitioner contends that Patent
`Owner bears the burden to establish compliance with § 316(d)(3)’s
`requirement that an amendment “may not enlarge the scope of the claims of
`the patent or introduce new matter.” Opp. 4. Patent Owner did not contest
`this position in its Reply. Tr. 72:8; see also id. at 91:16–20 (Petitioner
`arguing Patent Owner waived any argument that Patent Owner does not bear
`the burden of showing the Motion to Amend does not comply with
`35 U.S.C. § 316(d)(3)).
`We, therefore, must determine whether Patent Owner has established
`that its Motion to Amend complies with section 316(d)(3)’s requirement that
`an amendment “may not enlarge the scope of the claims of the patent.”
`Patent Owner argues that it came forward with “a prima facie case of
`nonenlargement.” Tr. 71:20–72:4. We disagree.
`Original claim 1 recites “[a] magnetic recording and reproducing
`method comprising recording and reproducing a signal with a magnetic head
`in a track width (A) of less than 5 μm on a magnetic recording medium.”
`Ex. 1001, 26:5–9. Claim 2 also recites “track width (A),” and claims 3–6
`depend from either claim 1 or claim 2. Id. at 26:15–43. Patent Owner’s
`proposed substitute claims 7 and 8 recite the term “read head width (A)” in
`place of “track width (A).” Mot., Claim Listing Appendix.5
`We begin with a discussion of the term “track width” used in the
`original claims. The term refers generally to the width of the data track on a
`
`5 Substitute claims 9–12 depend from either claim 7 or claim 8. Mot., Claim
`Listing Appendix. As a result, the question of whether replacing “track
`width (A)” with “read head width (A)” enlarges the scope of the claims of
`the patent, which the parties dispute, applies to all of the substitute claims.
`
`
`
`8
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`IPR2017-00809
`Patent 6,703,106 B2
`
`magnetic recording medium. See Ex. 1015 (Declaration of David B. Bogy,
`Ph.D), ¶ 25. Dr. Bogy explains that “[i]n order to achieve improvements in
`areal density, multiple data tracks have been squeezed side-by-side on
`recording media at ever increasing numbers of tracks per unit width of
`media (“track density”).” Id. Dr. Bogy provides a figure, reproduced below,
`to show how the track width decreases when the number of tracks on the
`same recording medium increases.
`
`
`
`
`Id. This figure shows the inverse relationship between track density and
`track width.
`Petitioner directs us to evidence demonstrating that a person of
`ordinary skill in the art would have understood that there are several
`different, alternative ways to measure track width. Id. ¶ 55. These include
`(1) the reciprocal of track density (1/TPI), (2) width of the data recorded
`
`
`
`9
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`IPR2017-00809
`Patent 6,703,106 B2
`
`within the track, and (3) read head width. Id.; see also Tr. 11:3–20 (counsel
`for Patent Owner agreeing the same three measurements can be used to
`determine track width). Dr. Bogy provides the following diagram to
`illustrate the different ways to measure track width.
`
`
`
`Ex. 1015 ¶ 55. This diagram shows the differences between track width
`values measured as 1/TPI, read head width, and data track width.
`Although the parties dispute the exact numerical ratios, it is
`undisputed that the track width measured as read head width will typically
`be less than track width measured as 1/TPI. Id.; Ex. 1040, 33:22–34:3;
`Tr. 9:20–21.
`Patent Owner contends that its amendment changing “track width
`(A)” to “‘read head width (A)’—narrow[s] the scope of the claims relative
`to the Board’s interpretation of the original term ‘track width’.” Mot. 1
`(emphasis added). Specifically, Patent Owner argues that in the Institution
`Decision, we “construed the term ‘track width’ to include: (1) the reciprocal
`
`
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`IPR2017-00809
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`
`of track density, (2) the width of recorded data, or (3) the width of the read
`head.” Id. at 6 n.1, 9; see also Tr. 71:19 (arguing that the broadest
`reasonable interpretation we adopted in the Institution Decision is
`disjunctive). Patent Owner contends that substitute claims 7 and 8 are
`narrower than original claims 1 and 2 because they recite only one of those
`three possibilities. Mot. 6, 9; Reply 2. According to Patent Owner,
`“[l]imiting the claim to one of those three possibilities must, as a matter of
`logic and common sense, be narrower.” Reply 2–3 (citing Int’l Flavors &
`Fragrances v United States, Case IPR2013-00124 (PTAB May 20, 2014)
`(Paper 12), finding that reducing the number of compounds in a Markush
`group is a narrowing amendment).
`Patent Owner’s argument, however, incorrectly characterizes our
`interpretation of the term “track width” in the Institution Decision. Patent
`Owner’s argument is based on our statement in the Institution Decision that
`Petitioner “contends the broadest reasonable interpretation of ‘track width’
`should include track width values based on the reciprocal of track density,
`the width of recorded data, or the width of the read head.” Inst. Dec. 7–8
`(citing Pet. 18); Reply 2. Patent Owner relies on this sentence and our use of
`the word “or,” in isolation, to argue that we adopted a construction of the
`term “track width” that resembles a Markush-style claim. Reply 2–3. In
`other words, Patent Owner contends that the original claim covered a closed
`list of alternatively useable members. See Abbott Labs v. Baxter Pharm.
`Prods., Inc., 334 F.3d 1274, 1280–81 (Fed. Cir. 2003) (explaining that
`members of a Markush group are used singly, and that a Markush group
`should be closed, i.e., excludes any members not specified in the group).
`
`
`
`11
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`IPR2017-00809
`Patent 6,703,106 B2
`
`
`The record, however, does not support Patent Owner’s arguments. In
`the Petition, Petitioner explained that the possible measures of “track width”
`included (1) reciprocal of the track density (1/TPI); (2) the width of the data
`recorded on the track; and (3) the width of the read head. Pet. 15–17;
`Opp. 5–6. Petitioner then argued that
`[u]nder the [broadest reasonable interpretation (BRI)] standard
`that the Board applies in this proceeding, “track width” should
`be interpreted broadly enough to cover at least the specific
`measures that the specification describes. All of the grounds
`relied upon herein demonstrate that the claimed range of track
`widths is met using any of the measures discussed above.
`([Ex. 1015] ¶58). Thus, it is unnecessary for the Board to
`attempt to determine the full metes and bounds of this
`limitation as that is not necessary or determinative for any
`ground. . . . The claims are unpatentable under each ground
`when the claimed “track width” is determined using any of the
`specific measures described
`in
`the specification, which
`necessarily meet the BRI of this limitation.
`Pet. 18–19.
`We understood Petitioner to be arguing that even though it believed
`the claim term “track width” was indefinite,6 trial could be instituted because
`the cited prior art read on that claim limitation under all of the possible
`values for “track width.” Id.; Inst. Dec. 6–8; Opp. 5. The sentence in the
`Institution Decision, upon which Patent Owner relies to support its argument
`that its proposed amendment is narrowing, simply restated Petitioner’s
`position that the broadest reasonable interpretation of “track width,” for
`purposes of this inter partes review, includes all three identified possible
`measures of “track width,” not just any one of those three.
`
`
`6 In the aforementioned ITC proceeding, ALJ Shaw found the term “track
`width” to be indefinite. Ex. 2011, 197–200.
`
`
`
`12
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`IPR2017-00809
`Patent 6,703,106 B2
`
`
`Although we did use the word “or” in the Institution Decision (Inst.
`Dec. 7–8), as noted above, there is insufficient support in the record for
`Patent Owner’s assertion that we adopted a construction of “track width”
`that recites a closed list of alternatively useable members. The only instance
`where only one of the three recited measurements may be used singly is the
`exact situation Petitioner presents, wherein track width is measured by
`1/TPI. And the use of a single measurement in that one instance is
`acceptable only because track width values measured as read head width or
`data width values are necessarily smaller than track width values measured
`as 1/TPI, meaning that all three measurement values will be less than or
`equal to the track width value measured as 1/TPI.7 The same cannot be said
`for measurements taken based on read head width alone or data width alone.
`In that regard, Patent Owner directs us to nothing in the record
`demonstrating that Petitioner’s proposed construction included using only
`read head width to measure track width or only the width of the recorded
`data to measure track width. As a result, our interpretation of the term in the
`Institution Decision was limited to subject matter that met the “track width”
`limitation in the original claim using all three of the possible measurement
`methods.
`Thus, the full record developed during this trial does not support
`Patent Owner’s contention that the broadest reasonable interpretation of
`
`
`7 Petitioner argued that because the prior art reference disclosed a magnetic
`recording medium with a track width value less than 5 µm (as required by
`original claim 1) measured as 1/TPI, it necessarily would have had a track
`width value less than 5 µm if the track width were measured as read head
`width or recorded data width, as these values are necessarily smaller than
`track width measured as 1/TPI. Pet. 30.
`
`
`
`13
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`IPR2017-00809
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`
`“track width” is a disjunctive interpretation that “broadly encompasse[s]
`(1) the reciprocal of track density, (2) the width of recorded data, or (3) the
`width of the read head” as alternatively useable members. Reply 1. Because
`Patent Owner’s argument that it narrowed the claims by selecting one of
`three possible values is based on its disjunctive interpretation of “track
`width,” we are not persuaded that it presented “a prima facie case of
`nonenlargement.” Tr. 72:1–3.
`Petitioner presents a persuasive argument that, by choosing to replace
`“track width” with “read head width,” Patent Owner enlarges the scope of
`the claims because the amended claims now recite only the broadest of the
`three measurements of track width required by the original claims. Opp. 2,
`5. Petitioner provides an example to illustrate this, noting that the same
`medium could have a track width measured as 1/TPI of 5.5 µm and a track
`width measured as read head width of 4.4 µm. Id. at 7 (based on an 80%
`size ratio between 1/TPI and read head width (see Ex. 1015 ¶ 55)). Under
`Petitioner’s interpretation of track width in the original claim (requiring a
`track width less than 5 µm measured all three ways), this medium would not
`fall within the scope of the original claim due to the 1/TPI value being
`greater than 5 µm. This medium, however, would fall within the scope of
`the proposed substitute claims – which require only a read head width of less
`than 5 µm. Accordingly, the proposed substitute claims would encompass
`material that does not fall within the scope of the original claims.
`Patent Owner’s only response to this argument is based on its
`disjunctive interpretation of track width:
`Because the BRI of the original claim encompassed 1/TPI or
`read head width, the example would infringe the original claims
`and a substitute claim which is limited to read head width. In
`
`
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`
`other words, “{4.4 μm} < 5 μm” is not (and cannot) be broader
`than “{4.4 μm OR 5.5 μm} < 5 μm.
`Reply 3. As noted above, Patent Owner offers insufficient evidence to
`support such an interpretation of the original claim. Nor does Patent Owner
`explain how the amended claims do not enlarge the scope of the claims
`under Petitioner’s actual proposed interpretation, requiring all three track
`width measurement values to be less than 5 µm, instead of just one of the
`three.
`
`For all of the reasons discussed above, we are not persuaded that
`Patent Owner’s Motion to Amend meets the statutory requirements set forth
`in 35 U.S.C. § 316(d)(3) or the regulatory requirements set forth in
`37 C.F.R. § 42.121(a)(2)(ii). We, therefore, deny Patent Owner’s Motion to
`Amend with respect to the proposed substitute claims.
`III. CONCLUSION
`For the foregoing reasons, we cancel claims 1–6, and we determine
`that Patent Owner’s proposed substitute claims do not satisfy the
`requirements of 35 U.S.C. § 316(d)(3) and 37 C.F.R. § 42.121(a)(2)(ii).
`IV. ORDER
`For the reasons given, it is hereby
`ORDERED that Patent Owner’s Motion to Amend is granted-in-part
`as to its request to cancel claims 1–6;
`FURTHER ORDERED that Patent Owner’s Motion to Amend is
`denied-in-part as to substitute claims 7–12; and
`FURTHER ORDERED that, because this is a final written decision,
`parties to the proceeding seeking judicial review of the decision must
`comply with the notice and service requirements of 37 C.F.R. § 90.2.
`
`
`
`15
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`PETITIONER:
`Brandon S. Blackwell, Ph.D.
`Randy J. Pritzker
`Richard F. Giunta
`Gerald B. Hrycyszyn
`Michael N. Rader
`Chelsea A. Loughran
`Gregory F. Corbett
`WOLF GREENFIELD & SACKS, P.C.
`BBlackwell-PTAB@wolfgreenfield.com
`RPritzker-PTAB@wolfgreenfield.com
`RGiunta-PTAB@wolfgreenfield.com
`GHrycyszyn-PTAB@wolfgreenfield.com
`MRader-PTAB@wolfgreenfield.com
`Chelsea.Loughran@WolfGreenfield.com
`Gregory.Corbett@WolfGreenfield.com
`
`
`PATENT OWNER:
`Eliot D. Williams
`Robert C. Scheinfeld
`Robert L. Maier
`Joseph C. Akalski
`BAKER BOTTS L.L.P.
`eliot.williams@bakerbotts.com
`robert.scheinfeld@bakerbotts.com
`robert.maier@bakerbotts.com
`joseph.akalski@bakerbotts.com
`
`
`
`
`
`
`
`
`
`
`
`16
`
`
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