`571.272.7822
`
`
`
` Paper 8
`
` Entered: December 5, 2017
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`HUTCHINSON TECHNOLOGY INC.,
`HUTCHINSON TECHNOLOGY OPERATIONS (Thailand) CO., LTD.,
`Petitioners,
`
`v.
`
`NITTO DENKO CORPORATION,
`Patent Owner.
`____________
`
`Case IPR2017-01499
`Patent 7,923,644
`____________
`
`
`
`Before THOMAS L. GIANNETTI, CHRISTA P. ZADO, and
`MELISSA A. HAAPALA, Administrative Patent Judges.
`
`HAAPALA, Administrative Patent Judge.
`
`
`
`
`DECISION
`Denying Institution of Inter Partes Review
`37 C.F.R. § 42.108
`
`
`
`
`
`
`
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`
`
`
`
`
`
`Hutchinson Technology Incorporated and Hutchinson Technology
`Operations (Thailand) Co., Ltd. (collectively, “Petitioner”) filed a Petition
`pursuant to 35 U.S.C. §§ 311–319 to institute an inter partes review of
`claims 1–4 and 6 of U.S. Patent No. 7,923,644 B2 (“the ’644 patent”).
`Paper 2 (“Pet.”). Nitto Denko Corporation (“Patent Owner”) filed a
`Preliminary Response. Paper 6 (“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 deny Petitioner’s request and do not institute an inter
`partes review of the ’644 patent.
`I. BACKGROUND
`
`A. The ‘644 Patent (Ex. 1001)
`The ’644 patent describes a particular type of printed circuit board
`
`(suspension board) for aligning the magnetic head of a hard disk drive with a
`desired track of a magnetic disk. See Ex. 1001, 1:7–9, 1:13–15. The printed
`circuit board has reduced characteristic impedances of wiring patterns. Id. at
`1:49–56. Figure 1 is depicted below:
`
`
`
`2
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Figure 1 is a plan view of a suspension board. Id. at 5:58–59. Suspension
`board 1 includes suspension body 10 formed of a long-sized metal substrate.
`Id. at 6:34–36. Write wiring patterns W1, W2 and read wiring patterns R1,
`R2 are formed on suspension body 10. Id. at 6:36–38. Electrode pads 21,
`22, 23, 24 are formed on one end of the suspension body and electrode pads
`
`3
`
`
`
`
`
`
`
`
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`31, 32, 33, 34 are formed on the other end. Id. at 6:46–49. Electrode pads
`21 to 24 and electrode pads 31 to 34 are electrically connected to one
`another through wiring patterns W1, W2 and read wiring patterns R1, R2,
`respectively. Id. at 6:49–53.
`
`Figure 2 of the ’644 patent, as annotated in the Preliminary Response
`(at p. 4), is depicted below:
`
`
`Figure 2 is an annotated schematic diagram showing the configurations of
`write wiring patterns W1, W2. Ex. 1001, 6:65–67. Write wiring pattern 1
`(depicted in red and yellow) is constituted by lines LA4 (first line),
`LA3/LA5 (divided second line), LA1 (third line), and LA2 (fourth line). Id.
`at 7:1–2. LA1 is connected to electrode pad 21 and LA2 is connected to
`
`4
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`
`
`
`
`
`
`electrode pad 31. Id. at 7:2–4. One end of lines LA3, LA4 are integrated
`with line LA1, and the other end of line LA3 and end of line LA5 are
`electrically connected to each other in intersection region CN1. Id. at 7:5–8.
`Write wiring pattern 2 (depicted in blue and yellow) is constituted by
`lines LB3/LB5 (divided fifth line), LB4 (sixth line), LB1 (seventh line), and
`LB2 (eight line). Id. at 7:11–12. LB1 is connected to electrode pad 22 and
`LB2 is connected to electrode pad 32. Id. at 7:12–13. One ends of lines
`LB3, LB4 are integrated with line LB1, and the other end of line LB3 and
`end of line LB5 are electrically connected to each other in intersection
`region CN2. Id. at 7:14–17.
`Lines LA3, LA4, LB4, and LB5 are in parallel with one another and
`arranged so that LA3 is located between lines LB4, LB5 and LB5 is located
`between lines LA3, LA4. Id. at 7:20–25. LA3 of write wiring pattern W1
`extends to pass through a portion in between the ends of lines LB3, LB5 in
`intersection region CN2, and LB5 of write wiring pattern W2 extends to pass
`through a portion in between the ends of lines LA3, LA5 in intersection
`region CN1. Id. at 7:25–31.
`
`B. Illustrative Claim
`
`Claims 1 and 6 are independent claims. Claim 1 is illustrative of the
`subject matter of the claims at issue:
`1. A printed circuit board comprising:
`an insulating layer;
`first and second wiring patterns that are formed on one
`surface of said insulating layer and constitute a signal line pair;
`first and second electrode pads that are formed on one
`surface of said insulating layer and are connected to said first
`wiring pattern;
`
`
`
`5
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`
`
`
`
`
`
`third and fourth electrode pads that are formed on one
`surface of said insulating layer and are connected to said second
`wiring pattern;
`a first connecting layer that is provided on the other
`surface of said insulating layer, wherein
`said first wiring pattern has first, second, third and fourth
`lines,
`said second wiring pattern has fifth, sixth, seventh and
`eighth lines,
`one ends of said first and second lines are electrically
`connected to each other and the other ends of said first and
`second lines are electrically connected to each other,
`said third line extends to be branched from the one end of
`said first line or the one end of said second line and is
`connected to said first electrode pad,
`said fourth line extends to be branched from the other
`end of said first line or the other end of said second line and is
`connected to said second electrode pad,
`one ends of said fifth and sixth lines are electrically
`connected to each other and the other ends of said fifth and
`sixth lines are electrically connected to each other,
`said seventh line extends to be branched from the one
`end of said fifth line or the one end of said sixth line and is
`connected to said third electrode pad,
`said eighth line extends to be branched from the other
`end of said fifth line or the other end of said sixth line and is
`connected to said fourth electrode pad,
`said first and second lines of said first wiring pattern and
`said fifth and sixth lines of said second wiring pattern are
`arranged such that any one of said first and second lines is
`located between said fifth and sixth lines and any one of said
`fifth and sixth lines is located between said first and second
`lines,
`
`
`
`6
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`a first intersection region in which said first or second
`line of said first wiring pattern and said fifth or sixth line of said
`second wiring pattern intersect with each other is provided,
`a second intersection region in which said first or second
`line of said first wiring pattern and said fifth or sixth line of said
`second wiring pattern intersect with each other is provided,
`a portion of said first or second line of said first wiring
`pattern positioned in said first intersection region is divided, a
`portion of said fifth or sixth line of said second wiring pattern
`positioned in said first intersection region is arranged on said
`insulating layer to pass through a portion in between divided
`portions of said first or second line of the first wiring pattern,
`said insulating layer has first and second through holes in
`said first intersection region, one of said divided portions of
`said first or second line of the first wiring pattern is electrically
`connected to said first connecting layer through said first
`through hole, and the other of said divided portions of said first
`or second line of the first wiring pattern is electrically
`connected to said first connecting layer through said second
`through hole.
`C. References
`Petitioner relies on the following references:
`1. U.S. Patent No. 8,154,827, issued Apr. 10, 2012
`(“Contreras”) (Ex. 1005).
`2. U.S. Patent No. 8,379,349, issued Feb. 19, 2013 (“Pro”)
`(Ex. 1006).
`
`
`
`
`
`D. Grounds Asserted
`
`Petitioner challenges the patentability of the claims of the ’644 patent
`
`over the following combinations of references:
`Reference(s)
`Basis
`Contreras
`35 U.S.C. § 102(e)
`Contreras and Pro
`35 U.S.C. § 103(a)
`Pro
`35 U.S.C. § 102(e)
`
`Claim(s)
`1–4
`6
`1–4, 6
`
`7
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`E. Related Proceedings
`
`The parties identify the following civil action involving the ’644
`
`patent: Nitto Denko Corporation v. Hutchinson Technology Incorporated,
`C.A. No. 2:16-cv-03595-MF, pending in the United States District Court for
`the District of New Jersey. Pet. 3; Paper 4, 1. Petitioner also has filed a
`second petition for inter partes review of the ’644 patent (IPR2017-01625).
`F. Real Parties in Interest
`Petitioner identifies the following additional real parties in interest:
`1. Magnecomp Precision Technology Public Company Limited
`2. Magnecomp Corporation
`3. Headway Technologies, Inc.
`4. TDK Corporation
`5. TDK U.S.A. Corporation
`6. SAE Magnetics (Hong Kong) Limited
`7. Acrathon Precision Technologies (HK) Limited
`8. Acrathon Precision Technologies (Dong Guan) Co., Ltd
`Pet. 1–3. Patent Owner identifies no additional real parties in interest.
`Paper 4, 1.
`
`II. ANALYSIS
`
`
`
`A. Claim Construction
`In an inter partes review, claims of an unexpired patent are interpreted
`using the broadest reasonable construction in light of the specification of the
`patent in which they appear. See 37 C.F.R. § 42.100(b); Cuozzo Speed
`Techs., LLC v. Lee, 136 S. Ct. 2131, 2144–46 (2016). Under that standard,
`claim terms are generally given their ordinary and customary meaning, as
`would be understood by one of ordinary skill in the art in the context of the
`
`8
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`
`
`
`
`
`
`entire disclosure. In re Translogic Tech., Inc., 504 F.3d 1249, 1257 (Fed.
`Cir. 2007).
`Petitioner proposes a construction for “connecting layer,” which
`appears in all challenged claims. Pet. 9–10. Patent Owner asserts this term
`can be afforded its plain and ordinary meaning. Prelim. Resp. 7–8.
`Patent Owner proposes a construction for “extend[] . . . from the . . .
`end,” which appears in certain of the claimed “lines” limitations in
`independent claims 1 and 4. Id. at 8–9.
`In view of our analysis, we do not find it necessary to construe any
`terms for purposes of this Decision. See Vivid Techs., Inc. v. Am. Sci. &
`Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999) (holding that “only those
`terms need be construed that are in controversy, and only to the extent
`necessary to resolve the controversy”).
`B. Anticipation by Contreras and Obviousness over Contreras and
`Pro
`Petitioner contends that claims 1–4 are unpatentable as anticipated
`under 35 U.S.C. § 102(e) by Contreras. Pet. 10–36. Petitioner further
`contends that claim 6 is unpatentable as obvious under 35 U.S.C. § 103(a)
`over Contreras and Pro. Id. at 37–46. For the reasons that follow, Petitioner
`fails to demonstrate a reasonable likelihood of prevailing on these grounds.
`1. Overview of Contreras
`Contreras describes an integrated lead suspension (also called
`“flexure”) with interleaved coplanar electrically conductive lines or traces
`for connection of read/write circuitry to the read/write head in a magnetic
`recording disk drive. Ex. 1005, 1:9–13, 1:44–46. Figure 2A of Contreras is
`depicted below:
`
`
`
`9
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Figure 2A is a plan view of flexure 30 showing an elongate segment 31
`between gimbal segment 51 and pad segment 52. Id. at 2:65–67. Gimbal
`segment 51 has conductive traces 53 leading to pads 55 for electrical
`connection to pads on the slider; traces 53 are also connected to electrical
`connection end 34. Id. at 3:4–9. Electrical connection end 36 is connected
`to pads 54, 56 on pad segment 52. Id. at 3:11–13. A plurality of interleaved
`electrically conductive traces or lines 32, extend generally parallel to one
`another along elongate segment 31 between flexure ends 34, 36. Id. at
`13–16.
`Figure 3A illustrates the multiple –crossover coplanar connection
`(MCC) of the conductive traces and is depicted below:
`
`10
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Figure 3A is a plan view of a portion of flexure 30 showing end 36 and the
`connection to pads 54, 56. Id. at 3:51–52. Pad 54 is connected via lead 81
`to line 71 and then to traces 73, 75, 77 below insulating layer 64. Id. at
`3:52–55. Pad 56 is connected via lead 89 that fans out to leads 82, 84, 86,
`88 that connects to traces 72, 74, 76, 78. Id. at 3:55–58. Signal lines 71, 73,
`75, 77 in the first set and lines 72, 74, 76, 78 in the second set are interleaved
`and coplanar on insulating layer 64 and run generally parallel to one another
`along elongate segment 31. Id. at 3:58–61. End 36 also includes island 90
`of a metal substrate which allows connection of lines 71, 73, 75, 77 to lead
`81 below the insulator layer through a plurality of conductive vias in the
`insulating layer. Id. at 4:7–9, 4:14–18. Flexure elongate segment 31 has a
`similar MCC at end 34 near gimbal segment 51 (not depicted in Figure 3A),
`which allows connection of lines 72, 74, 76, 78 in a similar fashion. Id. at
`4:26–29.
`
`11
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`2. Claims 1–4
`Independent claim 1, and claims 2–4 by virtue of their dependency,
`
`recite “said eighth line extends to be branched from the other end of said
`fifth line or the other end of said sixth line and is connected to the fourth
`electrode pad” (“eighth line” limitation). Petitioner identifies one of the
`conductive traces 53 as the recited eighth line and asserts the identified trace
`53 branches from both the fifth line 72 and the sixth line 74 at electrical
`connection end 34. Pet. 24. Petitioner further provides an annotated version
`of a selected area of Figure 2A, depicted below:
`
`
`
`Petitioner’s annotated version of Figure 2A illustrates a selected magnified
`portion of that figure. Id. In the figure, Petitioner identifies the fifth and
`sixth lines and the specific trace 53 asserted to be the eight line connected to
`electrode pad 55. Id. In support of its assertions, Petitioner cites to
`declaration testimony of its expert, Thomas M. Coughlin, Ph.D. Id. (citing
`Ex. 1007 ¶ 95). In paragraph 95 of his declaration, Dr. Coughlin repeats the
`assertions made in the Petition, and in paragraph 96 (not cited in the
`Petition), Dr. Coughlin testifies that “there is a mistake in Fig. 2A of the
`Contreras patent, the eighth line should be connected with the buried
`conductive island, which is not clearly shown in the Fig. 2A. Ex. 1007
`¶¶ 95, 96.
`
`12
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`
`
`
`
`
`
`Patent Owner contends Contreras does not disclose the “eighth line”
`
`limitation. Prelim. Resp. 10–15. Specifically, Patent Owner argues Figure
`2A shows trace 53 (identified as the recited “eighth line”) traveling the
`entire length of the flexure and entirely bypassing—without any connection
`at all—the ends of all of the lines 72, 74, 76, 78. Id. at 12–13. Patent Owner
`further argues there is no support for Dr. Coughlin’s testimony that there is a
`mistake in Figure 2A. Id. at 14. Additionally, Patent Owner asserts that
`even if Dr. Coughlin were correct and Figure 2A does have the alleged error,
`trace 53 would still not be the claimed “eighth line” because it would extend
`from the buried island structure, not from the lines identified by Petitioner as
`the fifth or sixth lines. Id. at 14–15.
`
`We find that the cited evidence does not support Petitioner’s position
`that the specific identified trace 53 meets the “eighth line” limitation.
`Petitioner’s own annotated version of Figure 2A shows the identified trace
`53 bypassing the lines identified as the fifth and sixth lines and not
`“branching from fifth and sixth lines” as asserted by Petitioner. 1 See Pet.
`24. The cited portions of Contreras also fail to describe that the identified
`trace 53 extends to be branched from the end of line 72 (fifth line) or the end
`of line 74 (sixth line). See Ex. 1005, 3:6–16, 4:26–34. We do not find
`credible Dr. Coughlin’s testimony that there is a mistake in Figure 2A
`because it is conclusory and not supported by evidence. See 37. C.F.R.
`§ 42.65(a) (“Expert testimony that does not disclose the underlying facts or
`data on which the opinion is based is entitled to little or no weight.”); see
`also Skky, Inc. v. MindGeek, s.a.r.l., 859 F.3d 1014, 1022 (Fed. Cir. 2017)
`
`1 Figure 2A does show a trace that extends from the ends of lines 71, 72, 73,
`74, but Petitioner maps this trace to the claimed “fourth line” and not the
`“eighth line.” See Pet. 21–22.
`
`
`
`13
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`
`
`
`
`
`
`(“The Board reviewed the evidence presented by the parties, and chose not
`to credit Skky’s expert testimony. . . we discern no reversible error in that
`choice.”). Furthermore, we agree with Patent Owner that even if Dr.
`Coughlin’s testimony is correct that the identified line should be connected
`with the buried conductive island (Ex. 1007 ¶ 96), Petitioner fails to explain
`how a line that connects to the buried conductive island meets the claim
`limitation “extends to be branched from the other end of said fifth line or the
`other end of said sixth line” (emphasis added).
`For the foregoing reasons, we conclude Petitioner has not
`demonstrated a reasonable likelihood of prevailing in establishing claims
`1–4 are anticipated by Contreras.
`
`3. Claim 6
`
`Independent claim 6 recites the same “eighth line” limitation
`discussed above. Petitioner does not assert that Pro discloses this limitation,
`but rather relies on the analysis for claim 1 to meet the “eighth line”
`limitation. See Pet. 45–46. Accordingly, Petitioner fails to cure the
`deficiencies in Contreras discussed above and has not demonstrated a
`reasonable likelihood of prevailing on this challenge.
`C. Anticipation by Pro
`Petitioner contends that claims 1–4 and 6 are unpatentable as
`anticipated under 35 U.S.C. § 102(e) by Pro. Pet. 46–75. For the following
`reasons, Petitioner fails to demonstrate a reasonable likelihood of prevailing
`on this ground.
`Pro describes various jumper constructions that are adapted to
`electrically connect two or more traces of integrated transmission line arrays
`of an integrated lead flexure of a disk drive head suspension. See Ex. 1006,
`
`
`
`14
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`1:16–18, 3:46–50. One such jumper construction is shown in Figure 2A,
`depicted below:
`
`
`
`
`
`
`
`
`
`
`Figure 2A is a schematic view showing a jumper construction for an
`integrated lead flexure. Id. at 1:65–68. Jumper construction 100 includes
`trace layer 112, insulating layer 114, base layer 116, isolated conductor layer
`118 (also described as a conductive island) and a plurality of interconnects
`120a, 120b. Id. at 4:24–28. Trace layer 112 includes a plurality of traces
`122a-122d of one or more integrated transmission line arrays. Id. at 4:28–
`29. Traces 122a-122d are coplanar and are in an interleaved configuration.
`Id. at 4:30–31. First and third traces 122a, 122c are electrically joined
`through isolated conductor layer 118; second and fourth traces 122b, 122d
`are electrically joined within trace layer 112. Id. at 4:35–39. First and
`second interconnects 120a, 120b, in combination with isolated conductor
`layer 118, form a jumper connection between first and third traces 122a,
`122c. Id. at 5:1–5.
`
`Petitioner asserts Pro discloses the “third line . . . connected to said
`first electrode pad” and the “seventh line . . . connected to said third
`
`15
`
`
`
`
`
`
`
`
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`electrode pad,” as recited in independent claims 1 and 6 (and claims 2–4 by
`virtue of their dependency). See Pet. 55, 57; see also Pet. 74–75 (pointing to
`the analysis of claim 1 for the similar recitations set forth in claim 6). In
`support of its position, Petitioner provides an annotated version of Figure
`2A, depicted below:
`
`
`
`Petitioner’s annotated version of Figure 2A identifies the claimed first,
`second, third, fifth, sixth, and seventh lines with elements in the jumper
`construction 100 shown in the figure. Id. at 55, 57. In particular, Petitioner
`identifies a portion of 122a as the “third line” and a portion of 122b as the
`“seventh line.” Id. Petitioner asserts Pro discloses the illustrated jumper
`construction may be located near terminal connector pads, and, therefore,
`discloses the identified portion of trace 122a “is connected to one of the
`terminal connector pads 40 constituting the first electrode pad.” Id. at 55.
`Petitioner makes a similar assertion that the portion of the trace 122b
`identified as the seventh line is connected to one of the terminal connector
`pads constituting the third electrode pad. Id. at 57. Petitioner’s expert
`repeats the same assertions in his testimony. See Ex. 1007 ¶¶ 169, 172.
`
`Patent Owner contends Pro fails to disclose the “third” and “seventh”
`lines that connect to “first” and “third” electrode pads respectively. Prelim.
`Resp. 17. Patent Owner argues that Petitioner assumes the two identified
`
`16
`
`
`
`
`
`
`
`
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`lines connect to “terminal connector pads 40,” but Pro “never actually
`explains how the jumper constructions set forth in Figure 2A is connected to
`terminals.” Id. at 17–18. Patent Owner asserts that Petitioner is not relying
`on actual disclosure in Pro, but rather has made assumptions regarding how
`different components could be attached to the jumper shown in Figure 2A.
`Id. at 18.
`
`We have reviewed Petitioner’s analysis and evidence and determine
`Petitioner fails to establish Pro discloses the claimed “third” and “seventh”
`lines connected to first and third electrode pads, respectively. Petitioner’s
`assertion that traces 122a, 122b connect to terminal connector pads 40 is not
`supported by the cited Figure. See Ex. 1005, Fig. 2A. Pro does describe that
`in some embodiments, the jumper construction illustrated in Figure 2A is
`located proximate to one of the terminal connector pads 40. Id. at 3:52–54.
`But, Pro does not describe that it is traces 122a, 122b that connect to
`terminal pad 40, let alone that the specific portions of these traces identified
`by Petitioner as the third and seventh lines have such a connection.2
`Moreover, Pro’s description that the jumper connection may be proximate to
`one of the terminal connector pads does not support Petitioner’s position that
`traces 122a, 122b (third and seventh lines) connect to different terminal pads
`(first and third electrode pads).
`Accordingly, for the foregoing reasons, we conclude Petitioner has
`not demonstrated a reasonable likelihood of prevailing in establishing claims
`1–4 and 6 are anticipated by Pro.
`
`
`2 Petitioner identifies different portions of traces 122a, 122b as the claimed
`first line and fifth line, respectively. Pet. 51, 53.
`
`17
`
`
`
`IPR2017-01499
`Patent 7,923,644
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`III. ORDER
`In view of the foregoing, it is:
`ORDERED that Petitioner’s request for inter partes review of claims
`1–4 and 6 of U.S. Patent 7,923,644 is denied.
`
`
`
`
`PETITIONER:
`
`Jennifer Hayes
`Daniel J. Burnham
`Nixon Peabody LLP
`jenhayes@nixonpeabody.com
`dburnham@nixonpeabody.com
`
`
`PATENT OWNER:
`
`Alex V. Chachkes
`Don Daybell
`Orrick, Herrington & Sutcliffe LLP
`A34PTABDocket@orrick.com
`D2DPTABDocket@orrick.com
`
`18
`
`