Trials@uspto.gov
`571-272-7822
`
`
`
`
`
`
`
`
`
`
`
` Paper 12
`
`
`
` Entered: June 1, 2018
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`IAC SEARCH & MEDIA, INC.,
`Petitioner,
`
`v.
`
`MYMAIL, LTD.,
`Patent Owner.
`____________
`
`Case IPR2018-00118
`Patent 8,275,863 B2
`____________
`
`
`
`Before KEVIN F. TURNER, KAMRAN JIVANI, and
`MONICA S. ULLAGADDI, Administrative Patent Judges.
`
`ULLAGADDI, Administrative Patent Judge.
`
`
`
`
`DECISION
`Denying Institution of Inter Partes Review
`35 U.S.C. § 314
`
`
`
`
`
`
`571-272-7822
`
`
`
`
`
`
`
`
`
`
`
` Paper 12
`
`
`
` Entered: June 1, 2018
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`IAC SEARCH & MEDIA, INC.,
`Petitioner,
`
`v.
`
`MYMAIL, LTD.,
`Patent Owner.
`____________
`
`Case IPR2018-00118
`Patent 8,275,863 B2
`____________
`
`
`
`Before KEVIN F. TURNER, KAMRAN JIVANI, and
`MONICA S. ULLAGADDI, Administrative Patent Judges.
`
`ULLAGADDI, Administrative Patent Judge.
`
`
`
`
`DECISION
`Denying Institution of Inter Partes Review
`35 U.S.C. § 314
`
`
`
`
`
`
`
`IPR2018-00118
`Patent 8,275,863 B2
`
`
`I.
`
`INTRODUCTION
`
`A. Background
`
`IAC Search and Media, Inc. (“Petitioner”) filed a Petition (Paper 1,
`
`“Pet.”) for inter partes review of claims 1–5, 7–20, 22, and 23 (“the
`
`challenged claims”) of U.S. Patent No. 8,275,863 B2 (Ex. 1001, “the ’863
`
`patent”). Mymail, Ltd. (“Patent Owner”) timely filed a Preliminary
`
`Response (Paper 7, “Prelim. Resp.”).
`
`Pursuant to 35 U.S.C. § 314(a), an inter partes review may not be
`
`instituted “unless . . . there is a reasonable likelihood that the petitioner
`
`would prevail with respect to at least 1 of the claims challenged in the
`
`petition.”
`
`Upon consideration of the Petition, the Petition’s supporting evidence,
`
`as well as Patent Owner’s Preliminary Response and supporting evidence,
`
`we are not persuaded Petitioner has established a reasonable likelihood that
`
`it would prevail with respect to at least one of the challenged claims.
`
`Accordingly, for the reasons that follow, we do not institute an inter partes
`
`review of the ’863 patent as to the challenged claims.
`
`B. Related Proceedings
`
`Petitioner informs us that the ’863 patent is asserted in the following
`
`pending litigations: MyMail, Ltd. v. Yahoo!, Inc., Case No. 2-16-cv-01000
`
`(E.D. Tex.), filed September 7, 2016 (“Yahoo! litigation”); MyMail, Ltd. v.
`
`ooVoo LLC, Case No. 5:17-cv-04487 (N.D. Cal.); MyMail, Ltd. v. IAC
`
`Search & Media, Inc., Case No. 3:17-cv-04488 (N.D. Cal.); and MyMail,
`
`Ltd. v. Yahoo Holdings, Inc., Case No. 3-17-cv-03098 (E.D. Tex.). Pet. 1
`
`2
`
`
`
`IPR2018-00118
`Patent 8,275,863 B2
`
`(citing Exs. 1002–1004, 1028).
`
`Exhibit 1003 is a complaint for infringement in MyMail, Ltd. v. ooVoo
`
`LLC, Case No. 2-16-cv-01281 (E.D. Tex.), filed November 18, 2016.
`
`Exhibit 1004 is a complaint for infringement in MyMail, Ltd. v. IAC Search
`
`& Media, Inc., Case No. 2-16-cv-01434 (E.D. Tex.), filed December 20,
`
`2016.
`
`Patent Owner informs us the ’863 patent was also asserted in the
`
`following litigations: MyMail, Ltd. v. ESPN, Inc., Case No. 2-17-cv-00200
`
`(E.D. Tex.), filed March 14, 2017, terminated June 6, 2017; MyMail, Ltd. v.
`
`Duck Duck Go, Inc., Case No. 2-16-cv-01474 (E.D. Tex.), filed December
`
`29, 2016, terminated January 31, 2017; MyMail, Ltd. v. Panda Distribution,
`
`Inc., Case No. 2-16-cv-01282 (E.D. Tex.), filed November 18, 2016,
`
`terminated April 21, 2017; MyMail, Ltd. v. Comcast Corp., Case No. 2-16-
`
`cv-01280 (E.D. Tex.), filed November 18, 2016, terminated October 24,
`
`2017; MyMail, Ltd. v. Oracle Corp., Case No. 2-16-cv-01249 (E.D. Tex.),
`
`filed November 9, 2016, terminated December 21, 2016; MyMail, Ltd. v.
`
`Nasdaq, Inc., Case No. 2-16-cv-00889 (E.D. Tex.), filed August 10, 2016,
`
`terminated December 19, 2016; and MyMail, Ltd. v. Conduit Ltd., Case No.
`
`2-13-cv-00961 (E.D. Tex.), filed November 14, 2013, terminated January 8,
`
`2016. Paper 5, 1–2.
`
`Petitioner further informs us that it filed concurrently a petition for
`
`inter parties review of a child to the ’863 patent, U.S. Patent No. 9,021,070
`
`in the IPR2018-00117 proceeding. Pet. 1. The ’863 patent is also the
`
`subject of the IPR2017-00967 proceeding, which is presently pending. The
`
`’863 patent was also the subject of IPR2015-00269, which was terminated
`
`3
`
`
`
`IPR2018-00118
`Patent 8,275,863 B2
`
`after institution.
`
`C. The ’863 Patent
`
`The ’863 patent relates to modifying a toolbar. Ex. 1001, [54].
`
`Figure 16 is reproduced below:
`
`
`
`Figure 16 of the ’863 patent illustrates a toolbar
`
`According to the ’863 patent, information related to updating the toolbar is
`
`obtained from button bar database 208, included in user (computer) 110, that
`
`stores attributes of the toolbar including: a button title or name; an attribute
`
`that enables or disables the function associated with a button; an execution
`
`type for the button; a hint that describes the functionality of the button; and
`
`an attribute that specifies a file to be executed or uniform resource locator
`
`(URL) to be opened when the button is actuated. Id. at 9:20–23, 10:38–62.
`
`A button can be configured, for example, to “go to the USA Today . . . web
`
`site.” Id. at 10:63–11:4. The ’863 patent further discloses how button bar
`
`database 208 and an MOT1 script are used to build a button bar or toolbar
`
`according to the specifications of the MOT script. Id. at 11:10–13. The
`
`’863 patent also discloses a Pinger process that dynamically changes or
`
`
`
`1 The ’863 patent discloses that “MOT is not, however, an acronym for
`anything meaningful.” Ex. 1001, 12:50–51.
`4
`
`
`
`IPR2018-00118
`Patent 8,275,863 B2
`
`updates a toolbar via database updates to user (computer) 110. Id. at 10:15–
`
`32.
`
`D. Illustrative Claim
`
`As noted above, Petitioner challenges claims 1–5, 7–20, 22, and 23 of
`
`the ’863 patent, of which claim 1 is independent. Claim 1 is representative:
`
`1. A method of modifying a toolbar, comprising the steps
`
`of:
`
`a user Internet device displaying a toolbar comprising one
`or more buttons, the toolbar defined by toolbar data stored in one
`or more toolbar-defining databases, the toolbar data comprising
`a plurality of attributes, each attribute associated with a button of
`the toolbar, wherein for each button of the toolbar, at least one of
`the plurality of attributes identifying a function to be performed
`when the button is actuated by the user Internet device;
`
`the user Internet device automatically sending a revision
`level of the one or more toolbar-defining databases to a
`predetermined network address;
`
`the predetermined network address
`server at
`a
`determining, from the revision level, the user Internet device
`should receive the toolbar update data;
`
`the user Internet device receiving toolbar update data from
`the Internet;
`
`the user Internet device initiating without user interaction
`an operation to update the toolbar data in accordance with the
`toolbar update data received;
`
`the user Internet device updating, by the operation, the
`toolbar data in accordance with the toolbar update data, thereby
`producing updated toolbar data, the updating comprising at least
`one of the following steps (a) and (b), each respectively
`comprising:
`
`(a) writing at least one new attribute to the original toolbar
`data, wherein the writing at least one new attribute to the toolbar
`5
`
`
`
`IPR2018-00118
`Patent 8,275,863 B2
`
`
`data comprises changing the one or more buttons of the toolbar
`by adding a button; and
`
`(b) updating at least one attribute of the toolbar data; and
`
`the user Internet device displaying the toolbar as defined
`by the updated toolbar data.
`
`E. The Evidence of Record
`
`Petitioner relies upon the following references, as well as the
`
`Declaration of Dr. Benjamin Goldberg (Ex. 1009):
`
`Reference
`U.S. Patent No. 5,740,549 (“Reilly”)
`
`Dave Raggett, “HTML 3.2 Reference
`Specification: W3C Working Draft” available
`at https://www.w3.org/TR/WD-html32-
`960909 (“HTML 3.2”)
`John December et al., “The World Wide Web
`1996 Unleased,” 2nd Ed., Sams.net Publishing
`(“December”)
`Melissa J. Perenson, “New and Improved:
`News of Announced Products and Upgrades–
`Hot Prospect: Desktop Delivery of Web
`Pages,” PC Magazine, Vol. 15, No. 10, p. 75
`(“Perenson”)
`Edward Mendelson, “Web Browser Add-Ons:
`Off-line Readers Deliver the World of the Web
`to Your Hard Disk,” PC Magazine, Vol. 15,
`No. 14, pp. 43–44 (“Mendelson-1”)
`Edward Mendelson, “The 1997 Utility Guide
`internet Off-line browsers,” PC Magazine,
`Vol. 16, No. 7, pp. 207–216, 218
`(“Mendelson-2”)
`U.S. Patent No. 6,151,643 (“Cheng”)
`
`6
`
`Date
`filed June 12,
`1995; issued
`April 14, 1998
`September 1996
`
`Exhibit
`1013
`
`1014
`
`1996
`
`1016
`
`May 1996
`
`1017
`
`August 1996
`
`1018
`
`April 1997
`
`1019
`
`filed June 7,
`
`1022
`
`
`
`IPR2018-00118
`Patent 8,275,863 B2
`
`
`Reference
`
`Osel, et al., “OpenDist - Incremental Software
`Distribution,” USENIX 9th Sys. Admin.
`Conf., pp. 181–94 (“Osel”)
`Sankar, “Internet Explorer Plug-in and
`ActiveX Companion,”
`QUE Corp., pp. 1, 8–17, 19–35, 173–230
`(“Sankar”)
`
`Date
`1996; issued
`Nov. 21, 2000
`September 1995
`
`Exhibit
`
`1023
`
`1997
`
`1027
`
`Petitioner asserts unpatentability of the challenged claims of the ’863
`
`patent based on the following grounds (Pet. 29):
`
`Reference(s)
`
`Reilly
`
`Reilly and the Browser-based
`Toolbar References2
`Reilly and HTML 3.2 and/or
`Sankar
`Reilly and the Script
`References3
`
`Basis
`§ 103
`
`§ 103
`
`Claim(s) Challenged
`1, 3, 5, 9–11, 14–20, and
`23
`2
`
`§ 103
`
`4, 7, 8, 10, and 22
`
`§ 103
`
`12 and 13
`
`
`
`2 Petitioner collectively refers to HTML 3.2 (Ex. 1014), December (Ex.
`1016), Perenson (Ex. 1017), Mendelson-1 (Ex. 1018), Mendelson-2 (Ex.
`1019), and Sankar (Ex. 1027) as “the Browser-based Toolbar References.”
`See Pet. 16–24.
`3 Petitioner collectively refers to Cheng (Ex. 1022) and Osel (Ex. 1023) as
`“the Script References.” See Pet. 25–29.
`7
`
`
`
`IPR2018-00118
`Patent 8,275,863 B2
`
`
`II. DISCUSSION
`
`A. Claim Construction
`
`Both parties agree that the ’863 patent is set to expire in June of 2018.
`
`Pet. 8; Prelim. Resp. 4 (asserting that “[t]he ’863 patent is set to expire
`
`within 18 months from the entry of the Notice of Filing Date Accorded to
`
`Petition”). Pursuant to 37 C.F.R. § 42.100(b), Patent Owner filed a motion
`
`requesting application of a district court-type claim construction under the
`
`standard provided by Phillips v. AWH Corp., 415 F.3d 1303, 1312‒17 (Fed.
`
`Cir. 2005) (en banc). Paper 6 (Patent Owner’s Motion for District Court
`
`(Phillips) Claim Construction under 37 C.F.R. § 42.100(b)); see In re
`
`Rambus, Inc., 694 F.3d 42, 46 (Fed. Cir. 2012) (explaining that for claims of
`
`an expired patent, the Board’s claim interpretation is similar to that of a
`
`district court). As the ’863 patent will expire prior to the issuance of a final
`
`written decision in the present proceeding, we agree that interpreting the
`
`claims under a Phillips construction is appropriate, and grant Patent Owner’s
`
`motion. “In determining the meaning of the disputed claim limitation, we
`
`look principally to the intrinsic evidence of record, examining the claim
`
`language itself, the written description, and the prosecution history, if in
`
`evidence.” DePuy Spine, Inc. v. Medtronic Sofamor Danek, Inc., 469 F.3d
`
`1005, 1014 (Fed. Cir. 2006) (citing Phillips, 415 F.3d at 1312‒17). The
`
`words of a claim generally are given their ordinary and customary meaning,
`
`and that is the meaning the terms would have had to a person of ordinary
`
`skill at the time of the invention, in the context of the entire patent, including
`
`the specification. See Phillips, 415 F.3d at 1312–13.
`
`8
`
`
`
`IPR2018-00118
`Patent 8,275,863 B2
`
`
`Petitioner argues that we should construe the claim term “toolbar” to
`
`mean “[a]ny arrangement of user controls to activate functions in an
`
`application.” Pet. 8. Petitioner acknowledges a claim construction order
`
`entered in the co-pending Yahoo! litigation (id. at 9) in which the district
`
`court construed “toolbar” to mean a “button bar that can be dynamically
`
`changed or updated via a Pinger process or a MOT script” (Ex. 1012, 16).
`
`In reaching this construction, the district court relied principally on the
`
`disclosure in the ’863 patent that “[t]he Toolbar of the present invention has
`
`some unique properties as it can be dynamically changed or updated via a
`
`Pinger process or a MOT script” and that “in the description of exemplary
`
`embodiments, the toolbar always has this ability.” Ex. 1012, 14 (quoting Ex.
`
`1001, 10:16–26) (emphasis ours).
`
`Petitioner, however, asserts that its construction for “toolbar” should
`
`be adopted instead of the district court’s construction because, in its
`
`prosecution history, Patent Owner assigned express constructions to certain
`
`terms, including “toolbar.” Pet. 9. Petitioner further notes that the district
`
`court’s claim construction order “does not acknowledge the definitions
`
`provided during prosecution of the ’863 patent.” Id. During prosecution of
`
`the application underlying the ’863 patent, Patent Owner submitted
`
`definitions for certain claim terms, including toolbar:
`
`Page 428 gives a definition of the term “toolbar.” That
`definition is: “A row or column of on-screen buttons used to
`activate functions in the application. Some toolbars are
`customizable, letting you add and delete buttons as required. See
`tool palette.” (Emphasis in original). This definition is generally
`consistent with the meaning Applicant intends to give “toolbar”
`in the application, including the claims. However, Applicant
`
`9
`
`
`
`IPR2018-00118
`Patent 8,275,863 B2
`
`
`does not intend “toolbar” to be limited to a “row” or “column”
`of buttons. Applicant instead intends “toolbar” to comprise
`buttons in any other arrangement, such as, for example and
`without limitation, multiple rows or columns, one or more circles
`of buttons, adjoined and/or separate buttons, stationary or
`moving buttons, and/or buttons arranged in irregular and/or
`regular shapes. Further, Applicant intends “toolbar” as used in
`the application, including the claims, to not be limited to on-
`screen buttons. Accordingly, a “toolbar” could also comprise,
`for example and without limitation, other possibilities for
`activating functions in the application which might not ordinarily
`be referred to as “buttons,” such as, for example and without
`limitation, temporarily or intermittently displayed buttons and
`text boxes.
`
`Ex. 1007, 1075–76.
`
`
`
`Patent Owner contends “toolbar” should be construed in accordance
`
`with the district court’s claim construction. Prelim. Resp. 5. With respect to
`
`the definitions submitted during prosecution, Patent Owner argues that
`
`[N]one of these statements . . . are incompatible with the
`construction determined by the district court. In particular,
`Applicant’s statements above relate to the arrangement or
`appearance of the toolbar. These statements do not address the
`modification or update process for the toolbar and cannot
`simply replace other requirements set forth in the ’863 patent
`specification without clear intention to do so. See, e.g., Phillips,
`415 F.3d at 1317 (“because the prosecution history represents an
`ongoing negotiation between the PTO and the applicant, rather
`than the final product of that negotiation, it often lacks the clarity
`of the specification and thus is less useful for claim construction
`purposes”).
`
`Id. at 7 (emphasis added). We agree with Patent Owner, and adopt the
`
`district court’s claim construction, but with a modification as discussed
`
`below.
`
`10
`
`
`
`IPR2018-00118
`Patent 8,275,863 B2
`
`
`The district court found that “toolbar” was defined in the Specification
`
`as having “unique properties.” Ex. 1012, 14 (quoting Ex. 1001, 10:16–26)).
`
`In particular, the district court explained that the Specification required “‘the
`
`toolbar of the present invention’ [to have the] ability to be updated via a
`
`Pinger Process or a MOT script” and is described in each embodiment of the
`
`’863 patent in conjunction with the ability to be updated by a Pinger process
`
`or a MOT script and thus, was definitional. Ex. 1012, 14. In addition to this
`
`disclosure, with respect to the only toolbar depicted in the ’863 patent, in
`
`Figure 16, the ’863 patent discloses that the toolbar can be generated using
`
`MOT script language in combination with data retrieved from the databases.
`
`Ex. 1001, 26:55–58; see id. at 26:58–60; see id. at 11:5–13 (disclosing how
`
`the toolbar is built automatically according to MOT script specifications and
`
`button bar database 208 information).
`
`We agree with the district court that each embodiment disclosing a
`
`toolbar in the ’863 patent is accompanied by a disclosure indicating that the
`
`toolbar is generated or updated via a Pinger process or a MOT script.
`
`Moreover, while not dispositive in our determination, nearly every
`
`disclosure of the Pinger process and the MOT script is accompanied by a
`
`disclosure of how updating the databases, including button bar database 208,
`
`is part of its responsibilities. The ’863 patent discloses a Pinger process as:
`
`[A]n entity that acts transparently as a services coordinator to
`provide and/or administer the following:
`
`1. Heartbeat service to help maintain network connectivity with
`a client.
`
`2. Authentication services that securely authenticate client access
`to email, commerce, and other public and private network servers
`
`11
`
`
`
`IPR2018-00118
`Patent 8,275,863 B2
`
`
`and services.
`
`3. Update services that can perform client software, database,
`and maintenance services during periods of inactivity.
`
`The Pinger entity, as suggested above, has, as one of its
`functions, the responsibility of providing database updates to the
`client user.
`
`Ex. 1001, 10:19–32 (emphasis added); see id. at 11:57–60 (disclosing the
`
`functions of the Pinger process as including read, write, and update
`
`capabilities for any of the databases, including button bar database 208); see
`
`id. at 12:33–47 (disclosing how a Pinger process allows the download of
`
`database updates to user (computer) 110). The ’863 patent discloses the
`
`MOT script as “a ‘mime type’ definition part of an E-mail message, an
`
`HTTP web document download . . . which transparently automates the
`
`Toolbar update,” and as “defin[ing] how to build a button bar using the
`
`button bar database 208 and its database entries.” Id. at 10:32–35, 11:5–7
`
`(emphasis added); see id. at 11:5–13.
`
`Because the ’863 patent discloses that a toolbar is necessarily
`
`generated and updated based on button bar database 208 and updates thereto,
`
`we determine that the disclosed toolbar is indirectly generated or updated via
`
`a Pinger process or MOT script. As such, we further determine that the ’863
`
`patent defines “toolbar” as a button bar that can be generated, dynamically
`
`changed, or dynamically updated via a Pinger process or a MOT script.
`
`We are not persuaded by Petitioner’s argument that Patent Owner’s
`
`statements made during prosecution supersede the definition for “toolbar”
`
`set forth in the ’863 patent. During prosecution, Patent Owner asserted that
`
`buttons of a toolbar could be arranged in “multiple rows or columns, one or
`
`12
`
`
`
`IPR2018-00118
`Patent 8,275,863 B2
`
`more circles of buttons, adjoined and/or separate buttons, stationary or
`
`moving buttons, and/or buttons arranged in irregular and/or regular shapes.”
`
`Ex. 1007, 1075–76. Patent Owner further asserted that the toolbar is “not
`
`limited to on-screen buttons” and made statements with respect to the length
`
`of display of the toolbar. Id. at 1076. Patent Owner’s statements during
`
`prosecution relate to the visual appearance of the buttons, specifically, their
`
`geometry, spatial arrangement, and display. See id. at 1075–76. Thus, we
`
`determine that Patent Owner’s statements define a different aspect of the
`
`toolbar that is not mutually exclusive with respect to the definition set forth
`
`in the ’863 patent. More particularly, the geometry, arrangement, and
`
`display of buttons in the toolbar argued by Patent Owner does not conflict
`
`with the definition set forth in the ’863 patent.
`
`For the foregoing reasons, we determine that “toolbar” should be
`
`construed as “a button bar that can be generated, dynamically changed, or
`
`dynamically updated via a Pinger process or a MOT script.” Although our
`
`construction differs from the district court’s construction with the addition of
`
`“generating,” even if we apply the district court’s construction of “toolbar”
`
`we determine that Petitioner fails to demonstrate a reasonable likelihood of
`
`prevailing with respect to any of the challenged claims.
`
`B. Challenges Applying Reilly
`
`In its Petition, Petitioner bases each of its challenges on Reilly (Ex.
`
`1013). See Pet. 31–86. Petitioner relies on Reilly for teaching the toolbar.
`
`However, Petitioner does not address how Reilly’s toolbar “can be
`
`generated, dynamically changed, or dynamically updated via a Pinger
`
`13
`
`
`
`IPR2018-00118
`Patent 8,275,863 B2
`
`process or a MOT script,” in accordance with the construction for “toolbar”
`
`set forth above in Section II.A. See generally Pet. Petitioner’s stated
`
`position does not rely on the secondary references, i.e., the references
`
`comprising the Browser-based Toolbar References and the Script
`
`References, to cure this deficiency of Reilly. See id. On this basis, we are
`
`not persuaded that Petitioner has established a reasonable likelihood it would
`
`prevail with respect to at least one of the challenged claims based on the
`
`challenges relying on Reilly.
`
`C. Summary
`
`For the foregoing reasons, on this record, we determine Petitioner
`
`does not establish sufficiently that the claimed “toolbar” recited in
`
`independent claim 1 is disclosed or suggested by the cited references.
`
`III. CONCLUSION
`
`For the foregoing reasons, we determine that Petitioner has not
`
`demonstrated a reasonable likelihood it would prevail in establishing the
`
`unpatentability of challenged claims 1–5, 7–20, 22, and 23 of ’863 patent.
`
`Accordingly, we decline to institute an inter partes review of the challenged
`
`claims of the ’863 patent.
`
`In consideration of the foregoing, it is
`
`IV. ORDER
`
`ORDERED that the petition for inter partes review is denied and no
`
`trial is instituted.
`
`
`
`14
`
`
`
`IPR2018-00118
`Patent 8,275,863 B2
`
`PETITIONER:
`
`Robert Hails
`T Cy Walker
`BAKER HOSTETLER LLC
`rhails@bakerlaw.com
`cwalker@bakerlaw.com
`
`
`
`PATENT OWNER:
`Jon Wright
`Daniel S. Block
`Steven M. Pappas
`STERNE KESSLER GOLDSTEIN FOX P.L.L.C.
`jwright-ptab@sternekessler.com
`dblock-ptab@sternekessler.com
`spappas-ptab@sternekessler.com
`
`
`
`15
`
`
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