Trials@uspto.gov
`571-272-7822
`
`
`
`
`Paper 12
`Entered: September 25, 2018
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`GOOGLE LLC,
`Petitioner,
`
`v.
`
`SEVEN NETWORKS, LLC,
`Patent Owner.
`_______________
`
`IPR2018-01047 and IPR2018-01048 (Patent 9,516,129)
`IPR2018-01049 and IPR2018-01101 (Patent 9,553,816)
`IPR2018-01051 and IPR2018-01052 (Patent 9,516,127)
`IPR2018-01094 and IPR2018-01095 (Patent 9,444,812)
`IPR2018-01116 and IPR2018-01117 (Patent 9,351,254)
`IPR2018-01102 (Patent 8,811,952)1
`____________
`
`
`Before THU A. DANG, KARL D. EASTHOM, JONI Y. CHANG,
`THOMAS L. GIANNETTI, ROBERT J. WEINSCHENK, and
`JACQUELINE T. HARLOW, Administrative Patent Judges.2
`
`CHANG, Administrative Patent Judge.
`
`
`ORDER
`Conduct of Proceeding
`37 C.F.R. § 42.5
`
`
`
`
`1 This Order applies to each of the above-listed proceedings. We exercise
`our discretion to issue one Order to be filed in each proceeding. The parties
`are not authorized to use this heading style in any subsequent papers.
`2 This is not an expanded panel of the Board. It is a listing of all the Judges
`on the panels of the above-listed proceedings.
`
`
`571-272-7822
`
`
`
`
`Paper 12
`Entered: September 25, 2018
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`GOOGLE LLC,
`Petitioner,
`
`v.
`
`SEVEN NETWORKS, LLC,
`Patent Owner.
`_______________
`
`IPR2018-01047 and IPR2018-01048 (Patent 9,516,129)
`IPR2018-01049 and IPR2018-01101 (Patent 9,553,816)
`IPR2018-01051 and IPR2018-01052 (Patent 9,516,127)
`IPR2018-01094 and IPR2018-01095 (Patent 9,444,812)
`IPR2018-01116 and IPR2018-01117 (Patent 9,351,254)
`IPR2018-01102 (Patent 8,811,952)1
`____________
`
`
`Before THU A. DANG, KARL D. EASTHOM, JONI Y. CHANG,
`THOMAS L. GIANNETTI, ROBERT J. WEINSCHENK, and
`JACQUELINE T. HARLOW, Administrative Patent Judges.2
`
`CHANG, Administrative Patent Judge.
`
`
`ORDER
`Conduct of Proceeding
`37 C.F.R. § 42.5
`
`
`
`
`1 This Order applies to each of the above-listed proceedings. We exercise
`our discretion to issue one Order to be filed in each proceeding. The parties
`are not authorized to use this heading style in any subsequent papers.
`2 This is not an expanded panel of the Board. It is a listing of all the Judges
`on the panels of the above-listed proceedings.
`
`
`
`IPR2018-01047 and IPR2018-01048 (Patent 9,516,129)
`IPR2018-01049 and IPR2018-01101 (Patent 9,553,816)
`IPR2018-01051 and IPR2018-01052 (Patent 9,516,127)
`IPR2018-01094 and IPR2018-01095 (Patent 9,444,812)
`IPR2018-01116 and IPR2018-01117 (Patent 9,351,254)
`IPR2018-01102 (Patent 8,811,952)
`
`
`I. INTRODUCTION
`On September 24, 2018, Judges Dang, Easthom, Chang, Giannetti,
`Weinschenk, and Harlow held a conference call with counsel for Google
`LLC (“Petitioner”) and counsel for SEVEN Networks, LLC (“Patent
`Owner”). A court reporter was present on the conference call. This order
`summarizes statements made during the conference call. A more complete
`record may be found in the court reporter’s transcript.3
`In its Petition (Paper 24, “Pet.”), Petitioner identifies Google LLC as
`the sole real party in interest. Pet. 68. Patent Owner filed a Preliminary
`Response (Paper 10, “Prelim. Resp.”) in each of the above-identified
`proceedings, except in Cases IPR2018-01094 and IPR2018-01095. In its
`Preliminary Responses, Patent Owner argues that Petitioner failed to identify
`all real parties in interest, namely Alphabet, Inc. and XXVI Holdings, Inc.
`(collectively, “Google’s parent companies”) as well as Samsung Electronics
`Co., Ltd. and/or Samsung Electronics America, Inc. (collectively,
`“Samsung”). Prelim. Resp. 13−38. According to Patent Owner, the failure
`to identify all real parties in interest “requires denial of the petition when the
`§ 315(b) bar has elapsed.” Id. at 14.
`The purpose of the conference call, requested by the Board, was to
`discuss the real party in interest issues raised by Patent Owner, and a few
`
`
`3 We authorize Petitioner to file the court reporter’s transcript as an exhibit
`in each of the above-identified proceedings.
`4 We cite to the record in IPR2018-01047, unless otherwise noted.
`
`2
`
`
`
`IPR2018-01047 and IPR2018-01048 (Patent 9,516,129)
`IPR2018-01049 and IPR2018-01101 (Patent 9,553,816)
`IPR2018-01051 and IPR2018-01052 (Patent 9,516,127)
`IPR2018-01094 and IPR2018-01095 (Patent 9,444,812)
`IPR2018-01116 and IPR2018-01117 (Patent 9,351,254)
`IPR2018-01102 (Patent 8,811,952)
`
`other procedural matters. During the conference call, Petitioner requested
`authorization to file a reply to address Patent Owner’s real party in interest
`arguments and Patent Owner requested authorization to file a sur-reply.
`Upon consideration of the totality of the circumstances, we grant both
`parties’ requests as set forth below.
`
`II. DISCUSSION
`Petitioner is Required to Identify all Real Parties in Interest
`
`Under 35 U.S.C. § 312(a)(2), a petitioner is required to identify all of
`the real parties in interest in each proceeding. The identification of real
`parties in interest must be submitted in the mandatory notices in accordance
`with 37 C.F.R. § 42.8(b)(1).
`We generally accept a petitioner’s initial identification of real parties
`in interest unless the patent owner presents some evidence to support that an
`unnamed party should be included as a real party in interest. See Worlds
`Inc. v. Bungie, Inc., No. 2017-1481, 2018 WL 4262564, at *3 (Fed. Cir.
`Sept. 7, 2018) (explaining that “an IPR petitioner’s initial identification of
`the real parties in interest should be accepted unless and until disputed by a
`patent owner,” and that “a patent owner must produce some evidence to
`support its argument that a particular third party should be named a real
`party in interest”). Furthermore, the petitioner bears the burden of
`persuasion to demonstrate that it actually has identified all of the real parties
`in interest. Cf. id. at *3−4. This burden does not shift to the patent owner.
`Id. at *4−5.
`
`3
`
`
`
`IPR2018-01047 and IPR2018-01048 (Patent 9,516,129)
`IPR2018-01049 and IPR2018-01101 (Patent 9,553,816)
`IPR2018-01051 and IPR2018-01052 (Patent 9,516,127)
`IPR2018-01094 and IPR2018-01095 (Patent 9,444,812)
`IPR2018-01116 and IPR2018-01117 (Patent 9,351,254)
`IPR2018-01102 (Patent 8,811,952)
`
`
`Patent Owner is Conflating § 312(a)(2) with § 315(b)
`
`Here, Patent Owner’s arguments incorrectly conflate § 312(a)(2) with
`§ 315(b) by applying § 312(a)(2) as part of the timeliness inquiry under
`§ 315(b). Prelim. Resp. 13−38. These statutory provisions “entail distinct,
`independent inquiries.” Applications in Internet Time, LLC v. RPX Corp.,
`897 F.3d 1336, 1364 (Fed. Cir. 2018) (Judge Reyna’s concurring opinion).
`As the U.S. Court of Appeals for the Federal Circuit has noted, it “is
`incorrect” to “conflate[] ‘real party in interest’ as used in § 312(a)(2) and
`§ 315(b), and claim[] that ‘§ 312(a)(2) is part and parcel of the timeliness
`inquiry under § 315.’” Wi-Fi One, LLC v. Broadcom Corp., 878 F.3d 1364,
`1374 n.9 (Fed. Cir. 2018) (en banc). “For example, if a petition fails to
`identify all real parties in interest under § 312(a)(2), the Director can, and
`does, allow the petitioner to add a real party in interest.” Id. (noting the
`following cases as examples: Intel Corp. v. Alacritech, Inc., Case
`IPR2017-01392, slip op. at 23 (PTAB Nov. 30, 2017) (Paper 11); Elekta,
`Inc. v. Varian Med. Sys., Inc. Case IPR2015-01401, slip op. at 6−10 (PTAB
`Dec. 31, 2015) (Paper 19)); see also Applications in Internet Time, 897 F.3d
`at 1364 (Fed. Cir. 2018) (Judge Reyna’s concurring opinion) (explaining
`that “Section 312(a)(2) is akin to a pleading requirement that can be
`corrected”). “In contrast, if a petition is not filed within a year after a real
`party in interest, or privy of the petitioner is served with a complaint, it is
`time-barred by § 315(b), and the petition cannot be rectified and in no event
`can IPR be instituted.” Wi-Fi One, 878 F.3d at 1374 n.9.
`
`4
`
`
`
`IPR2018-01047 and IPR2018-01048 (Patent 9,516,129)
`IPR2018-01049 and IPR2018-01101 (Patent 9,553,816)
`IPR2018-01051 and IPR2018-01052 (Patent 9,516,127)
`IPR2018-01094 and IPR2018-01095 (Patent 9,444,812)
`IPR2018-01116 and IPR2018-01117 (Patent 9,351,254)
`IPR2018-01102 (Patent 8,811,952)
`
`
`Here, it is undisputed that Google LLC was served on May 18, 2017,
`with a complaint alleging infringement of at least one of the challenged
`patents. Ex. 2003, 2. The petitions at issue were timely filed within one
`year from May 18, 2017. Paper 4, 1 (“The petition for inter partes review,
`filed in the above proceeding has been accorded the filing date of May 18,
`2018”). None of the allegedly unnamed real parties in interest was served
`on or before May 18, 2017, with a complaint alleging infringement of at
`least one of the challenged patents. The evidence in this record does not
`show, nor does Patent Owner argue, that Google’s parent companies or
`Samsung were served with a complaint more than one year before May 18,
`2018. Prelim. Resp. 13−38.
`Therefore, even if the allegedly unnamed parties are real parties in
`interest, the Petitions at issue would not be time-barred under § 315(b).
`
`Procedures for Rectifying Noncompliance of § 312(a)(2)
`
`The Federal Circuit also has recognized that “the PTO has established
`procedures to rectify noncompliance of § 312(a)(2).” Wi-Fi One, 878 F.3d
`at 1374 n.9 (citing Lumentum Holdings, Inc. v. Capella Photonics, Inc., Case
`IPR2015-00739, slip op. at 5 (PTAB Mar. 4, 2016) (Paper 38)
`(precedential); 37 C.F.R. §§ 42.8(a)(3), 42.8(b)(1)); see also Applications in
`Internet Time, 897 F.3d at 1364 (Fed. Cir. 2018) (Judge Reyna’s concurring
`opinion) (explaining that “Section 312(a)(2) does not act as a prohibition on
`the Director’s authority to institute”). Our precedential decision in
`Lumentum Holdings, indicates that “a lapse of compliance with those
`
`5
`
`
`
`IPR2018-01047 and IPR2018-01048 (Patent 9,516,129)
`IPR2018-01049 and IPR2018-01101 (Patent 9,553,816)
`IPR2018-01051 and IPR2018-01052 (Patent 9,516,127)
`IPR2018-01094 and IPR2018-01095 (Patent 9,444,812)
`IPR2018-01116 and IPR2018-01117 (Patent 9,351,254)
`IPR2018-01102 (Patent 8,811,952)
`
`requirements [under § 312(a), including that all real parties in interest be
`identified] does not deprive the Board of jurisdiction over the proceeding, or
`preclude the Board from permitting such lapse to be rectified.” Case
`IPR2015-00739, slip op. at 5; see also Intel, Case IPR2017-01392, slip op.
`at 23 (noting that real parties in interest can be corrected); Elekta, Case
`IPR2015-01401, slip op. at 6−10 (holding that disclosing additional real
`parties in interest via an updated disclosure does not mandate a change in
`petition’s original filing date). Furthermore, our policy is to “secure the just,
`speedy, and inexpensive resolution of every proceeding.” 37 C.F.R. § 42.1.
`To that end, we authorize Petitioner to add by October 5, 2018, some
`or all of the allegedly unnamed parties (Google’s parent companies and
`Samsung) as real parties in interest in its mandatory notices for the instant
`proceedings. Such corrected mandatory notices, if timely filed, will not
`change the filing dates accorded to the Petitions in the instant proceedings.
`See Fasteners for Retail, Inc. v. RTC Industries, Inc., Case IPR2018-00741,
`slip op. 2−3 (PTAB July 20, 2018) (Paper 13); Halliburton Energy Services,
`Inc. v. Schlumberger Tech. Corp., Case IPR2017-01564, slip op. 2−4 (PTAB
`Oct. 27, 2017) (Paper 13).
`Should Petitioner add less than all of the allegedly unnamed parties,
`Petitioner is authorized to file by October 5, 2018, a 15-page Reply and
`supporting evidence, in each instant proceeding in which Patent Owner filed
`a Preliminary Response, to address Patent Owner’s arguments concerning
`the allegedly unnamed parties that are not added. For example, if Petitioner
`
`6
`
`
`
`IPR2018-01047 and IPR2018-01048 (Patent 9,516,129)
`IPR2018-01049 and IPR2018-01101 (Patent 9,553,816)
`IPR2018-01051 and IPR2018-01052 (Patent 9,516,127)
`IPR2018-01094 and IPR2018-01095 (Patent 9,444,812)
`IPR2018-01116 and IPR2018-01117 (Patent 9,351,254)
`IPR2018-01102 (Patent 8,811,952)
`
`timely files a corrected mandatory notice adding Google’s parent companies,
`but not Samsung, Petitioner is authorized to file a 15-page Reply to address
`Patent Owner’s real party in interest arguments regarding Samsung (Prelim.
`Resp. 34−38). However, if Petitioner timely files a corrected mandatory
`notice adding both Google’s parent companies and Samsung, it will not be
`necessary for Petitioner to file a Reply.
`If Petitioner files a Reply in an instant proceeding, Patent Owner is
`authorized to file a 7-page Sur-reply in that proceeding, within five business
`days of the filing of Petitioner Reply. However, Patent Owner is not
`authorized to file evidence with the Sur-reply.
`At this time, we do not decide, on the merits, the issue of whether the
`allegedly unnamed parties are real parties in interest. That is, this Order
`shall not be construed as a finding that any of the allegedly unnamed parties
`are real parties in interest in these proceedings.
`
`Other Procedural Matters
`
`1
`As discussed above, Patent Owner filed a Preliminary Response in
`each of the above-identified proceedings, except in Cases IPR2018-01094
`and IPR2018-01095. During the conference call, upon inquiry, Patent
`Owner explained that it has filed disclaimers of all of the claims challenged
`in these two cases with another organization of the Office, but not with the
`Board. For clarity of our records here, we required Patent Owner to file a
`
`7
`
`
`
`IPR2018-01047 and IPR2018-01048 (Patent 9,516,129)
`IPR2018-01049 and IPR2018-01101 (Patent 9,553,816)
`IPR2018-01051 and IPR2018-01052 (Patent 9,516,127)
`IPR2018-01094 and IPR2018-01095 (Patent 9,444,812)
`IPR2018-01116 and IPR2018-01117 (Patent 9,351,254)
`IPR2018-01102 (Patent 8,811,952)
`
`copy of the disclaimer in each of Cases IPR2018-01094 and IPR2018-
`01095, within five business days of the call.
`2
`Under 37 C.F.R. § 42.14, “[a] party intending a document or thing to
`be sealed shall file a motion to seal concurrent with the filing of the
`document or thing to be sealed.” In Case IPR2018-01048, Patent Owner
`filed a nonpublic version of its Preliminary Response (Paper 11), but it was
`not accompanied by a motion to seal. For clarity of the record, Patent
`Owner is authorized to file, within 5 business days of this Order, a motion to
`seal the nonpublic version of its Preliminary Response (Paper 11) in Case
`IPR2018-01048.
`
`3
`In Case IPR2018-01116, Patent Owner filed a Preliminary Response
`(Paper 10) and a Corrected Preliminary Response (Paper 11) on September
`7, 2018. Upon inquiry, Patent Owner indicated that it did not seek prior
`authorization to file the Corrected Preliminary Response. On this record, it
`is unclear which paper should be considered on the merits.
`During the conference call, Patent Owner requested that we consider
`the Corrected Preliminary Response (Paper 11). For clarity of the record,
`we grant Patent Owner’s request, and expunge the original Preliminary
`Response (Paper 10).
`
`4
`In Case IPR2018-01051, Petitioner takes the position that Lin, U.S.
`Patent No. 9,474,022 B2 (Ex. 1007, “Lin”), is entitled to the filing date of a
`
`8
`
`
`
`IPR2018-01047 and IPR2018-01048 (Patent 9,516,129)
`IPR2018-01049 and IPR2018-01101 (Patent 9,553,816)
`IPR2018-01051 and IPR2018-01052 (Patent 9,516,127)
`IPR2018-01094 and IPR2018-01095 (Patent 9,444,812)
`IPR2018-01116 and IPR2018-01117 (Patent 9,351,254)
`IPR2018-01102 (Patent 8,811,952)
`
`prior filed Chinese patent application 201210507375.8 (“the ’375 Chinese
`Application”). Case IPR2018-01051, Paper 2, 17−18. Petitioner asserts that
`the filing date of the ’375 Chinese Application is “November 20, 2012.” Id.
`(emphasis added). However, the front page of Lin indicates the foreign
`priority date is “November 30, 2012.” Case IPR2018-01051, Ex. 1007, at
`[30] (emphasis added). It is unclear on this record whether there is a
`typographical error in the Petition or Lin.
`In addition, Petitioner cites to Exhibits 1009, 1011, and 1013,
`allegedly included the ’375 Chinese Application. Id. However, Petitioner
`did not file a copy of Exhibits 1009 and 1011. Exhibit 1013 contains a
`Certificate of Translation and Declaration of Dr. William Ira Brown.
`Exhibit 1012 includes an English translation of Application Publication No.
`CN 103857019 A (“the ’019 Publication”), which is a publication of the
`’375 Chinese Application, not the original disclosure of the ’375 Chinese
`Application. It is also unclear on this record whether there are material
`differences between the original disclosure of the ’375 Chinese Application
`and the ’019 Publication.
`For clarity of the record and to promote efficiency, Petitioner is
`authorized to file in Case IPR2018-01051, within 5 business days of this
`Order: (1) a copy of the original disclosure of the ’375 Chinese Application;
`(2) an English translation of the original disclosure of the ’375 Chinese
`Application and an affidavit attesting to the accuracy of the translation in
`compliance with 37 C.F.R. § 42.63(b); and (3) a redline version showing the
`
`9
`
`
`
`IPR2018-01047 and IPR2018-01048 (Patent 9,516,129)
`IPR2018-01049 and IPR2018-01101 (Patent 9,553,816)
`IPR2018-01051 and IPR2018-01052 (Patent 9,516,127)
`IPR2018-01094 and IPR2018-01095 (Patent 9,444,812)
`IPR2018-01116 and IPR2018-01117 (Patent 9,351,254)
`IPR2018-01102 (Patent 8,811,952)
`
`differences between the English translation of the original disclosure of the
`’375 Chinese Application and the English translation of the ’019
`Publication.
`During the conference call, Patent Owner opposed, arguing that the
`Petition should be denied because Petitioner failed to submit the documents
`necessary to substantiate its assertion that Lin is entitled to the foreign
`priority claim. Patent Owner also alleged that Petitioner would have the
`opportunity to tailor the English translation of the ’375 Chinese Application
`to overcome Patent Owner’s arguments presented in its Preliminary
`Response. Patent Owner further argued that it would not have any
`opportunity to response.
`Patent Owner’s arguments are misplaced. At this time, we do not
`decide, on the merits, the issue of whether Lin is entitled to the foreign
`priority claim, but rather, to ensure clarity of the record and to promote
`efficiency, we simply authorize the submission of the aforementioned
`documents. As we explained during the conference call, should we
`determine to institute a trial, Patent Owner will have a complete opportunity
`to present additional new arguments and evidence with its Response. For
`example, Patent Owner may present its own English translations if it
`believes there are errors in Petitioner’s English translations. Furthermore,
`Patent Owner will have the opportunity file an objection to evidence and a
`motion to exclude under 37 C.F.R. §§ 42.64(b)(1) and 42.64(c).
`
`10
`
`
`
`IPR2018-01047 and IPR2018-01048 (Patent 9,516,129)
`IPR2018-01049 and IPR2018-01101 (Patent 9,553,816)
`IPR2018-01051 and IPR2018-01052 (Patent 9,516,127)
`IPR2018-01094 and IPR2018-01095 (Patent 9,444,812)
`IPR2018-01116 and IPR2018-01117 (Patent 9,351,254)
`IPR2018-01102 (Patent 8,811,952)
`
`
`III. ORDER
`In consideration of the foregoing, it is hereby
`ORDERED that Petitioner is authorized to add by October 5, 2018,
`some or all of the allegedly unnamed parties (Google’s parent companies
`and Samsung) as real parties in interest in its mandatory notices for all of the
`above-identified proceedings; such corrected mandatory notices, if timely
`filed, will not change the filing dates accorded to the Petitions in the instant
`proceedings;
`FURTHER ORDERED that, should Petitioner add less than all of the
`allegedly unnamed parties, Petitioner is authorized to file a 15-page Reply
`and supporting evidence by October 5, 2018, in each of the above-identified
`proceedings in which Patent Owner filed a Preliminary Response, to address
`Patent Owner’s arguments concerning the allegedly unnamed parties that are
`not added;
`FURTHER ORDERED that, within five business days of Petitioner’s
`Reply, Patent Owner is authorized to file a seven-page Sur-reply, but not
`evidence, in each of the instant proceedings in which Petitioner files a
`Reply;
`FURTHER ORDERED that, within five business days of the
`conference call held on September 24, 2018, Patent Owner is required to file
`a copy of its disclaimer of all challenged claims in each of Cases IPR2018-
`01094 and IPR2018-01095;
`
`11
`
`
`
`IPR2018-01047 and IPR2018-01048 (Patent 9,516,129)
`IPR2018-01049 and IPR2018-01101 (Patent 9,553,816)
`IPR2018-01051 and IPR2018-01052 (Patent 9,516,127)
`IPR2018-01094 and IPR2018-01095 (Patent 9,444,812)
`IPR2018-01116 and IPR2018-01117 (Patent 9,351,254)
`IPR2018-01102 (Patent 8,811,952)
`
`
`FURTHER ORDERED that, in Case IPR2018-01048, Patent Owner is
`authorized to file, within five business days of this Order, a motion to seal
`the nonpublic version of its Preliminary Response (Paper 11);
`FURTHER ORDERED that, in Case IPR2018-01116, Patent Owner’s
`request to expunge the original Preliminary Response (Paper 10), and
`maintain the Corrected Preliminary Response (Paper 11) in the record for
`consideration, is granted; and
`FURTHER ORDERED that, in Case IPR2018-01051, Petitioner is
`authorized to file, within five business days of this Order: (1) a copy of the
`original disclosure of the ’375 Chinese Application; (2) an English
`translation of the original disclosure of the ’375 Chinese Application and an
`affidavit attesting to the accuracy of the translation in compliance with 37
`C.F.R. § 42.63(b); and (3) a redline version showing the differences between
`the English translation of the original disclosure of the ’375 Chinese
`Application and the English translation of the ’019 Publication.
`
`
`
`
`
`
`12
`
`
`
`IPR2018-01047 and IPR2018-01048 (Patent 9,516,129)
`IPR2018-01049 and IPR2018-01101 (Patent 9,553,816)
`IPR2018-01051 and IPR2018-01052 (Patent 9,516,127)
`IPR2018-01094 and IPR2018-01095 (Patent 9,444,812)
`IPR2018-01116 and IPR2018-01117 (Patent 9,351,254)
`IPR2018-01102 (Patent 8,811,952)
`
`PETITIONER:
`
`Erika H. Arner
`Rachel L. Emsley
`FINNEGAN, HENDERSON, FARABOW, GARRETT, & DUNNER LLP
`erika.arner@finnegan.com
`rachel.emsley@finnegan.com
`
`Naveen Modi
`Joseph Palys
`Daniel Zeilberger
`Arvind Jairam
`PAUL HASTINGS LLP
`naveenmodi@paulhastings.com
`josephpalys@paulhastings.com
`danielzeilberger@paulhastings.com
`arvindjairam@paulhastings.com
`
`
`PATENT OWNER:
`
`Kenneth J. Weatherwax
`Nathan Lowenstein
`Edward Hsieh
`Parham Hendifar
`Patrick Maloney
`LOWENSTEIN & WEATHERWAX LLP
`weatherwax@lowensteinweatherwax.com
`lowenstein@lowensteinweatherwax.com
`hsieh@lowensteinweatherwax.com
`hendifar@lowensteinweatherwax.com
`maloney@lowensteinweatherwax.com
`
`
`
`
`13
`
`
`
`IPR2018-01047 and IPR2018-01048 (Patent 9,516,129)
`IPR2018-01049 and IPR2018-01101 (Patent 9,553,816)
`IPR2018-01051 and IPR2018-01052 (Patent 9,516,127)
`IPR2018-01094 and IPR2018-01095 (Patent 9,444,812)
`IPR2018-01116 and IPR2018-01117 (Patent 9,351,254)
`IPR2018-01102 (Patent 8,811,952)
`
`
`
`Sangeeta G. Shah
`David S. Bir
`Richard J. Cantor
`BROOKS KUSHMAN P.C.
`sshah@brookskushman.com
`dbir@brookskushman.com
`rjcantor@brookskushman.com
`
`14
`
`
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