`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`
`MOBILITY WORKX, LLC
`Patent Owner.
`____________
`Case IPR2018-01150
`Patent 8,213,417
`____________
`
`PATENT OWNER’S SUR-REPLY
`
`
`
`
`
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`
`
`TABLE OF CONTENTS
`
`Requirements of Claim 1. ........................................................................... 3
`
`of Claim 1. ................................................................................................. 11
`
`Claim 1 and Fail for the Same Reasons. ................................................... 14
`
`I. ARGUMENT ........................................................................................... 1
`A. Petitioner, Not Patent Owner, Misunderstands the Art. ....................... 1
`B. Liu’s MF-Agent and MF-Assignment Reply Do Not Meet the
`C. The Combination of Liu and Gwon Does Not Meet the Requirements
`D. UPI’s Arguments Concerning Claims 2-4 Depend on Its Analysis of
`E. Claim 7 is Patentable over the Combination of Liu and Lau. ............ 15
`II.
`CONCLUSION. ................................................................................. 16
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`ii
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`
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`CASES
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`
`
`TABLE OF AUTHORITIES
`
`CFMT, Inc. v. Yieldup Intern. Corp.,
`349 F.3d 1333 (Fed. Cir. 2003) ............................................................. 7, 11
`
`
`Hartness Int’l. Inc. v. Simplimatic Engineering Co.,
`819 F.2d 1100 (Fed. Cir. 1987) ........................................................... 14, 15
`
`
`In re Gordon,
`733 F.2d 900 (Fed. Cir. 1984) ................................................................... 12
`
`
`In re Magnum Oil Tools International, Ltd.,
`829 F.3d 1364 (Fed Cir. 2016) .................................................................... 8
`
`
`In re Ratti,
`270 F.2d 810 (CCPA 1959) ...................................................................... 12
`
`REGULATIONS
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`
`
`37 C.F.R. 42.23(b) .......................................................................................... 3
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`
`
`iii
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`
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`EXHIBIT LIST
`
` Description
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`
` Screenshot of http://www.unifiedpatents.com/npe/
`downloaded July 16, 2018.
` Screenshot of http://www.unifiedpatents.com/npe/
`downloaded August 31, 2018.
` Screenshot of http://www.unifiedpatents.com/success
`downloaded July 16, 2018.
` Screenshot of http://www.unifiedpatents.com/home
`downloaded July 16, 2018.
` Declaration of Suku Nair, Ph.D., PE.
` CV of Suku Nair, Ph.D, PE.
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`
`
`
`Exhibit No.
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`2001
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`2002
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`2003
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`2004
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`2005
`2006
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`
`
`iv
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`
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`I. ARGUMENT
`A. Petitioner, Not Patent Owner, Misunderstands the Art.
`Contrary to UPI’s assertions, Reply at p. 2, it is Petitioner, not Patent
`
`Owner, that misunderstand the art it relies upon. The ’417 patent is
`
`concerned with “reduc[ing] registration overhead and setup times associated
`
`with mobile node handoffs.” Ex. 1001 at 3:54-55. This is accomplished, in
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`part, using ghost-foreign agents to advertise the presence of foreign agents in
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`a network to make a mobile node aware of the foreign agents’ presence
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`before the mobile node actually arrives in a region covered by the foreign
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`agent. Id. at 4:1-7. In Liu, on the other hand, a mobile node specifies its
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`intention to move to a new location and instructs its associated M-agent to
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`set up an MF-agent at that new location so that data files being accessed by
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`the mobile node can be cached, awaiting the mobile node’s arrival.1 Ex.
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`1003 at 7:26-35. Rather than relying upon an MF-agent to make it aware of
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`the presence of a foreign agent, in Liu a mobile node dictates the
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`establishment of an MF-agent to act on behalf of the mobile node’s M-agent
`
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`1 In some cases, a previously created MF-agent may be used, Ex. 1003 at
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`7:39-44, but all MF-agents are first created at the request of a mobile
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`terminal and have only designated times to live. Id. at 7:32-36; 8:48 – 9:2.
`
`
`
`1
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`
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`prior to the mobile node’s handoff to the new location and registration with
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`the foreign agent. Id. at 8:7-12, 17-20. This is the antithesis of “using ghost-
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`foreign agents to advertise the presence of foreign agents in a network to
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`make a mobile node aware of the foreign agents’ presence before the mobile
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`node actually arrives in a region covered by the foreign agent.” See Ex.
`
`1001 at 4:1-7 and claim 1. Moreover, using the mobile node to establish an
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`MF-agent at handoff would increase overhead and introduce further delays,
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`not reduce overhead as the ’417 patent teaches.
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`Importantly, in Liu the mobile terminal still needs to undertake a
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`registration process when it arrives at the location serviced by the foreign
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`agent. Id. at 8:7-12. This requirement is avoided under the ’417 patent. Ex.
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`1001 at 10:8-13; and see Ex. 2005 at ¶¶ 37, 39.
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`Gwon too is distinct from the ’417 patent. For example, in Gwon, a
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`Neighbor Discovery (ND) mechanism is used to identify routers, Ex. 1004 at
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`[0049], [0051], “which affects the quality of real-time interactive data
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`communications” in the network. Id. at [0049]. Mobile nodes must wait until
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`they are near the vicinity of a next router before becoming aware of their
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`presence. Id. at [0051]-[0053]. Like Liu, this is the opposite of using MF-
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`agents to make mobile nodes aware of their presence on behalf of foreign
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`
`
`2
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`
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`agents prior to a mobile node arriving in the coverage area of the foreign
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`agent.
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`
`
`B. Liu’s MF-Agent and MF-Assignment Reply Do Not Meet the
`Requirements of Claim 1.
`Contrary to UPI’s contentions, the MF-assignment reply sent by the
`
`MF-agent to the M-agent does not meet the requirements of claim 1 of
`
`the ’417 patent. Beginning at p. 3 of its Reply, UPI attempts to convince the
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`Board that the MF-agent assignment reply is an advertised message that
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`indicates the presence of a ghost-foreign agent on behalf of a foreign agent
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`as required by the claim. Reply at pp. 3 et seq. To do so, UPI introduces a
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`new argument—that “the MF-agent would acquire the IP address of the
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`foreign agent as part of [the] registration process [and that the IP address
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`would be] subsequently forwarded to the mobile device, thus informing the
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`mobile device of the presence of the foreign agent and the MF-agent linked
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`to it.” Id. at 4 (citing Ex. 1010 at ¶¶ 10-14). Not only is this argument
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`improperly presented for the first time in the Reply, and so should be
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`disregarded by the Board, 37 C.F.R. 42.23(b), it is factually incorrect.2
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`2 Consider, for example Claim 10 of Liu, which recites:
`
`The method according to claim 3, further comprising the steps of:
`sending a registration request from the mobile user to the foreign
`
`
`
`3
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`
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`In its Petition, UPI argued, “The created or assigned MF-agent then
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`‘registers itself with the foreign agent,’ (i.e., acts on behalf of a foreign
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`agent), and sends an ‘MF-assignment reply back to the M-agent’ that is then
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`sent ‘back to the mobile terminal.’ . . . In Liu, the MF-agent assignment
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`reply that is initiated at the MF-agent (i.e. ‘ghost foreign agent’) provides the
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`mobile node with a notification of the presence of the assigned MF-agent in
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`the foreign network.” Pet. at 20 (citing Ex. 1003 at 7:51-57). Nowhere did
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`UPI mention, let alone argue, that “the MF-agent would acquire the IP
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`address of the foreign agent as part of [the] registration process,” as now
`
`alleged in the Reply. Nor is there any discussion of such an acquisition in
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`Liu itself.
`
`When it comes to the MF-agent assignment reply, Liu states only,
`
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`agent; and in response to receipt of the registration request, if there
`is an MF-agent registered for the mobile user, then sending, from the
`FA to the mobile user, a confirmation and a link for accessing the
`MF-agent.
`
`Ex. 1003 at 20:62-21:02. In other words, the MF-agent does not send
`
`information ) about the foreign agent to the mobile terminal (less so the
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`foreign agent’s IP address), instead the foreign agent sends the mobile node
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`information about the MF-agent. Id.; and see id. at 8:9-12.
`
`
`
`4
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`
`
`After the MF-agent 52 is alternatively created or assigned,
`it registers itself with the Foreign Agent 73 (F-agent)
`(708). The MF-agent 52 then sends an MF-assignment
`reply back to the M-agent 50 containing the registration
`information (709).
`
`Ex. 1003 at 7:51-55. This is the sole mention of the MF-assignment reply in
`
`Liu, and nowhere are the contents of the MF-assignment reply described,
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`except insofar as the above passage indicates that it “contain[s] the
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`registration information.” Id. Liu offers no further description of the
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`“registration information.”
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`
`
`Despite the scant information concerning the MF-assignment reply in
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`Liu, UPI now contends, “The MF-agent would then forward this registration
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`information, including the IP address of the foreign agent, to the M-agent in
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`its MF-agent assignment reply.” Reply at 4. Liu itself disputes this
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`contention inasmuch as Liu states, “The M-agent 50 then sends a reply back
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`to the mobile terminal 55 and maintains a data consistency link 63 with the
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`MF-agent 52 (710).” Ex. 1003 at 7:54-56. Nowhere does Liu state that there
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`is any “forwarding” of any information, IP address or otherwise, that it
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`received from the MF-agent as part of the MF-agent assignment reply. All
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`that is reported is that the M-agent sends a reply to the mobile terminal—
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`presumably a reply to the mobile terminal’s MF-agent assignment request, id.
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`
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`5
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`
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`at 7:26-29—and that the M-agent maintains a data consistency link with the
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`MF-agent.
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`UPI, through Dr. Haas, surmises that without the IP address of the
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`foreign agent being provided to the mobile device, the mobile device would
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`“lose its point of attachment to the network when traveling outside its home
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`network,” Reply at pp. 4-5, but this is not true. Liu states that when making
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`the initial MF-agent assignment request the mobile device sends the M-agent
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`“an address of the new location it is traveling to.” Ex. 1003 at 7:28-29. In
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`other words, the mobile agent already knows which foreign agent it will be
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`connecting to and so does not require the M-agent, or the MF-agent for that
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`matter, to forward it the IP address of that foreign agent. The purported basis
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`for UPI’s allegation of forwarding IP addresses simply is wrong and nothing
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`in Liu supports it. All that can be said from Liu’s disclosure is that the MF-
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`agent registers itself with the F-agent and then sends an MF-assignment
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`reply back to the M-agent containing the registration information.
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`By including its own registration information in the MF-assignment
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`reply, the MF-agent does not indicate its presence on behalf of the foreign
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`agent. Rather, if anything, it indicates only the MF-agent’s own successful
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`registration with the foreign agent. Ex. 1003 at 7:51-55; Ex. 2005 at ¶ 29.
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`Consequently, UPI’s argument fails, and claim 1 is not obvious in view of
`
`
`
`6
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`
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`Liu. CFMT, Inc. v. Yieldup Intern. Corp., 349 F.3d 1333, 1342 (Fed. Cir.
`
`2003) (“obviousness requires a suggestion of all limitations in a claim”)
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`(citing In re Royka, 490 F.2d 981, 985 (CCPA 1974)).
`
`There are further errors in UPI’s Reply. At p. 5, UPI alleges that “the
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`fact that the MF-agent assignment reply is first sent to the M-agent before
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`being directly forwarded to the mobile terminal is inconsequential.” Reply at
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`p. 5. In making this allegation, UPI distorts Patent Owner’s argument,
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`making it appear as though Patent Owner somehow “admitted that the M-
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`agent forwards the MF-agent assignment reply to the mobile node.” Id. This
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`is not true. In its Response to the petition, Patent Owner made clear that the
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`M-agent only “sends a reply back to mobile terminal.” Response at p. 15
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`(emphasis added). UPI’s modification to this statement in its Reply is an
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`attempt to make it appear as though Patent Owner somehow agreed that the
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`M-agent sends the same communication it receives from the MF-agent to the
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`mobile device. Patent Owner made no such assertion (or admission) and the
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`Board should not be swayed by this mischaracterization of Patent Owner’s
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`argument.
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`Furthermore, the fact that the M-agent sends only a reply to the
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`mobile terminal and does not forward the MF-agent’s assignment reply,
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`does have consequences for UPI’s case. As noted in Patent Owner’s
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`
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`7
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`
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`Response, it is a central tenet of UPI’s allegations of unpatentability that
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`Liu’s MF-agent advertises messages to a mobile node. Response at pp. 15-
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`16 (citing Pet. at pp. 18-26). Claim 1 requires such advertising and it is
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`UPI’s burden to address all elements of the claim. In re Magnum Oil Tools
`
`International, Ltd., 829 F.3d 1364 (Fed Cir. 2016) (the burden of proving
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`unpatentability of a claim in an IPR always rests with the petitioner). As
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`demonstrated above, nothing in Liu suggests that “the registration
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`information is sent to the mobile node” as UPI contends. Reply at p. 5.
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`Instead, all one can conclude is that the registration information is sent to the
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`M-agent and the M-agent sends a reply to the mobile terminal as a response
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`to its MF-agent assignment request. Contrary to UPI’s speculation, because
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`the mobile terminal already knows the address to which it is traveling, Ex.
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`1003 at 7:28-29, it does not need that information forwarded by the M-agent,
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`even if it were included in the MF-agent’s communication with the M-agent
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`(but the content of the MF-agent’s message is simply not taught by Liu).
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`UPI’s arguments concerning the MF-agent acting on behalf of a
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`foreign agent are also wrong. Reply at pp. 5-6. UPI continues to allege that
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`registering with a foreign agent is acting on behalf of the foreign agent.
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`Reply at p. 6. UPI provides no explanation as to why this is so. According to
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`UPI’s expert, Dr. Haas, “a ghost-foreign agent acts on behalf of a foreign
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`
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`8
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`
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`agent when it furthers the proactive allocation of resources by sending
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`advertisements on behalf of the foreign agent.” Ex. 1010 at ¶ 13.3
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`Registering with a foreign agent is not sending advertisements on behalf of
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`the foreign agent, so even under UPI’s own analysis this could not qualify as
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`the MF-agent acting on behalf of a foreign agent. Furthermore, as explained
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`in Patent Owner’s Response, when the MF-agent is reporting its registration
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`with the foreign agent it is acting on its own behalf and doing so at the
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`direction of the M-agent, not the foreign agent. Ex. 2005 at ¶ 30; Ex. 1003 at
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`7:24-38.
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`UPI’s assertion that the MF-agent’s actions on behalf of the M-agent
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`are somehow not connected with the same embodiment to which UPI refers
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`in its petition is untrue. Reply at pp. 6-7. At the very first instance of a
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`discussion of MF-agents in Liu, the following point is made:
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`In accordance with one aspect of the invention, network
`services and resources are distributed to a mobile user in
`a mobile communication system by providing the mobile
`user with a mobility (M)-agent executing on a home
`fixed host or router. It is then determined that the mobile
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`3 Throughout his declaration, Dr. Haas uses the term “foreign router.” See,
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`e.g., Ex. 1010 at ¶¶ 5, 9, 10, 11, 12, 20, and 27. This term appears nowhere
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`in Liu itself. Instead, Liu describes a “foreign agent.” Ex. 1003 at 7:50-51.
`
`
`
`9
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`
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`user is or will be travelling to a destination that is outside
`a service area of the home fixed host or router, and a pre-
`assignment request is sent from the M-agent to at least
`one mobile floating (MF)-agent manager executing on a
`corresponding one of a like number of remote fixed hosts
`or routers located at the destination. Each MF-agent may
`include a set of processes, executing on the
`corresponding remote fixed host or router, for
`communicating and connecting with local resources and
`for managing a variable replicated secondary data cache
`on behalf of the M-agent. The M-agent may include a set
`of processes, executing on the home host or router, for
`communicating with each MF-agent. A mobile floating
`(MF)-agent is then established for use by the mobile user
`at each of the remote fixed hosts or routers, and the M-
`agent is used to send data or service information from the
`service area of the home fixed host or router to the MF-
`agent at each of the remote fixed hosts or routers. In this
`way, services and/or data may be pre-connected/pre-
`arranged at the mobile user's destination.
`
`Ex. 1003 at 2:11-34 (emphasis added). This passage makes clear that even
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`the establishment of the MF-agent is for purposes of “communicating and
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`connecting with local resources and for managing a variable replicated
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`secondary data cache on behalf of the M-agent.” Id. (emphasis added).
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`That is, the role of the MF-agent is always to act on behalf of the M-agent,
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`
`
`10
`
`
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`and not the foreign agent and UPI’s contentions to the contrary ignore the
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`actual teachings of Liu.
`
`For at least the above reasons, and those set forth in Patent Owner’s
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`Response, UPI case for obviousness fails and claim 1 remains patentable
`
`over Liu. CFMT, Inc., 349 F.3d at 1342.
`
`
`
`C. The Combination of Liu and Gwon Does Not Meet the
`Requirements of Claim 1.
`UPI argues in its Reply that,
`
`Petitioner’s proposed modification is consistent with
`Liu’s process for proactive resource allocation. In the
`proposed modification, MF-agents, operating as software
`on foreign routers, simply begin the resource pre-
`allocation process by advertising their presence and the
`IP address of the foreign router they are linked to, to the
`mobile device.
`
`Reply at p. 9 (citing Ex. 1010 at ¶¶ 17-21). As noted in Patent Owner’s
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`Response, however, this proposed modification changes the principle of
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`operation of Liu. Response at pp. 21 et seq.
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`In Liu, MF-agents do not exist unless and until they are established at
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`the instruction of M-agents. Ex. 1003 at 7:36-49. The process begins with a
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`mobile terminal sending an MF-agent assignment request to its M-agent. Id.
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`
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`11
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`
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`at 7:26–28. The M-agent registers the request and forwards it to an MF-
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`agent manager at the new location, id. at 7:37–38, whereupon the MF-agent
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`manager creates an MF-agent for the requesting M-agent. Id. at 7:38–50.
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`The MF-agent then registers itself with the foreign agent and sends an MF-
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`assignment reply back to M-agent, which subsequently sends a reply back to
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`mobile terminal. Id. at 7:50–57. UPI’s contention that an MF-agent would
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`simply advertise its presence to the mobile terminals and not to the M-agents
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`that requested the MF-agent in the first place is a marked departure from this
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`protocol. Under UPI’s arrangement the M-agent receives no
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`acknowledgement that an MF-agent has been established. Nor does the
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`mobile terminal that initiated the process receive a reply to its original MF-
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`agent assignment request. UPI contends the new procedure obviates the need
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`for such a request, Reply at p. 10, but this is not true because it is through
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`the MF-agent assignment request that the mobile terminal instructs the M-
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`agent to “have any necessary services and data ready for the mobile terminal,
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`when it arrives at the new location.” Ex. 1003 at 7:30-36. UPI’s proposed
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`modification eliminates this vital component of the Liu protocol; hence it is
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`not an obvious modification. In re Ratti, 270 F.2d 810, 813 (CCPA 1959); In
`
`re Gordon, 733 F.2d 900, 902 (Fed. Cir. 1984).
`
`
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`12
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`
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`UPI’s position is further undercut by its insistence that, “It is the MF-
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`agent that conveys the IP address of the foreign agent in the foreign
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`network.” Reply at p. 11 (citing Ex. 1010 at ¶¶ 10-14). This is not true
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`because prior to the creation of an MF-agent, a mobile terminal sends an
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`MF-agent assignment request to its M-agent and that request includes the
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`address of the location the mobile terminal is traveling to. Ex. 1003 at 7:26–
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`31. The mobile terminal already knows the address of the foreign agent to
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`which it is traveling, so there is no need for the MF-agent to “convey” that
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`address in response to a request that already included it. In this regard, it is
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`not Dr. Nair’s analogy that is flawed, it is UPI’s position. See Reply at pp.
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`11-13.
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`Finally, Dr. Haas is wrong when he alleges that, “The combination of
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`Gwon’s neighbor discovery mechanism with Liu’s MF-agent pre-assignment
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`process . . . requires only a simple modification of software on a router in the
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`foreign network.” Ex. 1010 at ¶ 18. For example, Gwon’s neighbor
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`discovery mechanism and Liu’s MF-agent pre-assignment process operate at
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`distinct layers of their respective networks. See, e.g., Ex. 1003 at FIG. 6
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`(Liu’s pre-assignment process operating above the IP layer (L3)); Ex. 1004
`
`at [0047] et seq. (Gwon’s methodology is concerned with the network link
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`layer (L2)). Dr. Haas does not discuss these protocol layer distinctions.
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`
`
`13
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`
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`Further, Gwon’s unsolicited router advertisements are useful in cases where
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`a mobile terminal is already in transit from one location to another. Ex. 1004
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`at [0050]-[0053]; Ex. 2005 at ¶ 40. Liu, however, is concerned with
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`notifying the mobile terminal that an MF-agent is awaiting its arrival at the
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`new location. Ex. 1003 at 7:32-37, 55-57. That notification is absent in the
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`case of Gwon’s unsolicited router advertisements, which are unknown to the
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`mobile terminal until it begins its transit. The simple modification of
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`software proposed by Dr. Haas would not address this missing notification.
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`Ex. 2005 at ¶ 33.
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`For at least the above reasons, and those set forth in Patent Owner’s
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`Response, UPI case for obviousness in view of Liu and Gwon fails and
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`claim 1 remains patentable over this combination of references.
`
`Claims 5 and 6 depend from claim 1 and are therefore patentable over
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`Liu and over Liu and Gwon for at least the same reasons as claim 1.
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`Hartness Int’l. Inc. v. Simplimatic Engineering Co., 819 F.2d 1100, 1108
`
`(Fed. Cir. 1987).
`
`
`
`D. UPI’s Arguments Concerning Claims 2-4 Depend on Its Analysis
`of Claim 1 and Fail for the Same Reasons.
`UPI criticizes Patent Owner’s treatment of Grounds 2 and 3. Reply at
`
`pp. 13-14. However, in each of those grounds UPI relies on its analysis of
`
`
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`14
`
`
`
`claim 1, Pet. at pp. 37-38, 45, and UPI admits as much. Reply at p. 14. As
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`explained in the Response, the teachings of the additional references, Lau
`
`and IETF RFC 2402, when considered in combination with those of Liu and
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`Liu and Gwon still would not suggest a ghost-foreign agent that advertises
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`messages to one of the mobile nodes indicating presence of the ghost-foreign
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`agent on behalf of one of the foreign agents when the mobile node is located
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`in a geographical area where the foreign agent is not physically present, as
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`recited in claim 1. Hence claims depending from claim 1 remain patentable
`
`over the combined teachings of Liu, Gwon, and Lau and Liu, Gwon, and
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`IETF RFC 2402 for at least the reasons presented above and in Patent
`
`Owner’s Response with respect to claim 1. Hartness Int’l. Inc., 819 F.2d at
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`1108.
`
`
`
`E. Claim 7 is Patentable over the Combination of Liu and Lau.
`Notwithstanding UPI’s comments in its Reply, it arguments with
`
`respect to claim 7 remain premised on a rewriting of the claim itself. Reply
`
`at pp. 14 et seq. Patent Owner addressed this fault in its Response and
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`nothing in UPI’s Reply adequately explains its original error. The Board
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`should, therefore, confirm the patentability of claim 7 over UPI’s challenge.
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`15
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`
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`II. CONCLUSION.
`For at least the foregoing reasons, and those set forth in the Patent
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`Owner’s Response, the Board should not find any of claims 1-7 unpatentable.
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`Respectfully submitted,
`
`/Tarek N. Fahmi/
`Tarek N. Fahmi
`Reg. No. 41,402
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`Dated: July 3, 2019
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`Ascenda Law Group, PC
`333 W. San Carlos St., Suite 200
`San Jose, CA 95110
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`Tel: 866-877-4883
`Email: tarek.fahmi@ascendalaw.com
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`16
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`CERTIFICATE OF COMPLIANCE
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`This paper complies with the requirements of 37 CF.R. § 42.24 and
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`contains 3465 words (exclusive of the table of contents, table of authorities,
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`certificate of service, and this certification).
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`This paper complies with the typeface requirements of 37 C.F.R.
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`§ 42.6 and has been prepared in 14-point Times New Roman proportionally
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`spaced typeface with double line spacing.
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`Respectfully submitted,
`/Tarek N. Fahmi/
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`Tarek N. Fahmi
`Reg. No. 41,402
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`Dated: July 3, 2019
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`Ascenda Law Group, PC
`333 W San Carlos St., Suite 200
`San Jose, CA 95110
`Tel: 866-877-4883
`Email: patents@ascendalaw.com
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a copy of the foregoing
`PATENT OWNER’S SUR-REPLY
`was served on July 3, 2019, by filing this document though the PTAB E2E
`System as well as by delivering a copy via overnight courier directed to the
`attorneys of record for the Petitioner at the following address:
`Eric Buresh
`Jason R. Mudd
`Hunter A. Horton
`ERISE IP, P.A.
`7051 College Blvd. Suite 700
`Overland Park, Kansas 66211
`
`Ashraf Fawzy, Reg. No. 67,914
`Roshan Mansinghani, Reg. No. 62,429
`Unified Patents Inc.
`1875 Connecticut Ave NW, Floor 10
`Washington, DC 20009
`
`eric.buresh@eriseip.com
`jason.mudd@eriseip.com
`hunter.horton@eriseip.com
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`afawzy@unifiedpatents.com
`roshan@unifiedpatents.com
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`Respectfully submitted,
`/Tarek N. Fahmi/
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`Tarek N. Fahmi
`Reg. No. 41,402
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`Dated: July 3, 2019
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`Ascenda Law Group, PC
`333 W. San Carlos St., Suite 200
`San Jose, CA 95110
`Tel: 866-877-4883
`Email: patents@ascendalaw.com
`
`
`
`
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