Trials@uspto.gov
`571-272-7822
`
`
`Paper 34
`Date: September 1, 2021
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`DELL INC., ZTE (USA) INC., and ZTE CORPORATION,
`Petitioner,
`
`v.
`
`3G LICENSING S.A.,
`Patent Owner.
`____________
`
`IPR2020-01157
`Patent 7,274,933 B2
`____________
`
`
`Before TERRENCE W. McMILLIN, AMANDA F. WIEKER, and
`RUSSELL E. CASS, Administrative Patent Judges.
`
`CASS, Administrative Patent Judge.
`
`
`PRELIMINARY GUIDANCE
`
`PATENT OWNER’S CONTINGENT MOTION TO AMEND
`
`
`
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`IPR2020-01157
`Patent 7,274,933 B2
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`I. INTRODUCTION
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`
`
`On February 17, 2021, we instituted trial as to claims 1–4, 6–9, 11–14, and
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`19 of U.S. Patent No. 7,274,933 B2 (Ex. 1001, “the ’933 patent”). Paper 12. After
`
`institution, Patent Owner filed a Contingent Motion to Amend. Paper 24
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`(“Motion” or “Mot.”). Should we, in a final written decision, find that challenged
`
`claims 2 and 3 are unpatentable, Patent Owner proposes substitute claims 20 and
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`21, which correspond to challenged claims 2 and 3, respectively. Mot. 1.
`
`Petitioner filed an Opposition to the Motion. Paper 30 (“Opposition” or “Opp.”).
`
`In the Motion, Patent Owner requests that we provide preliminary guidance
`
`concerning the Motion in accordance with the Board’s pilot program concerning
`
`motion to amend practice and procedures. Mot. 1; see also Notice Regarding a
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`New Pilot Program Concerning Motion to Amend Practice and Procedures in Trial
`
`Proceedings under the America Invents Act before the Patent Trial and Appeal
`
`Board, 84 Fed. Reg. 9,497 (Mar. 15, 2019) (providing a patent owner with the
`
`option to receive preliminary guidance from the Board on its motion to amend)
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`(“Notice”). We have considered Patent Owner’s Motion and Petitioner’s
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`Opposition.
`
`In this Preliminary Guidance, we provide our initial, preliminary, non-
`
`binding views on whether Patent Owner has shown a reasonable likelihood that it
`
`satisfies the statutory and regulatory requirements associated with filing a motion
`
`to amend in an inter partes review and whether Petitioner (or the record)
`
`establishes a reasonable likelihood that the substitute claims are unpatentable. See
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`35 U.S.C. § 316(d); 37 C.F.R. § 42.121; Lectrosonics, Inc. v Zaxcom, Inc.,
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`IPR2018-01129 Paper 15 (PTAB Feb. 25, 2019) (precedential); see also Notice, 84
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`Fed. Reg. at 9,497 (“The preliminary guidance . . . provides preliminary,
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`IPR2020-01157
`Patent 7,274,933 B2
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`non-binding guidance from the Board to the parties about the [motion to
`
`amend].”).
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`For purposes of this Preliminary Guidance, we focus on the proposed
`
`substitute claims, and specifically on the amendments proposed in the Motion. See
`
`Notice, 84 Fed. Reg. at 9,497. We do not address the patentability of the
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`originally challenged claims. Id. Moreover, in formulating our preliminary views
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`on the Motion and Opposition, we have not considered the parties’ other
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`substantive papers on the underlying merits of Petitioner’s challenges. We have
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`considered, however, our Institution Decision in determining whether the
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`amendments “respond to a ground of unpatentability involved in the trial.”
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`Lectrosonics, Paper 15 at 5. We emphasize that the views expressed in this
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`Preliminary Guidance are subject to change upon consideration of the complete
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`record, including any revision to the Motion that might be filed by Patent Owner.
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`Thus, this Preliminary Guidance is not binding on the Board when rendering a
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`final written decision. See Notice, 84 Fed. Reg. at 9,500.
`
`II. PRELIMINARY GUIDANCE
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`A. Statutory and Regulatory Requirements
`
`For the reasons discussed below, at this stage of the proceeding, and based
`
`on the current record, it appears that Patent Owner has not shown a reasonable
`
`likelihood that it has satisfied the statutory and regulatory requirements associated
`
`with filing a motion to amend.
`
`1. Reasonable Number of Substitute Claims
`
`Does Patent Owner propose a reasonable number of substitute claims?
`(35 U.S.C. § 316(d)(1)(B))
`
`Yes.
`
`
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`3
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`Patent 7,274,933 B2
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`
`Patent Owner proposes no more than one substitute claim for each of
`challenged claims 2 and 3 of the ’933 patent. See Mot. 1; id. at 16,
`App. A. Petitioner does not argue otherwise. See generally Opp.
`
`
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`2. Respond to Ground of Unpatentability
`
`Does the Motion respond to a ground of unpatentability involved in the
`trial? (37 C.F.R. § 42.121(a)(2)(i))
`
`Yes.
`
`Patent Owner responds to the grounds of unpatentability at pages 10–14 of
`the Motion. Petitioner does not argue otherwise. See generally Opp.
`
`
`
`3. Scope of Amended Claims
`
`Does the amendment seek to enlarge the scope of the claims? (35 U.S.C.
`§ 316(d)(3); 37 C.F.R. § 42.121(a)(2)(ii))
`
`Yes.
`
`Patent Owner asserts that “[p]roposed substitute claims 20 and 21 narrow
`the scope of claims 2 and 3, respectively,” because “[e]ach substitute
`claim imposes additional limitations.” Mot. 4.
`
`Petitioner argues that proposed substitute claims 20 and 21 “negate the
`steps of independent claim 1 in circumstances where there is no
`HPLMN[1] list” and thus “impermissibly enlarge the scope of the claims
`of the patent.” Opp. 16.
`
`At this stage of the proceeding, Petitioner appears to have the better
`position.
`
`Each of original claims 2 and 3, and proposed substitute claims 20 and 21,
`depends from independent claim 1. Proposed substitute claims 20 and 21
`contain the newly added limitation “implementing the method [or steps] of
`claim 1” “only if the HPLMN list is contained on the mobile station’s SIM
`or in its memory” (emphasis added). Mot. 16, App. A. Thus, proposed
`substitute claims 20 and 21, as written, call for “implementing the steps of
`
`
`1 “HPLMN” refers to a home public land mobile network. Ex. 1001, 1:43–44.
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`claim 1” only if the necessary condition is met. If the necessary condition
`is not met, then proposed substitute claims 20 and 21 call for not
`implementing the steps of claim 1. In other words, each of proposed
`substitute claims 20 and 21, as written, covers at least two methods: one
`that requires implementing the steps of claim 1 (necessary condition is
`met) and one that requires not implementing the steps of claim 1
`(necessary condition is not met). Cf. Ex Parte Schulhauser, No. 2013-
`007847, 2016 WL 6277792 (PTAB Apr. 28, 2016) (precedential)
`(discussing conditional limitations in the context of ex parte appeals).
`
`Therefore, each of proposed substitute claims 20 and 21—which depends
`from claim 1—indicates that the steps of claim 1 are not performed under
`certain conditions, i.e., if the HPLMN list is not contained on the mobile
`station’s SIM or in its memory. Thus, proposed substitute claims 20 and
`21, unlike original claims 2 and 3, cover situations where none of the steps
`of independent claim 1 are performed.
`
`
`
`4. New Matter
`
`Does the amendment seek to add new subject matter? (35 U.S.C.
`§ 316(d)(3); 37 C.F.R. § 42.121(a)(2)(ii))
`
`For the limitation “determine whether the HPLMN list, containing a
`plurality of home network MCC and MNC pairs, is stored in the memory
`of the mobile station, in the SIM, or neither” in proposed substitute claims
`20 and 21.
`
`Yes.
`
`Patent Owner asserts that this limitation of proposed substitute claims 20
`and 21 is supported by the original disclosures in U.S. Application No.
`10/932,899 (“the ’899 Application”)—the application that issued as the
`’933 patent—and in European Application No. 03255483, to which the
`’933 patent claims priority. Mot. 5–11; Ex. 1001, codes (21), (30). Patent
`Owner provides a chart including citations to the ’899 and European
`Applications to support the limitations of proposed substitute claims 20
`and 21. Mot. 5–11.
`
`Petitioner argues that the phrase “or neither” in proposed substitute
`claims 20 and 21 implies that “the HPLMN list may be present in ‘neither’
`the SIM nor the mobile station memory.” Opp. 6. According to
`
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`Petitioner, the written description of the ’933 patent does not support the
`absence of the HPLMN list in both locations. Id. Petitioner argues that
`the presence of the HPLMN list in at least one of the SIM or the memory
`is required “throughout the Specification” (id.) and that the HPLMN list
`being present in neither location is not described and, in fact, “defeats the
`very purpose of the patent” (id. at 8).
`
`We agree with Petitioner that the embodiments relied on by Patent Owner
`“require the HPLMN list to be either in the SIM or memory” and “exclude
`the possibility that it may be absent from both.” Opp. 7.
`
`For example, Patent Owner relies on an embodiment of the ’899
`Application that is described as “a slight variation of the method of”
`Figure 7, but the description of that embodiment indicates that if the
`HPLMN list is not stored on the SIM, then the mobile station utilizes an
`HPLMN list “stored in its own memory.” Mot. 6–7; Ex. 1002, 25.
`
`In other words, there appears to be written description support for the
`HPLMN list being absent from either the SIM or the mobile station
`memory. However, at this stage of the proceeding and on the record
`before us, Patent Owner has not identified written description support for
`the HPLMN list being absent from both locations as recited in proposed
`substitute claims 20 and 21.
`
`For the limitation “implementing the method [or steps] of claim 1 only if
`the HPLMN list is contained on the mobile station’s SIM or in its
`memory” in proposed substitute claims 20 and 21:
`
`Yes.
`
`Patent Owner asserts that support for this limitation is provided in the ’899
`and European Applications. See Mot. 5–10.
`
`Petitioner argues there is no support in the written description of the ’933
`patent for this limitation. Opp. 8–10.
`
`As discussed above in section II.A.3, proposed substitute claims 20 and 21
`encompass a circumstance where the steps of claim 1 are not performed,
`i.e., when the HPLMN list is not contained on the mobile station’s SIM or
`in its memory. In that circumstance, proposed substitute claims 20 and 21
`contain a negative limitation of not “implementing the steps of claim 1.”
`“Negative claim limitations are adequately supported when the
`specification describes a reason to exclude the relevant limitation.”
`Santarus, Inc. v. Par Pharm., Inc., 694 F.3d 1344, 1351 (Fed. Cir. 2012).
`
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`Thus, we look to the cited portions of the written description, including the
`’899 and European Applications, to determine whether they describe a
`reason to exclude the steps of claim 1 in the circumstance recited in the
`proposed substitute claims.
`
`Patent Owner’s citations for both proposed substitute claims are to the
`same portions in each of the ’899 and European Applications. Mot. 7–10.
`Both Applications describe “the mobile station utilizes a multiple home
`network list on the SIM if it is stored on the SIM but, if such a list is not
`stored on the SIM, the mobile station utilizes a multiple home network list
`stored in its own memory.” Ex. 1002, 25. Patent Owner does not identify
`any discussion of a scenario where the HPLMN list is not stored in either
`location. Also, Patent Owner does not identify anywhere in the European
`or ’899 Applications that discusses reasons why one would not perform
`the steps of claim 1 in any scenario.
`
`Accordingly, based on the current record, it appears that Patent Owner’s
`proposed amendment adds new subject matter to the claims.
`
`B. Patentability
`
`For the reasons discussed below, at this stage of the proceeding, and based
`
`on the current record,2 it appears that Petitioner (or the record) has shown a
`
`reasonable likelihood that proposed substitute claims 20 and 21 are unpatentable.
`
`
`
`Does the record establish a reasonable likelihood that the proposed
`substitute claims are unpatentable?
`
`Yes.
`
`
`2 We express no view on the patentability of original claims 2 and 3 in this
`Preliminary Guidance. Instead, we focus on limitations added to those claims in
`Patent Owner’s Motion to Amend.
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`1. Indefiniteness under 35 U.S.C. § 112 ¶ 23
`
`On this record, it appears that the entirety of the record shows a reasonable
`likelihood that proposed substitute claims 20 and 21 are indefinite under
`35 U.S.C. § 112 ¶ 2.
`
`Proposed substitute claims 20 and 21 recite, in relevant part, implementing
`the method (or steps) of claim 1 “only if the HPLMN list is contained on
`the mobile station’s SIM or in its memory” (emphasis added). It is not
`clear whether the modifier “its” refers to the mobile station or the SIM.
`
`Although Petitioner does not assert proposed substitute claims 20 and 21
`are indefinite for this particular reason, we address it here to provide
`further guidance to the parties. We determine the evidence is “readily
`identifiable and persuasive such that the Board should take it up in the
`interest of supporting the integrity of the patent system, notwithstanding
`the adversarial nature of the proceedings.” Hunting Titan, Inc. v.
`DynaEnergetics Europe GmbH, IPR2018-00600, Paper 67, 13 (PTAB
`July 6, 2020) (designated precedential). The evidence relevant to this
`issue is nothing more than the language of the proposed substitute claims,
`and the ’933 patent Specification. We determine that the issue is
`sufficiently persuasive to address at this preliminary stage. By addressing
`this issue now, Patent Owner will be able to, should it desire, present
`proposed substitute claims in a revised motion to amend that do not suffer
`from the same potential infirmity. See Notice, 84 Fed. Reg. 9,499–500.
`
`Accordingly, there is a reasonable likelihood that proposed substitute
`claims 20 and 21 are indefinite because they “fail[] to inform, with
`reasonable certainty, those skilled in the art about the scope of the
`invention.” Nautilus, Inc. v. Biosig Instruments, Inc., 572 U.S. 898, 901
`(2014); see USPTO Memorandum on the Approach to Indefiniteness
`Under 35 U.S.C. § 112 in AIA Post-Grant Proceedings (Jan. 6, 2021);
`MPEP § 2173.05(e) (9th ed., Rev. 08.2017, June 2020).
`
`
`
`
`3 The Leahy-Smith America Invents Act, Pub. L. No. 112-29, 125 Stat. 284 (2011)
`(“AIA”), included revisions to 35 U.S.C. §§ 103 and 112 that became effective
`after the effective filing date of the challenged claims. Therefore, we apply the
`pre-AIA version of 35 U.S.C. §§ 103 and 112.
`
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`2. Improper Dependent Form under 35 U.S.C. § 112 ¶ 4 and
`Indefiniteness under 35 U.S.C. § 112 ¶ 2
`
`On this record, it appears that Petitioner (and/or the entirety of the record)
`has shown a reasonable likelihood of establishing that proposed substitute
`claims 20 and 21 are unpatentable under 35 U.S.C. § 112 ¶ 4 as being of
`improper dependent form (Opp. 19) and indefinite under 35 U.S.C. § 112
`¶ 2 (Opp. 12–15).
`
`35 U.S.C. § 112 ¶ 4 provides:
`
`Subject to the following paragraph [concerning multiple
`dependent claims], a claim in dependent form shall contain a
`reference to a claim previously set forth and then specify a
`further limitation of the subject matter claimed. A claim in
`dependent form shall be construed to incorporate by reference
`all the limitations of the claim to which it refers.
`
`Proposed substitute claims 20 and 21 each recites “implementing the
`method [or steps] of claim 1” “only if the HPLMN list is contained on the
`mobile station’s SIM or in its memory.” As discussed above in section
`II.A.3, proposed substitute claims 20 and 21 therefore encompass methods
`that do not perform the limitations of claim 1, and therefore fall outside the
`scope of claim 1. See Opp. 19. Thus, proposed substitute claims 20 and
`21 do not necessarily “incorporate by reference all the limitations of”
`claim 1 as required by 35 U.S.C. § 112 ¶ 4. See Pfizer Inc. v. Ranbaxy
`Labs. Ltd., 457 F.3d 1284, 1292 (Fed. Cir. 2006) (holding that when a
`claim relying on another claim “fails to ‘specify a further limitation of the
`subject matter’ of the [other] claim to which it refers because it is
`completely outside the scope of [the other claim,]” such claim is invalid
`under 35 U.S.C. § 112 ¶ 4).
`
`Furthermore, proposed substitute claims 20 and 21 create uncertainty as to
`whether they require “implementing the steps of claim 1.” See Opp. 14
`(“[I]t is unclear to a POSITA whether the steps of claim 1 (which are
`incorporated into the substitute claims) must ever be performed at all.”).
`Each of proposed substitute claims 20 and 21 begins, on its face, with
`“[t]he method of claim 1.” Yet, as discussed above, proposed substitute
`claims 20 and 21 make “implementing the method [or steps] of claim 1”
`conditional. Thus, proposed substitute claims 20 and 21 each contain an
`inherent contradiction: proposed substitute claims 20 and 21 require “the
`method of claim 1” while, under certain circumstances, not “implementing
`
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`the method [or steps] of claim 1.” See Opp. 13–15 (citing Synchronoss
`Techs., Inc. v. Dropbox, Inc., 987 F.3d 1358 (Fed. Cir. 2021)). We do not
`see how it is possible to perform the method of claim 1 without
`implementing the method (or steps) of claim 1. Cf. Synchronoss Techs.,
`987 F.3d at 1366–67 (claims held indefinite because they were
`“nonsensical and require an impossibility”). Accordingly, there is a
`reasonable likelihood that proposed substitute claims 20 and 21 are
`indefinite for this additional reason.
`
`Finally, proposed substitute claim 20 recites that the test is performed
`“each time the mobile station is to display a network name,” presumably
`referring to the claim 1 steps of “causing a home network display name . . .
`to be visually displayed . . . and otherwise causing an alternate display
`name to be visually displayed.” Ex. 1001, 15:36–37. This language of
`proposed substitute claim 20 appears to be indefinite because it is unclear
`how the recited test of claim 20 can be performed at the “display” time
`recited in claim 1, where the result of claim 20’s test may result in the
`steps of claim 1 never being performed at all, i.e., if the HPLMN list is not
`contained in the SIM or memory. This contradiction is similar to, albeit
`more specific than, the contradiction argued by Petitioner on pages 12–15
`of the Opposition. See, e.g., Opp. 14 (“[T]he method of claim 1 is
`unconditional, but the new claims instruct not to perform it unless a certain
`condition is met.”). Again, because the evidence relevant to this issue is
`readily identifiable and sufficiently persuasive, we address it at this
`preliminary stage. Hunting Titan, IPR2018-00600, Paper 67 at 13; Notice,
`84 Fed. Reg. 9, 499–500.
`
`
`
`3. Written Description under 35 U.S.C. § 112 ¶ 1
`
`On this record, it appears that Petitioner has shown a reasonable likelihood
`of establishing that proposed substitute claims 20 and 21 lack written
`description support.
`
`Petitioner argues that the proposed substitute claims lack written
`description support. See supra § II.A.4.
`
`As discussed above in section II.A.4, the portions of the ’899 and
`European Applications cited by Patent Owner in the Motion do not
`provide support for the full scope of proposed substitute claims 20 and 21.
`These claims recite the possibility that the HPLMN list is stored in neither
`the SIM nor the mobile station memory, such that the steps of claim 1 are
`
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`not performed, which is a possibility that is not described in the cited
`portions of the written description.
`
`Proposed substitute claims 20 and 21 also recite a negative limitation of
`not implementing the steps of claim 1 under certain circumstances. We
`tend to agree with Petitioner that the portions of the written description
`cited by Patent Owner do not adequately describe “a reason to exclude”
`performing the steps of claim 1. Santarus, 694 F.3d at 1351.
`
`
`
`4. Obviousness under 35 U.S.C. § 103
`
`On this record, it appears that Petitioner has shown a reasonable likelihood
`of establishing that proposed substitute claims 20 and 21 are unpatentable
`as obvious.
`
`Patent Owner contends that proposed substitute claims 20 and 21 have not
`been shown to be unpatentable because “no prior art reference discloses
`conducting a test—either once during or after SIM initialization (substitute
`claim 21), or every time the [user equipment (]UE[)] is to display a
`network name (substitute claim 20).” Mot. 11.
`
`Petitioner asserts that “[t]he proposed substitute claims would have been
`obvious to a [person of ordinary skill in the art (]POSITA[)] at the time of
`the ’933 patent based on the same Grounds raised in the Petition.” Opp.
`19. Petitioner identifies three new limitations contained in each of
`proposed substitute claims 20 and 21: (1) the test to determine whether the
`HPLMN list is stored in the SIM, the mobile station’s memory, or neither;
`(2) the condition that the method of claim 1 is implemented only if the
`HPLMN list is contained on the mobile station’s SIM or in its memory;
`and (3) the timing of performing the test of limitation (1). Id. at 4.
`According to Petitioner, “McElwain (which is included in all five
`Grounds) renders obvious each of the three additional limitations added in
`the proposed substitute claims.” Id. at 19–20.
`
`With respect to limitation (1), Petitioner asserts that “McElwain teaches
`that an HPLMN list (the Cousin SID list) can be stored in the SIM or in
`memory of a mobile device.” Opp. 21 (citing Ex. 1004 ¶¶ 38–39).
`According to Petitioner, “[i]t would have been obvious to a POSITA, in
`light of McElwain, to run a test to determine whether the HPLMN list is
`stored in the SIM, memory, or neither” because “it is a precursor to using
`the HPLMN list to locate it, if it exists.” Id. (citing Ex. 1029 ¶¶ 57–61).
`
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`Petitioner also asserts that “TS-22.101 (which is part of Ground 5) teaches
`storing network names in either the SIM or memory of the mobile, with
`information stored on the SIM taking priority” and argues that “[t]his
`confirms that it would have been known to a POSITA to check (i.e., test)
`multiple locations to determine whether specific data is available.” Id. at
`22 (citing Ex. 1008, 28).
`
`At this stage of the proceeding and based on the current record, we are
`persuaded by Petitioner’s arguments that one of ordinary skill in the art
`would have understood that performing a test to determine whether the
`HPLMN list is stored in the SIM, the mobile station’s memory, or neither,
`would have been necessary, or at least desirable, for the reasons set forth
`by Dr. Kakaes. See Ex. 1029 ¶¶ 57–61. For example, Dr. Kakaes explains
`that “attempting to read non-existing data would typically lead to
`unexpected and indeterminate software-related malfunctions.” Id. ¶ 61.
`At this stage, we credit this testimony, which is consistent with the
`disclosures of the prior art of record.
`
`With respect to limitation (2), Petitioner asserts that “[t]he comparisons
`and name display procedures required by claim 1 would not—and could
`not—be implemented if the HPLMN list (Cousin SID list) is not present”
`and, “[t]hus, McElwain teaches implementing the method of claim 1 only
`if the HPLMN list is contained on the mobile station’s SIM or in its
`memory.” Opp. 22–23 (citing Ex. 1029 ¶¶ 63–64).
`
`At this stage of the proceeding and based on the current record, we are
`persuaded by Petitioner’s arguments that one of ordinary skill in the art
`would have understood that the steps of claim 1 could not be implemented
`if the HPLMN list (Cousin SID list) is absent, as Dr. Kakaes explains. See
`Ex. 1029 ¶ 64. At this stage, we credit this testimony, which is consistent
`with the disclosures of the prior art of record.
`
`With respect to limitation (3), Petitioner asserts that the two alternative
`times for performing the test of proposed substitute claims 20 and 21 “are
`ones of a finite set of options for when to perform this kind of test.”
`Opp. 23 (citing Ex. 1029 ¶ 67). For example, Dr. Kakaes explains that
`performing the test once during or after a SIM initialization procedure
`would have been an obvious choice because “a mobile device already uses
`the initialization procedure to check that the SIM is the right format and
`contains necessary data” and “no test could be run before that procedure.”
`Ex. 1029 ¶ 68. As for the alternative of proposed substitute claim 20, i.e.,
`performing the test “each time the mobile station is to display a network
`
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`name,” Dr. Kakaes explains that “[i]t is a common and well-known
`practice in computer science to test for the existence of data before trying
`to read it, every time the data would be read,” and is “simply a prudent
`way to write software to ensure that the data is available before trying to
`read it.” Ex. 1029 ¶ 69. At this stage, we credit this testimony, which is
`consistent with the disclosures of the prior art of record.
`
`For the reasons discussed above and based on the current record, it appears
`that Petitioner has shown a reasonable likelihood that proposed substitute
`claims 20 and 21 would have been obvious.
`
`
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`FOR PETITIONER:
`
`Brian Buroker
`Paul Torchia
`Nathan Curtis
`GIBSON, DUNN & CRUTCHER LLP
`bburoker@gibsondunn.com
`ptorchia@gibsondunn.com
`ncurtis@gibsondunn.com
`
`John Hutchins
`Chunhsi Mu
`Wesley Jones
`BANNER & WITCOFF, LTD.
`jhutchins@bannerwitcoff.com
`amu@bannerwitcoff.com
`wjones@bannerwitcoff.com
`
`
`
`FOR PATENT OWNER:
`
`Timothy Devlin
`Neil Benchell
`Stephanie Berger
`DEVLIN LAW FIRM LLC
`td-ptab@devlinlawfirm.com
`nbenchell@devlinlawfirm.com
`sberger@devlinlawfirm.com
`
`
`
`
`
`
`
`14
`
`