Case IPR2020-1157
`Patent No. 7,274,933
`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`DELL, INC.,
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`Petitioner
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`v.
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`3G LICENSING S.A.,
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`Patent Owner
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`Case IPR2020-1157
`Patent No. 7,274,933
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`PATENT OWNER’S REPLY TO PETITIONER’S
`OPPOSITION TO REVISED MOTION TO AMEND
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`Submitted Electronically via PTAB E2E
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`
`
`
`Patent No. 7,274,933
`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`DELL, INC.,
`
`Petitioner
`
`v.
`
`3G LICENSING S.A.,
`
`Patent Owner
`
`Case IPR2020-1157
`Patent No. 7,274,933
`
`
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`
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`PATENT OWNER’S REPLY TO PETITIONER’S
`OPPOSITION TO REVISED MOTION TO AMEND
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`Submitted Electronically via PTAB E2E
`
`
`
`
`
`Case IPR2020-1157
`Patent No. 7,274,933
`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
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`TABLE OF CONTENTS
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`I.
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`INTRODUCTION ............................................................................................... 1
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`II. THE PROPOSED AMENDMENTS ARE APPROPRIATE .......................... 1
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`A. The Specification Provides Sufficient Support for Testing ............................. 1
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`B. The Specification Provides Sufficient Written Support for the Timing
`Limitations .............................................................................................................. 3
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`III. THE PROPOSED AMENDMENTS DO NOT RENDER CLAIMS
`INDEFINITE ............................................................................................................. 7
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`IV. THE PROPOSED SUBSTITUTE CLAIMS ARE NOT OBVIOUS .............. 9
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`A. Elements 20[b] and 25[c] Are not Obvious in Light of McElwain .................. 9
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`B. Elements 20[c] and 25[d] from Limitations (2a) and (2b) Are not Obvious in
`Light of McElwain ................................................................................................10
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`C. Elements 20[d] and 25[e] Are not Obvious in Light of McElwain ................12
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`D. Petitioner Has Failed to Demonstrate a Motivation to Combine McElwain
`and/or Uchida with Hicks and the 3GPP Standards .............................................12
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`V. CONCLUSION ..................................................................................................12
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`Case IPR2020-1157
`Patent No. 7,274,933
`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
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`TABLE OF AUTHORITIES
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`Page(s)
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`Cases
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`Arendi S.A.R.L. v. Apple Inc.,
`832 F.3d 1355 (Fed. Cir. 2016) ............................................................................10
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`Belden Inc. v. Berk-Tek LLC,
`805 F.3d 1064 (Fed. Cir. 2015) ............................................................................12
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`In re Giannelli,
`739 F.3d 1375 (Fed. Cir. 2014). ...........................................................................12
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`Markman v. Westview Instruments, Inc.,
`52 F.3d 967 (Fed. Cir. 1995) .................................................................................. 6
`
`Phillips v. AWH Corp.,
`415 F.3d 1303 (Fed. Cir. 2005) .............................................................................. 6
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`Synchronoss Techs., Inc. v. Dropbox Inc.,
`389 F. Supp. 3d 703 (N.D. Cal. 2019) .................................................................... 8
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`Verify Smart Corp. v. Askeladden, L.L.C.,
`824 F. App’x 1015 (Fed. Cir. 2020) ....................................................................... 6
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`Virtual Sols., LLC v. Microsoft Corp.,
`925 F. Supp. 2d 550 (S.D.N.Y. 2013) .................................................................... 8
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`Statutes
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`35 U.S.C. § 316 .......................................................................................................... 1
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`Regulations
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`37 C.F.R. § 42.121 ..................................................................................................... 1
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`ii
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`Case IPR2020-1157
`Patent No. 7,274,933
`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
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`TABLE OF EXHIBITS
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`
`
`Description
`Exhibit
`2001 Declaration of Stu Lipoff in Support of Patent Owner
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`2002 Affidavit of Stephanie Berger
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`2003 Affidavit of Neil Benchell
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`2004 Affidavit of Andrew DeMarco
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`2005 Second Declaration of Stu Lipoff in Support of Patent Owner
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`2006
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`3rd Generation Partnership Project; Technical Specification Group
`Core Network; NAS Functions related to Mobile Station (MS) in idle
`mode (Release 7) (3GPP TS 23.122 V7.0.0) (“TS 23.122 V7.0.0”)
`3rd Generation Partnership Project; Universal Mobile
`Telecommunications (UMTS); Characteristics of the USIM
`application (Release 6) (3GPP TS 31.102 V6.8.0) (“TS-31.102
`V6.8.0”)
`“The North American Official Cellular User’s Guide” Available to
`Help Cellular Telephone Users, Business Wire, December 18, 1990
`2009 Amy Zuckerman, Those Black Holes in Your Mobile Phone Service,
`New York Times, December 24, 2000
`Nancy Gohring, Falling Short of Replacement: Wireless Carrier Plans
`Compete with Landline but Don’t Cut it Out of the Equation,
`Telephony, April 27, 2998
`Judy Strausbaugh, Oh, Give me a Cell Phone Where the Signals Won’t
`Roam, Sunday News (Lancaster, PA), May 19, 2002
`
`2007
`
`2008
`
`2010
`
`2011
`
`2012
`
` Settlement Agreement dated August 4, 2021
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`2013 Third Declaration of Stu Lipoff in Support of Patent Owner
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`2014 Fourth Declaration of Stu Lipoff in Support of Patent Owner
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`iii
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`Case IPR2020-1157
`Patent No. 7,274,933
`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
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`I.
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`INTRODUCTION
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`Contrary to Petitioner’s contention, the proposed substitute claims 20
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`through 29 in Patent Owner’s Revised Motion to Amend (the “Revised Motion”)
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`are patentable. (See generally Paper 37.) All of the amendments respond to
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`Petitioner’s grounds of unpatentability, none of the amendments seeks to enlarge
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`the scope of the claims or to introduce new subject matter, and the original
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`disclosure of the patent fully supports the requested changes in each substitute
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`claim. See 35 U.S.C. § 316(d)(3); 37 C.F.R. § 42.121(a)(2). Further, the
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`amendments sought in the Revised Motion reflect the Board’s Preliminary
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`Guidance. (See generally Paper 34.)
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`Petitioner’s arguments in opposition to the Revised Motion rely on
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`misrepresentations of the record, the law, and the Board’s Preliminary Guidance.
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`Thus, Petitioner has not met its burden to show that the revised proposed substitute
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`claims are unpatentable. For these reasons and those detailed below, the Revised
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`Motion should be granted.
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`II. THE PROPOSED AMENDMENTS ARE APPROPRIATE
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`A. The Specification Provides Sufficient Support for Testing
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`The Board’s Preliminary Guidance found that:
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`[the original substitute claims 20 and 21] recite the possibility that the
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`HPLMN list is stored in neither the SIM nor the mobile station memory,
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`such that the steps of claim 1 are not performed, which is a possibility
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`that is not described in the cited portions of the written description.
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`1
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`Case IPR2020-1157
`Patent No. 7,274,933
`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
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`(Paper 34 at 10-11 (emphasis original).)1 Patent Owner’s revised substitute claims
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`foreclose that possibility. Instead, the substitute claims unambiguously state that
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`the HPLMN list can only be stored either on the mobile station’s SIM or memory.
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`(See tbl. below; see also Revised Motion at 11 (independent claim 25).)
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`Original substitute claim 20
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`New substitute claim 20
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`(substitute for claim 2 if found
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`(substitute for claim 1 if found
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`unpatentable)
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`unpatentable)
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`The method of claim 1,
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`A network name displaying
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`wherein each time the mobile
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`method in a mobile station, the method
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`station is to display a network
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`comprising:
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`name, the mobile station runs a
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`. . .
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`test to determine whether the
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`conducting a test that determines
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`HPLMN list, containing a
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`whether a Home Public Land Mobile
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`plurality of home network
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`Network (HPLMN) list, containing a
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`MCC and MNC pairs, are is
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`plurality of home network MCC and
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`stored in the memory of the
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`MNC pairs, is stored on the mobile
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`mobile station, in the SIM, or
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`station’s SIM or memory, said test
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`neither; and
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`being run each time the mobile station
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`implementing the method of claim 1
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`is to display a roaming indicator;
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`only if the HPLMN list is contained on
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`determining that a HPLMN list,
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`the mobile station’s SIM or in its
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`containing a plurality of home network
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`memory.
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`MCC and MNC pairs, is stored on the
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`mobile station’s SIM or memory; . . . .
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`1 Unless specified otherwise, emphasis added throughout this Reply.
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`2
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`Patent No. 7,274,933
`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
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`(Paper 24 at 16 (underlining and
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`(Revised Motion at 6-7 (underlining
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`strikethrough original; bold italics
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`original; bold italics added).)
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`added).)
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`The new substitute claims are amended in such a way that the HPLMN list
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`cannot be absent from both the SIM and the memory. As a result, the phrase “or
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`neither” has been removed from the new substitute claims. Petitioner’s argument
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`that the new proposed amendments would encompass a test “to determine [the]
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`availability [of the HPLMN list] at all” (Paper 40 at 6) is no longer availing.
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`The original specification contains sufficient written support for the HPLMN
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`list being located in the SIM or in the mobile station’s memory. (See, e.g., Ex.
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`1002 at 24:20-22 (“These multiple MCC/MNC pairs may be stored in a Home
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`Public Land Mobile Network (HPLMN) list on a Subscriber Identity Module
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`(SIM). Alternatively, the multiple MCC/MNC pairs may be stored in memory of
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`the mobile station.”); id. at 25:21-23.) Indeed, Petitioner admits that the
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`specification discloses “tests that assume the availability of an HPLMN list and . . .
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`specify its location, in either the SIM or memory.” (Paper 40 at 7.)
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`B.
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`The Specification Provides Sufficient Written Support for the
`Timing Limitations
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`Petitioner admits that the specification “describes specific timings for testing
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`the location of the HPLMN list . . . .” (Paper 40 at 8.) Namely, it admits that the
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`testing “may be performed every time the mobile station goes through the network
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`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
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`name displaying technique or, alternatively, only once during or shortly after a
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`SIM initialization procedure performed by the mobile station.” (Id. at 8 (quoting
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`Ex. 1001, 14:35-38).) Despite these admissions, Petitioner still asserts that the
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`proposed timing limitations (2a) and (2b) are improper.
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`Petitioner argues that the specification’s statement that “every time the
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`mobile station goes through the network name displaying technique” provides no
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`support for the timing in 2(a) “every time a roaming indicator is to be displayed”
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`because “the point of the patented method[] is to inform users that the mobile
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`station is not roaming[.]” (Paper 40 at 8-9 (emphasis original).) But this argument
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`is unavailing.
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`First, Petitioner misrepresents “the point” of the patented method. The
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`patent addresses the need for improved home network name displaying methods
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`and apparatus for multiple home networks. (Ex. 1001 at 2:38-40.) This need
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`arises, among other times, when a subscriber using an alternative network is
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`roaming but may avoid roaming charges and be charged a standard rate instead as
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`if he was using the home network. (Id. at 2:1-3.) This may be confusing to a
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`Case IPR2020-1157
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`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
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`subscriber believing, for example, that roaming charges are being incurred due to
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`the use of the alternative network. (Id. at 2:5-8.)2
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`Second, the patent explains that the network name displaying technique is an
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`alternative to the “tradition[al]” approach, under which a roaming indicator would
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`be imparted to a mobile station after it is determined that the mobile station is
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`using a network other than the home network. (Id. at 11:64-66.)
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`Third, utilizing the network name displaying technique may result in
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`displaying a roaming indicator, for example, where the alternative networks are not
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`associated with the home network. (Ex. 1001 at 12:11-14; see also id. at 12:1-8
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`(no roaming status where the same provider owns the alternative networks even
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`though their MCC and MNC pairs are different from those of the home network);
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`fig. 4; fig. 7.) Indeed, Petitioner admits as much:
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`Limitation (2a)—i.e., running a test for the HPLMN list each time the
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`mobile station is to display a roaming indicator—is a step in the
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`network name display procedure, and the result of that overall
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`2 A similar need arises in a situation where the service provider becomes the new
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`owner of one or more networks which have MCC/MNC pairs different from that of
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`the primary home network’s. (Ex. 1001 at 2:24-27.) Additionally, compatibility
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`issues may arise between previous, current, and future versions mobile stations and
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`SIMs. (Id. at 2:34-37.)
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`Case IPR2020-1157
`Patent No. 7,274,933
`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
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`procedure is to decide whether to display a home network name or, if
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`not, a roaming indicator.
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`(Paper 40 at 11.) Therefore, Petitioner’s argument that the limitation (2a) lacks
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`written support should be disregarded.
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`The limitation (2b) recites the relevant time for performing the test as “during
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`or after” SIM initialization. Petitioner takes the position that (2b) should mirror the
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`specification word-for-word and recite “during or shortly after.” (Paper 40 at 9.)
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`This argument is likewise unavailing.
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`To begin, Petitioner cites no authority (and Patent Owner is unaware of any)
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`that the claims should recite the specification verbatim. On the contrary, it is well
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`established that claims should be construed in light of the specification. Markman
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`v. Westview Instruments, Inc., 52 F.3d 967, 979 (Fed. Cir. 1995), aff’d, 517 U.S.
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`370 (1996); id. at 978 (“The patent is a fully integrated written instrument.”).
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`“[T]he specification is always highly relevant to the claim construction analysis.
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`Usually, it is dispositive; it is the single best guide to the meaning of a disputed
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`term.” Phillips v. AWH Corp., 415 F.3d 1303, 1315 (Fed. Cir. 2005) (internal
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`quotation marks omitted).
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`The Verify case on which Petitioner relies is inapposite. There, the
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`specification concerned cell phones and the claims referred to communication
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`devices. Verify Smart Corp. v. Askeladden, L.L.C., 824 F. App’x 1015, 1023 (Fed.
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`Cir. 2020). The Federal Circuit affirmed the Board’s denial of the motion to
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`Case IPR2020-1157
`Patent No. 7,274,933
`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
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`amend because a vastly broader category of communication devices encompassed
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`not only cell phones but also other communication devices of “any nature.” Id. at
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`1023. Here, both the specification and the claim provide the same time markers—
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`“during” or “after” SIM initialization.
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`Petitioner also attacks the proposed amendments for lack of written support,
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`alleging the substitute claims are obvious because
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`[t]here are only a finite number of times at which a test for an HPLMN
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`list could be run, and the two covered by the substitute claims would be
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`the most logical candidates for a POSITA to select. One of the two
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`options is barely even limiting.
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`(Paper 40 at 14-15.) Patent Owner rejects this allegation and will address
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`Petitioner’s obviousness arguments below. However, Petitioner’s obviousness
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`allegation cannot be reconciled with its argument that (2b) lacks written support.
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`III. THE PROPOSED AMENDMENTS DO NOT RENDER CLAIMS
`INDEFINITE
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`Petitioner’s indefiniteness arguments simply repackage its lack of written
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`support arguments. For these same reasons the indefiniteness arguments fail. (See
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`supra Part II.)
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`Additionally, Petitioner takes issue with the phrase “each time” in (2a). That
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`phrase is clear and would be understood by a POSITA. The record supports the
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`test being performed “every time the mobile station goes through the network
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`name displaying technique.” (Ex. 1001 at 14:35-38; Ex. 1002 at 24, 25.)
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`Case IPR2020-1157
`Patent No. 7,274,933
`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
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`Petitioner’s suggestion that an open app may “hide[] the roaming indicator, and
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`then the user closes the app such that the mobile station displays the roaming
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`indicator again[]” is irrelevant because opening apps has no bearing on the patent’s
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`objectives. (See Paper 40 at 11.)
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`The language of the proposed limitation (2a) is not circular or logically
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`impossible, and therefore, the Synchronoss and Virtual Solutions cases are
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`inapposite. In Synchronoss, the patent was invalid for indefiniteness because it
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`required generation of a single digital media file that also had to be a directory of
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`digital media files. Synchronoss Techs., Inc. v. Dropbox Inc., 389 F. Supp. 3d 703,
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`714 (N.D. Cal. 2019). Virtual Solutions dealt with a paradoxical situation where
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`“position information” was simultaneously part of, and used separately from, the
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`“physical characteristic signal” to generate a behavior vector. Virtual Sols., LLC v.
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`Microsoft Corp., 925 F. Supp. 2d 550, 569 (S.D.N.Y. 2013) (the defendant’s
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`motion for summary judgment granted), aff’d, 540 F. App’x 997 (Fed. Cir. 2013).
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`Here, in contrast, displaying a roaming indicator is part of the network name
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`display process. (Paper 40 at 11.) If a match between the MCC and MNC pairs of
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`the selected network and the home network is identified, a home network display
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`name is displayed. (Revised Motion at 8.) If no match is found, an alternative
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`display name is displayed. (Id. at 8.)
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` As to the proposed limitation (2b), the specification uses the term “shortly”
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`to qualify the time marker “after” SIM initialization. In light of the specification,
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`Case IPR2020-1157
`Patent No. 7,274,933
`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
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`(2b) recites a narrow and precise time boundary—starting when the SIM
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`initialization commences and ending shortly after the SIM initialization procedure
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`is complete. (Ex. 1001 at 14:35-38.) It is thus false that “‘during or after a SIM
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`initialization procedure’ encompasses essentially all the time that a mobile unit is on
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`and functional . . .” as Petitioner claims. (See Paper 40 at 13.)
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`IV. THE PROPOSED SUBSTITUTE CLAIMS ARE NOT OBVIOUS
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`A. Elements 20[b] and 25[c] Are not Obvious in Light of McElwain
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`Petitioner also argues that McElwain “teaches using the HPLMN list,
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`whether stored in the SIM or memory, to perform the comparisons and name
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`display procedures required by claim 1.” (Paper 40 at 15.) Patent Owner has
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`already demonstrated this argument is futile in its briefing responsive to the
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`Petition, which is incorporated by reference here. (See, e.g., Paper 36 at 9-11.)
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`Additionally, nowhere do McElwain or the 3GPP references disclose any test to
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`determine the existence of an HPLMN list. (See Paper 37 at 18; Ex. 2005, ¶¶ 66-
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`74.)
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`Insofar as Petitioner relies on Dr. Kakaes (and the Board’s acceptance of his
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`testimony in the Preliminary Guidance), that testimony falls afoul of the Federal
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`Circuit’s holding in Arendi. In Arendi, the Court rejected the Board’s finding that
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`it would have been “common sense” for a program to display user information
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`related to duplicate telephone numbers when searching for information regarding a
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`single number because the testimony was conclusory. Arendi S.A.R.L. v. Apple
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`Inc., 832 F.3d 1355, 1360 (Fed. Cir. 2016). Dr. Kakaes provided similarly
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`conclusory testimony. (See, e.g., Paper 37 at 19-20 (discussing Ex. 1009).)
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`Petitioner’s assurances that the limitation at issue “plays far from a ‘major role’ in
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`the claims” is of no moment. (See Paper 40 at 24.)
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`Petitioner also asserts that the 3GPP standards are irrelevant to this
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`discussion. (Id. at 21-24.) Not so. The 3GPP standards are important because
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`they directly contradict Dr. Kakaes’s statement that “attempting to read non-
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`existent data” would “typically” meet with unexpected errors. (Ex. 1029 at ¶ 61.)
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`Patent Owner has showed, among other things, that TS-31.102 cited by Petitioner
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`contemplated that in a 3GPP system certain filetypes may be overlooked by a UE
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`if designated as optional. (See Paper 37 at 19-20.)
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`B.
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`Elements 20[c] and 25[d] from Limitations (2a) and (2b) Are not
`Obvious in Light of McElwain
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`Petitioner admits that “McElwain is silent on when the test for the HPLMN
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`list would be run . . . .” (Paper 40 at 17.) Yet, despite this admission and contrary
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`to its indefiniteness and lack of written support arguments, Petitioner argues that
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`[t]he two alternatives—running the test each time the mobile station is
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`to display a network name or only once in connection with SIM
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`initialization— . . . are the most natural and obvious choices for when
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`to perform a test for an HPLMN list.
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`(Id. at 17.) This is false.
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`Once it is understood that it is desirable to test for an HPLMN list, the test
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`may be performed at a variety of times, for example:
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`•
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`•
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`When the end user wakes the phone from sleep mode;
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`When the mobile station in motion crosses the boundary from one cell
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`site to another;
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`•
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`Periodically (e.g., once per hour). (Ex. 2014 at ¶ 36.)
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`However, these exemplary choices differ in a material way from the two
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`specific times to test in the substitute claims. The times to test in the substitute
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`claims allow the contents of the SIM card to be read prior to the end user’s need to
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`actually use the phone such that the results of the test can be stored in the phone
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`and used without delay at the time the end user wants to use the phone at some
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`point after testing. (Id. at ¶ 38.) Understanding the limitations of SIM cards in the
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`time frame of the 2003 priority date of the patent, a POSITA would realize that it
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`would take over 7 seconds (i.e., 30ms per record for 255 records in the HPLMN
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`list) to read the HPLMN file from the SIM card into the memory of the mobile
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`station before a test could be performed. (Id. at ¶ 39) By reading and testing the
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`HPLMN list at either of the two times identified in the substitute claims, the results
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`of the test would be known in advance of the end user needing to use the phone
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`without requiring an over 7 second delay before usage. (Id. at ¶¶ 39-40.)
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`Patent No. 7,274,933
`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
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`C. Elements 20[d] and 25[e] Are not Obvious in Light of McElwain
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`Patent Owner’s arguments regarding the non-obviousness of these elements
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`are set forth in its briefing responsive to the Petition, and there is no need to repeat
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`them here. (See, e.g., Paper 36 at 8-13.)
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`D.
`
`Petitioner Has Failed to Demonstrate a Motivation to Combine
`McElwain and/or Uchida with Hicks and the 3GPP Standards
`
`Petitioner has yet to provide any disclosure from McElwain or Uchida that
`
`would allow a POSITA to understand how or why a POSITA might be able to
`
`apply their teachings on a SIM card. McElwain and Uchida are CDMA references,
`
`and CDMA phones at the time did not have SIM cards. The mere statements in
`
`McElwain and Uchida that their teachings could be done on a SIM are not
`
`sufficient. See Belden Inc. v. Berk-Tek LLC, 805 F.3d 1064, 1073 (Fed. Cir. 2015)
`
`(“[O]bviousness concerns whether a skilled artisan not only could have made but
`
`would have been motivated to make the combinations or modifications of prior art
`
`to arrive at the claimed invention.”); In re Giannelli, 739 F.3d 1375, 1380 (Fed.
`
`Cir. 2014).
`
`V. CONCLUSION
`
`For these reasons, Patent Owner’s Revised Motion should be granted.
`
`
`
`
`
`12
`
`
`
`Case IPR2020-1157
`Patent No. 7,274,933
`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
`
`
`Dated: November 17, 20201
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`/ Timothy Devlin /
`Timothy Devlin
`Registration No. 41,706
`DEVLIN LAW FIRM LLC
`1526 Gilpin Avenue
`Wilmington, DE 19806
`Telephone: (302) 449-9010
`Facsimile: (302) 353-4251
`tdevlin@devlinlawfirm.com
`
`Attorney for Patent Owner
`
`
`
`13
`
`
`
`Case IPR2020-1157
`Patent No. 7,274,933
`Patent Owner’s Reply to Petitioner’s Opposition to Revised Motion to Amend
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that the foregoing document was served
`
`electronically via electronic mail on November 17, 2021 on the following counsel
`
`of record for Petitioners:
`
`
`LEAD COUNSEL
`
`Brian M. Buroker (Reg. 39,125)
`bburoker@gibsondunn.com
`
`Gibson, Dunn & Crutcher LLP
`1050 Connecticut Ave. NW
`Washington, DC 20036
`Phone: (202) 955-8500
`
`
`Counsel for Dell, Inc.
`
`FIRST BACKUP COUNSEL
`
`Paul Torchia (Reg. 55,683)
`ptorchia@gibsondunn.com
`
`Gibson, Dunn, & Crutcher LLP
`200 Park Avenue
`New York, NY 10166
`Phone: (212) 351-3953
`
`ADDITIONAL BACKUP COUNSEL
`
`Nathan R. Curtis (Reg. 70,471)
`ncurtis@gibsondunn.com
`
`Gibson, Dunn & Crutcher LLP
`2001 Ross Ave., Ste. 2100
`Dallas, TX 75201
`Phone: (214) 698-3100
`Additional email for service: Dell-IPRService@gibsondunn.com
`
`
`
`
`
`
`
`
`/s/ Timothy Devlin
` Timothy Devlin
`
`
`
`14
`
`
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