throbber
PGR2020-00088
`Petitioner’s Request for Rehearing
`
`Filed on behalf of Supercell Oy
`
`By:
`BRIAN HOFFMAN, Reg. No. 39,713
`MICHAEL J. SACKSTEDER
`KEVIN X. MCGANN, Reg. No. 48,793
`JENNIFER R. BUSH, Reg. No 50,784
`GREGORY HOPEWELL, Reg. No. 66,012
`GEOFFREY MILLER
`FENWICK & WEST LLP
`555 California Street, 12th Floor
`San Francisco, CA 94104
`Telephone: 415.875.2300
`Facsimile: 415.281.1350
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`SUPERCELL OY,
`Petitioner
`
`v.
`
`GREE, INC.,
`Patent Owner.
`
`
`Case PGR2020-00088
`Patent 10,518,177 B2
`_____________
`
`PETITIONER’S REQUEST FOR REHEARING
`
`
`
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`TABLE OF CONTENTS
`
`Page
`INTRODUCTION AND REQUESTED RELIEF .......................................... 1
`LEGAL STANDARD ..................................................................................... 1
`BASIS FOR THE REQUESTED RELIEF ..................................................... 2
`1.
`The NHK-Fintiv Factors Support Institution......................................... 2
`a.
`The Board’s conclusion regarding Factor 4 rests on
`clearly erroneous fact finding, and also impacts the
`analysis of Factors 2 and 3 ......................................................... 3
`The Board’s conclusion regarding Factor 6 rests on
`clearly erroneous fact finding and is clearly
`unreasonable, arbitrary, or fanciful............................................. 5
`The Board misapprehended or overlooked the proper
`weighing of the Fintiv factors. ................................................... 6
`Exercising Discretion Based on the NHK-Fintiv Factors Is
`Improper ................................................................................................ 7
`CONCLUSION .............................................................................................. 10
`
`
`
`b.
`
`c.
`
`A.
`B.
`C.
`
`D.
`
`
`
`2.
`
`i
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`TABLE OF AUTHORITIES
`
`Page(s)
`
`CASES
`Apple Inc. v. Fintiv, Inc.,
`IPR2020-00019, Paper 11 (P.T.A.B. Mar. 20, 2020) ..................................passim
`Apple Inc. v. Seven Networks, LLC,
`IPR2020-00235, Paper 10 (P.T.A.B. July 28, 2020) ............................................ 6
`Aqua Prods., Inc. v. Matal,
`872 F.3d 1290 (Fed. Cir. 2017) ............................................................................ 8
`Facebook, Inc. v. Blackberry Ltd.,
`IPR2019-00899, Paper 15 (P.T.A.B. Oct. 8, 2019) .............................................. 4
`Facebook, Inc. v. Windy City Innovations, LLC,
`973 F.3d 1321 (Fed. Cir. 2020) ............................................................................ 8
`Intelligent Bio-Systems, Inc. v. Illumina Cambridge Ltd.,
`821 F.3d 1359 (Fed. Cir. 2016) ........................................................................ 1, 6
`NanoCellect Biomedial, Inc., v. Cytonome/ST, LLC,
`IPR2020-00551, Paper 19 (P.T.A.B. Aug. 27, 2020) ........................................... 6
`NHK Spring Co. v. Intri-Plex Techs., Inc.,
`IPR2018-00752, Paper 8 (P.T.A.B. Sept. 12, 2018)............................................. 2
`Oticon Medical AB v. Cochlear Ltd.,
`IPR2019-00975, Paper 15 (P.T.A.B. Oct. 16, 2019) ........................................ 3, 4
`Sand Revolution II, LLC v. Cont’l Intermodal Grp.,
`IPR2019-01393, Paper 24 (P.T.A.B. June 16, 2020) ........................................... 6
`Snap, Inc. v. SRK Technology LLC,
`IPR2020-00820, Paper 15 (P.T.A.B. Oct. 21, 2020) ........................................ 3, 4
`VMWare, Inc. v. Intellectual Ventures I LLC,
`IPR2020-00407, Paper 12 (P.T.A.B. Aug. 18, 2020) ........................................... 6
`
`ii
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`
`
`TABLE OF AUTHORITIES
`(Continued)
`
`Page(s)
`
`
`STATUTES AND RULES
`35 U.S.C. § 314 ...................................................................................................... 3, 9
`35 U.S.C. § 316 ...................................................................................................... 7, 9
`35 U.S.C. § 324 .............................................................................................. 2, 5, 7, 9
`35 U.S.C. § 326(b) ..................................................................................................... 9
`OTHER AUTHORITIES
`37 C.F.R. § 42.71 ....................................................................................................... 1
`The Eleventh Auer: The Effect of Kisor v. Wilkie On Rulemaking and
`Adjudication at the United States Patent and Trademark Office,
`19, Chi.-Kent J. Intell. Prop. 485, 501-502 (2020) ............................................... 8
`
`
`
`
`
`iii
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`EXHIBIT LIST (37 CFR § 42.63(e))
`
`Exhibit
`
`Description
`
`1010
`
`1001 U.S. Patent No. 10,518,177 to Suzuki
`1002 File History of U.S. Patent No. 10,518,177
`1003 U.S. Patent No. 10,583,362
`1004 File History of U.S. Patent No. 10,583,362
`1005 Declaration of Steve Meretzky
`1006 Curriculum Vitae of Steve Meretzky
`1007 GREE’s Amended Disclosure of Asserted Claims and Infringement
`Contentions dated August 19, 2020 in Case No. 2:19-cv-00413-JRG-RSP
`(E.D. Tex.)
`1008 Microsoft Computer Dictionary, 4th Ed. (1999)
`1009 YouTube - Master Hearthstone in 10 Minutes! The Ultimate Beginner’s
`Guide (“MH”) (web page print out from
`https://www.youtube.com/watch?v=CVZ4qyx-c2o)
`“Master Hearthstone in 10 Minutes! The Ultimate Beginner’s Guide,”
`webpage as captured by The Internet Archive on January 2, 2014
`“Master Hearthstone in 10 Minutes! The Ultimate Beginner’s Guide” –
`Video File
`“Master Hearthstone in 10 Minutes! The Ultimate Beginner’s Guide” –
`Transcript
`1013 U.S. Patent Publication No. 2013/0281173 to Gilson et al.
`1014 US Patent Publication No. 2014/0349723 to Nakatani et al.
`1015 U.S. Patent No. 5,662,332 to Garfield
`1016
`“Dynamic game difficulty balancing,” Wikipedia page as captured by
`The Internet Archive on December 12, 2011
`
`1011
`
`1012
`
`iv
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`
`Exhibit
`
`Description
`
`1017
`
`1018
`
`1019
`
`1021
`
`“And That’s A Wrap! BlizzCon 2013 Has Officially Come to an End!”
`webpage as captured by the Internet Archive on Nov. 16, 2013
`“FAQ – Hearthstone” webpage as captured by the Internet Archive on
`Nov. 16, 2013
`“Hearthstone: Heroes of Warcraft Official Game Site” webpage as captured
`by the Internet Archive on Nov. 16, 2013
`1020 GREE, Inc.’s Opposition to Defendant Supercell Oy’s Motion to Dismiss,
`Dkt. No. 34, Filed April 8, 2020, Case No. 2:19-cv-00413-JRG-RSP (E.D.
`Texas)
`[Model] Order Focusing Patent Claims and Prior Art to Reduce Costs,
`retrieved from
`http://www.txed.uscourts.gov/sites/default/files/forms/ModelPatentOrder.pdf
`1022 Declaration of Madeline Byers, Custodian of Records for Google LLC
`1023 Affidavit of Elizabeth Rosenberg, Records Processor at the Internet Archive
`1024 Declaration of Jennifer R. Bush in Support of Supercell Oy’s Reply to Patent
`Owner’s Preliminary Response
`
`
`
`v
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`INTRODUCTION AND REQUESTED RELIEF
`A.
`Pursuant to 37 C.F.R. § 42.71, Petitioner Supercell Oy (“Supercell” or
`
`“Petitioner”) respectfully requests rehearing of the Board’s Decision Denying
`
`Institution of Inter Partes Review of U.S. Patent No. 10,518,177 (the “’177 Patent”)
`
`(Paper 11) (“Decision”) because the Board “misapprehended or overlooked” matters
`
`addressed by the Petition and thus abused its discretion in denying institution.
`
`See 37 C.F.R. § 42.71(c) and (d). Specifically, the Board misapprehended the impact
`
`of the lack of overlap between the issues in the district court and this proceeding and
`
`improperly weighed the Fintiv factors to deny institution.
`
`B.
`
`LEGAL STANDARD
`A request for rehearing “must specifically identify all matters the party
`
`believes the Board misapprehended or overlooked, and the place where each matter
`
`was previously addressed in a motion, an opposition, [or] a reply.” 37 C.F.R.
`
`§ 42.71(d). “When rehearing a decision on petition, a panel will review the decision
`
`for an abuse of discretion.” 37 C.F.R. § 42.71(c). “An abuse of discretion is found if
`
`the decision: (1) is clearly unreasonable, arbitrary, or fanciful; (2) is based on an
`
`erroneous conclusion of law; (3) rests on clearly erroneous fact finding; or
`
`(4) involves a record that contains no evidence on which the Board could rationally
`
`base its decision.” Intelligent Bio-Systems, Inc. v. Illumina Cambridge Ltd., 821
`
`F.3d 1359, 1367 (Fed. Cir. 2016).
`
`1
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`C. BASIS FOR THE REQUESTED RELIEF
`The NHK-Fintiv Factors Support Institution
`1.
`The Board relied on the multi-factor test set forth in the precedential
`
`NHK Spring decision and Fintiv order in reaching its decision to deny institution.
`
`See generally Decision at 5-14; NHK Spring Co. v. Intri-Plex Techs., Inc.,
`
`IPR2018-00752, Paper 8 (P.T.A.B. Sept. 12, 2018) (precedential); Apple Inc. v.
`
`Fintiv, Inc., IPR2020-00019, Paper 11 (P.T.A.B. Mar. 20, 2020) (precedential). In
`
`its analysis, the Board concluded that Factors 1 (stay) and 6 (other circumstances,
`
`including
`
`the merits) were neutral, and Factors 2 (proximity of
`
`trial),
`
`3 (investment), 4 (overlap), and 5 (parties) weighed in favor of Patent Owner,.
`
`Decision at 13. Ultimately, the Board concluded that “the trial date, investment,
`
`overlap, and same parties factors outweigh facts that may support exercising
`
`discretion to deny institution.” Id. Therefore, the Board determined “the inefficient
`
`duplication of efforts here is likely. Accordingly, we determine that the
`
`circumstances presented weigh in favor of institution under 35 U.S.C. § 324(a).” Id.
`
`However, the Board overlooked or misapprehended facts regarding Factors
`
`4 and 6, and their impact on Factors 2 and 3 that, when properly considered, tip the
`
`balance in favor of institution.
`
`2
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`The Board’s conclusion regarding Factor 4 rests on clearly
`a.
`erroneous fact finding, and also impacts the analysis of
`Factors 2 and 3
`The Board’s conclusion that there is substantial overlap between the art and
`
`arguments in this proceeding and the parallel litigation is clearly erroneous, when
`
`case precedent and the facts are properly considered.
`
`“[T]he Board proceeding would not be directly duplicative of the District
`
`Court[’s] consideration of validity” here, as in the Oticon case. Oticon Medical AB
`
`v. Cochlear Ltd., IPR2019-00975, Paper 15 at 23-24 (P.T.A.B. Oct. 16, 2019)
`
`(Precedential). In Oticon, Patent Owner “acknowledge[d]
`
`that
`
`the Board
`
`proceeding would not be directly duplicative of the District Court consideration of
`
`validity,” which weighed in favor of institution. Id. Similar facts are present here.
`
`In its POPR, GREE acknowledges that inclusion of Master Hearthstone in the
`
`Petition – which is not applied in litigation – makes the Overlap factor favor
`
`institution. Prelim. Resp. at 30.
`
`Likewise, in Snap, Inc. v. SRK Technology LLC, IPR2020-00820, Paper 15
`
`at 19 (P.T.A.B. Oct. 21, 2020) (Precedential as to § II.A.), the Board declined to
`
`exercise its discretion under § 314(a) when a reference cited in the Petition was not
`
`at issue in the litigation. See Snap at 15. The new reference in the IPR rendered “the
`
`prior art and arguments included in the Petition [] materially different than those
`
`presented in the District Court.” Snap at 15 (emphasis added). The same type of
`
`3
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`material difference is present here since the PGR contains a primary reference –
`
`Master Hearthstone – not applied in the district court. The overlap is therefore
`
`minimal.
`
`Thus, the Board’s conclusion that the overlap of Ground 2 based on Gilson
`
`alone – which is not a primary reference in this proceeding, but is merely used to
`
`show it was known to play a battle card game using the generic computer-related
`
`limitations recited by the claims – is inconsistent both with the positions of both
`
`parties, and with the precedential decisions in Oticon and Snap.
`
`Further, due to the minimal overlap, key issues in the Petition will not be
`
`resolved in the parallel proceeding, in particular the fact that the primary reference
`
`asserted in Ground 2 – “Master Hearthstone” – is invalidating prior art.
`
`In addition to the non-overlapping art and arguments, only 11 claims remain
`
`in the district court proceeding, whereas all of the claims are challenged in this
`
`proceeding. Further, GREE very likely will drop claims before trial, as they have
`
`done in the past, and as instructed under the E.D. Tex. Model Order Focusing
`
`Patent Claims. Ex. 1021 at 2. The Petition
`
`thus presents significant
`
`non-overlapping claim challenges – and the overlap is likely to decrease ahead of
`
`trial – which weighs against discretionary denial. See Facebook, Inc. v. Blackberry
`
`Ltd., IPR2019-00899, Paper 15 at 12 (P.T.A.B. Oct. 8, 2019).
`
`4
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`These issues impact not just Factor 4 where the Board considered them, but
`
`Factors 2 and 3 as well, since they reduce the likelihood of “inconsistent results” in
`
`the district court. When the lack of overlap is properly considered, the facts weigh
`
`in favor of institution.
`
`b.
`
`The Board’s conclusion regarding Factor 6 rests on clearly
`erroneous fact finding and is clearly unreasonable, arbitrary,
`or fanciful.
`The Board’s analysis regarding Factor 6 appears to disregard precedent
`
`regarding the impact of the “merits” on Factor 6 in the Fintiv analysis. The Board
`
`found that “Petitioner’s challenge based on § 101 has merit” and “based on § 103
`
`also has merit,” yet concluded that “the facts underlying this factor are neutral.”
`
`Decision at 13. The standard for institution is whether it is “more likely than not
`
`that at least 1 of the claims challenged in the petition is unpatentable” based on the
`
`petition as filed. 35 U.S.C. § 324. Here, the Board concluded that Petitioner did in
`
`fact establish that at least one of the claims challenged in the petition is
`
`unpatentable, yet somehow still found this factor “neutral.” Decision at 13.
`
`This conclusion is inconsistent with the Fintiv case itself, on which these
`
`factors are based. In Fintiv, the Board stated, “if the merits of a ground raised in
`
`the petition seem particularly strong on the preliminary record, this fact has
`
`favored institution.” Fintiv, Paper 11 at 14–15. Fintiv states that institution in such
`
`an instance “may serve the interest of overall system efficiency and integrity.” Id.
`
`5
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`Here, Petitioner has established that not just “a ground” has merit, but both
`
`grounds do. It should follow that these facts should favor institution. Since the
`
`Board came to the opposite conclusion, contrary to many cases and to Fintiv itself,
`
`this conclusion is “clearly unreasonable, arbitrary, or fanciful,” and thus constitutes
`
`an “abuse of discretion” under Intelligent Bio-Systems, 821 F.3d at 1367. Under a
`
`proper rationale, Factor 6 weighs in favor of institution.
`
`c.
`
`The Board misapprehended or overlooked the proper
`weighing of the Fintiv factors.
`The Board misapprehended or overlooked the weighing of the factors when
`
`conducting the holistic analysis of Fintiv, used reasoning that was clearly
`
`unreasonable, arbitrary, or fanciful, and came to its ultimate conclusion based on
`
`erroneous findings of fact. In particular, Factors 4 and 6 especially should weigh in
`
`favor of institution under the correct reasoning.
`
`The Board previously has found Factors 4 and 6 to be definitive in reaching
`
`its decisions to institute, regardless of its findings regarding other factors. See, e.g.,
`
`Sand Revolution II, LLC v. Cont’l Intermodal Grp., IPR2019-01393, Paper 24 at 9
`
`(P.T.A.B. June 16, 2020) (Informative); Apple Inc. v. Seven Networks, LLC,
`
`IPR2020-00235, Paper 10 (P.T.A.B. July 28, 2020); NanoCellect Biomedial, Inc., v.
`
`Cytonome/ST, LLC, IPR2020-00551, Paper 19 (P.T.A.B. Aug. 27, 2020); VMWare,
`
`Inc. v. Intellectual Ventures I LLC, IPR2020-00407, Paper 12 (P.T.A.B. Aug. 18,
`
`6
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`2020). Here, Factors 4 and 6 are likewise strong, and the Board should institute this
`
`PGR consistent with its prior decisions.
`
`The Board appears to have misapprehended or overlooked the similarity of
`
`case precedent in which Factors 4 and 6 carried great import in whether to apply
`
`discretion to denial institution.
`
`As discussed above, when correctly considered, Factors 4 and 6 each weigh
`
`in favor of institution, which in turn impact Factors 2 and 3, which collectively
`
`outweigh Factors 1 (neutral) and 5 (weighs towards denial). Thus, when fully
`
`considered, the holistic analysis favors institution.
`
`2.
`
`Exercising Discretion Based on the NHK-Fintiv Factors Is
`Improper
`In fact, the entire NHK-Fintiv framework relied on by the Board to deny
`
`institution is improper. Section § 324(a) sets forth the requirements for the Director
`
`to institute PGR; it does not grant the Director authority to create new tests for
`
`denying institution. See 35 U.S.C. § 324(a) (“The Director may not authorize a
`
`post-grant review to be instituted unless…”). Rather, 35 U.S.C. § 316(a)(2)
`
`requires the Director to prescribe regulations “setting forth the standards for the
`
`showing of sufficient grounds to institute a review.”
`
`The Director has not prescribed regulations setting forth the standards used
`
`by the Board to deny institution of the instant Petition. Neither the precedential
`
`decision and order of NHK-Fintiv nor the 2019 Consolidated Trial Practice Guide
`
`7
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`(“2019 TPG”) are regulations. See Andrew Schneider & Jonathan Stroud, The
`
`Eleventh Auer: The Effect of Kisor v. Wilkie On Rulemaking and Adjudication at
`
`the United States Patent and Trademark Office, 19 Chi.-Kent J. Intell. Prop. 485,
`
`501-502 (2020) (finding that neither the 2019 TPG nor the SOP 2, which includes
`
`guidance on the process for designating PTAB decisions as precedential, are the
`
`result of notice-and-comment rulemaking). Moreover, the Court of Appeals for the
`
`Federal Circuit has expressly found that precedential opinions are not regulations
`
`within the context of § 316(a), stating that “[t]here is no indication in the statute
`
`that Congress either intended to delegate broad substantive rulemaking authority to
`
`the Director to interpret statutory provisions through POP opinions or intended him
`
`to engage in any rulemaking other than through the mechanism of prescribing
`
`regulations.” Facebook, Inc. v. Windy City Innovations, LLC, 973 F.3d 1321, 1350
`
`(Fed. Cir. 2020) (additional views by Prost, C.J., Plager & O’Malley, J.J.).
`
`The NHK-Fintiv framework is thus procedurally invalid because it prescribes
`
`a new standard for institution but was not promulgated via the requisite regulation.
`
`The “Patent Office cannot effect an end-run around its congressionally delegated
`
`authority by conducting rulemaking through adjudication without undertaking the
`
`process of promulgating a regulation.” Aqua Prods., Inc. v. Matal, 872 F.3d 1290,
`
`1339 (Fed. Cir. 2017) (separate opinion of Reyna & Dyk, J.J.). Any rule “resulting”
`
`from such evasion of the congressionally specified process “is a nullity.” Id. at 1338.
`
`8
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`This invalid framework is apparent from the Patent Office’s own writings.
`
`Fintiv states that “in evaluating the factors, the Board takes a holistic view of
`
`whether efficiency and integrity of the system are best served by denying or
`
`instituting review. See 2019 TPG at 58 (quoting 35 U.S.C. § 316(b)).” Fintiv at 6.
`
`The portion of the 2019 TPG cited by Fintiv states, in relevant part: “There may be
`
`other reasons besides the ‘follow-on’ petition context where the ‘effect . . . on the
`
`economy, the integrity of the patent system, the efficient administration of the
`
`Office, and the ability of the Office to timely complete proceedings,’ 35 U.S.C.
`
`§ 316(b), favors denying a petition even though some claims meet the threshold
`
`standards for institution under 35 U.S.C. §§ 314(a), and 324(a).” 2019 TPG at 58.
`
`However, as discussed above, both §§ 316(b) and 326(b) require the Director
`
`to consider “the economy, the integrity of the patent system, [and] the efficient
`
`administration of the Office” “[i]n prescribing regulations.” 35 U.S.C. §§ 316(b),
`
`326(b) (emphasis added). Thus, the 2019 TPG misstates the law by using the
`
`economy, integrity, and efficiency factors outside the context of regulation. It is
`
`improper for the Director, and the Board, to deny institution based on these
`
`considerations absent properly-promulgated regulations. Hence, the Board, in its
`
`reliance on “binding precedent” to exercise its discretion to deny institution of a
`
`meritorious petition, has overlooked or misunderstood the law.
`
`9
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`D. CONCLUSION
`Petitioners respectfully request that the Board rehear the Decision and grant
`
`institution based on all grounds raised in the Petition.
`
`
`
`Dated: May 14, 2021
`
`Respectfully submitted,
`FENWICK & WEST LLP
`
`/Jennifer R. Bush/
`Jennifer R. Bush
`Reg. No. 50,784
`Attorneys for Petitioner Supercell Oy
`
`
`
`10
`
`

`

`PGR2020-00088
`Petitioner’s Request for Rehearing
`CERTIFICATION OF SERVICE ON PATENT OWNER
`
`The undersigned hereby certifies that the foregoing Petitioner’s Request for
`
`Rehearing was served on Patent Owner’s lead and back-up counsel in its entirety by
`
`electronic service at the email addresses provided below:
`
`Andrew W. Rinehart
`Kilpatrick Townsend & Stockton LLP
`1001 West Fourth Street
`Winston-Salem, NC 27101
`arinehart@kilpatricktownsend.com
`
`Scott A. McKeown
`Ropes & Gray
`2099 Pennsylvania Avenue, N.W.
`Washington, D.C. 2006
`scott.mckeown@ropesgray.com
`
`
`FENWICK & WEST LLP
`
`/Jennifer R. Bush/
`Jennifer R. Bush
`Reg. No. 50,784
`Attorneys for Petitioner Supercell Oy
`
`
`
`
`
`
`John C. Alemanni
`Kilpatrick Townsend & Stockton LLP
`4208 Six Forks Road, Suite 1400
`Raleigh, NC 27609
`jalemanni@kilpatricktownsend.com
`
`Joshua H. Lee
`Kilpatrick Townsend & Stockton LLP
`1100 Peachtree Street NE, Suite 2800
`Atlanta, GA 30309-6582
`jlee@kilpatricktownsend.com
`
`Dated: May 14, 2021
`Fenwick & West LLP
`801 California Street
`Mountain View, CA 94041
`Telephone: (650) 988-8500
`
`
`
`
`11
`
`

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