UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` PELICAN BIOTHERMAL, )
` )
` Petitioner, )
` )
` vs. )
` )
` VA-Q-TEC, )
` )
` Patent Owner. )
`
` CASE NO. PGR2021-00085
` Conference Call held before Administrative Patent
`Judges TIMOTHY G. MAJORS, JOHN G. NEW, ROBERT A.
`POLLOCK, held via telephone conference and transcribed
`by Nicole Marie DeBartolo, CSR, RPR, a Licensed
`Shorthand Reporter, on Thursday, October 14, 2021,
`9:00 a.m. Central Standard Time.
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`www.veritext.com
`
`Veritext Legal Solutions
`
`888-391-3376
`
`PGR2021-00085
`Pelican EX1049
`
`

`

`1 APPEARANCES VIA TELEPHONE:
`2 FOLEY & LARDNER
` MR. MICHAEL R. HOUSTON
`3 321 North Clark
` Suite 3000
`4 Chicago, Illinois 60654
` Phone: 312.832.4500
`5 E-Mail: mhouston@foley.com
`6 - and -
`7 FOLEY & LARDNER
` MR. TED R. RITTMASTER
`8 555 South Flower Street
` Suite 3300
`9 Los Angeles, California 90071
` Phone: 213.972.4500
`10 E-Mail: trittmaster@foley.com
`11 On behalf of the Petitioner;
`12 ANDRUS INTELLECTUAL PROPERTY LAW, LLP
` MR. AARON T. OLEJNICZAK
`13 790 North Water Street
` Suite 2200
`14 Milwaukee, Wisconsin 53202
` Phone: 414.271.7590
`15 E-Mail: aarono@andruslaw.com
`16 On behalf of the Patent Owner.
`17
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` * * * * * * *
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`Page 2
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`Page 4
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`1 will let introduce herself.
`2 MR. RITTMASTER: And that was correct. This is Ted
`3 Rittmaster. Sorry to interrupt.
`4 THE COURT: No problem.
`5 And the court reporter is on?
`6 THE REPORTER: Yes. Nicole DeBartolo with
`7 Veritext.
`8 THE COURT: Nice to talk to everyone for the first
`9 time.
`10 Court Reporter, if you -- if we cut out at any
`11 point or you are having difficulty hearing any of us,
`12 just -- just speak up. That way we'll get a clean
`13 record.
`14 So we're here today for a conference call
`15 requested by Petitioner in PGR2021-00085, case of
`16 Pelican BioThermal versus va-Q-tec? Is that the right
`17 way to pronounce your client?
`18 MR. OLEJNICZAK: That's correct, yes.
`19 THE COURT: All right. And Petitioner, you
`20 requested the call. We did look at the e-mail that was
`21 sent and Patent Owner's response to the e-mail. It
`22 looks like you want a short preliminary reply to address
`23 something in the area of claim construction.
`24 So what we'll do is we'll open the floor up
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`Page 3
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`Page 5
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`1 THE COURT: The Panel is on. This is Judge Majors
`2 and on with me are Judges New and Pollock.
`3 I heard some talking in the background, but if
`4 counsel could please identify themselves, including the
`5 party they represent.
`6 MR. OLEJNICZAK: Good morning. This is attorney
`7 Aaron Olejniczak from Andrus Intellectual Property Law.
`8 I represent the Patent Owner, va-Q-tec.
`9 THE COURT: Good morning. Pronounce your name one
`10 more time.
`11 MR. OLEJNICZAK: Olejniczak.
`12 THE COURT: Olejniczak. I apologize if I butcher
`13 that a few times.
`14 MR. OLEJNICZAK: It's a constant struggle that I've
`15 dealt with over my practice, so no concerns.
`16 THE COURT: Okay. And any other -- anybody else on
`17 for Patent Owner?
`18 MR. OLEJNICZAK: No one else.
`19 THE COURT: Okay.
`20 MR. HOUSTON: And good morning, your Honor. This
`21 is Michael Houston of Foley & Lardner on for Petitioner,
`22 Pelican BioThermal, and I believe I have my colleague
`23 Ted Rittmaster on as well.
`24 And we also have a court reporter on, who I
`
`1 first to Petitioner; Patent Owner, then you'll have an
`2 opportunity to respond; if necessary, then we can come
`3 back to Petitioner and see if there are any further
`4 clarifications or questions. We may jump in and ask
`5 some questions ourselves. We'll -- the Panel will
`6 likely then either drop off or at least put everybody
`7 else on hold so that we can discuss and see if we can
`8 resolve this on the phone.
`9 So with that, Mr. Houston, I assume you're
`10 going to be doing the speaking for Petitioner's part?
`11 MR. HOUSTON: Yes, your Honor. Thank you.
`12 THE COURT: Okay. So you can start whenever you're
`13 ready.
`14 MR. HOUSTON: Thank you, your Honor.
`15 Yes, so Petitioner seeks -- asked for this
`16 phone call to seek leave to file a reply to the Patent
`17 Owner preliminary response under 37 CFR 42.108(c).
`18 The good-cause basis for Petitioner's request
`19 is to address what we view as new claim construction --
`20 new claim constructions proposed by Patent Owner in
`21 their preliminary response. Specifically the claim
`22 construction positions that we would like to address are
`23 directed -- are expressly directed to two terms, and
`24 those two terms are -- the first one is, quote, "corner
`2 (Pages 2 - 5)
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`PGR2021-00085
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`
`

`

`Page 6
`1 protector elements," end quote, and the second one is,
`2 "a cover."
`3 The -- the preliminary response proposed
`4 constructions and took claim construction positions on
`5 those two terms that Petitioner has not had a chance to
`6 address, and we would like to have a chance to briefly
`7 address those in a reply.
`8 There's a third term that we would also seek
`9 to include in our reply, and that term is, if I shorten
`10 it, the actual term is, quote, "covering surfaces of the
`11 side walls."
`12 And by the way, your Honors, all three of
`13 these terms do appear in Claim 1. I suspect they appear
`14 in some of the other claims. I don't have a full
`15 listing of all the claims that appear, but they can be
`16 found in Claim 1.
`17 That third term, "covering the surfaces of
`18 side walls," is the one that the preliminary response
`19 did not take an express position on in the claim
`20 construction section of the brief, but it is our view
`21 that the Patent Owner very much did advance --
`22 effectively advance a claim construction for that term
`23 when it attempted to distinguish the prior art based on
`24 that term or that phrase. And it did that in -- in I
`
`Page 8
`1 It would have required a more complete disassembly of
`2 that product and, thereby, essentially destroyed it as
`3 the -- as the single sample of an old prior art product
`4 that we were able to locate.
`5 And so we would just like to put that on the
`6 record regarding the photos that are in the petition and
`7 the reason why it was not further disassembled to show
`8 more complete pictures.
`9 Your Honors, for all of those issues, the
`10 claims construction issues as well as the last one I
`11 just mentioned, I want to emphasize for Petitioner that
`12 we do not seek to introduce any new evidence. We will
`13 not seek to introduce any new photos, we are not
`14 introducing any testimony, nothing of the sort. So we
`15 are not attempting to seek to introduce any new
`16 evidence. We just want to reply to those arguments in
`17 the Patent Owner preliminary response and take a
`18 position on those for the Board's benefit.
`19 We think we can do that in a fairly short
`20 reply. I was -- I have in mind a five-page reply. So I
`21 think that is what Petitioner is requesting from our
`22 end. And that is everything unless for whatever reason
`23 the Board has identified any issues upon reviewing the
`24 papers that it would ask us to further address. I've
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`Page 7
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`Page 9
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`1 think for all three of the major grounds of invalidity
`2 based on prior art. And so while they didn't provide an
`3 express construction for that term, we felt like the --
`4 they, in effect, did advance a construction of that
`5 term, which we would seek to address as well.
`6 Your Honors, besides those three claim
`7 construction issues, there's one additional issue the
`8 Petitioner would seek to put on the record in its reply,
`9 and that has to do with the significant argument that's
`10 included in the preliminary response alleging that the
`11 petition doesn't show the bottom VIP panels in the prior
`12 art product that was the basis for the petition, the
`13 98596 prior art product. And just for context for the
`14 Board, that was the product that the Petitioner found in
`15 its display case. So it's the -- a prior art product
`16 from the -- before the priority date.
`17 And what we would like to put on the record,
`18 your Honors, as -- as regards to that is to point out
`19 that there are pictures of the bottom panels of that
`20 product in the petition, No. 1; and No. 2, we'd further
`21 like to put on the record that the reason there are not
`22 more detailed pictures is because that would
`23 have eventually -- essentially amounted -- required, I
`24 should say, required destructive testing, if you will.
`
`1 never -- I've never had that happen, but I wanted to
`2 mention it just in case the Board would like us to
`3 address something additional.
`4 Thank you, your Honors.
`5 THE COURT: Okay. Thank you, Mr. Houston.
`6 I will confess, at least for my part, I'm
`7 really not in a position just yet to -- to have delved
`8 into the record all that thoroughly to ask you any
`9 questions. That doesn't mean I won't at some point, but
`10 I did look briefly at the -- since I saw that this was
`11 related to claim construction issues.
`12 So it looks like, if I could just play back
`13 quickly some of what you said, there is a -- a dispute
`14 concerning a -- the limitation, which I -- I did see
`15 that there was a construction offered by Petitioner for
`16 the corner protection elements, I think is the term.
`17 That -- it seems like Patent Owner disputes that that
`18 should be a means-plus-function term, and -- but even if
`19 it is, disagrees with the structure that Petitioner has
`20 cited as corresponding to the function. So you want
`21 some briefing on that.
`22 There's a limitation concerning a cover, that
`23 I gather, just because that was not expressly construed
`24 in the petition, but looks like Patent Owner is offering
`3 (Pages 6 - 9)
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`PGR2021-00085
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`
`

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`Page 10
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`1 some interpretation of it.
`2 What -- what sometimes gets problematic, I'll
`3 just sort of forecast this, would be if Petitioner was
`4 going to, you know -- sort of would read the papers and
`5 say: Okay, if they're not offering express construction
`6 for the cover term, you must just be applying a -- just
`7 a kind of plain, ordinary meaning of the language
`8 itself.
`9 Where this can sometimes get problematic is if
`10 the Petitioner then comes in and says: Well, you know,
`11 now we actually want to give you some sort of express
`12 construction for it in a preliminary stage. I'm not --
`13 maybe you're not doing that. Maybe you just want to
`14 say: No, it's plain meaning and what Patent Owner said
`15 is, you know, for reading limitations into the language
`16 is -- something to that effect. Well, let me put a
`17 Post-it note on that for a second and come back to it in
`18 a second.
`19 And then there's another term, "covering
`20 surfaces of side walls," for which you say there's an
`21 implicit construction being advanced by Patent Owner,
`22 you wanted to talk about that. And then as you said
`23 before, you think you have an explanation for why
`24 there's not a more detailed discussion around, I guess,
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`Page 11
`1 certain parts of a preexisting -- or alleged preexisting
`2 product that -- whether that satisfies one of the claim
`3 elements.
`4 Is that -- did I miss anything.
`5 MR. HOUSTON: That's generally correct, your Honor.
`6 And thank you. You caught I think I -- for
`7 one claim term, I did say "corner protector elements,"
`8 it's "corner protection elements." Thank you for
`9 catching that.
`10 On that term, your Honor, not only does Patent
`11 Owner dispute whether that should be a
`12 means-plus-function term, they also do advance their own
`13 proposed construction for that term. So there's that --
`14 kind of that added nuance there for that one.
`15 Regarding "a cover," your Honor, I don't know
`16 that we would need to advance a construction. The --
`17 the dispute is really going to focus around the meaning
`18 of the word "a" or "ah" in that phrase. I'm not sure it
`19 would require construction on that point, but
`20 anticipating what your Honor's concern was for that, we
`21 certainly wouldn't oppose giving Patent Owner the
`22 five-page sur-reply, which I understand is reasonably
`23 common if a petitioner reply is granted. So we could
`24 perhaps address it that way.
`
`1 By anyway, thank you, you Honor. You
`2 summarized the issues, captured the issues just right.
`3 Thank you.
`4 THE COURT: Okay. All right. So unless there's
`5 anything else at the moment, I'll open the floor up to
`6 Mr. Olejniczak.
`7 MR. OLEJNICZAK: Olejniczak. Thank you, your
`8 Honor.
`9 THE COURT: Olejniczak.
`10 MR. OLEJNICZAK: So our position is relatively
`11 straightforward, and I'm sure you can anticipate where
`12 we are coming from.
`13 The -- the -- the PGR process is set out so
`14 that the Petitioner must establish their case in their
`15 petition requesting institution, and Patent Owner has
`16 the opportunity to take advantage of a preliminary
`17 reply, which we did to clarify or address certain
`18 positions that the Petitioner takes in their initial
`19 petition. And that's precisely what we did here.
`20 There was a corner protection element issue
`21 that -- claim construction that was raised. We
`22 addressed that. We did submit our own construction. We
`23 feel that the Board is entirely capable of reviewing the
`24 computing constructions and the intrinsic evidence and
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`Page 13
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`1 deducing the proper construction for that claim.
`2 With regard to a cover, we did advance a
`3 construction there. It's noted that the Petitioner did
`4 not advance a particular construction and, therefore,
`5 did address the common and ordinary meaning of the term
`6 when they were addressing the prior art. Again, if the
`7 argument is about what "a" means, that is something that
`8 I think can be resolved without additional briefing
`9 based on the record.
`10 Finally, the covering surface of the side
`11 walls issue, we did not advance a construction there.
`12 We did not advance an implicit construction. Simply
`13 stated, that is an element that when you take the common
`14 and ordinary meaning of the claim language, it
`15 distinguishes the claim language from the prior art
`16 asserted, and that's simply the purpose of these
`17 preliminary responses, namely to identify where the
`18 Petitioner's arguments fail in certain respects. That
`19 is simply all that we did here and we do not believe
`20 that the Petitioner should be allowed to pivot and
`21 potentially change their arguments or argue around their
`22 initial positions based on -- on arguments that we have
`23 made for why the petition should not be instituted.
`24 And then, finally, on the -- the issue of
`4 (Pages 10 - 13)
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`

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`Page 14
`1 these pictures and the destruction of evidence, again,
`2 this is something that -- that could have been
`3 anticipated by the Petitioner. If there was an issue
`4 that needed to be addressed, that could have been set
`5 forth in the petition.
`6 I understand that the Petitioner wants to add
`7 statements but somehow not introduce new testimony or
`8 new evidence. I'm unsure how that would take place, and
`9 it seems like something that would be outside of the
`10 scope of -- of the replies that are typically granted
`11 by -- by the PTAB.
`12 So for all those reasons, counsel and the
`13 Patent Owner, va-Q-tec, opposes this request for a
`14 reply. And if any reply would be granted, we would
`15 respectfully respect the opportunity for a commensurate
`16 sur-reply.
`17 THE COURT: Okay. Thank you, Mr. Olejniczak.
`18 Again, sorry if I keep messing that up. I'll get it at
`19 some point, I promise.
`20 Petitioner, I'll give you about 30 seconds if
`21 you want to say anything in response.
`22 MR. HOUSTON: Sure, your Honor.
`23 I think the main point I would like to make in
`24 response to Patent Owner's argument is that we don't
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`Page 15
`1 intend to change our positions, we don't intend to sort
`2 of make fresh arguments. This really is directed at
`3 replying to arguments advanced by Patent Owner. Of
`4 course, these are the first time we have seen these
`5 arguments on claim construction. Of course, we also
`6 tried to anticipate what claim construction might be
`7 considered by Patent Owner or considered by the Board,
`8 but nonetheless, here we have a brief that advances
`9 claim construction positions that just, you know, could
`10 not effectively have been anticipated the way they were
`11 positioned.
`12 So I do think this amounts to a situation that
`13 merits a reply. It's really for the benefit of the
`14 Board to have the legal issue of claim construction a
`15 bit more fleshed out by both sides, and we think it's
`16 justified simply because Petitioner hasn't had a chance
`17 to address the legal positions advanced by Patent Owner
`18 with respect to those claim construction positions.
`19 So I just want to emphasize we don't intend to
`20 change our arguments, add any new arguments. That's
`21 what we are seeking here. I think that addresses it,
`22 your Honor.
`23 Regarding the pictures and the -- the
`24 potential destruction of evidence, your Honor, we would
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`Page 16
`1 point to a footnote in the Declarant's testimony simply
`2 to support our argument. So again, there we don't
`3 intend to introduce any new factual evidence. We just
`4 want to point out what is already in the papers, albeit,
`5 didn't use the word "destructive testing," which we
`6 think goes a little bit more to a legal concept,
`7 destruction of evidence, so we just want to link up
`8 that -- the legal concept there with what's already in
`9 the papers.
`10 That's everything, your Honor.
`11 THE COURT: Okay. All right. Thank you. I'm
`12 going to put everyone on hold for hopefully it won't be
`13 too long, talk to the other two judges, and see if we
`14 can get you a decision. Just be patient with us here.
`15 Hold on.
`16 (A short recess was had.)
`17 THE COURT: Thank you, again. We're back.
`18 Okay. Here's what we're going to do:
`19 Petitioner's request for authorization is going to be
`20 granted, five pages to cover the issues that we talked
`21 about; however, just be forewarned, that, you know, we
`22 will be looking to see whether something is, you know,
`23 truly new argument, and not, again, saying that that's
`24 what the intent is, or new evidence -- no new evidence
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`Page 17
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`1 will be submitted.
`2 So for example, just hitting on that last
`3 issue, Mr. Houston, about where the -- the Panel's
`4 limitation, I guess, or wherever that was cited, you
`5 know, you can point to: Okay. Here's where we --
`6 here's where said in the petition that this element is
`7 met with, you know, evidence that's in the record,
`8 but -- but no new evidence on the matter.
`9 As far as the covering surface of the side
`10 wall's issue, again, I think it's fair game for you to
`11 say: Well, we've established that that element is met.
`12 We showed that in the petition. They -- you know,
`13 whatever your argument may be, but Patent Owner has got
`14 a -- maybe a narrower view of -- of that language as --
`15 implicit in there, their argument.
`16 That's the type of thing that I would
`17 anticipate, not something where, again, all of a sudden
`18 you're saying: Well, covering surface of the side walls
`19 should actually be, you know, construed to be X, Y,
`20 and Z.
`21 So with that -- and since the page numbers are
`22 short, I think you're going to have to pick your battles
`23 as far as where you want to focus on.
`24 Patent Owner, you're going to get a
`5 (Pages 14 - 17)
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`PGR2021-00085
`Pelican EX1049
`
`

`

`Page 18
`1 commensurate sur-reply to respond to whatever Petitioner
`2 puts forth in their paper.
`3 And again, I -- I do hear you, Patent Owner,
`4 on the need to -- for Petitioner to make out their case
`5 in the petition. On the other hand, at least for my
`6 part, I've been burned before in letting claim
`7 construction issues fester at the institution stage and
`8 then you end up fighting about it at the hearing or even
`9 beyond that.
`10 So in that light, again, assuming it's still
`11 within the realm of what was argued specifically in the
`12 petition, it's -- we're of the view that it's better to
`13 figure that out early and see which way that directs us
`14 as far as an institution decision.
`15 As far as timing is concerned, is a week for
`16 the reply sufficient time, Petitioner?
`17 MR. HOUSTON: Your Honor, in general, yes. I was
`18 wondering, I am scheduled to be out of the office a week
`19 from today. I was wondering if we might have until the
`20 Monday after? So that would be six business days
`21 instead of five. Actually, I'm sorry. I'm looking at
`22 my calendar. I've had quite a week. I'm mixed up on my
`23 days. I'm actually scheduled to be out next week
`24 Thursday and Friday, so I was going to ask if we could
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`Page 20
`1 THE COURT: Okay. Thank you everyone. Appreciate
`2 it. And the call is adjourned.
`3 MR. HOUSTON: Your Honor, I'm sorry. I do have one
`4 more thing. I'm sorry. I just realized.
`5 Would you like the transcript from this call
`6 to be filed as an exhibit? I believe that's the typical
`7 practice, but I -- I don't know. It's something I can
`8 speak up and ask that question.
`9 THE COURT: That's fine. I'm glad you raised that.
`10 Just to be clear, however, whatever was
`11 discussed on today's call is not -- it's not going to be
`12 argument that's considered for purposes of the
`13 institution decision. I just want to make that also
`14 clear. So I wouldn't expect or want any citation to
`15 what was discussed today, but it's -- it's primarily to
`16 resolve the dispute and put everyone on notice of the
`17 due dates going forward.
`18 MR. HOUSTON: Okay. Thank you, your Honor.
`19 THE COURT: Okay. All right. Thank you, again,
`20 everyone.
`21 MR. OLEJNICZAK: Thank you. Have a great day.
`22 (Which were all the proceedings had in
`23 the above-entitled matter.)
`24
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`Page 21
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`1 STATE OF ILLINOIS )
` ) SS:
`2 COUNTY OF COOK )
`
`34
`
` I, NICOLE MARIE DeBARTOLO, a Certified
`5 Shorthand reporter of the State of Illinois, do hereby
`6 certify that I reported in shorthand the proceedings had
`7 at the teleconference hearing aforesaid and that the
`8 foregoing is a true, complete, and correct transcript of
`9 the proceedings of said hearing as appears from my
`10 stenographic notes so taken and transcribed by me.
`11 IN WITNESS WHEREOF, I do hereunto set my hand
`12 at this 2nd day of November, 2021.
`13
`14
`rerererererrerererererererererererererere%>%>>%>%>%>%>%>%>%>%>%>%>%>%>%>%>%>%>>%
`15 <%20304,Signature%>
`NICOLE MARIE D BAR
` NICOLE MARIE DeBARTOLO, CSR, RPR
`16 One North Franklin
` Suite 3000
`17 Chicago, Illinois 60606
` Phone: 312.442.9087
`
`18
`19
`20 CSR License No. 084-004127
`21
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`Page 19
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`1 make a reply due on Monday the 25th, which would be
`2 actually two extra business days. If the Board prefers,
`3 we -- we can make it work and submit within a week if
`4 that's critical to the timing.
`5 THE COURT: That's okay. I want to get all this
`6 additional briefing wrapped up by early November. So it
`7 just depends.
`8 Patent Owner, could you have your responsive
`9 paper in by Tuesday, the 2nd of November?
`10 MR. OLEJNICZAK: Yes, we can -- we can handle that.
`11 THE COURT: Okay. Okay. So Petitioner, your reply
`12 will be due on the 25th of October; Patent Owner, your
`13 sur-reply -- preliminary sur-reply will be due on the
`14 2nd of November. We'll put -- it will either be a short
`15 e-mail from the Board or a short order of -- conduct of
`16 proceeding order reflecting the call today and
`17 resolution and the various dates. So be on the lookout
`18 for that, but in the meantime, please be working towards
`19 those dates as we discussed.
`20 MR. HOUSTON: Understood for Petitioner, your
`21 Honor. Thank you.
`22 THE COURT: Okay. Anything further?
`23 MR. OLEJNICZAK: Nothing further from Patent Owner,
`24 thank you.
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`6 (Pages 18 - 21)
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`
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`andruslaw.com
`2:15
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`16:19
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`Page 1
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`b
`back 5:3 9:12
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`
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`5:16 19:16 20:2,5
`20:11
`capable 12:23
`captured 12:2
`
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`Veritext Legal Solutions
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`888-391-3376
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`PGR2021-00085
`Pelican EX1049
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`

`

`[case - evidence]
`
`case 1:8 4:15 7:15
`9:2 12:14 18:4
`catching 11:9
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`14:15 18:1
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`13:5,13
`
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`
`complete 8:1,8
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`
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`d
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`Veritext Legal Solutions
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`Page 2
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`disassembled 8:7
`disassembly 8:1
`discuss 5:7
`discussed 19:19
`20:11,15
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`13:15
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`20:17
`
`e
`e 2:5,10,15 4:20,21
`19:15
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`established 17:11
`eventually 7:23
`everybody 5:6
`evidence 8:12,16
`12:24 14:1,8
`
`888-391-3376
`
`PGR2021-00085
`Pelican EX1049
`
`

`

`[evidence - limitation]
`
`15:24 16:3,7,24,24
`17:7,8
`example 17:2
`exhibit 20:6
`expect 20:14
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`f
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`
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`h
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`
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`
`i
`identified 8:23
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`16:3
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`interpretation
`10:1
`
`Veritext Legal Solutions
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`Page 3
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`interrupt 4:3
`intrinsic 12:24
`introduce 4:1 8:12
`8:13,15 14:7 16:3
`introducing 8:14
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`j
`john 1:10
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`keep 14:18
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`11:15 15:9 16:21
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`20:7
`
`l
`language 10:7,15
`13:14,15 17:14
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`16:8
`letting 18:6
`license 21:20
`licensed 1:12
`light 18:10
`limitation 9:14,22
`17:4
`
`888-391-3376
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`PGR2021-00085
`Pelican EX1049
`
`

`

`[limitations - positioned]
`
`limitations 10:15
`link 16:7
`listing 6:15
`little 16:6
`llp 2:12
`locate 8:4
`long 16:13
`look 4:20 9:10
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`18:21
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`
`m
`mail 2:5,10,15
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`monday 18:20
`19:1
`morning 3:6,9,20
`
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`
`n
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