DoDots Licensing Solutions, LLC

Patent Trials and Appeals Board

Sep 9, 2020

IPR2019-00988 (P.T.A.B. Sep. 9, 2020)

Trials@uspto.gov Paper 37
571-272-7822 Date: September 9, 2020

UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE PATENT TRIAL AND APPEAL BOARD

LENOVO HOLDING COMPANY, INC., LENOVO
(UNITED STATES) INC., and MOTOROLA MOBILITY LLC,
Petitioner,

v.

DODOTS LICENSING SOLUTIONS LLC,
Patent Owner.

IPR2019-00988
Patent 9,369,545 B2

Before GRACE KARAFFA OBERMANN, JAMES A. WORTH, and
PAUL J. KORNICZKY, Administrative Patent Judges.

KORNICZKY, Administrative Patent Judge.

JUDGMENT
Final Written Decision
Determining No Challenged Claims Unpatentable
35 U.S.C. § 318(a)

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I. INTRODUCTION
Lenovo Holding Company, Inc., Lenovo (United States) Inc., and
Motorola Mobility LLC (“Petitioner”) filed a Petition for an inter partes
review of claims 1–10 and 12–15 of U.S. Patent No. 9,369,545 B2
(Ex. 1001, “the ’545 patent”). Paper 1 (“Pet.”). We issued a decision to
institute an inter partes review of these claims. Paper 7 (“Inst. Dec.”). After
institution, Patent Owner filed a Patent Owner Response (Paper 15, “PO
Resp.”), Petitioner filed a Reply (Paper 24, “Reply”), and Patent Owner filed
a Redacted Sur-Reply to Petitioner’s Reply1 (Paper 35, “Sur-reply”).
Oral argument was held on June 10, 2020, and the transcript of the
hearing has been entered as Paper 36 (“Tr.”).
We have jurisdiction under 35 U.S.C. § 6. This Final Written
Decision is issued pursuant to 35 U.S.C. § 318(a) and 37 C.F.R. § 42.73.
Petitioner bears the burden of proving unpatentability of the
challenged claims, and the burden of persuasion never shifts to Patent
Owner. Dynamic Drinkware, LLC v. Nat’l Graphics, Inc., 800 F.3d 1375,
1378 (Fed. Cir. 2015). To prevail, Petitioner must prove unpatentability by
a preponderance of the evidence. See 35 U.S.C. § 316(e) (2016); 37 C.F.R.
§ 42.1(d). For the reasons that follow, we determine that Petitioner has not
shown by a preponderance of the evidence that claims 1–10 and 12–15 of
the ’545 patent are unpatentable. See 35 U.S.C. § 316(e).

1 In our Order dated June 9, 2020 (Paper 34), we granted Petitioner’s
motion to strike (Paper 29) certain portions of Patent Owner’s Sur-Reply
(Paper 26). In response to our Order, Patent Owner filed its Redacted Sur-
Reply.
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II. BACKGROUND AND SUMMARY
A. Real Parties in Interest
According to Petitioner, Lenovo Holding Company, Inc., Lenovo
(United States) Inc., and Motorola Mobility LLC are the real parties-in-
interest. Pet. 64. According to Patent Owner, DoDots Licensing Solutions
LLC is the real party-in-interest. Paper 4, 2.

B. Related Matters
According to Petitioner, the ’545 patent as well as U.S. Patent
Nos. 8,020,083 and 8,510,407 are at issue in DoDots Licensing Solutions
LLC v. Lenovo Holding Company, Inc. et al., Case No. 18-098-MN (D.
Del.). Pet. 64; see also Paper 4, 2 (Patent Owner identifies the district court
action).

C. The ’545 Patent (Ex. 1001)
The title of the ʼ545 patent is “Accessing and Displaying Network
Content.” Ex. 1001, code (54). The ’545 patent discloses, among other
things, a method for accessing and displaying network content in a graphic
user interface (“GUI”). Id. at code (57).
According to the ’545 patent, conventional web browsers are limited
in the “aggregation” and “presentation” of content. Id. at 1:48–51. As to the
aggregation of content, the ’545 patent states that a user may use
conventional web pages to view content sources in a single web page, such
as stock, weather and sports information (id. at 1:27–38), and because the
user is not in a position to separately aggregate the content at a client
computer, the user is constrained to view the content that has been delivered
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in the manner provided by the server computer hosting the web page (id.
at 1:45–48). As to the presentation of content, the ’545 patent states that
conventional content was divided into regions on a single web page. Id. at
1:27–38. The ’545 patent identified a purported problem, noting that when
disparate content was aggregated, it was “reassembled into a full web page
and [] served through a full-screen browser.” Id.
In contrast to conventional web pages, the ’545 patent discloses a
method for accessing and displaying network content in a GUI. Id. at code
(57). It is capable of processing distributable computer readable media. Id.
at 4:29–30. Distributable computer readable media includes, but is not
limited to, standard web content, such as HTML, dHTML, images,
imbedded ActiveX and Java applications, JavaScript, CSS, Pen scripts,
Streaming Media, and/or Flash. Id. at 4:31–34.
According to the ’545 patent, a user logs into a server by providing a
login identifier, which is used to obtain the user’s profile. Id. at 4:44–47.
The user profile includes references to networked information monitors
(NIMs). Id. at 4:54–56. In the ’545 patent, the term “networked information
monitor” refers to a fully configurable frame with one or more controls,
which stands in contrast to conventional web browsers, which have limited
means to alter the browser controls. Id. at 4:56–63. A “NIM template”
defines the characteristics of a specific NIM, including fully configurable
frame characteristics, viewer and control characteristics, and NIM content
references. Id. at 6:34–37; see id. at 2:30–32 (referred “a definition of a
Networked Information Monitor (NIM)” which defines a “NIM frame”).
After the user accesses the user profile and the NIM template defines the
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characteristics of the NIM frame, the content is placed in the NIM viewer
defined by the frame. Id. at 2:30–34.
D. Illustrative Claim
As mentioned above, the challenged claims are claims 1–10 and 12–
15. Claim 1 is the only independent claim among the challenged claims, and
is reproduced below:2
1. [1.preamble] A computer-implemented method of obtaining
content over a network and displaying the content to a user,
the method being implemented in a client computing device in
operative communication with a server over a network, the
client computing device including electronic storage, a
display, and one or more processors configured to execute one
or more computer program modules, the method comprising:
[1.A] transmitting a request to the server over the
network, the request requesting network information monitor
template;
[1.B]: receiving the requested networked information
monitor template from the server over the internet, the
requested networked information monitor template having
been transmitted from the server over the network responsive
to the transmitted request, the networked information monitor
template comprising:
[1.C]: a definition of a viewer graphical user interface
within which content in a web browser-readable language may
be presented on the display of the client computing device; and
[1.D]: a definition of a first content element for the
networked information monitor template, the definition of the
first content element referencing a first network location from
which the first content element for the networked information
monitor template is served over the network;

2 For ease of reference, claim 1 includes Petitioner’s bracketed limitation
designations. See Pet. 17–19.
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[1.E]: responsive to instructions included in the requested
networked information monitor template, presenting the
viewer graphical user interface defined by the networked
information monitor on the display of the client computing
device separate from and outside of any other graphical viewer
user interface that includes user controls for specifying the
first network location from which the first content element for
the networked information monitor is served over the network;
[1.F]: responsive to instructions included in the requested
networked information monitor template, transmitting over
the network a first content request to the first network location
referenced by the definition of the first content element for the
networked information monitor template;
[1.G]: receiving, over the network, the first content
element transmitted responsive to the first content request;
presenting the received the first content element in the viewer
graphical user interface defined by the networked information
monitor template,
[1.I]: wherein the definition of the viewer graphical user
interface and/or the first content element define all controls for
enabling a user to interact with the first content element
through the viewer graphical user interface.
Ex. 1001, 42:22–43:4 (emphasis added).

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E. Prior Art References
Petitioner relies on the following references:
Reference Description Date Exhibit
Hoff3 US 5,919,247 Issued July 6, 1999 Ex. 1006
Berg Cliff Berg, How Do I
Create a Signed
Castanet Channel?, DR.
DOBB’S JOURNAL,
January 1, 1998
Published Jan. 1, 1998 Ex. 1007
Razavi US 6,401,134 B1 Issued June 4, 2002 Ex. 1008
Banthia US 5,922,044 Issued July 13, 1999 Ex. 1009
Berry US 5,586,244 Issued Dec. 17, 1996 Ex. 1010
Dang US 7,216,300 B2 Issued May 8, 2007 Ex. 1011
Cordell US 5,778,372 Issued July 7, 1998 Ex. 1013

F. Asserted Grounds
Petitioner asserts that claims 1–10 and 12–15 are unpatentable on the
following grounds:
Ground Claim(s) 35 U.S.C. §4 Reference(s)
1 1, 2, 10, 14 103 Hoff, Berg
2 2–5, 9 103 Hoff, Berg, Dang, Berry
3 6, 7, 12, 13, 15 103 Hoff, Berg, Razavi, Banthia
4 8 103 Hoff, Berg, Razavi,
Banthia, Cordell
5 1, 6, 7, 10, 12–15 103 Razavi, Banthia

3 The first-named inventor is Arthur Van Hoff, but, for consistency with the
Petition, we refer to the patent as “Hoff.”
4 The Leahy-Smith America Invents Act, Pub. L. No. 112-29, 125 Stat. 284
(September 16, 2011) (“AIA”), included revisions to 35 U.S.C. §103 that
became effective on March 16, 2013. Because the ’545 patent issued from
an application filed before March 16, 2013, we apply the pre-AIA version of
the statutory basis for unpatentability.
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Ground Claim(s) 35 U.S.C. §4 Reference(s)
6 2–5, 9 103 Razavi, Banthia, Dang,
Berry
7 8 103 Razavi, Banthia, Cordell
Pet. 1. Petitioner relies on the testimony from Dr. Vijay K. Madisetti (Ex.
1005). Based on his statement of qualifications and experience, we find Dr.
Madisetti qualified to opine about the understanding of a person of ordinary
skill in the art at the time of the invention. See Ex. 1005 ¶¶ 6–30 (statement
of qualifications and experience).

III. ANALYSIS
A. Legal Standards
A claim is unpatentable under 35 U.S.C. § 103(a) if the differences
between the subject matter sought to be patented and the prior art are such
that the subject matter as a whole would have been obvious at the time the
invention was made to a person having ordinary skill in the art to which said
subject matter pertains. KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 406
(2007). The question of obviousness is resolved based on underlying factual
determinations including: (1) the scope and content of the prior art; (2) any
differences between the claimed subject matter and the prior art; (3) the level
of ordinary skill in the art; and (4) when in the record, objective evidence of
nonobviousness, such as commercial success. Graham v. John Deere Co.,
383 U.S. 1, 17–18 (1966). In that regard, an obviousness analysis “need not
seek out precise teachings directed to the specific subject matter of the
challenged claim, for a court can take account of the inferences and creative
steps that a person of ordinary skill in the art would employ.” KSR, 550 U.S.
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at 418. Further, “[t]o satisfy its burden of proving obviousness, a petitioner
cannot employ mere conclusory statements. The petitioner must instead
articulate specific reasoning, based on evidence of record, to support the
legal conclusion of obviousness.” In re Magnum Oil Tools Int’l, Ltd., 829
F.3d 1364, 1380 (Fed. Cir. 2016). We analyze the asserted grounds with
these principles in mind.

B. Level of Ordinary Skill in the Art
Petitioner asserts that a person of ordinary skill in the art would have a
“bachelor’s degree in Electrical or Computer Engineering, Computer
Science, or a related field and have three or more years of experience in the
field.” Pet. 8 (citing Ex. 1005 ¶¶ 38–41). Patent Owner does present
evidence regarding the education and experience of a person of ordinary
skill in the art.
Petitioner’s proposal appears to be consistent with the prior art of
record and with the ’545 patent. Okajima v. Bourdeau, 261 F.3d 1350, 1355
(Fed. Cir. 2001) (explaining that specific findings regarding ordinary skill
level are not required where the prior art itself reflects an appropriate level
and a need for testimony is not shown) (internal quotation marks and citation
omitted). We adopt Petitioner’s asserted level of ordinary skill in the art.

C. Claim Construction
In an inter partes review based on a petition filed after November 13,
2018, the claims are construed
using the same claim construction standard that would be used
to construe the claim in a civil action under 35 U.S.C.
§ 282(b), including construing the claim in accordance with
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the ordinary and customary meaning of such claim as
understood by one of ordinary skill in the art and the
prosecution history pertaining to the patent.
See Changes to the Claim Construction Standard for Interpreting Claims in
Trial Proceedings Before the Patent Trial and Appeal Board, 83 Fed. Reg.
51,340, 51,340, 51,358 (Oct. 11, 2018) (amending 37 C.F.R. § 42.100(b)
effective November 13, 2018) (now codified at 37 C.F.R. § 42.100(b).
(2019)); see Phillips v. AWH Corp., 415 F.3d 1303, 1312–13 (Fed. Cir.
2005). Any special definitions for claim terms must be set forth in the
specification with reasonable clarity, deliberateness, and precision. See In re
Paulsen, 30 F.3d 1475, 1480 (Fed. Cir. 1994).
To resolve Petitioner’s challenge, the parties assert that two claim
terms need to be construed: network information monitor (NIM) and
network information monitor template (NIM template).
1. Network Information Monitor (NIM)
Patent Owner asserts that the “inventors defined NIMs in the
specification as follows: ‘As used herein, the term networked information
monitor or NIM refers to a fully configurable frame with one or more
controls; the frame through which content is optionally presented.’” PO
Resp. 8 (citing Ex. 1001, 4:56–59). Petitioner agrees that the Specification
defines “a NIM as ‘a fully configurable frame with one or more controls’
through which content is presented to the user.” Reply 2 (citing Ex. 1001,
2:28–30; 4:56–67). We agree that the Specification defines a NIM as “a
fully configurable frame with one or more controls through which content is
presented to the user,” and this is the interpretation we apply here. Ex. 1001,
4:56–63.

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2. Network Information Monitor Template (NIM template)
a) The Parties’ Contentions
Patent Owner asserts that “the NIM template (a.k.a., NIM definition)
is a data structure that defines the NIM; it is not the NIM and it is not an
executable program (i.e., compiled code).” PO Resp. 8 (citing Ex. 2001
¶¶ 20–36); id. at 2 (“NIM templates are ‘data structures,’ not applications”).
According to Patent Owner, the Specification states that “NIMs are
extremely flexible, because the definition of the NIM is content, rather
than compiled code.” Id. at 8 (citing Ex. 1001, 21:58–60 (emphasis added),
6:33–37 (“NIM templates database 74 includes a large number of NIM
templates. Each NIM template defines the characteristics of a specific
NIM, including fully configurable frame characteristics, view and control
characteristics, and NIM content references.”) (emphasis added), 3:31-33
(“FIG. 13 illustrates a data structure for a NIM definition, stored in the
NIM application server’s template database or user profile database.”)
(emphasis added)). Patent Owner also argues that “NIM templates are
significantly smaller than the NIMs they define.” Id. at 9 (citing Ex. 2001
¶ 24; Ex. 1001, 33:47–55 (“Each NIM definition contains just enough
information to define and initialize the NIM's components (NIM frame,
controls, etc.). For example, this information may contain data to configure
the skeleton or frame that is filled in by NIM content from a developer’s
server. The NIM definition is therefore fairly small in size (~2K), and is
therefore easily distributable as an XML file or Blob (binary large object),
which is communicated using the same mechanisms (HTTP/ HTTPS
requests) as regular Web pages.”)).
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Petitioner does not present a construction for a “NIM template,” but
criticizes Patent Owner’s proposed construction and argues that a NIM
template should encompass executable programs and compiled code. Reply
2–4. Petitioner argues that “nothing in the claims or specification limits a
NIM template to a data structure excluding an executable program, as Patent
Owner proposes.” Id. at 2. Petitioner argues that Patent Owner’s examples
of NIM templates in the Specification, which exclude compiled code and
executable applications, are merely “non-limiting examples of NIM
templates” (id. at 3), while certain other embodiments disclose NIM
templates that are executable code (id. at 5). Petitioner also argues that
extrinsic evidence––statements in another related patent and in related
litigation––evidence that NIM templates may contain executable code. As
discussed in our analysis below, Petitioner’s arguments are not persuasive.

b) Construction of “NIM Template”
After considering the usage of “NIM template” in the claims, the
Specification, the prosecution history, and the parties’ contentions, we
determine that a NIM template is a data structure which defines the
characteristics of a NIM, including the NIM frame, view and control
characteristics, and which excludes executable applications/compiled code.
Turning to the usage of NIM template in the claims, claim 1, in
relevant part, states:
the networked information monitor template comprising:
[1.C]: a definition of a viewer graphical user interface
within which content in a web browser-readable language may
be presented on the display of the client computing device; and
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[1.D]: a definition of a first content element for the
networked information monitor template, the definition of the
first content element referencing a first network location from
which the first content element for the networked information
monitor template is served over the network.
Ex. 1001, 42:36–47. From claim 1, we understand that the NIM template
defines the characteristics of the viewer and the content on the viewer.
As to the prosecution history of the ’545 patent, the parties did not
identify, and we did not find, any portion of the prosecution history that is
helpful in determining the meaning of NIM template.
The Specification of the ’545 patent does address the meaning of NIM
template. The Specification states the “NIMs allow a developer to provide
an application feel without developing custom client applications” (Ex.
1001, 26:33–35), and the “NIM template defines the characteristics of a
specific NIM, including fully configurable frame characteristics, viewer and
control characteristics, and NIM content references” (id. at 6:34–37). See
also id. at 21:21–23 (“The NIM definitions, as discussed above, includes the
NIM frame definition and the definition of the controls for filling the viewer
within the frame with content.”).
Figure 13 of the ’545 patent is reproduced below.
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Figure 13 “illustrates a data structure for a NIM definition.” Id. at 21:42,
3:31. According to the Specification, in the exemplary embodiment of
Figure 13, “the definition of a NIM includes tags that identify the NIM 270,
define and configure the NIM frame 271, specify and layout the controls 273
in the NIM viewer, and specify parameters to initialize all the NIM’s
components with content or data.” Id. at 22:4–8. This disclosure does not
indicate that the data structure for the NIM template contains compiled code.
The Specification states that “a NIM is defined as a frame that
contains a collection of controls, or functional units, such as a web rendering
control or a GIF rendering control,” and the NIM definitions “include all the
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information needed to build a NIM frame and fill the NIM with NIM
content.” Id. at 21:42–53. The Specification further states:
In one embodiment, the NIM definitions are defined using
Extensible Markup Language (XML), so that the NIM as a
whole–the frame and the content within the viewer––is
advantageously as flexible as standard web content. NIMs are
extremely flexible, because the definition of the NIM is content,
rather than compiled code. The NIM definition defines the
structure of the NIM, and everything that is visible in a NIM is
based on standard Internet content, such as HTML, dHTML, or
GIFs, and is referenced or pointed to by the NIM definition. An
“application”–type NIM, such as a web calendar or web mail,
may be changed by the user, by the content provider, or by other
content, while advantageously avoiding the need to distribute
and support a hard-coded compiled application. The definition
of a NIM thus includes everything that is needed for the NIM to
be rendered and filled with Internet content.
Id. at 21:55–22:3 (emphasis added). From this disclosure, we understand
that the Specification prohibits the NIM template from using compiled code
or an executable application. Our review of the Specification did not
identify use of compiled code or an executable application by the NIM
template.
Petitioner argues that the data structure illustrated in Figure 13 and the
related discussion of Figure 13 is merely one non-limiting embodiment, and
that the Figure 13 embodiment merely describes implementing a NIM
template as XML rather than compiled code. Reply 3–4 (citing Innova/Pure
Water, Inc. v. Safari Water Filtration Sys., Inc., 381 F.3d 1111, 1117 (Fed.
Cir. 2004) (“particular embodiments appearing in the written description
will not be used to limit claim language that has broader effect”)).
Petitioner’s argument is not persuasive. While we agree with Petitioner that
the XML is one possible embodiment of a NIM template, the Specification
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distinguishes the XML embodiment from embodiments using other
languages for data structures, rather than distinguishing the XML
embodiment from embodiments in which the template is compiled code.
The Specification’s broad statement that a NIM template does not use
compiled code or executable applications applies to all NIM templates, not
just one particular embodiment. The Specification does not describe any
NIM template that uses compiled code or executable applications.
Petitioner argues that the Specification provides several examples of a
NIM template which uses executable code. First, Petitioner references the
Specification’s statement that “[t]he NIM definition is . . . fairly small in size
(~2K), and is therefore easily distributable as an XML file or Blob (binary
large object) . . . .” Reply 4–5 (citing Ex. 1001, 33:51–53). Petitioner
argues that a “binary large object” “might contain any binary content,
including executable code.” Id. at 4. Petitioner’s argument is not
persuasive. The Specification refers to an “XML file” and an “XML Blob.”
See, e.g., Ex. 1001, 34:21 (referring to “XML Blob”). In addition,
Petitioner’s contention is attorney argument unsupported by persuasive
expert testimony. In re Geisler, 116 F.3d 1465, 1470–1471 (Fed. Cir. 1997)
(argument by counsel cannot take the place of evidence); In re Pearson, 494
F.2d 1399, 1405 (CCPA 1974) (“Attorney’s arguments in a brief cannot take
the place of evidence.”). Unlike Patent Owner, Petitioner provided no
declarant testimony probative to the issue of how the ordinary artisan would
understand and interpret the relevant Specification passages and the
limitation in dispute.
Second, Petitioner argues that the “second executable module”
described in the specification is an embodiment of a “NIM template.”
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Reply 5. According to Petitioner, the Specification states a “second
executable module defines a NIM frame for the NIM using the definition,”
and because “the ‘second executable module’ defines a NIM frame, the
‘second executable module’ is a NIM template under its plain and ordinary
meaning.” Id. (citing Ex. 1001, 2:38–30, 2:44–45). Petitioner further argues
that the “NIM definition modules” are “executable code as distinct from
data.” Id. at 6. Petitioner’s argument is not persuasive because Petitioner
does not identify, and we do not find, any portion of the Specification which
discloses that the second executable module contains compiled code. In the
context of the Specification, the second executable module and the NIM
definition module contains the “data structure” for a NIM definition, and
appears to mean that the content in the modules are used with the specified
operation. See Ex. 1001, 3:31. In addition, Petitioner’s contentions about
the meaning of NIM template, second executable module, and NIM
definition module are attorney argument unsupported by persuasive expert
testimony. In re Geisler, 116 F.3d at 1470–1471 (argument by counsel
cannot take the place of evidence). The Specification does not describe any
NIM template that uses compiled code or executable applications.
Third, Petitioner argues that, during prosecution of a related ’874
application,5 Patent Owner admitted that the NIM template can be executed.
Reply 6. According to Petitioner, “the ’874 Application includes claims
reciting ‘executing the first networked information monitor template,’ and

5 According to Petitioner, the’545 patent indirectly claims priority to U.S.
Patent No. 7,660,868 (the “’868 patent”), and the’545 and ’868 patents share
essentially the same specifications. Reply 6–7. U.S. Patent Application No.
13/215,874 (the “’874 application”) also claims priority to and shares a
specification with the ’868 patent. Id.
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during prosecution, Patent Owner differentiated the claims from a prior art
reference on the basis that the prior art did not ‘teach or suggest executing’
the claimed NIM template.” Id. at 7 (citing Ex. 1019, 6–7, 14). Petitioner
argues that Patent Owner’s attempt to define NIM template differently in
this proceeding is improper. Id. at 6 (citing Omega Eng’g, Inc. v. Raytek
Corp., 334 F.3d 1314, 1334 (Fed. Cir. 2003)). As an initial matter, Exhibit
1019 is the Second Amended Complaint in a litigation, not the prosecution
history of the ’874 patent application. In addition, Petitioner’s contentions
about the meaning of the disputed terms are attorney argument unsupported
by citations to persuasive intrinsic evidence or testimony from a witness
competent to opine about how an ordinarily skilled artisan would understand
the terms. In re Geisler, 116 F.3d at 1470–1471 (argument by counsel
cannot take the place of evidence). Petitioner’s argument is not persuasive.
Fourth, Petitioner argues that “Patent Owner’s assertion that an
application could never be a NIM template (i.e., that a NIM template cannot
be executable) is further contradicted by its infringement allegations against
the Petitioners in the underlying district court action, where Patent Owner
has contended that each step of Claim 1 is performed by the use of ‘a stocks
(finance) app, MSN weather app, sports team app, a podcast app and
numerous other apps . . . .’” Reply 7 (citing Ex. 1020, 6–7). Petitioner’s
argument is not persuasive because it does not present any evidence about
how the “apps” work and how they apply to the disputed NIM template,
compiled code, and executable applications. In addition, Petitioner’s
contentions about the meaning of the disputed terms and apps are attorney
argument unsupported by persuasive evidence. In re Geisler, 116 F.3d at
1470–1471 (argument by counsel cannot take the place of evidence). A
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parties’ infringement allegations do not override the meaning of the claims
based on the intrinsic evidence. To the extent Petitioner is contending that
Patent Owner is taking inconsistent claim construction positions in an effort
to establish infringement in the related litigation, Petitioner can, of course,
present that argument to the court should litigation continue.
For the reasons above, we determine that a NIM template is a data
structure which defines the characteristics of a NIM, including the NIM
frame, view and control characteristics, and which excludes executable
applications/compiled code.

D. Ground 1– Obviousness over Hoff and Berg
Petitioner contends that the subject matter of claims 1, 2, 10, and 14
would have been obvious over the combined teachings of Hoff and Berg.
Pet. 22–29. We first describe the prior art that Petitioner seeks to combine
to show that independent claim 1 is obvious, and then turn to the merits of
the combination.
1. Overview of Hoff (Ex. 1006)
Hoff is a patent titled “Method for the Distribution of Code and Data
Updates,” and issued on July 6, 1999. Ex. 1006, codes (54), (45). Petitioner
contends Hoff is prior art under 35 U.S.C. § 102(e). Pet. 10.
Hoff discloses a system and method for distributing software
applications and data to thousands of clients over a network. Ex. 1006, code
(57). In Hoff, the applications are called “channels,” the server is called the
“transmitter,” and the client is called the “tuner.” Id. The end-user needs to
subscribe to a channel before it can be executed. Id. When the end-user
subscribes to a channel, the associated code and data is downloaded to the
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local hard-disk and, once downloaded, the channel can be executed many
times without requiring further network access. Id. Because the channel’s
software and data updates can be automatically downloaded and installed in
the background at regular intervals by the tuner, Hoff states that the end-user
is not required to manually install software updates. Id. Hoff asserts that
this method of automatic downloading of updates achieves for the client the
same result as the broadcast distribution of software over a connection based
network, but wherein the client initiates each update request without
requiring any special broadcast networking infrastructure. Id.

2. Overview of Berg6 (Ex. 1007)
Berg is an article titled “How Do I Create a Signed Castanet
Channel?” Ex. 1007, 1. Berg discloses using Marimba’s Castanet, the
“Java-centric (but not limited to Java) push technology,” to distribute
content from Marimba. Berg, 1. Castanet is “a technology for deploying
highly scalable applications, with centralized update and administration
capabilities.” Id. at 2. Berg states that:
Castanet consists of a client called the “tuner” and a server
called the “transmitter.” Channels are published by an
administrator on a transmitter. A workstation that has a tuner
installed can subscribe to any number of channels on any
number of transmitters. The tuner updates the channel's
content, which may consist of Java code, media, and other

6 The parties dispute whether Berg was publicly accessible as of the critical
date (April 26, 1999), and, therefore, available as a prior art printed
publication. PO Resp. 12–14; Reply 9–11. We do not reach the dispute
regarding the prior art status of Berg because it is not necessary to our
ultimate decision. Even if we accept Petitioner’s view that Berg qualifies as
prior art, we find that Petitioner has not established the unpatentability of
any challenged patent claim.
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files, including binary code (signed channels can load native
methods supported by DLLs). The tuner presents a user
interface for managing channels. The tuner interface is set
apart from the interface constructed by any given channel (if
the channel even has a user interface). This is unlike a
browser, which imposes a user interface frame around any
application that runs within it. Channels construct their own
frames if and when they need them.
Id.
Berg discloses a HotJavaBean component, which is an HTML
renderer, used in a Castanet channel to render full “style-sheets, applets, and
frames” in a GUI, such that “by deploying an application via Castanet, you
do not have to forego the web capabilities of a browser.” Ex. 1007, 3. Berg
discloses that the channel application contains parameters defining a GUI,
including (1) the location of the viewing window to display the selected
webpage; (2) the size of the GUI; (3) a drop-down menu for selecting a
webpage; and (4) an “X” for closing the GUI. Id., 2–4. The channel
application can “provide users with a customized selection of URLs to view”
and the “viewing window can be placed anywhere within the Java
application, just like any other component.” Id., 3. For example, Berg
discloses an exemplary channel—BigCorporateApp—as a Java application
that can be downloaded to a client. Id., 3–5. When the user initiates that
channel, the application opens a GUI and presents the user with a menu
selection of three URLs. Id. Once the user selects a URL, the application
fetches that webpage over the Internet via the corresponding address and
displays the webpage within a portion of the GUI. Id; Ex. 1005 ¶¶ 93–95.

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3. Claims 1, 2, 10, 14 ––Obviousness Over Hoff and Berg
In support of Petitioner’s contention that claims 1, 2, 10, and 14 are
obvious over the combined teachings of Hoff and Berg, Petitioner provides
an element-by-element analysis showing where each element of the
challenged claims is in Hoff or Berg. Pet. 22–29. Petitioner also provides
supporting testimony by Dr. Madisetti (Ex. 1005). Patent Owner, relying on
supporting testimony by Dr. Sacerdoti (Ex. 2001), argues that Petitioner
does not show that claims 1, 2, 10, and 14 are unpatentable because, in part:
(1) Hoff and Berg do not have a NIM template, (2) Hoff and Berg do not
have a separate NIM and NIM template, and (3) objective evidence of non-
obviousness such as commercial success undermines Petitioner’s arguments
of unpatentability.7 For reasons set forth below, we determine that
Petitioner has not shown that Hoff and Berg teach or suggest the limitations
of claims 1, 2, 10, and 14.
a) Claim 1––The NIM Template Limitation
Claim 1, the only challenged independent claim, recites, in part
(emphasis added):

7 Patent Owner asserts that objective evidence of non-obviousness ––
commercial success –– supports a finding of non-obviousness of the ’545
patent. PO Resp. 17–18. We do not assess the objective evidence of non-
obviousness because we find that Petitioner fails to carry its burden of
demonstrating the unpatentability of any challenged claim based on the
asserted prior art. See, e.g., Hamilton Beach Brands, Inc. v. f’real Foods,
LLC, 908 F.3d 1328, 1343 (Fed. Cir. 2018) (holding, in affirming Board
decision determining that petitioner had not shown unpatentability, that
“objective indicia of nonobviousness” “need not [be] addressed” because the
court “affirmed the Board’s findings regarding the failure of the prior art to
teach or suggest all [claim] limitations”).
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[1.A] transmitting a request to the server over the network,
the request requesting network information monitor template;
[1.B]: receiving the requested networked information
monitor template from the server over the internet, the requested
networked information monitor template having been
transmitted from the server over the network responsive to the
transmitted request, the networked information monitor template
comprising:
[1.C]: a definition of a viewer graphical user interface
within which content in a web browser-readable language may
be presented on the display of the client computing device; and
[1.D]: a definition of a first content element for the
networked information monitor template, the definition of the
first content element referencing a first network location from
which the first content element for the networked information
monitor template is served over the network.
Petitioner asserts that Hoff and Berg teach the “NIM” recited in
claim 1 by disclosing a channel application. Pet. 23 (citing Ex. 1006,
Abstract, 2:45–48, 2:56–67, 3:1–5 (“[A] request is made to the transmitter
hosting the channel.”), 4:47–49; Ex. 1007, 2; Ex. 1005 ¶¶ 113–115).
Petitioner also asserts that “the ‘channel’ applications disclosed in
Hoff and Berg contain the claimed NIM template.” Pet. 23 (citing Ex. 1005
¶¶ 116–118), 24–25. According to Petitioner, “Hoff discloses that the client
receives the code and data (NIM template) necessary to implement a channel
(NIM) from the transmitter (located on the server) in response to a request
from the tuner (located on the client).” Reply 8. Petitioner explains that
Hoff discloses, “in response to a transmitted request from the tuner, the
client receives the requested channel from the transmitter, which is located
on the server.” Pet. 23–24 (citing Ex. 1006, code (57), 2:45–48, 2:64–66,
3:2–5 (“[C]ode and data for the channel is downloaded and stored in a local
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persistent storage.”), 4:49–57). Petitioner also asserts that the
“communication between the client and the server occurs over ‘a network
101 such as the Internet.’” Id. at 24 (citing Ex. 1006, 3:34–36). As to Berg,
Petitioner asserts that Berg “discloses that the tuner can be used to
‘subscribe to any number of channels on any number of transmitters.’” Id.
(citing Ex. 1007, 2). Relying on Dr. Madisetti’s testimony, Petitioner asserts
that the “channel downloaded from the transmitter and stored on the client
computer in Hoff and Berg includes the claimed NIM template” and “the
channel contains instructions and data used to create a GUI and display
content therein.” Id. (citing Ex. 1005 ¶ 118).
Petitioner’s arguments are not persuasive because Petitioner does not
show persuasively that Hoff’s and Berg’s channel application containing the
alleged NIM template comprises a data structure which defines the
characteristics of a NIM, including the NIM frame, view and control
characteristics, and which excludes executable applications/compiled code.
Indeed, Petitioner admits that the asserted “NIM template” in Hoff and Berg
contains compiled “code and data.” Reply 8; Pet. 23–24. Hoff discloses
that its invention
consists of a system and method for the large scale distribution
of application code and data. The system consists of a client-
side component, which the user uses to download
applications, as well as a server-side component, which is
used by a content provider or developer to make applications
available for distribution. The system also allows for the
automatic updating, personalization, and usage monitoring of
applications. In addition it is possible to use the application
even when the host computer is not always connected to the
network.
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Ex. 1006, 2:43–53 (emphasis added). Hoff also discloses that a channel,
which Petitioner argues contains the NIM template, is a “named application
consisting of code and data which can be subscribed to by an end-user,” and
“[o]nce delivered to the end-user[,] a channel behaves much like a normal
application.” Id. at 2:56–59 (emphasis added). Dr. Madisetti, for example,
testifies that Hoff and Berg’s channel contains compiled code or executable
applications. See, e.g., Ex. 1005 ¶ 114 (citing Ex. 1006, 3:1–5 (“The [Hoff]
end-user uses the tuner to subscribe to channels. When the user first
subscribes to a channel a request is made to the transmitter hosting the
channel. As a result of this request, the code and data for the channel is
downloaded and stored in a local persistent storage, usually a hard disk.”)
(emphasis added)), ¶ 113 (“channels . . . are the downloaded applications”),
¶ 119 (stating “in the provided code and description of the exemplary
channel application, Berg discloses that the channel application contains
parameters that define a GUI” (citing Ex. 1007, 2–5) (emphasis added)). We
also credit Dr. Sacerdoti’s testimony that Hoff’s and Berg’s channels contain
compiled code or executable applications, as consistent with the other
evidence of record. See, e.g., Ex. 2001 ¶¶ 56 (“[T]he petition identifies or
references Berg discussing the source code of an application. One of skill in
the art would understand that the Java source code defining the channel
disclosed in Berg was compiled into byte codes (likely on a device different
from the server disclosed by Berg) prior to the channel being downloaded
from a server to a client.”). Like Hoff, Berg concerns itself with applets and
applications. See, e.g., Ex. 1007, 2 (“Using [Castanet] . . . you can now
create full-featured client applications . . . .”). In contrast, the claimed NIM
templates use data structures rather than applets or applications.
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Further, both Petitioner and Patent Owner agree that the NIM and the
NIM template are separate and distinct elements. Reply 2; PO Resp. 8.
However, neither Petitioner nor Dr. Madisetti identify what in Hoff and Berg
might be a NIM template separate and distinct from the NIM. To the
contrary, Petitioner argues that the channel applications (i.e., the NIM)
contain the NIM template. See, e.g., Pet. 23–24; Ex. 1005 ¶ 118 (“The
channel downloaded from the transmitter and stored on the client computer
in Hoff and Berg includes the claimed NIM template.”). We also credit Dr.
Sacerdoti’s testimony that, under Petitioner’s interpretation, Hoff’s and
Berg’s channel application (NIM) contains the claimed NIM template, but
do not disclose a NIM and a NIM template that are separate and distinct
elements. Ex. 2001 ¶¶ 50 (“The petition does not identify any entity
disclosed by Hoff operating on the client that is responsive to instructions
included in a NIM template, presents a viewer graphical user interface
defined by a NIM, and presents content within that interface, that is distinct
from the NIM template.”), 55 (“As with Hoff, neither Madisetti nor the
petition asserts what in Berg might be the NIM template (channel template)
that is distinct from the NIM (channel).”).
Thus, for the reasons discussed above, we conclude that Petitioner has
not demonstrated by a preponderance of the evidence that claim 1 would
have been obvious over the asserted prior art.

b) Claims 2, 10, and 14
Each of claims 2, 10, and 14 depend from independent claim 1, and,
therefore, require a “NIM template.” Ex. 1001, 43:5–44:31. Thus, for the
same reasons discussed above with respect to Petitioner’s challenge of claim
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1, we also conclude that Petitioner has not demonstrated by a preponderance
of the evidence that claims 2, 10, and 14 would have been obvious over the
asserted prior art.

c) Summary of Claims 1, 2, 10, and 14
For the reasons above, Petitioner has not shown that Hoff and Berg,
either singly or in combination with each other, disclose a NIM template
comprising a data structure which defines the characteristics of a NIM,
including the NIM frame, view and control characteristics, and which
excludes executable applications/compiled code. Thus, Petitioner has not
shown by the preponderance of the evidence that claims 1, 2, 10, and 14 are
unpatentable over Hoff and Berg.

E. Grounds 2–4: Claims 2–9, 12, 13, 15
As mentioned above, Petitioner also challenges the patentability of (1)
claims 2–5 and 9 over the combination of Hoff, Berg, Dang, and Berry, (2)
claims 6, 7, 12, 13, and 15 over the combination of Hoff, Berg, Razavi, and
Banthia, and (3) claim 8 over the combination of Hoff, Berg, Razavi,
Banthia, and Cordell. Pet. 29–44. Each of claims 2–9, 12, 13, and 15
depend, directly or indirectly, from independent claim 1, and, therefore,
require a “NIM template.” Ex. 1001, 43:5–44:31. Petitioner does not argue
that Dang, Berry, Razavi, Banthia, or Cordell remedy the deficiencies of
Hoff and Berg. Thus, for the same reasons discussed above with respect to
Petitioner’s challenge of claim 1, we also conclude that Petitioner has not
demonstrated by a preponderance of the evidence that claims 2–9, 12, 13,
and 15 would have been obvious over the asserted prior art.
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F. Ground 5– Obviousness over Razavi and Banthia
Petitioner contends that the subject matter of claims 1, 6, 7, 10, and
12–15 would have been obvious over the combined teachings of Razavi and
Banthia. Pet. 44–57. We first describe the prior art that Petitioner seeks to
combine to show that independent claim 1 is obvious, and then turn to the
merits of the combination.
1. Overview of Razavi (Ex. 1008)
Razavi is a patent titled “Detachable Java Applets,” and was filed on
July 25, 1997. Ex. 1008, codes (54), (22). Petitioner contends Razavi is
prior art under 35 U.S.C. § 102(e). Pet. 13.
Razavi discloses a system and method for “detaching Java applets
from the constraints of the application such as a browser.” Ex. 1008, code
(57). Razavi’s applets run “without regard to the graphical interface limits
of the [browser] application.” Id. Razavi discloses conventional applets
presented in a browser that were constrained by “a window size that the
applet must execute within.” Id. at 1:35–44. Razavi discloses a method to
“detach Java applets from the constraints of the application so that they can
be GUI-controlled directly” and “not be limited by the state of the
application in which the applets are spawned.” Id. at 3:5–10. Razavi
discloses Java source code for a Jukebox streaming audio applet in
Appendix A. Id. at 4:18–25. Razavi discloses that when “an applet is
defined/created, its source code can be modified to include methods for
detaching the applet.” Id.

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2. Overview of Banthia (Ex. 1009)
Banthia is a patent titled “System and Method for Providing
Information to Applets in a Virtual Machine,” and was filed on June 12,
1997. Ex. 1009, codes (54), (22). Petitioner contends Banthia is prior art
under 35 U.S.C. § 102(e). Pet. 15.
Banthia discloses a system and method for simultaneously displaying
a set of display applets while optimizing the number of server connections.
Ex. 1009, code (57). Banthia discloses displaying multiple applets—i.e., a
“controlling applet” and “display applets”—in communication with a server
and one another. Id. at 3:35–44. The controlling applet establishes a
connection from a client to a server and sends data to the display applets. Id.
at 3:51–56; 3:64–4:6. Banthia’s display applets may be “torn off” from the
browser window and moved to a portion of the display, while being
“continually updated by the controlling applet.” Id. at 2:44–49; 5:7–20.

3. Claims 1, 6, 7, 10, 12–15––Obviousness Over Razavi and
Banthia
In support of Petitioner’s contention that claims 1, 6, 7, 10, and 12–15
are obvious over the combined teachings of Razavi and Banthia, Petitioner
provides an element-by-element analysis showing where each element of the
challenged claims allegedly appears in Razavi and Banthia. Pet. 44–57.
Petitioner also provides supporting testimony by Dr. Madisetti (Ex. 1005).
Patent Owner, relying on supporting testimony by Dr. Sacerdoti (Ex. 2001),
argues that Petitioner does not show that the challenged are unpatentable
because, in part: (1) Razavi and Banthia do not have a NIM template, (2)
Razavi and Banthia do not have a separate NIM and NIM template, and (3)
objective evidence of non-obviousness such as commercial success
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undermines Petitioner’s arguments of unpatentability. For reasons set forth
below, we determine that Petitioner has not shown that Razavi and Banthia
teach or suggest the limitations of claims 1, 6, 7, 10, and 12–15.
a) Claim 1 –– The NIM Template Limitation
Petitioner asserts that the Java applets disclosed in Razavi and Banthia
contain the claimed NIM template. Pet. 47 (citing Ex. 1005 ¶ 204).
According to Petitioner, “while the source code for the applets in Banthia is
not disclosed, a POSA would understand that the functionality of the applets
(i.e., generating a GUI and retrieving content over the network to be
included in the GUI) indicates the applets contain instructions and data used
to enable such functionality.” Id. Petitioner explains that the “applets are
written in Java, and Java GUIs are capable of presenting text and images,
which are readable by web browsers, as well as HTML web pages (e.g.,
through the HotJavaBean).” Id. at 48 (citing Ex. 1005 ¶ 208).
Petitioner’s arguments are not persuasive because Petitioner does not
show persuasively that Razavi’s and Banthia’s Java applets containing the
alleged NIM template comprise a data structure which defines the
characteristics of a NIM, including the NIM frame, view and control
characteristics, and which excludes executable applications/compiled code.
Indeed, Petitioner admits that the asserted “NIM template” in Razavi and
Banthia contains compiled “instructions and data.” Reply 11–12; Pet. 47–
48. Razavi and Banthia both pertain to executable Java applets. Ex. 1008,
3:13–15 (explaining that Razavi’s invention is a method and system “for
detaching Java applets from the constraints of the application which
provides the Java virtual machine for executing those applets”); Ex. 1009,
2:34–36 (explaining that Banthia’s invention “provides systems and methods
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for simultaneously displaying a set of applets while optimizing the number
of server connections”). As Banthia explains, a Java “applet is a small
program with a single purpose designed to be distributed across a network,
. . . often to add extra functionality to some other program.” Ex. 1009, 1:61–
63. Finally, Dr. Sacerdoti’s unrebutted testimony is that a person of ordinary
skill in the art would understand that Razavi’s and Banthia’s Java applets are
“compiled byte code, not a data structure that defines the characteristics of a
specific NIM.” Ex. 2001 ¶ 71; see id. at ¶ 63 (“Applets and applications
were known in the art to be executable code, distinct from data structures
such as a NIM template. One of skill in the art would understand that
Razavi discloses no applet template or definition of an applet that is distinct
from the applet itself.”).
Both Petitioner and Patent Owner agree that the NIM and the NIM
template are separate and distinct elements. Reply 2; PO Resp. 8. However,
neither Petitioner nor Dr. Madisetti identify what in Razavi and Banthia
might be a NIM template separate and distinct from the NIM. To the
contrary, Petitioner argues that the Java applets (i.e., the NIM) contain the
NIM template. See, e.g., Pet. 13–14 (Razavi), 15 (Banthia), 46–47; Ex. 1005
¶¶ 198 (“Razavi discloses . . . that webpage includes an applet (‘NIM’).”),
200 (“the applets disclosed in Razavi and Banthia contain the claimed NIM
template”). We also credit Dr. Sacerdoti’s testimony that, under Petitioner’s
interpretation, Razavi’s and Banthia’s Java applets (NIM) contain the
claimed NIM template, but Razavi and Banthia do not disclose a NIM and a
NIM template that are separate and distinct elements. See, e.g., Ex. 2001
¶¶ 63 (“Razavi discloses downloading applets, and nothing else, over the
Internet. Applets and applications were known in the art to be executable
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code, distinct from data structures such as a NIM template. One of skill in
the art would understand that Razavi discloses no applet template or
definition of an applet that is distinct from the applet itself.”), 66 (“Because
Razavi discloses Java applets, but discloses no separate definition of or
template for Java applets, it cannot possibly disclose or render obvious
claims that require both NIMs and distinct NIM templates.”).

b) Claims 6, 7, 10, and 12–15
Each of claims 6, 7, 10, and 12–15 depend, directly or indirectly, from
independent claim 1, and, therefore, require a “NIM template.” Ex. 1001,
43:5–44:31. Thus, for the same reasons discussed above with respect to
Petitioner’s challenge of claim 1, we also conclude that Petitioner has not
demonstrated by a preponderance of the evidence that claims 6, 7, 10, and
12–15 would have been obvious over the asserted prior art.

c) Summary of Claims 1, 6, 7, 10, and 12–15
For the reasons above, Petitioner has not shown that Razavi and
Banthia, either singly or in combination with each other, disclose a NIM
template comprising a data structure which defines the characteristics of a
NIM, including the NIM frame, view and control characteristics, and which
excludes executable applications/compiled code. Thus, Petitioner has not
shown by the preponderance of the evidence that claims 1, 6, 7, 10, and 12–
15 are unpatentable over Razavi and Banthia.

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G. Grounds 6–7: Claims 2–5, 8, and 9
As mentioned above, Petitioner also challenges the patentability of (1)
claims 2–5 and 9 over the combination of Razavi, Banthia, Dang, and Berry,
and (2) claim 8 over the combination of Razavi, Banthia, and Cordell. Pet.
58–63. Each of claims 2–5, 8, and 9 depend, directly or indirectly, from
independent claim 1, and, therefore, require a “NIM template.” Ex. 1001,
43:5–44:31. Petitioner does not argue that Dang, Berry, or Cordell remedy
the deficiencies of Razavi and Banthia. Thus, for the same reasons
discussed above with respect to Petitioner’s challenge of claim 1, we also
conclude that Petitioner has not demonstrated by a preponderance of the
evidence that claims 2–5, 8, and 9 would have been obvious over the
asserted prior art.

H. Patent Owner’s Secret Prior Art Argument
Patent Owner argues that, because Hoff, Razavi, Banthia, and Dang
were published after the critical date for the ’545 patent (April 26, 1999),
they are “secret prior art” because they were not available to one of ordinary
skill in the art as of the critical date. PO Resp. 14–15. Patent Owner
acknowledges that under current Federal Circuit precedent these patents are
considered prior art despite not being publicly accessible as of the critical
date, but DoDots contends that the law should be changed. Id.
Because we must follow the law as it stands, we decline to address
Patent Owner’s arguments.

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IV. CONCLUSION
For the reasons expressed above, we determine that Petitioner has not
proven by a preponderance of the evidence that the challenged claims are
unpatentable, as summarized in the following table:

V. ORDER
In consideration of the foregoing, it is hereby:
ORDERED that claims 1–10 and 12–15 of the ʼ545 patent have not
been shown to be unpatentable; and
Claims

35
U.S.C. §
Reference(s)/Basis Claims
Shown
Unpatentable
Claims
Not shown
Unpatentable
1, 2, 10,
14
103 Hoff, Berg 1, 2, 10, 14
2–5, 9 103 Hoff, Berg, Dang,
Berry
2–5, 9
6, 7, 12,
13, 15
103 Hoff, Berg,
Razavi, Banthia
6, 7, 12, 13,
15
8 103 Hoff, Berg,
Razavi, Banthia,
Cordell
8
1, 6, 7,
10, 12–
15
103 Razavi, Banthia 1, 6, 7, 10,
12–15
2–5, 9 103 Razavi, Banthia,
Dang, Berry
2–5, 9
8 103 Razavi, Banthia,
Cordell
8
Overall
Outcome
1–10, 12–15
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FURTHER ORDERED that, because this is a Final Written Decision,
parties to the proceeding seeking judicial review of the Decision must
comply with the notice and service requirements of 37 C.F.R. § 90.2.
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FOR PETITIONER:

John Alemanni
Matthew Meyer
KILPATRICK TOWNSEND
jalemanni@kilpatricktownsend.com
mmeyer@kilpatricktownsend.com

FOR PATENT OWNER:

Lewis Hudnell, III
HUDNELL LAW
lewis@hudnelllaw.com