Ex Parte Allocca et al

Board of Patent Appeals and Interferences

Jan 23, 2009

09547540 (B.P.A.I. Jan. 23, 2009)

UNITED STATES PATENT AND TRADEMARK OFFICE 1
___________ 2
3
BEFORE THE BOARD OF PATENT APPEALS 4
AND INTERFERENCES 5
___________ 6
7
Ex parte WILLIAM ALLOCCA, JORDAN HAY, JONATHAN A. 8
LEBLANG, COLLEEN MCQUEEN, and JAMES PRUDENTE 9
___________ 10
11
Appeal 2008-4062 12
Application 09/547,540 13
Technology Center 3600 14
___________ 15
16
Decided: January 26, 2009 17
___________ 18
19
Before HUBERT C. LORIN, ANTON W. FETTING, and BIBHU R. 20
MOHANTY, Administrative Patent Judges. 21
22
FETTING, Administrative Patent Judge. 23
24
DECISION ON APPEAL 25
26
STATEMENT OF THE CASE 27
28
William Allocca, Jordan Hay, Jonathan A. Leblang, Colleen 29
McQueen, and James Prudente (Appellants) seek review under 30
35 U.S.C. § 134 of a final rejection of claims 1-10, 13-27, 29-33, 35-38, 40, 31
41, 50-65, 67, 68, and 129, the only claims pending in the application on 32
appeal. 33
Appeal 2008-4062
Application 09/547,540

2
We have jurisdiction over the appeal pursuant to 35 U.S.C. § 6(b) (2002). 1
2
We AFFIRM. 3
The Appellants invented a way of ordering items over the internet 4
(Specification 1:8-10) using a Selection Of Procurement Option. When the user 5
selects a procurement option to complete the ordering of the item (e.g., by 6
performance of a single action), the system retrieves the procurement option 7
information for the selected procurement option and uses that information to 8
complete the ordering of the item. For example, the initially generated Web page 9
may contain a displayed element that, when selected, proceeds to display the 10
various available procurement options (Specification 37:9-18). An understanding 11
of the invention can be derived from a reading of exemplary claims 1 and 29, 12
which are reproduced below [bracketed matter and some paragraphing added]. 13
1. A method for a user at a client system to place an order for an item, 14
the user having a plurality of groups of predefined order fulfillment 15
information, the method comprising: 16
[1] displaying at the client system information identifying the item; 17
[2] displaying at the client system an element representing order 18
fulfillment instructions for the identified item; 19
[3] receiving indications of multiple groups of order fulfillment 20
information 21
that are each predefined for the user and 22
that each include a unique combination of 23
a delivery address, 24
shipping instructions distinct from the delivery address, 25
and a payment source; 26
[4] when the displayed element is selected by the user, 27
displaying at the client system an indication of each of the 28
identified multiple groups; and 29
[5] after selection by the user of a displayed indication of one of the 30
identified multiple groups and 31
without further intervention by the user, 32
Appeal 2008-4062
Application 09/547,540

3
sending to a server computer a request to order the identified 1
item such that the identified item 2
is to be sent to the delivery address for the selected 3
indicated group using the shipping instructions for the 4
selected indicated group and 5
is to be paid for by the payment source for the selected 6
indicated group, 7
so that a single action of selecting a group of order 8
fulfillment information 9
orders and pays for the item. 10
11
29. A computer-readable medium whose contents cause a computer 12
system to order an item using a client system, by performing a method 13
comprising: 14
[1] displaying information identifying the item; 15
[2] for each of multiple procurement options that each have information 16
related to ordering that includes at least delivery information and 17
information regarding payment, 18
displaying an indication of the procurement option such that selection 19
of the displayed indication represents using the information of the 20
procurement option for ordering of the identified item; and 21
[3] after selection of a displayed indication, sending to a server system a 22
request to order the identified item using the information of the 23
procurement option for the selected indication. 24
25
This appeal arises from the Examiner’s Final Rejection, mailed July 8, 2003. 26
The Appellants filed an Appeal Brief in support of the appeal on December 8, 27
2003, and the Examiner reopened prosecution with another Final Rejection, mailed 28
March 2, 2004. The Appellants filed a Supplemental Brief on June 2, 2004 and the 29
Examiner mailed an Examiner’s Answer to the Appeal Brief and Supplemental 30
Brief on May 2, 2006. A Reply Brief was filed July 3, 2006. The Examiner mailed 31
a replacement Examiner’s Answer on September 14, 2006 to comply with a 32
requirement that the references of record be listed. The Appellants filed a 33
Supplemental Reply Brief, consisting solely of a request that the prior Reply Brief 34
Appeal 2008-4062
Application 09/547,540

4
and its accompanying request for oral hearing be considered as responsive, on 1
November 14, 2006. 2
The Appellants filed another Supplemental Reply Brief on Aug. 27, 2007 to 3
comment on the patentability of their claims after KSR. This was not in response 4
to an Examiner’s Answer, and therefore was not in compliance with 37 C.F.R. § 5
41.41(a). Accordingly, the appeal was remanded to the Examiner. The Examiner 6
mailed a Supplemental Answer that added to, but did not replace, the September 7
14, 2006 Answer, on November 13, 2007. The Appellants filed another Reply 8
Brief on January 8, 2008. 9
Thus, generic references in this opinion to the Appeal Brief refer to the 10
December 8, 2003 filing, generic references to the Reply Brief refer to the January 11
8, 2008 filing, and generic references to the Examiner’s Answer refer to the Sep. 12
14, 2006 mailing. References to the Supplemental Answer refer to the November 13
13, 2007 Supplemental Answer. 14
15
PRIOR ART 16
The Examiner relies upon the following prior art: 17
Hartman US 5,960,411 Sep. 28, 1999 18
Yamada US 6,336,100 B1 Jan. 1, 2002 19
Holland US 6,493,742 B1 Dec. 10, 2002 20
21
22
Appeal 2008-4062
Application 09/547,540

5
REJECTIONS1 1
Claims 1-7, 9-10, 13, 15-27, 29-33, 35, 37-38, 40-41, 50-65, 67-68, and 129 2
stand rejected under 35 U.S.C. § 103(a) as unpatentable over Hartman and 3
Yamada. 4
Claim 8 stands rejected under 35 U.S.C. § 103(a) as unpatentable over 5
Hartman, Yamada, and Official Notice. 6
Claims 14 and 36 stand rejected under 35 U.S.C. § 103(a) as unpatentable 7
over Hartman, Yamada, and Holland. 8
9
ISSUES 10
The issues pertinent to this appeal are 11
• Whether the Appellants have sustained their burden of showing that the 12
Examiner erred in rejecting claims 1-7, 9-10, 13, 15-27, 29-33, 35, 37-38, 13
40-41, 50-65, 67-68, and 129 under 35 U.S.C. § 103(a) as unpatentable over 14
Hartman and Yamada. 15
• Whether the Appellants have sustained their burden of showing that the 16
Examiner erred in rejecting claim 8 under 35 U.S.C. § 103(a) as 17
unpatentable over Hartman, Yamada, and Official Notice. 18
• Whether the Appellants have sustained their burden of showing that the 19
Examiner erred in rejecting claims 14 and 36 under 35 U.S.C. § 103(a) as 20
unpatentable over Hartman, Yamada, and Holland. 21
The pertinent issue turns on whether the art describes or it was 22
otherwise predictable to provide, for each of multiple procurement 23

1 The Appellants respond to a rejection under 35 U.S.C. § 112, first paragraph
(App. Br. 27: ¶ C.), but the Examiner indicated such a rejection had previously
been withdrawn (Answer 3: Status of Claims).
Appeal 2008-4062
Application 09/547,540

6
options that each have information related to ordering that includes at 1
least delivery information and information regarding payment, 2
displaying an indication of the procurement option such that selection of 3
the displayed indication represents using the information of the 4
procurement option for ordering of the identified item. 5
6
FACTS PERTINENT TO THE ISSUES 7
The following enumerated Findings of Fact (FF) are believed to be 8
supported by a preponderance of the evidence. 9
Hartman 10
01. Hartman is directed to a one-click ordering of an item from a client 11
system. The client system is provided with an identifier that identifies a 12
customer. The client system displays information that identifies the item 13
and displays an indication of an action (e.g., a single action such as 14
clicking a mouse button) that a purchaser is to perform to order the 15
identified item. In response to the indicated action being performed, the 16
client system sends to a server system the provided identifier and a 17
request to order the identified item. The server system uses the identifier 18
to identify additional information needed to generate an order for the 19
item and then generates the order (Hartman 2:51-62). 20
02. Purchaser-specific order information may include the purchaser's 21
name, the purchaser's credit card number, and a shipping address for the 22
order (Hartman 1:60-62). Such information may also include a shipping 23
method and payment method (Hartman Fig. 1C:108; Hartman 6:1-3). 24
03. Purchaser specific information may be saved at a web site to prefill 25
the next order (Hartman 2:34-36). 26
Appeal 2008-4062
Application 09/547,540

7
04. Hartman describes displaying partial purchaser-specific order 1
information on the ordering page. This information may include a 2
shipping address moniker selected by the purchaser and credit card 3
number digits (Hartman 7:8-13). 4
05. Hartman’s server system can map a client identifier to multiple 5
customers who have recently used the client system. The server system 6
can then allow the users to identify themselves by selecting one of the 7
mappings based on a display of partial purchaser-specific order 8
information (Hartman 9:58-63). 9
Yamada 10
06. Yamada is directed to an online shopping system in which a customer 11
can designate addresses or places where he or she wants to have goods 12
delivered (Yamada 1:19-22). 13
07. Yamada displays a list of destination addresses for a customer to 14
select from (Yamada Fig. 9) and the selected destination is used for an 15
order (Yamada Fig. 10). 16
Holland 17
08. Holland is directed to aggregating registries. Holland allows 18
registrants to collect all registries, both custom and retail-specific, in a 19
single web site (Holland 2:25-29). 20
Facts Related To The Level Of Skill In The Art 21
09. Neither the Examiner nor the Appellants has addressed the level of 22
ordinary skill in the pertinent arts of systems analysis and programming, 23
user interfaces, and commercial sales transaction systems. We will 24
therefore consider the cited prior art as representative of the level of 25
ordinary skill in the art. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 26
Appeal 2008-4062
Application 09/547,540

8
(Fed. Cir. 2001) (“[T]he absence of specific findings on the level of skill 1
in the art does not give rise to reversible error ‘where the prior art itself 2
reflects an appropriate level and a need for testimony is not shown’”) 3
(quoting Litton Indus. Prods., Inc. v. Solid State Sys. Corp., 755 F.2d 4
158, 163 (Fed. Cir. 1985). 5
Facts Related To Secondary Considerations 6
10. There is no evidence on record of secondary considerations of non-7
obviousness for our consideration. 8
9
PRINCIPLES OF LAW 10
Claim Construction 11
During examination of a patent application, pending claims are given 12
their broadest reasonable construction consistent with the specification. In 13
re Prater, 415 F.2d 1393, 1404-05 (CCPA 1969); In re Am. Acad. of Sci. 14
Tech Ctr., 367 F.3d 1359, 1369 (Fed. Cir. 2004). 15
Limitations appearing in the specification but not recited in the claim are not 16
read into the claim. E-Pass Techs., Inc. v. 3Com Corp., 343 F.3d 1364, 1369 (Fed. 17
Cir. 2003) (claims must be interpreted “in view of the specification” without 18
importing limitations from the specification into the claims unnecessarily). 19
Although a patent applicant is entitled to be his or her own lexicographer of 20
patent claim terms, in ex parte prosecution it must be within limits. In re Corr, 21
347 F.2d 578, 580 (CCPA 1965). The applicant must do so by placing such 22
definitions in the Specification with sufficient clarity to provide a person of 23
ordinary skill in the art with clear and precise notice of the meaning that is to be 24
construed. See also In re Paulsen, 30 F.3d 1475, 1480 (Fed. Cir. 1994) (although 25
an inventor is free to define the specific terms used to describe the invention, this 26
Appeal 2008-4062
Application 09/547,540

9
must be done with reasonable clarity, deliberateness, and precision; where an 1
inventor chooses to give terms uncommon meanings, the inventor must set out any 2
uncommon definition in some manner within the patent disclosure so as to give 3
one of ordinary skill in the art notice of the change). 4
5
Obviousness 6
A claimed invention is unpatentable if the differences between it and the 7
prior art are “such that the subject matter as a whole would have been obvious at 8
the time the invention was made to a person having ordinary skill in the art.” 35 9
U.S.C. § 103(a) (2000); KSR Int’l Co. v. Teleflex Inc., 127 S. Ct. 1727, 1729-30 10
(2007); Graham v. John Deere Co., 383 U.S. 1, 13-14 (1966). 11
In Graham, the Court held that the obviousness analysis is bottomed on 12
several basic factual inquiries: “[(1)] the scope and content of the prior art are to be 13
determined; [(2)] differences between the prior art and the claims at issue are to be 14
ascertained; and [(3)] the level of ordinary skill in the pertinent art resolved.” 383 15
U.S. at 17. See also KSR, 127 S. Ct. at 1734. “The combination of familiar 16
elements according to known methods is likely to be obvious when it does no more 17
than yield predictable results.” Id. at 1739. 18
“When a work is available in one field of endeavor, design incentives and 19
other market forces can prompt variations of it, either in the same field or a 20
different one. If a person of ordinary skill can implement a predictable variation, § 21
103 likely bars its patentability.” Id. at 1740. 22
“For the same reason, if a technique has been used to improve one device, 23
and a person of ordinary skill in the art would recognize that it would improve 24
similar devices in the same way, using the technique is obvious unless its actual 25
application is beyond his or her skill.” Id. 26
Appeal 2008-4062
Application 09/547,540

10
“Under the correct analysis, any need or problem known in the field of 1
endeavor at the time of invention and addressed by the patent can provide a reason 2
for combining the elements in the manner claimed.” Id. at 1742. 3
4
ANALYSIS 5
Claims 1-7, 9-10, 13, 15-27, 29-33, 35, 37-38, 40-41, 50-65, 67-68, and 129 6
rejected under 35 U.S.C. § 103(a) as unpatentable over Hartman and Yamada . 7
The Appellants created an 18 member grouping to which the Appellants 8
apply six arguments in support of patentability, each such argument, except for 9
one, B.3, is applied to plural such groups. The Appellants nominate the first 10
argument as A, the second, third, fourth, and fifth as B.1, B.2, B.3, and B.4, and 11
the sixth as C. The sixth argument C, refers to a rejection under 35 U.S.C. § 112, 12
first paragraph, in the Jul. 8, 2003 Final Rejection. Argument C is moot because 13
this rejection was withdrawn by the Examiner in the Mar. 2, 2004 Final Rejection. 14
Argument B.3 applies to claim 18 alone, and is discussed, infra. Arguments 15
A, B.1, B.2, and B.4 all apply to the group the Appellants designated as group 2, 16
which includes claim 1. Each of these arguments apply to other groups as well, but 17
since each argument applies to a group of groups, each argument applies to all of 18
the claims in those collective groups, which always includes claim 1. Therefore, 19
each of the Appellant’s arguments applied to this rejection are applied to claim 1, 20
and therefore the Appellants have made arguments A, B.1, B.2, and B.4 against 21
claim 1. Accordingly, since claim 1 is representative of each of the groups of 22
groups made by the Appellants, we find that the Appellants have argued these 23
claims as a group and stand or fall with claim 1. 24
25
Claim 1 26
Appeal 2008-4062
Application 09/547,540

11
The Examiner found that Hartman discloses the limitations of claim 1, 1
except that it does not expressly teach displaying multiple groups/procurement 2
options associated with a single user of the client system having information 3
related to ordering the identified item. To overcome this deficiency, the Examiner 4
found that Yamada, in the same field of online shopping, teaches displaying 5
multiple groups/procurement options associated with a single user and allowing the 6
user to select one of the multiple groups/procurement options. The Examiner 7
concluded that disclosing several predefined choices for delivery destination 8
corresponds to multiple pre-defined procurement options and satisfies the 9
limitation recited in the independent claims 1, 10, and 29. 10
The Examiner further concluded that, in view of Yamada, it would have 11
been obvious to a person of an ordinary skill in the art at the time of the invention 12
to modify Hartman to display multiple groups or procurement options having 13
information related to ordering the identified item as expressly taught in Yamada. 14
Thus, when Yamada is combined with Hartman, for each different delivery 15
address, the Examiner contends the combination would result in unique 16
combinations of delivery address, shipping instructions different from delivery 17
address, and payment source/information because doing so would allow the user 18
the novelty and the convenience to order items online for different destinations for 19
him and/or gifts for individuals other than him (Answer 4-6). 20
21
Appellant’s Argument A 22
The Appellants contend that none of the cited references teaches or suggests 23
using multiple predefined procurement options to assist a user in ordering an item, 24
with each procurement option having associated information of multiple types 25
including at least payment information and delivery information (Br. 12-16). 26
Appeal 2008-4062
Application 09/547,540

12
The Appellants apply this contention to claims 1-10, 13-27, 29-33, 35-38, 1
40-41, 50-63 and 129, which the Appellants have designated as Groups 1-8 and 11-2
18 in their grouping of claims. 3
We disagree with the Appellants. Hartman describes requiring procurement 4
options to complete an order, and those options may include payment information 5
and delivery information (FF 01-04). Hartman further describes predefining such 6
options (FF 03) and mapping users to sets of partial purchaser-specific order 7
information with client identifiers (FF 05). Thus, each such client identifier maps 8
to a procurement option having associated information of multiple types including 9
at least payment information and delivery information. Although Hartman 10
characterizes the codes that identify each set of partial purchaser-specific order 11
information as client identifiers, these identifiers may be selected by the current 12
system user (FF 05) and thus operate as a collection of partial purchaser-specific 13
order information identifiers for a given user. 14
The Appellants contend there is no proper motivation to combine the 15
techniques from Hartman and Yamada, and even if there were such a motivation, a 16
combination of Hartman and Yamada would result in a system in which a user can 17
select to use a single previously provided delivery address and financial 18
information to order an item with a single action, or in which a user can select 19
among multiple predefined delivery addresses when ordering items from a 20
shopping cart, such as by also manually specifying payment information to be used 21
alter selecting one of the predefined delivery addresses. (Br. 16). 22
We again disagree with the Appellants. Yamada provides data entry 23
implementation details useful to Hartman’s sales system, including suggested data 24
entry screens for purchase information such as Hartman’s destination information 25
(FF 07). As to the resulting combination of the references, "[t]he test for 26
Appeal 2008-4062
Application 09/547,540

13
obviousness is not whether the features of a secondary reference may be bodily 1
incorporated into the structure of the primary reference .... Rather, the test is what 2
the combined teachings of those references would have suggested to those of 3
ordinary skill in the art." In re Keller, 642 F.2d 413, 425 (CCPA 1981). One of 4
ordinary skill would have known that Yamada’s screen for selecting destination 5
options described an implementation for Hartman’s selection of codes representing 6
groups of partial purchaser-specific order information. 7
8
Appellant’s Argument B1 9
The Appellants contend that none of the cited references teaches or suggests 10
that the predefined procurement options include "shipping instructions" for use in 11
delivering ordered items in addition to the delivery and payment information (Br. 12
17-19). The Appellants apply this contention to claims 1-9, 13, 35, and 51, which 13
the Appellants have designated as Groups 1, 2, 5, 8, and 16 in their grouping of 14
claims. 15
We disagree with the Appellants. Since we found supra that Hartman 16
described presenting a group of procurement options, the only issue here is 17
whether Hartman suggested including shipping instructions in such options. 18
Hartman explicitly shows including shipping instructions in the form of a shipping 19
method in such options, at least at the data entry level (FF 02). 20
21
Appellant’s Argument B2 22
The Appellants contend that none of the cited references teaches or suggests 23
that each of the predefined procurement options includes a "unique combination" 24
of a delivery address, shipping instructions, and a payment source or each has a 25
"distinct combination" of multiple types of information that is "sufficient to 26
Appeal 2008-4062
Application 09/547,540

14
complete an order" for an identified item (Br. 19-21). The Appellants apply this 1
contention to claims 1-8, 10, 13-27, 33, 35-38, and 50-55, which the Appellants 2
have designated as Groups 2-8, 14, and 16 in their grouping of claims. 3
We disagree with the Appellants. We found supra that the references 4
suggest that each of the predefined procurement options includes a combination of 5
a delivery address, shipping instructions, and a payment source. As there is no 6
point in entering redundant such combinations, one of ordinary skill would have 7
known that generally such combinations would be unique. Hartman describes 8
selecting such an option (FF 05) and then selecting a product such that the 9
combination is sufficient to complete an order (FF 01). One of ordinary skill 10
would have known that because the combination of these two steps provided the 11
information necessary for the order, the steps could have been reversed, and the 12
sequence preferred would simply depend on whether one desired to retain or not 13
retain the ordering options when selecting multiple items. In such a case it would 14
have been the selection of the purchase options rather than the item that was 15
sufficient to complete the order at that stage. 16
17
Appellant’s Argument B4 18
The Appellants contend that none of the cited references teaches or suggests 19
that the user can order an item using the item ordering information associated with 20
one of multiple predefined procurement options by merely selecting the displayed 21
indication for that procurement option (Br. 24-27). The Appellants apply this 22
contention to claims 1-9, 33, 35-38, and 64-68, which the Appellants have 23
designated as Groups 1, 2, and 6-10 in their grouping of claims. 24
We disagree with the Appellants. We found supra that Hartman describes 25
selecting such an option (FF 05) and then selecting a product such that the 26
Appeal 2008-4062
Application 09/547,540

15
combination is sufficient to complete an order (FF 01). One of ordinary skill 1
would have known that because the combination of these two steps provided the 2
information necessary for the order, the steps could have been reversed, and the 3
sequence preferred would simply depend on whether one desired to retain or not 4
retain the ordering options when selecting multiple items. In such a case it would 5
have been the selection of the purchase options rather than the item that was 6
sufficient to order the item at that stage. 7
8
Claim 18 9
Appellant’s Argument B3 10
The Appellants contend that none of the cited references teaches or suggests 11
interactive creation of a new procurement option for use in ordering the item (Br. 12
21-24). The Examiner found that Yamada described creating a new procurement 13
option in response to selecting a particular city, such as New York, which in turn 14
provided options attributable to that city for the user to select from. We agree with 15
the Examiner. Claim 18 does not further narrow the manner in which the option is 16
created. Creating based upon examples, such as cities in Yamada is still an act of 17
creating. 18
The Appellants have not sustained their burden of showing that the 19
Examiner erred in rejecting claims 1-7, 9-10, 13, 15-27, 29-33, 35, 37-38, 40-41, 20
50-65, 67-68, and 129 under 35 U.S.C. § 103(a) as unpatentable over Hartman and 21
Yamada. 22
Appeal 2008-4062
Application 09/547,540

16
Claim 8 rejected under 35 U.S.C. § 103(a) as unpatentable over Hartman, 1
Yamada, and Official Notice. 2
The Appellants present no argument specific to claim 8, and so have not 3
sustained their burden of showing that the Examiner erred in rejecting claim 8 4
under 35 U.S.C. § 103(a) as unpatentable over Hartman, Yamada, and Official 5
Notice. 6
7
Claims 14 and 36 rejected under 35 U.S.C. § 103(a) as unpatentable over 8
Hartman, Yamada, and Holland. 9
The Appellants present no arguments specific to claims 14 and 36, and so 10
have not sustained their burden of showing that the Examiner erred in rejecting 11
claims 14 and 36 under 35 U.S.C. § 103(a) as unpatentable over Hartman, 12
Yamada, and Holland. 13
14
CONCLUSIONS OF LAW 15
The Appellants have not sustained their burden of showing that the 16
Examiner erred in rejecting claims 1-10, 13-27, 29-33, 35-38, 40, 41, 50-65, 67, 17
68, and 129 under 35 U.S.C. § 103(a) as unpatentable over the prior art. 18
19
DECISION 20
To summarize, our decision is as follows: 21
• The rejection of claims 1-7, 9-10, 13, 15-27, 29-33, 35, 37-38, 40-41, 50-65, 22
67-68, and 129 under 35 U.S.C. § 103(a) as unpatentable over Hartman and 23
Yamada is sustained. 24
• The rejection of claim 8 under 35 U.S.C. § 103(a) as unpatentable over 25
Hartman, Yamada, and Official Notice is sustained. 26
Appeal 2008-4062
Application 09/547,540

17
• The rejection of claims 14 and 36 under 35 U.S.C. § 103(a) as unpatentable 1
over Hartman, Yamada, and Holland is sustained. 2
No time period for taking any subsequent action in connection with this 3
appeal may be extended under 37 C.F.R. § 1.136(a)(1)(iv) (2007). 4
5
AFFIRMED 6
7
8
9
10
11
hh 12
13
FENWICK & WEST, LLP 14
SILICON VALLEY CENTER 15
801 CALIFORNIA STREET 16
MOUNTAIN VIEW, CA 94041 17