Ex Parte Shotey et al

Patent Trials and Appeals BoardJun 9, 2014

90012087 - (D) (P.T.A.B. Jun. 9, 2014)

UNITED STATES PATENT AND TRADEMARKOFFICE UNITED STATES DEPARTMENT OF COMMERCE United States Patent and Trademark Office Address: COMMISSIONER FOR PATENTS P.O. Box 1450 Alexandria, Virginia 22313-1450 www.uspto.gov APPLICATION NO. FILING DATE FIRST NAMED INVENTOR ATTORNEY DOCKET NO. CONFIRMATION NO. 90/012,087 02/16/2012 Michael J. Shotey 60816 1077 1609 7590 06/10/2014 ROYLANCE, ABRAMS, BERDO & GOODMAN, L.L.P. 1300 19TH STREET, N.W. SUITE 600 WASHINGTON,, DC 20036 EXAMINER WHITTINGTON, KENNETH ART UNIT PAPER NUMBER 3992 MAIL DATE DELIVERY MODE 06/10/2014 PAPER Please find below and/or attached an Office communication concerning this application or proceeding. The time period for reply, if any, is set in the attached communication. PTOL-90A (Rev. 04/07) UNITED STATES PATENT AND TRADEMARK OFFICE ____________________ BEFORE THE PATENT TRIAL AND APPEAL BOARD ____________________ Ex parte HUBBELL INCORPORATED Appellant ____________________ Appeal 2014-005985 Reexamination Control 90/012,087 U.S. Patent 7,119,277 B1 Technology Center 3900 ____________________ Before JEAN R. HOMERE, JASON V. MORGAN, and MICHAEL J. STRAUSS, Administrative Patent Judges. STRAUSS, Administrative Patent Judge. DECISION ON APPEAL Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 2 This is an appeal under 35 U.S.C. § 134(b) from the Examiner’s final rejection of claims 1-20, which are subject to reexamination. Claims 21 and 22 are indicated to be allowable and/or confirmed. Final Office Action (Jul. 24, 2012) [hereinafter “FOA”]. We have jurisdiction under 35 U.S.C. §§ 6(b) and 306. We AFFIRM. STATEMENT OF THE CASE Real Party in Interest The real party in interest is the current patent owner, Hubbell Incorporated of Shelton, Connecticut, (“Hubbell”). App. Br. 1, USPTO assignment records. Reexamination Proceedings A request for ex parte reexamination of U.S. Patent No. 7,119,277 B1 (the “’277 patent”) was filed on February 16, 20121, requesting the reexamination of claims 1-20 and assigned Reexamination Control No. 90/012,087. New claims 21 and 22, added by the Amendment filed May 29, 2012, are indicated to be allowable and/or confirmed. Claims 1-20 stand rejected under 35 U.S.C. § 103(a). 1 The February 16, 2012, request replaced an earlier filed January 10, 2012, which was found to be non-compliant. See Notice of Failure to Comply with Ex Parte Reexamination Request Filing Requirements dated January 17, 2012. Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 3 Related Reexamination Proceeding Appellant identifies a related reexamination of U.S. Patent No. 7,323,639 B1 (the “’639 patent”) which claims to be a continuation of the subject ’277 patent and which has been assigned Reexamination Control No. 90/012,086. App. Br. 2. By our decision of April 10, 2014, we affirmed the Examiner’s final rejection of claims 1-23 of the ’639 patent. PTAB 2014- 003866. Appellant’s Claimed Invention The ’277 patent, entitled “Convertible Electrical Device Cover and Method for Installing Same,” issued October 10, 2006, to Michael J. Shotey, Marcus J. Shotey, and Edgar W. Maltby (“Inventors”), based on Application No. 11/257,888, filed on October 24, 2005, which is said to be a continuation of Application No. 10/881,288, filed on June 29, 2004, now U.S. Patent No. 6,987,225, which is said to be a continuation of Application No. 10/700,737, filed on November 3, 2003, now U.S. Patent No. 6,770,816, which is said to be a continuation of Application No. 09/948,920, filed on September 7, 2001, now U.S. Patent No. 6,642,453. The ’277 patent is said to be assigned to Hubbell Incorporated, said to be the assignee and real party in interest. Appellant invented a convertible electrical device cover including a base plate and an adapter plate that are both configured to accommodate an electrical device. When the convertible electrical device cover is placed in an operative position over the electrical device the adapter plate may be Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 4 located between the electrical device and a rear side of the base plate. Abstract. The Claims Claim 1, reproduced below, is representative of the claimed subject matter: 1. An in-use weather protective electrical outlet cover for an electrical outlet having at least one socket face and at least one mounting screw aperture, the electrical outlet cover comprising: a base unit comprising an adapter plate coupled to a base plate; wherein the base plate is formed as a single molded piece; wherein the adapter plate has at least one opening extending through the adapter plate, the at least one opening having a size large enough to receive the at least one socket face; wherein the base unit having at least one base hinge member on a side of the base unit and at least one keyhole slot extending from a front side of the base unit to a back side of the base unit; and a protective cover having at least one cover hinge member configured for hinged attachment to the base hinge member; wherein the base unit is configured such that after the base unit is installed on the electrical outlet, the at least one opening in the adapter plate surrounds the at least one socket face, the at least one keyhole slot is aligned with the mounting screw aperture, and the at least one keyhole slot is accessible for selective tightening, loosening, and adjustment of the base unit after the base unit is installed. Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 5 References The prior art relied upon by the Examiner in rejecting the claims on appeal is: Hartmann Shotey Hayduke US 1,557,526 US 5,763,831 US 6,133,531 Oct. 13, 1925 Jun. 9, 1998 Oct. 17, 2000 The Rejections The Examiner made the following rejections: Claims 1, 18, and 19 stand rejected under 35 U.S.C. § 103(a) as being unpatentable over Hayduke and Hartmann. FOA 3-7.2,3 Claims 2-17 and 20 stand rejected under 35 U.S.C. § 103(a) as being unpatentable over Hayduke, Hartmann, and Shotey. FOA 7-19.4 2 In connection with this rejection, Appellant argues the rejection of claim 1. Separate patentability is not argued for claims 18 and 19. “A statement which merely points out what a claim recites will not be considered an argument for separate patentability of the claim.” 37 C.F.R. § 41.37(c)(1)(vii). Further, merely restating with respect to a second claim an argument, previously presented with respect to a first claim, is not an argument for separate patentability of the two claims. Therefore, based on Appellant’s arguments, we decide the appeal of the rejection of claims 1, 18, and 19 under 35 U.S.C. § 103(a) over Hayduke and Hartmann based on claim 1 alone. 3 Appellant’s Appeal Brief erroneously indicates that claims 1-3, 18, 19, 22 and 23 stand rejected under 35 U.S.C. § 103(a) over Hayduke and Hartmann. App. Br. 5; Ans. 3, fn. 1. 4 In connection with this rejection, separate patentability is not argued for claims 2-17 and 20. Therefore, we decide the appeal of the rejection of these claims under 35 U.S.C. § 103(a) over the combination of Hayduke, Hartmann, and Shotey based on claim 1 alone. See 37 C.F.R. § 41.37(c)(1)(vii). Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 6 ANALYSIS We have reviewed the Examiner’s rejections in light of Appellant’s arguments that the Examiner has erred. We disagree with Appellant’s conclusions. We adopt as our own (1) the findings and reasons set forth by the Examiner in the action from which this appeal is taken (FOA 2-17) and (2) the reasons set forth by the Examiner in the Examiner’s Answer in response to Appellant’s Appeal Brief (Ans. 3-19) and concur with the conclusions reached by the Examiner. We note Appellant’s contentions of error and the issues raised in the instant appeal are substantially the same as corresponding arguments presented in Appellant’s prior appeal filed in connection with the ’639 patent and which we found unpersuasive of reversible error. While we incorporate the relevant portions of our prior opinion herein5, we highlight the following for emphasis. A. Rejection of Claims 1, 18, and 19 over Hayduke and Hartmann Appellant’s Contentions A.1. Hartmann does not establish that it would have been obvious to one skilled in the art to modify the wall plate or back body of Hayduke, which prevents access to the mounting screw and the keyhole slot, in a manner to provide access to the mounting screw extending through the keyhole slot in the back body of Hayduke to adjust the position of the outlet cover after installation on the electrical receptacle [as required by claim 1]. App. Br. 5-6 (emphasis omitted). 5 PTAB 2014-003866 pp. 6-12. Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 7 A.2. Hayduke does not disclose an outlet cover with an accessible keyhole slot or a cover that is adjustable after installation. Id. at 6. A.3. Hartmann does not teach a final assembly having an accessible keyhole slot for adjusting the position of the assembly. Id. at 7. A.4. Claim 1 is not obvious over Hayduke in view of Hartmann. Id. at 9. Analysis Contention A.1 In connection with contention A.1 Appellant argues neither Hayduke nor Hartmann discloses an assembled device having an accessible keyhole slot for a mounting screw or an assembled device that can be adjusted after installation. Id. at 5. According to Appellant, partial disassembly of either device would be required to access the keyhole slot after installation. Id. Appellant further argues, Hartmann does not establish that it would have been obvious to one skilled in the art to modify the wall plate or the back body of Hayduke, which prevents access to the mounting screw and the keyhole slot, in a manner to provide access to the mounting screw extending through the keyhole slot in the back body of Hayduke to adjust the position of the outlet cover after installation on the electrical receptacle. Id. at 5-6. The Examiner responds, finding “Hartmann teaches a modification of outlet covers to make the mounting screws accessible after mounting the outlet cover to allow for aligning of the cover and tightening of the mounting screws, and further providing such access even through interfering structures.” Ans. 6. Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 8 We find Appellant’s arguments unpersuasive for the reasons articulated by the Examiner, which we adopt herein. Id. at 3-6. That is, Hartmann teaches modifying an outlet cover unit having an aperture providing access to screw holes after mounting of the outlet cover unit. Id. at 6. The Examiner finds the motivation for providing access is to allow tightening of the mounting screws after installation of the outlet cover. Id. We agree with the Examiner, “the [asserted] combination is merely applying a simple improvement taught in Hartmann, i.e., accessible mounting screws, to the outlet cover of Hayduke to yield predictable results.” Id. We disagree with Appellant that “Hartman [sic] only suggest[s] modifying a fixed support hook and not modifying a removable cover plate or an adapter plate.” Reply Br. 3. Hartmann’s hook 17 is an integral part of the plate 14 (Hartmann p. 1, ll. 60-68) with opening 17b formed in hook 17 of plate 14. Therefore, modifying the hook results in modifying the plate, of which it is a part. Accordingly, for the reasons supra, we find contention A.1 unpersuasive of Examiner error. Contention A.2 In connection with contention A.2 Appellant argues, “Hayduke requires partial disassembly of the outlet cover to access the mounting screws and screw holes to enable adjustment of the position of the cover after installation.” App. Br. 6. The Examiner responds explaining, “this is the reason the teachings of Hartmann are being applied to modify the teachings of Hayduke in the rejections.” Ans. 7. We agree with the Examiner and find Appellant is responding to the rejection by attacking the Hayduke reference Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 9 individually, even though the rejection is based on the combined teachings of the references. Nonobviousness cannot be established by attacking the references individually when the rejection is predicated upon a combination of prior art disclosures. See In re Merck & Co., Inc., 800 F.2d 1091, 1097 (Fed. Cir. 1986). We are also not persuaded of error by Appellant’s argument that modifying Hayduke’s wall plate or housing to provide access to the keyhole slots would “result in the wall plate not covering the rear wall of the back body as required by the disclosure of Hayduke.” App. Br. 7 (emphasis added). While Hayduke discloses wall plate 90 covering the electrical box opening, Appellant has not shown that Hayduke requires the outlet cover cannot have an aperture. See Ans. 7. Therefore, we find contention A.2 unpersuasive of Examiner error. Contention A.3 In connection with contention A.3 Appellant argues Hartmann’s keyhole slots are covered by an electrical fixture in final assembly and, therefore, are not accessible during the normal use of the fixture support. App. Br. 7. In response, the Examiner finds: (a) the electrical fixture is not part of Hartmann’s outlet cover plate (Ans. 8); (b) claim 1 does not require the keyholes slots be accessible through an electrical device or fixture plugged into the outlet (id. at 9); (c) plugging an electrical device into an outlet does not make the device an integral part of the outlet cover plate (id.); (d) if an electrical device were hung on Hartmann’s hook, one skilled in the art would know to remove the device as necessary to adjust the cover plate (id.); (e) Appellant has provided no evidence that an electrical device Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 10 would cover the plate so as to render the keyhole slots inaccessible (id. at 10); and (f) Appellant’s argument is inconsistent with Appellant’s invention which includes a protective cover plate which must be removed or rotated to provide access to the mounting screws (id.) We agree with the Examiner and adopt the Examiner’s analysis and conclusions. Ans. 8-10. While Hartmann’s outlet cover plate includes a hook which can support an electrical fixture, placing an electrical fixture on the hook does not make the electrical fixture part of the cover plate just as hanging a picture on a picture hook does not make the picture part of a picture support. Similarly, claim 1 is directed to an electrical outlet cover, not to an electrical apparatus or other device using or otherwise associated with the cover. Therefore Appellant’s argument based on interference caused by the mounting of an electrical fixture onto the Hartmann’s hook is not commensurate in scope with claim 1, and thus, for that reason, does not demonstrate error in the Examiner’s rejection . See In re Self, 671 F.2d 1344, 1348 (CCPA 1982) (limitations not appearing in the claims cannot be relied upon for patentability). Furthermore, while Appellant argues “[t]he hook portion of the electrical fixture or other device will reside in the space between the hook 17 and the base plate 14 during normal use, thereby covering the screw holes and rendering the screws and the screw holes inaccessible” (Reply Br. 6), absent evidence in support, such conclusions are mere speculation. Attorney arguments and conclusory statements that are unsupported by factual evidence are entitled to little probative value. See In re Geisler, 116 F.3d 1465, 1470 (Fed. Cir. 1997); see also In re De Blauwe, 736 F.2d 699, 705 Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 11 (Fed. Cir. 1984.) For example, contrary to Appellant’s argument, rather than fill the entirety of the void between hook 17 and the front surface of plate 14 so at to obstruct access to slot 15 (Hartmann Fig. 2), an electrical device might include and be suspended by a thin wire hook which rests on the horizontal shoulder portion of hook 17 without upwardly extending so as to obstruct access to slot 15 through opening 17b. Therefore, for the reasons supra, we find contention A.3 unpersuasive of Examiner error. Contention A.4 In connection with contention A.4 Appellant argues Hartmann does not suggest adjustment of the final assembly. App. Br. 9. However, while claim 1 recites a keyhole slot is accessible for selective tightening, loosening, and adjustment of the base unit after the base unit is installed, we find the highlighted language is merely a statement of intended use and, therefore, fails to patentably distinguish claim 1 over the applied combination of Hayduke and Hartmann.6 6 Our reviewing Court has held that a statement of intended use in an apparatus claim cannot distinguish over a prior art apparatus that discloses all the recited limitations and is capable of performing the recited function. See In re Schreiber, 128 F.3d 1473, 1477 (Fed. Cir. 1997). We also note that “[a]n intended use or purpose usually will not limit the scope of the claim because such statements usually do no more than define a context in which the invention operates.” Boehringer Ingelheim Vetmedica, Inc. v. Schering- Plough Corp., 320 F.3d 1339, 1345 (Fed. Cir. 2003). Although “[s]uch statements often . . . appear in the claim’s preamble,” a statement of intended use or purpose can appear elsewhere in a claim. In re Stencel, 828 F.2d 751, 754 (Fed. Cir. 1987). Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 12 Appellant further argues Hartmann does not disclose a two-part base unit as required by claim 1. App. Br. 9. We are unpersuaded by this argument because the Examiner relies on Hayduke, not Hartmann, to describe the disputed two-part base plate. FOA 3, Ans. 11-12. As such, Appellant’s are responding to the rejection by attacking the Hartmann reference individually, even though the rejection is based on the combined teachings of the references. Nonobviousness cannot be established by attacking the references individually when the rejection is predicated upon a combination of prior art disclosures. See In re Merck & Co., Inc. 800 F.2d at, 1097; In re Keller, 642 F.2d 413, 425 (CCPA 1981). Neither do we find persuasive of Examiner error Appellant’s argument that, because Hartmann does not describe providing a hole in any electrical fixture supported by Hartmann’s hook it fails to suggest providing a hole into the wall plate of Hayduke. App. Br. 10. In response, the Examiner finds and we agree “the electrical fixture of Hartmann is not part of the outlet cover nor is it relevant to the teachings of Hartmann applied in the rejection.” Ans. 12. Nor are we persuaded of error by Appellant’s argument that Hayduke “does not require a hook or other member fixed to the back body 40 that overlies the screw holes” and that the “hook or other member according to Hartmann would clearly interfere with the attachment of the wall plate 90 to the back body 40 and would serve no useful purpose.” App. Br. 10. As found by the Examiner (Ans. 12), the disputed rejection does not suggest applying a hook to any portion of Hayduke’s wall plate (id.), only making Hayduke’s “keyholes accessible through interfering plates as taught by Hartmann in the outlet cover of Hayduke [by] providing a hole through Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 13 the adapter plate of Hayduke to provide access to the keyholes in the base plate” (FOA 5.) Furthermore, for the reasons supra and as set forth by the Examiner (Ans. 12-14), neither are we persuaded of error by Appellant’s further arguments that: 1. Neither Hartmann nor Hayduke suggest accessible screw holes in the base unit after installation (App. Br. 11); 2. The “Office Action has not provided an adequate reason why it would have been obvious to provide an opening in the wall plate of Hayduke based on the teachings of Hartmann” (id.); 3. Because the electrical fixture of Hartmann must be removed to make the keyhole slots accessible Hartmann fails to teach making keyhole slots accessible (id.); and 4. An embodiment depicted in Hartmann’s Figures 6-11includes a canopy which prevents access to screws 11 (App. Br. 11-12.) Appellant further argues “Hartmann does not suggest the ability or the desirability of the completed assembly having accessible keyhole slots for adjusting the position of the assembly of the electrical fixture and the base plate after installation.” App. Br. 13. We disagree for the reasons set forth by the Examiner (Ans. 9-10) and for the reasons supra, having found the electrical fixture not to be part of the outlet cover. Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 14 For the reasons articulated by the Examiner (id. at 14-16) we further disagree with Appellant’s contention that the combination of Hayduke and Hartmann is improper because (i) there was no motivation to make the combination (App. Br. 13), and (ii) the combination is based on hindsight (id.). We find the Examiner has articulated reasoning with rational underpinnings sufficient to justify the legal conclusion of obviousness. See FOA 5-6; Ans. 10-11. In contrast, Appellant fails to provide sufficient evidence or argument that the combination yields anything other than predictable results. See KSR Int’l Co. v. Teleflex, Inc., 550 U.S. 398, 401 (2007) (The “combination of familiar elements according to known methods is likely to be obvious when it does no more than yield predictable results.”). We are also not persuaded that combining the respective familiar elements of the cited references in the manner proffered by the Examiner was “uniquely challenging or difficult for one of ordinary skill in the art.” See Leapfrog Enters., Inc. v. Fisher-Price, Inc., 485 F.3d 1157, 1162 (Fed. Cir. 2007) (citing KSR, 550 U.S. at 418). Therefore, we find the Examiner’s proffered combination of familiar prior art elements according to their established functions would have conveyed a reasonable expectation of success to a person of ordinary skill at the time of the invention. We are likewise not persuaded that Hayduke’s teaching of a wall plate for preventing direct access to the underlying electrical box teaches away from the proposed modification. App. Br. 13-14. As found by the Examiner, Appellant has not provided explicit evidence from Hayduke specifically discouraging or discrediting providing such accessibility. Ans. 16. “A reference may be said to teach away when a person of ordinary skill, upon Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 15 reading the reference, would be discouraged from following the path set out in the reference, or would be led in a direction divergent from the path that was taken by the applicant.” In re Gurley, 27 F.3d 551, 553 (Fed. Cir. 1994). Appellant fails to provide sufficient evidence or argument that Hayduke so disparages providing access to keyhole slots as taught by Hartmann to the extent that one skilled in the art would be discouraged from making the combination. Furthermore, Appellant has failed to show that the proposed modification would permit substantial direct access to the underlying electrical box such that anything other than de minimis direct access would be permitted. For the reasons supra, we find Appellant’s contention A.4 unpersuasive of Examiner error. Therefore, for the reasons supra, we are unpersuaded the Examiner erred in rejecting claim 1. Accordingly, we sustain the rejection of independent claim 1 and, for the same reasons, independent claims 18 and 19 under 35 U.S.C. § 103(a) over Hayduke and Hartmann. B. Rejection of Claims 2-17 and 20 over Hayduke, Hartmann, and Shotey Appellant’s Contentions Shotey does not cure the deficiencies of Hayduke and Hartmann argued in connection with claim 1 including an outlet cover having a keyhole slot that is accessible after installation on an electrical outlet. App. Br. 16-23. Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 16 Analysis Because, for the reasons supra, we find no deficiencies in the combined teachings of Hayduke and Hartmann in connection with the rejection of claim 1, Appellant’s contention that Shotey also fails to teach the argued limitations is not persuasive of error. We are also not persuaded of Examiner error by Appellant’s arguments repeating contentions of error asserted in connection with claim 1 for the reasons supra and as found by the Examiner (Ans. 17-19.). We agree with the Examiner (id.) that Appellant’s arguments in connection with claims 2-8, 10-17, and 20 as found at pages 16-23 of Appellant’s Brief merely repeat arguments presented in connection with the respective base claims 1 and 18. We also agree Appellant’s argument for the patentability of claim 9 is improper because it attacks the Shotey reference individually when the Examiner relies on the combination of Hayduke, Hartmann, and Shotey. Therefore, because Appellant provides no substantive arguments for patentability in connection with claims 2-17 and 20 other than to either restate arguments made with respect to another claim or merely allege that the prior art fails to disclose or suggest the claimed limitations, we are not persuaded of Examiner error. Merely citing a claim limitation and asserting it is not present falls short of identifying an error in the Examiner’s rejection as required on appeal. See In re Jung, 637 F.3d 1356, 1365 (Fed. Cir. 2011) (“[I]t has long been the Board’s practice to require an applicant to identify the alleged error in the examiner’s rejections . . .”); In re Lovin, 652 F.3d 1349, 1357 (Fed. Cir. 2011) (“[T]he Board reasonably interpreted Rule 41.37 to require more substantive arguments in an appeal brief than a mere Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 17 recitation of the claim elements and a naked assertion that the corresponding elements were not found in the prior art.”). Therefore, for the reasons supra, we sustain the rejection of claims 2-17 and 20 under 35 U.S.C. § 103(a) over Hayduke, Hartmann, and Shotey. CONCLUSIONS We find 1. The Examiner did not err in rejecting claims 1, 18, and 19 under 35 U.S.C. § 103(a) over Hayduke and Hartmann. 2. The Examiner did not err in rejecting claims 2-17 and 20 under 35 U.S.C. § 103(a) over Hayduke, Hartmann, and Shotey. DECISION The Examiner’s decision that claims 1-20 are unpatentable over the prior art is affirmed. No time period for taking any subsequent action in connection with this appeal may be extended under 37 C.F.R. § 1.136(a)(1)(iv). AFFIRMED tj Appeal 2014-005985 Reexamination Control 90/012,087 Patent 7,119,277 B1 18 For Appellant/Patent Owner: ROYLANCE, ABRAMS, BERDO & GOODMAN, L.L.P. 1300 19th Street, N.W. Suite 600 Washington, DC 20036 For Third Party Requester: O’SHEA GETZ PC 1500 Main Street Suite 912 Springfield, MA 01115