Qualtrics, LLCv.OpinionLab, Inc.

Patent Trial and Appeal Board

Jul 24, 2015

10210256 (P.T.A.B. Jul. 24, 2015)

Trials@uspto.gov Paper 41
Tel: 571-272-7822 Entered: July 24, 2015

UNITED STATES PATENT AND TRADEMARK OFFICE
_______________

BEFORE THE PATENT TRIAL AND APPEAL BOARD
_______________

QUALTRICS, LLC,
Petitioner,

v.

OPINIONLAB, INC.,
Patent Owner.
_______________

Case IPR2014-00420
Patent 7,370,285 B1
_______________

Before RAMA G. ELLURU, JEREMY M. PLENZLER,
GEORGIANNA W. BRADEN, and CARL M. DeFRANCO,
Administrative Patent Judges.

BRADEN, Administrative Patent Judge.

FINAL WRITTEN DECISION
35 U.S.C. § 318 and 37 C.F.R. § 42.73

IPR2014-00420
Patent 7,370,285 B1

2
I. INTRODUCTION
A. Background
Qualtrics, LLC (“Petitioner”) filed a Petition (Paper 1, “Pet.”) to
institute an inter partes review of claims 1, 4, 5, 7, 9, 12, 13, and 15 of U.S.
Patent No. 7,370,285 B1 (Ex. 1001, “the ’285 patent”) pursuant to 35 U.S.C.
§ 311. OpinionLab, Inc. (“Patent Owner”) filed a Preliminary Response
(Paper 6, “Prelim. Resp.”). We instituted an inter partes review of claims 1,
4, 5, 7, 9, 12, 13, and 15 on certain grounds of unpatentability alleged in the
Petition. Paper 7 (“Dec. to Inst.”). After institution of trial, the Patent
Owner filed a Patent Owner Response (Paper 17, “PO Resp.”), to which
Petitioner filed a Reply (Paper 29, “Reply”). An oral argument was held on
April 22, 2015.
1

We have jurisdiction under 35 U.S.C. § 6(c). In this Final Written
Decision, issued pursuant to 35 U.S.C. § 318(a) and 37 C.F.R. § 42.73, we
determine Petitioner has shown by a preponderance of the evidence that all
of the challenged claims of the ’285 patent are unpatentable.
B. Related Proceedings
Petitioner informs us that the ’285 patent is involved in two co-
pending federal district court cases captioned: OpinionLab, Inc. v. Qualtrics
Labs, Inc., No. 1:13-cv-01574 (N.D. Ill.) and OpinionLab, Inc. v.
iPerceptions Inc., No. 1:12-cv-05662 (N.D. Ill.). Pet. 2. In addition,
Petitioner filed several petitions requesting inter partes review of related
patents. Id. These cases are: IPR 2014-00314 requesting review of U.S.
Patent No. 6,421,724; IPR2014-00356 requesting review of U.S. Patent No.

1
A transcript (“Tr.”) of the oral hearing is included in the record. Paper 40.
IPR2014-00420
Patent 7,370,285 B1

3
6,606,581; IPR2014-00406 requesting review of U.S. Patent No. 7,085,820;
and IPR2014-00366 requesting review of U.S. Patent No. 8,041,805.
Petitioner also filed IPR 2014-00421 requesting review of certain claims of
U.S. Patent No. 8,024,668, which is a continuation of the ’285 patent. Id.
We consolidated the oral hearings for IPR2014-00314, IPR2014-00356,
IPR2014-00406, IPR 2014-00420 and IPR 2014-00421. See Paper 34.
C. The ’285 Patent
The ’285 patent relates to a method for receiving page-specific user
feedback concerning a web page of a website. Ex. 1001, Abstract. The
method includes using a comment icon viewable on the web page to solicit
from a user one or more page-specific, open-ended comments concerning
the web page. Id. The ’285 patent specification discloses several
embodiments that, for example, provide a user reaction measurement tool
that is incorporated into a particular web page of a website. Id. at 6:14–18,
14:56–58. An example of a user reaction measurement tool is icon 50,
shown in Figure 2 reproduced below.

Figure 2 illustrates an embodiment of a user reaction measurement tool as
icon 50.
Icon 50 has associated software components, so that when a user
clicks on the icon, a multi-level subjective rating scale becomes visible and
IPR2014-00420
Patent 7,370,285 B1

4
allows users to provide reactions to the web page. Id. at 15:30–36. Figure 3,
reproduced below, shows a multi-level subjective rating scale.

Figure 3 illustrates a multi-level subjective rating scale as icon 60.
Certain embodiments present a user with a pop-up window when the
user clicks icon 50. Ex. 1001, 18:47–55. The pop-up window includes a
field for the user to type in comments about a particular web page, as shown
in Figure 6 reproduced below. Id. at 19:17–22.

Figure 6 illustrates a pop-up window with field 79 for type-written
comment(s).
In one embodiment, the specification teaches that the pop-up window
is generated from a remote server separate from the server hosting the
website rather than generating the window locally. Id. at 10:16–25.
IPR2014-00420
Patent 7,370,285 B1

5
D. Illustrative Claim
As noted above, inter partes review was instituted for claims 1, 4, 5,
7, 9, 12, 13, and 15 of the ’285 patent, of which claims 1 and 9 are
independent. Claim 1 is illustrative of the challenged claims and is
reproduced below:
1. A system for receiving page-specific user feedback concerning
a particular web page of a website displayed at a computer system of a
user that has accessed the particular web page, the system comprising:
a comment icon viewable on the particular web page and soliciting
one or more page-specific open-ended comments concerning the
particular web page from the user; and
software associated with the comment icon and operable to:
in response to the user selecting the comment icon, automatically
communicate a request for a comment window to a remote computer
system that is separate from a computer system hosting the website
and also separate from the computer system of the user, the comment
window allowing the user to provide the one or more page-specific
open-ended comments concerning the particular web page;
receive, at the computer system of the user, the comment window
from the remote computer system that is separate from the computer
system hosting the website and also separate from the computer
system of the user;
present the comment window to the user at the computer system of
the user; and
receive the one or more or more page-specific open-ended
comments concerning the particular web page from the user for
reporting to a website owner, the one or more page-specific open-
ended comments concerning the particular web page being provided
using the comment window.

Id. at 31:17–47.

IPR2014-00420
Patent 7,370,285 B1

6
E. Prior Art References Alleged to Support Unpatentability
Challenges
The instituted ground asserted the following prior art references:
Reference Patent/Printed Publication Date Exhibit
McDonald Michael J. McDonald et al.,
Multimedia Feedback Systems
for Engineering, Sandia National
Laboratories
April 25, 1999 1005
Pinsley U.S. Patent No. 6,070,145 May 30, 2000 1007

F. Grounds of Unpatentability Instituted for Trial
The following table summarizes the challenge to patentability that
was instituted for inter partes review:
Reference(s) Basis Claim(s) challenged
McDonald and Pinsley § 103(a) 1, 4, 5, 7, 9, 12, 13, and 15

II. DISCUSSION
A. Claim Construction
In an inter partes review, claim terms in an unexpired patent are
interpreted according to their broadest reasonable construction in light of the
Specification of the patent in which they appear. 37 C.F.R. § 42.100(b); see
also In re Cuozzo Speed Techs., LLC, No. 2014-1301, 2015 WL 4097949, at
*7, *8 (Fed. Cir. July 8, 2015) (“Congress implicitly approved the broadest
reasonable interpretation standard in enacting the AIA,” and “the standard
was properly adopted by PTO regulation.”). Under that standard, and absent
any special definitions, we give claim terms their ordinary and customary
meaning, as would be understood by one of ordinary skill in the art at the
time of the invention. In re Translogic Tech., Inc., 504 F.3d 1249, 1257
(Fed. Cir. 2007).
IPR2014-00420
Patent 7,370,285 B1

7
Petitioner proposes construction of several claim terms of the ’285
patent (Pet. 9–15), and Patent Owner does not contend that any terms should
be given a special meaning (PO Resp. 6–7 n.3). We determine that no
express constructions of claims are required for our analysis.
B. Principles of Law
To prevail in its challenges to the patentability of the claims, a
petitioner must establish facts supporting its challenges by a preponderance
of the evidence. 35 U.S.C. § 316(e); 37 C.F.R. § 42.1(d). 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 on the basis of 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 skill in
the art; and (4) objective evidence of nonobviousness, i.e., secondary
considerations. See Graham v. John Deere Co., 383 U.S. 1, 17–18 (1966).
We analyze the instituted grounds of unpatentability in accordance
with the above-stated principles.
C. Level of Ordinary Skill in the Art
In determining whether an invention would have been obvious at the
time it was made, we consider the level of ordinary skill in the pertinent art
at the time of the invention. Graham v. John Deere, 383 U.S. at 17. “The
importance of resolving the level of ordinary skill in the art lies in the
IPR2014-00420
Patent 7,370,285 B1

8
necessity of maintaining objectivity in the obviousness inquiry.” Ryko Mfg.
Co. v. Nu-Star, Inc., 950 F.2d 714, 718 (Fed. Cir. 1991).
Petitioner contends that a person of ordinary skill in the art at the time
of the ’285 patent would have a “Bachelor’s degree in computer science (or
equivalent technical field), experience in Web-based programming, an
understanding of the basic principles governing the collection and reporting
of customer feedback (i.e., basic survey methodology), and five or more
years of relevant work experience.” Pet. 16 (citing Ex. 1009 ¶¶ 48–51).
Patent Owner’s declarant, Michael I. Shamos (“Dr. Shamos”) testifies that
one of ordinary skill in the art at the time of the ’285 patent would have had
an undergraduate degree in computer science, or equivalent work
experience, and, in addition, at least two years of work experience, including
familiarity with web-based programming and user interfaces. Ex. 2002 ¶ 32.
Dr. Shamos disagrees with Petitioner’s characterization of the level of
ordinary skill “because it appears to [him] to require too much work
experience.” Id. ¶ 29. Dr. Shamos also does not believe that experience in
survey methodology would be required. Id. According to Dr. Shamos, “the
’285 patent does not deal with or claim survey design, but is concerned with
the collection and transmission of feedback information. In practice, the
questions to be asked of a respondent might be designed by a survey
specialist, but the questions themselves would then be presented over a user
interface of the type disclosed and claimed in the ’285 Patent.” Id. Patent
Owner concurs with Dr. Shamos’s opinion regarding the level of skill in the
art at the time of the ’285 patent. PO Resp. 19 n.5 (citing Ex. 2002 ¶¶ 27–
34).
IPR2014-00420
Patent 7,370,285 B1

9
Based on our review of the ’285 patent and the types of problems and
solutions described in the ’285 patent and cited prior art, we conclude a
person of ordinary skill in the art at the time of the ’285 patent would have a
Bachelor’s degree in computer science (or equivalent technical field) and at
least two years of work experience, including familiarity with web-based
programming and user interfaces. Based on the stated qualifications of
Petitioner’s declarant, Mr. John Chisholm (Ex. 1009 ¶¶ 9–18) and his
Curriculum Vitae (Ex. 1010), Petitioner’s declarant meets the requirements
of this definition. Additionally, based on the stated qualifications of Patent
Owner’s declarant, Dr. Shamos (Ex. 2002 ¶¶ 4–16) and his Curriculum
Vitae (Ex. 2003), Patent Owner’s declarant meets the requirements of this
definition. We further note that the applied prior art reflects the appropriate
level of skill at the time of the claimed invention. See Okajima v.
Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001).
D. Alleged Obviousness of Claims 1, 4, 5, 7, 9, 12, 13, and 15 in view
of McDonald and Pinsley
Petitioner alleges that claims 1, 4, 5, 7, 9, 12, 13, and 15 of the ’285
patent are unpatentable under 35 U.S.C. § 103(a) over McDonald and
Pinsley. Pet. 29–36. Patent Owner disputes Petitioner’s position, arguing
that a person of ordinary skill in the art would not have had reason to
combine the references in the manner proposed by Petitioner and further that
the combination of the references fails to teach or suggest all of the claim
limitations. PO Resp. 1–4.
We have reviewed the Petition, the Patent Owner Response, and
Petitioner’s Reply, as well as the relevant evidence discussed in those
papers. For reasons that follow, we determine that Petitioner has shown by a
IPR2014-00420
Patent 7,370,285 B1

10
preponderance of the evidence that claims 1, 4, 5, 7, 9, 12, 13, and 15 of the
’285 patent are unpatentable as obvious over McDonald and Pinsley.
1. Overview of McDonald
McDonald discloses systems that allow users to provide typewritten
comments about web pages, electronic documents, and videos. Ex. 1005, 5–
6. McDonald specifically teaches software for implementing a web page
commenting system that includes use of HTML and JavaScript. Id. at 1.
McDonald states that the web page feedback system “allows people to make
context-sensitive comments about specific web content” and “[t]he first
system ties comments to specific web pages.” Id. According to the
disclosure in McDonald, the web page commenting feedback system “first
appears to reviewers as a ‘feedback’ link on each important web page of a
report . . . This link has a similar function as typical ‘mailto’ links.” Id. at 4.
McDonald further discloses that when the “feedback link” is opened
on a web page, the system automatically fills a comment form with basic
information on the “Make Comment Page.” Id. Such information includes
the URL of the page the user was viewing when he or she clicked the
feedback link, the date, and the user’s name and email address. Id. The
reviewer then writes and submits his or her comments to a web server. Id.
Figure 2 of McDonald, reproduced below, illustrates the basic process of
submitting and viewing comments associated with an electronic document.
IPR2014-00420
Patent 7,370,285 B1

11

Figure 2 illustrates the basic process of the commenting system of
McDonald.
McDonald also discloses an embodiment of a feedback system that
allows a user to comment on digital movies (i.e., a “digital movie
commenting system”). Ex. 1005, 5–6. In that system, a “user clicks on a
provide/review comments about movie link and is then brought to a movie
commenting page” (i.e., “feedback link”). Id. at 6. McDonald teaches that
the digital movies are stored on a web server. Id. A web page (HTML)
loads a Java commenting applet. The Java commenting applet loads and
plays the movie, provides user controls, and interacts with the remote
database. Id. A Java server program (on the remote database) interacts with
the commenting applet and retrieves and stores comment data on a network
server. Id. at 6, Fig. 4. Figure 4 of McDonald, reproduced below, illustrates
the architecture of the digital movie commenting system and identifies the
interactions of the different elements of the system.
IPR2014-00420
Patent 7,370,285 B1

12

Figure 4 illustrates the basic elements of the digital movie commenting
system of McDonald.
2. Overview of Pinsley
Pinsley describes methods for surveying the users of an advertiser
website. Ex. 1007, Abstract. Pinsley teaches embedding into certain web
page(s) of the website a GIF (graphic image format) icon that links to a
recruit program located at a surveyor’s site. Id. at 2:45–47; 3:9–16. Figure
1 of Pinsley, reproduced below, illustrates the different computer systems
used by Pinsley’s disclosed methods.

Figure 1 illustrates the basic elements of Pinsley’s survey system.
Pinsley teaches that survey program (element 9) is located on a
computer network (Surveyor’s Web Site 3), remote from the Advertiser’s
IPR2014-00420
Patent 7,370,285 B1

13
Web Site (element 1) and the user’s computer system (elements 6 and 7).
Id. at 5:10–12.
The surveyor site monitors how many times the Advertiser’s Web Site
is accessed by users. Ex. 1007, 2:47–54. A recruit program on the surveyor
site selects users of the website to be presented with a banner on the
advertiser’s website. Id. The banner entices the user to participate in a
survey about the advertiser’s website. Id. When a user clicks on the banner,
the program launches and presents the user with a survey, as shown in
Figure 4 reproduced below. Id. at 2:51–56, Fig. 4.

Figure 4 illustrates a survey presented to users of an Advertiser’s Web Site
as disclosed in Pinsley’s survey system.
After the survey is completed, the information is collected, processed
and analyzed by the surveyor, and then the information is delivered to the
advertiser or otherwise used. Id. at 3:5–8.
IPR2014-00420
Patent 7,370,285 B1

14
3. Analysis
a. McDonald and Pinsley Teach or Suggest All the
Recited Limitations of Independent Claims 1 and 9
Petitioner contends the combination of McDonald and Pinsley, as
summarized above, renders claims 1 and 9 of the ’285 patent obvious.
Pet. 29. Independent claims 1 and 9 each require communicating a request
for a “comment window” to and receiving a “comment window” from “a
remote computer system that is separate from a computer system hosting the
website and also separate from the computer system of the user.” Ex. 1001,
31:17–47. Thus, all the claims require three separate computer systems: (1)
a remote computer system to which a request for a “comment window” is
communicated and from which a “comment window” is received by the user
computer; (2) a computer system that hosts the website for which a user
provides comments; and (3) a user computer system.
According to Petitioner, McDonald discloses every limitation of the
challenged claims. Pet. 17–29. Petitioner supports its assertions with a first
Declaration of Mr. John Chisholm (“Mr. Chisholm”), who testifies that
McDonald teaches a system that includes three distinct and separate
computer systems with a web-based user feedback system (and
corresponding database) that can be hosted on a remote server, different
from both the computer system hosting the web content and the computer
system of the user. Ex. 1009 ¶¶ 118–19. Additionally, Petitioner contends
Pinsley explicitly discloses and claims several limitations of the challenged
claims, so that Pinsley considered in view of McDonald would have led one
of skill in the art to consider claims 1 and 9 obvious. Pet. 30; Ex. 1009
¶ 122.
IPR2014-00420
Patent 7,370,285 B1

15
Petitioner specifically asserts that Pinsley discloses hosting a Web-
based survey (“comment window”) on a remote computer system that is
different from both the computer system hosting the website and the
computer system of the user as required by independent claims 1 and 9 of
the ’285 patent. Pet. 30–36 (citing Ex. 1007, 1:6–10, 1:62-65, 2:11–14).
Petitioner supports its assertions with testimony from Mr. Chisholm, who
states that “Pinsley discloses (among other things) ‘a system for
administering a survey for Internet Web site visitors . . . by embedding in the
Web site a reference to an executable graphic image that initiates a program
at a surveyor’s computer site.’” Ex. 1009 ¶ 123. Mr. Chisholm notes that
Pinsley states “[r]esponding to the graphic stimulus causes the actual survey
to be fetched from the surveyor’s site.” Id. (citing Ex. 1007, 2:3–14).
Relying, in part, on Figure 1 of Pinsley, Mr. Chisholm then testifies that
Pinsley discloses three distinct and separate computer systems: (1) the
computer hosting the “Advertiser’s Web Site”; (2) the computer hosting the
“Surveyor’s Web Site”; and (3) the computers of the “consumers” (i.e.,
website users). Id. ¶ 124. Mr. Chisholm’s annotated Figure 1 of Pinsley is
reproduced below:

IPR2014-00420
Patent 7,370,285 B1

16
Mr. Chisholm’s annotated Figure 1, shown above, indicates that Surveyor’s
Web Site 3 is separate from both Advertiser’s Web Site 1 and the computers
of consumer N and consumer N-1. Id. ¶ 124 n.23 (citing Ex. 1007, 2:42–59,
Fig. 1).
Petitioner then contends that Pinsley discloses receiving a Web-based
survey (“comment window”) at the computer system of the user, and that the
comment window is hosted on a remote computer system (Surveyor’s Web
Site 3) that is different from the computer system hosting the advertiser’s
website. Pet. 35–36 (citing Ex. 1007, 2:51–56, Fig. 4). Petitioner, thus,
asserts that “Pinsley discloses ‘receiv[ing], at the computer system of the
user, the comment window from the remote computer system that is separate
from the computer system hosting the website and also separate from the
computer system of the user [and] present[ing] the comment window to the
user at the computer system of the user[.]’” Id. at 36 (citing Ex. 1009
¶¶ 132–33).
Petitioner also contends that Pinsley discloses “embedding into [the]
HTML Web page a reference to the surveyor’s program.” Pet. 33 (citing Ex.
1007, 3:13–14). Petitioner explains that given this disclosure in Pinsley, it
would have been obvious to a person of skill in the art to implement the
HTML link to a “comment window” disclosed in McDonald using a remote
computer system to host the “comment window.” Id. at 34. According to
Petitioner, this implementation of a link to a “comment window” comprises
“software associated with the comment icon and operable to: in response to
the user selecting the comment icon, automatically communicate a request
for a comment window to a remote computer system that is separate from a
computer system hosting the website and also separate from the computer
IPR2014-00420
Patent 7,370,285 B1

17
system of the user[.]” Id. Petitioner concludes that when the link is clicked
by the user, it is operable to automatically communicate an HTTP request
for the “comment window” to the remote computer system. Id.
Patent Owner contests Petitioner’s position, arguing neither
McDonald nor Pinsley teaches or suggests that a “comment window” is
requested and received from a “remote computer system separate from a
computer system hosting the website and also separate from the computer
system of the user.” PO Resp. 30–37. Patent Owner first contends that
“McDonald merely discloses communication with a remote database, such
as to submit comment information,” because the video commenting tool in
McDonald is “merely a client-side Java applet” that is not requested and
received from the “Web Database Server.” PO Resp. 30, 33–34. Rather,
according to Patent Owner, the database server and web server shown in
Figure 4 of McDonald both appear to reside on the same computer system
and McDonald only discloses that the database is remote from the user’s
computer system (which runs the video commenting applet), but not from
the web server (i.e., the computer system hosting the particular web page).
Id. at 34 (citing Ex. 1005, 6 (“The commenting applet . . . interacts with the
remote database”)); Ex. 2002 ¶¶ 56–57. Patent Owner, thus, concludes that
McDonald does not disclose three separate systems with a “comment
window” being requested and received from a “remote computer system.”
Id.
Patent Owner relies on the Declaration of Dr. Shamos to support its
position regarding McDonald. See Ex. 2002 ¶¶ 56–57. Dr. Shamos states in
his declaration that Figure 4 of “McDonald shows a web browser at the left
running on a client and web server on the right,” therefore, “Figure 4 at most
IPR2014-00420
Patent 7,370,285 B1

18
discloses two computer systems.” Id. (citing Ex. 1005, Fig 4). Dr. Shamos,
however, testified to the contrary during his deposition, stating that
McDonald discloses three different systems, including a Web Database
Server that allows reviewers to comment on a movie with the comments
being requested, received, and stored on a system that is separate from that
storing the movie. See Ex. 1022, 221:17–222:15, 227:5–230:20.
Specifically, Dr. Shamos testified as follows regarding Figure 4 of
McDonald:
Q Right.
And so there could be three separate
systems; one for the client web browser, one for the
movie being served by a web browser and another for
the server entitled “Web Database”; is that right?
MR. CREMEN: Same objections.
THE WITNESS: I think in -- it is contemplated
that there would be three separate systems. The
reason is that this system structure that’s disclosed
here would allow you to comment on any movie
whatsoever, even if it hadn’t been made at Sandia;
for example, if it were available on a remote
website.
You still might want to capture comments at
Sandia about it and you wouldn’t have the luxury of
going and fooling around with the website from which
the movie was being served. And so it’s
contemplated, because there's -- with separate boxes,
that there would be three different systems.
There are other technical reasons that it
should be three different systems because normally
the database server is simply serving the results of
SQL queries and you don’t want to burden it with
streaming video, which is a huge transmission burden.
Id. at 221:17–222:15.
IPR2014-00420
Patent 7,370,285 B1

19
We credit the testimony of both Dr. Shamos (Ex. 1022,
221:17-222:15, 227:5-230:20) and Mr. Chisholm (Ex. 1009 ¶ 118). Based
on the evidence, we agree with Petitioner that McDonald at least suggests
three separate computer systems with a web-based user feedback system
(and corresponding database) that can be hosted on a remote server, different
from both the computer system hosting the web content and the computer
system of the user. See Pet. 19–21 (citing Ex. 1005, 5, Fig. 2; Ex. 1009
¶¶ 117–19).
Patent Owner further contends that Pinsley does not teach or suggest a
request for a “comment window” that is both requested and received from a
“remote computer system separate from a computer system hosting the
website and also separate from the computer system of the user” and that is
displayed to a user. PO Resp. 34–35. According to Patent Owner, Pinsley is
largely silent on where or how the website survey page (as opposed to its
survey program) is stored and Pinsley suggests that the survey web page is
stored on the same computer system as the advertiser’s page, not a “remote
computer system” as claimed in the ’285 Patent. Id. at 35. Patent Owner
explains that the URLs of the advertiser page and survey page in Figures 3
and 4, respectively, along with the exemplary HTML code in column 3,
indicate that the pages are part of the same website, because the page
including the invitation and the website survey page itself all refer to the
same domain—NPD’s site (mis.npd.com). Id. at 36 (citing Ex. 1007, Figs.
2–4). Therefore, Patent Owner argues that the advertiser page and survey
page are part of the same website and are delivered from the advertiser’s
system, while the Surveyor’s Web Site is a remote computer system. Id. at
15–16. Patent Owner contends that if the survey page itself were located at
IPR2014-00420
Patent 7,370,285 B1

20
the Surveyor’s Web Site then the surveyor would not have to collect survey
results after the completion of a survey. Id. at 16 (citing Ex. 1007, 3:5–8).
Patent Owner, thus, concludes that Pinsley does not disclose that the website
survey page is requested and received from a “remote computer system.” Id.
at 36-37.
Patent Owner again relies on the Declaration of Dr. Shamos to support
its position, yet Dr. Shamos again testifies counter to Patent Owner.
Ex. 2002 ¶¶ 74–80; Ex. 1022, 242:6–243:23, 248:2–250:3. Specifically, Dr.
Shamos testifies that the Advertiser’s Web Site in Figure 1 of Pinsley never
delivers any web pages (or anything else) to a user. Ex. 2002 ¶ 74. Rather,
according to Dr. Shamos, a user’s request is passed on to the Surveyor’s
Web Site (id. ¶ 75) and a survey page is delivered by the Surveyor’s Web
Site (id. ¶ 78). Although Dr. Shamos testifies that the Advertiser’s Web Site
is the remote computer (Ex. 1022, 242:6–243:23, 248:2–250:3), rather than
the Surveyor’s Web Site as argued by Patent Owner, we do not find that Dr.
Shamos’s testimony is inconsistent with Patent Owner’s position because
both argue that the advertiser’s webpage and the survey page are co-located
rather than the survey page being remotely located from the advertiser’s
webpage.
Despite the consistency we discern between the different theories
proffered by Patent Owner and Dr. Shamos, we are not persuaded by either
theory. Rather, we agree with Petitioner that Pinsley teaches that the survey
program (element 9) is located on a computer network (Surveyor’s Web Site
3) remote from the Advertiser’s Web Site (element 1) and the user’s
computer systems (elements 6 and 7). See Pet. 31–32 (citing Ex. 1007,
5:10–12). Pinsley also teaches giving users an opportunity to access the
IPR2014-00420
Patent 7,370,285 B1

21
survey by presenting a graphic icon to the user, and responding to the
graphic icon causes the actual survey (i.e., the claimed “comment window”)
to be fetched from the surveyor’s site (i.e., the claimed “remote computer
system”). Id. at 2:11–14. Despite Figure 4 of Pinsley showing two arrows
directed from the survey’s site to the user’s computer and no arrows from
the advertiser’s site to the user’s computer, we are not persuaded that the
Advertiser’s Web Site goes through the survey’s site to the user as suggested
by Dr. Shamos. See Ex. 1022, 249:14–250:3. Such a conclusion is
contradicted by Pinsley’s disclosure that (i) “The advertiser’s Web (1) may
have an HTML document (2), which may be the home page, with a few
additional lines of codes. . . . The added code should be in the form of a
reference to an executable graphic image program (9) located at the
surveyor’s site (3)” (Ex. 1007, 2:42–46), and (ii) “a user (6) reference the
[survey] program by visiting the advertiser’s (1) web site” (id. at 5:11–12).
Thus, we find that Pinsley teaches hosting a Web-based survey (“comment
window”) on a remote computer system that is different from both the
computer system hosting the website and the computer system of a user.
Patent Owner also contends that neither McDonald nor Pinsley
teaches or suggests soliciting “page-specific” open-ended comments
concerning a particular web page, as required by independent claims 1 and
9. PO Resp. 37–40. According to Patent Owner, McDonald fails to teach
that limitation, because McDonald is directed to peer-review of multimedia
files, not particular web pages of a website. Id. at 38–39. Patent Owner
argues that the web pages holding the content are incidental to the
commenting process and, although individual source web page URLs are
tracked, the tracking is done simply to identify the particular report provided
IPR2014-00420
Patent 7,370,285 B1

22
at that URL, not to facilitate comments about that web page. Id. Patent
Owner then notes that Petitioner does not assert that Pinsley discloses that
limitation, and therefore, Petitioner fails to meet its burden to show
obviousness of the independent claims. Id. at 39. Petitioner, however,
asserts that McDonald does teach that limitation. Specifically, Petitioner
asserts that McDonald discloses that “[e]ach system allows people to make
context-sensitive comments about specific web content. . . .The first system
ties comments to specific web pages[.]” Pet. 18 (citing Ex. 1005, 1)
(emphasis added). McDonald further states that this “Web Page
Commenting” system “interoperates with regular web pages to allow
reviewers to comment on web page content.” Id. (citing Ex. 1005, 5).
Given the disclosure in McDonald, we agree with Petitioner and find that
McDonald teaches open-ended comments concerning a particular web page
as recited in the challenged claims.
Patent Owner further contends that neither McDonald nor Pinsley
teaches a “comment window” that is received by the computer system of the
user, following the user “access[ing] the particular web page: and “selecting
the comment icon” viewable on the particular web page. PO Resp. 40–42.
According to Patent Owner, the McDonald system forces the user to
navigate away from the web page with the “feedback link,” such that the
“Make Comment Page” is never simultaneously viewable with the
underlying web page on which the user indicated a desire to provide
comments. Id. at 41 (citing Ex. 1005, 5, Figs. 1-3; Ex. 2002 ¶¶ 59-61;
Ex. 2004, 86:8–87:2). Patent Owner, thus, concludes that the “Make
Comment Page” cannot be considered a “comment window” as recited in the
challenged claims. Petitioner, however, argues that the “make a comment
IPR2014-00420
Patent 7,370,285 B1

23
web form” corresponds to the claimed “comment window.” Pet. 19–21
(citing Ex. 1009 ¶¶ 120, 131). Petitioner supports its position with a second
declaration from Mr. Chisholm. See Ex. 1021 ¶ 23. We agree with
Petitioner, because there is nothing in the claims that requires the “comment
window” to be simultaneously viewable with the underlying web page on
which the user indicated a desire to provide comments; the claims simply
require that the comment window allows a user to provide one or more page-
specific open-ended comments concerning a particular web page. The
“make a comment web form” disclosed in McDonald fulfills the stated
requirement of the challenged independent claims.
Patent Owner lastly contends that neither McDonald nor Pinsley
teaches or suggests “reporting [feedback comments] to a website owner,” as
required by independent claims 1 and 9. PO Resp. 42–43. According to
Patent Owner, the comments collected in McDonald are intended for and
reviewed by peers of the commenters, and not by the owner of the
underlying website that maintains the particular website. Id. at 43 (citing
Ex. 1005, 1). Petitioner asserts, however, that McDonald teaches reporting
user comments to a website owner through a Web-based “Report Page.”
Pet. 24 (citing Ex. 1005, 5, Fig. 2). Petitioner points out that McDonald
specifically states website owners can submit search terms through a web
form on the Report Query Page to generate custom reports of reviewer
comments (Report Pages). Id. These reports display the comments and
provide hyperlinks to the Source Page to which the comment refers.
Ex. 1005, 5. Based on the disclosure in McDonald cited by Petitioner, we
find that McDonald teaches reporting feedback comments to a website
owner.
IPR2014-00420
Patent 7,370,285 B1

24
Accordingly, we hold that Petitioner has shown by a preponderance of
the evidence that claims 1 and 9 are unpatentable under 35 U.S.C. § 103(a)
for obviousness in view of McDonald and Pinsley.
b. McDonald and Pinsley Teach or Suggest the Recited
Limitations of Dependent Claims 4, 5, 7, 12, 13, and
15
Petitioner contends dependent claims 4, 5, 7, 12, 13, and 15 are
unpatentable under 35 U.S.C. § 103(a) as having been obvious over
McDonald and Pinsley. Pet. 25-29, 59-60; Ex. 1009 ¶¶ 139–50. Patent
Owner contests Petitioner’s position, arguing neither McDonald nor Pinsley
teaches or suggests a “comment window,” let alone a “comment window
that is customizable by the website owner” as recited by the challenged
dependent claims. PO Resp. 44–46. McDonald, however, discloses a
“Make a Comment” form that is accessed through a “feedback link” on a
particular web page (the “source page”), while the form itself is on a
different web page (the “Make Comment Page”) hosted by a remote server.
Ex. 1005, 5, Fig. 2. According to Petitioner, the website owner need not
modify the particular web page in order to customize the comment window.
Pet. 25, 28; Ex. 1009 ¶ 140. As explained by Petitioner, as long as the URL
of the “Make Comment Page” remains the same, the (unmodified) link on
the particular web page will still function to call the (modified) comment
window. Pet. 25, 28; Ex. 1009 ¶ 140. We agree with Petitioner and find
that the “Make a Comment Page” disclosed in McDonald fulfills the stated
requirement of the challenged dependent claims for a customizable comment
window.
Patent Owner does not provide separate contentions regarding
additional limitations recited in the dependent claims. After careful
IPR2014-00420
Patent 7,370,285 B1

25
consideration of the language recited in claims 4, 5, 7, 12, 13, and 15, we
find that one of ordinary skill in the art would have considered these
dependent claims obvious over McDonald and Pinsley. Accordingly, we
determine that Petitioner has shown by a preponderance of the evidence that
claims 4, 5, 7, 12, 13, and 15 are unpatentable under 35 U.S.C. § 103(a)
because they would have been obvious in view of McDonald and Pinsley.
c. Reasons for Combining the Elements Taught in
McDonald and Pinsley
Petitioner contends that a person of ordinary skill in the art would
have had reason to combine the teachings of McDonald with those of
Pinsley for at least the following reasons: (1) the references address the
same problem: the solicitation of feedback from users of a web page; (2) the
references address this problem in the same manner: presenting users with a
comment icon (referred to in Pinsley as a “graphic image”), which they can
click to open a comment window; and (3) the references rely on the same
basic Web technology, including, in particular, an HTML link to a Web-
based survey (comment window). Pet. 29 (citing Ex. 1009 ¶¶ 91-106.)
Additionally, Petitioner explains that a person of ordinary skill in the
art would have been led to combine the remote computer system hosting a
Web-based survey (comment window) in Pinsley with the teachings of
McDonald because: (1) McDonald also discloses the use of a remote
computer system to host a “comment window”; (2) hosting Web-based
surveys (e.g., “comment windows”) on a remote server was routine industry
practice by 1997-98 (and beyond); (3) remote hosting offered a number of
business, technical and market research advantages, including, e.g., avoiding
security issues and other constraints associated with the server hosting the
IPR2014-00420
Patent 7,370,285 B1

26
website, and reducing traffic on the website server; and (4) implementing a
“comment window” on a remote computer system was straightforward from
a technical perspective, and could be accomplished simply by ensuring that
the destination of the corresponding HTML link (appearing on the web
page(s) for which feedback was being provided) was set to the address
(URL) of the survey on the remote server. Id. at 29–30 (citing Ex. 1009
¶¶ 107–11).
Patent Owner contests Petitioner’s position, arguing that one of
ordinary skill in the art at the time of the invention of the challenged claims
would not have been motivated to try to combine McDonald and Pinsley, for
several reasons. PO Resp. 1, 17. First, Patent Owner contends that the
proposed combination fails to account for the fact that the two references are
directed to contrary endeavors. Id. at 1–2, 19–21. According to Patent
Owner, McDonald’s peer review system would never look to Pinsley’s Nth
visitor selection system. Patent Owner argues that a system such as
Pinsley’s would defeat a key objective of scientific peer review, where one
expects all reviewers to comment, not merely every Nth visitor whether or
not they have an opinion. Id. at 2, 21–22.
Second, Patent Owner contends that the Pinsley approach of soliciting
comments about an advertiser’s overall website from a smaller number of
visitors, as a complementary function of the advertiser’s website, lends itself
to a “distributed thin-client system.” Id. at 2, 21–23. Patent Owner argues it
would not have made sense to try to apply that approach with McDonald,
whose entire purpose was instead to provide a “highly-integrated peer
review system.” Id. at 2. Patent Owner explains:
IPR2014-00420
Patent 7,370,285 B1

27
In other words, distributing across a network the storage and
handling of McDonald’s tightly-coupled multimedia files and
associated comments using a thin-client approach would have
provided no benefit to McDonald and, in fact, would have
degraded performance and increased cost. That was especially
true in the early 2000s, when network bandwidth was at a
premium and data transfer was typically much slower and more
expensive than it is today.
Id.
Lastly, Patent Owner contends that Petitioner’s arguments: (1) fail to
provide a reason for why a person of ordinary skill in the art would combine
McDonald and Pinsley together (id. at 17); (2) fail to demonstrate that there
would have been reasonable expectation of success by combining the
references (id.); (3) solely rest on hindsight analysis (id. at 18); and (4) are
technologically incorrect and unreliable (id. at 23-26).
We are not persuaded by Patent Owner’s arguments, as they narrowly
focus on small differences between McDonald and Pinsley and fail to
consider the collective teachings of McDonald and Pinsley from the
perspective of one of ordinary skill in the art. See KSR, 550 U.S. at 420
(“[F]amiliar items may have obvious uses beyond their primary purpose, and
in many cases a person of ordinary skill will be able to fit the teachings of
multiple patents together like pieces of a puzzle.”); EWP Corp. v. Reliance
Universal Inc., 755 F.2d 898, 907 (Fed. Cir. 1985) (a prior art reference
must be considered for everything it teaches by way of technology and is not
limited to the particular invention it is describing and attempting to protect).
Moreover, the test for obviousness is not whether one could
physically incorporate Pinsley’s Nth visitor selection system (that solicits
comments from users through a remote system) into McDonald, but whether
IPR2014-00420
Patent 7,370,285 B1

28
a person of ordinary skill in the art would have reason to incorporate the
teachings of Pinsley to modify McDonald. In that regard, Patent Owner’s
expert testified that collecting feedback on a website basis was well known
and that it was within the knowledge of one of skill in the art to program a
comment collecting survey to be sent to a user. See, e.g., Ex. 1022, 89:17–
20, 88:7–20, 90:16–21, 95:16–96:2. Thus, Petitioner has proffered a reason
for combining McDonald and Pinsley, which has a rational underpinning, in
support of Petitioner’s obviousness argument. See KSR, 550 U.S. at 418.
Therefore, we conclude Petitioner has established by a preponderance of the
evidence that one would have been led to combine the peer review
commenting system (containing three separate and distinct systems) of
McDonald with the commenting solicitation teachings of Pinsley (containing
three separate and distinct systems) because such a combination appears to
be merely a “predictable use of prior-art elements according to their
established functions.” See id. at 417.
d. Secondary Considerations of Non-Obviousness
Factual inquiries for an obviousness determination include secondary
considerations based on evaluation and crediting of objective evidence of
nonobviousness. See Graham v. John Deere Co., 383 U.S. 1, 17 (1966).
Notwithstanding what the teachings of the prior art would have suggested to
one with ordinary skill in the art at the time of the ’285 patent’s invention,
the totality of the evidence submitted, including objective evidence of
nonobviousness, may lead to a conclusion that the challenged claims would
not have been obvious to one with ordinary skill in the art. In re Piasecki,
745 F.2d 1468, 1471-72 (Fed. Cir. 1984). Secondary considerations may
include any of the following: long-felt but unsolved needs, failure of others,
IPR2014-00420
Patent 7,370,285 B1

29
unexpected results, commercial success, copying, licensing, and praise. See
Graham, 383 U.S. at 17; Leapfrog Enters., Inc. v. Fisher-Price, Inc., 485
F.3d 1157, 1162 (Fed. Cir. 2007).
To be relevant, evidence of nonobviousness must be commensurate in
scope with the claimed invention. In re Kao, 639 F.3d 1057, 1068 (Fed. Cir.
2011) (citing In re Tiffin, 448 F.2d 791, 792 (CCPA 1971)); In re Hiniker
Co., 150 F.3d 1362, 1369 (Fed. Cir. 1998). In that regard, in order to be
accorded substantial weight, there must be a nexus between the merits of the
claimed invention and the evidence of secondary considerations. In re
GPAC Inc., 57 F.3d 1573, 1580 (Fed. Cir. 1995). “Nexus” is a legally and
factually sufficient connection between the objective evidence and the
claimed invention, such that the objective evidence should be considered in
determining nonobviousness. Demaco Corp. v. F. Von Langsdorff Licensing
Ltd., 851 F.2d 1387, 1392 (Fed. Cir. 1988). The burden of showing that
there is a nexus lies with the patent owner. Id.; see Paulsen, 30 F.3d at
1482. Here, Patent Owner argues that commercial success, industry praise,
and copying demonstrate that the challenged claims would not have been
obvious to a person of ordinary skill in the art. PO Resp. 46–57.
(1) Commercial Success
As evidence of commercial success, Patent Owner alleges its “page-
specific feedback solution embodying the claimed invention
2
is utilized by
“half of the Fortune 50 organizations.” Id. at 53 (citing Ex. 2015). Patent
Owner further contends that “this feedback solution, as designated by

2
Patent Owner identifies “the claimed invention” in its discussion of
secondary considerations as independent claims 1 and 25. Pet. 33 n.9.
IPR2014-00420
Patent 7,370,285 B1

30
OpinionLab’s [+] feedback symbol, had already been ‘adopted by hundreds
of brands and implemented on more than 6,500 websites worldwide.’” Id.
(citing Ex. 2007; Ex. 2002 ¶ 106).
We are not persuaded by Patent Owner’s arguments.
Initially, we note that “[e]vidence of commercial success, or other
secondary considerations, is only significant if there is a nexus between the
claimed invention and the commercial success.” Ormco Corp. v. Align
Tech., Inc., 463 F.3d 1299, 1311–12 (Fed. Cir. 2006). In its summary of the
legal standard for secondary considerations, Patent Owner states, generally,
that “[a] nexus is presumed[] when a marketed product is coextensive with
the asserted claims.” PO Resp. 47 (citing Teva Pharms. USA, Inc. v.
Sandoz, Inc., 723 F.3d 1363, 1372 (Fed. Cir. 2013)). Patent Owner,
however, offers no persuasive explanation or evidence to support the
allegation that its allegedly commercially successful product is coextensive
with the claimed invention. In fact, Patent Owner’s reference to the patent
markings on its product appears to evidence that the product is not
coextensive with the claimed invention, as its product lists at least fourteen
patents, in addition to the ’285 patent, that apply to its product. See id. at
47–48.
In its specific discussion of “nexus,” Patent Owner contends that “[a]
nexus between the OpinionLab product and the challenged claims is easy to
show,” but simply alleges that its product includes the limitations of claim 1
and references the patent markings discussed above. Id. at 47. To show
how commercial success supports non-obviousness, however, Patent Owner
must prove that the sales were a direct result of the unique characteristics of
the invention, and not a result of economic and commercial factors unrelated
IPR2014-00420
Patent 7,370,285 B1

31
to the quality of the patented subject matter. Patent Owner has not so
shown. See In re Applied Materials, Inc., 692 F.3d 1289, 1299–1300 (Fed.
Cir. 2012). Even if Patent Owner’s product includes the limitations of claim
1, there is no explanation as to how these limitations are related to the
alleged commercial success other than simply alleging that the limitations
are present in its product. See PO Resp. 47–52. Patent Owner provides
examples of the database and reporting module features of its product and
discusses use of various features by its customers, but does not attempt to tie
any of these features to the alleged commercial success. Patent Owner’s
specific discussion of “commercial success” does not cure this deficiency.
See id. at 52–53 (alleging that “OpinionLab’s page-specific user feedback
solution embodying the claimed invention is utilized by an extensive list of
customers” and that “OpinionLab’s customer list has continued to grow”
without tying this alleged commercial success to the unique characteristics
of the claims).
Accordingly, we are not persuaded by Patent Owner’s allegations of
commercial success.
(2) Industry Praise
Patent Owner contends, generally, that it “has received widespread
industry recognition and praise for the claimed technology as demonstrated
in the many articles written on OpinionLab’s page-specific user feedback
solution.” Id. at 53 (citing Ex. 2002 ¶ 107). As with commercial success,
however, evidence of industry praise is only relevant when it is directed to
the merits of the invention claimed. See Ormco, 463 F.3d at 1311. Patent
Owner identifies various documents discussing features of its product. See
PO Resp. 54. For example, Patent Owner quotes a discussion from Exhibit
IPR2014-00420
Patent 7,370,285 B1

32
2009 touting “the iconic image of a rotating plus/minus sign,” a discussion
from Exhibit 2020 stating “OpinionLab, the pioneer and leader in voice-of-
customer (VOC) listening technologies,” and a discussion from Exhibit 2017
regarding “OpinionLab’s [+] feedback symbol.” Id. Notably, these
materials quoted in the Patent Owner Response praise OpinionLab’s product
in general. Patent Owner does not identify any praise due to specific
features that are present in the claims. Patent Owner has not established a
sufficient nexus with the claimed invention.
Accordingly, we are not persuaded by Patent Owner’s allegations of
industry praise.
(3) Copying
Patent Owner contends that “there is strong evidence of copying by
others of OpinionLab’s page-specific user feedback solution covered by the
’285 Patent claims.” Id. at 55. Patent Owner notes that “[t]his copying is
generally shown for at least the reasons identified in Exhibit 1012 to the
Petition, which includes OpinionLab’s Infringement Contentions. . . .”
3
Id.
Patent Owner notes that “[t]he Infringement Contentions of Exhibit 1012
illustrate in detail how each element of the challenged claims are present in
Petitioner’s system.” Id. Patent Owner’s arguments regarding copying are
not persuasive.
“[C]opying requires evidence of efforts to replicate a specific
product.” Wyers v. Master Lock Co., 616 F.3d 1231, 1246 (Fed. Cir. 2010).

3
To the extent Patent Owner relies on arguments in Exhibit 1012 not
discussed in the Patent Owner response, we decline to address those
arguments. See 37 C.F.R. § 42.6(a)(3) (“Arguments must not be
incorporated by reference from one document into another document.”).
IPR2014-00420
Patent 7,370,285 B1

33
Patent Owner does not provide any analysis or explanation of how other
companies, such as Petitioner, allegedly copied its product that allegedly
includes the features of the claimed invention. Rather, Patent Owner simply
shows similarities between its products and those offered by Petitioner. See
Pet. 55–56.
Accordingly, we are not persuaded by Patent Owner’s allegations of
copying.
e. Conclusion
We have considered the entirety of the evidence, including the
evidence of obviousness and the evidence submitted by Patent Owner to
show commercial success. For the reasons set forth above, Petitioner has
established, based on a preponderance of the evidence, that claims 1, 4, 5, 7,
9, 12, 13, and 15 would have been obvious over the combination of
McDonald and Pinsley.
E. Petitioner’s Motion to Exclude
Petitioner filed a Motion to Exclude Evidence seeking to exclude
portions of the Shamos Declaration (Ex. 2002) and portions of the
deposition testimony of Dr. Shamos (Ex. 1022). Paper 33 (“Mot.”). Even
without excluding this evidence, we have determined that Petitioner has
established, based on a preponderance of the evidence, the unpatentability of
claims 1, 4, 5, 7, 9, 12, 13, and 15 of the ’285 patent. Further, Petitioner’s
arguments on these items go to the weight to be accorded to the evidence.
See, e.g., Mot. 4 (Dr. Shamos allegedly failed to consider any of the prior art
in the field of the challenged patent), 4 n.1 (Dr. Shamos’s characterization of
a person of ordinary skill in the art), 7 (Dr. Shamos did not conduct
independent research or analysis regarding secondary considerations).
IPR2014-00420
Patent 7,370,285 B1

34
Decisions regarding the appropriate weight to accord to evidence are within
the purview of the Panel.
For these reasons, we deny Petitioner’s motion.
III. CONCLUSION
We conclude Petitioner has shown by a preponderance of the evidence
the unpatentability of claims 1, 4, 5, 7, 9, 12, 13, and 15 under
35 U.S.C. § 103(a) for obviousness over McDonald and Pinsley.

IV. ORDER
For the reasons given, it is
ORDERED that claims 1, 4, 5, 7, 9, 12, 13, and 15 of the ’285 patent
are held unpatentable;
FURTHER ORDERED that Petitioner’s Motion to Exclude is denied;
and
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.

IPR2014-00420
Patent 7,370,285 B1

35
FOR PETITIONER:

Robert Steinberg
Neil A. Rubin
Jonathan M. Jackson
Philip Wang
LATHAM & WATKINS LLP
bob.steinberg@lw.com
neil.rubin@lw.com
jonathan.jackson@lw.com
philip.wang@lw.com

For PATENT OWNER:

Christopher W. Kennerly
Timothy P. Cremen
Naveen Modi
PAUL HASTINGS LLP
chriskennerly@paulhastings.com
timothycremen@paulhastings.com
naveenmodi@paulhastings.com