2Wire, Inc.v.TQ Delta LLCDownload PDFPatent Trial and Appeal BoardMay 29, 201513284549 (P.T.A.B. May. 29, 2015) Copy Citation Trials@uspto.gov Paper 18 571-272-7822 Entered: May 29, 2015 UNITED STATES PATENT AND TRADEMARK OFFICE ____________ BEFORE THE PATENT TRIAL AND APPEAL BOARD ____________ 2WIRE, INC., Petitioner, v. TQ DELTA LLC, Patent Owner. ____________ Case IPR2015-00242 Patent 8,218,610 B2 ____________ Before KALYAN K. DESHPANDE, JUSTIN T. ARBES, and TREVOR M. JEFFERSON, Administrative Patent Judges. ARBES, Administrative Patent Judge. DECISION Denying Institution of Inter Partes Review 37 C.F.R. § 42.108 IPR2015-00242 Patent 8,218,610 B2 2 Petitioner 2Wire, Inc. filed a Petition (Paper 2, “Pet.”) to institute an inter partes review of claims 1, 6, 7, and 31 of U.S. Patent No. 8,218,610 B2 (Ex. 1001, “the ’610 patent”) pursuant to 35 U.S.C. §§ 311–19. Patent Owner TQ Delta LLC filed a Preliminary Response (Paper 11, “Prelim. Resp.”). We have jurisdiction under 35 U.S.C. § 314. Pursuant to 35 U.S.C. § 314(a), the Director may not authorize an inter partes review unless the information in the petition and preliminary response “shows that there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” For the reasons that follow, we have decided not to institute an inter partes review. I. BACKGROUND A. The ’610 Patent The ’610 patent pertains to multicarrier communications systems, such as digital subscriber line (DSL) systems using discrete multitone modulation (DMT), where a transmitter communicates over a communication channel by modulating “[c]arrier signals (carriers) or sub-channels spaced within a usable frequency band of the communication channel.” Ex. 1001, col. 1, ll. 32–38. In such a system, the phase and amplitude of the modulated carrier signals typically “can be considered random” because they “result from the modulation of an arbitrary sequence of input data bits comprising the transmitted information.” Id. at col. 1, ll. 47–51. In some situations, however, the phases of the modulated carriers may combine to produce a spike in the transmitted signal, which increases the peak-to-average power ratio (PAR) of the signal, i.e., the “ratio of the instantaneous peak value (i.e., maximum magnitude) of a signal parameter IPR2015-00242 Patent 8,218,610 B2 3 (e.g., voltage, current, phase, frequency, power) to the time-averaged value of the signal parameter.” Id. at col. 1, l. 59–col. 2, l. 24. According to the ’610 patent, PAR is an important consideration in designing a DMT communication system because an increased PAR can result in high power consumption or clipping of the transmission signal. Id. at col. 2, ll. 7–26. Therefore, there was a need in the art for a system that can “effectively scramble the phase of the modulated carrier signals in order to provide a low PAR for the transmission signal.” Id. at col. 2, ll. 27–29. Figure 1 of the ’610 patent is reproduced below. Figure 1 above depicts transceiver 10 communicating transmission signal 38 over communication channel 18 (e.g., a pair of twisted wires of a telephone line) to remote transceiver 14. Id. at col. 3, ll. 24–49. Quadrature amplitude modulation (QAM) encoder 42 maps input serial data bit stream 54 in the time domain into parallel QAM symbols 58 in the frequency domain. Id. at col. 3, ll. 62–67. Modulator 46 modulates each carrier signal with a different IPR2015-00242 Patent 8,218,610 B2 4 QAM symbol 58 so that the signals have the phase and amplitude associated with the respective QAM symbol 58 (and input serial bit stream 54). Id. at col. 4, ll. 9–21. Phase scrambler 66 in modulator 46 calculates a phase shift for each carrier signal and combines the calculated phase shift with the phase characteristic of the respective carrier signal. Id. at col. 4, l. 47–col. 5, l. 3, col. 6, ll. 40–53. Phase scrambler 66 calculates the phase shift for a carrier signal by (1) determining one or more values “independently of the QAM symbols 58, and, therefore, independently of the bit value(s) modulated onto the carrier signal,” and (2) solving a “predetermined equation” using the value associated with the carrier signal. Id. at col. 4, ll. 47–52, 63–66. For example, the value for a carrier signal may be “derived from one or more predefined parameters, such as a pseudo-random number generator.” Id. at col. 4, ll. 52–57. According to the ’610 patent, the use of a value determined independently of the input bit values results in a lower PAR for the transmission signal. Id. at col. 2, l. 33–col. 3, l. 2. Transceiver 10 combines all of the carrier signals to form the transmission signal that is sent to remote transceiver 14. Id. at col. 8, ll. 13–18. B. Illustrative Claim Claim 1 of the ’610 patent recites: 1. A method, in a first transceiver that uses a plurality of carrier signals for receiving a bit stream that was transmitted by a second transceiver, wherein each carrier signal has a phase characteristic associated with the bit stream, the method comprising: receiving the bit stream from the second transceiver, wherein: IPR2015-00242 Patent 8,218,610 B2 5 each carrier signal is associated with a value determined independently of any bit value of the bit stream carried by that respective carrier signal, the value associated with each carrier signal determined by a pseudo-random number generator, a phase shift for each carrier signal is at least based on: the value associated with that carrier signal, and the combining of a phase for each carrier signal with the phase characteristic of that respective carrier signal so as to substantially scramble the phase characteristics of the plurality of carrier signals, and multiple carrier signals corresponding to the plurality of phase shifted and scrambled carrier signals are used by the first transceiver to demodulate a same bit value of the received bit stream; and wherein: the first and second transceivers communicate over one or more of a pair of twisted wires of a telephone subscriber line and fiber optic, and the first and second transceivers transport video. C. The Prior Art Petitioner relies on the following prior art: U.S. Patent No. 5,694,415, issued Dec. 2, 1997 (Ex. 1009, “Suzuki ’415”); U.S. Patent No. 5,903,614, issued May 11, 1999 (Ex. 1003, “Suzuki ’614”); U.S. Patent No. 6,301,268 B1, filed Mar. 10, 1998, issued Oct. 9, 2001 (Ex. 1004, “Laroia”); U.S. Patent No. 6,781,951 B1, filed Oct. 22, 1999, issued Aug. 24, 2004 (Ex. 1008, “Fifield”); IPR2015-00242 Patent 8,218,610 B2 6 ANSI TECHNICAL REPORT TR-004, NETWORK MIGRATION 1997 (Ex. 1014, “TR-004”); and ANSI T1.413-1998, DRAFT AMERICAN NATIONAL STANDARD FOR TELECOMMUNICATIONS, NETWORK AND CUSTOMER INSTALLATION INTERFACES—ASYMMETRIC DIGITAL SUBSCRIBER LINE (ADSL) METALLIC INTERFACE (John Bingham & Frank Van der Putten, eds., 1998) (Ex. 1006, “T1.413”). D. The Asserted Grounds Petitioner challenges claims 1, 6, 7, and 31 of the ’610 patent on the following grounds: Reference(s) Basis T1.413, Laroia, Suzuki ’415, and TR-004 35 U.S.C. § 103(a) T1.413, Fifield, Suzuki ’415, and TR-004 35 U.S.C. § 103(a) T1.413, Suzuki ’614, Suzuki ’415, and TR-004 35 U.S.C. § 103(a) E. Claim Interpretation The Board interprets claims using the “broadest reasonable construction in light of the specification of the patent in which [they] appear[].” 37 C.F.R. § 42.100(b); see Office Patent Trial Practice Guide, 77 Fed. Reg. 48,756, 48,766 (Aug. 14, 2012); In re Cuozzo Speed Techs., LLC, 778 F.3d 1271, 1278–82 (Fed. Cir. 2015). Petitioner argues that no terms in claims 1, 6, 7, and 31 require interpretation. Pet. 14. Patent Owner proposes interpretations for two phrases: “a value determined independently of any bit value” and “multiple carrier signals corresponding to the plurality IPR2015-00242 Patent 8,218,610 B2 7 of phase shifted and scrambled carrier signals are used by the first transceiver to demodulate a same bit value of the received bit stream.” Prelim. Resp. 10–16. After reviewing the parties’ papers, we determine that no claim terms require express interpretation for purposes of this Decision. II. DISCUSSION A. Obviousness Based on T1.413, Laroia, Suzuki ’415, and TR-004 Petitioner contends that claims 1, 6, 7, and 31 are unpatentable over T1.413, Laroia, Suzuki ’415, and TR-004 under 35 U.S.C. § 103(a). Pet. 26–33. Petitioner relies on T1.413 and Laroia for the limitations recited in the preamble of independent claims 1 and 31 1 (e.g., first and second transceivers, carrier signals), relies on T1.413 alone for the step of “receiving the bit stream from the second transceiver,” and relies on “T1.413 in combination with Laroia and Suzuki ’415” for the limitations of “each carrier signal [being] associated with a value determined independently of any bit value of the bit stream carried by that respective carrier signal,” a phase shift based on the value associated with the carrier signal, and scrambling the phase characteristics of the carrier signals. Id. at 26–28. Petitioner further cites T1.413 and Laroia for the limitation of using the multiple carrier signals to demodulate the “same bit value of the received bit stream,” cites T1.413 for the limitations of communication over a “pair of twisted wires of a telephone subscriber line and fiber optic” and transporting video, and cites T1.413 and TR-004 for the limitation of using the 1 Claims 1 and 31 are identical but for the recitation in claim 1 that the first and second transceivers “transport video,” whereas claim 31 recites that they “are used for internet access.” IPR2015-00242 Patent 8,218,610 B2 8 transceivers for internet access. Id. at 28–29. Petitioner provides a claim chart citing various portions of T1.413, Laroia, and Suzuki ’415, and states that the claim chart is supported by the Declaration of Krista S. Jacobsen, Ph.D. Id. at 26, 30–33 (citing Ex. 1002 ¶¶ 162–242, App. B1). We are not persuaded that Petitioner has established a reasonable likelihood of prevailing on its asserted ground based on T1.413, Laroia, Suzuki ’415, and TR-004. “Section 103(a) forbids issuance of a patent when ‘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, 405 (2007). A patent claim, however, “is not proved obvious merely by demonstrating that each of its elements was, independently, known in the prior art.” Id. at 418. “Rather, obviousness requires the additional showing that a person of ordinary skill at the time of the invention would have selected and combined those prior art elements in the normal course of research and development to yield the claimed invention.” Unigene Labs., Inc. v. Apotex, Inc., 655 F.3d 1352, 1360 (Fed. Cir. 2011). For an obviousness analysis, “it can be important to identify a reason that would have prompted a person of ordinary skill in the relevant field to combine the elements in the way the claimed new invention does.” KSR, 550 U.S. at 418. Further, an assertion of obviousness “‘cannot be sustained by mere conclusory statements; instead, there must be some articulated reasoning with some rational underpinning to support the legal conclusion of obviousness.’” Id. (citing In re Kahn, 441 F.3d 977, 988 (Fed. Cir. 2006)). IPR2015-00242 Patent 8,218,610 B2 9 Petitioner does not explain sufficiently in the Petition why a person of ordinary skill in the art would have had reason to combine the teachings of T1.413, Laroia, Suzuki ’415, and TR-004 to achieve the methods of claims 1, 6, 7, and 31, for three reasons. First, with respect to Laroia, Petitioner argues as follows: It would have been obvious to combine the network structures disclosed in T1.413 to implement them with the multicarrier modulation and transmission systems disclosed in Laroia. As would have been appreciated by a person having ordinary skill in the art at the time of the alleged invention, T1.413 is the standard for ADSL [asymmetric digital subscriber line], which describes operations performed by ADSL transceivers (referred to as the ATU-C and ATU-R). Pet. 28–29 (citations omitted). Petitioner’s statement that it “would have been obvious” to implement “the network structures” disclosed in T1.413 with “the multicarrier modulation and transmission systems” of Laroia is conclusory and does not demonstrate a reason to combine. See KSR, 550 U.S. at 417–18; Unigene, 655 F.3d at 1360; In re Chaganti, 554 F. App’x 917, 922 (Fed. Cir. 2014) (“It is not enough to say that there would have been a reason to combine two references because to do so would ‘have been obvious to one of ordinary skill.’ Such circular reasoning is not sufficient —more is needed to sustain an obviousness rejection.” (citation omitted)). Petitioner’s other statement also is unpersuasive. The fact that T1.413 was a standard for ADSL does not explain sufficiently why a person of ordinary skill in the art would have combined its teachings with features of Laroia’s IPR2015-00242 Patent 8,218,610 B2 10 particular system, such as assigning a multiplier via random assignment, as Petitioner contends. 2 See Pet. 27, 30–31. Second, with respect to Suzuki ’415, Petitioner argues that “[i]t would have been obvious to one of ordinary skill in the art to combine the teachings of T1.413 and Laroia with Suzuki ’415, because Suzuki ’415 supplies a method for generating the random numbers disclosed in Laroia.” Id. at 27. The mere fact that Suzuki ’415 discloses “a method” (i.e., one particular way) of generating random numbers does not establish a sufficient reason why an ordinarily skilled artisan would have looked to Suzuki ’415’s method of random number generation (as opposed to any other, for instance), when contemplating modifying the combination of T1.413 and Laroia. Accordingly, Petitioner has not set forth, in the Petition, a rationale for combining the random number calculations of Suzuki ʼ415 with T1.413 and Laroia in reaching a conclusion of obviousness. Third, even assuming that Petitioner had provided a sufficient rationale to combine T1.413, Laroia, and Suzuki ’415, Petitioner has not provided any reason to combine the teachings of those references with TR-004. Petitioner’s asserted ground is based on the combination of all four references, but the only mention of TR-004 in the asserted ground is that, 2 Petitioner also argues, in asserting that its three asserted grounds are not redundant to each other, that “Laroia teaches that [its] technique is applicable in an ADSL system, such as that of the ADSL standard known as T1.413.” Pet. 24. To the extent Petitioner may contend that this is a reason for combining the teachings of Laroia and T1.413, we note that mere suggestion that a technique is applicable in an ADSL system, including that disclosed in T1.413, does not explain sufficiently why or how a person of ordinary skill in the art would have considered combining them. Petitioner also does not point to where Laroia allegedly teaches that its technique can be applied in an ADSL system. See id. IPR2015-00242 Patent 8,218,610 B2 11 with respect to claim 31, “TR-004 further discusses ADSL network migration options including standardized ADSL that uses DMT . . . and that accesses the internet.” Id. at 29. Petitioner does not identify any reason why a person of ordinary skill in the art would have combined any teachings of TR-004 with those of the other cited references, or explain what specific features from TR-004 would be combined. Accordingly, Petitioner has not provided, in the Petition, sufficient explanation of a reason to combine the various teachings of the prior art. See 37 C.F.R. § 42.104(b)(4)–(5); Prelim. Resp. 25–29. We recognize that the Declaration of Dr. Jacobsen (Ex. 1002) includes additional discussion regarding the combination of T1.413, Laroia, Suzuki ’415, and TR-004. See, e.g., Ex. 1002 ¶¶ 201–06, 235–42. That analysis, however, is not discussed adequately in the Petition itself, as Petitioner only includes blanket citations to eighty-two paragraphs and a thirty-three-page appendix of the Declaration. See Pet. 26–29 (citing Ex. 1002 ¶¶ 161–242, App. B1). A petition seeking inter partes review must identify “[h]ow the construed claim is unpatentable under the statutory grounds identified” and “where each element of the claim is found in the prior art,” and must explain the “relevance of the evidence to the challenge raised,” because the Board may “give no weight to the evidence where a party has failed to state its relevance or to identify specific portions of the evidence that support the challenge.” 37 C.F.R. § 42.104(b)(4)–(5); see also 37 C.F.R. § 42.22(a)(2) (a petition must include a “full statement of the reasons for the relief requested, including a detailed explanation of the significance of the evidence”). Dr. Jacobsen’s analysis is not reflected in the Petition itself, and cannot be incorporated in the Petition by reference. See 37 C.F.R. IPR2015-00242 Patent 8,218,610 B2 12 § 42.6(a)(3) (“Arguments must not be incorporated by reference from one document into another document.”); Cisco Sys., Inc. v. C-Cation Techs., LLC, Case IPR2014-00454, slip op. at 7–10 (PTAB Aug. 29, 2014) (Paper 12) (informative) (noting that “[o]ne purpose of the prohibition against incorporation by reference is to eliminate abuses” of the page limits established for the parties’ substantive papers, and that citing “large portions of another document, without sufficient explanation of those portions, amounts to incorporation by reference”). Consequently, we do not consider information presented in the Declaration but not discussed sufficiently in the Petition. Petitioner has not demonstrated a reasonable likelihood of prevailing on its assertion that claims 1, 6, 7, and 31 are unpatentable over T1.413, Laroia, Suzuki ’415, and TR-004. B. Obviousness Based on T1.413, Fifield, Suzuki ’415, and TR-004 Petitioner’s asserted ground of unpatentability based on T1.413, Fifield, Suzuki ’415, and TR-004 under 35 U.S.C. § 103(a) suffers from the same deficiency as its ground based on T1.413, Laroia, Suzuki ’415, and TR-004. See supra Section II.A; Prelim. Resp. 35–36. Petitioner relies on T1.413 and Fifield for the limitations recited in the preambles of independent claims 1 and 31 (e.g., first and second transceivers, carrier signals) and the step of “receiving the bit stream from the second transceiver,” and relies on “T1.413, in combination with Fifield and Suzuki ’415,” for the limitations of “each carrier signal [being] associated with a value determined independently of any bit value of the bit stream carried by that respective carrier signal,” a phase shift based on the value associated IPR2015-00242 Patent 8,218,610 B2 13 with the carrier signal, scrambling the phase characteristics of the carrier signals, using the multiple carrier signals to demodulate the “same bit value of the received bit stream,” and transporting video. Pet. 34–35. Petitioner further cites T1.413 for the limitation of communication over a “pair of twisted wires of a telephone subscriber line and fiber optic,” and cites T1.413 and TR-004 for the limitation of using the transceivers for internet access. Id. at 35–36. Petitioner includes a claim chart and cites eighty paragraphs and a thirty-four-page appendix of Dr. Jacobsen’s Declaration. Id. at 33, 36–40 (citing Ex. 1002 ¶¶ 243–323, App. C1). Petitioner merely alleges that the challenged claims would have been “obvious” in view of the four prior art references, and describes how the references allegedly teach various aspects of the claims. See id. at 33–36. Petitioner does not identify in the Petition any reason why an ordinarily skilled artisan would have had reason to combine the teachings of the various references, and Petitioner cannot rely on the more detailed analysis of Dr. Jacobsen, as that analysis is not discussed or reflected in the arguments made in the Petition itself. See id.; KSR, 550 U.S. at 417–18; Unigene, 655 F.3d at 1360; Chaganti, 554 F. App’x at 922. Also, the discussion of TR-004 in the Petition is identical to that for the asserted ground based on T1.413, Laroia, Suzuki ’415, and TR-004, and is insufficient for the same reasons. See Pet. 29, 36; supra Section II.A. Petitioner has not shown sufficiently a reason to combine the teachings of T1.413 with those of Fifield, Suzuki ’415, and TR-004, or explained sufficiently what aspects of the references would be combined. IPR2015-00242 Patent 8,218,610 B2 14 Accordingly, Petitioner has not demonstrated a reasonable likelihood of prevailing on its assertion that claims 1, 6, 7, and 31 are unpatentable over T1.413, Fifield, Suzuki ’415, and TR-004. C. Obviousness Based on T1.413, Suzuki ’614, Suzuki ’415, and TR-004 Petitioner’s asserted ground of unpatentability based on T1.413, Suzuki ’614, Suzuki ’415, and TR-004 under 35 U.S.C. § 103(a) is deficient as well. See Prelim. Resp. 41–42. Similar to its other asserted grounds, Petitioner relies on T1.413 and Suzuki ’614 for the limitations recited in the preambles of independent claims 1 and 31 (e.g., first and second transceivers, carrier signals), relies on T1.413 alone for the step of “receiving the bit stream from the second transceiver,” and relies on “T1.413 in combination with Suzuki ’614 and Suzuki ’415” for the limitations of “each carrier signal [being] associated with a value determined independently of any bit value of the bit stream carried by that respective carrier signal,” a phase shift based on the value associated with the carrier signal, and scrambling the phase characteristics of the carrier signals. Pet. 41–43. Petitioner further cites T1.413 for the limitations of using the multiple carrier signals to demodulate the “same bit value of the received bit stream,” 3 communication over a “pair of twisted wires of a telephone subscriber line and fiber optic,” and transporting video, and cites T1.413 and TR-004 for the limitation of using the transceivers for internet access. Id. at 43–45. Petitioner includes a claim chart and cites ninety-nine paragraphs 3 Petitioner also cites Laroia for the “same bit value” limitation. Pet. 43. Because the asserted ground is based only on T1.413, Suzuki ’614, Suzuki ’415, and TR-004, however, we presume that the citation of Laroia was a typographical error. IPR2015-00242 Patent 8,218,610 B2 15 and a thirty-four-page appendix of Dr. Jacobsen’s Declaration. Id. at 41, 46–49 (citing Ex. 1002 ¶¶ 324–422, App. A1). Again, Petitioner merely alleges that the claims would have been “obvious,” without explaining in the Petition any reason why a person of ordinary skill in the art would have combined the teachings of the four prior art references. See id. at 41–45. For example, with respect to the limitation of “each carrier signal [being] associated with a value determined independently of any bit value of the bit stream carried by that respective carrier signal,” Petitioner acknowledges that Suzuki ’614 does not “describe the details” of how the reference generates random phase shift data for each subcarrier, and argues that Suzuki ’415 teaches the generation of M-bit random numbers, which, according to Petitioner, are “determined independently of any bit value” because they are random. Id. at 42–43 (citing Ex. 1009, col. 1, ll. 52–55, col. 3, ll. 25–30). Petitioner then makes the conclusory statement that “[i]t would be obvious to one of ordinary skill in the art to combine the teachings of Suzuki ’614 and Suzuki ’415 with the network of T1.413,” without identifying in the Petition any reason why an ordinarily skilled artisan would have thought to do so. See id. The mere fact that Suzuki ’614 does not describe the “details” of its random phase shift data does not mean that a person of ordinary skill in the art would have looked to the particular calculations of Suzuki ’415. See id. Indeed, as Patent Owner correctly points out, Suzuki ’614 only discloses the end result of phase shifts, without any detail as to how the phase shifts are calculated. See Prelim. Resp. 38–40; Ex. 1003, col. 6, l. 36–col. 7, l. 18, Fig. 6. Accordingly, Petitioner has not set forth a rationale for combining the IPR2015-00242 Patent 8,218,610 B2 16 calculations of Suzuki ʼ415 with T1.413, Suzuki ʼ614, and TR-004 in reaching a conclusion of obviousness. In addition, Petitioner cannot rely on the more detailed analysis of Dr. Jacobsen that is not discussed sufficiently in the Petition, and Petitioner’s assertions regarding TR-004, which are identical to those it makes for the other grounds addressed above, are inadequate. See Pet. 29, 36, 41–45; KSR, 550 U.S. at 417–18; Unigene, 655 F.3d at 1360; Chaganti, 554 F. App’x at 922; supra Sections II.A, II.B. Petitioner has not shown sufficiently a reason to combine the teachings of T1.413 with those of Suzuki ’614, Suzuki ’415, and TR-004, or explained sufficiently what aspects of the references would be combined. Accordingly, Petitioner has not demonstrated a reasonable likelihood of prevailing on its assertion that claims 1, 6, 7, and 31 are unpatentable over T1.413, Suzuki ’614, Suzuki ’415, and TR-004. D. Conclusion We conclude that Petitioner has not demonstrated a reasonable likelihood that at least one of the challenged claims of the ’610 patent is unpatentable based on the asserted grounds. Therefore, we do not institute an inter partes review on any of the asserted grounds as to any of the challenged claims. III. ORDER In consideration of the foregoing, it is hereby: ORDERED that the Petition is denied as to all challenged claims of the ’610 patent. IPR2015-00242 Patent 8,218,610 B2 17 PETITIONER: Jennifer A. Albert Eleanor M. Yost GOODWIN PROCTER LLP Jalbert@goodwinprocter.com eyost@goodwinprocter.com PATENT OWNER: Peter J. McAndrews Thomas J. Wimbiscus Christopher M. Scharff McANDREWS HELD & MALLOY, LTD. pmcandrews@mcandrews-ip.com wimbiscus@mcandrews-ip.com cscharff@mcandrews-ip.com Copy with citationCopy as parenthetical citation