Cisco Systems, Inc.v.Bockstar Technologies LLCDownload PDFPatent Trial and Appeal BoardFeb 3, 201509408380 (P.T.A.B. Feb. 3, 2015) Copy Citation Trials@uspto.gov Paper 8 Tel: 571-272-7822 Entered: February 3, 2015 UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE PATENT TRIAL AND APPEAL BOARD CISCO SYSTEMS, INC., Petitioner, v. BOCKSTAR TECHNOLOGIES LLC, Patent Owner. Case IPR2014-01193 Patent 6,684,241 B1 Before BEVERLY M. BUNTING, BARBARA A. PARVIS, and MATTHEW R. CLEMENTS, Administrative Patent Judges. BUNTING, Administrative Patent Judge. DECISION Denying Institution of Inter Partes Review 37 C.F.R. § 42.108 IPR2014-01193 Patent 6,684,241 B1 2 I. INTRODUCTION Cisco Systems, Inc. (“Petitioner”) filed a Petition requesting inter partes review of claims 1–39 (the “challenged claims”) of U.S. Patent No. 6,684,241 B1 (Exhibit 1001, “the ’241 patent”) pursuant to 35 U.S.C. §§ 311–319. Paper 1 (“Pet.”). Patent Owner, Bockstar Technologies LLC, (“Patent Owner”) timely filed a Preliminary Response to the Petition. Paper 6 (“Prelim. Resp.”). We have jurisdiction under 35 U.S.C. § 314, which provides that an inter partes review may not be instituted “unless . . . there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” Upon consideration of the information presented in the Petition and Preliminary Response, we determine that Petitioner has not demonstrated that there is a reasonable likelihood that Petitioner would prevail with respect to at least one challenged claim. Accordingly, we deny the petition and decline to institute an inter partes review of claims 1–39 of the ’241 patent based on the asserted ground. II. BACKGROUND A. Related Proceedings Petitioner and Patent Owner indicate that the ’241 patent is the subject of the following judicial matter: Bockstar Technologies LLC v. Cisco Systems, Inc. et al., No. 1:13-cv-2020 (D. Del., filed December 11, 2013). Pet. 3; Paper 4, 1. IPR2014-01193 Patent 6,684,241 B1 3 B. The ’241 Patent (Ex. 1001) The ’241 patent is directed to an apparatus and method for configuring a first network device that is a member of a subnet. Ex. 1001, 1:20–21. In a preferred embodiment, the first network device is an unconfigured router 14 capable of monitoring traffic in its local subnet 12 transmitted by an already configured router, and based on the monitored traffic, configuring itself to communicate with other routers. Id. at 3:29–32, 41–45. The configured router includes memory 17 for storing subnet related configuration data. Id. Unconfigured router 14 includes “a configuration database 22 for storing configuration data parsed and processed from monitored packets, a configuration module 24 for configuring the router 14 in accord with the data in the configuration database 22, and a plurality of inter-router protocol modules 26 for communicating with other routers 14.” Id. at 3:51–58. Data packets transmitted within the subnet include “message data (e.g., data packets), control data (e.g., control packets), or any other type of data transported by packets.” Id. at 3:48–51. Figure 3, reproduced below, further illustrates the process for configuring a router to be added to a subnet. IPR2014-01193 Patent 6,684,241 B1 4 Figure 3 shows a process for configuring a router added to a subnet. In step 300, the router to be configured passively retrieves packets having configuration data by monitoring traffic on the subnet, as shown in Figure 4. Id. at 4:5–27. The retrieved packets are parsed to determine the configuration data, and the parsed configuration data is stored in the configuration database for subsequent use in configuring the router. Id. Additionally, in step 302, unconfigured router 14 can actively retrieve configuration data from another network device in the subnet, as shown in Figure 5. Id. at 4:67–5:3. In one embodiment, unconfigured router 14 may receive an advertisement from another router that is preconfigured to transmit specified data via the advertisement. Id. at 5:8–12. In another embodiment, unconfigured router 14 accesses the server and generates a data request message containing the Internet Protocol address of each router in the subnet. Id. at 5:33–37. The server generates a reply message containing the relevant information that is transmitted back to unconfigured router 14. Id. at 5:39–49. IPR2014-01193 Patent 6,684,241 B1 5 As shown in step 304, the retrieved data is “utilized (i.e., processed in many cases) to determine additional configuration data” and “[a]ny necessary data may be calculated.” Id. at 5:56–58. After the configuration data “is parsed and/or generated from all sources,” in step 306 the configuration data is stored in the configuration database, and in step 308 the unconfigured router to be added is configured using the data in the database. Id. at 6:12–22. C. Illustrative Claim Of challenged claims 1–39 of the ’241 patent, claims 1, 11, 21, 30, 34, and 39 are independent. Claim 1 is illustrative of the challenged claims and is reproduced below: 1. A method of configuring an unconfigured first network device that is a part of a subnet, the subnet having a second network device, the method comprising: retrieving packets having configuration data at the unconfigured first network device, the retrieved packets being transmitted by the second network device; parsing the retrieved packets to ascertain the configuration data; storing at least a portion of the configuration data parsed from the retrieved packets in a configuration database associated with the unconfigured first network device; utilizing at least one datum of the configuration data to produce additional configuration data; and storing the additional configuration data in the configuration database, the first network device operating in accord with the data in the configuration database. IPR2014-01193 Patent 6,684,241 B1 6 D. The Prior Art Petitioner relies on the following prior art references (Pet. 4) and the Declaration of Dr. Paul Clark (Ex. 1005): Reference Patent/Printed Publication No. Date Exhibit RFC 1812 Baker, Fred, Network Working Group RFC 1812, Cisco Systems June 1995 1003 AutoInstall Internet Archive, http://www.cisco.com/warp/public /417/12.html Dec. 27, 1996 1004 E. Asserted Grounds Petitioner asserts that claims 1–39 of the ’241 patent are unpatentable under 35 U.S.C. § 103(a) as obvious over AutoInstall and RFC 1812. Pet. 4. III. ANALYSIS A. Claim Interpretation In an inter partes review, “[a] claim in an unexpired patent shall be given its broadest reasonable construction in light of the specification of the patent in which it appears.” 37 C.F.R. § 42.100(b); see Office Patent Trial Practice Guide, 77 Fed. Reg. 48,756, 48,764 (Aug. 14, 2012) (Claim Construction); In re Am. Acad. of Sci. Tech. Ctr., 367 F.3d 1359, 1364 (Fed. Cir. 2004). Under the broadest reasonable interpretation standard, claim terms generally are given their ordinary and customary meaning, as would be understood by one of ordinary skill in the art in the context of the entire disclosure. See In re Translogic Tech., Inc., 504 F.3d 1249, 1257 (Fed. Cir. 2007). Any special definition for a claim term must be set forth in the IPR2014-01193 Patent 6,684,241 B1 7 specification “with reasonable clarity, deliberateness, and precision.” In re Paulsen, 30 F.3d 1475, 1480 (Fed. Cir. 1994). In the absence of such a definition, limitations are not to be read from the specification into the claims. See In re Van Geuns, 988 F.2d 1241, 1184 (Fed. Cir. 1993). Petitioner proposes a claim construction for each of the following claim terms: “configuration database”; “produce additional configuration data”; “control packets”; and “inter-router protocol.” Pet. 8–11. Patent Owner disputes Petitioner’s proposed constructions of “produce additional configuration data,” “control packets,” and “configuration database,” and in turn proposes a claim construction for these claim terms. Prelim. Resp. 13– 25. For purposes of this decision, we see no need to construe expressly the claim terms “configuration database,” “control packets,” and “inter-router protocol” in the challenged claims. The claim term “produce additional configuration data” is addressed below within the context of construing the claim phrase “utilizing at least one datum of the configuration data to produce additional configuration data.” “utilizing at least one datum of the configuration data to produce additional configuration data” Directing us to the Specification (Ex. 1001, 5:54–60) and relying on the testimony of its declarant, Dr. Clark, Petitioner takes the position that “one of ordinary skill in the art would understand that utilizing the configuration data to ‘produce additional configuration data’ can be performed by utilizing the configuration data to ‘determine additional configuration data.’” Pet. 10 (citing Ex. 1005 ¶¶ 30–32). Patent Owner counters that Petitioner’s construction of the claim term “produce additional configuration data” is unreasonably broad when taken in context with the entirety of the “utilizing at least one datum of the configuration data to IPR2014-01193 Patent 6,684,241 B1 8 produce additional configuration data” claim limitation. Prelim. Resp. 13. In support of its position, Patent Owner alleges that the claim term “produce” does not encompass the steps of “requesting” or “retrieving” because “[t]he ordinary meaning of ‘produce’ requires generating something new, while ‘request’ and ‘retrieve’ seek something that already exists.” Id. at 14. Relying on Figure 3 for support, Patent Owner further contends that it is the already-retrieved and parsed configuration data that is then ‘“utiliz[ed]’… to “produce additional configuration data.” Id. at 16. Patent Owner notes that the Specification describes requesting and receiving configuration data from another device on the network as “active retrieval” (Id. at 19) and “produce additional configuration data” as a “derivation or calculation that follows retrieval.” Id. at 19–20 (citing Ex. 1001, 5:53–58). Based on this disclosure, Patent Owner asserts that the claim term ‘“produce additional configuration data’ refers to processing that is distinct from the mere parsing of packets that are retrieved either passively or actively.” Id. at 20. We first address Petitioner’s proposed replacement of the term “produce” with the term “determine” in the context of the claim phrase “utilizing at least one datum of the configuration data to produce additional configuration data.” Both parties’ arguments rely on the following teaching in the Specification: once the configuration data is actively retrieved, then the process continues to step 304 in which selected data retrieved in either or both of steps 300 and 302 are utilized (i.e., processed in many cases) to determine additional configuration data. Any necessary data may be calculated. Ex. 1001, 5:53–58 (emphasis added). We note that the particular example provided involves calculating data. IPR2014-01193 Patent 6,684,241 B1 9 Based on our review, the Specification of the ’241 patent does not explicitly define the term “produce” in connection with “additional configuration data.” For example, the Specification discloses “[i]n addition at least one datum from the configuration data is processed to produce additional configuration data that also is stored in the configuration database.” Ex. 1001, Abstract; (see also 2:8, 2:44, 7:63) (emphasis added). Supporting that interpretation, Figure 3 also uses the term “process.” Id. at Fig. 3. In other contexts, we find that the Specification uses the term “produce” in accordance with its usual and customary meaning. 1 Any special definition for a claim term must be set forth in the specification “with reasonable clarity, deliberateness, and precision.” In re Paulsen, 30 F.3d 1475, 1480 (Fed. Cir. 1994). In the absence of such a definition, limitations are not to be read from the specification into the claims. See In re Van Geuns, 988 F.2d 1241, 1184 (Fed. Cir. 1993). Because the Specification does not set forth a special definition for “produce” with “reasonable clarity, deliberateness, and precision,” we construe it to have its ordinary and customary meaning as would be understood by one of ordinary skill in the art in the context of the entire disclosure. Translogic, 504 F.3d at 1257. We, therefore, decline to adopt Petitioner’s proposed construction in light of the ordinary and customary meaning of the term “produce.” 1 The Merriam-Webster Dictionary defines “produce” as “to make (something) especially by using machines”; “to make or create (something by a natural process”; and “to cause (something) to exist or happen: to cause (a particular result or effect).” Merriam-Webster.com, http://www.merriam- webster.com/dictionary/produce (last viewed on January 22, 2015). IPR2014-01193 Patent 6,684,241 B1 10 To the extent Patent Owner argues that the claim phrase “utilizing at least one datum of the configuration data to produce additional configuration data” should be considered in its entirety, we agree. See Prelim. Resp. 13. Patent Owner’s further argument, characterizing the step of “retrieving” as described in Figure 3, and in further detail in Figures 4–5, as a separate step from the step of “utilizing,” is also persuasive. See Id. at 13–21. Therefore, based on the current record, and for purposes of this proceeding, we determine that the broadest reasonable interpretation of the claim phrase “utilizing at least one datum of the configuration data to produce additional configuration data” is “utilizing at least one datum of the retrieved and parsed configuration data, by the unconfigured first network device, to create additional configuration data.” For purposes of this decision, we need not construe expressly any of the other terms in the challenged claims at this time. B. Obviousness Based on AutoInstall and RFC 1812 We now turn to Petitioner’s asserted grounds of unpatentability and Patent Owner’s arguments in its Preliminary Response. Petitioner contends that clams 1–39 are unpatentable under 35 U.S.C. § 103(a) as obvious over AutoInstall and RFC 1812. Pet. 17–57. The Declaration of Dr. Clark is cited by the Petitioner to support the analysis advocated in the Petition. Ex. 1005. Patent Owner counters that the cited references fail to disclose “utilizing at least one datum of the configuration data to produce additional configuration data.” Prelim. Resp. 31–39. Having considered the explanations and supporting evidence presented, we are not persuaded that AutoInstall and RFC 1812 teach “utilizing at least one datum of the IPR2014-01193 Patent 6,684,241 B1 11 configuration data to produce additional configuration data.” A detailed analysis of our determination follows after a brief overview of AutoInstall and RFC 1812. 1. Overview of AutoInstall (Ex. 1004) AutoInstall is a product bulletin describing how to make Cisco’s access routers plug and play by “offloading the software configuration task from the installer” and controlling it “directly from the central network operations center.” Ex. 1004, 1. AutoInstall describes three steps to configure a new router (referred to as “newrouter”): 1) learn IP address; 2) learn name; and 3) download full configuration. Id. at 2. In particular, the step of learning the IP address involves newrouter sending out an IP address request packet that is received by an existing router, which replies with the IP address of the newrouter. Id. After newrouter acquires its IP address, it learns its host name by either broadcasting a request for the global configuration file “network-confg,” or by broadcasting a reverse domain name server request over the network. Id. Once newrouter receives its name, newrouter broadcasts for its full configuration file, newrouter-confg, which is “automatically downloaded to newrouter’s running memory, thereby configuring it for full operation.” Id. 2. Overview of RFC 1812 (Ex. 1003) RFC 1812 is a document prepared by the Internet Engineering Task Force’s Network Working Group, and is an updated version of RFC 1716, the Historical Router Requirements document. RFC 1812 describes use of the Bootstrap Protocol (BOOTP), which allows a booting host to configure itself dynamically and without user supervision. Ex. 1003, 120. BOOTP is utilized “to notify a host of its assigned IP address, the IP address of a boot IPR2014-01193 Patent 6,684,241 B1 12 server host, and the name of a file to be loaded into memory and executed,” as well as other configuration information. Id. at 121. RFC 1812 notes that some routers boot from the network using the TFTP protocol, and that “[t]here is no reason that BOOTP could not be used for locating the server that the boot image should be loaded from.” Id. at 125. To locate the current boot host, the router to be configured would send a “BOOTP Request” with its hardware address, and TFTP could then be used to retrieve the image in the BOOTP reply. Id. RFC 1812 suggests that the router should have the ability to store parameters learned through BOOTP. Id. 3. Discussion A patent claim is unpatentable, under 35 U.S.C. § 103(a), if the differences between the claimed subject matter 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) where in evidence, so-called secondary considerations. Graham v. John Deere Co., 383 U.S. 1, 17–18 (1966). Against this backdrop, we consider Petitioner’s argument that AutoInstall discloses each of the limitations of claims 1–39, and “to the extent any limitation is not disclosed by AutoInstall, the limitation is obvious in view of the AutoInstall-RFC 1812 combination.” Pet. 15. To demonstrate which teachings in AutoInstall satisfy the limitations of the claims, Petitioner provides a brief summary of the AutoInstall reference, and claim charts IPR2014-01193 Patent 6,684,241 B1 13 identifying quotations in the reference that correspond with claim elements. Pet. 17–57. a. Claim 1 Petitioner argues that AutoInstall discloses the claim limitation of “utilizing at least one datum of the configuration data to produce additional configuration data.” Pet. 21. In particular, Petitioner argues that “AutoInstall discloses that the hostname of the unconfigured router (corresponding to the “additional configuration data” of claim 1) can be determined using the IP address ascertained from the received packets.” Id. (citing Ex. 1004, 2–3). Petitioner also argues that AutoInstall discloses how data from the global configuration file (ascertained by parsing received packets) can be used to obtain a second file (newrouter-confg), which corresponds to the “additional configuration data’ portion” of the limitation. Id. (citing Ex. 1004, 2–3). In its Preliminary Response, Patent Owner advances a number of arguments challenging Petitioner’s contention that AutoInstall discloses the claim 1 limitation of “utilizing at least one datum of the configuration data to produce additional configuration data.” Prelim. Resp. 31–34. According to Patent Owner, the disclosure in AutoInstall regarding using the IP address to extract the hostname from another device on the network is not “utilizing . . . to produce;” it is merely a second instance of “actively retrieving” and “parsing.” Id. at 32. Specifically, the processes of requesting and receiving packets responsive to a TFTP request or reverse DNS lookup are “an additional iteration of retrieving and parsing packets to extract configuration data,” according to Patent Owner. Id. at 33. Patent Owner further argues that the description in AutoInstall of downloading a full configuration file IPR2014-01193 Patent 6,684,241 B1 14 likewise “discloses obtaining (e.g., through TFTP) configuration data by retrieving further packets that include the alleged additional configuration data, which is ascertained by again parsing the retrieved packets.” Id. at 34 (citing Ex. 1004, 2). In response to Petitioner’s argument that the newrouter-confg file in AutoInstall corresponds to the “additional configuration data” of claim 1 (Pet. 21 (citing Ex. 1004, 2–3)), Patent Owner contends that “AutoInstall’s disclosure of using either TFTP or Reverse DNS to retrieve a hostname does not teach a router using the IP address to itself produce additional data.” Prelim. Resp. 33 (emphasis added). We are not persuaded Petitioner’s arguments and evidence demonstrate sufficiently that the cited portions of AutoInstall disclose “utilizing at least one datum of the configuration data to produce additional configuration data,” as recited in claim 1. As noted above, we interpret the steps of “retrieving packets” and “parsing the retrieved packets to ascertain configuration data” as separate from the step of “utilizing at least one datum of the configuration data to produce additional configuration data.” For the reasons provided supra, we construe “utilizing at least one datum of the configuration data to produce additional configuration data” as requiring more than just retrieving data and parsing the retrieved data; additional configuration data must be created by the unconfigured first network device. Patent Owner argues persuasively that the claims and Specification “clearly distinguish active retrieval and parsing from ‘utilizing . . . to produce additional configuration data.’” Id. at 33. Indeed, the Specification describes how the packets “first are retrieved and then parsed to ascertain the configuration data” and that “at least one datum from the configuration data IPR2014-01193 Patent 6,684,241 B1 15 is processed to produce additional configuration data.” Ex. 1001, Abstract. Additional support for Patent Owner’s position can be found in the description of steps 300, 302, and 304 of the Specification described above, as well as the following passage from the Specification: Once the configuration data is parsed and/or generated from all sources (i.e. steps 300, 302 and 304 above), then the process continues to step 306 in which the configuration data is stored in the configuration database 22 on the given router 14. . . . The process then continues to step 308 in which the given router 14 is configured with the data in the database 22, thus ending the process. Ex. 1001, 6:13–22. Thus, Patent Owner argues persuasively that the newrouter-confg file is not “produced” because it is merely retrieved from a configured router in the network. Prelim Resp. 32–33. Patent Owner also argues persuasively that the description in AutoInstall of how the unconfigured router either “TFTP broadcasts for its full configuration file newrouter-confg” or “broadcasts a reverse domain name server (DNS) request over the network” (Ex. 1004, 2) retrieves, but does not “produce,” additional configuration data. Id. On this record, Petitioner does not demonstrate sufficiently that the description in AutoInstall concerning the unconfigured router learning its IP address or learning its name teaches “utilizing at least one datum of the configuration data to produce additional configuration data.” Having determined that AutoInstall does not disclose this limitation, we next consider Petitioner’s arguments regarding RFC 1812. Petitioner contends that RFC 1812 discloses that the unconfigured router can obtain its IP address and other configuration parameters using BOOTP (Pet. 19 (citing Ex. 1003, 120–121, 124–125)) and then uses the received parameters to IPR2014-01193 Patent 6,684,241 B1 16 configure itself. Id. at 20 (citing Ex. 1003, 124–125). Patent Owner counters that RFC 1812’s teaching to use data from received BOOTP packets to obtain a second configuration file does not teach “utilizing at least one datum of the configuration data to produce additional configuration data.” Prelim. Resp. 34. Instead, Patent Owner contends that RFC 1812, like AutoInstall, teaches only to retrieve and parse, but not to “produce,” additional configuration data. Id. at 34 (citing Ex. 1003, 120–21, 124–125). We are not persuaded, on this record, that Petitioner’s arguments and evidence demonstrate sufficiently that RFC 1812 teaches “utilizing at least one datum of the configuration data to produce additional configuration data.” Petitioner’s contention that “the unconfigured router uses its IP address, the name of the configuration file, and the address of the server hosting the configuration file (all in the BOOTP response packets) to obtain the configuration file” (Pet. 22 (citing Ex. 1003, 120–121, 124–125; Ex. 1005 ¶ 60)) fails to identify any configuration data that is “created” by the unconfigured first network device (i.e. router) as the result of processing the configuration data. After considering fully the parties’ arguments and evidence with regards to independent claim 1, we are not persuaded sufficiently by Petitioner’s arguments that the teachings of AutoInstall and RFC 1812 each disclose the limitation of “utilizing at least one datum of the configuration data to produce additional configuration data,” as recited by independent claim 1. Because we are not persuaded that AutoInstall and RFC 1812 disclose this limitation, we need not address arguments advanced by Petitioner concerning motivations to combine these references. Pet. 15–17. IPR2014-01193 Patent 6,684,241 B1 17 b. Dependent Claims 2–10 Petitioner provides separate arguments and claim charts for claims 2– 10 that depend from claim 1. Pet. 32–48. By virtue of their dependency, claims 2–10 incorporate the same limitations as their underlying base claim. For the same reasons discussed above, our determination concerning the insufficiency of Petitioner’s evidence with respect to the “utilizing at least one datum of the configuration data to produce additional configuration data” limitation of independent claim 1, applies equally to the claims that depend from claim 1. c. Independent Claims 11, 21, 30, 34, and 39 Petitioner further argues that independent claims 11, 21, 30, 34 and 39 are unpatentable under 35 U.S.C. § 103(a) as obvious based on AutoInstall and RFC 1812 “for reasons analogous to those discussed above with respect to Claim 1.” Pet. 48–49; 53–57. Having considered Petitioner’s arguments concerning the prior art references of AutoInstall and RFC 1812, we are not persuaded that Petitioner has demonstrated a reasonable likelihood that it would prevail in demonstrating the obviousness of challenged claims 11, 21, 30, 34 and 39 for the same reasons discussed above for claim 1. d. Dependent Claims 12–20; 22–29; 31–33; and 35–38 Petitioner provides separate arguments and claim charts for claims 12–20 that depend from claim 11; claims 22–29 that depend from claim 21; claims 31–33 that depend from claim 30; and claims 35–38 that depend from claim 34. Pet. 49–56. Again, by virtue of their dependency, each of these dependent claims incorporate the same limitations as their respective underlying base claim. For the same reasons discussed above, our determination concerning the insufficiency of Petitioner’s evidence with IPR2014-01193 Patent 6,684,241 B1 18 respect to the “utilizing at least one datum of the configuration data to produce additional configuration data” limitation of independent claim 1, also applies to the claims that depend from independent claims 11, 21, 30, and 34, respectively. e. Summary On this record, Petitioner has not demonstrated a reasonable likelihood that it would prevail with respect to its contention that claims 1– 39 of the ’241 patent are obvious over AutoInstall and RFC 1812. IV. CONCLUSION For the foregoing reasons, we conclude that Petitioner has not demonstrated a reasonable likelihood that at least one of challenged claims 1–39 of the ’241 patent is unpatentable based on the asserted grounds. V. ORDER In consideration of the foregoing, it is hereby: ORDERED that the Petition for inter partes review of the ’241 patent is DENIED. IPR2014-01193 Patent 6,684,241 B1 19 PETITIONER: Barton E. Showalter Chad C. Walters Douglas M. Kubehl BAKER BOTTS L.L.P. bart.showalter@bakerbotts.com chad.walters@bakerbotts.com doug.kubehl@bakerbotts.com PATENT OWNER: Andrea G. Reister Gregory S. Discher Jay I. Alexander COVINGTON & BURLING LLP areister@cov.com gdischer@cov.com jalexander@cov.com Copy with citationCopy as parenthetical citation