Ex Parte 7838221 et al

Patent Trial and Appeal Board

Feb 25, 2016

95002216 (P.T.A.B. Feb. 25, 2016)

UNITED STATES PATENT AND TRADEMARK OFFICE
UNITED STATES DEPARTMENT OF COMMERCE
United States Patent and Trademark Office
Address: COMMISSIONER FOR PATENTS
P.O. Box 1450
Alexandria, Virginia 22313-1450
www.uspto.gov
APPLICATION NO. FILING DATE FIRST NAMED INVENTOR ATTORNEY DOCKET NO. CONFIRMATION NO.
95/002,216 09/13/2012 7838221 GENOM.057X1(P-7322RE) 1078
95896 7590 02/25/2016
David W. Highet, VP and Chief IP Counsel
Becton, Dickinson and Company
(Knobbe Martens)
1 Becton Drive, MC-110
Franklin Lakes, NJ 07417
EXAMINER
TURNER, SHARON L
ART UNIT PAPER NUMBER
3991
MAIL DATE DELIVERY MODE
02/25/2016 PAPER
Please find below and/or attached an Office communication concerning this application or proceeding.
The time period for reply, if any, is set in the attached communication.
PTOL-90A (Rev. 04/07)

UNITED STATES PATENT AND TRADEMARK OFFICE
____________

BEFORE THE PATENT TRIAL AND APPEAL BOARD
____________

BECKMAN COULTER, INC.
Requester and Appellant

v.

GENEOHM SCIENCES CANADA, INC.
Patent Owner and Respondent
____________

Appeal 2015-006967
Reexamination Control 95/002,216
Patent 7,838,221 B2
Technology Center 3900
____________

Before RICHARD M. LEBOVITZ, JEFFREY N. FREDMAN, and
JEFFREY B. ROBERTSON, Administrative Patent Judges.

LEBOVITZ, Administrative Patent Judge.

DECISION ON APPEAL
This is a decision on the appeal by the Requester from the Patent Examiner’s
final decision to not adopt rejections of claims 1–14 in the above-identified inter
partes reexamination of US 7,449,289 B2. The Board’s jurisdiction for this appeal
is under 35 U.S.C. §§ 6(b), 134, and 315.
We affirm the Examiner’s decision.
Appeal 2015-006967
Reexamination Control 95/002,216
Patent 7,838,221 B2

2

I. BACKGROUND
The patent in dispute in this appeal is US 7,838,221 B2 (“the ’221 patent”)
which issued November 23, 2010.
A request for inter partes reexamination of the ’221 patent under 35 U.S.C.
§§ 311-318 and 37 C.F.R. §§ 1.902-1.997 was filed September 13, 2012. The
Requester is Beckman Coulter, Inc. (“Requester”). Appeal Br. 3. The real party in
interest for the ’221 patent is GeneOhm Sciences Canada, Inc. (“Patent Owner”).
Patent Owner Respondent Brief (“Resp’t Br.”) 3.
The claimed subject matter of the ’221 patent relates to a method to detect
the presence of a methicillin-resistant type xiii Staphylococcus aureus (MRSA)
strain in a specimen. S. aureus is a human opportunistic pathogen which is major
cause of morbidity and mortality. ’221 patent, col. 1, ll. 23–25. “Some of the most
common infections caused by S. aureus involve the skin.” Id. at col. 1, ll. 25–26.
“Some of the more serious infections produced by S. aureus are bacteremia,
pneumonia, osteomyelitis, acute endocarditis, myocarditis, pericarditis, cerebritis,
meningitis, scalded skin syndrome, and various abscesses.” Id. at col. 1, ll. 28–31.
“Methicillin-resistant S. aureus (MRSA) emerged in the 1980s as a major
clinical and epidemiologic problem in hospitals.” ’221 patent, col. 1, ll. 36–38.
MRSA are resistant to all β-lactams, including penicillins and cephalosporins,
which are some of the most commonly used antibiotics to treat S. aureus
infections. Id. at col. 1, ll. 39–41.
Methicillin-resistance is conferred by the acquisition of the mecA gene.
’221 patent, col. 1, ll. 51–64. It was discovered previously that the mecA gene is
carried by a genetic element, designated as the staphylococcal cassette
chromosome mec (SCCmec), which is inserted into the chromosomal DNA. Id. at
Appeal 2015-006967
Reexamination Control 95/002,216
Patent 7,838,221 B2

3

col. 1, l. 5 to col. 2, l. 3. The patent teaches that there are various “types” of
MRSA strains which differ in the sequence of the region where the SCCmec
integrates into the chromosomal DNA. Id. at col. 3, ll. 10–13. The ’221 patent
describes published methods of characterizing different MRSA strains by using
primers that “hybridize to the right extremities of the 3 types of SCCmec DNAs in
combination with a primer specific to the S. aureus chromosome, which
corresponds to the nucleotide sequence on the right side of the SCCmec integration
site.” Id. at col. 2, ll. 63–66. These methods are called “MREP typing” (mec right
extremity polymorphism) because of the presence of polymorphisms around the
integration site. Id. at col. 3, ll. 6 –7.
The ’221 patent claims are specifically directed to the detection of a type xiii
MRSA strain. Type xiii MRSA differs in sequence from previously known MRSA
types. The ’221 patent teaches that the nucleotide sequences from the right
extremity of SSCmec obtained from type xiii bacterial strains were different from
previously known MRSA types by lacking a 102 bp insertion found in several
other types, and that this difference could be identified by amplicon size. Id. at col.
20, ll. 59–64; col. 21, ll. 5–8; Fig. 2; Appeal Br. 14.

II. RELATED APPEALS
This appeal is related to Reexamination Control No. 95/001,599 of U.S.
Patent No. 7,449,289. A decision by the Patent Trial and Appeal Board was issued
August 28, 2014. An Inter Partes Reexamination Certificate issued on Dec. 7,
2015 confirming the patentability of claims 3 and 4, and canceling claims 1, 2, and
5.
Appeal 2015-006967
Reexamination Control 95/002,216
Patent 7,838,221 B2

4

III. REJECTIONS
In view of claim amendments made by Patent Owner, the Examiner
withdrew the following rejections:
1. Claims 1–14 under 35 U.S.C. § 102(b) (pre-AIA) as anticipated by WO
02/099034 (Huletsky et al., published December 12, 2001) (“the ’034 WO
Application”);
2. Claim 1–2, 5, 6, 9 and 11–14 under 35 U.S.C. § 102(b) (pre-AIA) as
anticipated by EP 1529847 (Cuny et al., published November 5, 2015) (“the ’847
EP application”);
3. Claims 1–14 under 35 U.S.C. § 103(a) (pre-AIA) as obvious in view of
Ito et al. (2001), Antimicrobial Agents and Chemotherapy, 45: 1323-1336 (“Ito”)
and the ’034 WO Application.
Requester appeals from the Examiner’s withdrawal of the rejections. Appeal
Br. 4.
4. Requester also contends that the claim amendments made by Patent
Owner on March 19, 2014 do not meet the requirements of 35 U.S.C. § 112. Id. at
10–12. Although Requester specifically mentions § 112, second paragraph (pre-
AIA), the arguments also implicate § 112, first paragraph for lack of written
description (pre-AIA). Id. We therefore have addressed both statutory
requirements.
IV. CLAIM
Claim 1 is the only independent claim on appeal. Claims 2–14 depend from
claim 14. Claim 1 reads as follows [brackets indicate deleted material and
underling indicates added material relative to the original claims]:
Appeal 2015-006967
Reexamination Control 95/002,216
Patent 7,838,221 B2

5

1. A method to detect the presence of an MREJ type xiii methicillin
resistant Staphylococcus aureus (MRSA) strain comprising:
contacting a first primer and a second primer with a sample to
be analyzed for the presence of said MREJ type xiii MRSA strain,
said MREJ type xiii MRSA strain including a Staphylococcal cassette
chromosome mec (SCCmec) element containing a mecA gene inserted
into chromosomal DNA, thereby generating a polymorphic right
extremity junction (MREJ) type xiii sequence that comprises
sequences from both the SCCmec element right extremity and
chromosomal DNA adjoining said right extremity, wherein said first
and second primers are at least 10 nucleotides in length, and wherein
said first primer is specific for and hybridizes with said SCCmec
element right extremity of an MREJ type xiii sequence selected from
the group consisting of SEQ ID NOs: 15, 25 and 26 and complements
thereof, and wherein said second primer hybridizes with a
chromosomal sequence of S. aureus, wherein said first primer and
said second primer together generate a first amplicon of MREJ type
xiii specific sequences that spans the mec right extremity junction of
MREJ type xiii sequences under amplification conditions only if said
MREJ type xiii MRSA strain is present in the sample; and wherein
said contacting of said first primer and said second primer takes place
under annealing conditions; and
[[wherein generating and ]]detecting the presence of said first
amplicon of MREJ type xiii specific sequences as indicative of the
presence of said MREJ type xiii MRSA strain in the sample.

V. ENTRY OF CLAIM AMENDMENTS
Requester contends the claim amendments made March 19, 2014 by Patent
Owner are improper and should not have been entered. Appeal Br. 8.
The proprietary of the Examiner’s action in entering a claim amendment is
not appealable to the Patent Trial and Appeal Board (“PTAB”). Under 35 U.S.C.
134, only rejections of a claim are appealable to the PTAB. Consequently, we
shall not consider this issue.
Appeal 2015-006967
Reexamination Control 95/002,216
Patent 7,838,221 B2

6

VI. ANTICIPATION REJECTIONS
Claim 1 requires “contacting a first primer and a second primer with a
sample to be analyzed for the presence of said MREJ type xiii MRSA strain.”
The first primer “is specific for and hybridizes with said SCCmec element
right extremity of an MREJ type xiii sequence selected from the group consisting
of SEQ ID NOs: 15, 25 and 26 and complements thereof.”
The second primer “hybridizes with a chromosomal sequence of S. aureus.”
The claim further requires that “said first primer and said second primer
together generate a first amplicon of MREJ type xiii specific sequences that spans
the mec right extremity junction of MREJ type xiii sequences under amplification
conditions only if said MREJ type xiii MRSA strain is present in the sample.”
(Underlining indicates amendment to original claim.)
Requester contends that each of the ’034 WO Application and the ’847 EP
Application describe the first and second primers recited in the claim. Appeal Br.
12–13; 22–23. While Requester does not identify MREJ type xiii specific
sequences in the’034 WO and the ’847 EP Applications, Requester contends that
the claim does not require detection of type xiii sequences. Id. at 14. Rather,
Requester contends that the claim covers detecting the presence or absence of
MREJ type xiii sequences. Id. at 7. When the type xiii sequences are absent from
the sample, Requester argues that the claim is anticipated by the ’034 WO
Application and the ’847 EP Application which utilize the same primers as
claimed, albeit to detect other MRSA types.
The Examiner construed the claim to require generating a first amplicon of
MREJ type xiii specific sequences and detecting the presence of the type xiii
specific amplicon as indicative of the strains presence in the sample. RAN 6–7.
Appeal 2015-006967
Reexamination Control 95/002,216
Patent 7,838,221 B2

7

Since neither of the ’034 WO Application and the ’847 EP Application detected
type xiii sequences, the Examiner did not adopt the rejections.
The principal issue in both anticipation rejections is the proper interpretation
of claim 1. We thus must begin with claim interpretation.

Claim interpretation
Claim 1 is drawn to a “method to detect the presence of an MREJ type xiii
methicillin resistant Staphylococcus aureus (MRSA).” The method comprises a
“contacting” step and “detecting” step. The “detecting” step was added by
amendment on March 19, 2014 in which Patent Owner deleted “wherein
generating” from the claim and amended the claim to explicitly require “detecting
the presence of said first amplicon of MREJ type xiii specific sequences.” Despite
the recitation of an explicit step in which of MREJ type xiii sequences are detected,
Requester contends that the claim reads on carrying out the “contacting” step but
not “detecting” the type xiii sequences because the claim also recites (emphasis
added:
wherein said first primer and said second primer together generate a first
amplicon of MREJ type xiii specific sequences that spans the mec right
extremity junction of MREJ type xiii sequences under amplification
conditions only if said MREJ type xiii MRSA strain is present in the sample.
Requester argues that the “plain meaning” of the claim in view of the “only
if” clause “is that the claims encompass assays in which the amplicon is produced
only under certain circumstances, i.e., when the MREJ type xiii strain is present in
the sample.” Rebuttal Br. 4. Requester also contends that the “detecting” step
“encompasses a physical detection step suitable for detecting the presence of any
Appeal 2015-006967
Reexamination Control 95/002,216
Patent 7,838,221 B2

8

MREJ amplicon, regardless of the particular MREJ type that is actually detected.”
Appeal Br. 8.
The question is whether the “wherein” clause stating that an amplicon is
generated “only if” the “MREJ type xiii MRSA strain is present in the sample” has
the effect of enlarging the scope of the claim to embodiments in which the strain is
absent from the sample. In our opinion, this is not the broadest reasonable
interpretation of the claim. (During reexamination of an unexpired patent, claims
are given their broadest reasonable interpretation consistent with the patent
specification. In re Suitco Surface, Inc., 603 F.3d 1255, 1259 (Fed. Cir. 2010); In
re Abbott Diabetes Care Inc., 696 F.3d 1142, 1148 (Fed. Cir. 2012).)
To begin with, the claim preamble recites a “method to detect the presence
of an MREJ type xiii methicillin resistant Staphylococcus aureus (MRSA) strain.”
The claim preamble thus positively recites to “detect the presence of” the type xiii
strain, not the presence or absence of it. Presence or absence is an embodiment
contemplated by the ’221 patent. (See ’221 patent, col. 8, ll. 13–15: “Also
disclosed herein are methods providing for the detection of the presence or absence
of an MRSA strain in a sample that includes nucleic acids.”) However, presence
or absence is not recited in the claim preamble. The “terms appearing in a
preamble may be deemed limitations of a claim when they ‘give meaning to the
claim and properly define the invention.’” In re Paulsen, 30 F.3d 1475, 1479 (Fed.
Cir. 1994). “Language in a preamble limits a claim where it breathes life and
meaning into the claim . . . but not where it merely recites a purpose or intended
use of the invention.” (Internal citations omitted.) Innova/Pure Water, Inc. v.
Safari Water Filtration Sys., Inc., 381 F.3d 1111, 1118 (Fed. Cir. 2004).
Appeal 2015-006967
Reexamination Control 95/002,216
Patent 7,838,221 B2

9

The claim also positively recites a step in which the type xiii MRSA strain is
detected: “detecting the presence of said first amplicon of MREJ type xiii specific
sequences as indicative of the presence of said MREJ type xiii MRSA strain in the
sample.” When this step is read in the context of the claim preamble, it would be
understood by one of skill in the art that the step requires the presence of an MREJ
type xiii amplicon to be physically detected. If the physical step of detecting the
amplicon of MREJ type xiii specific sequences is not accomplished, the claim is
not performed.
The “wherein” clause is not inconsistent with this interpretation. The
“wherein” clause states that an “amplicon of MREJ type xiii specific sequences” is
“generate[d] . . . only if” the type xiii MRSA strain “is present in the sample.”
This language is a statement that, when (“only if”) the type xiii strain is present in
the sample, an amplicon “specific” for it is generated. In other words, it is an
assertion that a “specific” amplicon for type xiii strains is generated by the first and
second primers. Because both the claim preamble and the detecting step require
detecting the presence of the type xiii MRSA strain, it would be unreasonable to
read the “wherein clause” as broadening the claim to cover identifying the absence
of the type xiii strain when no MREJ type xiii specific amplicon sequences is
generated.
In reaching this determination, we do not find the “wherein” clause to be
non-limiting, but rather construe it to be statement of the properties of the two
primers when they contact a MREJ type xiii MRSA strain under annealing
condition as required by the claim. See Griffin v. Bertina, 285 F.3d 1029, 1033–34
(Fed. Cir. 2002) stating that whether a “wherein” clause is limiting is “fact-
specific” and depends on the context in which it is recited in the claim.
Appeal 2015-006967
Reexamination Control 95/002,216
Patent 7,838,221 B2

10

Requester’s contention that the claim covers conducting the “contacting”
step in the absence of detecting a type xiii MRSA specific amplicon and without
detecting it ignore the claim preamble, the positive recitation of a “detecting” step,
and construes the “wherein” clause broader than reasonably justified by the full
context of the claim.
Anticipation
The anticipation rejections are based on Requester’s contention that each of
the ’034 WO Application and the ’847 EP Application describe the same typing
MRSA assay and primers as claimed. Appeal Br. 12–24. Requester does not
assert, nor provide evidence, that the cited published patent applications describe a
type xiii MRSA strain. Instead, Requester asserts that the claims do not require the
presence of a type xiii strain. Id. at 14, 24. As explained above, Requester’s
interpretation of the claim is not reasonable. The claims require detecting the
presence of a type xiii MRSA strain.
Requester also argues:
Since the primers described in the ’034 application hybridize to MREJ
type xiii, the methods described there would necessarily result in the
generation of an MREJ type xiii specific amplicon, if the MREJ type
xiii strain were present in the sample.
Id. at 15.
However, no evidence has been presented that the ’034 WO Application, nor
the ’847 EP Application, describe a sample with a type xiii MRSA strain.

VII. OBVIOUSNESS REJECTION
Requester contends that the Examiner erred in failing to reject claim 1–14
under 35 U.S.C. § 103 as obvious in view of Ito and the ’034 WO Application.
Appeal 2015-006967
Reexamination Control 95/002,216
Patent 7,838,221 B2

11

Requester states that Ito describes PCR-based, MREP typing on different MRSA
strains. Appeal Br. 24. Requester further states that “the ‘034 application follows
on Ito et al. and provides sequence information for the MREJ region of an
additional seven MRSA strains (MREJ types iv to x) that were available from
public depositories.” Id. at 25. Requester contends that the type xiii strains
“identified as ‘new’ in the ’221 patent were previously known clinical isolates and
references strains that had been deposited in publicly available depositories.” Id.
Requester argues that it would have been obvious to one of ordinary skill in the art
to have obtained these strains and design primers to them based on the new
sequence information obtained from them. Id. at 26–27.
The Examiner did not adopt the rejection. The Examiner explained:
The prior art fails to demonstrate the existence of such [type xiii]
strains, such sequence differences, their location and size, or the
ability to identify such differences as type xiii, based upon any prior
art procedure. There was no foreknowledge that such type xiii strains
existed, nor could the artisan be assured that the standard procedures
would have found them.
RAN 16.
Requester has not provided persuasive evidence to establish the obviousness
of the claimed subject matter. The ‘221 patent lists strains CCR1-11976, -12382,
and -12383 as the sources of the type xiii sequences. ’221 patent, Table 3 and 8.
However, Requester has not provided persuasive evidence that CCRI strains -
11976, -12382, and -12383 were publically available and characterized as MRSA
strains. Absent such information, the skilled worker would not have had the
starting materials readily available, and/or known they were MRSA strains, which
could have provided the basis to select them and characterize by the methods
Appeal 2015-006967
Reexamination Control 95/002,216
Patent 7,838,221 B2

12

described in Ito and the ’034 WO Application. Consequently, we affirm the
Examiner’s decision not to adopt the rejection.

SECTION 112
Requester contends that claim amendments do not comply with 35 U.S.C. ¶
112. Requester contends that the ’221 patent “fails to disclose a single detection
method or primer that is specific to the detection of only an MREJ type xiii-
specific amplicon.” Appeal Br. 10. Requester also contends the term “MREJ type
xiii specific sequences” lacks support in the Specification and is ambiguous
because “it is not clear whether the amendments to claim 1 require generation of an
amplicon comprising sequences that are truly unique to MREJ type xiii, or whether
such sequences may also be present in other MREJ types.” Id. at 11.
To satisfy the written description requirement under 35 U.S.C § 112, the
inventor “must . . . convey with reasonable clarity to those skilled in the art that, as
of the filing date sought, he or she was in possession of the invention.” Vas-Cath,
Inc. v. Mahurkar, 935 F.2d 1555, 1563-64 (Fed. Cir. 1991).
Requester’s arguments are not supported by persuasive evidence. The
claims do not require the first and second primer to be specific for a type xiii
sequence. Rather, the claims recite “first primer . . . specific for and hybridizes
with said SCCmec element right extremity of an MREJ type xiii sequence selected
from the group consisting of SEQ ID NOs: 15, 25 and 26 and complements
thereof” and a second primer to a chromosomal sequence of S. aureus. The primer
does not have to be “specific” for the type xiii sequence; rather, it must be specific
for the SSCmec element of the type xiii sequence. This does not impose the
requirement that the primers be specific for the type xiii sequence, itself.
Appeal 2015-006967
Reexamination Control 95/002,216
Patent 7,838,221 B2

13

The ’221 patent describes the use of the claims first and second primers to
obtain an MREJ type sequence. ’221 patent, col. 17, ll. 10-20; col. 20, ll. 59–65;
col. 4, ll. 41–44. The ’221 patent characterizes the PCR product from three
bacterial strains as “new,” “novel” and indicative of MREJ type xiii. Id. at Table 8
(SEQ ID NOS. 15, 25, and 26); col. 7, l. 29; col. 20, ll. 59–64. While the phrase
“MREJ type xiii specific sequences” is not recited in the ’221 patent, based on the
mentioned disclosure in the patent and the disclosure of “specific amplification
products (id. at col. 14, l. 8), the ordinary skilled would have understood that the
new and novel sequences 15, 25, and 26 are “specific” for the type xiii strain. In
describing the claimed invention, there is no requirement that the wording be
identical to that used in the specification as long as there is sufficient disclosure to
show one of skill in the art that the inventor “invented what is claimed.” Union Oil
Co. v. Atlantic Richfield Co., 208 F.3d 989, 997 (Fed. Cir. 2000). Thus, as long as
a person “of ordinary skill in the art would have understood the inventor to have
been in possession of the claimed invention at the time of filing, even if every
nuance of the claims is not explicitly described in the specification, then the
adequate written description requirement is met.” In re Alton, 76 F.3d 1168, 1175
(Fed. Cir. 1996).
In regard to Requester’s statement that it is not clear whether the claimed
amplicon comprises sequence “truly unique to MREJ type xiii” or “whether such
sequences may also be present in other MREJ types,” the ’221 patent expressly
refers to using primers and probes “specific” for different MREJ types so that the
type of the MREJ can be determined (at col. 11, ll. 4–7) and describes “MRSA-
specific multiplex PCR” assays (at col. 15, ll. 63–64), specific detection of MRSA
strains (Example 1), and detection of novel sequences present in type xiii strains,
Appeal 2015-006967
Reexamination Control 95/002,216
Patent 7,838,221 B2

14

but no other strains (at col. 20, ll. 59–64). As pointed out by the Examiner, “Type
xiii strains and amplicons are characterized by SEQ ID NO's 15, 25 and 26 and
differ by the absence of one or two 102 base pair insertions, see particularly ‘221
20:59-64, 21:4-9, Figure 2 and SEQ ID NO's 15, 25 and 26.” RAN 7.
Accordingly, it would be understood that recited specific amplicons are unique to
the MREJ type xiii.

TIME PERIOD FOR RESPONSE
In accordance with 37 C.F.R. § 41.79(a)(1), the “[p]arties to the appeal may
file a request for rehearing of the decision within one month of the date of: . . .
[t]he original decision of the Board under § 41.77(a).” A request for rehearing
must be in compliance with 37 C.F.R. § 41.79(b). Comments in opposition to the
request and additional requests for rehearing must be in accordance with 37 C.F.R.
§ 41.79(c)-(d), respectively. Under 37 C.F.R. § 41.79(e), the times for requesting
rehearing under paragraph (a) of this section, for requesting further rehearing under
paragraph (d) of this section, and for submitting comments under paragraph (c) of
this section may not be extended.
An appeal to the United States Court of Appeals for the Federal Circuit
under 35 U.S.C. §§ 141-144 and 315 and 37 C.F.R. § 1.983 for an inter partes
reexamination proceeding “commenced” on or after November 2, 2002 may not be
taken “until all parties’ rights to request rehearing have been exhausted, at which
time the decision of the Board is final and appealable by any party to the appeal to
the Board.” 37 C.F.R. § 41.81. See also MPEP § 2682 (8th ed., Rev. 7, July
2008).
Appeal 2015-006967
Reexamination Control 95/002,216
Patent 7,838,221 B2

15

In the event neither party files a request for rehearing within the time
provided in 37 C.F.R. § 41.79, and this decision becomes final and appealable
under 37 C.F.R. § 41.81, a party seeking judicial review must timely serve notice
on the Director of the United States Patent and Trademark Office. See 37 C.F.R.
§§ 90.1 and 1.983.

AFFIRMED

Patent Owner:

Brenden Gingrich
KNOBBE, MARTENS, OLSON & BEAR LLP
12790 El Camino Real
San Diego, CA 92130

Third Party Requester:

Kevin Bastian
KILPATRICK TOWNSEND & STOCKTON LLP
Two Embarcadero Center
8th Floor
San Francisco, CA 94111-3834