LiTL LLC

Patent Trials and Appeals Board

Sep 3, 2021

IPR2021-00681 (P.T.A.B. Sep. 3, 2021)

Trials@uspto.gov Paper 8
Tel: 571-272-7822 Date: September 3, 2021

UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE PATENT TRIAL AND APPEAL BOARD

LENOVO (UNITED STATES) INC.,
Petitioner,

v.

LITL LLC,
Patent Owner.

IPR2021-00681
Patent 8,289,688 B2

Before KRISTINA M. KALAN, CHRISTOPHER M. KAISER,
and BRIAN D. RANGE, Administrative Patent Judges.

KAISER, Administrative Patent Judge.

DECISION
Denying Institution of Inter Partes Review
35 U.S.C. § 314

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INTRODUCTION
A. Background
Lenovo (United States) Inc. (“Petitioner”) filed a Petition (Paper 1,
“Pet.”) requesting an inter partes review of claims 1–9 and 11–32 of U.S.
Patent No. 8,289,688 B2 (Ex. 1001, “the ’688 patent”). LiTL LLC, Inc.
(“Patent Owner”) filed a Preliminary Response. Paper 7 (“Prelim. Resp.”).
We have authority to determine whether to institute an inter partes
review. 35 U.S.C. § 314(b); 37 C.F.R. § 42.4(a) (2020). The standard for
instituting an inter partes review is set forth in 35 U.S.C. § 314(a), 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.”
After considering the Petition, the Preliminary Response, and the
evidence of record, we determine that Petitioner has not demonstrated a
reasonable likelihood that it would prevail with respect to at least one
challenged claim. Accordingly, we do not institute an inter partes review of
any challenged claim on any asserted ground.
B. Related Matters
The parties identify LiTL LLC v. Lenovo (United States), Inc., Case
No. 1:20-cv-00689 (D. Del.), as a matter related to the present proceeding.
Pet. 1; Paper 6, 1. Patent Owner also notes that there are several related
inter partes review proceedings: IPR2021-00786, IPR2021-00800,
IPR2021-00821, and IPR2021-00822. Paper 6, 1.
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C. The Asserted Grounds of Unpatentability
Petitioner contends that claims 1–9 and 11–321 of the ’688 patent are
unpatentable based on the following grounds (Pet. 37–113):2
Claim(s) Challenged 35 U.S.C. §3 References/Basis
1–7, 19, 29–32 103 Shimura,4 Hisano5
12, 13, 24, 26 103 Shimura, Tsuji6
8, 9, 14–16, 20, 23,
25
103 Shimura, Hisano, Tsuji
17, 18, 21, 22, 27, 28 103 Shimura, Hisano, Shigeo7
11 103 Shimura, Hisano, Shigeo, Choi8
D. The ’688 Patent
The ’688 patent, titled “Portable Computer with Multiple Display
Configurations,” issued on October 16, 2012. Ex. 1001, codes (45), (54).
The patent relates to a “portable computer that is configurable between a
plurality of display modes.” Id. at code (57). According to the ’688 patent,

1 Patent Owner has disclaimed claim 29. Ex. 2009, 1.
2 Petitioner also relies on a declaration from Jean Renard Ward. Ex. 1010.
3 The earliest priority date claimed by the ’688 patent is April 1, 2008.
Ex. 1001, codes (22), (60). Thus, the application leading to the ’688 patent
has an effective filing date before March 16, 2013, so patentability is
governed by the versions of 35 U.S.C. §§ 102 and 103 that were in force
before they were amended by the Leahy-Smith America Invents Act
(“AIA”), Pub. L. No. 112–29, 125 Stat. 284 (2011).
4 JP 1994-242853 A, published September 2, 1994 (Ex. 1003) (certified
English translation provided as Ex. 1004).
5 US 2006/0034042 A1, published Feb. 16, 2006 (Ex. 1005).
6 US 2005/0062715 A1, published Mar. 24, 2005 (Ex. 1006).
7 JP 1996-179851 A, published July 12, 1996 (Ex. 1007) (certified English
translation provided as Ex. 1008).
8 US 6,918,159 B2, issued July 19, 2005 (Ex. 1009).
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“[c]onventional portable computers most commonly have a ‘clam-shell’
configuration, with a base including the keyboard, various ports, connectors
and/or inputs . . . and a display component pivotably coupled to the base by
a hinge.” Id. at 1:21–27. Conventional computers sometimes “operat[e] in
‘tablet mode,’” and the ’688 patent also describes existing computers that
were “capable of operating either as a normal laptop computer receiving user
input via a keyboard (‘laptop mode’), or as a tablet computer receiving user
input via a touch screen.” Id. at 1:32–41. In this latter case, “the display
component of the computer is attached to the base of the computer by hinges
that allow the display to be tilted relative to the base (for laptop mode), and
to be rotated and folded against the base to configure the computer into
tablet mode.” Id. at 1:41–46.
The ’688 patent builds on these configurations, describing “a portable
computer” that “is configurable between various modes, including a closed
mode, a laptop mode, an easel mode, a flat mode, and a frame mode.” Id.
at 2:19–22. Each of these modes is depicted in a figure of the ’688 patent.
Id. at 4:40–5:39. Figure 1, reproduced below, shows the laptop mode.

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Figure 1 depicts the portable computer of the ’688 patent in laptop mode.
Id. at 6:24–27. Display component 102 is “inclined at a viewing angle from
the base 104.” Id. at 6:27–28.
Figure 2, reproduced below, shows the closed mode.

Figure 2 depicts the portable computer of the ’688 patent in closed mode.
Id. at 6:63–64. The angle between display component 102 and base 104 is
zero, and “the display screen is disposed ‘face down’ against the keyboard of
the base 104.” Id. at 6:65–7:1.
Figure 4, reproduced below, shows the easel mode.

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Figure 4 depicts the portable computer of the ’688 patent in the easel mode.
Id. at 7:48–49. “[B]ase 104 and the display component 102 form an inverted
‘V’ shape with the bottom of the base and the back of the display component
fac[ing one] another.” Id. at 7:49–57.
Figure 26, reproduced below, shows the frame mode.

Figure 26 depicts the portable computer of the ’688 patent in the frame
mode. Id. at 16:1–3. In this mode, display component 102 and base 104 are
separated by a similar angle 134 as in the easel mode, but “the portable
computer is placed on a surface 212 with the keyboard 106 ‘face down’ . . .
and the display 110 facing upward,” rather than being placed in the “inverted
‘V’” of the easel mode. Id. at 16:3–13.
Figure 27, reproduced below, shows the flat mode.

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Figure 27 depicts the portable computer of the ’688 patent in the flat mode.
Id. at 16:18–20. Display component 102 and base 104 are “rotated (or
opened) to approximately 180 degrees with respect to” one another, “such
that the base component and display component lay flat on a surface, with
the keyboard 106 and display screen 110 exposed.” Id. at 16:20–24.
In some of these display modes, the ’688 patent describes rotating the
information displayed on display screen 110 “such that the information
appears ‘right-way-up,’ even though the display screen is upside-down
compared to when the portable computer is in the laptop mode.” Id. at 8:7–
12. The portable computer may “include[] an orientation (or mode) sensor
that is configured to detect whether the portable computer is in the laptop
mode or the easel mode, and to adjust the display accordingly.” Id. at 8:17–
20. In addition, in some modes, the portable computer of the ’688 patent
may be configured to permit a user to rotate the information displayed
manually by 90 or 180 degrees. Id. at 16:27–50.
E. Illustrative Claim
Claims 1–9 and 11–32 of the ’688 patent are challenged. Claims 1,
11, 12, 17, 19, and 29 are independent, and claim 1 is illustrative; it recites:
1. A portable computer configurable between a plurality
of display modes including a closed mode, a laptop
mode and an easel mode, the portable computer
comprising:
a single display component including a display
screen;
a base including a keyboard;
a hinge assembly at least partially housed within
the base and the display component configured to
pivotably couple the display component to the
base, wherein the hinge assembly defines a single
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longitudinal axis running along an interface
between the display component and the base, and
wherein the display component and the base are
rotatable about the single longitudinal axis;
wherein, in the closed mode, the display screen is
disposed substantially against the base;
wherein rotating either the single display
component or the base by an operator about the
single longitudinal axis up to approximately 180
degrees from the closed mode configures the
portable computer into the laptop mode, wherein in
the laptop mode the single display component is
oriented towards the operator and the keyboard is
oriented to receive input from the operator;
wherein rotating either the single display
component or the base by the operator about the
single longitudinal axis beyond approximately 180
degrees from the closed mode configures the
portable computer into the easel mode; and
wherein in the easel mode the single display
component is oriented facing the operator with the
keyboard oriented away from the operator.
Ex. 1001, 17:10–38.
ANALYSIS
A. Procedural Defects
A petition for inter partes review must “identif[y], in writing and with
particularity, each claim challenged, the grounds on which the challenge to
each claim is based, and the evidence that supports the grounds for the
challenge to each claim.” 35 U.S.C. § 312(a)(3). According to 37 C.F.R.
§ 42.104(b)(4), a petition for inter partes review “must identify how the
construed claim is unpatentable under the statutory grounds on which the
petitioner challenges the claims, and must specify where each element of the
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claim is found in the prior art patents or printed publications relied upon.”
Rule 42.104(b)(5) adds that the Petition must “identify[] specific portions of
the evidence that support the challenge.” Similarly, Rule 42.22(a)(2) states
that each petition must include “[a] full statement of the reasons for the relief
requested, including a detailed explanation of the significance of the
evidence including material facts, and the governing law, rules, and
precedent.” The Patent Trial Practice Guide suggests that “parties should
avoid submitting a repository of all the information that a judge could
possibly consider, and instead focus on concise, well-organized, easy-to-
follow arguments supported by readily identifiable evidence of record.”
Patent Trial and Appeal Board Consolidated Trial Practice Guide, available
at https://www.uspto.gov/TrialPracticeGuideConsolidated (Nov. 14, 2019),
at 39. Patent Owner argues that the Petition fails to comply with each of
these requirements with respect to each of the asserted grounds. Prelim.
Resp. 8–15. For the reasons discussed below, we agree with Patent Owner’s
argument.
1. The Structure of the Petition Creates a Lack of Clarity
The Petition’s lack of clarity begins with the labyrinthine way
Petitioner chooses to present its unpatentability arguments. A brief
description of the structure of the Petition will illustrate this problem. The
Petition’s unpatentability analysis begins with a synopsis of each reference,
describing what Petitioner contends the references relied upon in the Petition
generally disclose. Pet. 17–37 (§§ VII.A.1–VII.A.5). These sections
paraphrase the disclosure of the references, and they include figures that add
annotations to the figures of the references, as well as some citations to the
Ward Declaration. Id.
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Next, each of the Petition’s five asserted grounds begins with a
section describing a hypothetical computer that a person of ordinary skill in
the art allegedly would have arrived at by combining the teachings of the
references asserted in that particular ground. Id. at 37–49, 66–69, 76–87,
92–95, 100–105 (§§ VII.B.1, VII.C.1, VII.D.1, VII.E.1, VII.F.1); see also
Ex. 1013 (describing the hypothetical computers of each asserted ground).9
These sections rely heavily on the Ward Declaration, cite to multiple
portions of the references in question, and contain further characterizations
of the disclosure of the references, including figures with added annotations.
Pet. 37–49, 66–69, 76–87, 92–95, 100–105. They also refer back to earlier
sections of the Petition. Id.
Finally, each asserted ground in the Petition presents a list of the
limitations of the challenged claims with some discussion of how the prior
art in question teaches or suggests those limitations. Id. at 49–66, 69–76,
87–91, 95–100, 105–113 (§§ VII.B.2–VII.B.13, VII.C.2–VII.C.5, VII.D.2–
VII.D.9, VII.E.2–VII.E.7, VII.F.2). For support, these sections refer
extensively back to, and rely extensively upon, the previously discussed
sections of the Petition. Id. Patent Owner demonstrates this nested form of
argument in graphical form for one portion of the Petition in the figure
reproduced below.

9 To the extent Petitioner intends to rely on the content of Exhibit 1013 for a
clear description of the hypothetical computers it uses in its arguments, that
constitutes incorporation by reference in violation of 37 C.F.R. § 42.6(a)(3).
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Prelim. Resp. 10. In the figure reproduced above, Patent Owner summarizes
Petitioner’s argument for limitation [25b] of claim 25 of the ’688 patent. Id.
Specifically, the figure shows that the “2 sentences” of argument in the
“[25b]” portion of the Petition refer back to nine sections of the Petition
covering “24 pages” and that those nine sections refer back to one another,
as well as to an additional seven sections of the Petition spanning an
additional six pages. Id. Patent Owner’s figure accurately represents the
structure of Petitioner’s argument. See Pet. 91 (citing Pet. 14–16, 37–49
(citing Pet. 17–26), 56–59 (citing Pet. 17–26, 54), 59 (citing Pet. 37–49),
59–60 (citing Pet. 37–49, 56–59), 60 (citing Pet. 37–49, 56–60), 61–63
(citing Pet. 17–26, 49–51, 55–61)).
Thus, Petitioner’s unpatentability analysis relies on the description of
a set of hypothetical computers relying, in part, on Petitioner’s descriptions
and characterizations of the teachings of the prior art. The result of all these
layers of analysis is that the final unpatentability analysis is two or three
levels removed from the actual disclosure of the references. Petitioner’s
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approach completely blurs the line between the actual teachings of each
asserted reference, Petitioner’s modifications to those teachings, and
Petitioner’s characterizations of those teachings.
A good example of the nested nature of the cross-references in the
Petition can be seen in the analysis of limitation [13a]. In alleging that
“Shimura discloses [13a]” and “[t]he Shimura-Hisano combination10
discloses the function and corresponding structure for the means-plus-
function limitation in [13a],” the Petition cites to several earlier sections.
Pet. 75 (citing Pet. §§ VI.C, VII.A.1, VII.B.4, VII.B.5.a, VII.B.5.b). These
earlier sections cover pages 14–22 and 56–60 of the Petition, a span of
fourteen pages. In addition, some of the cited sections themselves cite other
portions of the Petition. Id. at 56–59 (§ VII.B.4, citing Pet. §§ VI.C,
VII.A.1, VII.B.1, VII.B.2.a, VII.B.2.e), 59 (§ VII.B.5.a, citing Pet.
§ VII.B.1), 59–60 (§ VII.B.5.b, citing Pet. §§ VII.B.1, VII.B.4, VII.B.5.a).
All told, the material cited on page 75 of the Petition, together with the
material cited in that cited material, covers eight sections of the Petition
spanning thirty pages, none of which expressly discusses the language of
limitation [13a] or how the prior art teaches or suggests that language. This
approach of forcing the reader to follow a web of nested cross-references to
find Petitioner’s arguments improperly shifts the burden of deciphering
Petitioner’s arguments onto Patent Owner and the Board. See Apple Inc. v.
ContentGuard Holdings, Inc., IPR2015-00442, Paper 9 at 5–10 (PTAB July
13, 2015).

10 Although Petitioner challenges claim 13 on the basis of the combination
of Shimura and Tsuji, Petitioner argues here that a different combination of
references, Shimura and Hisano, teaches or suggests limitation [13a].
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2. The Ward Declaration Contributes to the Petition’s Lack of
Clarity
As in ContentGuard, the problem of nested citations here is not
limited to the Petition. The Ward Declaration also makes use of the same
type of internal cross-references. For example, in arguing that the prior art
teaches or suggests limitation [13a], the Petition cites to paragraph 253 of
the Ward Declaration. Pet. 75 (citing Ex. 1010 ¶ 253). That paragraph,
however, cites to nine additional paragraphs and three additional sections of
the declaration for support. Ex. 1010 ¶ 253 (citing Ex. 1010 ¶¶ 116, 124,
127–133, §§ VIII.A.4, VIII.A.5.a, VIII.A.5.b). Together, the cited material
spans twenty paragraphs of the Ward Declaration. See id. ¶¶ 116, 124, 127–
133, 188–198. Similar citations from the declaration to other large portions
of the declaration plague Ward’s discussion of many of the challenged
claims. See, e.g., Ex. 1010 ¶¶ 188–193 (discussing claim 3 and citing Ex.
1010 ¶¶ 111, 112, 124, 150–169, 170, 171, 178), 297–299 (discussing
limitation [25b] and citing Ex. 1010 ¶¶ 123, 124, 150–169, 188–200, 207–
215).
In most cases, the material the Petition cites in the Ward Declaration,
together with the other portions of the declaration cited therein, is far more
extensive than any argument present in the Petition. See, e.g., Pet. 56–59
(four pages of argument regarding claim 3, relying on testimony appearing
on twenty-three pages of Ward Declaration), 75 (four lines of argument
regarding limitation [13a], relying on testimony appearing on seventeen
pages of Ward Declaration), 91 (six lines of argument regarding limitation
[25b], relying on testimony appearing on twenty-six pages of Ward
Declaration). This incorporation by reference also contributes to the
deficiency of the Petition. See 37 C.F.R. § 42.6(a)(3).
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3. The Petition’s Analysis of the Challenged Claims is Largely
Conclusory
As noted above, the Petition’s discussion of nearly every limitation
relies upon earlier portions of the Petition (usually in a nested fashion) to
identify the evidence that allegedly supports Petitioner’s unpatentability
arguments. See, e.g., id. at 56–59 (citing Pet. §§ VI.C, VII.A.1, VII.B.1,
VII.B.2.a, VII.B.2.e), 75 (citing Pet. §§ VI.C, VII.A.1, VII.B.4, VII.B.5.a,
VII.B.5.b), 91 (citing Pet. §§ VI.C, VII.B.1, VII.B.4, VII.B.5.a, VII.B.5.b,
VII.B.6, VII.B.9.e–VII.B.9.h). Some of these sections also contain text
explaining Petitioner’s argument that the prior art teaches or suggests the
limitation in question, along with citations directly to the relevant prior art.
See, e.g., id. at 56–59 (citing Ex. 1004 ¶ 12, Fig. 1). Most of these sections,
however, do not contain this type of argument, opting instead for conclusory
statements that a particular reference or the hypothetical combination of
references discloses the limitation in question, referring the reader to earlier
portions of the Petition for any relevant argument. See, e.g., id. at 75, 91.
This latter type of argument is particularly problematic because it shifts an
even greater portion of the burden of deciphering Petitioner’s arguments
onto Patent Owner and the Board. For these limitations, Petitioner provides
no argument at all, requiring Patent Owner or the Board to sift through
multiple lengthy sections of the Petition even to determine what argument
Petitioner intends to make. And this type of argument appears more often
than not in the Petition; the great majority of the limitations discussed are
discussed only in this fashion. See Pet. 54–56, 59–61, 63–65, 69–70, 75,
89–91, 95–100, 105, 111–112 (discussing limitations [1c2], [1c3], [1e], [1g],
[2], [4b], [5]–[7], [19pre]–[19d], [19g], [29pre], [29b]–[29f], [30], [31],
[12pre]–[12e], [13a], [13b], [24], [9a], [9b], [14a], [14b], [15a], [15b], [16a],
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[16b], [20], [23], [25a], [25b], [17pre]–[17j], [18a]–[18c], [22], [27a], [28],
[11pre]–[11b], [11d]). Moreover, this particular type of deficient argument
affects multiple limitations of each of the independent claims of the ’688
patent, as well as limitations of many of the dependent claims. Id.
4. The Petition’s Incorporation of Exhibit 1012 by Reference
Exacerbates the Lack of Clarity
The Petition’s deficient analysis is further exacerbated by Petitioner’s
drafting of the Petition in such a way as to make it incomprehensible unless
we ignore our rule against incorporation by reference. The arguments in the
Petition rely extensively on abbreviations for the limitations of the ’688
patent’s claims, such as [1pre], [1c2], and [17f]. Pet. 37–113. There is no
way to understand many of Petitioner’s arguments without an understanding
of the meaning of these abbreviations. See, e.g., id. at 54 (arguing that “[t]he
Shimura-Hisano combination discloses [1c2] and renders it obvious,”
without defining what “[1c2]” means). Despite the reader’s need to
understand these abbreviations, the Petition does not define them. Id. at 1–
113. Instead, Petitioner directs us to Exhibit 1012 for the definitions of these
abbreviations. Id. at 11 (“EX-1012 is a claim listing that enumerates each
claim element.”). But “[a]rguments must not be incorporated by reference
from one document into another document.” 37 C.F.R. § 42.6(a)(3). This
additional layer of obfuscation, in violation of Rule 42.6(a)(3), takes the
Petition even further away from the clarity required by Rules 42.22(a) and
42.104(b).
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5. Some of the Petition’s Arguments Can Be Understood but
Lack Sufficient Explanation in Support
In addition to the problems discussed above, some arguments in the
Petition can be understood but lack sufficient explanation in support. For
example, Petitioner offers a construction of the term “display orientation
module,” which it contends is a means-plus-function term that has a
different function in each claim in which it appears (and in some cases,
different functions in different limitations of the same claim). Pet. 14–16.
Despite these differing functions, Petitioner’s arguments that the prior art
teaches or suggests the function of this term in claims 4, 5, 11, 13, 14, 16,
19, and 25 all rely exclusively on citation back to Petitioner’s argument for
claim 3 (which, according to Petitioner, recites a different function). Id.
at 60–63, 75, 89–91, 111–112 (citing Pet. §§ VII.B.4). The Petition does not
contain any explanation of why the teaching of one function also teaches a
different function, leaving the Petition deficient with respect to claims 4, 5,
11, 13, 14, 16, 19, and 25.
6. Conclusion
As explained above, the Petition provides deficient arguments that fail
to explain Petitioner’s positions fully. Where the Petition provides some
explanation, it does so only through a web of internal cross-references that
require the reader to engage in extensive analysis just to decipher what is
being argued, much less evaluate the merits of that argument. Although it
might be possible for us to wade through this voluminous information and
separate the teachings of the references, the Ward testimony, Petitioner’s
characterizations of the evidence, and Petitioner’s arguments, that is not our
role. Instead, Petitioner is required to “specify where each element of the
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claim is found in the prior art patents or printed publications relied upon”
and to both “identify[] specific portions of the evidence that support the
challenge” and explain “the relevance of [that] evidence to the challenge
raised.” 37 C.F.R. § 42.104(b)(4)–(5); see also id. § 42.22(a)(2) (petitions
“must include . . . [a] full statement of the reasons for the relief requested,
including a detailed explanation of the significance of the evidence”).
Petitioner has not complied with our rules. To hold otherwise would require
us to “play archaeologist with the record,” which we decline to do. DeSilva
v. DiLeonardi, 181 F.3d 865, 866–67 (7th Cir. 1999),
Based on all these deficiencies, the Petition fails to specify
sufficiently where the limitations of the challenged claims of the ’688 patent
are taught or suggested by any of the asserted references. It also fails to
provide a sufficiently detailed explanation of the significance of the citations
to the asserted references and the Ward Declaration. These failures violate
the requirements of 35 U.S.C. § 312(a)(3), 37 C.F.R. § 42.22(a)(2), and
37 C.F.R. § 42.104(b)(4)–(5). Because these requirements must be met to
show that “there is a reasonable likelihood that the petitioner would prevail
with respect to at least 1 of the claims challenged in the petition” under
35 U.S.C. § 314(a), we determine that Petitioner has not made such a
showing.
B. Remaining Arguments
Petitioner presents arguments for the construction of some claim
terms, and Patent Owner disagrees with some of those arguments. Pet. 11–
17; Prelim. Resp. 18–24. Petitioner and Patent Owner also present
arguments on the merits of each of Petitioner’s five asserted grounds of
unpatentability. Pet. 37–113; Prelim. Resp. 37–80. Finally, Patent Owner
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argues that Petitioner circumvented the word-count limit applicable to the
Petition by moving some material into exhibits and by improperly
formatting its citations. Prelim. Resp. 17–18. Because we determine that
the Petition does not satisfy the requirements of 35 U.S.C. § 312(a)(3),
37 C.F.R. § 42.22(a)(2), and 37 C.F.R. § 42.104(b)(4)–(5), we need not
evaluate these arguments.
CONCLUSION
Upon consideration of the Petition, the Preliminary Response, and the
evidence presented, we determine that Petitioner has not shown a reasonable
likelihood that it will prevail in showing that at least one of the challenged
claims is unpatentable. Accordingly, we do not institute an inter partes
review of any challenged claim based on any ground asserted in the Petition.

ORDER
It is hereby
ORDERED that, pursuant to 35 U.S.C. § 314, the Petition is denied,
and no inter partes review is instituted.

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For PETITIONER:
Martin Bader
Nam Kim
SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
mbader@sheppardmullin.com
nkim@sheppardmullin.com

For PATENT OWNER:
Gerald B. Hrycyszyn
Richard F. Giunta
Jason Balich
WOLF GREENFIELD & SACKS, P.C.
ghrycyszyn-ptab@wolfgreenfield.com
rgiunta-ptab@wolfgreenfield.com
jbalich-ptab@wolfgreenfield.com