This document is Versata's sur-reply to Zoho's motion for summary judgment regarding patent infringement. It argues that Zoho mischaracterized facts and ignored key evidence in its reply. Specifically, it argues that Zoho's mobile clients are separate programs from its web clients, not just websites viewed on mobile devices as Zoho claimed. It also argues that mobile displays were not generic at the time of the patent application. The document claims Zoho's Alice analysis is flawed and overgeneralizes the purpose and ignores improvements of the patent. It asserts Zoho misapplied a prior court decision and exaggerated preemption concerns regarding the patent claims.
Microsoft Dynamics CRM 2015 has 4 type of processes, which are Workflow, Dialog, Actions & Business Process Flow. First 3 Types are discussed in these Slides
This document provides recommendations from a design team to improve collaboration between design and development. It outlines challenges such as tight deadlines not allowing for research, misunderstandings in how designs translate to code, lack of version control training for designers, and handoffs between teams. The recommendations include allocating time for initial research, collaborative sessions to share processes, hands-on Perforce training, using a scrum board to track all tasks, and providing style sheets to standardize UI elements. The overall goal is to craft engaging experiences by leveraging SAP software through co-innovation and collaboration between designers, strategists, and developers.
This document is a certificate of completion for part one of a two-part course on key fundamentals of flood insurance. It was issued to Tracy Richardson by Dorothy Martinez, the director of training for the National Flood Insurance Program, on September 22nd, 2016 after completing a basic agent webinar.
The document summarizes the Work Related Learning program at East Norfolk Sixth Form College. The program provides students opportunities such as work experience, industry visits, mentoring and mock interviews to prepare them for careers. The program partners with local businesses to create learning opportunities in key sectors like manufacturing, life sciences and energy. Students apply for and are selected for opportunities like placements, where they gain experience and feedback. The goal is to mimic real work experiences and connect students to the local job market.
This document provides a branding lookbook for Happy Joe's fall 2015 campaign. It outlines objectives to promote four new pizza flavors and a new Crunch Crust Pizza while attracting a younger demographic. A suggested slogan is "Every Pizza Has a Story." The campaign includes a storyboard, billboard, and social media promotions on Facebook, Twitter, and Instagram offering discounts for engaging with posts. Suggestions are made to promote drink specials like happy hours and half-price wine to pair with the new Crunch Crust Pizza.
This document summarizes Daniel Little's views on social science as presented in his work "Action in History and Social Science". It discusses key concepts such as social regularities, causal explanations, and agents and structures. Little argues that social science differs from natural science due to weak social regularities and lack of governing laws. However, causal mechanisms and analyses of how social entities influence individuals can provide a basis for limited predictions in social science. The scope of prediction is narrower than in natural sciences given the complexity of human behaviors and institutions.
O documento descreve projetos de voluntariado da Comissão Estadual de Voluntariado em Contabilidade Pública (PVCC) no Brasil, incluindo uma rede nacional de fiscalidade cívica, educação financeira, doações para crianças e idosos, e ações locais de voluntariado.
Microsoft Dynamics CRM 2015 has 4 type of processes, which are Workflow, Dialog, Actions & Business Process Flow. First 3 Types are discussed in these Slides
This document provides recommendations from a design team to improve collaboration between design and development. It outlines challenges such as tight deadlines not allowing for research, misunderstandings in how designs translate to code, lack of version control training for designers, and handoffs between teams. The recommendations include allocating time for initial research, collaborative sessions to share processes, hands-on Perforce training, using a scrum board to track all tasks, and providing style sheets to standardize UI elements. The overall goal is to craft engaging experiences by leveraging SAP software through co-innovation and collaboration between designers, strategists, and developers.
This document is a certificate of completion for part one of a two-part course on key fundamentals of flood insurance. It was issued to Tracy Richardson by Dorothy Martinez, the director of training for the National Flood Insurance Program, on September 22nd, 2016 after completing a basic agent webinar.
The document summarizes the Work Related Learning program at East Norfolk Sixth Form College. The program provides students opportunities such as work experience, industry visits, mentoring and mock interviews to prepare them for careers. The program partners with local businesses to create learning opportunities in key sectors like manufacturing, life sciences and energy. Students apply for and are selected for opportunities like placements, where they gain experience and feedback. The goal is to mimic real work experiences and connect students to the local job market.
This document provides a branding lookbook for Happy Joe's fall 2015 campaign. It outlines objectives to promote four new pizza flavors and a new Crunch Crust Pizza while attracting a younger demographic. A suggested slogan is "Every Pizza Has a Story." The campaign includes a storyboard, billboard, and social media promotions on Facebook, Twitter, and Instagram offering discounts for engaging with posts. Suggestions are made to promote drink specials like happy hours and half-price wine to pair with the new Crunch Crust Pizza.
This document summarizes Daniel Little's views on social science as presented in his work "Action in History and Social Science". It discusses key concepts such as social regularities, causal explanations, and agents and structures. Little argues that social science differs from natural science due to weak social regularities and lack of governing laws. However, causal mechanisms and analyses of how social entities influence individuals can provide a basis for limited predictions in social science. The scope of prediction is narrower than in natural sciences given the complexity of human behaviors and institutions.
O documento descreve projetos de voluntariado da Comissão Estadual de Voluntariado em Contabilidade Pública (PVCC) no Brasil, incluindo uma rede nacional de fiscalidade cívica, educação financeira, doações para crianças e idosos, e ações locais de voluntariado.
Platform-independent application development frameworkTal Lavian Ph.D.
Embodiments of the invention provide a platform-independent application development framework for programming an application. The framework comprises a content interface configured to provide an Application Programming Interface (API) to program the application comprising a programming code to be executed on one or more platforms. The API provided by the framework is independent of the one or more platforms. The framework further comprises an application environment configured to provide an infrastructure that is independent of the one or more platforms and one or more plug-in interfaces configured to provide an interface between the application environment and the one or more platforms.
https://www.google.com/patents/US20090313004?dq=20090313004&hl=en&sa=X&ei=0cpTVLawNcGzmAWr1YBQ&ved=0CB8Q6AEwAA
This document discusses standard essential patents (SEPs) and FRAND disputes in the smartphone industry. It provides background on the smartphone patent wars, the role of SEPs in litigation between companies like Apple, Motorola, and Samsung, and issues around FRAND commitments. Specifically, it summarizes that FRAND commitments require SEP holders to license their patents under fair, reasonable, and non-discriminatory terms, but disputes arise because definitions of FRAND terms are unclear and not specified in standards setting organization policies. This has led to courts interpreting FRAND commitments and whether injunctive relief is appropriate for SEPs.
Platform-independent application development frameworkTal Lavian Ph.D.
Embodiments of the invention provide a platform-independent application development framework for programming an application. The framework comprises a content interface configured to provide an Application Programming Interface (API) to program the application comprising a programming code to be executed on one or more platforms. The API provided by the framework is independent of the one or more platforms. The framework further comprises an application environment configured to provide an infrastructure that is independent of the one or more platforms and one or more plug-in interfaces configured to provide an interface between the application environment and the one or more platforms.
CAFC Chronicles: Costly Tales of Claim Construction FailsAurora Consulting
The difference between getting claim construction right and getting it wrong is the difference between a valid patent and an invalid patent – and the difference between millions of dollars awarded from infringement decisions vs. ending up with a worthless piece of paper.
In this month’s episode, Dr. David Jackrel, President of Jackrel Consulting, leads a discussion into three real-world applications for patent claim construction, as tested and decided upon by the United States Court of Appeals for the Federal Circuit. This is the highest court in the land under the Supreme Court for handling intellectual property disputes – and establishes much of the legal precedent the patent world has to go on … for better and for worse. The panel dissects the claims for each case, discusses the court’s analysis, and provides tips and strategies for more effective claim drafting in light of the strengths and weaknesses of the litigated patents.
Dave is joined today by our always exceptional group, including:
⦿ Dr. Ashley Sloat, President and Director of Patent Strategy at Aurora
⦿ Kristen Hansen, Patent Strategy Specialist at Aurora
⦿ Ty Davis, Patent Strategy Associate at Aurora
Listen here: https://patentlystrategic.buzzsprout.com/1734511/14991984-cafc-chronicles-costly-tales-of-claim-construction-fails
Presented at Kansas City Bar Association on October 23, 2018 by John Bednarz during CLE: Patent Law Update, Recent Subject Matter Eligibility Decisions and Trends at the USPTO.
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Print this page
11.2 Technology of Information Infrastructure
Animation: Technology Infrastructure
LEARNING OBJECTIVE
Identify the way information infrastructure creates business opportunities.
UPS estimates that it saves nearly 1 million gallons of gas each year across North America just by using mapping technology that minimizes left
turns (drivers turning left risk being delayed by oncoming traffic). The mapping system has also eliminated millions of miles of travel by matching
packages, delivery times, and truck locations in order to optimize routes and maximize delivery densities. By tracking this data in real time and
running complex analytics, the firm is able to improve efficiency, thereby saving time and money. Digital technologies make this possible (see
Figure 11.7).
Figure 11.7Assessing the level of information infrastructure in countriesThe
information infrastructure consists of communication technologies and information
technologies such as data storage and processing.
In a similar way, the country Estonia uses digital technology to run many government operations. Estonia began the process of digitizing its
operations in 1997. The system now enables citizens to register vehicles, file health insurance claims, and even vote, all through an electronic
platform called X-Road. The system is so successful that over 900 agencies—some global, including energy, telecom, and banking—offer services
through the site. Because of the boost in efficiency, the platform saves an estimated five days a year per citizen by eliminating trips to government
offices by both citizens and businesses, which can access information such as land deeds. The efficiency of the system adds 7 million workdays to
the Estonian economy. For instance, in Estonia taxes can be filed in five minutes using prefilled, auto-generated reports; by contrast, most
Germans hire tax consultants to help them fill out tax forms and spend hours on the process.
Digital infrastructure like the Internet can also help international businesses improve their communication networks, data storage, and information
processing, as we'll see next.
Communication Technologies
Changes in communication technologies can dramatically affect international business opportunities. For example, even in Brazil's poorest favelas
(slums), satellite TV and even Internet access are nearly ubiquitous (Figure 11.8). Because nearly all consumers have access to media,
international companies like Samsung, LG, and Apple can market their electronics to global customers. Companies can launch products in new
markets more quickly and efficiently when they can harness global media.
40
41
42
43
6/8/20, 1:52 PMTechnological Change and Infrastructure
Page 2 of 7https://edugen.wileyplus.com/edugen/courses/crs1205.
Recent Developments in Proving Damages in Intellectual Property DisputesParsons Behle & Latimer
The document summarizes a presentation given on November 13, 2014 in Salt Lake City, Utah on intellectual property damages. The presentation covered trends in patent damages after the Uniloc case, new approaches to calculating patent damages, recent developments in trademark damages awards, recent decisions on proving copyright damages, and alternative theories for trade secret damages cases. It provided details on methodologies for calculating lost profits and reasonable royalties in patent cases, challenges in applying the entire market value rule, proving non-infringing alternatives, and issues relating to foreign sales and the Nash bargaining solution in damages analyses.
Embodiments of techniques that may be used to improve communication efficiency in a network are provided. One or more versions of one or more communication protocols in the network may be monitored. A document object model of data may be processed at a device to generate raw data. Subsequently, the raw data may be transmitted by the device on the network based on the versions of the communication protocols.
https://www.google.com/patents/US20100146112?dq=20100146112&hl=en&sa=X&ei=1clTVOzRI-K7mQWBx4C4Bg&ved=0CB8Q6AEwAA
Protecting Emerging Technology in the World of Internet of Things (IoTs), Art...Essentiality Check
The document discusses challenges for intellectual property counsel in protecting emerging technologies integrated into business products and services. It focuses on challenges for protecting internet of things (IoT) technologies, including artificial intelligence. Key challenges include securing adequate patent protection given that new innovations may automate known processes or apply known techniques. The document also discusses compliance with various standards and regulations for wireless technologies used in IoTs, as well as issues around graphical user interfaces, design patents, and patent eligibility of artificial intelligence inventions.
The Wireless Remote Control Car Based On Arm9IOSR Journals
Abstract: TheInternetof Things (IoT) are of great importance in promoting and guiding development of information technology and economic. At Present, theapplicationoftheIoT develops rapidly, but due to the special requirements of some applications, the existing technology cannot meet them very good. Much research work is doing to build IoT. Wi-Fi basedWirelessremote control has the features of high bandwidth and rate, non-line-transmission ability, large-scale data collection and high cost-effective, and it has the capability of video monitoring, which cannot be realized with RF. The research on Wi-Fi based remote control car has high practical significance to the development oftheInternetof Things. Based on the current research work ofapplicationsthe characteristics of Wi-Fi, this paper discusses controlling the car by using Wi-Fi module along with the conditions can be monitored through remote PC or Lap top which supports Wi-Fi technology. In PC or Lap top two tabs are present. In the first tab we can monitor the conditions and in the second tab four buttons are present to control the car in forward, back ward, left side and right side directions. Keywords: S3C2440 (ARM9), Wi-Fi Module, Camera, DC motors with driver IC and laptop with Wi-Fi module.
BrightEdge Technologies, Inc. filed a patent infringement complaint against Searchmetrics GmbH and Searchmetrics, Inc. alleging that Searchmetrics' SEO software platform infringes four patents held by BrightEdge related to search engine optimization technology. BrightEdge seeks monetary damages, a permanent injunction, attorneys' fees, and a jury trial.
Software engineering based fault tolerance model for information system in pl...IJECEIAES
The rapid development of mobile phone technologies in recent years promoted them for being used in various areas of life, such as commercial, health, transportation and tourism and other uses. In this paper, a software engineering based fault tolerance model is proposed to manage the expected faults in the adopted servers. The underlying QR based information system in plants shopping center employs different local serves allocated at local shops that are connected to the main server. In a fault case detection at any local server, the main server can cover the management of the system until the maintenance is completed. This is performed in efficient way as the main server keeps a copy of the information for all local branches. It is important to note that the self-checking process is adopted for fault detection. After completing the maintenance, a copy of the updated information is sent back to the investigated local server including all sales, etc. Moreover, the main and local servers contain information about all offer’s plants in different languages and in text and image form, customer's information and admin's information. The proposed system is tested in several cases to prove the efficiency and effectivity in retrieving and managing information and data as well as the fault tolerance administration.
This document discusses the importance of user experience for mobile applications on Windows Phone. It emphasizes designing applications around intuitive touch gestures and a seamless experience across different devices and screen orientations. The document provides examples of prototype mobile photo apps and best practices for application design, such as keeping interfaces simple and delivering information in small chunks optimized for mobile. It promotes developing apps for the Windows Phone Marketplace to reach global customers and earn attractive revenue sharing from sales.
This patent application describes a system for managing software development projects. The system aggregates status and requirement information over time. It generates multi-dimensional vectors to represent the status and requirements. It calculates the difference between these vectors to determine a project estimate. This estimate includes the predicted completion time and recommended changes to meet targets. The system dynamically adjusts the estimate as the status and requirements change over the course of the project.
This document summarizes a research paper that designed and implemented a location-based mobile application to provide local information to users. The application allows users to select the type, amount, and region of local information they want to view based on their current or specified location. The application was implemented with secure coding techniques to protect user information and system resources from attacks. Key features included categorizing local information, setting display preferences, and separating server and client modules for increased security.
Mfuse - Native vs HTML5 - Whitepaper - Nov12Paul Galbraith
The document discusses the debate between developing mobile applications as native apps or browser-based HTML5 apps, noting that native apps have more functionality but higher costs while HTML5 aims for "write once, run anywhere" but has varying browser support; it reviews the pros and cons of each approach and examines the fragmentation of devices, browsers, and HTML5 feature support across platforms, concluding that true cross-platform support does not currently exist and multiple versions may still be needed.
Mobile Provisioning Enterprise Network PON-Revisi-Final - EnglishMuharam Cahyadi
This paper proposes renewing the mobile provisioning system for Passive Optical Networks (PON) in line with the development of the Internet of Things ecosystem. The proposed system uses an Android application on a smartphone with an RFID scanner as a client to automate the provisioning process. This allows provisioning times to be reduced by half compared to the previous manual system and reduces operational costs. The system architecture includes registration, database, billing and RADIUS servers that communicate via open APIs to provision new customers onto the PON network automatically.
As a part of developing the IoT patent prosecution strategy, USPTO prosecution history file wrappers for 192 patent applications regarding the key IoT applications are reviewed and analyzed. The192 patent applications regarding the key IoT applications mostly filed within three years. They cover Home Automation, Home Security, Home Energy/Utility Management System, Home Safety Monitoring, Home Lighting System, Vehicle Accident Avoidance System, Vehicle Control Automation, Vehicle Navigation System, Vehicle Maintenance/Diagnostic/Alert System, Vehicular Communication System, Vehicle Infotainment System, Fitness Management System, Health ICT System, Health Management System, Medication Management System, Physical Activity Monitoring, Physiological Monitoring System, Sleep Monitoring System, and Telemedicine System.
The most cited rejection ground in the first non-final office action (OA) was 103. The 103 rejection ground accounted for 74 % (143/192) of the total patent applications. For other rejection grounds, 102 accounted for 55 % (106/192); 112 accounted for 33 % (64/192); 101 accounted for 16 % (30/192) of the total patent applications. Among 168 issued patents 32 patents allowed without any rejection (excluding double patenting rejection), which accounted for 19 %.
AirView aims to expand the Internet of Things (IoT) by connecting outdoor structures using drones to place low-cost sensors. The sensors would gather environmental and infrastructure data via WiFi networks in a cost-effective way. AirView's software platform would manage sensor communication, data storage, and analytics. This would provide useful data to reduce costs and generate future revenue streams from applications like remote security, environmental monitoring, and predictive maintenance of bridges and buildings.
115 steven m. mello - 7766223 - method and system for mobile servicesMello_Patent_Registry
This patent describes a method and system for providing mobile financial services using a mobile device. The system associates a unique identification number of a mobile device, such as an MDN or MEID, with a user's financial account. Transactions are conducted using the mobile device. Security authentication involves multiple factors including the device ID, passwords, and voice biometrics. The financial institution has ownership rights over the mobile device including the ability to disable it.
More Related Content
Similar to Versata's Sur-Reply re Patent Eligibility
Platform-independent application development frameworkTal Lavian Ph.D.
Embodiments of the invention provide a platform-independent application development framework for programming an application. The framework comprises a content interface configured to provide an Application Programming Interface (API) to program the application comprising a programming code to be executed on one or more platforms. The API provided by the framework is independent of the one or more platforms. The framework further comprises an application environment configured to provide an infrastructure that is independent of the one or more platforms and one or more plug-in interfaces configured to provide an interface between the application environment and the one or more platforms.
https://www.google.com/patents/US20090313004?dq=20090313004&hl=en&sa=X&ei=0cpTVLawNcGzmAWr1YBQ&ved=0CB8Q6AEwAA
This document discusses standard essential patents (SEPs) and FRAND disputes in the smartphone industry. It provides background on the smartphone patent wars, the role of SEPs in litigation between companies like Apple, Motorola, and Samsung, and issues around FRAND commitments. Specifically, it summarizes that FRAND commitments require SEP holders to license their patents under fair, reasonable, and non-discriminatory terms, but disputes arise because definitions of FRAND terms are unclear and not specified in standards setting organization policies. This has led to courts interpreting FRAND commitments and whether injunctive relief is appropriate for SEPs.
Platform-independent application development frameworkTal Lavian Ph.D.
Embodiments of the invention provide a platform-independent application development framework for programming an application. The framework comprises a content interface configured to provide an Application Programming Interface (API) to program the application comprising a programming code to be executed on one or more platforms. The API provided by the framework is independent of the one or more platforms. The framework further comprises an application environment configured to provide an infrastructure that is independent of the one or more platforms and one or more plug-in interfaces configured to provide an interface between the application environment and the one or more platforms.
CAFC Chronicles: Costly Tales of Claim Construction FailsAurora Consulting
The difference between getting claim construction right and getting it wrong is the difference between a valid patent and an invalid patent – and the difference between millions of dollars awarded from infringement decisions vs. ending up with a worthless piece of paper.
In this month’s episode, Dr. David Jackrel, President of Jackrel Consulting, leads a discussion into three real-world applications for patent claim construction, as tested and decided upon by the United States Court of Appeals for the Federal Circuit. This is the highest court in the land under the Supreme Court for handling intellectual property disputes – and establishes much of the legal precedent the patent world has to go on … for better and for worse. The panel dissects the claims for each case, discusses the court’s analysis, and provides tips and strategies for more effective claim drafting in light of the strengths and weaknesses of the litigated patents.
Dave is joined today by our always exceptional group, including:
⦿ Dr. Ashley Sloat, President and Director of Patent Strategy at Aurora
⦿ Kristen Hansen, Patent Strategy Specialist at Aurora
⦿ Ty Davis, Patent Strategy Associate at Aurora
Listen here: https://patentlystrategic.buzzsprout.com/1734511/14991984-cafc-chronicles-costly-tales-of-claim-construction-fails
Presented at Kansas City Bar Association on October 23, 2018 by John Bednarz during CLE: Patent Law Update, Recent Subject Matter Eligibility Decisions and Trends at the USPTO.
6820, 152 PMTechnological Change and InfrastructurePage.docxfredharris32
6/8/20, 1:52 PMTechnological Change and Infrastructure
Page 1 of 7https://edugen.wileyplus.com/edugen/courses/crs12056/ebook/c11/…OTc4MTExOTI0NDgzN2MxMV8zXzAueGZvcm0.enc?course=crs12056&id=ref
Print this page
11.2 Technology of Information Infrastructure
Animation: Technology Infrastructure
LEARNING OBJECTIVE
Identify the way information infrastructure creates business opportunities.
UPS estimates that it saves nearly 1 million gallons of gas each year across North America just by using mapping technology that minimizes left
turns (drivers turning left risk being delayed by oncoming traffic). The mapping system has also eliminated millions of miles of travel by matching
packages, delivery times, and truck locations in order to optimize routes and maximize delivery densities. By tracking this data in real time and
running complex analytics, the firm is able to improve efficiency, thereby saving time and money. Digital technologies make this possible (see
Figure 11.7).
Figure 11.7Assessing the level of information infrastructure in countriesThe
information infrastructure consists of communication technologies and information
technologies such as data storage and processing.
In a similar way, the country Estonia uses digital technology to run many government operations. Estonia began the process of digitizing its
operations in 1997. The system now enables citizens to register vehicles, file health insurance claims, and even vote, all through an electronic
platform called X-Road. The system is so successful that over 900 agencies—some global, including energy, telecom, and banking—offer services
through the site. Because of the boost in efficiency, the platform saves an estimated five days a year per citizen by eliminating trips to government
offices by both citizens and businesses, which can access information such as land deeds. The efficiency of the system adds 7 million workdays to
the Estonian economy. For instance, in Estonia taxes can be filed in five minutes using prefilled, auto-generated reports; by contrast, most
Germans hire tax consultants to help them fill out tax forms and spend hours on the process.
Digital infrastructure like the Internet can also help international businesses improve their communication networks, data storage, and information
processing, as we'll see next.
Communication Technologies
Changes in communication technologies can dramatically affect international business opportunities. For example, even in Brazil's poorest favelas
(slums), satellite TV and even Internet access are nearly ubiquitous (Figure 11.8). Because nearly all consumers have access to media,
international companies like Samsung, LG, and Apple can market their electronics to global customers. Companies can launch products in new
markets more quickly and efficiently when they can harness global media.
40
41
42
43
6/8/20, 1:52 PMTechnological Change and Infrastructure
Page 2 of 7https://edugen.wileyplus.com/edugen/courses/crs1205.
Recent Developments in Proving Damages in Intellectual Property DisputesParsons Behle & Latimer
The document summarizes a presentation given on November 13, 2014 in Salt Lake City, Utah on intellectual property damages. The presentation covered trends in patent damages after the Uniloc case, new approaches to calculating patent damages, recent developments in trademark damages awards, recent decisions on proving copyright damages, and alternative theories for trade secret damages cases. It provided details on methodologies for calculating lost profits and reasonable royalties in patent cases, challenges in applying the entire market value rule, proving non-infringing alternatives, and issues relating to foreign sales and the Nash bargaining solution in damages analyses.
Embodiments of techniques that may be used to improve communication efficiency in a network are provided. One or more versions of one or more communication protocols in the network may be monitored. A document object model of data may be processed at a device to generate raw data. Subsequently, the raw data may be transmitted by the device on the network based on the versions of the communication protocols.
https://www.google.com/patents/US20100146112?dq=20100146112&hl=en&sa=X&ei=1clTVOzRI-K7mQWBx4C4Bg&ved=0CB8Q6AEwAA
Protecting Emerging Technology in the World of Internet of Things (IoTs), Art...Essentiality Check
The document discusses challenges for intellectual property counsel in protecting emerging technologies integrated into business products and services. It focuses on challenges for protecting internet of things (IoT) technologies, including artificial intelligence. Key challenges include securing adequate patent protection given that new innovations may automate known processes or apply known techniques. The document also discusses compliance with various standards and regulations for wireless technologies used in IoTs, as well as issues around graphical user interfaces, design patents, and patent eligibility of artificial intelligence inventions.
The Wireless Remote Control Car Based On Arm9IOSR Journals
Abstract: TheInternetof Things (IoT) are of great importance in promoting and guiding development of information technology and economic. At Present, theapplicationoftheIoT develops rapidly, but due to the special requirements of some applications, the existing technology cannot meet them very good. Much research work is doing to build IoT. Wi-Fi basedWirelessremote control has the features of high bandwidth and rate, non-line-transmission ability, large-scale data collection and high cost-effective, and it has the capability of video monitoring, which cannot be realized with RF. The research on Wi-Fi based remote control car has high practical significance to the development oftheInternetof Things. Based on the current research work ofapplicationsthe characteristics of Wi-Fi, this paper discusses controlling the car by using Wi-Fi module along with the conditions can be monitored through remote PC or Lap top which supports Wi-Fi technology. In PC or Lap top two tabs are present. In the first tab we can monitor the conditions and in the second tab four buttons are present to control the car in forward, back ward, left side and right side directions. Keywords: S3C2440 (ARM9), Wi-Fi Module, Camera, DC motors with driver IC and laptop with Wi-Fi module.
BrightEdge Technologies, Inc. filed a patent infringement complaint against Searchmetrics GmbH and Searchmetrics, Inc. alleging that Searchmetrics' SEO software platform infringes four patents held by BrightEdge related to search engine optimization technology. BrightEdge seeks monetary damages, a permanent injunction, attorneys' fees, and a jury trial.
Software engineering based fault tolerance model for information system in pl...IJECEIAES
The rapid development of mobile phone technologies in recent years promoted them for being used in various areas of life, such as commercial, health, transportation and tourism and other uses. In this paper, a software engineering based fault tolerance model is proposed to manage the expected faults in the adopted servers. The underlying QR based information system in plants shopping center employs different local serves allocated at local shops that are connected to the main server. In a fault case detection at any local server, the main server can cover the management of the system until the maintenance is completed. This is performed in efficient way as the main server keeps a copy of the information for all local branches. It is important to note that the self-checking process is adopted for fault detection. After completing the maintenance, a copy of the updated information is sent back to the investigated local server including all sales, etc. Moreover, the main and local servers contain information about all offer’s plants in different languages and in text and image form, customer's information and admin's information. The proposed system is tested in several cases to prove the efficiency and effectivity in retrieving and managing information and data as well as the fault tolerance administration.
This document discusses the importance of user experience for mobile applications on Windows Phone. It emphasizes designing applications around intuitive touch gestures and a seamless experience across different devices and screen orientations. The document provides examples of prototype mobile photo apps and best practices for application design, such as keeping interfaces simple and delivering information in small chunks optimized for mobile. It promotes developing apps for the Windows Phone Marketplace to reach global customers and earn attractive revenue sharing from sales.
This patent application describes a system for managing software development projects. The system aggregates status and requirement information over time. It generates multi-dimensional vectors to represent the status and requirements. It calculates the difference between these vectors to determine a project estimate. This estimate includes the predicted completion time and recommended changes to meet targets. The system dynamically adjusts the estimate as the status and requirements change over the course of the project.
This document summarizes a research paper that designed and implemented a location-based mobile application to provide local information to users. The application allows users to select the type, amount, and region of local information they want to view based on their current or specified location. The application was implemented with secure coding techniques to protect user information and system resources from attacks. Key features included categorizing local information, setting display preferences, and separating server and client modules for increased security.
Mfuse - Native vs HTML5 - Whitepaper - Nov12Paul Galbraith
The document discusses the debate between developing mobile applications as native apps or browser-based HTML5 apps, noting that native apps have more functionality but higher costs while HTML5 aims for "write once, run anywhere" but has varying browser support; it reviews the pros and cons of each approach and examines the fragmentation of devices, browsers, and HTML5 feature support across platforms, concluding that true cross-platform support does not currently exist and multiple versions may still be needed.
Mobile Provisioning Enterprise Network PON-Revisi-Final - EnglishMuharam Cahyadi
This paper proposes renewing the mobile provisioning system for Passive Optical Networks (PON) in line with the development of the Internet of Things ecosystem. The proposed system uses an Android application on a smartphone with an RFID scanner as a client to automate the provisioning process. This allows provisioning times to be reduced by half compared to the previous manual system and reduces operational costs. The system architecture includes registration, database, billing and RADIUS servers that communicate via open APIs to provision new customers onto the PON network automatically.
As a part of developing the IoT patent prosecution strategy, USPTO prosecution history file wrappers for 192 patent applications regarding the key IoT applications are reviewed and analyzed. The192 patent applications regarding the key IoT applications mostly filed within three years. They cover Home Automation, Home Security, Home Energy/Utility Management System, Home Safety Monitoring, Home Lighting System, Vehicle Accident Avoidance System, Vehicle Control Automation, Vehicle Navigation System, Vehicle Maintenance/Diagnostic/Alert System, Vehicular Communication System, Vehicle Infotainment System, Fitness Management System, Health ICT System, Health Management System, Medication Management System, Physical Activity Monitoring, Physiological Monitoring System, Sleep Monitoring System, and Telemedicine System.
The most cited rejection ground in the first non-final office action (OA) was 103. The 103 rejection ground accounted for 74 % (143/192) of the total patent applications. For other rejection grounds, 102 accounted for 55 % (106/192); 112 accounted for 33 % (64/192); 101 accounted for 16 % (30/192) of the total patent applications. Among 168 issued patents 32 patents allowed without any rejection (excluding double patenting rejection), which accounted for 19 %.
AirView aims to expand the Internet of Things (IoT) by connecting outdoor structures using drones to place low-cost sensors. The sensors would gather environmental and infrastructure data via WiFi networks in a cost-effective way. AirView's software platform would manage sensor communication, data storage, and analytics. This would provide useful data to reduce costs and generate future revenue streams from applications like remote security, environmental monitoring, and predictive maintenance of bridges and buildings.
115 steven m. mello - 7766223 - method and system for mobile servicesMello_Patent_Registry
This patent describes a method and system for providing mobile financial services using a mobile device. The system associates a unique identification number of a mobile device, such as an MDN or MEID, with a user's financial account. Transactions are conducted using the mobile device. Security authentication involves multiple factors including the device ID, passwords, and voice biometrics. The financial institution has ownership rights over the mobile device including the ability to disable it.
Similar to Versata's Sur-Reply re Patent Eligibility (20)
115 steven m. mello - 7766223 - method and system for mobile services
Versata's Sur-Reply re Patent Eligibility
1. 1
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS
VERSATA SOFTWARE, INC., et al.
Plaintiffs,
v.
ZOHO CORPORATION
d/b/a MANAGEENGINE
Defendant.
§
§
§
§
§
§
§
§
CIVIL ACTION NO. 1:13-cv-00371-SS
JURY TRIAL DEMANDED
VERSATA’S SUR-REPLY TO ZOHO’S MOTION FOR SUMMARY JUDGMENT
Pursuant to ¶ 32 of the Court’s Policies and Procedures,1
plaintiff Versata respectfully
submits this brief addressing certain errors in the Reply (Dkt. 99) filed by Zoho Corporation.
I. THE REPLY MISCHARACTERIZES FACTS AND IGNORES KEY EVIDENCE
First, Zoho represents to the Court that its accused “mobile client is simply a website that
can be viewed using a mobile device.”2
This is misleading. Like the accused iPhone and Android
apps, Zoho’s Mobile Clients are separate programs from Zoho’s standard web clients and are
contained in distinct code files.3
Zoho’s Mobile Clients do not simply display Zoho’s standard
websites on a mobile device. Rather, as Versata’s Infringement Contentions clearly depict, they
present interfaces specifically configured for mobile displays.4
Zoho’s own internal documents
confirm this feature in both the ServiceDesk Plus and Applications Manager products:
The Mobile Client is compatible with mobile devices such as Blackberry and
iPhone, and is accessed through the mobile browser on typing the URL
1
Fact Sheet for Judge Sam Sparks ¶ 32, at http://www.txwd.uscourts.gov/General/Judges/judge_policy.asp
2
Zoho Corporation’s Reply in Support for Motion for Summary Judgment (Dkt. 99) (“Reply”) at 3.
3
In keeping with common industry practice, the code files for the mobile applications are generally designated by
terms such as “mobile,” “iOS” (for iPhone operating systems), “iphone” or “android” in the filepath name.
4
See Att. 1, Infringement of U.S. Pat. 7,092,740 by ManageEngine ServiceDesk Plus, and Att. 3, Infringement of
U.S. Pat. 7,092,740 by ManageEngine Applications Manager (“Infringement Contentions”). The fact that Zoho
develops and advertises these software features tends to belie any claim that they are not technologically important.
Case 1:13-cv-00371-SS Document 100 Filed 08/31/15 Page 1 of 8
2. 2
http://<machine-name>:<port-number>, which redirects to the ‘mc’ context.5
Optimized for all types of smart phones available in the market, the
Applications Manager Mobile Client provides a convenient method to track critical
applications, perform actions, receive alerts and identify issues quickly and easily
from any location….The mobile client is adapted for efficiency on
smartphones....6
The methods used by these applications to optimize for mobile displays infringe the ’740 patent.
Second, Zoho’s repeated insistence that “mobile devices are generic computing
equipment”7
ignores the extensive evidence of record that mobile displays (the element recited in
the claims) are not.8
Thus, even if (as Zoho alleges) the computing properties of mobile phones
could be considered generic at the time of the ’740 application, the use of – and presentation of
information on – mobile displays certainly was not generic. Despite thirty pages of briefing,
Zoho presents no factual evidence to the contrary.
Third, Zoho’s Reply repeats the erroneous assertion that the ’740 invention does not
5
See Att. 2, ManageEngine ServiceDesk Plus User Guide at 79, cited in Att. 1 at D-19 (emphasis added). Zoho’s
reply brief quotes this same language, but omits the clause “which redirects to the ‘mc’ context.” Reply at 3.
6
See Att. 4, “Mobile Client for Applications Manager,” cited in Att. 3 at B-2 (emphasis added, para. break omitted).
7
Reply at 6, 10.
8
E.g., the following documents cited in and attached to Versata’s Response (Dkt. 97) demonstrate the non-
conventional nature of mobile displays and of the application of the ’740 techniques to them:
• U.S. Pat. 7,092,740 (“the ’740 patent”) at 1:12-20, 1:30-33, 7:21-37, 7:41-50 (Att. 1 to Resp.) (Dkt. 97-1);
• Navrátil Decl. ¶ 17-18, 22-29, 44-46 (Att. 2 to Resp.) (Dkt. 97-2);
• A. Neibauer, How to Do Everything with Yahoo! (2000) at 170 (Fig. 7-12), 171 (Att. 8 to Resp.) (Dkt. 97-8);
• P. Campbell, Mobile Web Design: Getting to the Point - Part I (Oct. 29, 2008) (Att. 4 to Resp.) (Dkt. 97-4);
• M. Homann et al., “Towards User Interface Patterns for ERP Applications on Smartphones,” Business
Information Systems: 16th International Conference, BIS 2013 at 14-15 (Att. 5 to Resp.) (Dkt. 97-5).
See also Att. 5, C. Zwick et al., Designing for Small Screens (2005) at:
• 012/013 (“The strategies of software design can only be transferred from the ‘big’ devices to their ‘small’
counterparts to a very limited extent. This means that the development of the user interface is the crucial factor
in the design process.”)
• 040/041 (“The lack of space on smaller screens means that the quest for the dynamic organisation of space is
one of the most challenging aspects associated with the design process.”)
• 048/049 (“Interaction with small screens is typically characterised by greater user impatience and shorter
reading times or attention spans than with large screens. The interaction scenario must take this into account by
displaying legible text in small and easily manageable portions only.”)
Case 1:13-cv-00371-SS Document 100 Filed 08/31/15 Page 2 of 8
3. 3
“improve[] the performance of a mobile device.”9
The ’740 patent shows that this assertion is
untrue,10
and Zoho provides neither evidence nor argument that the improvements described in
the patent are illusory. The patent’s improvements in usability, coding efficiency and bandwidth
are pragmatic advantages that compare favorably with the patents upheld in DDR Holdings
(which addressed “a specific way to automate the creation of a composite web page by an
‘outsource provider’ that incorporates elements from multiple sources in order to solve a
problem faced by websites on the Internet”)11
and Trading Techs. (which “eliminated some
problems of prior GUIs [graphical user interfaces] relating to speed, accuracy and usability”).12
Zoho also complains that the ’740 claims “do not provide sufficient instruction to direct
the practitioner how to carry out the claims.”13
But tellingly, Zoho has not alleged that a person
of ordinary skill would be unable to implement the claimed method. Like the Trading Techs.
claims which this Court reviewed approvingly in Affinity/Amazon,14
the ’740 claims adequately
describe the claimed display techniques, while leaving software coding and other specific design
choices to the practitioner. None of Zoho’s cases require the inventor to provide specific design
choices or code as part of the patent disclosure.
9
Reply at 6; see also Zoho Corporation’s Motion for Summary Judgment (Dkt. 93) (“Zoho Br.”) at 17.
10
See, e.g., ’740 patent at:
• 7:17-20 (“data encodings of such display indications may be encoded in a few bytes if necessary or desirable.
Consequently, the described techniques can facilitate display updates over even low bandwidth networks.”)
• 7:21-26 (“In contrast with existing text-based linking techniques, which in most practical cases could support
no more than 4 links on a screen, some implementations support a dense grid of display indictions [sic] which
could easily support 20 to 50 links in the same space.”)
• 7:45-50 (“For example, the state information for a 32-cell data grid could be stored in just 4 bytes (compare this
to 2 KB for even the smallest web graphics, or about 64 bytes for text). Consequently, the described techniques
may continue to work well, even under extremely bandwidth constrained situations.”)
To the extent Zoho contends that such advantages must be recited in the claims, such is not the law.
11
DDR Holdings LLC v. Hotels.com, 773 F.3d 1245, 1259 (Fed. Cir. 2014).
12
Trading Technologies Int’l Inc. v. CQG Inc., 2015 WL 774655 *5 (N.D. Ill. 2015).
13
Reply at 7.
14
Affinity Labs of Texas v. Amazon.com Inc., 2015 WL 3757497 *12 (W.D. Tex. 2015), citing Trading Techs. at *5.
Case 1:13-cv-00371-SS Document 100 Filed 08/31/15 Page 3 of 8
4. 4
II. THE REPLY REPEATS FATAL FLAWS IN ZOHO’S ALICE ANALYSIS
A. Zoho erroneously presumes an overly-abstract purpose
Zoho wrongly alleges that “Versata does not dispute that the ’740 patent is directed to an
abstract idea” and that “Versata Concedes that the Purpose of the Claims Is Abstract.”15
Neither
of these statements is true. In fact, § IV(A)(1) of Versata’s Response contends in detail that
“Zoho cannot show that the claims are directed to an ‘abstract idea’.”
Next, Zoho repeats its assumption that the purpose of the patent extends beyond mobile
displays to “any way of using symbols on a display to represent information and updating these
symbols as information changes,” and then argues that this purpose is “ancient” and “abstract.”16
Zoho’s assumption has multiple flaws. First, by framing the purpose of the patent as broadly as
possible, it presumes the abstraction it seeks to prove, committing exactly the error of over-
generalization that the Supreme Court warned against in Alice.17
Such caution is especially
important with respect to software, which inherently addresses problems that can be stated
conceptually and provides solutions for particular applications.18
Second, Zoho’s description
cannot be squared with the ’740 claims or disclosure, every aspect of which expressly directs the
invention to mobile displays and nothing else.19
In essence, Zoho pretends that the mobile
display limitations are not present – even though they are the raison d’etre of the invention.
15
Reply at 1.
16
Id. at 1-2.
17
Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 134 S.Ct. 2347, 2354 (2014) (“At some level, all inventions embody, use,
reflect, rest upon or apply laws of nature, natural phenomena or abstract ideas. Thus, an invention is not rendered
ineligible for patent simply because it involves an abstract concept”) (internal citations and punctuation omitted); see
also Versata Resp. at 6.
18
California Inst. of Tech. v. Hughes Communications, 59 F.Supp.3d 974, 990 (C.D. Cal. 2014) (“Caltech”) (“most
inventions today build on what is known in the art, and an improvement to software will almost inevitably be an
algorithm or concept which, when viewed in isolation, will seem abstract. This analysis would likely render all
software patents ineligible, contrary to Congress’s wishes.”)
19
See, e.g., ’740 patent at Abstract, 1:12-14, 1:45-50, 2:27-31; see also Navrátil Decl. ¶ 21.
Case 1:13-cv-00371-SS Document 100 Filed 08/31/15 Page 4 of 8
5. 5
Third, Zoho’s theory ignores the Supreme Court’s principle, followed by this Court, that merely
employing an abstract idea “does not render a claimed method unpatentable where the method
improves upon an existing technological process.”20
B. Zoho’s misapplies this Court’s holding in Affinity/Amazon
Zoho cites Affinity/Amazon for the theory that mobile phones are “generic” devices,
noting the Court’s reference to “a generic, electronic device – in this case, a wireless handheld
device….”21
However, the case made no finding regarding mobile displays, which were not at
issue. Moreover, the “wireless handheld device” mentioned in the Affinity/Amazon patent22
was
“generic” only because it was “operating as a ‘ubiquitous information-transmitting medium, not
a novel machine’….”23
The patent-in-suit was not tied in any way to the particular constraints of
such a device, but relied only on the device’s general computing capabilities. In contrast, the
’740 patent, far from treating mobile devices as generic, makes clear that the differences between
mobile and conventional displays (including screen size, line count and pixel count) are the very
reason for the invention. More generally, although Zoho offers the Affinity/Amazon patent as its
best analogy to the claims at bar,24
a closer look shows that nothing in the patent at issue there
20
Wavetronix LLC v Iteris Inc., 2015 WL 300726 (W.D. Tex. 2015) *6, citing the Supreme Court’s decisions in
Alice, 134 S.Ct. at 2358 and Diamond v. Diehr, 450 U.S. 175 (1981). Zoho’s attempts to distinguish Wavetronix are
unavailing. Just as the Wavetronix claims were, in Zoho’s words, directed to a “specific unsolved problem” (Reply
at 10) in traffic signaling, the ’740 claims are directed to a specific and well-documented problem in mobile
displays. Similarly, while the Wavetronix claims recited “specialized sensors” (Reply at 10), they did so in the same
way that the ’740 claims recite mobile displays: as the reason for and implementation of the subsequently described
technique.
21
Reply at 6, citing Affinity/Amazon at *10 (W.D. Tex. 2015).
22
Att. 6, U.S. Pat. 8,688,085.
23
Affinity/Amazon at *10 (italics added), quoting Ultramercial Inc. v. Hulu LLC, 772 F.3d 709, 716-717 (Fed. Cir.
2014). The italicized clause, which is the latter part of this Court’s finding cited by Zoho, is missing from
Zoho’s quotation.
24
Reply at 8-9. Notably, the “case law” discussion in Zoho’s Reply does not dispute Versata’s case-by-case
analysis distinguishing Zoho’s other references, nor does it dispute any of the cases cited by Versata upholding
patents similar to the ’740. Cf. Versata Resp. at 17-20, Zoho Reply at 8-9.
Case 1:13-cv-00371-SS Document 100 Filed 08/31/15 Page 5 of 8
6. 6
linked the invention to a particular problem in the prior art or a specific improvement in
performance. As detailed in Versata’s Response, the ’740 patent is exactly the opposite: it
addresses a known technological problem of mobile displays compared to conventional displays,
and the claimed techniques achieve concrete technical advantages in this context.25
C. Zoho’s preemption arguments are unsupportable
Zoho states that “Versata mischaracterizes the preemption doctrine when it suggests that
a claim must cover ‘all uses of an abstract idea’ for it to raise preemption concerns.”26
But the
“all uses” language about which Zoho complains was not Versata’s phrasing – it was Zoho’s
own argument, which alleged that the ’740 claims “threaten to pre-empt all uses of the abstract
idea.”27
More fundamentally, Zoho’s Reply disputes neither the principle that preemption claims
are to be viewed warily28
nor any of Versata’s examples showing that Zoho has exaggerated the
preemption concern.29
Zoho has not met its burden of showing that the ’740 claims improperly
tie up the field of mobile display design, much less that they pre-empt “too much.”
For the foregoing reasons, as well as the reasons stated in Versata’s Response, the Court
should reject Zoho’s request for summary invalidation of the ’740 patent.
DATED: August 31, 2015 Respectfully submitted,
/s/ George W. Webb III
Demetrios Anaipakos
Texas Bar No. 00793258
25
See, e.g., Versata Resp. at 9-12, 14-15; Navrátil Decl. at ¶¶ 17-30.
26
Reply at 9, citing Versata Resp. at 15.
27
See Zoho Br. at 13 (emphasis in original), Reply at 9 (“Patents such as the ’740…risk burdening all present and
future ways of doing so”).
28
Alice, 134 S.Ct. at 2354 (“we tread carefully in construing this exclusionary principle lest it swallow all of patent
law”); see also the Enfish and Kenexa cases cited in Versata Resp. at 16.
29
Cf. Versata Resp. at 15-16, Reply at 9. In addition, the ’740 claims do not foreclose other techniques of small-
screen design, such as use of color or highlighting. See, e.g., Att. 4, Designing for Small Screens at 048/049,
144/145.
Case 1:13-cv-00371-SS Document 100 Filed 08/31/15 Page 6 of 8
7. 7
danaipakos@azalaw.com
Amir Alavi
Texas Bar No. 00793239
aalavi@azalaw.com
Steven J. Mitby
Texas Bar No. 24037123
smitby@azalaw.com
Alisa A. Lipski
Texas Bar No. 24041345
alipski@azalaw.com
George W. Webb III
Texas Bar No. 24003146
gwebb@azalaw.com
AHMAD, ZAVITSANOS, ANAIPAKOS, ALAVI &
MENSING, P.C.
1221 McKinney Street, Suite 3460
Houston, TX 77010
Telephone: 713-655-1101
Facsimile: 713-655-0062
Travis C. Barton
Texas Bar No. 00790276
tcbarton@mcginnislaw.com
Patton G. Lochridge
Texas Bar No. 12458500
Richard D. Milvenan
Texas Bar No. 14171800
MCGINNIS, LOCHRIDGE & KILGORE LLP
600 Congress Avenue, Suite 2100
Austin, TX 78701
Telephone: 512-495-600
Facsimile: 512-495-6093
ATTORNEYS FOR PLAINTIFFS
Case 1:13-cv-00371-SS Document 100 Filed 08/31/15 Page 7 of 8
8. 8
ATTACHMENTS
Attachment
to this
Response
Description Short Reference
Previous
Exhibit No.
(if applicable)
1
Infringement of U.S. Pat. No. 7,092,740 by
ManageEngine ServiceDesk Plus (served
3/02/2015 as Att. D to Versata’s First
Supplemental Response to Zoho’s
Interrogatory No. 6)
ServiceDesk Plus
Infringement
Contentions
Zoho Reply,
Sacksteder
Decl. Ex. A
(Dkt. 99-2)
2
ManageEngine ServiceDesk Plus User
Guide at 79-84, cited in Infringement of
U.S. Pat. No. 7,092,740 by
ManageEngine ServiceDesk Plus at D-19
ServiceDesk Plus
User Guide
3
Infringement of U.S. Pat. No. 7,092,740 by
ManageEngine Applications Manager
(served 3/02/2015 as Att. B to Versata’s
First Supplemental Response to Zoho’s
Interrogatory No. 6)
App. Mgr.
Infringement
Contentions
4
“Mobile Client for Applications Manager,”
cited in Infringement of U.S. Pat. No.
7,092,740 by ManageEngine
Applications Manager at B-2
“Mobile Client
for App. Mgr.”
5
Carol Zwick, Burkhard Schmitz & Kerstin
Kuhl, Designing for Small Screens (2005)
(selected pages)
Designing for
Small Screens
6
U.S. Pat. 8,688,085 (patent-in-suit in
Affinity/Amazon)
’085 patent
7
Declaration of George W. Webb III to
Accompany Versata’s Sur-Reply to
Zoho’s Motio for Summary Judgment
Webb Sur-Reply
Decl.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that all counsel of record who are deemed to have consented to
electronic service are being served on August 31, 2015, with a copy of this document via the
Court’s CM/ECF system per Local Rule CV-5(b)(1).
/s/ George W. Webb III
4833-9831-6071, v. 3
Case 1:13-cv-00371-SS Document 100 Filed 08/31/15 Page 8 of 8