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November 01, 2018


Thanks for publishing the chart of the reasons why proposed claim amendments were denied. Some were also denied as being presented way to late in the proceedings. It can be seen that most outcomes would not be changed by the new procedures. Also note that the total of 305 IPR motions to amend [actually, substitutions] is a surprisingly small percentage of all IPRs. We will see if it now substantially increases. That will require early and more realistic appraisals of the prior art cited in the Petition vis a vis the subject claims.

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