US GOVERNMENT
CONTRACTS AND RIGHTS IN
PATENTS AND TECH DATA
MARGARET M.
M GATTI,
GATTI ESQ
ESQ.
LOUIS K. ROTHBERG, ESQ.
MARCH, 2012
www.morganlewis.com
Ground Rules
 No Charge
 Electronic submission of questions
 Slides Available Upon Request
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2
Disclaimer
 Information only
 NOT legal advice!
 Accurate as of date of Webinar
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GENERAL PRINCIPLES
 Ri
Rights
ht off contractor
t t and
d subcontractor
b
t t to
t patents
t t
and data [“IPR”] under a USG contract controlled by
federal law and federal regulations
g
unique
q to federal
procurement
 NOT governed by State statutory nor State common
law as if 2 private parties
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GENERAL PRINCIPLES
 Federal Acquisition Regulations [FAR] apply to all
Federal contracts
 Defense Federal Acquisition Regulations Supplement
[DFARS] apply
l tto D
Defense
f
D
Department
t
t [D
[DoD]
D]
contracts
 Other Government agencies
g
also have supplements
pp
 Our focus today is FAR & DFARS
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GENERAL PRINCIPLES
• In Government contracts,
contracts law requires certain
provisions to be included:
– Omitted clauses included as if in contract
– Contract is reformed to comply with law
• Contract Officer’s ability
y to negotiate
g
is
constrained
• Cannot assume that:
– IP provision
i i that
th t is
i nott initially
i iti ll included
i l d d will
ill nott be
b
automatically included later or
– An initially
y included p
provision will not be removed
as contrary to law (Christian Doctrine)
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GENERAL PRINCIPLES
 The specific clauses incorporated stipulate the
contactor’s and Government’s IPR rights as if set
forth verbatim and in full text
 Section of the Prime Contract most likely to
contain the incorporation of IPR clauses is
Section I [“eye”] – although may be elsewhere
You will see only citation to FAR or DFARS
You must review referenced FAR or DFARS cites
Y mustt also
You
l review
i
definitions
d fi iti
for
f terms
t
used
d
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GENERAL PRINCIPLES
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GENERAL PRINCIPLES
 USG P
Prime
i
Contract
C t
t iis between
b t
USG agency
and prime contractor
 Subcontract is between Prime Contractor and
its subcontractors who will assist Prime
Contractor in performing tasks under Prime
Contract
 Prime and sub contracts will INCORPORATE
BY REFERENCE relevant FAR and DFARS
clauses by specific clause number
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GENERAL PRINCIPLES
 Contractor MUST know which IPR clauses
Contracting Officer is seeking to insert into
the Prime Contract
 Subcontractor MUST know which IPR clauses
have been incorporated into Prime Contract
and hence will FLOW DOWN to control IPR
rights under subcontract
 If subcontract states only that all FAR /
DFARS provisions in prime contract flow
down to subcontract, get a copy of the prime
contract
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GENERAL PRINCIPLES
 “Flow
Flow-Down
Down” means that a Prime Contractor is
mandated by USG Prime Contract to include certain
clauses or other terms/conditions in subcontracts
under the Prime Contract
 Flow-down will dictate subcontractor’s rights
g
in IPR
data because IPR clauses have been pre-determined in
prime
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GENERAL PRINCIPLES
 IPR clauses
l
affect
ff t th
the rights
i ht in
i
IPR of all contractors and
subcontractors under a USG
contract
 Read your contracts
 Look
L k up FAR / DFARS clauses
l
referenced!
 Review definitions of terms
used in the FAR / DFARS
provisions!
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Prime
Sub
Contractor
Sub
Contractor
Sub
Contractor
GENERAL PRINCIPLES
 NOT knowing which IPR clauses have been
incorporated into a prime or which flow down
th
through
h a sub-contract
b
t
t iis common
 Negligent to agree to be bound by critical
impact of IPR clauses about which you know
little or nothing
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GENERAL PRINCIPLES
 Obtain and read all IPR clauses BEFORE
signing
i i prime
i
or subcontract.
b
t
t
 Avoid nasty surprises later on!
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PATENTS
P
Patent
t t rights
i ht under
d USG contracts
t t governed
d by
b
policies set forth in FAR Subpart 27.3 [48 CFR 27.300
– 27.306].
]
 Apply to all executive agencies of USG subject to
i di id l agency supplements
individual
l
t
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PATENTS:
M i Concepts
Main
C
t
USG gets certain “use rights” in
inventions made by the contractor
d ring the performance of work
during
ork under
nder
the USG contract
Contractor must disclose patentable
invention to USG agency,
g
y but thereafter
CAN elect to retain title/ownership in
patent to any “subject invention”
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PATENTS:
M i Concepts
Main
C
t
“Subject
j
invention” is invention
made by the contractor in
performance of a USG contract
o Represents
p
contracted deliverable
o Also represents non-contracted /
unanticipated deliverable
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PATENTS:
USG Rights
Ri ht
 Th
The “subject
“ bj t invention”
i
ti ” invented
i
t d during
d i performance
f
off
USG contract may:
o Have been developed exclusively with USG funds or
o Have been developed partially with USG funds
 Source of funding for “subject
subject invention
invention” is not relevant.
relevant
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PATENTS
USG Rights
Ri ht
 USG will receive use right [called license] to use
patent
 USG will have at least a nonexclusive, nontransferable, irrevocable, paid-up license to practice or
have p
practiced for or on behalf of USG,, the subject
j
invention worldwide while Contractor owns patent
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PATENTS
USG Rights
Ri ht
 Paid
P id up means royalty
lt free
f
- no fee
f to
t USG
 USG license may be broadened in a specific contract
to provide USG with additional rights as the USG
deems necessary to meet its obligations under
treaties, international agreements, MOUs
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PATENTS
USG Rights
Ri ht
 St
Standard
d d FAR P
Patent
t t Cl
Clause 52
52.227-11
227 11 [48 CFR
52.227-11] is 6 pages in length. Used for small
businesses and non-profit
p
entities. There are special
p
provisions for “subject inventions” made by:
 Nonprofit entities
 Small business entities
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PATENTS
USG Rights
Ri ht
Standard FAR Patent Clause 52
52.227
227-11
11
[48 CFR 52.227-11] does not apply to NASA, DOE
and DOD as they have their own Clauses
 NASA and DOE clauses provide for ownership rights
as opposed to use rights.
 DoD Patent Clause for Large Business contracts is
DFARS 252.227-7038 which grants Contractor same
j
invention as FAR
option to retain title to subject
52.227-11 – but contains different reporting and
election provisions
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PATENTS
C t
Contractor’s
t ’ O
Ownership
hi
 Some key provisions of Patent Clause 52
52.227-11
227 11 for
contractors are as follows:
 Contractor shall disclose to Contracting Office [KO] in
writing each subject invention within 2 months after
the inventor discloses it in writing
g to Contractor
personnel responsible for patent matter.
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PATENTS
C t
Contractor’s
t ’ O
Ownership
hi
 Contractor
C t
t shall
h ll elect
l t in
i writing
iti whether
h th or nott
to retain ownership of subject invention within
2 years of disclosure to agency.
 This election also applies to foreign patent
applications. USG may file applications in all
unelected foreign countries
 Contractor shall file patent application with
Patent Office on an elected subject invention
within 1 year after election
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PATENTS:
C t
Contractor’s
t ’ O
Ownership
hi
 If Contractor
C t t elects
l t to
t retain
t i title,
titl timely
ti l prosecutes,
t
and
d
obtains patent from Patent Office, Contractor may
exploit
p
all patent
p
rights
g
as Contractor sees fit, subject
j
to
USG use/license rights
 Contractor may authorize/license third parties to use
patent upon agreed terms
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PATENTS
C t
Contractor’s
t ’ O
Ownership
hi
C
Contractor
t t should
h ld require
i by
b written
itt agreementt its
it own
employees, to disclose promptly in writing to appropriate
Contractor p
personnel each subject
j
invention in order for
Contractor to comply with disclosure provisions and to
execute all necessary papers required for patent
prosecution as require by Clause
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PATENTS
C t
Contractor’s
t ’ O
Ownership
hi
 FAR Clause allocates patent rights between
USG and Contractor
 Contractor needs to have separate contract
or agreement with inventor/employee which
enables Contractor to honor Clause
obligations to USG – otherwise
inventor/employer may assert rights to
patent
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PATENTS
C t
Contractor’s
t ’ O
Ownership
hi
 TO CONTRACTORS:
CONTRACTORS
 CAUTION
 If Contractor fails to disclose or elect ownership
within the times specified in the Clause or elects not
to retain ownership, Contractor shall assign to agency
on written
itt request,
t title
titl to
t any subject
bj t invention
i
ti
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PATENTS
C t
Contractor’s
t ’ O
Ownership
hi
C
Contractor
t t shall
h ll also
l assign
i to
t agency on written
itt request,
t
title to any subject invention in those countries in which
Contractor fails to file p
patent applications
pp
with times
specified in Clause or in any country where Contractor
decides not to continue patent prosecution process or
pay any required fees
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PATENTS
Where USG acquires title to patent in
subject invention, Contractor is granted
a revocable,
bl nonexclusive,
l i
paid-up
id
license to that subject invention
worldwide
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PATENTS
M
March-in
h i Rights
Ri ht - Contractor
C t t agrees th
thatt USG gets
t
right to grant other entities licenses or give a license
to USG in p
patent if USG deems necessary
y to do so in
certain specified cases. See 35 USC 203 and 37 CFR
401.6
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PATENTS RIGHTS
SUMMARY
 USG has non
non-exclusive
exclusive USE RIGHTS (non
(nonnegotiable) in “subject inventions”
 Contractor will have right
g to elect ownership
p in
the subject inventions but must:
o Disclose invention
o Elect to retain title
o File a patent application
o Commercialize
 USG may take ownership if contractor does
not comply with ownership requirements
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PATENT INFRINGEMENT
O
One exclusive
l i remedy
d for
f patent
t t infringement
i fi
t by,
b or
on behalf of, USG BY A USG CONTRACTOR
PERFORMING A USG CONTRACT
 Patentee must bring suit against USG for money
damages ONLY
 Must
M t sue iin Court
C
t off F
Federal
d l Claims
Cl i
 No injunctive relief available
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PATENT INFRINGEMENT
• 28 USC 1498 bars an infringement suit directly
against Contractor when Contractor or
subcontractor allegedly infringes US patent
owned by third party while Contractor or
subcontractor perform work for USG under
USG contract
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PATENT INFRINGEMENT
• USG will
ill expressly
l
authorize and consent to
Contractor’s use or
manufacture of
inventions covered by
US patent held by third
party, i.e. USG can
authorize infringement
b Contractor
by
C t t - FAR
Clause 52.227-1
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PATENT INFRINGEMENT
• USG requires
i
notice
ti and
d assistance
i t
from
f
Contractors
C t t
regarding claims for patent infringement – FAR Clause
52.227-2
• USG may, but need not, require Contractor to reimburse
USG for damage
g liability
y for infringement
g
– FAR Clause
52.227-3
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PATENT INFRINGEMENT
• Failure by USG to insert FAR Clause 52-227-3
(reimbursement clause) results in USG
assumption of liability to patent owner for
Contractor’s infringement of patent during
Contractor’s
Contractor
s performance of USG contract
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TECHNICAL DATA
• Technical
T h i lD
Data
t Ri
Rights
ht P
Policy
li ffound
d iin
– FAR S
Subpart
bpart 27
27.4
4 – civilian
ci ilian agencies
– DFARS Subpart 52.227 – DoD agencies
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TECHNICAL DATA
• Clauses
Cl
iincorporated
t d iinto
t contracts
t t ffound
d iin
– FAR S
Subpart
bpart 52
52.227
227 – civilian
ci ilian agencies
– DFARS Subpart 252.227 – DoD agencies
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TECHNICAL DATA
• T
Term “technical
“t h i l d
data”
t ” iis d
defined
fi d iin 41 USC 403(8) and
d
10 USC 2302(4):
• “Recorded information, regardless of the form or method
of recording, of a scientific or technical nature, including
computer software documentation, relating to supplies
procured by an agency.”
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TECHNICAL DATA
• D
DoD
D St
Standard
d d Cl
Clause ffor rights
i ht iin ttechnical
h i ld
data
t relating
l ti
to non-commercial items is
• DFARS Clause 252
252.227
227-7013
7013
• Used in contracts requiring delivery of data to USG in
R&D contracts
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TECHNICAL DATA
• DFARS Clause
252.227-7015 is
i
incorporated
t d when
h
data is acquired
under contract
involving commercial
item, component
p
or
process
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TECHNICAL DATA
• FAR Cl
Clause 52
52.227-14
227 14 iis th
the FAR b
basic
i d
data
t rights
i ht
clause
• Required for use in all solicitations and contracts by
civilian agencies if data will be produced, furnished or
acquired under the contract
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TECHNICAL DATA
• FAR also
l provides
id 5
Alternates to the basic
data rights
g
clause
• Agency can choose an
Alternate clause to fit
special agency
requirement
• Ascertain which specific
p
clause is in your contract
or subcontract
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TECHNICAL DATA
• FAR contains
t i no special
i l clause
l
ffor rights
i ht iin d
data
t ffor
procurement of commercial items.
• FAR 12.211 says USG should acquire only rights in data
customarily given to public with commercial item.
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TECHNICAL DATA
Tech
T
h data
d t protected
t t d through
th
h legal
l
l mechanisms
h i
arising
i i outt off
concepts of trade secret, copyright and contract law
All of these concepts are merged together into the tech data
rights
g
clauses in the FAR and DFARS
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TECHNICAL DATA
• KEY PRINCIPLE - USG
rights to use technical
data will be determined
on the basis of the
source of funds used
by the contractor or subsub
contractor to develop the
item or perform the
research
h ffrom which
hi h th
the
data was derived.
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TECHNICAL DATA
• USG never receives title to or ownership of
the technical data – JUST RIGHTS to use the
data [i.e.
[i e a license]
• Owner of technical data will be the
Contractor or subcontractor who developed
the data [DFARS 227.7103
227 7103-4(a)
4(a), FAR 27.403]
27 403]
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TECHNICAL DATA
• Th
Thus, the
th C
Contractor
t t or subcontractor
b
t t who
h owns the
th data
d t
can continue to use as the data as desired
• Can license/authorize others to do so generally.
• Simultaneously while the USG can exercise its parallel
but separate use rights
© Morgan, Lewis & Bockius LLP
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TECHNICAL DATA
• USG “Unlimited
“U li it d Rights”
Ri ht ” – Broadest
B d t
• USG obtains “Unlimited
Unlimited Rights”
Rights when data pertains to an
item or process developed exclusively with Government
funds. DFARS 227.7103-5(a); 252.227-7013(b)(1)
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TECHNICAL DATA
• Unlimited rights means USG forever may use,
duplicate, release, or disclose the technical data
in whole or in part in any manner to anyone for
any purpose whatsoever, and to have or to
permit others to do so. DFARS 252.227
252.2277013(a)(15)
• Contractor or subcontractor owner mayy similarlyy
use data or permit others to do so
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TECHNICAL DATA
• USG “Limited Rights” – Narrowest
• USG obtains “Limited Rights” when data pertains to an
item or process developed exclusivelyy with private funds.
DFARS 227.7103-5(c); DFARS 252.227-7013(b)(3)
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TECHNICAL DATA
• Limited rights means the rights to use, modify,
reproduce, release, perform, display, or disclose
t h i l data,
technical
d t in
i whole
h l or in
i part,
t within
ithi the
th
Government. The Government may not, without
the written permission of the party asserting
limited rights, release or disclose the technical
data outside the Government, use the technical
data for manufacture, or authorize the technical
data to be used by another party,
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TECHNICAL DATA
• except that the Government may reproduce
reproduce,
release or disclose such data or authorize the
use or reproduction of the data by persons
outside
t id th
the G
Governmentt if reproduction,
d ti
release,
l
disclosure, or use is—
• (i) Necessary for emergency repair and
overhaul; or
• (ii) A release or disclosure of technical data to,
or for a foreign government that is in the interest
of the Government;
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TECHNICAL DATA
• (iii) S
Subject
bj t tto a prohibition
hibiti on th
the ffurther
th reproduction,
d ti
release, disclosure, or use of the technical data; and
• (iv) The contractor or subcontractor asserting the
restriction is notified of such reproduction, release,
disclosure, or use. DFARS 252.227-7013(a)(13)
© Morgan, Lewis & Bockius LLP
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TECHNICAL DATA
• USG “Government
“G
t Purpose
P
Rights”
Ri ht ” –
• USG obtains “Government
Government Purpose Rights”
Rights when data
pertains to an item or process developed with both
Government and private funds. DFARS 227.7103-5(b);
DFARS 252.227-7013(b)(2)
© Morgan, Lewis & Bockius LLP
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TECHNICAL DATA
• G
Governmentt purpose rights
i ht means the
th rights
i ht FOR FIVE
YEARS to—
• (i) Use, modify, reproduce, release, perform, display, or
disclose technical data within the Government without
restriction; and
© Morgan, Lewis & Bockius LLP
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TECHNICAL DATA
• (ii) R
Release
l
or di
disclose
l
ttechnical
h i ld
data
t outside
t id th
the
Government and authorize persons to whom release or
disclosure has been made to use,, modify,
y, reproduce,
p
,
release, perform, display, or disclose that data for United
States government purposes.
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TECHNICAL DATA
• Upon expiration of
th fi
the
five-year or other
th
negotiated period,
the Government shall
have unlimited rights
in the technical data
DFARS 252.2277013(a)(11) and
7013(b)(2)
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TECHNICAL DATA
• S
Specifically
ifi ll negotiated
ti t d lilicense rights.
i ht The
Th standard
t d d
license rights granted to the Government, including the
period during
p
g which the Government shall have
government purpose rights in technical data, may be
modified by mutual agreement to provide such rights as
the parties consider appropriate.
appropriate
© Morgan, Lewis & Bockius LLP
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TECHNICAL DATA
• Wh
When rights
i ht are specifically
ifi ll negotiated,
ti t d th
the USG rights
i ht
cannot be less than limited rights.
• Any rights so specifically negotiated shall be identified in
a license agreement made part of this contract.
© Morgan, Lewis & Bockius LLP
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TECHNICAL DATA
• USG will
ill automatically
t
ti ll receive
i unlimited
li it d rights
i ht in
i
technical data unless Contractor or subcontractor
take affirmative steps
p to restrain such presumption
p
p
of USG unlimited rights in data
• DFARS 252-227-7013(b)(1)(vii)
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TECHNICAL DATA
• IIn its
it bid offer,
ff
Contract
C t
t mustt list
li t all
ll data
d t that
th t
it will give to USG in which USG will NOT
receive unlimited rights. DFARS 227.7103
227.7103-3
3
and -10
• This list will be made part of the contract if
the USG agrees to accept less than unlimited
rights
• If Data NOT on list – USG may claim
unlimited rights.
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TECHNICAL DATA
• Data Marking – Very Important
• Contractor must mark each piece of data on which it
claims restrictions indicating what level use rights
the USG is to have DFARS 252.227-7013(f)
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TECHNICAL DATA
• If Contractor
C t t Mistakenly
Mi t k l submits
b it to
t USG Unmarked
U
k dd
data
t
• Contractor can request to have the data subsequently
marked so long as request is made within 6 months after
submission to USG – DFARS 227.7103-10(c)(2)
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TECHNICAL DATA
• If USG h
has already
l d released
l
d th
the d
data,
t nothing
thi can b
be
done to correct the omission
• USG can challenge Contractor asserted restrictions on
USG rights in data
© Morgan, Lewis & Bockius LLP
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TECHNICAL DATA
• C
Contractor
t t mustt keep
k
records
d to
t validate
lid t or jjustify
tif
restrictive markings on data submitted to USG – DFARS
227.7103-11
• If USG refutes asserted restrictions, will notify Contractor
who has 60 days to respond - DFARS 227-7103-13(c)
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TECHNICAL DATA
• USG challenge may occur within 3 years after
date of submission of data by Contractor to
USG DFARS 227-7103-13(c)(1)
USG227 7103 13(c)(1)
• If Contractor fails to respond or cannot justify
factually the asserted restrictions
restrictions, the
Contracting Officer can declare USG has
unlimited rights
g
and the matter will be litigated
g
in
court
© Morgan, Lewis & Bockius LLP
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TECHNICAL DATA
• C
Contractor
t t is
i required
i d tto flflow d
down th
the d
data
t rights
i ht clause
l
to all its subcontractors
• Thus in any case where a subcontractor has developed
data and wishes to restrict USG rights, the subcontractor
must comply with marking and other requirements.
© Morgan, Lewis & Bockius LLP
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TECHNICAL DATA
Foreign contracts –
If the USG contracts with a company
outside the USA or Canada, USG can
o e special
spec a clause
c ause giving
g
g the
t e USG
invoke
unlimited rights in all data regardless of
th funding
the
f di source use to
t develop
d
l data
d t
DFARS 227.7103-17
Canada firms – treated as US contractors
© Morgan, Lewis & Bockius LLP
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TECHNICAL DATA
Summary:
Contractor retains title / ownership of
technical data
USG get use rights that vary with level
of USG funding:
 Unlimited Use Rights
 USG Purpose Rights
 Limited Use Rights
© Morgan, Lewis & Bockius LLP
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COMPARISON OF USG RIGHTS AND
AUSTRALIAN GOV RIGHTS
• E
Example:
l A
Australian
t li G
Governmentt “Approved
“A
d
Subcontractor IP Deed”
• Australian Government takes DIVERGENT approach
from USG on IPR rights
© Morgan, Lewis & Bockius LLP
72
COMPARISON OF USG RIGHTS AND
AUSTRALIAN GOV RIGHTS
• A
Australian
t li G
Gov takes
t k ownership
hi rights
i ht iin “F
“Foreground
d IP”
by default – unless negotiated by subcontractor
otherwise
• “Foreground IP” is “IP” created under or otherwise in
connection with performance of subcontract
© Morgan, Lewis & Bockius LLP
73
COMPARISON OF USG RIGHTS AND
AUSTRALIAN GOV RIGHTS
• “IP” iis ““allll copyrights,
i ht allll rights
i ht iin relation
l ti tto iinventions
ti
including patent rights and any other rights resulting from
intellectual activityy in the industrial,, scientific,, literaryy and
artistic fields recognized in domestic law anywhere in the
world.”
© Morgan, Lewis & Bockius LLP
74
COMPARISON OF USG RIGHTS AND
AUSTRALIAN GOV RIGHTS
• O
Ownership
hi rights
i ht allow
ll
A
Australian
t li G
Gov tto authorize
th i
others to commercialize the Foreground IP for
unrestricted sales in the g
global g
general civilian
marketplace
• Subcontractor left with NO rights to use “Foreground IP”
© Morgan, Lewis & Bockius LLP
75
COMPARISON OF USG RIGHTS AND
AUSTRALIAN GOV RIGHTS
• A
Australian
t li G
Gov may on requestt grantt to
t subcontractor
b
t t a
license/use rights in “Foreground IP” on terms
acceptable
p
to the Australian Gov including
gp
payment
y
by
y
sub of license fees to Australian Gov
• Australian Gov is NOT compelled by Deed terms to do
this
© Morgan, Lewis & Bockius LLP
76
COMPARISON OF USG RIGHTS AND
AUSTRALIAN GOV RIGHTS
• A
Australian
t li G
Gov takes
t k defense
d f
purpose rights
i ht iin
“Background IP” by default – unless negotiated by
subcontractor otherwise
• Subcontractor has ownership.
• “Background IP” is “IP” that is in existence on the date
the Deed is signed
© Morgan, Lewis & Bockius LLP
77
COMPARISON OF USG RIGHTS AND
AUSTRALIAN GOV RIGHTS
• B
Background
k
d IP is
i also
l IP b
brought
ht iinto
t existence
i t
other
th
than as a result of the performance of the subcontract
• “Defense
Defense Purposes”
Purposes is defined as any purpose within the
Power of Australian Gov with respect to the defense of
Australia, peacekeeping, civil emergency
© Morgan, Lewis & Bockius LLP
78
COMPARISON OF USG RIGHTS AND
AUSTRALIAN GOV RIGHTS
• A
Appears similar
i il tto DFARS “G
“Governmentt Purpose”
P
” use
rights.
• Defense Purpose would not appear to permit
commercialization Background IP by Australian Gov
© Morgan, Lewis & Bockius LLP
79
SUMMARY
• R
Read
d and
d understand
d t dP
Patent
t t and
dD
Data
t rights
i ht clauses
l
incorporated by reference into your contract
• If you are subcontractor
subcontractor, ask your prime contractor about
all clauses flowed down
• Adhere to any time constraints for filing notices with USG
© Morgan, Lewis & Bockius LLP
80
SUMMARY
• M
Markk your data
d t with
ith appropriate
i t USG use rights
i ht
• Keep records that can justify any USG rights less than
unlimited rights
© Morgan, Lewis & Bockius LLP
81
QUESTIONS
© Morgan, Lewis & Bockius LLP
82
Contact Information
Margaret M. Gatti, Esq.
215-963-5569
202-739-5409
mgatti@morganlewis.com
Louis K
K. Rothberg
Rothberg, Esq
Esq.
202-739-5281
lrothberg@morganlewis com
lrothberg@morganlewis.com
© Morgan, Lewis & Bockius LLP
83
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© Morgan, Lewis & Bockius LLP
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