- PTAB · Apr 19, 2022 · IPR2022-00035 · APJ Debra K Stephens · IPR · Institution
The Board instituted inter partes review of claim 1 on both § 103 grounds, finding a reasonable likelihood that Petitioner would show the claim unpatentable over each asserted combination.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“(Pet. 11). Generally, Patent Owner contends that the Petition should be denied (see Prelim. Resp.). Based on our review of the record, we conclude that Petitioner is reasonably likely to prevail in demonstrating that at least one of the challenged claims is not patentable.” slip op. at 2
- Skill levelSkill level petitioner adoptedDecided for petitioner
“Petitioner asserts that a person of ordinary skill in the art (“POSITA”) in July 2003 would have had a working knowledge of the network communications art that is pertinent to the ’066 Patent, including network security. A POSITA would have had a bachelor’s degree in computer science, computer engineering, or an equivalent, and two years of professional experience relating to network communications. Lack of professional experience can be remedied by additional education, and vice versa (Pet. 9 (citing Ex. 1003 ¶¶ 17–19)). Patent Owner agrees with Petitioner’s assertion and further asserts a “higher level of education (e.g., a Master’s degree) may make up for less work experience, and additional work experience may make up for less education” (Prelim. Resp. 14 (citing Ex. 2001 ¶¶ 14–22)).” slip op. at 11
- Claim Construction › Intrinsic evidence (Phillips canons) › Plain and ordinary meaning to a POSITATerm construed board ownDecided for patent owner
“We disagree with Patent Owner’s construction. Patent Owner’s arguments ignore significant claim language of claim 1 that contradicts Patent Owner’s proposed construction, instead focusing on tying to equate broad, ordinary terms — “utilization” with “applying” and “across” with “to” (see id. at 16–21). In particular, Patent Owner ignores the portion of the limitation which recites “cause utilization of different occurrence mitigation actions of diverse occurrence mitigation types, including a firewall-based occurrence mitigation type and a other occurrence mitigation type, across the plurality of devices” (emphasis added). To aid in understanding the meaning of “a firewall-based occurrence mitigation type,” we turn to the disclosure of the ’066 Patent (see Ex. 1001). The ’066 Patent includes a detailed disclosure which contradicts Patent Owner’s argument that the limitation at issue excludes mitigation actions of a network defense system providing firewall functionality.” slip op. at 16
- Obviousness (§103) › Graham factors (scope of art, differences, level of skill)Instituted
“intrusion functionality 116 detects . . .an attempt from outside the network 14 to exploit [a] noted vulnerability (for example, a certain IP address is noted as being a source of traffic relating to the IIS buffer overflow vulnerability as detected by the code red signature)” (Ex. 1005, 14:59–64; see Pet. 37). Willebeek-LeMair further teaches, in step 312, “[t]his is reported back to the agent 126” which “responds in step 314 by reporting . . . that an attempt to exploit has occurred” (Ex. 1005 14:64–67; see Pet. 37). Willebeek-LeMair discloses the agent 126 additionally “instructs the firewalling functionality 118 in step 316 to drop the packet traffic relating to the attempted exploitation” and “in step 318 instruct[s] the firewall to block all traffic originating from the noted IP address of the attacker” (Ex. 1005 14:67–15:6, 1:7–10; see Pet. 37). Thus, because Willebeek-LeMair discloses a firewalling functionality, at this juncture, we determine Willebeek-LeMair teaches the recited “firewall-based occurrence mitigation type.” Additionally, because Willebeek-LeMair discloses instructing the firewall to block all traffic from the attacker (an occurrence mitigation action), based on the record before us, we determine Willebeek-LeMair teaches the recited “firewall-based occurrence mitigation type,” as recited in claim 1. and specifically, “a terminate action [ ] taken by the intrusion detector functionality 116 to terminate any session associated with a possible attack” (Ex. 1005, 12:40–43; see Pet. 38). Willebeek-LeMair also teaches the intrusion detector functionality generates alerts from its analysis of the network traffic content (Ex. 1005, 9:34–27, 1:7–10; see Pet. 38). Based on the record before us, we determine this intrusion detector functionality is an occurrence mitigation action that is different than the firewall-based occurrence mitigation type. Accordingly, based on the record before us, we determine Willebeek-LeMair teaches the recited “a other occurrence mitigation type,” as recited in claim 1. In combination of these two functionalities, we determine on the current record, Willebeek-LeMair teaches the recited “cause utilization of different occurrence mitigation actions of diverse occurrence mitigation types, including a firewall-base occurrence mitigation type and a other occurrence mitigation type” (see Pet. 38 (citing Ex. 1003 ¶ 97)).” slip op. at 26
Claim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 10,893,066 - PTAB · Dec 21, 2021 · IPR2021-01129 · APJ Trevor M Jefferson · IPR · Institution
The Board instituted IPR on claims 1, 3–7, 10, 17, 21, 22, 28, 33–39, and 43–45 based on a reasonable likelihood of success on the asserted obviousness grounds.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“unless the information presented in the petition “shows that there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” The following findings of fact and conclusions of law are not final, but are made for the sole purpose” slip op. at 2
- PTAB / AIA Trials › Discretionary denialNot reached
“Petitioners provide argument that the Board should not exercise its discretion under Sections 314(a) and 325(d) as addressed in Apple Inc. v. Fintiv, Inc., IPR2020-00019, Paper 11 at 3 (PTAB Mar. 20, 2020) (precedential) (“Fintiv”) (see Pet. 85–86) and General Plastic Indus. Co. v. Canon Kabushiki Kaisha, IPR2016-01357, Paper 19 (PTAB Sep. 6, 2017) (precedential as to Section II.B.4.i) (“General Plastic”). See Pet. 95–97; see also Patent Trial and Appeal Board Consolidated Trial Practice Guide 58 (Nov. 2019), https://www.uspto.gov/sites/default/files/documents/ tpgnov.pdf) (explaining that parties may wish to address the Board’s discretion to institute review in their papers). In addition, Petitioners filed a paper ranking the petitions filed challenging the ’837 patent and supporting the material differences among the petitions. Paper 2. Patent Owner did not file a preliminary response, and, accordingly, we do not reach or address Petitioners’ arguments on these issues.” slip op. at 9
- Skill levelSkill level petitioner adoptedDecided for petitioner
“Decision in IPR2019-01568, Google ’837 IPR at 8–9. See Pet 5 n.3;5 Ex. 1003 ¶¶ 37. Our prior decision in IPR2019-01568 found that A [person of ordinary skill in the art] has an accredited bachelor’s degree in computer science, electrical engineering, or a related discipline that included coverage of wireless communications and the use of communication protocols used for real-time communications, and also at least two years of industry experience. In lieu of specific academic training, a [person of ordinary skill in the art] may draw upon appropriate industry experience to meet the foregoing requirements. Google ’837 IPR at 8. We apply this level of skill in the present case.” slip op. at 10
- Prior constructionPrior construction adoptedDecided for petitioner
“Petitioners offer no proposed claim constructions and apply the constructions determined by the Board in the IPR2019-01568 Final Written Decision. Pet. 5. Petitioners assert that the remaining terms are given their “ordinary and customary meaning as understood by a Person of Ordinary Skill in the Art as of the Critical Date . . . and [at] prosecution history.” Id. at 5–6 (citing Ex. 1003 ¶¶ 73–74; 37 C.F.R. §42.100(b)). We adopt the claim constructions determinations in IPR2019-01568 provided in the table below.” slip op. at 10
Claim construction§ 103 obviousnessDiscretionary denialPatents in suitUS 7,894,837 - PTAB · Dec 21, 2021 · IPR2021-01126 · APJ Trevor M Jefferson · IPR · Institution
The Board instituted IPR on claims 22, 23, and 31–40 because Petitioners showed a reasonable likelihood of prevailing on the asserted § 103 obviousness grounds.
RulingsInstitution decision- PTAB / AIA Trials › Discretionary denialNot reached
“Petitioners provide argument that the Board should not exercise its discretion under Sections 314(a) and 325(d) as addressed in Apple Inc. v. Fintiv, Inc., IPR2020-00019, Paper 11 at 3 (PTAB Mar. 20, 2020) (precedential) (“Fintiv”) and General Plastic Indus. Co. v. Canon Kabushiki Kaisha, IPR2016-01357, Paper 19 (PTAB Sep. 6, 2017) (precedential as to Section II.B.4.i) (“General Plastic”). See Pet. 84–86; see also Patent Trial and Appeal Board Consolidated Trial Practice Guide 58 (Nov. 2019), https://www.uspto.gov/sites/default/files/documents/tpgnov.pdf) (explaining that parties may wish to address the Board’s discretion to institute review in their papers). In addition, Petitioners filed a paper ranking the petitions filed challenging the ’870 patent and supporting the material differences among the petitions. Paper 2. Patent Owner did not file a preliminary response, and, accordingly, we do not reach or address Petitioners’ arguments on these issues.” slip op. at 9
- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“III. CONCLUSION On this record, we are persuaded that Petitioners demonstrate a reasonable likelihood that they would prevail in showing the unpatentability of at least one of challenged claims 22, 23, and 31–40 of the ’870 patent. We, accordingly, institute an inter partes review of the challenged claims. Our determination in this Decision is not a final determination on either the patentability of any challenged claims or the construction of any claim term and, thus, leaves undecided any remaining fact issues necessary to determine whether sufficient evidence supports Petitioners’ contentions by a preponderance of the evidence in the final written decision. See TriVascular, Inc. v. Samuels, 812 F.3d 1056, 1068 (Fed. Cir. 2016) (noting that “there is a significant difference between a petitioner’s burden to establish a ‘reasonable likelihood of success’ at institution, and actually proving invalidity by a preponderance of the evidence at trial”) (quoting 35 U.S.C. § 314(a) and comparing id. § 316(e)).” slip op. at 19
- Skill levelSkill level petitioner adoptedDecided for petitioner
“Petitioners assert the level of skill adopted in the Final Written Decision in IPR2019-01567, Google IPR at 8. See Pet. 9 n.3; Ex. 1003 ¶¶ 37–38. Our prior decision in IPR2019-01567 found that [a person of ordinary skill in the art] has an accredited bachelor’s degree in computer science, electrical engineering, or a related discipline that included coverage of wireless communications and the use of communication protocols used for real-time communications, and also at least two years of industry experience. In lieu of specific academic training, a [person of ordinary skill in the art] may draw upon appropriate industry experience to meet the foregoing requirements. Google IPR at 8. We apply this level of skill in the present case.” slip op. at 10
- Prior constructionPrior construction adoptedDecided for petitioner
“Petitioners offer no proposed claim constructions and apply the constructions determined by the Board in the IPR2019-01567 Final Written Decision. Pet. 6–7. We adopt the claim constructions determinations in IPR2019-01567 provided in the table below. Claim Term IPR2019-01567 Construction “a data entry device of a handheld “a handheld terminal capable of terminal” (claim 20) data entry” “network connection” (claim 20) No construction required “graphical symbols” (claim 20)” slip op. at 10
Claim construction§ 103 obviousnessDiscretionary denialPatents in suitUS 7,292,870 - PTAB · Dec 21, 2021 · IPR2021-01125 · APJ Trevor M Jefferson · IPR · Institution
The Board instituted inter partes review of claims 2–4, 11–14, 22, 23, and 31–33 based on the asserted obviousness grounds.
RulingsInstitution decision- PTAB / AIA Trials › Discretionary denialNot reached
“discretion under Sections 314(a) and 325(d) as addressed in Apple Inc. v. Fintiv, Inc., IPR2020-00019, Paper 11 at 3 (PTAB Mar. 20, 2020) (precedential) (“Fintiv”) and General Plastic Indus. Co. v. Canon Kabushiki Kaisha, IPR2016-01357, Paper 19 (PTAB Sep. 6, 2017) (precedential as to Section II.B.4.i) (“General Plastic”). See Pet. 87–90; see also Patent Trial and Appeal Board Consolidated Trial Practice Guide 58 (Nov. 2019), https://www.uspto.gov/sites/default/files/documents/tpgnov.pdf) (explaining” slip op. at 9
- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“III. CONCLUSION On this record, we are persuaded that Petitioners demonstrate a reasonable likelihood that they would prevail in showing the unpatentability of at least one of challenged claims 2–4, 11–14, 22, 23, and 31–33 of the ’870 patent. We, accordingly, institute an inter partes review of the challenged claims.” slip op. at 24
- Skill levelSkill level petitioner adoptedDecided for petitioner
“Petitioners assert the level of skill adopted in the Final Written Decision in IPR2019-01567, Google IPR at 8. See Pet. 4 n.2; Ex. 1003 ¶¶ 37–38. Our prior decision in IPR2019-01567 found that [a person of ordinary skill in the art] has an accredited bachelor’s degree in computer science, electrical engineering, or a related discipline that included coverage of wireless communications and the use of communication protocols used for real-time communications, and also at least two years of industry experience. In lieu of specific academic training, a [person of ordinary skill in the art] may draw upon appropriate industry experience to meet the foregoing requirements. Google IPR at 8. We apply this level of skill in the present case.” slip op. at 10
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)Prior construction adoptedDecided for petitioner
“Petitioners offer no proposed claim constructions and apply the constructions determined by the Board in the IPR2019-01567 Final Written Decision. Pet. 3–4. Petitioners argue that the remaining terms are given their “ordinary and customary meaning as understood by a Person of Ordinary Skill in the Art as of the Critical Date . . . and the patent’s prosecution history.” Id. at 4 (citing Ex. 1003 ¶ 69; 37 C.F.R. §42.100(b)). We adopt the claim constructions determinations in IPR2019-01567 provided in the table below. Claim Term IPR2019-01567 Construction “a data entry device of a handheld “a handheld terminal capable of terminal” (claim 20) data entry” “network connection” (claim 20) No construction required “graphical symbols” (claim 20)” slip op. at 10
Claim construction§ 103 obviousnessDiscretionary denialPatents in suitUS 7,292,870 - PTAB · Dec 21, 2021 · IPR2021-01124 · APJ Trevor M Jefferson · IPR · Institution
The Board instituted IPR on claims 1, 5–10, 17–19, and 36–40, finding a reasonable likelihood that the asserted combinations would render the challenged claims unpatentable.
RulingsInstitution decision- PTAB / AIA Trials › Discretionary denialNot reached
“Petitioners provide argument that the Board should not exercise its discretion under Sections 314(a) and 325(d) as addressed in Apple Inc. v. Fintiv, Inc., IPR2020-00019, Paper 11 at 3 (PTAB Mar. 20, 2020) (precedential) (“Fintiv”) (see Pet. 85–86) and General Plastic Indus. Co. v. Canon Kabushiki Kaisha, IPR2016-01357, Paper 19 (PTAB Sep. 6, 2017) (precedential as to Section II.B.4.i) (“General Plastic”). See Pet. 84–86; see also Patent Trial and Appeal Board Consolidated Trial Practice Guide 58 (Nov. 2019), https://www.uspto.gov/sites/default/files/documents/ tpgnov.pdf) (explaining that parties may wish to address the Board’s discretion to institute review in their papers). In addition, Petitioners filed a paper ranking the petitions filed challenging the ’870 patent and supporting the material differences among the petitions. Paper 2. Patent Owner did not file a preliminary response, and, accordingly, we do not reach or address Petitioners’ arguments on these issues.” slip op. at 9
- Skill levelSkill level petitioner adoptedDecided for petitioner
“Petitioners assert the level of skill adopted in the Final Written Decision in IPR2019-01567, Google IPR at 8. See Pet. 7 n.2; Ex. 1003 ¶¶ 37–38. Our prior decision in IPR2019-01567 found that [a person of ordinary skill in the art] has an accredited bachelor’s degree in computer science, electrical engineering, or a related discipline that included coverage of wireless communications and the use of communication protocols used for real-time communications, and also at least two years of industry experience. In lieu of specific academic training, a [person of ordinary skill in the art] may draw upon appropriate industry experience to meet the foregoing requirements. Google IPR at 8. We apply this level of skill in the present case.” slip op. at 9
- Prior constructionPrior construction adoptedDecided for petitioner
“We adopt the claim constructions determinations in IPR2019-01567 provided in the table below. Claim Term IPR2019-01567 Construction “a data entry device of a handheld “a handheld terminal capable of terminal” (claim 20) data entry” “network connection” (claim 20) No construction required “graphical symbols” (claim 20)” slip op. at 10
- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“III. CONCLUSION On this record, we are persuaded that Petitioners demonstrate a reasonable likelihood that they would prevail in showing the unpatentability of at least one of challenged claims 5–10, 17–19, and 36–40 of the ’870 patent. We, accordingly, institute an inter partes review of the challenged claims.” slip op. at 21
Claim construction§ 103 obviousnessDiscretionary denialPatents in suitUS 7,292,870 - Ecobee, Inc. v. Ecofactor, Inc.InstitutedPTAB · Oct 1, 2021 · IPR2021-00792 · APJ Scott B Howard · IPR · Institution
The Board instituted inter partes review of claims 1–20 based on Wedekind and Ehlers under §103, and granted Ecobee’s motion to join the Google IPR.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“determine whether to institute an inter partes review under 35 U.S.C. § 314 and 37 C.F.R. § 42.4(a). Inter partes review may not be instituted unless “the information presented in the petition filed under section 311 and any response filed under section 313 shows that there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition.” 35 U.S.C. § 314(a) (2018). “When instituting inter partes review, the Board will authorize the review to proceed on all of the challenged claims and on all grounds of unpatentability asserted for each claim.” PTAB Rules of Practice for Instituting on All Challenged Patent Claims and All Grounds and Eliminating the Presumption at Institution Favoring Petitioner as to Testimonial Evidence, 85 Fed. Reg. 79,120, 79,129 (Dec. 9, 2020), (to be codified at 37 C.F.R. 42.108(a)).” slip op. at 2
- PTAB / AIA Trials › Joinder §315(c) / SAS all-or-nothingJoinder, grantedGranted
“If the Director institutes an inter partes review, the Director, in his or her discretion, may join as a party to that inter partes review any person who properly files a petition under section 311 that the Director, after receiving a preliminary response under section 313 or the expiration of the time for filing such a response, determines warrants the institution of an inter partes review under section 314. A motion for joinder should (1) set forth reasons why joinder is” slip op. at 5
NonePatents in suitUS 8,498,753 - PTAB · Sep 27, 2021 · IPR2021-00701 · APJ Patrick M Boucher · IPR · Institution
The Board instituted IPR on claims 1, 3, 4, 6, and 10–18 on all petitioned grounds, finding a reasonable likelihood that at least one claim is unpatentable.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“Applying the standard set forth in 35 U.S.C. § 314(a), which requires demonstration of a reasonable likelihood that Petitioner would prevail with respect to at least one challenged claim, we grant the Petition and institute an inter partes review. The Board has not made a final determination regarding the patentability of any claim.” slip op. at 2
- Skill levelSkill level petitioner adoptedDecided for petitioner
“Petitioner proposes that a person of ordinary skill in the art would [have] possess[ed] at least a bachelor’s degree in computer science or electrical engineering and 3-5 years of professional experience in computer networks, or a master’s or doctorate and 1-2 years of professional experience in computer networks. Additional education could substitute for professional experience, and vice versa. Such a person would have been familiar with computer networks and would have been aware of design trends relating to authentication, authorization, and accounting (AAA). Pet. 15–16 (citing Ex. 1003 ¶ 13). At this stage, Patent Owner neither challenges Petitioner’s proposal nor proposes its own specific articulation of a level of ordinary skill in the art. Because we find Petitioner’s proposal reasonable, consistent with the level of skill reflected by the prior art, and supported by the testimony of Dr. Goldschlag, we adopt it for purposes of this Decision. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) (the prior art may reflect an appropriate level of skill in the art).” slip op. at 8
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“used to construe the claim in a civil action under 35 U.S.C. 282(b), including construing the claim in accordance with the ordinary and customary meaning of such claim as understood by one of ordinary skill in the art and the prosecution history pertaining to the patent.” 37 C.F.R. § 42.100(b) (2019); see Phillips v. AWH Corp., 415 F.3d 1303, 1312–13 (Fed. Cir. 2005) (en banc). Although Petitioner notes certain constructions that it has proposed in district court, both parties agree that no term requires construction to decide whether to institute an inter partes review in this proceeding. See Pet. 14 (Petitioner asserting that “[n]o term needs construction in this proceeding”); Prelim. Resp. 3 (“Patent Owner does not contend that any term requires construction for purposes of this Preliminary Response”). Because we also discern no term that requires construction to resolve the issues before us, we do not expressly construe any term for purposes of this Decision. See Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (“[W]e need only construe terms ‘that are in controversy, and only to the extent necessary to resolve the controversy.’” (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999))).” slip op. at 9
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundInstituted
“restricts access to its network for clients that do not conform with the required security policy.” Pet. 37. Specifically, upon determining nonconformance, Herrmann’s policy server 460 “may restrict a session to limited access (e.g., a set of IP addresses) rather than deny access completely.” Id. (citing Ex. 1005 ¶ 78). In addition, Herrmann also teaches the use of EAP during both authentication and authorization, including an express extension “to support policy-based authentication systems.” Id. at 40 (citing Ex. 1005 ¶¶ 56, 58; Ex. 1003 ¶¶ 92–93). Although Herrmann does not expressly describe implementing restricted access in the context of a network of VLANs, Petitioner reasons that such would have been obvious in light of Krantz’s teaching of VLANs, particularly because Krantz specifically assigns a subset of VLANs as an isolated “sandbox” area. Id. at 37–38. Specifically, Petitioner reasons that a person of ordinary skill in the art “would have been motivated to segregate Herrmann’s sandbox area using at least one separate VLAN to improve network security,” and supports that reasoning with testimony by Dr. Goldschlag. Id. at 22 (citing Ex. 1003 ¶ 53). Petitioner also provides evidence that VLANs would have been recognized at the time of invention as a well-known technique for segregating network portions having different security needs. Id. at 23 (citing Ex. 1003 ¶ 54 (testimony of Dr. Goldschlag); Ex. 1031, Abstr. (IEEE 802.1Q standard)). In addition, Dr. Goldschlag testifies that a person of ordinary skill in the art would have been motivated to implement Herrmann’s network using VLANs “for improved scalability and network management.” Ex. 1003 ¶ 55. Furthermore, Petitioner identifies language in Krantz to support its contention that Krantz itself motivates the combination by teaching that VLANs were a known alternative to IP filtering for restricting network access. Pet. 24 (citing Ex. 1006 ¶ 32; Ex. 1003 ¶ 56). Patent Owner does not dispute Petitioner’s reasons for combining Herrmann and Krantz, and, on the record before us, we find that reasoning supported by a rational underpinning. We accordingly find that Petitioner makes a sufficient showing at this stage with respect to the “restricting” limitation of independent claims 1 and 13.” slip op. at 19
Claim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 7,877,786
Holdings, summaries, rulings, issues, outcomes, winners and claim constructions shown for a decision were generated by a large language model reading the opinion. They are a guide to the decision, not the decision. Confirm every one against the court's own text before relying on it. Outcomes read from the patent owner’s side. Party names are extracted from the decision and are missing on about 900 short Director denials and scans, which carry the trial number instead.