1014-00005 · Optiwave Semiconductor Corp · Engagement & Administrative

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CALDERWOOD & HARKNESS LLP Attorneys at Law

555 California Street, 42nd Floor San Francisco, CA 94104

Intellectual Property Group

Telephone: (415) 555-7200 Facsimile: (415) 555-7201

September 15, 2023

Via Email and U.S. Mail

Marcus Whitfield, Esq. General Counsel Optiwave Semiconductor Corp. 4710 Ridgeview Parkway, Suite 300 Santa Clara, CA 95054

Re: Acknowledgment of Dormancy Status — Patent Prosecution Docket C&H Matter No. 1014-00005 Client: Optiwave Semiconductor Corp.

Dear Marcus:

1. Purpose of This Letter

This letter confirms the placement of the above-referenced patent prosecution matter into dormant status, effective as of the date hereof, following the budget-freeze directive imposed by Harborview Partners ("Veltrano") on August 11, 2023, as communicated to Calderwood & Harkness LLP ("C&H" or the "Firm") by Sandra Koh, Optiwave Semiconductor Corp.'s ("OWS") IP Manager and In-House Patent Counsel. Ms. Koh conveyed Veltrano's directive to us via telephone on August 14, 2023, and confirmed the same in writing by email dated August 15, 2023.

We understand that the budget-freeze directive is part of Veltrano's broader cost-reduction initiative internally designated as "Project Lighthouse," which, among other measures, imposes a cap on discretionary intellectual property spending with outside counsel at $25,000 per quarter across all outside counsel firms engaged by OWS. For context, OWS's average quarterly patent prosecution spend with C&H alone was approximately $87,400 over the four fiscal quarters preceding the freeze (Q3 2022 through Q2 2023), substantially exceeding the newly imposed quarterly cap. Given that the Project Lighthouse cap applies across all outside counsel — and not solely to C&H — it is apparent that meaningful prosecution activity on the docket discussed herein cannot be sustained within the budgetary parameters as currently defined.

C&H is writing to accomplish the following objectives: (i) formally acknowledge the dormancy status of this matter; (ii) comprehensively document the current status of all twelve applications comprising the patent prosecution docket; (iii) identify all upcoming statutory and regulatory deadlines — particularly those that, if missed, would result in irrevocable loss of patent rights; (iv) confirm the Firm's continuing obligations to OWS during the dormancy period, including our duties as attorneys of record before the United States Patent and Trademark Office ("USPTO"), the European Patent Office ("EPO"), and the Japan Patent Office ("JPO"); and (v) set forth our recommendations for next steps so that OWS can make fully informed decisions about how to proceed.

We recognize that budget constraints are a legitimate business consideration, and C&H respects OWS's prerogative to manage its expenditures in accordance with the directives of its board and its equity sponsors. However, because patent prosecution is governed by inflexible statutory deadlines — many of which cannot be extended and all of which carry the consequence of permanent loss of rights if missed — we believe it is essential that this letter be placed in the record to ensure that OWS, Veltrano, and all relevant stakeholders have a clear and complete picture of what is at stake.

2. Engagement Background

C&H's engagement for patent prosecution representation on behalf of OWS was formally opened on February 14, 2022, pursuant to an engagement letter executed on February 10, 2022 (countersigned by you, Marcus, in your capacity as General Counsel of OWS). The engagement was established following a competitive selection process in which C&H was retained to replace predecessor counsel, Kessler & Morin LLP, which had handled the initial provisional filing on behalf of OWS.

The scope of the engagement encompasses a family of twelve (12) related U.S. and international patent applications covering OWS's next-generation silicon-photonics modulator architecture. These applications are organized into three sub-families, as follows:

• Sub-Family A — Core Modulator Architecture (five applications): Directed to the fundamental waveguide geometry, doping profile, and optical modulation mechanisms underlying OWS's silicon-photonics modulator platform.

• Sub-Family B — Electrode Fabrication Process (four applications): Directed to the novel electrode deposition and patterning techniques developed by OWS's process engineering team, including the segmented traveling-wave electrode configuration.

• Sub-Family C — Packaging & Thermal Management (three applications): Directed to the proprietary packaging architecture and thermal dissipation solutions that enable OWS's modulator to operate at elevated data rates and extended temperature ranges.

All twelve applications in this family ultimately claim priority to U.S. Provisional Application No. 63/297,841, filed January 10, 2022, by predecessor counsel Kessler & Morin LLP. That provisional application expired on January 10, 2023, upon the expiration of the twelve-month provisional period; however, timely non-provisional and PCT filings were made prior to the expiration date, thereby preserving the priority chain for all applications in the family.

On June 1, 2023, the engagement scope was formally amended by letter agreement (countersigned by you, Marcus, on June 5, 2023) to expand coverage to the Sub-Family C applications, which had been under development by OWS's packaging engineering team and were not originally contemplated when the engagement was opened in February 2022.

For completeness, the C&H team assigned to this matter is as follows:

• Catherine Bloom, Partner — Responsible Partner

• Alan Ngo, Partner — Billing Partner

• Christy Bauer, Senior Associate — Lead Associate

• Peter Vassiliev, Associate — Working Associate

3. Last Activity and Current Prosecution Status

The last billable activity on this matter occurred on September 6, 2023, when Peter Vassiliev filed a two-month extension of time request for U.S. Application No. 17/672,204 (Sub-Family A, Application A1) with the USPTO. The extension fee of $640.00, calculated at the small entity rate applicable to OWS, was paid from the client's prepaid disbursement account. The filing of this extension was authorized by Sandra Koh via email on September 5, 2023, as a limited exception to the general budget freeze, in recognition of the critical nature of the A1 application to OWS's overall patent strategy.

Prior to the extension filing, on September 1, 2023, C&H filed the EPO Rule 161/162 response for European application C2 (EP 23 765 901.7) through Breitenfeld & Vogt Patentanwälte PartGmbB, C&H's designated foreign associate firm for European patent prosecution. That filing had been authorized and substantially completed prior to the imposition of the budget freeze and was within the pre-freeze budget allocation.

Additionally, an incomplete draft response to the non-final Office Action issued for A1 (U.S. Application No. 17/672,204) was in progress by Christy Bauer through August 2023. Ms. Bauer had devoted approximately 18.5 hours to the draft response, which included a preliminary analysis of the Examiner's prior art rejections, a proposed claim amendment strategy, and a partially drafted remarks section addressing the anticipation and obviousness rejections. This work was suspended prior to partner review when the budget freeze took effect. The draft remains preserved in C&H's document management system and can be resumed at any time upon authorization.

As of the date of this letter, all active prosecution work across the entire twelve-application docket has been paused. No substantive filings are pending or in preparation, and no additional work will be undertaken without prior written authorization and budget approval from OWS.

4. Current Docket Inventory and Status Summary

Set forth below is a comprehensive inventory of all twelve applications on the docket, organized by sub-family, with current status and relevant deadline information for each.

Sub-Family A — Core Modulator Architecture (5 Applications)

A1 — U.S. Application No. 17/672,204

Type: Non-Provisional Utility Application Filing Date: January 9, 2023 Office: United States Patent and Trademark Office (USPTO) Priority: U.S. Prov. App. No. 63/297,841 (January 10, 2022) Named Inventors: Dr. Raymond Chen; Dr. Anika Patel; James Whitmore Status: Non-Final Office Action received; response period in progress. A two-month extension of time was purchased on September 6, 2023, extending the initial three-month shortened statutory period. As of the date of this letter, four months of the maximum six-month statutory period remain from the extended date. The absolute final deadline for response is March 9, 2025. No further extensions of time will be available beyond that date under 37 C.F.R. § 1.136(a), as the six-month statutory period under 35 U.S.C. § 133 represents the maximum permissible response period. This is a hard, non-negotiable deadline.

A2 — U.S. Application No. 17/672,311

Type: Continuation Application (of A1) Filing Date: March 15, 2023 Office: USPTO Priority: Claims benefit of A1 and U.S. Prov. App. No. 63/297,841 Named Inventors: Dr. Raymond Chen; Dr. Anika Patel; James Whitmore Status: Awaiting First Office Action. Based on current USPTO pendency data for Technology Center 3600 / Art Unit 3621 (the art unit assigned to A1), the estimated First Office Action date is Q2 2025. No action is currently required.

A3 — U.S. Application No. 17/672,489

Type: Continuation-in-Part Application Filing Date: June 22, 2023 Office: USPTO Priority: Claims benefit of A1 and U.S. Prov. App. No. 63/297,841, with new matter added Named Inventors: Dr. Raymond Chen; Dr. Anika Patel; James Whitmore; Dr. Li Wei Status: Awaiting First Office Action. Estimated First Office Action date is Q3 2025, given the later filing date. No action is currently required.

A4 — PCT/US2023/010584

Type: PCT International Application Filing Date: January 9, 2023 Receiving Office: WIPO / USPTO (Receiving Office) Priority: U.S. Prov. App. No. 63/297,841 (January 10, 2022) Named Inventors: Dr. Raymond Chen; Dr. Anika Patel; James Whitmore Status: International phase complete. The International Search Report and Written Opinion (Chapter I) were issued on July 14, 2023. National phase entries have been completed for the European regional phase (see B3 below) and the Japanese national phase (see B4 below). The national phase entry deadline for any additional jurisdictions is July 9, 2025 (30 months from the January 10, 2022 priority date). Jurisdictions that OWS had previously indicated interest in — including the Republic of Korea (KIPO), the People's Republic of China (CNIPA), and Taiwan (TIPO) — would need to be entered by this date if OWS wishes to pursue patent protection in those markets. No action is currently required, but a decision regarding additional national phase entries should be made well in advance of the July 9, 2025 deadline, as preparation of national phase entry packages typically requires four to six weeks.

A5 — PCT/US2023/010612

Sub-Family B — Electrode Fabrication Process (4 Applications)

B1 — U.S. Application No. 17/814,057

Type: Non-Provisional Utility Application Filing Date: July 21, 2023 Office: USPTO Priority: U.S. Prov. App. No. 63/297,841 (January 10, 2022); also claims benefit of A1 Named Inventors: Dr. Anika Patel; Dr. Li Wei; Sergei Volkov Status: A Restriction Requirement was received from the USPTO Examiner. The original two-month shortened statutory period for response expires on October 21, 2024. Extensions of time are available under 37 C.F.R. § 1.136(a) in one-month increments up to a maximum of six months from the original response date (i.e., the absolute final deadline, assuming maximum extensions, would be approximately April 21, 2025). The Restriction Requirement requires OWS to elect one of the identified invention groups for initial examination; the non-elected groups may be pursued in divisional applications (see B2 below). A response to a Restriction Requirement is typically straightforward and requires limited attorney time, but the response must be filed timely to avoid abandonment.

B2 — U.S. Application No. 17/814,103 (Planned)

Type: Divisional Application (of B1) Filing Date: Not yet filed Office: USPTO Status: This application is a placeholder in the docket, designated for filing upon OWS's election and restriction in B1. The divisional will cover the non-elected invention group(s) from the B1 Restriction Requirement. No action is required until after the restriction response in B1 is filed and prosecution of B1 advances. Filing of B2 is not time-critical at this stage, provided that B1 remains pending (i.e., B2 can be filed at any point while B1 is co-pending).

B3 — European Patent Application No. EP 23 741 682.3

Type: European Regional Phase Entry (from A4 PCT) Entry Date: July 5, 2023 Office: European Patent Office (EPO) Foreign Associate: Breitenfeld & Vogt Patentanwälte PartGmbB (Munich, Germany) Status: Awaiting issuance of the Extended European Search Report ("EESR"). Based on current EPO pendency data, the EESR is estimated to issue in mid-to-late 2024. Upon issuance of the EESR, a six-month response period will commence under EPO Rules 70a, 161, and 162, during which OWS must file a response to any objections or observations raised in the search report. C&H and Breitenfeld & Vogt are monitoring the file for issuance of the EESR. No action is currently required.

B4 — Japanese Patent Application No. JP 2024-542197

Type: Japanese National Phase Entry (from A4 PCT) Entry Date: July 3, 2023 Office: Japan Patent Office (JPO) Foreign Associate: Nakashima & Togawa Patent Professional Corporation (Tokyo, Japan) Status: Awaiting request for examination. Under JPO practice, a request for examination must be filed within three years of the international filing date of the underlying PCT application. The examination request deadline for B4 is January 9, 2026 (three years from the January 9, 2023 PCT international filing date of A4). If the examination request is not filed by that date, the application will be deemed withdrawn. No action is immediately required, but this deadline must be calendared and tracked.

Sub-Family C — Packaging & Thermal Management (3 Applications)

C1 — U.S. Application No. 18/102,776 (Planned)

Type: Non-Provisional Utility Application Filing Date: Not yet filed as of the date of this letter Office: USPTO Named Inventors: Dr. Li Wei; Michael Ostrowski; Karen Tanaka Status: This application has been authorized for filing under the pre-freeze budget allocation and was in an advanced stage of preparation prior to the budget freeze. The application specification and claims have been drafted and reviewed by Dr. Wei and Ms. Koh but have not undergone final partner review. C&H anticipates filing this application under the existing pre-freeze authorization once final review is completed. Because the January 10, 2022 provisional priority date has already expired, this application will not claim priority to U.S. Provisional Application No. 63/297,841. Instead, it will rely on continuation-in-part priority through A1, and independent priority for new matter. The timing of filing should be discussed with OWS to confirm that the pre-freeze authorization remains in effect.

C2 — European Patent Application No. EP 23 765 901.7

Type: European Regional Phase Entry (from A5 PCT) Entry Date: July 8, 2023 Office: European Patent Office (EPO) Foreign Associate: Breitenfeld & Vogt Patentanwälte PartGmbB (Munich, Germany) Status: The Rule 161/162 response was filed on September 1, 2023, as noted above. The application is now awaiting issuance of the Extended European Search Report, which is estimated to issue in mid-2025 based on current EPO processing times. Upon issuance of the EESR, a six-month response window will apply. No further action is required at this time.

C3 — Japanese Patent Application No. JP 2024-542305

Type: Japanese National Phase Entry (from A5 PCT) Entry Date: July 8, 2023 Office: Japan Patent Office (JPO) Foreign Associate: Nakashima & Togawa Patent Professional Corporation (Tokyo, Japan) Status: Awaiting request for examination. The examination request deadline for C3 is January 9, 2026 (three years from the January 9, 2023 PCT international filing date of A5). The same considerations discussed above with respect to B4 apply. No action is immediately required.

The following summary table consolidates the key deadline information across all twelve applications:

5. Critical Deadlines and Consequences of Inaction

We wish to emphasize — in the strongest possible terms consistent with our professional obligations — that patent prosecution is governed by strict statutory and regulatory deadlines that, if missed, result in irrevocable loss of patent rights. In many jurisdictions and under many circumstances, there is no possibility of revival once a deadline has passed. Unlike certain other legal proceedings where extensions, stays, and continuances may be obtained on a relatively routine basis, patent prosecution deadlines are typically absolute. We set forth below our assessment of the critical deadlines in order of urgency.

5.1 Highest Priority — A1 (U.S. Application No. 17/672,204) — March 9, 2025

Application A1 is the foundational U.S. application in the entire portfolio family. It is the parent application from which A2 (continuation), A3 (continuation-in-part), and indirectly B1, B2, and C1 claim priority or benefit. While the pendency of the daughter applications is not directly contingent on A1 remaining pending (because benefit claims are fixed at filing), the claims being pursued in A1 are unique and cannot be replicated in the other applications without significant restructuring of the prosecution strategy — if they can be replicated at all.

The non-final Office Action response for A1 is due on an absolute basis by March 9, 2025. As of the date of this letter, a two-month extension of time has been purchased, and the remaining four months of the maximum six-month statutory period prescribed by 35 U.S.C. § 133 will run from the extended deadline. No further extensions of time are permitted under 37 C.F.R. § 1.136(a) beyond the six-month maximum. This is a hard statutory bar.

Failure to respond by March 9, 2025, will result in the abandonment of Application A1. While a petition to revive the application for unintentional delay may theoretically be available under 37 C.F.R. § 1.137, we caution that such petitions are granted at the discretion of the USPTO and carry no guarantee of success. The standard for revival requires the applicant to state that the entire delay in responding was "unintentional." Where, as here, the delay would be the direct result of a deliberate budget decision communicated in writing and documented in this very letter, the USPTO may take the position that the delay was not "unintentional" within the meaning of the rule. We strongly recommend that OWS not rely on the availability of revival as a fallback strategy.

The substantive significance of A1 cannot be overstated. The draft Office Action response currently in progress contains proposed claim amendments specifically directed to the tapered impedance-matching feature of OWS's modulator design. This feature is central to OWS's design-around strategy with respect to two issued patents held by Pinnacle Optics, Inc. — U.S. Patent Nos. 10,823,417 (the "'417 Patent") and 11,105,662 (the "'662 Patent"). As you will recall, C&H's Freedom-to-Operate Analysis, delivered on October 14, 2022 (C&H Work Product Reference No. FTO-2022-04187-001), concluded that OWS's commercial silicon-photonics modulator products face "moderate-to-high" infringement risk with respect to the Pinnacle '417 Patent absent the design-around features that the pending claims in A1 are specifically intended to protect. The loss of A1 would eliminate OWS's ability to obtain issued patent claims covering this design-around approach, leaving OWS commercially exposed to infringement assertions by Pinnacle without the benefit of a defensive patent position.

We estimate the cost to complete and file the A1 Office Action response as follows:

• Attorney time: 40–55 hours (including completion of the draft response by Ms. Bauer, partner review by Ms. Bloom, and filing by Mr. Vassiliev), at the blended billing rates applicable to the OWS engagement — approximately $22,000–$30,000.

• USPTO fees: $0 if the response is filed as a straightforward response to the non-final Office Action; up to $2,000 (small entity rate) if a Request for Continued Examination ("RCE") becomes necessary based on the claim amendment strategy. An RCE may be advisable depending on the scope of amendments required to overcome the prior art cited by the Examiner.

• Total estimated cost: $22,000–$32,000.

5.2 Near-Term Deadlines — B1 and B3

B1 (U.S. Application No. 17/814,057) — Restriction Requirement Response. The original two-month shortened statutory period for responding to the Restriction Requirement expires on October 21, 2024. Extensions of time are available in one-month increments under 37 C.F.R. § 1.136(a), up to a maximum of six months from the original mailing date of the Restriction Requirement. If OWS does not authorize a response and no extensions are purchased, the application will go abandoned after the initial two-month period expires. We estimate the cost of responding to the Restriction Requirement as follows:

• Attorney time: 8–12 hours — approximately $4,500–$6,750.

• USPTO fees for response: $0 (no fee is assessed for an election in response to a Restriction Requirement).

• USPTO extension fees: $640 per month of extension at the small entity rate (if extensions are needed to defer the response).

B3 (European Patent Application No. EP 23 741 682.3) — Extended European Search Report Response. The EESR has not yet been issued but is estimated to issue in mid-to-late 2024. Upon issuance, a six-month response period will commence under EPO Rules 70a, 161, and 162. We estimate the cost of responding to the EESR as follows:

• C&H attorney fees: Approximately $11,250–$16,875 (depending on the complexity of the search report and the number of prior art references cited).

• Foreign associate fees (Breitenfeld & Vogt): Approximately €3,500–€5,000.

• EPO official fees: Variable, depending on whether claim amendments trigger additional claims fees.

5.3 Medium-Term Deadlines — A4 and A5 PCT National Phase Entry

The national phase entry deadline for both A4 (PCT/US2023/010584) and A5 (PCT/US2023/010612) is July 9, 2025 — thirty months from the January 10, 2022 priority date. As noted above, European and Japanese national phase entries have already been completed for both PCT applications. However, OWS had previously expressed interest in pursuing patent protection in additional jurisdictions, including the Republic of Korea, the People's Republic of China, and Taiwan. Missing the July 9, 2025 deadline permanently and irrevocably forecloses the ability to obtain patent protection in any unselected jurisdiction. There is no mechanism for late national phase entry once the 30-month deadline has passed.

The cost of entering each additional national phase jurisdiction varies but typically ranges from $3,000 to $8,000 per jurisdiction (inclusive of foreign associate fees, government filing fees, and translation costs). If OWS wishes to enter Korea, China, and Taiwan for both A4 and A5, the total estimated cost would be approximately $36,000–$96,000 for all six filings. A decision on additional national phase entries should be communicated to C&H no later than May 2025 to allow sufficient time for preparation and coordination with foreign associate firms.

5.4 Longer-Term Deadlines — B4 and C3 JPO Examination Requests

Japanese patent applications B4 (JP 2024-542197) and C3 (JP 2024-542305) both face an examination request deadline of January 9, 2026 — three years from the January 9, 2023 PCT international filing date. Under Japanese Patent Act Article 48-3, an application for which an examination request has not been filed within the prescribed period is deemed to have been withdrawn, and the JPO does not provide a revival mechanism for missed examination request deadlines. The examination request fee at the JPO is currently ¥138,000 (approximately $930) plus ¥4,000 per claim (approximately $27 per claim) for each application, plus Nakashima & Togawa's professional fees for filing.

While this deadline is the furthest out on the current docket, we include it here for completeness and to ensure that it remains on OWS's radar throughout the dormancy period.

6. Actions Taken by C&H to Preserve the Docket

In connection with the transition of this matter to dormant status, C&H has taken the following affirmative steps to preserve the integrity of the docket and minimize the risk of inadvertent deadline failures:

a. C&H has instructed Trident intellectual Property Services, LLC ("Trident"), our outsourced docketing and deadline management vendor (Lisa Cheng, Account Manager), to hold all non-critical filings across the OWS docket but to continue monitoring all statutory and regulatory deadlines without interruption. Trident has been directed to alert C&H of any approaching deadlines with a minimum of 120 days' advance notice for U.S. deadlines and 180 days' advance notice for foreign deadlines. Our letter of instruction to Trident is dated September 12, 2023, and a copy is maintained in the matter file.

b. C&H has instructed Nakashima & Togawa Patent Professional Corporation (Kenji Nakashima, Lead Attorney), our designated foreign associate firm for Japanese patent prosecution, to hold the examination request filings for JP 2024-542197 (B4) and JP 2024-542305 (C3) pending resolution of the budget freeze and further instructions from C&H. Our letter of instruction to Nakashima & Togawa is dated September 20, 2023. Nakashima & Togawa has confirmed receipt and acknowledged the hold instruction.

c. C&H's internal prosecution team has set calendar reminders for all statutory deadlines across the twelve-application docket, using both the Firm's enterprise docketing system (IPFolio) and individual attorney calendars as redundant safeguards. An internal monitoring protocol has been established to ensure that no deadline passes without advance written notice to OWS. Under this protocol, C&H will issue written deadline reminder notices to OWS at 120 days, 90 days, 60 days, and 30 days prior to each critical deadline.

d. C&H has preserved all work-in-progress files, including the incomplete draft Office Action response for A1 (approximately 18.5 hours of work product by Ms. Bauer), all prior art search results, all inventor declarations and supporting documentation, and all correspondence with foreign associate firms. These materials are maintained in C&H's secure document management system and can be accessed and resumed immediately upon reactivation of the matter.

7. C&H's Continuing Obligations During the Dormancy Period

Notwithstanding the dormant status of this matter, C&H will continue to fulfill certain ongoing professional obligations with respect to the OWS patent prosecution docket. We wish to be explicit about the scope and nature of these obligations so that there is no ambiguity during the dormancy period.

Deadline Monitoring and Notification. C&H will continue to monitor all prosecution deadlines across the twelve-application docket and will provide timely written notification to OWS of each approaching deadline with sufficient advance notice for OWS to evaluate its options and authorize action if it elects to do so. As noted above, C&H's standard notification protocol calls for written reminders at 120, 90, 60, and 30 days prior to each critical deadline.

Professional Responsibility Obligations. C&H considers this continuing monitoring obligation to be required by the California Rules of Professional Conduct, specifically Rule 1.3 (Diligence), which requires a lawyer to act with reasonable diligence in representing a client, and Rule 1.4 (Communication), which requires a lawyer to keep the client reasonably informed about significant developments in the matter. Additionally, as attorneys of record before the USPTO, C&H's attorneys are subject to the USPTO Rules of Professional Conduct at 37 C.F.R. §§ 11.103 and 11.104, which impose parallel obligations of diligence and communication with respect to patent prosecution matters pending before the Office.

Counsel of Record Status. C&H remains counsel of record before the USPTO on all pending U.S. applications (A1, A2, A3, B1, and, upon filing, C1). C&H also remains the instructing firm for European applications prosecuted through Breitenfeld & Vogt Patentanwälte PartGmbB (B3 and C2) and for Japanese applications prosecuted through Nakashima & Togawa Patent Professional Corporation (B4 and C3). In this capacity, C&H will continue to receive and review all official communications from these patent offices — including Office Actions, search reports, restriction requirements, formality notices, and other official correspondence — and will promptly relay each such communication to OWS with an explanation of its significance and any required response deadlines.

Limitation on Substantive Work. C&H will not undertake substantive prosecution work during the dormancy period without prior written authorization and budget approval from OWS. For avoidance of doubt, "substantive prosecution work" includes, but is not limited to: drafting or filing Office Action responses; drafting or filing claim amendments; filing continuation, divisional, or continuation-in-part applications; entering new national or regional phases; filing requests for examination; filing requests for continued examination; conducting prior art searches or patentability analyses; and preparing or filing any other document requiring the exercise of substantive patent prosecution judgment. The Firm's continuing deadline-monitoring and notification activities, as described above, are excluded from this limitation and will continue without specific authorization.

8. Outstanding Financial Matters

As of the date of this letter, C&H's outstanding accounts receivable on this matter total $56,958.50, consisting of the following:

The unbilled work-in-progress amount of $34,218.50 consists primarily of Ms. Bauer's time on the draft A1 Office Action response (18.5 hours), Mr. Vassiliev's time on the September 6, 2023 extension filing and related docket management, and Ms. Bloom's supervisory time on the C2 EPO filing. A detailed time entry report will be provided with the forthcoming September invoice.

C&H respectfully requests that OWS arrange for payment of the two outstanding invoices (No. 2023-07-04187 and No. 2023-08-04187, totaling $22,740.00) at its earliest convenience. The payment terms set forth in the February 10, 2022 engagement letter provide for payment within thirty (30) days of invoice date. Both invoices are currently past due.

We wish to be clear that the Firm's continuing deadline-monitoring obligations described in Section 7 above are not contingent upon, and will not be suspended pending, resolution of the outstanding balance. C&H's professional obligations to OWS will be honored regardless of the status of accounts receivable. However, C&H expressly reserves all rights with respect to the unpaid amounts, including the right to pursue collection in accordance with the terms of the engagement letter and applicable law.

9. Lender and Collateral Considerations

C&H notes for the record — and brings to OWS's attention for further evaluation — the following considerations related to OWS's credit arrangements:

OWS's $55,000,000 senior secured Revolving Credit Facility with Meridian National Bank, N.A. (the "Credit Facility"), dated September 30, 2020, as amended and restated on March 15, 2022, contains intellectual property covenants at Section 5.15 thereof. As C&H understands the relevant provision (based on the copy of the Credit Agreement provided to C&H by Ms. Koh on February 28, 2022 for purposes of the engagement), Section 5.15 requires OWS to:

"maintain, preserve, and protect all Material intellectual Property, including by timely prosecuting all pending patent applications and paying all required maintenance fees."

Additionally, the Security Agreement executed in connection with the Credit Facility grants Meridian National Bank a first-priority perfected security interest in all "Intellectual Property Collateral," which is defined to include, among other things:

"all patents, patent applications, and patent rights, whether now existing or hereafter acquired, together with all proceeds thereof."

The implications of these provisions are potentially significant. If the continued dormancy of prosecution activity — or the potential abandonment of any pending applications — were deemed to constitute a failure by OWS to "maintain, preserve, and protect" its Material intellectual Property or to "timely prosecute" its pending patent applications, such failure could constitute a breach of the Section 5.15 covenant and potentially trigger a default or event of default under the Credit Facility. A default under the Credit Facility could, in turn, result in acceleration of outstanding obligations, imposition of a default interest rate, restriction of borrowing availability, or other adverse consequences.

C&H strongly recommends that OWS's General Counsel — in consultation with OWS's credit counsel, if different from C&H — evaluate whether the dormancy of prosecution activity, particularly with respect to applications that are subject to near-term statutory deadlines (most critically A1), could give rise to a covenant compliance issue under the Credit Facility. C&H is available to provide further analysis on this question if OWS requests and authorizes such work, subject to the scope of the existing engagement or a supplemental engagement as appropriate.

10. Graystone Valuation Considerations

We also bring to OWS's attention the potential implications of the dormancy for the valuation of OWS's patent portfolio. As you are aware, Graystone Valuation Advisors, LLC conducted a comprehensive patent portfolio valuation at the request of Veltrano Capital Partners, with the final report issued on April 28, 2023 (the "Graystone Report"). The Graystone Report, prepared under the direction of Rebecca Thornton (Lead Engagement Partner), estimated the fair market value of OWS's entire patent portfolio — encompassing both issued patents and pending applications — at $38.5 million. Of that total, approximately $12.2 million was attributed to the pending twelve-application family that is the subject of the prosecution docket addressed in this letter.

The $12.2 million valuation attributed to the pending application family reflects a number of assumptions, including the assumption that prosecution of all twelve applications would continue in the ordinary course and that OWS would ultimately obtain issued patents with commercially meaningful claim scope. Abandonment of one or more applications — particularly the foundational A1 application and its associated continuation family — would directly reduce the assessed portfolio value and would likely require a restatement of the Graystone Report's conclusions.

A reduction in portfolio value may have cascading implications for Veltrano's investment thesis regarding its equity position in OWS, for any future refinancing of OWS's debt facilities (including the Meridian Credit Facility discussed above), and for any future exit strategy contemplated by Veltrano — whether through a trade sale, secondary buyout, or initial public offering. While these considerations are ultimately business decisions for OWS and Veltrano, we raise them here to ensure that the full scope of consequences flowing from the dormancy and potential abandonment of prosecution activity is visible to all decision-makers.

11. Recommended Next Steps

In light of the foregoing, C&H respectfully recommends that OWS take the following actions:

a. Designate a Point of Contact for Deadline Notifications. OWS should designate a specific individual — we suggest Sandra Koh, given her familiarity with the docket and her role as IP Manager and In-House Patent Counsel — as the primary point of contact for receiving deadline notifications and providing instructions to C&H during the dormancy period. Having a single designated contact will ensure efficient and reliable communication as deadlines approach.

b. Evaluate the Project Lighthouse Budget Cap in Light of Critical Deadlines. OWS should evaluate the $25,000 per quarter budget cap imposed by the Project Lighthouse initiative in light of the critical deadlines identified in this letter — most importantly, the absolute March 9, 2025 deadline for the A1 Office Action response. OWS should communicate to C&H well in advance of that date — we recommend no later than December 2024 — whether budget authorization will be provided for C&H to complete and file the A1 response. Given the estimated cost of $22,000–$32,000 for the A1 response alone, a one-time exception to the Project Lighthouse cap may be necessary, and we understand that such exceptions require approval at the Veltrano operating partner level.

c. Conduct a Cost-Benefit Analysis of Reactivation Versus Value at Risk. C&H recommends that OWS consult with its Chief Financial Officer, Daniel Everhart, and with Veltrano Capital's Operating Partner, Christine Paulsen, regarding the relative cost of reactivating prosecution activity on the docket versus the value at risk. As noted above, the pending application portfolio has been valued at $12.2 million, and the loss of A1 in particular would expose OWS to significant infringement risk vis-à-vis Pinnacle Optics. The cost of completing prosecution across the entire docket — while not insignificant — represents a small fraction of the portfolio value at stake.

d. Assess Strategic Abandonment Options, If Appropriate. If, after conducting the cost-benefit analysis described above, OWS determines that the budget constraints are such that certain applications must be strategically abandoned rather than prosecuted to completion, C&H recommends that any such decisions be made on the basis of a formal abandonment impact assessment. Such an assessment would evaluate the commercial, competitive, and lender-covenant consequences of each potential abandonment decision and would prioritize the retention of applications that are most critical to OWS's competitive position and IP portfolio value. C&H is prepared to conduct such an assessment upon authorization by OWS.

e. Authorize a Docket Triage and Budget Reactivation Proposal. Finally, C&H is prepared to undertake a comprehensive docket triage exercise and to prepare a detailed budget reactivation proposal for OWS's consideration. Such a proposal would identify the minimum necessary prosecution activities and associated costs for each application, prioritize activities based on deadline urgency and strategic importance, and present options for phased reactivation that could potentially be structured to fit within — or at least minimize departures from — the Project Lighthouse budget parameters. We estimate that preparation of such a proposal would require approximately 15–20 attorney hours.

12. Disclaimer and Privileged Nature of This Communication

This letter is a privileged and confidential attorney-client communication, protected by the attorney-client privilege and the work product doctrine. It is intended solely for the use of OWS and its authorized officers and employees. This letter does not constitute a legal opinion on any of the matters discussed herein, including without limitation the enforceability or interpretation of the Meridian Credit Facility covenants, the likelihood of success of any petition to revive an abandoned application, or the infringement risk posed by the Pinnacle Optics patents. This letter is provided for informational and record-keeping purposes, and to document C&H's compliance with its professional obligations of communication and diligence.

C&H's observations regarding the Meridian National Bank Credit Facility covenants at Section 5.15, as set forth in Section 9 above, are limited to flagging the issue for OWS's attention and do not constitute a comprehensive analysis of OWS's covenant compliance obligations. Any formal analysis of the Credit Agreement, the Security Agreement, or OWS's obligations thereunder would require a separate engagement or specific written authorization expanding the scope of the current engagement. C&H's current engagement is limited to patent prosecution and related intellectual property matters as set forth in the February 10, 2022 engagement letter, as amended.

Marcus, we would appreciate your acknowledgment of receipt of this letter at your earliest convenience. Please also confirm OWS's preferred point of contact for ongoing deadline notifications during the dormancy period so that we may direct future communications accordingly.

We recognize that the current budgetary environment presents difficult choices, and we remain committed to supporting OWS through this period. C&H is prepared to discuss any of the foregoing matters at your convenience — whether by telephone, videoconference, or in person. Please do not hesitate to reach out to me directly or to any member of the C&H team.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

Catherine Bloom Partner, intellectual Property Group USPTO Reg. No. 58,412 555 California Street, 42nd Floor San Francisco, CA 94104 Direct: (415) 555-7218

Email: cbloom@calderwoodharkness.com

cc: Sandra Koh, IP Manager / In-House Patent Counsel, Optiwave Semiconductor Corp. Alan Ngo, Billing Partner, Calderwood & Harkness LLP Christy Bauer, Lead Associate, Calderwood & Harkness LLP Peter Vassiliev, Working Associate, Calderwood & Harkness LLP

Enclosure: Master Docket Summary — OWS Patent Prosecution Docket (12 applications with current status and upcoming deadlines)

App.	Jurisdiction	App. Number	Status	Next Critical Deadline	Consequence of Miss
A1	U.S. (USPTO)	17/672,204	OA response due	Mar. 9, 2025 (absolute)	Abandonment
A2	U.S. (USPTO)	17/672,311	Awaiting 1st OA	Est. Q2 2025	N/A (monitoring)
A3	U.S. (USPTO)	17/672,489	Awaiting 1st OA	Est. Q3 2025	N/A (monitoring)
A4	PCT (WIPO)	PCT/US2023/010584	Nat'l phase open	Jul. 9, 2025	Loss of add'l jurisdictions
A5	PCT (WIPO)	PCT/US2023/010612	Nat'l phase open	Jul. 9, 2025	Loss of add'l jurisdictions
B1	U.S. (USPTO)	17/814,057	Restriction req'd	Oct. 21, 2024 (+ext.)	Abandonment
B2	U.S. (USPTO)	17/814,103	Not yet filed	Co-pendency w/ B1	N/A (dependent on B1)
B3	EP (EPO)	EP 23 741 682.3	Awaiting EESR	Est. mid-late 2024 (+6 mo.)	Loss of EP rights
B4	JP (JPO)	JP 2024-542197	Awaiting exam req.	Jan. 9, 2026	Deemed withdrawal
C1	U.S. (USPTO)	18/102,776	Not yet filed	Pre-freeze auth.	See discussion above
C2	EP (EPO)	EP 23 765 901.7	Awaiting EESR	Est. mid-2025 (+6 mo.)	Loss of EP rights
C3	JP (JPO)	JP 2024-542305	Awaiting exam req.	Jan. 9, 2026	Deemed withdrawal
Category	Amount
Unbilled work-in-progress (through Sep. 6, 2023)	$34,218.50
Unpaid Invoice No. 2023-07-04187 (July 2023)	$12,360.00
Unpaid Invoice No. 2023-08-04187 (August 2023)	$10,380.00
Total Outstanding	$56,958.50

CALDERWOOD & HARKNESS LLP Attorneys at Law
555 California Street, 42nd Floor San Francisco, CA 94104
Intellectual Property Group
Telephone: (415) 555-7200 Facsimile: (415) 555-7201
September 15, 2023
Via Email and U.S. Mail
Marcus Whitfield, Esq. General Counsel Optiwave Semiconductor Corp. 4710 Ridgeview Parkway, Suite 300 Santa Clara, CA 95054
Re: Acknowledgment of Dormancy Status — Patent Prosecution Docket C&H Matter No. 1014-00005 Client: Optiwave Semiconductor Corp.
Dear Marcus:
1. Purpose of This Letter
This letter confirms the placement of the above-referenced patent prosecution matter into dormant status, effective as of the date hereof, following the budget-freeze directive imposed by Harborview Partners ("Veltrano") on August 11, 2023, as communicated to Calderwood & Harkness LLP ("C&H" or the "Firm") by Sandra Koh, Optiwave Semiconductor Corp.'s ("OWS") IP Manager and In-House Patent Counsel. Ms. Koh conveyed Veltrano's directive to us via telephone on August 14, 2023, and confirmed the same in writing by email dated August 15, 2023.
We understand that the budget-freeze directive is part of Veltrano's broader cost-reduction initiative internally designated as "Project Lighthouse," which, among other measures, imposes a cap on discretionary intellectual property spending with outside counsel at $25,000 per quarter across all outside counsel firms engaged by OWS. For context, OWS's average quarterly patent prosecution spend with C&H alone was approximately $87,400 over the four fiscal quarters preceding the freeze (Q3 2022 through Q2 2023), substantially exceeding the newly imposed quarterly cap. Given that the Project Lighthouse cap applies across all outside counsel — and not solely to C&H — it is apparent that meaningful prosecution activity on the docket discussed herein cannot be sustained within the budgetary parameters as currently defined.
C&H is writing to accomplish the following objectives: (i) formally acknowledge the dormancy status of this matter; (ii) comprehensively document the current status of all twelve applications comprising the patent prosecution docket; (iii) identify all upcoming statutory and regulatory deadlines — particularly those that, if missed, would result in irrevocable loss of patent rights; (iv) confirm the Firm's continuing obligations to OWS during the dormancy period, including our duties as attorneys of record before the United States Patent and Trademark Office ("USPTO"), the European Patent Office ("EPO"), and the Japan Patent Office ("JPO"); and (v) set forth our recommendations for next steps so that OWS can make fully informed decisions about how to proceed.
We recognize that budget constraints are a legitimate business consideration, and C&H respects OWS's prerogative to manage its expenditures in accordance with the directives of its board and its equity sponsors. However, because patent prosecution is governed by inflexible statutory deadlines — many of which cannot be extended and all of which carry the consequence of permanent loss of rights if missed — we believe it is essential that this letter be placed in the record to ensure that OWS, Veltrano, and all relevant stakeholders have a clear and complete picture of what is at stake.
2. Engagement Background
C&H's engagement for patent prosecution representation on behalf of OWS was formally opened on February 14, 2022, pursuant to an engagement letter executed on February 10, 2022 (countersigned by you, Marcus, in your capacity as General Counsel of OWS). The engagement was established following a competitive selection process in which C&H was retained to replace predecessor counsel, Kessler & Morin LLP, which had handled the initial provisional filing on behalf of OWS.
The scope of the engagement encompasses a family of twelve (12) related U.S. and international patent applications covering OWS's next-generation silicon-photonics modulator architecture. These applications are organized into three sub-families, as follows:
• Sub-Family A — Core Modulator Architecture (five applications): Directed to the fundamental waveguide geometry, doping profile, and optical modulation mechanisms underlying OWS's silicon-photonics modulator platform.
• Sub-Family B — Electrode Fabrication Process (four applications): Directed to the novel electrode deposition and patterning techniques developed by OWS's process engineering team, including the segmented traveling-wave electrode configuration.
• Sub-Family C — Packaging & Thermal Management (three applications): Directed to the proprietary packaging architecture and thermal dissipation solutions that enable OWS's modulator to operate at elevated data rates and extended temperature ranges.
All twelve applications in this family ultimately claim priority to U.S. Provisional Application No. 63/297,841, filed January 10, 2022, by predecessor counsel Kessler & Morin LLP. That provisional application expired on January 10, 2023, upon the expiration of the twelve-month provisional period; however, timely non-provisional and PCT filings were made prior to the expiration date, thereby preserving the priority chain for all applications in the family.
On June 1, 2023, the engagement scope was formally amended by letter agreement (countersigned by you, Marcus, on June 5, 2023) to expand coverage to the Sub-Family C applications, which had been under development by OWS's packaging engineering team and were not originally contemplated when the engagement was opened in February 2022.
For completeness, the C&H team assigned to this matter is as follows:
• Catherine Bloom, Partner — Responsible Partner
• Alan Ngo, Partner — Billing Partner
• Christy Bauer, Senior Associate — Lead Associate
• Peter Vassiliev, Associate — Working Associate
3. Last Activity and Current Prosecution Status
The last billable activity on this matter occurred on September 6, 2023, when Peter Vassiliev filed a two-month extension of time request for U.S. Application No. 17/672,204 (Sub-Family A, Application A1) with the USPTO. The extension fee of $640.00, calculated at the small entity rate applicable to OWS, was paid from the client's prepaid disbursement account. The filing of this extension was authorized by Sandra Koh via email on September 5, 2023, as a limited exception to the general budget freeze, in recognition of the critical nature of the A1 application to OWS's overall patent strategy.
Prior to the extension filing, on September 1, 2023, C&H filed the EPO Rule 161/162 response for European application C2 (EP 23 765 901.7) through Breitenfeld & Vogt Patentanwälte PartGmbB, C&H's designated foreign associate firm for European patent prosecution. That filing had been authorized and substantially completed prior to the imposition of the budget freeze and was within the pre-freeze budget allocation.
Additionally, an incomplete draft response to the non-final Office Action issued for A1 (U.S. Application No. 17/672,204) was in progress by Christy Bauer through August 2023. Ms. Bauer had devoted approximately 18.5 hours to the draft response, which included a preliminary analysis of the Examiner's prior art rejections, a proposed claim amendment strategy, and a partially drafted remarks section addressing the anticipation and obviousness rejections. This work was suspended prior to partner review when the budget freeze took effect. The draft remains preserved in C&H's document management system and can be resumed at any time upon authorization.
As of the date of this letter, all active prosecution work across the entire twelve-application docket has been paused. No substantive filings are pending or in preparation, and no additional work will be undertaken without prior written authorization and budget approval from OWS.
4. Current Docket Inventory and Status Summary
Set forth below is a comprehensive inventory of all twelve applications on the docket, organized by sub-family, with current status and relevant deadline information for each.
Sub-Family A — Core Modulator Architecture (5 Applications)
A1 — U.S. Application No. 17/672,204
Type: Non-Provisional Utility Application Filing Date: January 9, 2023 Office: United States Patent and Trademark Office (USPTO) Priority: U.S. Prov. App. No. 63/297,841 (January 10, 2022) Named Inventors: Dr. Raymond Chen; Dr. Anika Patel; James Whitmore Status: Non-Final Office Action received; response period in progress. A two-month extension of time was purchased on September 6, 2023, extending the initial three-month shortened statutory period. As of the date of this letter, four months of the maximum six-month statutory period remain from the extended date. The absolute final deadline for response is March 9, 2025. No further extensions of time will be available beyond that date under 37 C.F.R. § 1.136(a), as the six-month statutory period under 35 U.S.C. § 133 represents the maximum permissible response period. This is a hard, non-negotiable deadline.
A2 — U.S. Application No. 17/672,311
Type: Continuation Application (of A1) Filing Date: March 15, 2023 Office: USPTO Priority: Claims benefit of A1 and U.S. Prov. App. No. 63/297,841 Named Inventors: Dr. Raymond Chen; Dr. Anika Patel; James Whitmore Status: Awaiting First Office Action. Based on current USPTO pendency data for Technology Center 3600 / Art Unit 3621 (the art unit assigned to A1), the estimated First Office Action date is Q2 2025. No action is currently required.
A3 — U.S. Application No. 17/672,489
Type: Continuation-in-Part Application Filing Date: June 22, 2023 Office: USPTO Priority: Claims benefit of A1 and U.S. Prov. App. No. 63/297,841, with new matter added Named Inventors: Dr. Raymond Chen; Dr. Anika Patel; James Whitmore; Dr. Li Wei Status: Awaiting First Office Action. Estimated First Office Action date is Q3 2025, given the later filing date. No action is currently required.
A4 — PCT/US2023/010584
Type: PCT International Application Filing Date: January 9, 2023 Receiving Office: WIPO / USPTO (Receiving Office) Priority: U.S. Prov. App. No. 63/297,841 (January 10, 2022) Named Inventors: Dr. Raymond Chen; Dr. Anika Patel; James Whitmore Status: International phase complete. The International Search Report and Written Opinion (Chapter I) were issued on July 14, 2023. National phase entries have been completed for the European regional phase (see B3 below) and the Japanese national phase (see B4 below). The national phase entry deadline for any additional jurisdictions is July 9, 2025 (30 months from the January 10, 2022 priority date). Jurisdictions that OWS had previously indicated interest in — including the Republic of Korea (KIPO), the People's Republic of China (CNIPA), and Taiwan (TIPO) — would need to be entered by this date if OWS wishes to pursue patent protection in those markets. No action is currently required, but a decision regarding additional national phase entries should be made well in advance of the July 9, 2025 deadline, as preparation of national phase entry packages typically requires four to six weeks.
A5 — PCT/US2023/010612
Type: PCT International Application Filing Date: January 9, 2023 Receiving Office: WIPO / USPTO (Receiving Office) Priority: U.S. Prov. App. No. 63/297,841 (January 10, 2022) Named Inventors: Dr. Raymond Chen; Dr. Anika Patel; Dr. Li Wei Status: International phase complete. The International Search Report and Written Opinion (Chapter I) were issued on August 2, 2023. National phase entries have been completed for the European regional phase (see C2 below) and the Japanese national phase (see C3 below). The national phase entry deadline for any additional jurisdictions is July 9, 2025. The same considerations discussed above with respect to A4 apply equally to A5. No action is currently required.
Sub-Family B — Electrode Fabrication Process (4 Applications)
B1 — U.S. Application No. 17/814,057
Type: Non-Provisional Utility Application Filing Date: July 21, 2023 Office: USPTO Priority: U.S. Prov. App. No. 63/297,841 (January 10, 2022); also claims benefit of A1 Named Inventors: Dr. Anika Patel; Dr. Li Wei; Sergei Volkov Status: A Restriction Requirement was received from the USPTO Examiner. The original two-month shortened statutory period for response expires on October 21, 2024. Extensions of time are available under 37 C.F.R. § 1.136(a) in one-month increments up to a maximum of six months from the original response date (i.e., the absolute final deadline, assuming maximum extensions, would be approximately April 21, 2025). The Restriction Requirement requires OWS to elect one of the identified invention groups for initial examination; the non-elected groups may be pursued in divisional applications (see B2 below). A response to a Restriction Requirement is typically straightforward and requires limited attorney time, but the response must be filed timely to avoid abandonment.
B2 — U.S. Application No. 17/814,103 (Planned)
Type: Divisional Application (of B1) Filing Date: Not yet filed Office: USPTO Status: This application is a placeholder in the docket, designated for filing upon OWS's election and restriction in B1. The divisional will cover the non-elected invention group(s) from the B1 Restriction Requirement. No action is required until after the restriction response in B1 is filed and prosecution of B1 advances. Filing of B2 is not time-critical at this stage, provided that B1 remains pending (i.e., B2 can be filed at any point while B1 is co-pending).
B3 — European Patent Application No. EP 23 741 682.3
Type: European Regional Phase Entry (from A4 PCT) Entry Date: July 5, 2023 Office: European Patent Office (EPO) Foreign Associate: Breitenfeld & Vogt Patentanwälte PartGmbB (Munich, Germany) Status: Awaiting issuance of the Extended European Search Report ("EESR"). Based on current EPO pendency data, the EESR is estimated to issue in mid-to-late 2024. Upon issuance of the EESR, a six-month response period will commence under EPO Rules 70a, 161, and 162, during which OWS must file a response to any objections or observations raised in the search report. C&H and Breitenfeld & Vogt are monitoring the file for issuance of the EESR. No action is currently required.
B4 — Japanese Patent Application No. JP 2024-542197
Type: Japanese National Phase Entry (from A4 PCT) Entry Date: July 3, 2023 Office: Japan Patent Office (JPO) Foreign Associate: Nakashima & Togawa Patent Professional Corporation (Tokyo, Japan) Status: Awaiting request for examination. Under JPO practice, a request for examination must be filed within three years of the international filing date of the underlying PCT application. The examination request deadline for B4 is January 9, 2026 (three years from the January 9, 2023 PCT international filing date of A4). If the examination request is not filed by that date, the application will be deemed withdrawn. No action is immediately required, but this deadline must be calendared and tracked.
Sub-Family C — Packaging & Thermal Management (3 Applications)
C1 — U.S. Application No. 18/102,776 (Planned)
Type: Non-Provisional Utility Application Filing Date: Not yet filed as of the date of this letter Office: USPTO Named Inventors: Dr. Li Wei; Michael Ostrowski; Karen Tanaka Status: This application has been authorized for filing under the pre-freeze budget allocation and was in an advanced stage of preparation prior to the budget freeze. The application specification and claims have been drafted and reviewed by Dr. Wei and Ms. Koh but have not undergone final partner review. C&H anticipates filing this application under the existing pre-freeze authorization once final review is completed. Because the January 10, 2022 provisional priority date has already expired, this application will not claim priority to U.S. Provisional Application No. 63/297,841. Instead, it will rely on continuation-in-part priority through A1, and independent priority for new matter. The timing of filing should be discussed with OWS to confirm that the pre-freeze authorization remains in effect.
C2 — European Patent Application No. EP 23 765 901.7
Type: European Regional Phase Entry (from A5 PCT) Entry Date: July 8, 2023 Office: European Patent Office (EPO) Foreign Associate: Breitenfeld & Vogt Patentanwälte PartGmbB (Munich, Germany) Status: The Rule 161/162 response was filed on September 1, 2023, as noted above. The application is now awaiting issuance of the Extended European Search Report, which is estimated to issue in mid-2025 based on current EPO processing times. Upon issuance of the EESR, a six-month response window will apply. No further action is required at this time.
C3 — Japanese Patent Application No. JP 2024-542305
Type: Japanese National Phase Entry (from A5 PCT) Entry Date: July 8, 2023 Office: Japan Patent Office (JPO) Foreign Associate: Nakashima & Togawa Patent Professional Corporation (Tokyo, Japan) Status: Awaiting request for examination. The examination request deadline for C3 is January 9, 2026 (three years from the January 9, 2023 PCT international filing date of A5). The same considerations discussed above with respect to B4 apply. No action is immediately required.
The following summary table consolidates the key deadline information across all twelve applications:
5. Critical Deadlines and Consequences of Inaction
We wish to emphasize — in the strongest possible terms consistent with our professional obligations — that patent prosecution is governed by strict statutory and regulatory deadlines that, if missed, result in irrevocable loss of patent rights. In many jurisdictions and under many circumstances, there is no possibility of revival once a deadline has passed. Unlike certain other legal proceedings where extensions, stays, and continuances may be obtained on a relatively routine basis, patent prosecution deadlines are typically absolute. We set forth below our assessment of the critical deadlines in order of urgency.
5.1 Highest Priority — A1 (U.S. Application No. 17/672,204) — March 9, 2025
Application A1 is the foundational U.S. application in the entire portfolio family. It is the parent application from which A2 (continuation), A3 (continuation-in-part), and indirectly B1, B2, and C1 claim priority or benefit. While the pendency of the daughter applications is not directly contingent on A1 remaining pending (because benefit claims are fixed at filing), the claims being pursued in A1 are unique and cannot be replicated in the other applications without significant restructuring of the prosecution strategy — if they can be replicated at all.
The non-final Office Action response for A1 is due on an absolute basis by March 9, 2025. As of the date of this letter, a two-month extension of time has been purchased, and the remaining four months of the maximum six-month statutory period prescribed by 35 U.S.C. § 133 will run from the extended deadline. No further extensions of time are permitted under 37 C.F.R. § 1.136(a) beyond the six-month maximum. This is a hard statutory bar.
Failure to respond by March 9, 2025, will result in the abandonment of Application A1. While a petition to revive the application for unintentional delay may theoretically be available under 37 C.F.R. § 1.137, we caution that such petitions are granted at the discretion of the USPTO and carry no guarantee of success. The standard for revival requires the applicant to state that the entire delay in responding was "unintentional." Where, as here, the delay would be the direct result of a deliberate budget decision communicated in writing and documented in this very letter, the USPTO may take the position that the delay was not "unintentional" within the meaning of the rule. We strongly recommend that OWS not rely on the availability of revival as a fallback strategy.
The substantive significance of A1 cannot be overstated. The draft Office Action response currently in progress contains proposed claim amendments specifically directed to the tapered impedance-matching feature of OWS's modulator design. This feature is central to OWS's design-around strategy with respect to two issued patents held by Pinnacle Optics, Inc. — U.S. Patent Nos. 10,823,417 (the "'417 Patent") and 11,105,662 (the "'662 Patent"). As you will recall, C&H's Freedom-to-Operate Analysis, delivered on October 14, 2022 (C&H Work Product Reference No. FTO-2022-04187-001), concluded that OWS's commercial silicon-photonics modulator products face "moderate-to-high" infringement risk with respect to the Pinnacle '417 Patent absent the design-around features that the pending claims in A1 are specifically intended to protect. The loss of A1 would eliminate OWS's ability to obtain issued patent claims covering this design-around approach, leaving OWS commercially exposed to infringement assertions by Pinnacle without the benefit of a defensive patent position.
We estimate the cost to complete and file the A1 Office Action response as follows:
• Attorney time: 40–55 hours (including completion of the draft response by Ms. Bauer, partner review by Ms. Bloom, and filing by Mr. Vassiliev), at the blended billing rates applicable to the OWS engagement — approximately $22,000–$30,000.
• USPTO fees: $0 if the response is filed as a straightforward response to the non-final Office Action; up to $2,000 (small entity rate) if a Request for Continued Examination ("RCE") becomes necessary based on the claim amendment strategy. An RCE may be advisable depending on the scope of amendments required to overcome the prior art cited by the Examiner.
• Total estimated cost: $22,000–$32,000.
5.2 Near-Term Deadlines — B1 and B3
B1 (U.S. Application No. 17/814,057) — Restriction Requirement Response. The original two-month shortened statutory period for responding to the Restriction Requirement expires on October 21, 2024. Extensions of time are available in one-month increments under 37 C.F.R. § 1.136(a), up to a maximum of six months from the original mailing date of the Restriction Requirement. If OWS does not authorize a response and no extensions are purchased, the application will go abandoned after the initial two-month period expires. We estimate the cost of responding to the Restriction Requirement as follows:
• Attorney time: 8–12 hours — approximately $4,500–$6,750.
• USPTO fees for response: $0 (no fee is assessed for an election in response to a Restriction Requirement).
• USPTO extension fees: $640 per month of extension at the small entity rate (if extensions are needed to defer the response).
B3 (European Patent Application No. EP 23 741 682.3) — Extended European Search Report Response. The EESR has not yet been issued but is estimated to issue in mid-to-late 2024. Upon issuance, a six-month response period will commence under EPO Rules 70a, 161, and 162. We estimate the cost of responding to the EESR as follows:
• C&H attorney fees: Approximately $11,250–$16,875 (depending on the complexity of the search report and the number of prior art references cited).
• Foreign associate fees (Breitenfeld & Vogt): Approximately €3,500–€5,000.
• EPO official fees: Variable, depending on whether claim amendments trigger additional claims fees.
5.3 Medium-Term Deadlines — A4 and A5 PCT National Phase Entry
The national phase entry deadline for both A4 (PCT/US2023/010584) and A5 (PCT/US2023/010612) is July 9, 2025 — thirty months from the January 10, 2022 priority date. As noted above, European and Japanese national phase entries have already been completed for both PCT applications. However, OWS had previously expressed interest in pursuing patent protection in additional jurisdictions, including the Republic of Korea, the People's Republic of China, and Taiwan. Missing the July 9, 2025 deadline permanently and irrevocably forecloses the ability to obtain patent protection in any unselected jurisdiction. There is no mechanism for late national phase entry once the 30-month deadline has passed.
The cost of entering each additional national phase jurisdiction varies but typically ranges from $3,000 to $8,000 per jurisdiction (inclusive of foreign associate fees, government filing fees, and translation costs). If OWS wishes to enter Korea, China, and Taiwan for both A4 and A5, the total estimated cost would be approximately $36,000–$96,000 for all six filings. A decision on additional national phase entries should be communicated to C&H no later than May 2025 to allow sufficient time for preparation and coordination with foreign associate firms.
5.4 Longer-Term Deadlines — B4 and C3 JPO Examination Requests
Japanese patent applications B4 (JP 2024-542197) and C3 (JP 2024-542305) both face an examination request deadline of January 9, 2026 — three years from the January 9, 2023 PCT international filing date. Under Japanese Patent Act Article 48-3, an application for which an examination request has not been filed within the prescribed period is deemed to have been withdrawn, and the JPO does not provide a revival mechanism for missed examination request deadlines. The examination request fee at the JPO is currently ¥138,000 (approximately $930) plus ¥4,000 per claim (approximately $27 per claim) for each application, plus Nakashima & Togawa's professional fees for filing.
While this deadline is the furthest out on the current docket, we include it here for completeness and to ensure that it remains on OWS's radar throughout the dormancy period.
6. Actions Taken by C&H to Preserve the Docket
In connection with the transition of this matter to dormant status, C&H has taken the following affirmative steps to preserve the integrity of the docket and minimize the risk of inadvertent deadline failures:
a. C&H has instructed Trident intellectual Property Services, LLC ("Trident"), our outsourced docketing and deadline management vendor (Lisa Cheng, Account Manager), to hold all non-critical filings across the OWS docket but to continue monitoring all statutory and regulatory deadlines without interruption. Trident has been directed to alert C&H of any approaching deadlines with a minimum of 120 days' advance notice for U.S. deadlines and 180 days' advance notice for foreign deadlines. Our letter of instruction to Trident is dated September 12, 2023, and a copy is maintained in the matter file.
b. C&H has instructed Nakashima & Togawa Patent Professional Corporation (Kenji Nakashima, Lead Attorney), our designated foreign associate firm for Japanese patent prosecution, to hold the examination request filings for JP 2024-542197 (B4) and JP 2024-542305 (C3) pending resolution of the budget freeze and further instructions from C&H. Our letter of instruction to Nakashima & Togawa is dated September 20, 2023. Nakashima & Togawa has confirmed receipt and acknowledged the hold instruction.
c. C&H's internal prosecution team has set calendar reminders for all statutory deadlines across the twelve-application docket, using both the Firm's enterprise docketing system (IPFolio) and individual attorney calendars as redundant safeguards. An internal monitoring protocol has been established to ensure that no deadline passes without advance written notice to OWS. Under this protocol, C&H will issue written deadline reminder notices to OWS at 120 days, 90 days, 60 days, and 30 days prior to each critical deadline.
d. C&H has preserved all work-in-progress files, including the incomplete draft Office Action response for A1 (approximately 18.5 hours of work product by Ms. Bauer), all prior art search results, all inventor declarations and supporting documentation, and all correspondence with foreign associate firms. These materials are maintained in C&H's secure document management system and can be accessed and resumed immediately upon reactivation of the matter.
7. C&H's Continuing Obligations During the Dormancy Period
Notwithstanding the dormant status of this matter, C&H will continue to fulfill certain ongoing professional obligations with respect to the OWS patent prosecution docket. We wish to be explicit about the scope and nature of these obligations so that there is no ambiguity during the dormancy period.
Deadline Monitoring and Notification. C&H will continue to monitor all prosecution deadlines across the twelve-application docket and will provide timely written notification to OWS of each approaching deadline with sufficient advance notice for OWS to evaluate its options and authorize action if it elects to do so. As noted above, C&H's standard notification protocol calls for written reminders at 120, 90, 60, and 30 days prior to each critical deadline.
Professional Responsibility Obligations. C&H considers this continuing monitoring obligation to be required by the California Rules of Professional Conduct, specifically Rule 1.3 (Diligence), which requires a lawyer to act with reasonable diligence in representing a client, and Rule 1.4 (Communication), which requires a lawyer to keep the client reasonably informed about significant developments in the matter. Additionally, as attorneys of record before the USPTO, C&H's attorneys are subject to the USPTO Rules of Professional Conduct at 37 C.F.R. §§ 11.103 and 11.104, which impose parallel obligations of diligence and communication with respect to patent prosecution matters pending before the Office.
Counsel of Record Status. C&H remains counsel of record before the USPTO on all pending U.S. applications (A1, A2, A3, B1, and, upon filing, C1). C&H also remains the instructing firm for European applications prosecuted through Breitenfeld & Vogt Patentanwälte PartGmbB (B3 and C2) and for Japanese applications prosecuted through Nakashima & Togawa Patent Professional Corporation (B4 and C3). In this capacity, C&H will continue to receive and review all official communications from these patent offices — including Office Actions, search reports, restriction requirements, formality notices, and other official correspondence — and will promptly relay each such communication to OWS with an explanation of its significance and any required response deadlines.
Limitation on Substantive Work. C&H will not undertake substantive prosecution work during the dormancy period without prior written authorization and budget approval from OWS. For avoidance of doubt, "substantive prosecution work" includes, but is not limited to: drafting or filing Office Action responses; drafting or filing claim amendments; filing continuation, divisional, or continuation-in-part applications; entering new national or regional phases; filing requests for examination; filing requests for continued examination; conducting prior art searches or patentability analyses; and preparing or filing any other document requiring the exercise of substantive patent prosecution judgment. The Firm's continuing deadline-monitoring and notification activities, as described above, are excluded from this limitation and will continue without specific authorization.
8. Outstanding Financial Matters
As of the date of this letter, C&H's outstanding accounts receivable on this matter total $56,958.50, consisting of the following:
The unbilled work-in-progress amount of $34,218.50 consists primarily of Ms. Bauer's time on the draft A1 Office Action response (18.5 hours), Mr. Vassiliev's time on the September 6, 2023 extension filing and related docket management, and Ms. Bloom's supervisory time on the C2 EPO filing. A detailed time entry report will be provided with the forthcoming September invoice.
C&H respectfully requests that OWS arrange for payment of the two outstanding invoices (No. 2023-07-04187 and No. 2023-08-04187, totaling $22,740.00) at its earliest convenience. The payment terms set forth in the February 10, 2022 engagement letter provide for payment within thirty (30) days of invoice date. Both invoices are currently past due.
We wish to be clear that the Firm's continuing deadline-monitoring obligations described in Section 7 above are not contingent upon, and will not be suspended pending, resolution of the outstanding balance. C&H's professional obligations to OWS will be honored regardless of the status of accounts receivable. However, C&H expressly reserves all rights with respect to the unpaid amounts, including the right to pursue collection in accordance with the terms of the engagement letter and applicable law.
9. Lender and Collateral Considerations
C&H notes for the record — and brings to OWS's attention for further evaluation — the following considerations related to OWS's credit arrangements:
OWS's $55,000,000 senior secured Revolving Credit Facility with Meridian National Bank, N.A. (the "Credit Facility"), dated September 30, 2020, as amended and restated on March 15, 2022, contains intellectual property covenants at Section 5.15 thereof. As C&H understands the relevant provision (based on the copy of the Credit Agreement provided to C&H by Ms. Koh on February 28, 2022 for purposes of the engagement), Section 5.15 requires OWS to:
"maintain, preserve, and protect all Material intellectual Property, including by timely prosecuting all pending patent applications and paying all required maintenance fees."
Additionally, the Security Agreement executed in connection with the Credit Facility grants Meridian National Bank a first-priority perfected security interest in all "Intellectual Property Collateral," which is defined to include, among other things:
"all patents, patent applications, and patent rights, whether now existing or hereafter acquired, together with all proceeds thereof."
The implications of these provisions are potentially significant. If the continued dormancy of prosecution activity — or the potential abandonment of any pending applications — were deemed to constitute a failure by OWS to "maintain, preserve, and protect" its Material intellectual Property or to "timely prosecute" its pending patent applications, such failure could constitute a breach of the Section 5.15 covenant and potentially trigger a default or event of default under the Credit Facility. A default under the Credit Facility could, in turn, result in acceleration of outstanding obligations, imposition of a default interest rate, restriction of borrowing availability, or other adverse consequences.
C&H strongly recommends that OWS's General Counsel — in consultation with OWS's credit counsel, if different from C&H — evaluate whether the dormancy of prosecution activity, particularly with respect to applications that are subject to near-term statutory deadlines (most critically A1), could give rise to a covenant compliance issue under the Credit Facility. C&H is available to provide further analysis on this question if OWS requests and authorizes such work, subject to the scope of the existing engagement or a supplemental engagement as appropriate.
10. Graystone Valuation Considerations
We also bring to OWS's attention the potential implications of the dormancy for the valuation of OWS's patent portfolio. As you are aware, Graystone Valuation Advisors, LLC conducted a comprehensive patent portfolio valuation at the request of Veltrano Capital Partners, with the final report issued on April 28, 2023 (the "Graystone Report"). The Graystone Report, prepared under the direction of Rebecca Thornton (Lead Engagement Partner), estimated the fair market value of OWS's entire patent portfolio — encompassing both issued patents and pending applications — at $38.5 million. Of that total, approximately $12.2 million was attributed to the pending twelve-application family that is the subject of the prosecution docket addressed in this letter.
The $12.2 million valuation attributed to the pending application family reflects a number of assumptions, including the assumption that prosecution of all twelve applications would continue in the ordinary course and that OWS would ultimately obtain issued patents with commercially meaningful claim scope. Abandonment of one or more applications — particularly the foundational A1 application and its associated continuation family — would directly reduce the assessed portfolio value and would likely require a restatement of the Graystone Report's conclusions.
A reduction in portfolio value may have cascading implications for Veltrano's investment thesis regarding its equity position in OWS, for any future refinancing of OWS's debt facilities (including the Meridian Credit Facility discussed above), and for any future exit strategy contemplated by Veltrano — whether through a trade sale, secondary buyout, or initial public offering. While these considerations are ultimately business decisions for OWS and Veltrano, we raise them here to ensure that the full scope of consequences flowing from the dormancy and potential abandonment of prosecution activity is visible to all decision-makers.
11. Recommended Next Steps
In light of the foregoing, C&H respectfully recommends that OWS take the following actions:
a. Designate a Point of Contact for Deadline Notifications. OWS should designate a specific individual — we suggest Sandra Koh, given her familiarity with the docket and her role as IP Manager and In-House Patent Counsel — as the primary point of contact for receiving deadline notifications and providing instructions to C&H during the dormancy period. Having a single designated contact will ensure efficient and reliable communication as deadlines approach.
b. Evaluate the Project Lighthouse Budget Cap in Light of Critical Deadlines. OWS should evaluate the $25,000 per quarter budget cap imposed by the Project Lighthouse initiative in light of the critical deadlines identified in this letter — most importantly, the absolute March 9, 2025 deadline for the A1 Office Action response. OWS should communicate to C&H well in advance of that date — we recommend no later than December 2024 — whether budget authorization will be provided for C&H to complete and file the A1 response. Given the estimated cost of $22,000–$32,000 for the A1 response alone, a one-time exception to the Project Lighthouse cap may be necessary, and we understand that such exceptions require approval at the Veltrano operating partner level.
c. Conduct a Cost-Benefit Analysis of Reactivation Versus Value at Risk. C&H recommends that OWS consult with its Chief Financial Officer, Daniel Everhart, and with Veltrano Capital's Operating Partner, Christine Paulsen, regarding the relative cost of reactivating prosecution activity on the docket versus the value at risk. As noted above, the pending application portfolio has been valued at $12.2 million, and the loss of A1 in particular would expose OWS to significant infringement risk vis-à-vis Pinnacle Optics. The cost of completing prosecution across the entire docket — while not insignificant — represents a small fraction of the portfolio value at stake.
d. Assess Strategic Abandonment Options, If Appropriate. If, after conducting the cost-benefit analysis described above, OWS determines that the budget constraints are such that certain applications must be strategically abandoned rather than prosecuted to completion, C&H recommends that any such decisions be made on the basis of a formal abandonment impact assessment. Such an assessment would evaluate the commercial, competitive, and lender-covenant consequences of each potential abandonment decision and would prioritize the retention of applications that are most critical to OWS's competitive position and IP portfolio value. C&H is prepared to conduct such an assessment upon authorization by OWS.
e. Authorize a Docket Triage and Budget Reactivation Proposal. Finally, C&H is prepared to undertake a comprehensive docket triage exercise and to prepare a detailed budget reactivation proposal for OWS's consideration. Such a proposal would identify the minimum necessary prosecution activities and associated costs for each application, prioritize activities based on deadline urgency and strategic importance, and present options for phased reactivation that could potentially be structured to fit within — or at least minimize departures from — the Project Lighthouse budget parameters. We estimate that preparation of such a proposal would require approximately 15–20 attorney hours.
12. Disclaimer and Privileged Nature of This Communication
This letter is a privileged and confidential attorney-client communication, protected by the attorney-client privilege and the work product doctrine. It is intended solely for the use of OWS and its authorized officers and employees. This letter does not constitute a legal opinion on any of the matters discussed herein, including without limitation the enforceability or interpretation of the Meridian Credit Facility covenants, the likelihood of success of any petition to revive an abandoned application, or the infringement risk posed by the Pinnacle Optics patents. This letter is provided for informational and record-keeping purposes, and to document C&H's compliance with its professional obligations of communication and diligence.
C&H's observations regarding the Meridian National Bank Credit Facility covenants at Section 5.15, as set forth in Section 9 above, are limited to flagging the issue for OWS's attention and do not constitute a comprehensive analysis of OWS's covenant compliance obligations. Any formal analysis of the Credit Agreement, the Security Agreement, or OWS's obligations thereunder would require a separate engagement or specific written authorization expanding the scope of the current engagement. C&H's current engagement is limited to patent prosecution and related intellectual property matters as set forth in the February 10, 2022 engagement letter, as amended.
Marcus, we would appreciate your acknowledgment of receipt of this letter at your earliest convenience. Please also confirm OWS's preferred point of contact for ongoing deadline notifications during the dormancy period so that we may direct future communications accordingly.
We recognize that the current budgetary environment presents difficult choices, and we remain committed to supporting OWS through this period. C&H is prepared to discuss any of the foregoing matters at your convenience — whether by telephone, videoconference, or in person. Please do not hesitate to reach out to me directly or to any member of the C&H team.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Catherine Bloom Partner, intellectual Property Group USPTO Reg. No. 58,412 555 California Street, 42nd Floor San Francisco, CA 94104 Direct: (415) 555-7218
Email: cbloom@calderwoodharkness.com
cc: Sandra Koh, IP Manager / In-House Patent Counsel, Optiwave Semiconductor Corp. Alan Ngo, Billing Partner, Calderwood & Harkness LLP Christy Bauer, Lead Associate, Calderwood & Harkness LLP Peter Vassiliev, Working Associate, Calderwood & Harkness LLP
Enclosure: Master Docket Summary — OWS Patent Prosecution Docket (12 applications with current status and upcoming deadlines)
App. | Jurisdiction | App. Number | Status | Next Critical Deadline | Consequence of Miss
A1 | U.S. (USPTO) | 17/672,204 | OA response due | Mar. 9, 2025 (absolute) | Abandonment
A2 | U.S. (USPTO) | 17/672,311 | Awaiting 1st OA | Est. Q2 2025 | N/A (monitoring)
A3 | U.S. (USPTO) | 17/672,489 | Awaiting 1st OA | Est. Q3 2025 | N/A (monitoring)
A4 | PCT (WIPO) | PCT/US2023/010584 | Nat'l phase open | Jul. 9, 2025 | Loss of add'l jurisdictions
A5 | PCT (WIPO) | PCT/US2023/010612 | Nat'l phase open | Jul. 9, 2025 | Loss of add'l jurisdictions
B1 | U.S. (USPTO) | 17/814,057 | Restriction req'd | Oct. 21, 2024 (+ext.) | Abandonment
B2 | U.S. (USPTO) | 17/814,103 | Not yet filed | Co-pendency w/ B1 | N/A (dependent on B1)
B3 | EP (EPO) | EP 23 741 682.3 | Awaiting EESR | Est. mid-late 2024 (+6 mo.) | Loss of EP rights
B4 | JP (JPO) | JP 2024-542197 | Awaiting exam req. | Jan. 9, 2026 | Deemed withdrawal
C1 | U.S. (USPTO) | 18/102,776 | Not yet filed | Pre-freeze auth. | See discussion above
C2 | EP (EPO) | EP 23 765 901.7 | Awaiting EESR | Est. mid-2025 (+6 mo.) | Loss of EP rights
C3 | JP (JPO) | JP 2024-542305 | Awaiting exam req. | Jan. 9, 2026 | Deemed withdrawal
Category | Amount
Unbilled work-in-progress (through Sep. 6, 2023) | $34,218.50
Unpaid Invoice No. 2023-07-04187 (July 2023) | $12,360.00
Unpaid Invoice No. 2023-08-04187 (August 2023) | $10,380.00
Total Outstanding | $56,958.50

CALDERWOOD & HARKNESS LLP Attorneys at Law

CALDERWOOD & HARKNESS LLP

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