Bloomberg Inc., et al. v. Markets-Alert Pty Ltd.
`CBM2013-00005
`
`Bloomberg et al. – Exhibit 1046
`
`
`CBM2013-00005
`
`Bloomberg et al. – Exhibit 1046
`
`
`
`Procedural Background
`
`• Petitioners challenged every claim of the ’357 Patent (Claims 1-4) based on
`Satow, TradeStation (as described by several references including S&C
`Review), Window on WallStreet, Trading Expert Pro (as described by
`several references including Opening Bell), Investor/RT, eSignal, and
`Stutman.
`• The Board instituted trial based on Claims 1-4 as (1) anticipated by Satow,
`(2) anticipated by S&C Review, (3) anticipated by Opening Bell, and (4)
`
`obvious over Stutman and Opening Bell.obvious over Stutman and Opening Bell.
`• Because Bloomberg established that it is more likely than not that claims 1-
`4 are unpatentable under four grounds, the Board held that Bloomberg’s
`remaining grounds were redundant and denied the petition as to those
`grounds.
`In its motion to amend, Markets-Alert states “Claims 1-4 are cancelled.” PN
`42 at 2.
`
`•
`
`See PN 1, PN 18, PN 42
`
`2
`
`
`
`Petitioners’ Case: The Board Should Grant MA’s
`Request to Cancel ‘357 Patent Claims 1-4
`• Markets-Alert’s Motion to Amend at p. 1: “Markets-Alert hereby
`cancels Claims 1-4 and adds new Claims 5-8 (‘New Claims’)”
`“Nowhere in the Motion to Amend does MA request the cancelation
`to be contingent on further [action] by the Board of those claims.” PN
`51, p. 2.
`
`•
`
`• Unrebutted grounds on which the Board instituted trial:
`
`– “Instead of addressing the grounds of unpatentability raised in– “Instead of addressing the grounds of unpatentability raised in
`Petitioners’ Petition (PN 1, “Petition”) for now canceled claims 1-
`4, MA dedicates its Response to arguments relevant only to its
`proposed new claims 5-8, which were submitted in its Motion to
`Amend.” PN. 51, p. 1
`
`3
`
`
`
`Petitioners’ Response to MA’s Case: MA’s Motion to
`Amend Should Be Denied
`ISSUE #1: New Claims 5-8 improperly enlarge the
`scope of the ’357 Patent claims.
`ISSUE #2: New Claims 6-8 are wholly untraceable to
`any challenged claim.
`ISSUE #3: New claims 5-8 improperly introduce new
`
`matter that is not supported by the ’357 patentmatter that is not supported by the ’357 patent
`specification.
`ISSUE #4: The motion lacks claim construction.
`ISSUE #5: Markets-Alert fails to demonstrate any
`patentable distinction over the prior art.
`
`See PN 50 at Table of Contents, 1, 4, 9, 10
`
`4
`
`
`
`Issue #1
`
`Broadening
`
`New claims cannot be broadened
`
`“[A] substitute claim may not enlarge
`the scope . . . by eliminating any
`
`feature.”feature.”
`
`Idle Free Systems, Inc. v. Bergstrom, Inc., IPR2012-00027, PN 26 at 3-5
`(PTAB June 11, 2013).
`
`See PN 50 at 2
`
`5
`
`
`
`Issue #1
`
`Broadening
`
`Claims 5-8 eliminate the “periodically apply” feature
`
`Claims 1-4
`
`Require “using the network of
`computers to periodically apply the
`user-specified watch data . . .”
`
`Claims 1-4 required that the
`network of computers “periodically
`apply” watch data. The Board held
`that “periodically apply” includes
`“one or more time intervals.”
`
`Claims 5-8
`
`See PN 50 at 2
`
`Only require, e.g., “applying the
`user-specified watch data to the
`real-time stock market data as the
`real-time stock market data is
`received.” (Claim 5.)
`
`This limitation has been wholly
`eliminated from new claims 5-8.
`While the original claims required
`applying watch data over at least
`one time interval, the scope of new
`claims 5-8 is improperly enlarged to
`include non-periodic application of
`watch data.
`
`6
`
`
`
`Issue #1
`
`Broadening
`
`Claims 5-8 eliminate the notification “to the user” feature
`
`Claims 1-4
`
`
`
`Claims 5-8Claims 5-8
`
`See PN 50 at 2-3
`
`Require “causing a real-time
`notification by the network of
`computers to be provided to the
`user via a remote communications
`device upon occurrence of the
`event . . .”
`
`Only require, e.g., “the notificationOnly require, e.g., “the notification
`
`is provided in real-time by the
`provider’s network of computers to
`a remote communications device
`of the user.” (Claim 5.)
`
`Original claim 1 expressly required
`a real-time notification to the user.
`
`New claim 5 has been broadenedNew claim 5 has been broadened
`
`such that real-time notification need
`provided to only “a remote
`communication device.” In fact, the
`entire claim 1 clause “the real-time
`notification . . . for share market
`transactions on an instantaneous
`basis” has been completely
`removed from new claim 5.
`
`7
`
`
`
`Issue #1
`
`Broadening
`
`Mr. Goldstein agrees there is a difference between providing
`notification to a device rather than to a user
`
`Q: So does this claim [5] require that the notification only go to the device or
`that it also make it all the way to the human in real-time?
`A: No. It only specifies that it’s sent – that it’s generated and sent to the
`device in real-time.
`Q: Okay. So the notification may go to the device in real-time, but the human
`
`user might not discover it until some time later; right?user might not discover it until some time later; right?
`A: That’s true.
`Q: And that would fall within the scope of Claim 5; right?
`A: Claim 5 simply says that the device – that the notification must be provided
`in real-time to the communication device.
`It doesn’t mention the user.
`
`See PN 50 at 2-3; Ex. 1035 at
`128:9-129:24.
`
`8
`
`
`
`Issue #1
`
`Broadening
`
`Claims 5-8 eliminate the “upon the occurrence of the event”
`feature
`
`Claims 1-4
`
`Claims 5-8
`
`See PN 50 at 3
`
`Require “causing a real-time
`notification by the network of
`computers to be provided to
`the user via a remote
`communications device upon
`occurrence of the event
`defined by the user-specified
`
`watch data . . .”watch data . . .”
`Require, e.g., “notification in
`real-time when the valid stock
`market event has been
`determined to have occurred
`by the provider’s network of
`computers . . .” (Claim 5.)
`
`New claims 5-8 also eliminate
`the requirement of claims 1-4
`that the real-time notification to
`the user occurs “upon the
`occurrence of the event defined
`by the user-specified watch
`data.” Ex. 1001 at 5:21-6:1.
`
`Claim 5, in contrast to claim 1,
`more permissively requires
`generation of a notification
`“when the valid stock market
`event has been determined to
`have occurred by the provider’s
`network of computers.”
`
`9
`
`
`
`Issue #1
`
`Broadening
`
`Claim 8 is per se broadened
`
`“[W]here the original patent claims only the process, and
`the reissue application newly adds product claims, the
`scope of the claims has been broadened because a
`party could not necessarily be sued for infringement of
`the product based on the claims of the original patent (if
`
`it were made by a different process).”it were made by a different process).”
`
`MPEP § 1412.03.
`
`See PN 50 at 3
`
`10
`
`
`
`Issue #1
`
`Broadening
`
`Claim 8 is eliminates practice of a method as a feature
`
`Claims 1-4
`
`Claim 8
`
`See PN 50 at 2-3
`
`Require, e.g. “receiving real-
`time stock market data . . .
`receiving on the network of
`computers instructions from a
`user . . . using the network of
`computers . . . causing a real-
`time notification . . .”
`
`Claims 1-4 were directed solely
`to methods. Claims 1-4 only
`allow suit based on practice of
`a method.
`
`Requires only, e.g., “A real-
`time system . . . comprising: a
`network guardian . . . a history
`database subsystem . . . an
`alert managing subsystem . . .
`an output connector.”
`
`Claim 8 is per se broadened
`because it claims a system.
`Claim 8 would allow an
`infringement suit based, for
`example, on making an
`apparatus.
`
`11
`
`
`
`Issue #2
`
`Untraceable Claims
`
`Claims 6-8 bear no resemblance to any of claims 1-4
`
`“[A]ll proposed claims should be
`traceable to an original challenged
`
`claim.”claim.”
`
`Idle Free Systems, Inc. v. Bergstrom, Inc., IPR2012-00027, PN 26 at 5
`(PTAB June 11, 2013).
`
`See PN 50 at 2-3
`
`12
`
`
`
`Issue #3
`
`Improper New Matter
`
`Markets-Alert failed to demonstrate support for the new claims in
`the original disclosure
`
`A patent owner seeking to amend must “demonstrate
`support for the claimed subject matter as a whole.”
`
`Nichia Corp. v. Emcore Corp., IPR 2012-0005, PN 27 at 4 (PTAB June 3, 2013)
`(emphasis in original).
`
`MA’s motion fails to comply with 37 CFR § 42.221, as it
`does not identify requisite support for new claims 5-8 in the
`original disclosure.
`
`37 CFR § 42.221(b).
`
`See PN 50 at 4
`
`13
`
`
`
`Issue #3
`Improper New Matter
`Claim 5: Language “server-based, scalable and redundant” system is
`broader than the ‘357 Patent disclosure
`
`• The terminology “scalable” and “redundant” is found nowhere in
`the ’357 Patent specification.
`• The specification does not discuss a “redundant” network, or a
`network where if one computer becomes inoperable the system
`continues to operate without data being lost.
`
`• Even if the ’357 Patent’s short disclosure illustrates a network that• Even if the ’357 Patent’s short disclosure illustrates a network that
`could be considered, upon retrospective review, “server-based,
`scalable and redundant,” that does not constitute written
`description support for vastly broad claims such as proposed
`claims 5-8, which recite only distilled-out functional aspects of a
`system. See Lizardtech, Inc. v Earth Resources Mapping, Inc.,
`424 F.3d 1336, 1345 (Fed. Cir. 2005).
`
`See PN 50 at 5
`
`14
`
`
`
`Issue #3
`Improper New Matter
`Claim 5: No support for applying watch data to “as real-time stock
`market data is received”
`
`• Claim 5 presents new subject matter because the ’357 Patent
`specification only mentions that watch data/formulas are applied
`to data at a specified interval, or periodically.
`– “The drone then analysis [sic] the stock market at a specified
`internal [sic, interval] . . .” Ex. 1001 at 3:49-50.
`
`– “Technical analysis indicators can be set to ‘repeat’ over a– “Technical analysis indicators can be set to ‘repeat’ over a
`certain period . . .” Ex. 1001 at 4:49-51
`• The ’357 Patent includes no description of applying watch data
`as real-time data is received.
`
`See PN 50 at 6.
`
`15
`
`
`
`Issue #3
`Improper New Matter
`Claim 5: No support for “more than one technical analysis formula . . .
`defines a valid stock market event”
`
`• Claim 5 states that “more than one technical analysis formula . . . defines a valid
`stock market event.”
`• The ’357 Patent does not disclose watch data where more than one technical
`analysis formula defines a single event.
`• Markets-Alert cites to 2:47-58:
`The drone has two main purposes [sic] they are as follows:
`
`(1) To accept, process and return static stock market data which a user(1) To accept, process and return static stock market data which a user
`requested from the service.
`(2) To repetitively calculate users requested “watch data” (an event set by
`the user to trigger an alert which is sent to the users [sic] mobile or static
`device). The watch data can consist of: a simple, price/volume or price plus
`volume watch or a technical analysis request, e.g., trend line drawing,
`moving average alerts, as well as other documented technical analysis
`systems.
`• This merely identifies a few different but singular watch data examples.
`See PN 50 at 6-7
`
`16
`
`
`
`Issue #3
`
`Improper New Matter
`
`Claim 5: No support for “valid stock market event”
`
`• The term “valid stock market event,” which Markets-Alert
`and its expert admit is new, does not appear anywhere in
`the ’357 Patent.
`• Markets-Alert argues that this term “combines and makes
`explicit the language in the Original Claims [claims 1-4] with
`
`respect to an event and a valid response. The claim term isrespect to an event and a valid response. The claim term is
`supported by the Original Claims.”
`• Markets-Alert writes: “The ’357 Patent currently contains
`originally issued Claims 1-4 (‘Original Claims’).”
`• Claims 1-4 were not part of the ’357 Patent’s original
`disclosure.
`
`See PN 50 at 7; PN 62 at 7.
`
`17
`
`
`
`Issue #3
`
`Improper New Matter
`
`Claim 6 lacks support
`
`• Claim 6 requires “updating a cache of stock market data,” but the
`’357 Patent does not recite a “cache” or “updating a cache.”
`• Claim 6 requires “applying the technical analysis formula . . . to
`generate a technical analysis indicator.” The ’357 Patent never
`discloses that a technical analysis indicator may be the output of
`
`a technical analysis formula.a technical analysis formula.
`– Rather, the specification teaches that a technical analysis
`indicator is a formula. Ex. 1001 at 3:49-50 (“The drone . . .
`applies the users [sic] chosen technical and analysis
`indicators formulas to the data.”
`– Mr. Goldstein states, “The words ‘indicator’ and ‘formula’ are
`often used interchangeably.” Ex. 1035 at 137:18-19.
`
`See PN 50 at 7-8
`
`18
`
`
`
`Issue #3
`
`Improper New Matter
`
`Claim 7 lacks support for the newly claimed “live link”
`
`• New Claim 7 recites: “including in the real-time notification a live link
`between the user’s remote communication device and the provider’s
`network of computers, to enable the user to provide an instruction for a
`stock market transaction from the notification.”
`
`• The ’357 Patent never uses the term “link” and certainly fails to disclose
`
`a “live link” included in the “real-time notification” to enable the user toa “live link” included in the “real-time notification” to enable the user to
`provide an instruction for a stock market transaction.
`
`See PN 50 at 8
`
`19
`
`
`
`Issue #3
`
`Improper New Matter
`
`Markets-Alert cites no support for Claim 7’s live link to
`instruct a market transaction
`Markets-Alert provides citations below for “live link” :
`2:3-5 “The second system can comprise a users [sic] fixed or mobile telephone, a personal
`computing device, a facsimile or pager of the user.”
`2:12-14 “The users [sic] second system software component can send input commands to a
`software environment that is running on the network of computer systems.”
`2:29-33 “From an Internet software, Wap enabled phone or mobile input device, the user
`sends a message or command from a second system device, which is then intercepted by the
`switching box.”
`
`2:41-42 “(2) route alerts to an sms server to be sent to clients [sic] computers or mobile2:41-42 “(2) route alerts to an sms server to be sent to clients [sic] computers or mobile
`handsets”
`3:47-55 “The drone processes messages from the users (sent via the switch). These
`messages are technical indicator instructions. The drone the analysis [sic] the stock market at a
`specified internal [sic] and applies the users [sic] chosen technical and analysis indicators
`formulas to the data. If the data is a valid technical response (e.g., price has reached) the drone
`sends a message to the switch which then sends it to the SMS server. Element 4 data is fed
`from the exchange to the drone computers. (when [sic] requested to do so by the drone).”
`6:3-4 Citation to issued Claim 1.
`
`•
`
`•
`
`•
`
`
`
`••
`
`•
`
`•
`
`See PN 50 at 8
`
`20
`
`
`
`Issue #3
`
`Improper New Matter
`
`Claim 8 lacks support
`
`• Claim 8 recites “a network guardian, which comprises one or more switches.”
`The ’357 Patent discloses a “network guardian,” but does not disclose one
`comprising one or more switches.
`Instead, Fig. 2 of the ’357 Patent depicts
`switches outside of and separate from the “GUARDIAN,” and “does not describe
`any structure of the guardian.” See Ex. 1035 at 145:5-147:4.
`• Claim 8 recites a “history database subsystem” and “alert managing subsystem.”
`Such “subsystems” are not disclosed anywhere in the ’357 Patent.
`
`• Claim 8 recites an “output connector.” The ’357 Patent does identify an “output• Claim 8 recites an “output connector.” The ’357 Patent does identify an “output
`service” but not an “output connector.”
`• Claim 8 recites “one or more” with respect to various components (e.g.,
`switches, history clients, alert clients), but the ’357 Patent provides limited
`disclosure as in Fig. 2 (i.e., showing only 2 switches, only 3 history clients, only 3
`alert clients).
`• Claim 8 recites “applying technical analysis in real-time” and “apply more than
`one technical analysis formula.” See Claim 5 discussion.
`See PN 50 at 8-9
`
`21
`
`
`
`Issue #4
`
`No claim construction provided
`
`Markets-Alert’s motion to amend lacks claim construction for
`Claims 5-8
`Q: So this section [referring to the section of
`Mr. Goldstein’s declaration entitled “Claim
`Construction] really addresses the Claims 1
`through 4 –
`
`A: Correct.A: Correct.
`
`Mr. Neal Goldstein on August 28, 2013, Ex. 1035 at 75:12-14; see also id. at 74:4-6.
`
`Markets-Alert’s motion fails to provide construction
`of new terminology found in proposed claims 5-8.
`PN 42.
`
`See PN 50 at 9-10
`
`22
`
`
`
`Issue #5
`
`No showing of patentable distinction
`
`Markets-Alert addressed only four references
`
`Markets-Alert admittedly addressed only the four references
`upon which trial was ordered: Satow (Ex. 1004), S&C Review
`(Ex. 1005), Opening Bell (Ex. 1014) and Stutman (Ex. 1015):
`Q. Okay. So those are the four references that you reviewed and testified
`to in our declaration?
`
`A. That is correct.A. That is correct.
`Q. Were – were you asked to review and analyze any other prior art
`references?
`A. No, I was not.
`Q. So the scope of your testimony is limited to those four references?
`A. Yes, it is.
`
`Mr. Neal Goldstein on August 28, 2013, Ex. 1035 at 178:13-22; see also id. at 175:19-180:8; PN. 50 at 10-11
`
`23
`
`
`
`Issue #5
`
`No showing of patentable distinction
`
`Markets-Alert failed to address all art it was aware of
`
`Neither Markets-Alert nor its expert addressed proposed new claims 5-8
`vis-à-vis other prior art known to be in its possession, including other prior
`art Petitioners submitted in their petition for CBM Review such as:
`• Windows on Wall Street Web Archives (Exs. 1010-1013)
`• Windows on Wall Street User’s Guide (Ex. 1009)
`•
`Investor/RT (Exs. 1026-1032)
`• eSignal (Ex. 1033)
`• eSignal expressly teaches the very server-based, scalable and
`redundant network Markets-Alert argues as the primary distinctive
`feature of its proposed claims: “[u]nlike most competitive systems,
`eSignal offers speed and reliability by providing direct connections to
`the exchanges and multiple geographically dispersed server
`farms for data redundancy.” (Ex. 1033 at 1)
`
`PN 50 at 11
`
`24
`
`
`
`Issue #5
`
`No showing of patentable distinction
`
`Markets-Alert admits that elements of Claims 5-8 are taught
`in the art but did not distinguish that art.
`
`Markets-Alert’s expert conceded that a number of features of the proposed
`claims offered as points of distinction regarding the prior art were, in fact,
`actually taught in the prior art available to MA (e.g., via its expert) and
`known long before the ‘357 Patent:
`•
`Server-based, scalable and redundant networks were well known by 1980, possibly as far back as the
`1970s. Ex. 1035 at 14:2-15:5; 16:9-17:14.
`Server-based network, as specifically recited in claim 5, was known in the prior art. Id. at 62:17-19.
`
`Receiving data on a server-based, scalable and redundant network, as specifically recited in claim 5,Receiving data on a server-based, scalable and redundant network, as specifically recited in claim 5,
`was known in the prior art. Id. at 50:3-51:12.
`The fact that technical analysis was known in the art prior to the ’357 Patent is not a point in dispute. Id.
`at 27:17-28:4.
`Receiving user-specified watch data including more than one technical analysis request, as
`specifically recited in claim 5, was known in the prior art. Id. at 51:13-21.
`Using a network to periodically apply user-specified watch data to real-time financial data was known in
`the prior art. Id. at 54:22-55:2.
`Generating a notification in real-time, as specifically recited in claim 5, was known in the prior art. Id.
`at 62:3-24-63:5.
`
`•
`
`••
`
`•
`
`•
`
`•
`
`•
`
`PN 50 at 11-12
`
`25
`
`
`
`Issue #5
`
`No showing of patentable distinction
`
`Markets-Alert Improperly Attacks Prior Art References Individually
`
`Markets-Alert’s showing is deficient at least for failing to address the combined
`teachings of the identified four references.
`
`•
`
`•
`
`“The ’357 Patent does not recite or otherwise identify the term ‘provider’s
`network of computers,’ and Markets-Alert has provided no claim construction,
`either in the motion or via its expert, for this terminology.”
`
`“Neither Markets-Alert nor its expert ever address the obviousness of embodying
`known real-time technical analysis monitoring and notification processes (e.g.,
`TradeStation, Trading Expert Pro, etc.) using known server-based, financial
`network systems (e.g., Satow, eSignal).”
`
`PN 50 at 11-12
`
`26
`
`
`
`Issue #5
`
`No showing of patentable distinction
`
`“Real-time” cannot distinguish the art
`The ’357 Patent specification only mentions that watch data/formulas are applied to data at a
`specified interval, or periodically.
`As to prior art:
`•
`Satow is directed to a “real-time computerized stock trading system.” Ex. 1004 at
`1:16-17.
`“TradeStation users could be using . . . real-time data from an online feed . . .”
`S&C Review, Ex. 1005 at 0003-0004.
`Opening Bell describes that Trading Expert Pro users may achieve “access to real-
`
`time information” by “connect[ing] to the internet and select[ing] the Alerts buttontime information” by “connect[ing] to the internet and select[ing] the Alerts button
`from TradingExpert’s Quick Launch Menu.” Ex. 1014 at 5.
`“TradingExpert’s Real-Time Alerts function, designed for short-term traders, allows users
`to monitor tickers with dynamically updating real-time charts.” Id.
`“Investor/RT will monitor and analyze any security type transmitted by your data
`vendor.
`It does not matter if the data you receive from your data service is broadcast in
`real-time, delayed, or end-of-day.” Ex. 1026 at 1.
`Stutman discloses a “real-time,” remotely-configurable information distribution system.
`Ex. 1002 at ¶ 104.
`
`•
`
`PN 1 at 21, 26, 40, 46, 52; PN 50 at 6, 11-12
`
`27
`
`•
`
`•
`
`•
`
`•
`
`
`
`Issue #5
`
`No showing of patentable distinction
`
`Markets-Alert failed to meet their burden of showing
`patentable distinction over all prior art
`As one exemplary basis of
`unpatentability (in addition to prior
`art cited in the petition as well as
`those aspects of the claims MA
`admits were well known in the art), a
`
`person of ordinary skill would haveperson of ordinary skill would have
`considered the proposed claims
`unpatentable over prior art easily
`locatable through the Patent Office’s
`databases, such as U.S. Patent No.
`4,554,418 to Toy (Ex. 1041).
`
`See Toy (Ex. 1041); PN. 50 at 15; Second Declaration of Dr. Steven Kursh (Ex. 1043) at ¶45-51 and claim chart
`
`28
`
`
`
`Issue #5
`
`No showing of patentable distinction
`
`Markets-Alert has the burden to show patentable distinction
`
`“The burden is not on the petitioner to
`show unpatentability, but on the patent
`
`owner to show patentable distinction overowner to show patentable distinction over
`the prior art.” Idle Free at 7.
`
`See, e.g., PN 50 at 15
`
`29
`
`
`
`Conclusion: Markets-Alert’s Motion to Amend Should Be Denied
`
`New Claims 5-8 improperly enlarge the scope of the
`’357 Patent claims.
`New Claims 6-8 are wholly untraceable to any
`challenged claim.
`New claims 5-8 improperly introduce new matter that is
`
`not supported by the ’357 patent specification.not supported by the ’357 patent specification.
`The motion lacks claim construction.
`Markets-Alert fails to demonstrate any patentable
`distinction over the prior art.
`
`See PN 50 at Table of Contents, 1, 4, 9, 10
`
`30
`
`
`
`Markets-Alert’s Motion to Exclude Should be
`Denied
`•
`“MA does not raise any issue on the admissibility of Dr. Kursh’s
`declaration.
`In fact, MA plainly admits that the purpose of its motion
`is to address credibility and the weight of the evidence – subjects
`which the Board clearly explained are outside the proper scope of a
`motion to exclude.” PN 62, p. 1.
`
`•
`
`“In contrast, issues related to credibility and the weight of the
`
`evidence should be raised in responses and replies. Further, aevidence should be raised in responses and replies. Further, a
`motion to exclude may not be used to challenge the sufficiency of
`the evidence to prove a particular fact, or to present arguments that
`should have been presented in responses or replies.” PN 56, p. 5.
`
`31
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`
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`Wilson Sonsini Goodrich 8i Rosati
`
`PROFESSIONAL CORPORATION
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