`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`APPLE INC.,
`
`Petitioner,
`
`v.
`
`SMARTFLASH LLC,
`
`Patent Owner.
`
`____________
`
`Case CBM2014-001081
`
`Patent 8,061,598
`
`____________
`
`PATENT OWNER’S RESPONSE TO PETITION
`
`
`1 Case CBM2014-00109 has been consolidated with the instant proceeding.
`
`
`
`
`
`
`I.
`
`TABLE OF CONTENTS
`
`
`
`INTRODUCTION ........................................................................................... 1
`
`II.
`
` STATEMENT OF MATERIAL FACTS ........................................................ 3
`
`III. THE 00108 AND 00109 WECHSELBERGER DECLARATIONS
`SHOULD BE GIVEN LITTLE OR NO WEIGHT ......................................... 4
`
`IV. CLAIM CONSTRUCTION ............................................................................ 8
`
`V.
`
` OBVIOUSNESS GROUNDS AGAINST CLAIM 26 OF THE ‘598
`PATENT .......................................................................................................... 8
`
`A. Obviousness in Light of Stefik ‘235 and Stefik ‘980 ............................ 8
`
`B.
`
`Obviousness in Light of Ginter ........................................................... 12
`
`VI. CONCLUSION .................................................................................................. 16
`
`
`
`
`
`- i -
`
`
`
`I.
`
`
`
`INTRODUCTION
`
`The present proceeding is a consolidated proceeding for Cases CBM2014-
`
`00108 and CBM2014-00109. The only granted ground for unpatentability raised
`
`in the Petition in CBM2014-00108 (hereinafter “the 00108 Petition”) was for claim
`
`26 under 35 U.S.C. § 103 over U.S. Patent No. 5,530,235 (“Stefik ‘235”) and U.S.
`
`Patent No. 5,629,980 (“Stefik ‘980”). The PTAB denied the remaining grounds.
`
`Decision at 24.
`
`The only granted ground for unpatentability raised in the Petition in
`
`CBM2014-00109 (hereinafter “the 00109 Petition”) was for claim 26 under 35
`
`U.S.C. § 103 over U.S. Patent No. 5,915,019 (“Ginter”). The PTAB denied the
`
`remaining grounds. Decision at 24.
`
`In support of this Patent Owner’s Response, reference will be made to
`
`concurrently filed Exhibit 2030, Declaration of Jonathan Katz, Ph.D. (hereinafter
`
`“the Katz Declaration”). Reference will also be made herein to (1) Exhibit 1021,
`
`DECLARATION OF ANTHONY J. WECHSELBERGER IN SUPPORT OF
`
`APPLE INC.’S PETITION FOR COVERED BUSINESS METHOD PATENT
`
`REVIEW OF UNITED STATES PATENT NO. 8,061,598 PURSUANT TO 35
`
`U.S.C. § 321, 37 C.F.R. § 42.304, filed in CBM2014-00108 (hereinafter “the
`
`00108 Wechselberger Declaration”), and (2) Exhibit 1121, DECLARATION OF
`
`ANTHONY J. WECHSELBERGER IN SUPPORT OF APPLE INC.’S PETITION
`
`
`
`- 1 -
`
`
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`FOR COVERED BUSINESS METHOD PATENT REVIEW OF UNITED
`
`STATES PATENT NO. 8,061,598 PURSUANT TO 35 U.S.C. § 321, 37 C.F.R. §
`
`42.304, filed in CBM2014-00109 (hereinafter “the 00109 Wechselberger
`
`Declaration”).
`
`Reference will also be made herein to Exhibit 2025 which is a concatenation
`
`of Mr. Wechselberger’s Deposition transcript beginning on December 10, 2014
`
`and continuing to December 11, 2014. Pages 1-236 of Exhibit 2025 are for
`
`December 10, 2014, the first day of his two-day deposition for the combined
`
`proceedings of CBM2014-00102, -00106, -00108 and -00112. Pages 239-403 of
`
`Exhibit 2025 are for December 11, 2014. On December 11, 2014, a conference
`
`call was held with the PTAB to resolve an issue relating to testimony sought by
`
`Patent Owner’s counsel, and pages 339-356 are a transcription of the conference
`
`call. Because of the possibility of needing to redact a portion of the transcript in
`
`light of the conference call, transcript pages 358-378 are found on pages 364-384
`
`of Exhibit 2025, starting with their own caption pages. However, ultimately,
`
`Petitioner did not request that any part of the transcript be redacted. See Paper 20,
`
`page 2, footnote 2. The remaining portion of Mr. Wechselberger’s transcript is
`
`pages 379-396 found on pages 386-403 of Exhibit 2025. For consistency, all
`
`references to Exhibit 2025 are made with respect to the page numbers at the
`
`bottom of the exhibit which are Preceded by the word “Page,” not the transcript
`
`
`
`- 2 -
`
`
`
`page numbers in the upper-right corner of the page. References herein may be
`
`made in the form of (1) “nnn:xx-yy” which is intended to mean page “nnn”, lines
`
`“xx” to “yy” or (2) “mmm:xx - nnn:yy” which is intended to mean page “mmm”,
`
`line “xx” to page “nnn”, line “yy”.
`
`
`
`II.
`
`STATEMENT OF MATERIAL FACTS
`
`1.
`
`The 00108 Wechselberger Declaration does not state that Mr.
`
`Wechselberger’s opinions presented therein were based on a “preponderance of the
`
`evidence” standard.
`
`2.
`
`The 00109 Wechselberger Declaration does not state that Mr.
`
`Wechselberger’s opinions presented therein were based on a “preponderance of the
`
`evidence” standard.
`
`3.
`
`Exhibit 2007 is a document from Apple Inc. dated September 19,
`
`2012 entitled In-App Purchase Programming Guide (to which its Exhibit label has
`
`been added).
`
`4.
`
`Exhibit 2008 is a document from Apple Inc. dated September 18,
`
`2013 entitled In-App Purchase Programming Guide (to which its Exhibit label has
`
`been added).
`
`
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`- 3 -
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`
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`5.
`
`Exhibit 2013 is a document from Apple Inc. dated September 18,
`
`2013 entitled Receipt Validation Programming Guide (to which its Exhibit label
`
`has been added).
`
`
`
`III. THE 00108 AND 00109 WECHSELBERGER DECLARATIONS
`
`SHOULD BE GIVEN LITTLE OR NO WEIGHT
`
`The 00108 and 00109 Wechselberger Declarations do not disclose the
`
`underlying facts on which the opinions are based and are, therefore, entitled to
`
`little or no weight. 37 CFR 42.65 (“Expert testimony that does not disclose the
`
`underlying facts or data on which the opinion is based is entitled to little or no
`
`weight.”).
`
`More specifically, the 00108 and 00109 Wechselberger Declarations do not
`
`state the evidentiary weight standard (e.g., substantial evidence versus
`
`preponderance of the evidence) that Mr. Wechselberger used in arriving at his
`
`conclusions. Footnote 5 on page 16 of the Decision states “On this record, we are
`
`not persuaded by Smartflash’s argument that the Declaration of Mr. Wechselberger
`
`is entitled to little or no weight because it does not disclose the underlying facts on
`
`which the opinion is based. ... Smartflash identifies purported omissions from the
`
`Declaration, but offers no evidence that Mr. Wechselberger used incorrect criteria,
`
`failed to consider evidence, or is not an expert in the appropriate field.” However,
`
`
`
`- 4 -
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`
`
`establishing that Mr. Wechselberger failed to state the evidentiary standard that he
`
`used, Patent Owner has shown that Mr. Wechselberger “used incorrect criteria”
`
`(i.e., the incorrect evidentiary standard) because he used none.
`
`When questioned about what evidentiary standards are and which he used,
`
`Mr. Wechselberger could neither articulate what the difference was between
`
`“substantial evidence” and “prepondereance of the evidence”, nor could he
`
`articulate which standard he was supposed to use when alleging invalidity of
`
`claims in a patent. Exhibit 2025, 388:13-389:6. More specifically, Mr.
`
`Wechselberger testified:
`
`388: 13
`
`Q. If I could ask you, do you have an understanding of
`
`what substantial evidence is as it relates to relative burdens of proof?
`
`MS. ROBINSON: Objection to form.
`
`A. I don't think that I have used that term in any of my reports
`
`or declarations in conjunction with this case.
`
`Q. Do you have an understanding of what the standard
`
`"preponderance of the evidence" is?
`
`MS. ROBINSON: Objection to form.
`
`A. I don't think I've used that in any of my reports or
`
`declarations.
`
`BY MR. CASEY:
`
`
`
`- 5 -
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`
`
`389:2
`
`Q. Do you have an understanding as to what the standard
`
`called "clear and convincing evidence" is?
`
`MS. ROBINSON: Objection to form.
`
`A. Well, I understand these are all legal terms, and to the extent
`
`that I need to have a firm grip on their legal meaning, that is -- always
`
`ends up in one of my expert reports or a declaration. And, again, I
`
`don't know if that term has been so written out in any of my written
`
`materials.
`
`Q. Do you have an understanding that one has to show
`
`invalidity of a patent based on the legal standard of substantial
`
`evidence?
`
`MS. ROBINSON: Objection to form.
`
`A. Well, since I have just testified that I don't recall if the term
`
`"substantial evidence" appears in any of my reports, then I wouldn't
`
`have an understanding here today without having my report where
`
`that is explained.
`
`Q. So then it's also fair to say you don't have an understanding
`
`as to whether or not one has to show invalidity of a patent based on
`
`preponderance of the evidence?
`
`MS. ROBINSON: Objection to form.
`
`
`
`- 6 -
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`
`
`390:2
`
`A. Again, without the guidance of my report where that's
`
`been written out, I can look at it and read it, I'm not going to pretend
`
`that from a legal standpoint I have a firm grasp on all the four corners
`
`of the implications of those statements.
`
`
`
`No standard of evidence is disclosed in the 00108 and 00109 Wechselberger
`
`Declarations for the amount of evidence that he used in arriving at his allegations
`
`of unpatentability. Thus, based on the fact that Mr. Wechselberger testified that he
`
`did not know the difference between the standards or what standard to use, the
`
`PTAB can only afford little or no weight to the testimony therein. To do otherwise
`
`would be to accept his opinions without knowing “the underlying facts ... on which
`
`the opinion is based” (i.e., how much evidence he thinks shows any of his opinions
`
`discussed therein).
`
`For example, when Mr. Wechselberger opines that he believes a statement to
`
`be true (e.g., there is a motivation to modify a reference), is that belief based on
`
`less than a preponderance of the evidence, or more? Without his having disclosed
`
`what level of evidence he used, and given that he did not even know what level he
`
`was supposed to be using, the PTAB cannot rely on his statements. Thus, the
`
`PTAB should find that his declaration is entitled to little or no weight.
`
`
`
`
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`- 7 -
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`
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`IV. CLAIM CONSTRUCTION
`
`Petitioner has alleged that “payment data” should be construed to mean
`
`“data representing payment made for requested content data” and is distinct from
`
`“access control data.” See, for example, 00109 Petition at 25. However, no claim
`
`currently being challenged recites “payment data,” so the issue is moot in this
`
`proceeding.
`
`
`
`V. OBVIOUSNESS GROUNDS AGAINST CLAIM 26 OF THE ‘598
`
`PATENT
`
`
`
`A. Obviousness in Light of Stefik ‘235 and Stefik ‘980
`
`The Decision held that “we are not persuaded that Apple has established that
`
`it is more likely than not that claims 1, 2, 7, 13, 15, and 31 are unpatentable as
`
`anticipated by Stefik ’235 and Stefik ’980.” Decision at 15.
`
`However, the Decision further held “Apple has established that it is more
`
`likely than not that claim 26 is unpatentable as obvious over the combination of
`
`Stefik ’235 and Stefik ’980, but has not established that is more likely than not that
`
`claims 1, 2, 7, 13, 15, and 31 are unpatentable as obvious over Stefik ’235 and
`
`Stefik ’980.” Decision at 15. For the reasons set forth below, the 00108 Petition
`
`has not shown that it is more likely than not that the Stefik ‘235 and Stefik ‘980,
`
`either alone or in combination, renders obvious claim 26.
`
`
`
`- 8 -
`
`
`
`Claim 26 recites “A portable data carrier comprising: ... a subscriber identity
`
`module (SIM) portion storing identification data to identify a user of said portable
`
`data carrier to a network operator.” At page 15, the Decision held:
`
`with respect to claim 26, Apple argues that “[a] POSITA would have
`
`been motivated and found it obvious to employ a memory card for a
`
`mobile or cellular device that included a SIM portion that identifies a
`
`subscriber to a network operator, such as a mobile phone, as a
`
`repository in Stefik’s content distribution and access network.”
`
`
`
`However, the 00108 Petition has not shown that it is more likely than not that one
`
`of ordinary skill in the art would “have been motivated and found it obvious to
`
`employ a memory card for a mobile or cellular device that included a SIM portion
`
`that identifies a subscriber to a network operator, such as a mobile phone, as a
`
`repository in Stefik’s content distribution and access network.” Exhibit 2030, ¶ 13.
`
`Neither the 00108 Petition nor Mr. Wechselberger’s declaration cited therein
`
`explains why one of ordinary skill in the art, looking at Stefik ‘235 and Stefik ‘980,
`
`would have been motivated to “employ a memory card for a mobile or cellular
`
`device that included a SIM portion that identifies a subscriber to a network
`
`operator.” Neither patent identifies anything that indicates that a DocuCard or a
`
`
`
`- 9 -
`
`
`
`repository could be a mobile or cellular phone in which such a memory card would
`
`be used. Exhibit 2030, ¶ 14.
`
`Given that there is no disclosure of using a mobile or cellular phone as the
`
`repository or DocuCard of Stefik ‘235 or Stefik ‘980, there is no reason to change
`
`from the “unique number assigned to the DocuCard upon manufacture” to some
`
`other identifying information. Exhibit 2030, ¶ 14. Neither the 00108 Petition nor
`
`Mr. Wechselberger’s declaration cited therein addresses why such a change would
`
`be necessary. They also do not disclose whether the “unique number assigned to
`
`the DocuCard upon manufacture” has characteristics that would make it
`
`compatible with the SIM portion of a mobile phone, for example, whether the
`
`number of bits required by the “unique number assigned to the DocuCard upon
`
`manufacture” is greater than the number of bits that a SIM portion would utilize to
`
`identify a subscriber to a network operator. Exhibit 2030, ¶ 14. Thus, the 00108
`
`Petition does not show that it is more likely than not that one skilled in the art
`
`would have found it obvious to use a SIM portion that identifies a subscriber to a
`
`network operator as the “unique number assigned to the DocuCard upon
`
`manufacture” in Stefik ‘235. Exhibit 2030, ¶ 14.
`
`Further, the 00108 Petition has not shown that one of ordinary skill in the art
`
`“would have been motivated and found it obvious to employ a memory card for a
`
`mobile or cellular device that included a SIM portion … as a repository in Stefik’s
`
`
`
`- 10 -
`
`
`
`content distribution and access network,” since the structure and function of the
`
`alleged memory card has not been disclosed by the 00108 Petition as meeting the
`
`requirements of a repository according to Stefik ‘235 and Stefik ‘980. Exhibit
`
`2030, ¶ 16. For example, there is no discussion in the 00108 Petition that shows
`
`that the alleged memory card for a mobile or cellular device that included a SIM
`
`portion would be able to perform the registration process described with respect to
`
`Figure 3 of Stefik ‘235. Exhibit 2030, ¶ 16. Col. 6, lines 47-56, discloses:
`
`Referring to FIG. 3, the DocuCard and repository initiate
`
`registration transactions, step 301. Registration is a process by which
`
`two repositories establish a secure and trusted session. By secure and
`
`trusted it is meant that the session is reasonably safe from intrusion
`
`and that the respective repositories have established themselves as
`
`bona fide (i.e. not an intruder). The registration process is automatic
`
`and is triggered by the establishment of the electrical connection
`
`between the DocuCard and repository.
`
`If the alleged memory card cannot act as a repository, this further indicates
`
`that there is no motivation to employ a mobile or cellular device that included a
`
`SIM portion as a repository in Stefik’s content distribution and access network.
`
`Exhibit 2030, ¶ 17.
`
`
`
`- 11 -
`
`
`
`Thus, the 00108 Petition has not shown that it is more likely than not that
`
`Stefik ‘235 and Stefik ‘980, either alone or in combination, renders claim 26 of the
`
`‘598 patent obvious. Exhibit 2030, ¶ 18.
`
`
`
`B. Obviousness in Light of Ginter
`
`Claim 26 recites “A portable data carrier comprising: ... a subscriber identity
`
`module (SIM) portion storing identification data to identify a user of said portable
`
`data carrier to a network operator.” Just as the SIM portion limitation is not
`
`rendered obvious by Stefik ‘235 and Stefik ‘980, it is also not rendered obvious by
`
`Ginter. At page 20 the Decision held:
`
`With respect to the “subscriber identity module (SIM)” recited
`
`in claim 26, Apple argues that “a POSITA would have considered it at
`
`minimum obvious for the portable data carrier (e.g. electronic
`
`appliance) to communicate with Ginter’s network using a cellular
`
`connection and therefore to include a subscriber identity module
`
`(SIM) portion.” ... On this record, we are persuaded that a SIM would
`
`have been obvious in view of Ginter.
`
`The 00109 Petition, however, does not show that it is more likely than not
`
`that one of ordinary skill in the art would have considered it obvious for the
`
`portable data carrier (e.g. electronic appliance) to communicate with Ginter’s
`
`
`
`- 12 -
`
`
`
`network using a cellular connection, or to include a subscriber identity module
`
`(SIM) portion. The 00109 Petition also does not show that it is more likely than
`
`not that one of ordinary skill in the art would have considered it obvious to include
`
`a SIM portion in Ginter’s PEA. Exhibit 2030, ¶ 20.
`
`In support of its obviousness allegation, the 00109 Petition (pages 72-73)
`
`cites col. 161, lines 5-11, which states that communications with a clearinghouse
`
`“may be initiated across the electronic highway 108, or across other
`
`communications networks such as a LAN, WAN, two-way cable or using portable
`
`media exchange between electronic appliances.” However, the citation of wired
`
`networks for transmission in the environment of Ginter is not sufficient to show
`
`that communications with Ginter’s network using cellular communications is
`
`obvious, especially in light of the fact that Ginter repeatedly stresses the
`
`importance of secure communications and physical-security mechanisms. See
`
`Ginter, col. 63, lines 42-67. The transmission of information using wired
`
`transmissions is more secure against eavesdropping than wireless transmissions, a
`
`point that is ignored by the 00109 Petition. Exhibit 2030, ¶ 21. Given that Ginter
`
`limited its disclosure in col. 161, lines 5-11, to wired transmissions, the 00109
`
`Petition has not shown that it is more likely than not that one of ordinary skill in
`
`the art would have believed that cellular transmissions were obvious. Exhibit
`
`2030, ¶ 21.
`
`
`
`- 13 -
`
`
`
`Page 73 of the 00109 Petition also cites to col. 233, lines 53-57 which states
`
`“The portable device auxiliary terminal might be ‘on-line,’ that is electronically
`
`communicating back to a commercial establishment and/or third party information
`
`collection point through the use of cellular, satellite, radio frequency, or other
`
`communications means.” However, such a discussion is not describing cellular
`
`communication by the electronic appliance or PEA, but rather communication by
`
`an “auxiliary terminal” to see if the appliance is trustworthy. Exhibit 2030, ¶ 22.
`
`Ginter states, in the paragraph crossing cols. 233 and 234:
`
`The auxiliary terminal might, after a check by a commercial
`
`party in response to receipt of certain identification information at the
`
`collection point, communicate back to the auxiliary terminal whether
`
`or not to accept the portable appliance 2600 based on other
`
`information, such as a bad credit record or a stolen portable appliance
`
`2600. Such a portable auxiliary terminal would also be very useful at
`
`other commercial establishments, for example at gasoline stations,
`
`rental car return areas, street and stadium vendors, bars, and other
`
`commercial establishments where efficiency would be optimized by
`
`allowing clerks and other personnel to consummate transactions at
`
`points other than traditional cash register locations.
`
`
`
`- 14 -
`
`
`
`Further, as even admitted on page 68 of the 00109 Petition, Ginter 229:13-
`
`18 already discloses that “[p]ortable appliance 2600 RAM 534 may contain, for
`
`example, information which can be used to uniquely identify each instance of the
`
`portable appliance.” Thus, there is no reason to change from the “information
`
`which can be used to uniquely identify each instance of the portable appliance” to
`
`some other identifying information. Exhibit 2030, ¶ 23. Neither the 00109
`
`Petition nor Mr. Wechselberger’s declaration cited therein addresses why such a
`
`change would be necessary. They also do not disclose whether the “information
`
`which can be used to uniquely identify each instance of the portable appliance” has
`
`characteristics that would make it compatible with the SIM portion of a mobile
`
`phone, for example, whether the number of bits required by the “information
`
`which can be used to uniquely identify each instance of the portable appliance” is
`
`greater than the number of bits that a SIM portion would utilize to identify a
`
`subscriber to a network operator. Exhibit 2030, ¶ 23. The length of this
`
`information can directly affect the security of the system as Ginter discloses that
`
`the “information may be employed (e.g. as at least a portion of key or password
`
`information) in authentication, verification, decryption, and/or encryption
`
`processes.” Col. 229, lines 14-17. Thus, the 00109 Petition does not show that it
`
`is more likely than not that one skilled in the art would have found it obvious to
`
`use a SIM portion as the identifier in Ginter. Exhibit 2030, ¶ 23. The 00109
`
`
`
`- 15 -
`
`
`
`Petition therefore also has not shown that it is more likely than not that Ginter
`
`renders claim 26 of the ‘598 patent obvious. Exhibit 2030, ¶ 24.
`
`
`
`VI. CONCLUSION
`
`
`
`Thus, claim 26 of the ‘598 patent should be found to be VALID.
`
` /
`
` Michael R. Casey /
`
`
`Michael R. Casey
`Registration No. 40,294
`Davidson Berquist Jackson &
`
`Gowdey, LLP
`4300 Wilson Blvd, Suite 700
`Arlington, VA 22203
`Telephone: (703) 894-6406
`Fax: (703) 894-6430
`Email: mcasey@dbjg.com
`
`
`
`
`Dated: February 27, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`- 16 -
`
`
`
`CERTIFICATE OF SERVICE
`
`
`The undersigned hereby certifies that this PATENT OWNER’S RESPONSE
`
`TO PETITION (including Patent Owner’s List of Exhibits and Exhibits 2006,
`
`2007, 2008, 2013, 2019, 2020, 2021, 2025, and 2030) in CBM2014-00108 was
`
`served, by agreement of the parties, February 27, 2015 by emailing copies to
`
`counsel for the Petitioner as follows:
`
`Steven.Baughman@ropesgray.com
`Ching-Lee.Fukuda@ropesgray.com
`ApplePTABService-SmartFlash@ropesgray.com
`
`
`
`
`
` /
`
` Michael R. Casey /
`
`
`Michael R. Casey
`Registration No. 40,294
`Davidson Berquist Jackson &
`
`Gowdey, LLP
`4300 Wilson Blvd, Suite 700
`Arlington, VA 22203
`Telephone: (703) 894-6406
`Fax: (703) 894-6430
`Email: mcasey@dbjg.com
`Attorney for Patent Owner
`
`
`
`Dated: February 27, 2015
`
`
`
`
`
`- 17 -
`
`
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