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
`
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`PATENT OWNER’S OPPOSITION TO PETITIONER APPLE INC.’S
`MOTION TO EXCLUDE UNDER 37 C.F.R. §§ 42.62 AND 42.64
`
`
`
`
`
`1 Case CBM2014-00109 has been consolidated with the instant proceeding.
`
`
`
`
`
`________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`APPLE INC.,
`Petitioner,
`v.
`SMARTFLASH LLC,
`Patent Owner.
`________________________
`Case CBM2014-001081
`Patent 8,061,598
`
`
`
`
`
`
`
`
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`PATENT OWNER’S OPPOSITION TO PETITIONER APPLE INC.’S
`MOTION TO EXCLUDE UNDER 37 C.F.R. §§ 42.62 AND 42.64
`
`
`
`
`
`1 Case CBM2014-00109 has been consolidated with the instant proceeding.
`
`
`
`
`
`
`TABLE OF CONTENTS
`
`
`
`Introduction .......................................................................................................... 1
`I.
`II. Dr. Katz’s Declaration Should Not Be Excluded ................................................ 1
`A. Dr. Katz Qualifies as an Expert Whose Testimony is Admissible. ...... 1
`B.
`Petitioner’s Criticism of Dr. Katz is Unfair and Unfounded. ............... 4
`C. Dr. Katz Provides Relevant Testimony About Deficiencies in the
`Petition That Will Assist the Board in Understanding the Technical
`Evidence and Determining the Facts Regarding Patentability of the
`Claims at Issue. ...................................................................................... 9
`Patent Owner’s References to and Reliance on Dr. Katz’s Testimony
`in Patent Owner’s Response (Paper 23) Should Not be Excluded. .... 13
`III. Conclusion ...................................................................................................... 13
`
`D.
`
`
`
`i
`
`
`
`I.
`
`Introduction
`
`Patent Owner Smartflash, LLC opposes Petitioner Apple Inc.’s Motion to
`
`Exclude, which seeks to exclude Exhibit 2030 (Declaration of Jonathan Katz,
`
`Ph.D. in Support of Patent Owner’s Response to Petition), and any reference to or
`
`reliance on Dr. Katz’s declaration in Patent Owner’s Response (Paper 23). Motion
`
`to Exclude, Paper 37, at 3.
`
`Petitioner’s Motion to Exclude should be denied because Dr. Katz qualifies
`
`as an expert and his declaration testimony meets the requisites of FRE 702.
`
`Petitioner’s attack on Dr. Katz’s qualifications as an expert is unwarranted.
`
`Petitioner’s attack relies on deposition excerpts in which Petitioner examined Dr.
`
`Katz with ambiguously broad questions and/or on subject matter that was unrelated
`
`to the specific opinions he rendered about the application of the prior art references
`
`to the patent claims under review in this proceeding. Trying to discredit Dr. Katz,
`
`Petitioner strings together a litany of things that Dr. Katz was “not sure” about at
`
`his deposition, but that does not change or undermine Dr. Katz’s declaration about
`
`instances in which the Petition incorrectly alleges the existence of claim elements
`
`in the prior art references upon which this review was instituted.
`
`II. Dr. Katz’s Declaration Should Not Be Excluded
`A. Dr. Katz Qualifies as an Expert Whose Testimony is Admissible.
`Federal Rule of Evidence 702 provides:
`
`RULE 702. TESTIMONY BY EXPERT WITNESSES
`1
`
`
`
`
`
`A witness who is qualified as an expert by knowledge,
`skill, experience, training, or education may testify in the
`form of an opinion or otherwise if:
`(a) The expert’s scientific, technical, or other specialized
`knowledge will help the trier of fact to understand the
`evidence or to determine a fact in issue;
`(b) The testimony is based on sufficient facts or data;
`(c) The testimony is the product of reliable principles and
`methods; and
`(d) The expert has reliably applied the principles and
`methods to the facts of the case.
`
`FRE 702.
`
`The technology at issue in this proceeding generally relates to data storage
`
`and access systems, including portable data carriers for storing and paying for data
`
`and to computer systems for providing access to that data. Ex. 1001 at 00020,
`
`1:20-25. Dr. Katz earned a Ph.D. (with distinction) in Computer Science from
`
`Columbia University, has been a professor at University of Maryland since 2002,
`
`and has been working in the cybersecurity field since at least May 1999 (Ex. 2030
`
`at 16-17). He is qualified as an expert by knowledge, skill, experience, training,
`
`and education. As is clear from Dr. Katz’s declaration, he has reviewed the state
`
`of the art at the time of patent application filing, the patent claims at issue, the prior
`
`art references on which this proceeding was instituted, and he analyzed how
`
`Petitioner applies the references to the elements of the claims at issue. Ex. 2030 ¶¶
`
`10-24. As such, Dr. Katz’s testimony is based on sufficient facts or data, is the
`
`product of reliable principles and methods, and Dr. Katz has reliably applied the
`
`
`
`2
`
`
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`principles and methods to the facts of the case. Here, Dr. Katz’s declaration
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`succinctly points out areas in which the Petition incorrectly alleges the existence of
`
`claim elements in the prior art references on which this covered business method
`
`review was instituted. As such, Dr. Katz’s declaration testimony will help the
`
`Board understand the technical evidence and determine the facts regarding
`
`patentability of the claims under review. Dr. Katz’s testimony is admissible under
`
`FRE 702.
`
`Dr. Katz is qualified to testify about what a person having ordinary skill in
`
`the art (“POSITA”) would have known at the priority date, even if he did not meet
`
`the definition at the time. There is no requirement that Dr. Katz had to be a
`
`POSITA at the priority date. Therasense, Inc. v. Becton, Dickinson & Co., 593
`
`F.3d 1289, 1321 (Fed. Cir. 2010)(“Although [the expert] did not possess [the
`
`POSITA] qualifications in 1983 (the invention date of the … patent), this fact
`
`would not disqualify him from giving a competent opinion in 1995 as to what a
`
`hypothetical person of ordinary skill would have known in 1983”). Here, at the
`
`time Dr. Katz rendered his opinions, his qualifications met his POSITA definition.
`
`This is distinguishable from Extreme Networks, cited by Petitioner, in which the
`
`expert did not meet the POSITA definition at the time of rendering her opinion.
`
`Extreme Networks, Inc. v. Enterasys Networks, Inc., 395 Fed. Appx. 709, 715 (Fed.
`
`Cir. 2010)(expert opined that POSITA had Bachelor of Computer Science or
`
`
`
`3
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`
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`computer engineering degree, or equivalent experience, and 2-3 years experience
`
`in computer industry working on design or development of high speed switches,
`
`bridges, or routers for various networks, whereas expert had Associate of Applied
`
`Science degree in Computer Programming and “never seems to have worked on
`
`‘the design or development of high speed switches, bridges, or routers’”).
`
`Petitioner’s Criticism of Dr. Katz is Unfair and Unfounded.
`
`B.
`Petitioner’s criticism of Dr. Katz that he “was repeatedly unable to answer
`
`whether a POSITA would have known or understood various basic principles and
`
`technologies pertinent to the ’598 patent in the relevant time period” (Motion to
`
`Exclude at 5) is unfair and unfounded.
`
`At Dr. Katz’s deposition, Petitioner never established whose definition of a
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`POSITA Dr. Katz was to use. Ex. 1031 at 180:2-6. Dr. Katz’s definition is “a
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`bachelor’s degree in electrical engineering or its equivalent, or at least 5 years of
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`experience in manufacturing or engineering, with significant exposure to the digital
`
`content distribution and/or e-commerce industries.” Ex. 2030 ¶ 9. Petitioner’s
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`definition is “at least a Bachelor of Science degree in electrical engineering,
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`computer science or a telecommunications related field, and at least three years of
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`industry experience that included client-server data/information distribution and
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`management architectures.” Ex. 1021 ¶ 31. While there is obvious overlap, there
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`exist some people who would qualify as a POSITA under one definition who
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`
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`4
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`
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`would not meet the other definition. At deposition, there were times Dr. Katz
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`could not be sure what a POSITA would know without Petitioner defining a
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`POSITA for deposition purposes. For example Dr. Katz had no problem opining
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`that in the prior art time period a POSITA (by whatever definition) would know
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`what a merchant server was (Ex. 1031 at 19:3-10), but he was “not sure” whether
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`in the prior art time period a POSITA would have understood that digital content
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`could be bought and sold over a network or over the internet (id. at 13:16-14:3).
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`Certainly Dr. Katz’s POSITA with digital content distribution and/or e-commerce
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`experience would have understood, but that is not clear for Petitioner’s POSITA.
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`The Board should not fault Dr. Katz for answering the questions he was asked.
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`Moreover, the principal examples that Petitioner uses – that “Dr. Katz
`
`testified he was ‘not sure’ whether in the prior art time period a POSITA would
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`have ‘known how to carry out an electronic payment to sell digital content’ or
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`‘known how to implement an electronic sale of digital content’ (Motion to Exclude
`
`at 5-6 (citing Ex. 1031 at 21:12-16, 23:2-15)) resulted from questions so broad and
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`lacking context that an “I’m not sure” response was appropriate. For example, did
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`Petitioner mean “carry out an electronic payment to sell digital content” and
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`“implement an electronic sale of digital content” with the apparatus and methods
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`described and claimed in the ‘598 Patent? If that was the question, then the answer
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`would have been “no,” because the apparatus and methods were novel. Did
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`
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`5
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`
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`Petitioner mean “carry out an electronic payment to sell digital content” and
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`“implement an electronic sale of digital content” in some other specific, but
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`undefined, manner? That is not possible to answer without defining the specific
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`manner the questioner had in mind. The Board should not fault Dr. Katz for doing
`
`his best to answer the questions he was asked. It was not Dr. Katz’s job at the
`
`deposition to constrain the breadth of the questions or to seek out the context of the
`
`question. He answered the questions he was asked. Here, the “I’m not sure”
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`reflects the quality of the question, not the qualifications of the witness.
`
`Petitioner completely misconstrues the record in asserting “Dr. Katz was
`
`unable to defend his opinions regarding the ‘subscriber identity module (SIM)
`
`portion’ claimed in the ’598 patent. In his declaration, Dr. Katz interprets this
`
`limitation as requiring a SIM card… .” Motion to Exclude at 7. Dr. Katz did not
`
`interpret the “SIM portion” limitation as requiring a SIM card. Rather, Dr. Katz’s
`
`declaration contests Petitioner’s contention that one skilled in the art would “have
`
`been motivated and found it obvious to employ a memory card for a mobile or
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`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” Ex. 2030 ¶ 13.
`
`Petitioner’s criticism that “Dr. Katz confirmed in his deposition … that he
`
`had not considered differences between the SIM portion recited in the challenged
`
`
`
`6
`
`
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`claims and the SIM card device recited in other claims” (Motion to Exclude at 7-8)
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`criticizes Dr. Katz over an issue – the difference between a “SIM portion” and a
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`“SIM card device” – that simply does not exist. Claim 26 of the ‘598 Patent
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`claims “A portable data carrier, comprising, … a subscriber identity module (SIM)
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`portion to identify a subscriber to a network operator.” The “SIM portion” refers
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`back to the portable data carrier; i.e., it is a portion of the portable data carrier. The
`
`SIM portion of the portable data carrier can be a SIM card or some other discrete
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`part of the portable data carrier that acts as a SIM in the portable data carrier. The
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`Petition alleges that “a POSITA would have been motivated to employ a memory
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`card for a mobile or cellular device that included a SIM portion that identifies a
`
`subscriber to a network operator… .” Petition at 65, n. 17 (emphasis added). Dr.
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`Katz’ declaration, therefore, was directed to whether the prior art showed
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`motivation to employ whole memory cards to satisfy the claim element, and not
`
`differences between a SIM portion and a SIM card. As such, the criticism is
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`unwarranted.
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`Petitioner’s criticism of Dr. Katz that he “was not sure and did not have an
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`opinion on whether a memory address, a block of memory, or a single block of
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`memory storing only a single user identification number, like those disclosed in
`
`Stefik and Ginter, could be a ‘SIM portion’” (Motion to Exclude at 8) is similarly
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`without merit. Claim 26 of the ‘598 Patent claims “[a] portable data carrier,
`
`
`
`7
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`
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`comprising, … a subscriber identity module (SIM) portion…”. The claimed
`
`portable data carrier is comprised of, among other things, a SIM portion. What
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`internal structures the SIM portion could be comprised of, be it “a memory
`
`address,” “a block of memory,” or “a single block of memory storing only a single
`
`user identification number” as asked in the deposition is beyond the scope of the
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`positions taken in the Petition, and further is neither the subject of the claim nor the
`
`subject of this proceeding. The Petition alleges that “a POSITA 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… .” Petition at 65,
`
`n. 17 (emphasis added). Dr. Katz’ declaration, therefore, was directed to whether
`
`the prior art showed motivation to employ whole memory cards to satisfy the claim
`
`element, not what other things undisclosed in the Petition might satisfy the claim
`
`element.
`
`Similarly, Petitioner’s criticism that “[a]t his deposition … Dr. Katz was
`
`unable to identify any reason a POSITA would not be able to conform these
`
`identifiers—including the Stefik identifier explicitly addressed in his declaration—
`
`to meet the public specification of a SIM card” (Motion to Exclude at 9) misses the
`
`mark. In addition to the issue noted above that Petitioner never told Dr. Katz
`
`whose definition of a POSITA to use in answering deposition questions, the
`
`testimony sought was outside the scope of this proceeding. Claim 26 of the ‘598
`
`
`
`8
`
`
`
`Patent claims “[a] portable data carrier, comprising, … a subscriber identity
`
`module (SIM) portion…”. The claimed portable data carrier is comprised of,
`
`among other things, a SIM portion. The SIM portion of the portable data carrier
`
`can be a SIM card or some other discrete part of the portable data carrier that acts
`
`as a SIM in the portable data carrier. But “whether a person skilled in the art
`
`would have known to align the unique number assigned to the repository as
`
`referenced in Stefik ‘980 patent Column 13 with the specified byte format of a
`
`SIM card” (Ex. 1031 164:18-165:8) is nothing but another attempt by Petitioner to
`
`parse “a subscriber identity module (SIM) portion” into previously undisclosed
`
`elements. The composition of the SIM portion, including whether the unique
`
`number assigned to the repository as referenced in Stefik ‘980 could be aligned to
`
`the specified byte format of a SIM card, was not alleged in the Petition and is not
`
`the subject of this proceeding. As such, criticism of Dr. Katz for answering “I’m
`
`not sure” is unfair and unfounded.
`
`C. Dr. Katz Provides Relevant Testimony About Deficiencies in the
`Petition That Will Assist the Board in Understanding the
`Technical Evidence and Determining the Facts Regarding
`Patentability of the Claims at Issue.
`
`Dr. Katz provides relevant testimony about instances where the Petition
`
`incorrectly alleges the existence of claim elements in the prior art references that
`
`will help the Board understand the technical evidence and determine the facts
`
`
`
`9
`
`
`
`regarding patentability of the claims under review. For example Dr. Katz shows
`
`that:
`
`•
`
`Stefik ‘235 and Stefik ‘980 do not disclose, with respect to Claim 26, “a
`
`subscriber identity module (SIM) portion storing identification data to identify a
`
`user of said portable data carrier to a network operator” because the 00108 and
`
`00109 Petitions’ support for that claimed limitation is lacking. Dr. Katz
`
`demonstrates that the 00108 and 00109 Petitions have not “shown that it is more
`
`likely than not that one of ordinary skill in the art, as of the earliest foreign and
`
`domestic priority dates of the ‘598 patent, 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” (Ex.
`
`2030 ¶ 13) because (i) neither Stefik ‘235 nor Stefik ‘980 “identifies anything that
`
`indicates that a DocuCard or a repository could be a mobile or cellular phone in
`
`which such a memory card would be used” (id. ¶ 14); (ii) “given that there is no
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`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” (id. ¶ 15); (iii) there is no disclosure to support that “the ‘unique
`
`number assigned to the DocuCard upon manufacture’ has characteristics that
`
`
`
`10
`
`
`
`would make it compatible with the SIM portion of a mobile phone” (id.); (iv) “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” (id. ¶ 16); (v) “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 [in] Stefik
`
`‘235” (id.); and “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” (id. ¶ 17).
`
`•
`
`Ginter does not disclose, with respect to Claim 26, “a subscriber identity
`
`module (SIM) portion storing identification data to identify a user of said portable
`
`data carrier to a network operator” because the 00109 Petition’s evidence of
`
`support for this in Ginter is lacking. The 00109 Petition 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 network using a cellular connection, or to include a subscriber
`
`identity module (SIM) portion.” Ex. 2030 ¶ 20. This is because (i) one of the
`
`00109 Petition’s support of its obviousness allegation is Ginter 161:5-11, “which
`
`states that communications with a clearinghouse ‘may be initiated across the
`
`
`
`11
`
`
`
`electronic highway 108, or across other communications networks such as a LAN,
`
`WAN, two-way cable or using portable media exchange between electronic
`
`appliances,’” but “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”(Ex. 2030 ¶ 21 (citing Ginter 63:42-67)(emphasis
`
`added)); (ii) another of the 00109 Petition’s support of its obviousness allegation is
`
`Ginter 233:53-57 “which states that ‘the portable device auxiliary terminal might
`
`be ‘on-line,’ that is electronically communicating back to a commercial
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`establishment and/or third party information collection point through the use of
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`cellular, satellite, radio frequency, or other communications means,’” but that
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`“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” (Ex. 2030 ¶ 24); and (iii) neither the 00109 Petition nor Mr.
`
`Wechselberger’s declaration explains why it would be necessary to change to a
`
`SIM portion to identify a subscriber to a network operator when Ginter’s device
`
`already contains “information which can be used to uniquely identify each instance
`
`of the portable appliance” (Ex. 2030 ¶ 23) and (iv) neither the 00109 Petition nor
`
`Mr. Wechselberger’s declaration explains “whether the ‘information which can be
`
`
`
`12
`
`
`
`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” (id.).
`
`As can be seen from the above synopsis, Dr. Katz’s declaration testimony is
`
`relevant and will help the Board understand the technical evidence showing
`
`deficiencies in the Petition’s application of the subject prior art and determine the
`
`facts regarding patentability of the claims under review. It should not be excluded.
`
`D.
`
`Patent Owner’s References to and Reliance on Dr. Katz’s
`Testimony in Patent Owner’s Response (Paper 23) Should Not be
`Excluded.
`
`Because Dr. Katz is qualified and his declaration is admissible, the Board
`
`should not exclude any reference to, or reliance on, Dr. Katz’s declaration in Patent
`
`Owner’s Response (Paper 23).
`
`III. Conclusion
`For these reasons, Patent Owner Smartflash, LLC respectfully requests that
`
`the Board not exclude Exhibit 2030 (Declaration of Jonathan Katz, Ph.D. in
`
`Support of Patent Owner’s Response to Petition), or any reference to or reliance on
`
`Dr. Katz’s declaration in Patent Owner’s Response (Paper 23).
`
`
`
`13
`
`
`
`Dated: May 26, 2015
`
`
`
`
`
`
`
`/ Michael R. Casey /
`
`Michael R. Casey
`Registration No. 40,294
`Davidson Berquist Jackson & Gowdey, LLP
`8300 Greensboro Drive
`Suite 500
`McLean, VA 22102
`Telephone: (571) 765-7705
`Fax: (571) 765-7200
`Email: mcasey@dbjg.com
`Attorney for Patent Owner
`
`
`
`
`
`
`14
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that this PATENT OWNER’S
`
`OPPOSITION TO PETITIONER APPLE INC.’S MOTION TO EXCLUDE
`
`UNDER 37 C.F.R. §§ 42.62 AND 42.64 in CBM2014-00108 was served today, by
`
`agreement of the parties by emailing a copy to counsel for the Petitioner as
`
`follows:
`
`
`
`J. Steven Baughman (steven.baughman@ropesgray.com)
`Ching-Lee Fukuda (ching-lee.fukuda@ropesgray.com)
`Megan Raymond (megan.raymond@ropesgray.com)
`ApplePTABService-SmartFlash@ropesgray.com
`Ropes & Gray LLP
`
`
`
`
`
`
`Dated: May 26, 2015
`
` /
`
` Michael R. Casey /
`
`
`Michael R. Casey
`Registration No. 40,294
`Davidson Berquist Jackson & Gowdey, LLP
`8300 Greensboro Drive
`Suite 500
`McLean, VA 22102
`Telephone: (571) 765-7705
`Fax: (571) 765-7200
`Email: mcasey@dbjg.com
`Attorney for Patent Owner
`
`
`
`
`
`
`
`15
`
`
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