UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`APPLE INC.,
`Petitioner,
`v.
`SMARTFLASH LLC,
`Patent Owner.
`________________________
`Case CBM2014-001121
`Patent 7,942,317 B2
`
`
`
`
`
`
`
`
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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 CBM2014-00113 has been consolidated with the instant proceeding.
`
`
`
`
`
`________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`APPLE INC.,
`Petitioner,
`v.
`SMARTFLASH LLC,
`Patent Owner.
`________________________
`Case CBM2014-001121
`Patent 7,942,317 B2
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`PATENT OWNER’S OPPOSITION TO PETITIONER APPLE INC.’S
`MOTION TO EXCLUDE UNDER 37 C.F.R. §§ 42.62 AND 42.64
`
`
`1 Case CBM2014-00113 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. ...................................................................................... 8
`Patent Owner’s References to and Reliance on Dr. Katz’s Testimony
`in Patent Owner’s Response (Paper 22) 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 2031 (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 22). Motion
`
`to Exclude, Paper 35, 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. 2031
`
`at 17-18). 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. 2031 ¶¶
`
`10-31. 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
`
`
`
`principles and methods to the facts of the case. Here, Dr. Katz’s declaration
`
`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 of 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 computer
`
`
`
`3
`
`
`
`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 ‘317 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
`
`POSITA Dr. Katz was to use. Ex. 1031 at 180:2-6. Dr. Katz’s definition is “a
`
`bachelor’s degree in electrical engineering or its equivalent, or at least 5 years of
`
`experience in manufacturing or engineering, with significant exposure to the digital
`
`content distribution and/or e-commerce industries.” Ex. 2031 ¶ 9. Petitioner’s
`
`definition is “at least a Bachelor of Science degree in electrical engineering,
`
`computer science or a telecommunications related field, and at least three years of
`
`industry experience that included client-server data/information distribution and
`
`management architectures.” Ex. 1021 ¶ 28. While there is obvious overlap, there
`
`exist some people who would qualify as a POSITA under one definition who
`
`
`
`4
`
`
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`would not meet the other definition. At deposition, there were times Dr. Katz
`
`could not be sure what a POSITA would know without Petitioner defining a
`
`POSITA for deposition purposes. For example Dr. Katz had no problem opining
`
`that in the prior art time period a POSITA (by whatever definition) would know
`
`what a merchant server was (Ex. 1031 at 19:3-10), but he was “not sure” whether
`
`in the prior art time period a POSITA would have understood that digital content
`
`could be bought and sold over a network or over the internet (id. at 13:16-14:3).
`
`Certainly Dr. Katz’s POSITA with digital content distribution and/or e-commerce
`
`experience would have understood, but that is not clear for Petitioner’s POSITA.
`
`The Board should not fault Dr. Katz for answering the questions he was asked.
`
`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
`
`have ‘known how to carry out an electronic payment to sell digital content’ or
`
`‘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
`
`lacking context that an “I’m not sure” response was appropriate. For example, did
`
`Petitioner mean “carry out an electronic payment to sell digital content” and
`
`“implement an electronic sale of digital content” with the apparatus and methods
`
`described and claimed in the ‘317 Patent? If that was the question, then the answer
`
`would have been “no,” because the apparatus and methods were novel. Did
`
`
`
`5
`
`
`
`Petitioner mean “carry out an electronic payment to sell digital content” and
`
`“implement an electronic sale of digital content” in some other specific, but
`
`undefined, manner? That is not possible to answer without defining the specific
`
`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”
`
`reflects the quality of the question, not the qualifications of the witness.
`
`Petitioner’s other criticisms are similarly unfair and unfounded. Petitioner
`
`asserts that “at his deposition, Dr. Katz was not sure if Ginter’s disclosures fit his
`
`characterization of ‘pre-purchase processing’ even after consulting all of his
`
`declarations” (Motion to Exclude at 7, citing Ex. 1031 at 124:10-128:11) and that
`
`“[w]hen questioned by his own counsel, Dr. Katz testified that he did not even
`
`know what was meant by the term ‘pre-purchase processing’—the very term that
`
`he himself uses in his declaration” (id., citing Ex. 1031 at 190:14-20). This is a
`
`mischaracterization of the record. At deposition, upon first use of the term at
`
`124:13, Petitioner’s counsel never established what he meant by “pre-purchase
`
`processing” and never framed the question in terms of Dr. Katz’s definition or
`
`prior use of the term. Dr. Katz did not testify “that he did not even know what was
`
`meant by the term ‘pre-purchase processing,’” he testified that he did not know
`
`
`
`6
`
`
`
`what Petitioner’s counsel meant by the phrase pre-purchase processing. Ex. 1031
`
`at 190:14:20. It is unfair to claim that Dr. Katz “was not sure if Ginter’s
`
`disclosures fit his characterization of ‘pre-purchase processing’” when he was
`
`never asked the questions in that context.
`
`Petitioner’s criticisms of Dr. Katz’s regarding Ginter’s purported “disclosure
`
`of ‘payment data’” (Motion to Exclude at 8) similarly suffer from a lack of
`
`definition by Petitioner at the deposition. Dr. Katz’s definition of “payment data”
`
`differs from Petitioner’s definition. Ex. 2031 ¶ 11. Petitioner never established
`
`which definition to use and never asked about “payment data” in the context of the
`
`patent claims at issue. Ex. 1031 at 179:20-180:1. Moreover, the criticism that “Dr.
`
`Katz was not sure whether a POSITA would have understood that [“prepayments,”
`
`“credits,” “debits,” and “currency token deposit accounts” referred to in Ginter]
`
`could be used to pay for a VDE object” (Motion to Exclude at 8) is unfair given
`
`that Petitioner did not define a POSITA for deposition purposes, as detailed above.
`
`Petitioner’s other criticisms of Dr. Katz regarding what a POSITA would have
`
`known, such as whether a POSITA “knew what activating a credit account was” or
`
`“would have understood SIM cards could be used for billing) (Motion to Exclude
`
`at 7) are unfair for the same reason.
`
`Petitioner asserts that “at his deposition, Dr. Katz answered that he was not
`
`sure whether debit, debit transactions, or debit processing were in the prior art or if,
`
`
`
`7
`
`
`
`even today, debit cards are used to pay for goods electronically.” Motion to
`
`Exclude at 8-9 (citing Ex. 1031 at 31:14-17, 18:1-7, 18:15-20, 30:15-19, 32:5-14,
`
`33:5-10.). But the record shows that the questions were electronic transaction
`
`related and were generally framed in terms of what a POSITA would have known
`
`“in the prior art time period in connection with the sale of electronic content.” As
`
`noted above, Petitioner’s counsel never established whose definition of a POSITA
`
`should be used (Ex. 1031 at 180:2-6) and one of the differences between Dr.
`
`Katz’s and Petitioner’s definition is digital content distribution and/or e-commerce
`
`experience. Dr. Katz’s POSITA with such experience may have understood these
`
`payment concepts where Petitioner’s POSITA may not. The point is, without
`
`Petitioner establishing the definition for deposition purposes, Dr. Katz’s “I’m not
`
`sure” answers were accurate and do not reflect a lack of qualifications.
`
`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 to understand the technical evidence and to determine the facts
`
`regarding patentability of the claims under review. For example Dr. Katz shows
`
`that:
`
`
`
`8
`
`
`
`•
`
`Stefik ‘235 and Stefik ‘980 do not disclose, with respect to Claims 1, 6, and
`
`7, “a data access data store for storing records of data items available from the
`
`system, each record comprising a data item description and a pointer to a data
`
`provider for the data item” because the 00112 Petition has not “shown that it is
`
`more likely than not that one of ordinary skill in the art would have considered a
`
`start address for a string of bits to be the claimed ‘pointer to a data provider for the
`
`data item.’” Ex. 2031 ¶ 19. The 0012 Petition cites a number of portions of Stefik
`
`‘235 (Figs. 2 and 5a, Abstract, 2:35-36, 3:32-38, 6:2-17, and 7:22-32) “that
`
`disclose that a DocuCard can utilize a hierarchical file structure,” however “none
`
`of those citations discloses a pointer to a data provider.” Id. Another purported
`
`supporting cite in the 00102 Petition for “a pointer to a data provider for the data
`
`item” is Stefik ‘235, 7:63-8:10, “but the pointers described therein are pointers to
`
`other d-blocks in the description file, not pointers to data providers.” Id. Also, the
`
`“starting address 502 providing the start address of the first byte of the work”
`
`referenced in that cite is also not a “pointer to a data provider.” Id. Although
`
`Stefik ‘235, 7:35-42 states “The file information for a document is comprised of a
`
`‘contents file’ and a ‘description file.’… The description file contains the usage
`
`rights for the document and a pointer to the document in the content part,”
`
`however, “this is a pointer to the content part itself, not the claimed ‘data provider
`
`for the data item.’” The 00112 Petition cites Stefik ‘980, 9:54-10:1 as support for
`
`
`
`9
`
`
`
`“a pointer to a data provider,” however “the pointers are to other d-blocks in the
`
`description file, not pointers to data providers.” Id. ¶ 20. Also, the “starting
`
`address 702 providing the start address of the first byte of the work” referenced in
`
`that cite is also not a “pointer to a data provider.” Id. The additional citations to
`
`Stefik ‘980 10:26-32 and Table 1 “are for rights, rather than pointers.” Id. The
`
`citation to Stefik ‘980 14:28-39, “describes the storage system and that the storage
`
`system includes description tree storage 1203 and content storage 1204, and that
`
`those storages 1203 and 1204 may be on separate physical devices,” however,
`
`“that discussion does not disclose … the claimed ‘pointer to a data provider for the
`
`data item.’” Id.
`
`•
`
`Stefik ‘235 and Stefik ‘980 do not disclose, with respect to Claims 16, “a
`
`data access data store for storing records of data items available from the system,
`
`each record comprising a data item description and a resource locator identifying a
`
`data provider for the data item” because the 00112 Petition has not “shown that it
`
`is more likely than not that one of ordinary skill in the art would have considered a
`
`start address for a string of bits to be the claimed … ‘resource locator identifying a
`
`data provider for the data item.’” Ex. 2031 ¶ 19. The 0012 Petition cites a number
`
`of portions of Stefik ‘235 (Figs. 2 and 5a, Abstract, 2:35-36, 3:32-38, 6:2-17, and
`
`7:22-32) “that disclose that a DocuCard can utilize a hierarchical file structure,”
`
`however “none of those citations discloses … a resource locator identifying a data
`
`
`
`10
`
`
`
`provider for the data item.” Id. Another purported supporting cite in the 00112
`
`Petition for “a resource locator identifying a data provider for the data item” is
`
`Stefik ‘235, 7:63-8:10, “but the pointers described therein are pointers to other d-
`
`blocks in the description file, not … a resource locator identifying a data provider
`
`for the data item.” Id. Also, the “starting address 502 providing the start address
`
`of the first byte of the work” referenced in that cite is also not a “a resource locator
`
`identifying a data provider for the data item.” Id. Although Stefik ‘235, 7:35-42
`
`states “The file information for a document is comprised of a ‘contents file’ and a
`
`‘description file.’… The description file contains the usage rights for the document
`
`and a pointer to the document in the content part,” however, “this is a pointer to the
`
`content part itself, not “a resource locator identifying a data provider for the data
`
`item.’” Id. The 00112 Petition cites Stefik ‘980, 9:54-10:1 as support for “a
`
`resource locator identifying a data provider for the data item,” however “the
`
`pointers are to other d-blocks in the description file, not … a resource locator
`
`identifying a data provider for the data item.” Id. ¶ 20. Also, the “starting address
`
`702 providing the start address of the first byte of the work” referenced in that cite
`
`is also not a “a resource locator identifying a data provider for the data item.” Id.
`
`The citation to Stefik ‘980 14:28-39, “describes the storage system and that the
`
`storage system includes description tree storage 1203 and content storage 1204,
`
`and that those storages 1203 and 1204 may be on separate physical devices,”
`
`
`
`11
`
`
`
`however, “that discussion does not disclose … the claimed … ‘resource locator
`
`identifying a data provider for the data item.’” Id.
`
`•
`
`Ginter does not disclose, with respect to Claims 1, 6 and 7, “code to receive
`
`from the communications interface payment data comprising data relating to
`
`payment for the requested data item,” or with respect to Claim 16 “receiving
`
`payment data from the requester relating to payment for the requested data”
`
`because the 00113 Petition cites to Ginter’s “audit information” as the claimed
`
`“payment data,” but one of ordinary skill in the art would have not have considered
`
`such “audit information” to be “payment data.” Ex. 2031¶ 28. “Ginter itself
`
`acknowledges that auditing and payment are different” where Ginter states “SPU
`
`500 may also perform secure data management processes including governing
`
`usage of, auditing of, and where appropriate, payment for VDE objects 300.” Id.
`
`(citing Ginter 63:34-41). “[Ginter] 175:47-176:1 cited by the 00113 Petition
`
`likewise shows that audit information is post-usage information and not ‘payment
`
`data,’ when it states ‘a VDE repository may perform audit information
`
`clearinghouse services ... for usage information reported by VDE users.’” Id.
`
`Moreover, Ginter states that “the clearinghouse may analyze the contained audit
`
`information to determine whether it indicates misuse of the applicable VDE object
`
`300, which indicates the tracked usage has already occurred.” Id. ¶ 29. “To the
`
`extent that the Petition is relying on Ginter 63:34-41 as disclosing ‘real-time debits
`
`
`
`12
`
`
`
`from bank accounts,’” Dr. Katz notes that “the reference to ‘real-time debits from
`
`bank accounts’ [is] discussing real-time debits from bank accounts for paying for
`
`previous usage of VDE objects.” Id. ¶ 30.
`
`As can be seen from the above synopsis, Dr. Katz’s declaration testimony is
`
`relevant and will help the Board to understand the technical evidence showing
`
`deficiencies in the Petition’s application of the subject prior art and to 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 22) 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 22).
`
`III. Conclusion
`For these reasons, Patent Owner Smartflash, LLC respectfully requests that
`
`the Board not exclude Exhibit 2031 (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 22).
`
`
`
`
`
`
`
`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 CBM2014-00112 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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