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` Paper No. ______
`Filed: June 12, 2015
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`TD AMERITRADE HOLDING CORPORATION, TD AMERITRADE, INC., and
`TD AMERITRADE ONLINE HOLDINGS CORP.
`Petitioners
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`v.
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`TRADING TECHNOLOGIES INTERNATIONAL, INC.
`Patent Owner
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`Case CBM2014-00131
`Patent 7,533,056
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`Patent Owner’s Motion to Exclude
`Under 37 C.F.R. 42.64(c)
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`Case CBM2014-00131
`Patent No. 7,533,056
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`TABLE OF CONTENTS
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`I.
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`II.
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`Preliminary Statement ..................................................................................... 1
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`Standard ........................................................................................................... 2
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`III. The TSE Translation (Ex. 1004) Should Be Excluded ................................... 2
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`A.
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`TT Timely Objected to the TSE Translation, Which Was Relied
`Upon in TD’s Petition and Its Reply ..................................................... 2
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`B. All of the TSE Translation Should be Excluded for Failing to
`Comply with 37 C.F.R. § 42.63(b) ........................................................ 2
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`C.
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`In the Absence of Excluding All of TSE, At Least Pages 101-
`140 of the TSE Translation (Exhibit 1004) Should Be Excluded
`for Failing to Comply with 37 C.F.R. § 42.63(b) ................................. 7
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`IV. Dr. Román’s Supplemental Declaration (Ex. 1042) Should be
`Excluded ........................................................................................................10
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`A.
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`TT Timely Objected to the Supplemental Declaration, Which
`Was Relied Upon in TD’s Reply ........................................................10
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`B. Dr. Román’s Supplemental Declaration Lacks Relevance Under
`FRE 402 and is Prejudicial under FRE 403 ........................................10
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`Case CBM2014-00131
`Patent No. 7,533,056
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`I.
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`Preliminary Statement
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`Pursuant to 37 C.F.R. §§ 42.64(c) and 42.61(a) and the Federal Rules of
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`Evidence, Patent Owner Trading Technologies International, Inc. (“TT”), moves to
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`exclude the English translation of the TSE document (Ex. 1004), because the
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`translation fails to comply with the requirements of 37 C.F.R. § 42.63(b) and Fed.
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`R. Evid. 104(b) and 602-604. The original affidavit of Ms. O’Connell (Ex. 1005) is
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`defective because it was not made by a person having personal knowledge of the
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`translation. Because this defect is not curable by supplemental evidence, all of the
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`TSE translation should be excluded. Although subsequent affidavits were prepared
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`by Petitioner TD Ameritrade et al. (“TD” or “Petitioner”), one declarant, Mr.
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`Skidmore, denied that pages 101-140 of Ex. 1004 were his translation. For this
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`additional reason, at least pages 101-140 of Ex. 1004 should be excluded.
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`TT also moves to exclude the Supplemental Declaration of Kendyl A.
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`Román in Support of Petitioners’ Reply for Covered Business Method Review of
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`U.S. Patent 7,533,056 (Ex. 1042, “Supplemental Declaration”) because portions of
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`the Exhibit lack relevance (FRE 402), exceeding the proper scope of Petitioner’s
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`Reply under 37 C.F.R. § 42.23(b), and at least because of the prejudice resulting
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`from Patent Owner’s inability to respond to the untimely evidence and opinions
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`therein (FRE 403).
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`1
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`II.
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`Standard
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`A Motion to Exclude must (a) identify where in the record the objection was
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`made,1 (b) identify where in the record the evidence sought to be excluded was
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`relied upon by an opponent, (c) address objections to exhibits in numerical order,
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`and (d) explain the objection. Trial Practice Guide, 77 Fed. Reg. 48,756, 78,767
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`(Aug. 14, 2012).
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`III. The TSE Translation (Ex. 1004) Should Be Excluded
`A. TT Timely Objected to the TSE Translation,2 Which Was Relied
`Upon in TD’s Petition and Its Reply
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`TT objected to Exhibits 1003-1005 in objections served December 16, 2014.
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`Ex. 2273. TD relies upon the TSE translation (Ex. 1004) for all instituted prior art
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`grounds throughout its Petition and in its Reply. Pet., Paper 4 at 27-53; Reply,
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`Paper 48 at 12-18; I.D., Paper 19 at 19-23.
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`B. All of the TSE Translation Should be Excluded for Failing to
`Comply with 37 C.F.R. § 42.63(b)
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`When TD filed its Petition and the TSE translation, it filed an ineffective
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`1 Under the Rules published May 19, 2015, objections must now be filed. 80 Fed.
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`Reg. 28,561, 28,563. A copy of TT’s objections are being filed as Ex. 2273.
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`2 The Board determined that TT’s original objection to Exs. 1003-1005 preserved
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`its objections to the supplemental evidence (Exs. 1036-1040) and no further
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`objections were necessary. Ex. 3003 at 16:4-12.
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`2
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`Patent No. 7,533,056
`affidavit of Ms. Courtney O’Connell (Ex. 1005). Ms. O’Connell’s affidavit fails to
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`comply with § 37 C.F.R. § 42.63(b), which requires that “[w]hen a party relies on a
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`document . . . in a language other than English, a translation of the document into
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`English and an affidavit attesting to the accuracy of the translation must be filed
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`with the document.” A declarant “may testify to a matter only if evidence is
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`introduced sufficient to support a finding that the witness has personal knowledge
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`of the matter.” Fed. R. Evid. 602 (emphasis added). For foreign language
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`translations, a translation not certified as true and accurate is not admissible under
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`the Federal Rules of Evidence or the Board’s Rules. 37 C.F.R. § 42.63(b); City of
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`N.Y. v. Geodata Plus, LLC, 537 F. Supp. 2d 443, 448 n.9 (E.D.N.Y. 2007); cf.
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`Quiroga v. Fall River Music, Inc., No. 93-civ-2914, 1998 WL 851574 at *2 n.3
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`(S.D.N.Y. Dec. 7, 1998).
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`The accuracy of Ex. 1004 is a question of fact. Ms. O’Connell’s affidavits
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`(Exs. 1005 and 1040) cannot testify to the factual accuracy of the translation,
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`because she has no personal knowledge of Japanese-English translation or personal
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`knowledge of the underlying source document’s contents. Ex. 2093 [O’Connell
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`Tr.] at 16:16-17; Fed. R. Evid. 602; Zhongshan Broad Ocean Motor Co., Ltd. v.
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`Nidec Motor Corp., IPR2014-01121, Paper 20 at 11-12 (January 21, 2015).
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`Ms. O’Connell’s affidavits are thus irrelevant to these proceedings. Ms.
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`O’Connell admitted that she (1) speaks only English and, therefore, cannot attest to
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`3
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`the accuracy of a Japanese translation; (2) does not know which pages were
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`translated by any translator; and (3) did not perform a quality check on the
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`translations. Ex. 2093 at 16:16-17, 38:8-39:1, 72:10-19. Ms. O’Connell merely
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`managed the account relationship with TD, but she did not assign the translations,
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`communicate with the translators, compile the translations, or even review the
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`translations. Ex. 2093 at 73:17-74:3. In fact, Ms. O’Connell not only admitted that
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`she cannot read Japanese, but also admitted that the project manager, Courtney
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`Edmunds, also could not verify the accuracy of the translation because Ms.
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`Edmunds cannot read Japanese and has no Japanese translation experience. Ex.
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`2093 at 74:1-15.
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`To compound Ms. O’Connell’s lack of factual knowledge as to the accuracy,
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`she admits that no one performed any quality check or accuracy verification of the
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`translation. Ex. 2093 at 73:17-74:3. As a result of the failure to review or quality
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`check these rushed translations, there are numerous inconsistencies, missing parts
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`of the original Japanese document, and incorrect translations, rendering the
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`document unreliable and inaccurate. E.g., Ex. 2096 at 16:5-15, 18:12-17, 22:12-22,
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`23:5-21; 25:9-25, 41:4-9, Ex. 2094 at 50:6-51:2, 72:8-20 (translating “meigara” as
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`“brand” from commercial products not in the context of stocks), 76:14-77:14
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`(translating “saiken” as “securities” and “bond,” which are different terms) , 77:18-
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`22 (acknowledging that “shisuu” should have been translated as “index,” not
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`4
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`“security”), 81:1-82:9 (text for “nearby delivery month” not in source text and
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`changing translation text from source text characters), 82:10-83:10 (text of which
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`translator is unsure of meaning omitted from translation), 86:2-87:7 (modifiers to
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`text missing in translation), 87:12-89:5 (translator copied text from previous part
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`without adjusting meaning for different source text), 89:21-90:24 (missing words
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`in translation). Nor are these mistakes merely interchangeable words. For example,
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`although a “bond” may be a “security” in some cases, not all “securities” are
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`“bonds” and the mistranslations in Ex. 1004 obfuscate the correct underlying
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`substance of the source document. Furthermore, these mistranslations do not even
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`begin to address the omitted text, which cannot be cured. See id.
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`In fact, Ms. O’Connell’s declaration cannot be correct or reliable because
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`she never spoke with the translators. Any of her statements about accuracy of the
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`translation, in addition to being undermined by her admissions that she cannot read
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`or speak Japanese, are contradicted by the fact that one of the purported translators
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`admitted that the translation at pages 101-140 is not his. See Section III.C; Ex.
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`2096 [Skidmore Tr.] at 14:5-22, 17:7-17. The failure to collect affidavits of
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`accuracy from the actual translators renders Ms. O’Connell’s declaration incorrect
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`and unreliable, and also demonstrates that the entire TSE translation is unreliable
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`and should be excluded.
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`For at least the substantive issue opined on by Mr. Abilock, TD’s translation
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`5
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`is the only translation (of several) to make certain substantive errors in the
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`translation of jou-ge as either “up and down” or “above and below.” Compare Ex.
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`1004 at 115 with Ex. 2097 at ¶¶ 35 n.1, 76 and Ex. 2214 at 15; 2216 at 53; 2217 at
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`13; and 2218 at 13. Furthermore, TD’s assertions based on the EPO’s statement
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`about similarities are irrelevant because Ex. 1004 was not one of the translations
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`considered in those proceedings. Because of Ms. O’Connell’s admitted deficiency
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`in having personal knowledge to testify to the factual question of the translation’s
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`accuracy—and therefore fail to discern the numerous substantive errors in Ex.
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`1004—her affidavits cannot satisfy the requirement of 37 C.F.R § 42.63(b) or the
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`corresponding Federal Rules.
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`Nor can subsequent declarations cure this deficiency. Under the Board’s
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`rules, a proper affidavit of accuracy must be filed with the translation. 37 C.F.R.
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`§ 42.63(b). TD did not provide any translator declarations attesting to the accuracy
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`of the translation with the originally-filed Exhibit. See Exs. 1003-1005; Pet. at iii-v
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`(Exhibit List). When a proper affidavit is not filed with the translation (or even
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`obtained by the filing party), such errors cannot be cured by supplemental
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`evidence. Zhongshan Broad Ocean Motor Co., Ltd. v. Nidec Motor Corp.,
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`IPR2014-01121, Paper 20 at 11-12 (January 21, 2015) (holding that because an
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`affidavit was not filed with a translation, the Board would not consider the
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`reference). Like in Zhongshan, TD did not obtain any declaration from any
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`purported translator (the only people with personal knowledge of the factual
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`question of accuracy) until after the petition and translation exhibit were filed. See
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`Exs. 1036-1039 (signed on or after Dec. 30, 2014, after institution of the
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`proceeding). Zhongshan clearly states that a petitioner who fails to obtain an
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`original affidavit at the time of filing cannot cure the deficiency by supplemental
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`evidence. Id.
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`Because TD failed to comply with the requirement of 37 C.F.R. § 42.63(b)
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`and Fed. R. Evid. 602-604, the TSE translation (Ex. 1004) should be excluded.
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`C.
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`In the Absence of Excluding All of TSE, At Least Pages 101-140 of
`the TSE Translation (Exhibit 1004) Should Be Excluded for
`Failing to Comply with 37 C.F.R. § 42.63(b)
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`Even if the Board does not exclude the entire TSE translation, it should
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`exclude pages 101-140 because, even after submitting supplemental affidavits,
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`there is no affidavit from a person having personal knowledge of that part of the
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`translation. Although TD submitted an affidavit of Mr. Ronald Skidmore (Ex.
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`1036), during his deposition, Mr. Skidmore repeatedly stated that the translation
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`filed by TD did not appear to be his translation, because “it doesn’t look anything
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`like what [he] did.” Ex. 2096 [Skidmore Tr.] at 14:5-22, 17:7-17. Accordingly,
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`there is nothing in the record by a person having personal knowledge that attests to
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`the accuracy of translated pages 101-140, as required by Rule 42.63(b). As stated
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`above, Ms. O’Connell’s blanket affidavit cannot suffice because she cannot read
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`Japanese. Ex. 2093 at 16:16-17; see Fed. R. Evid. 602 (requiring personal
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`knowledge to testify to a matter); Fed. R. Evid. 104(b) (requiring proof that a fact
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`exists where the relevance of the evidence depends on the existence of a fact). No
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`other affidavit filed by TD even mentions these pages. See Exs. 1037-1040. Based
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`on this failure to comply with Rule 42.63(b), pages 101-140 of Exhibit 1004
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`should be excluded from the proceeding.
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`Mr. Skidmore’s declaration states only that he “translated pages 101-140 of
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`the TSE document,” which does not link any work that he did to the translation in
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`Ex. 1004. See Ex. 1036. When directly asked whether the translation in Ex. 1004
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`was Mr. Skidmore’s translation, he repeatedly stated that the translation did not
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`appear to be his:
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`THE WITNESS [Mr. Skidmore]: So, no, I’ve never seen
`this part. I’ve seen only the few page--- well, come to
`think of it, I don’t really know if I’ve seen this before.
`This might not be anything that I’ve ever seen before.
`Might be done by somebody else.
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`Ex. 2096 at 13:1-5 (emphasis added).
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`BY MR. RODKEY: Q And, in your declaration, did you
`testify that you translated pages 101 to 140 of this
`document?
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`[Mr. Skidmore] Yes, I did. But I’m not sure that this
`A
`is the actual copy of what I translated -- that this is my
`translation.
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`Ex. 2096 at 15:4-10 (emphasis added).
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`[Mr. Rodkey] We have some questions about the
`Q
`accuracy of the translation that I’ve given you.
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`[Mr. Skidmore] The more I look at this [pages 101-
`A
`140], the more it doesn’t even seem like mine. I don’t know
`-- you know, I can’t really...
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`Q
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`So you think this is not your translation?
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`I’m seeing various signs that -- it doesn’t look
`A
`anything like what I did.
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`Q Why does it not look like what you did?
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`A
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`Because I don’t forget things like this (indicating).
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`Ex. 2096 [Skidmore Tr.] at 17:7-17 (emphasis added). In light of Mr. Skidmore’s
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`repeated statements, pages 101-140 fail to comply with Rule 42.63(b) because no
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`affidavit was filed by a person having personal knowledge of their accuracy.
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`Without proper evidence attesting to the accuracy of the translation, the
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`translation is inadmissible. 37 C.F.R. § 42.61(a) (“Evidence that is not taken,
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`sought, or filed in accordance with this subpart is not admissible.”). The Board has
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`held that the failure to provide a proper affidavit under § 42.63(b) is grounds to
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`refuse to consider a translation. Zhongshan, IPR2014-01121, Paper 20 at 11-12.
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`As in Zhongshan, here TD failed to obtain an affidavit attesting to the
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`accuracy of pages 101-140. Although Mr. Skidmore executed an affidavit, he
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`admits that Ex. 1004 is not his translation. E.g., Ex. 2096 [Skidmore Tr.] at 14:5-
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`22, 17:7-17. Accordingly, TD has failed to comply with Rule 42.63(b), which
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`precludes the translation from being admissible. 37 C.F.R. § 42.61(a). Therefore,
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`pages 101-140 of the TSE translation must be excluded. Id.; Zhongshan, IPR2014-
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`01121, Paper 20 at 11-13.
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`IV. Dr. Román’s Supplemental Declaration (Ex. 1042) Should be Excluded
`A. TT Timely Objected to the Supplemental Declaration, Which Was
`Relied Upon in TD’s Reply
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`TT objected to Exhibit 1042 in objections served June 5, 2015. Paper 49. TD
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`relies upon the Supplemental Declaration (Ex. 1042) for its 35 U.S.C. § 103
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`grounds as well as its § 101 grounds. E.g., Reply, Paper 48 at 4, 5, 9, 14, 16-17.
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`B. Dr. Román’s Supplemental Declaration Lacks Relevance Under
`FRE 402 and is Prejudicial under FRE 403
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`Rather than further explain the original arguments set out in the Petition,
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`TD’s Reply improperly raises several issues for the first time, supported by Dr.
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`Román’s Supplemental Declaration. Thus, instead of narrowing the issues before
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`the Board, TD’s Reply expands them. 37 C.F.R. § 42.23(b) states “[a] reply may
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`only respond to arguments raised in the corresponding . . . patent owner response.”
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`As explained in the Trial Practice Guide, “new evidence necessary to make out a
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`prima facie case for [] unpatentability” and “new evidence that could have been
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`presented in a prior filing” are improper. 77 Fed. Reg. 48767. The Board should
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`not allow TD to propose entirely new theories of the alleged prior art’s application
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`to the claims in an attempt to cure its submission of an inaccurate and defective
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`translations, or new theories of unpatentability under 35 U.S.C. § 101 when those
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`arguments could have been presented in its Petition.
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`37 C.F.R. § 42.22(a)(2) requires that “[a] petition . . . must include ‘[a] full
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`statement of the reasons for the relief requested, including a detailed explanation of
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`the significance of the evidence including material facts, and the governing law,
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`rules, and precedent.’” TD’s late evidence to support new “reasons for the relief
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`requested” and new alleged “material facts” lacks relevance under Fed. R. Evid.
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`402, and goes beyond TD’s originally proposed “reasons for the relief requested”
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`in its Petition.
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`The new evidence prejudices Patent Owner under Fed. R. Evid. 403 because
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`its own experts cannot now respond to TD’s new arguments and opinions, and
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`Patent Owner is precluded from addressing the Supplemental Declaration in its
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`Patent Owner Response. See Intri-Plex Technologies, Inc. v. Saint-Gobain
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`Performance Plastics Rencol Limited, IPR2014-00309, Paper 83 at 13. The new
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`evidence is also a waste of time, confuses the issues, and could cause undue delay
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`(Fed. R. Evid. 403) because it unnecessarily expands the issues for Oral Hearing,
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`and presents multiple theories (legal, prior art, and claim construction) that have
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`not been fully briefed for consideration in the Board’s Final Written Decision.
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`For at least the following reason with respect to the instituted 35 U.S.C.
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`§ 103 grounds, the Supplemental Declaration is improper:
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`Citing to the Supplemental Declaration at ¶ 5, TD argues in its Reply for the
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`first time that “[t]he ordinary default may be used on system startup, and the user’s
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`last-entered quantity is used after the user enters a quantity.” Reply at 16-17. In its
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`Petition, TD did not differentiate between an “ordinary default” to be used at
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`“system startup” and “the user’s last-entered quantity” with respect to the alleged
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`prior art’s application to the claims. See Pet. at 30-32. TD only argued that
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`“Togher teaches a user entering a default quantity, called Normal Trade Size. . . .”
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`Pet. at 31. Nowhere in its Petition did TD limit its application of Togher’s “Normal
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`Trade Size” to “system startup” or to use “after the user enters a quantity.” This
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`new argument could have been included in Petitioner’s original paper, but was not.
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`And it raises new allegations with respect to the prior art and claim construction
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`issues that the Patent Owner cannot now brief. Dr. Román’s new testimony that
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`“[w]hen first started, the system would use the default value that survived
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`shutdown, and the last-entered value for subsequent operations,” and statements
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`supporting that argument in ¶ 5 are therefore irrelevant under Rule 402 and
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`12
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`prejudicial, a waste of time, confuse the issues, and are likely to cause undue delay
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`under Rule 403.
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`For at least the following reason with respect to the instituted
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`35 U.S.C. § 101 grounds, the Supplemental Declaration is improper:
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`Citing to the Supplemental Declaration at ¶ 3, TD argues for the first time in
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`its Reply that the displaying steps “can be done mentally or with a pen and paper,
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`or even in a trader’s mind” and that the alleged abstract idea is “digital equivalent
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`to a trader manually plotting or mentally visualizing such data.” See Reply at 4.
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`Also citing to the Supplemental Declaration at ¶ 3, TD argues for the first time that
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`“the claims do not recite any speed or time limitations.” See Reply at 5. These new
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`arguments could have been included in Petitioner’s original paper, but were not,
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`and they raise claim construction issues that the Patent Owner cannot now brief.
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`Dr. Román’s new conclusions and supporting statements in ¶ 3 are therefore
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`irrelevant under Rule 402 and prejudicial, a waste of time, confuse the issues, and
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`are likely to cause undue delay under Rule 403.
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`In its Petition, TD nowhere relied on expert testimony (by Dr. Román or
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`otherwise) to support its 35 U.S.C. § 101 grounds. See Pet. at 18-20. Evidence that
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`TD intended to rely upon to establish its prima facie case should have been
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`submitted with its Petition. See Intri-Plex Technologies, Inc. v. Saint-Gobain
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`Performance Plastics Rencol Limited, IPR2014-00309, Paper 83 at 13. The
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`Patent No. 7,533,056
`Supplemental Declaration raises claim construction issues and alleged facts
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`regarding what was routine and conventional, which Patent Owner cannot now
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`brief. The Supplemental Declaration at ¶¶ 3-4 is irrelevant under Rule 402 and
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`prejudicial, a waste of time, confuses the issues, and likely to cause undue delay
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`under Rule 403. Furthermore, TD has not cited to ¶¶ 6-7, which are therefore
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`irrelevant under Rule 402 for this additional reason.
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`
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`Dated: June 12, 2015
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`Respectfully submitted,
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`By: /Joshua L. Goldberg/
`Joshua L. Goldberg, Backup Counsel
`Registration No. 59,369
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing Patent
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`Owner’s Motion to Exclude was served on June 12, 2015, via email directed to
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`counsel of record for the Petitioner at the following:
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`Lori A. Gordon
`lgordon-ptab@skgf.com
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`Jonathan M. Strang
`jstrang-ptab@skgf.com
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`Robert E. Sokohl
`rsokohl-ptab@skgf.com
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`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
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`/Lisa C. Hines/
`Lisa C. Hines
`Litigation Clerk
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`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
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