UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SMARTFLASH LLC,
`Patent Owner.
`
`_________
`
`Case CBM2015-00017
`
`Patent 8,061,598 B2
`
`_________
`
`PATENT OWNER’S REQUEST FOR REHEARING
`
`
`
`
`
`
`
`
`
`
`
`_________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SMARTFLASH LLC,
`Patent Owner.
`
`_________
`
`Case CBM2015-00017
`
`Patent 8,061,598 B2
`
`_________
`
`PATENT OWNER’S REQUEST FOR REHEARING
`
`
`
`
`
`
`
`
`
`
`
`
`
`TABLE OF CONTENTS
`
`I.
`
`INTRODUCTION .............................................................................................. 1
`
`
`II. STATEMENT OF PRECISE RELIEF REQUESTED ...................................... 2
`
`
`III. BACKGROUND ................................................................................................ 2
`
`
`IV. ARGUMENT ..................................................................................................... 4
`
`A.
`
`Like the Claims in DDR Holdings, the Challenged Claims Are Patent
`Eligible Because They Teach a Specific Solution to a Novel Problem
`Presented By Digital Commerce ............................................................ 5
`
`B.
`
`The Challenged Claims Do Not Resemble Those in Alice .................. 10
`
`1.
`
`2.
`
`The Challenged Claims Are Directed To A Specific Device,
`Not An Abstract Idea ............................................................ 10
`
`The Challenged Claims Contain Numerous “Additional
`Features” That Demonstrate That They Do Not Cover An
`Abstract Idea ......................................................................... 12
`
`V. CONCLUSION ................................................................................................ 15
`
`
`
`i
`
`
`
`
`
`
`
`
`
`I.
`
`INTRODUCTION
`
`The Board’s final written decision in this covered business method patent
`
`review misapprehends the Federal Circuit’s and Supreme Court’s guidance on
`
`patent eligible subject matter under 35 U.S.C. § 101. The challenged claims cover
`
`a specific physical device operating within a novel content delivery system that
`
`facilitates distribution of digital content over the Internet while helping to reduce
`
`piracy—a pressing problem at the time of invention. The claims contain
`
`meaningful limitations that are both inventive and technological, which, when
`
`taken in ordered combination, amount to more than the idea of “controlling access
`
`to content” and do not pre-empt the field. Furthermore, the claims improve the
`
`functioning of computers used to download, store, and access data thereby
`
`effecting a technological improvement in the relevant field.
`
`The Board wrongly determined that these claims on a physical device
`
`actually covered an abstract idea and ignored the claims’ specific combination of
`
`hardware and software to hold that the claims contain no inventive concept. Under
`
`the Board’s analysis, any device used in an economic transaction that contains
`
`conventional components would be patent ineligible. This error is exactly what the
`
`Supreme Court cautioned against in Alice. See Alice Corp. Pty. Ltd. v. CLS Bank
`
`Int’l, 134 S. Ct. 2347, 2354 (2014) (warning against “construing this exclusionary
`
`
`
`1
`
`
`
`principle [to] swallow all of patent law”). Patent Owner respectfully requests
`
`rehearing to correct these errors. See 37 C.F.R. § 42.71(d).
`
`II.
`
`STATEMENT OF PRECISE RELIEF REQUESTED
`
`Patent Owner requests that the Board reverse its original decision (Paper 46,
`
`March 30, 2016) and hold that challenged claims 1, 2, and 15 are patent eligible.1
`
`III. BACKGROUND
`
`1.
`
`The opportunities and challenges associated with distribution of
`
`digital content over the Internet “introduces a problem that does not arise” with
`
`content distributed on physical media. DDR Holdings, LLC v. Hotels.com, L.P.,
`
`773 F.3d 1245, 125 (Fed. Cir. 2014). By the late 1990s, as a result of improved
`
`data compression and increasing bandwidth for Internet access, content providers,
`
`for the first time, had the ability to offer data for purchase over the Internet; at the
`
`same time, unprotected data files could be easily pirated and made available
`
`“essentially world-wide.” Ex. 1201, 1:32-33. The conventional operation of the
`
`Internet does not solve the problem of data piracy: on the contrary, the Internet
`
`facilitates the distribution of data without restriction or protection. Id. 1:49-55.
`
`Content providers had faced the issue of piracy before—a CD can be copied
`
`onto a cassette tape or onto another CD and the pirated copy sold—but the problem
`
`1 Patent Owner does not seek rehearing with respect to claim 31 but reserves the
`
`right to appeal the Board’s determination with regard to that claim.
`
`
`
`2
`
`
`
`of widespread distribution of pirated content over the Internet was unprecedented.
`
`There had never before been a way to make free, identical, and flawless copies of
`
`physical media available to millions of people instantaneously at virtually no
`
`incremental cost. See generally Metro-Goldwyn-Mayer Studios, Inc. v. Grokster,
`
`Ltd., 545 U.S. 913, 929-30 (2005). The advent of the Internet thus gave rise to an
`
`urgent need to address the problem of data piracy.
`
`
`
`The inventor devised a data storage and access system for downloading and
`
`paying for data, described in the specification and claimed in this patent and others,
`
`comprising specific elements designed to overcome the problems inherent in
`
`making digital content available over the Internet. Ex. 1201, at 1 (Abstract). The
`
`relevant claims of the ’598 patent are directed to one aspect of that system:
`
`namely, a “portable data carrier.” Id. at 25:54. Related patents cover other aspects
`
`of the system and interactions explained in the specification.
`
`Claim 1 requires the “portable data carrier” to include an “interface for
`
`reading and writing data from and to the portable data carrier”; “content data
`
`memory”; “use rule memory”; a “program store”; and a “processor . . . for
`
`implementing code in the program store,” “wherein the code comprises code for
`
`storing at least one content data item in the content data memory and at least one
`
`use rule in the use rule memory.” Ex. 1201, 25:54-67. Claim 2 adds the element
`
`of “code to provide access to . . . content data . . . in accordance with the . . . use
`
`
`
`3
`
`
`
`rule.” And Claim 15 adds a “content access PIN memory” to store a “PIN number
`
`for controlling access to the content data memory.”
`
`
`
`2.
`
`The Board found the challenged claims to be patent ineligible. First,
`
`the Board found (at 7-8) “that the challenged claims are drawn to a patent-
`
`ineligible abstract idea,” that is, “performing the fundamental economic practice of
`
`conditioning and controlling access to content.” The Board also found “that the
`
`additional elements . . . are either field of use limitations and/or generic features of
`
`a computer.” Id. at 10. And the Board distinguished DDR Holdings because
`
`“[d]ata piracy exists in contexts other than the Internet,” “the solution provided by
`
`the challenged claims is not rooted in specific computer technology” and the
`
`“result” does not “override[] the routine and conventional use of the recited
`
`devices and functions.” Id. at 14-15.
`
`IV. ARGUMENT
`
`The Board should reverse its decision in this case and find the claims
`
`directed to statutory subject matter because, in evaluating whether challenged
`
`claims 1, 2, and 15 comply with the requirements of § 101, the Board failed to give
`
`effect to the actual language of the claims and their specific limitations.2 The
`
`
`2 The Board disregarded the actual text of the claims, using nearly identical
`
`language in all the final written decisions of the covered business methods that
`
`
`
`4
`
`
`
`actual claim language, read in light of the specification, reflects a specific and
`
`concrete solution to a novel problem associated with distribution of digital content
`
`over the Internet. Such a technological advance is patent eligible.
`
`A. Like the Claims in DDR Holdings, the Challenged Claims Are
`Patent Eligible Because They Teach a Specific Solution to a Novel
`Problem Presented By Digital Commerce
`
`1.
`
`The claims of the ’598 patent are patent eligible because they
`
`embody one concrete aspect of a particular solution to the Internet-specific
`
`problem of digital piracy. This is not a patent that simply claims “use of the
`
`Internet” or a computer to perform an established business method. Cf.
`
`Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709, 716 (Fed. Cir. 2014). This is no
`
`digital telephone book. Cf. Paper 46, at 17. On the contrary, the challenged claim
`
`limitations reflect specific technical choices: a “portable data carrier” that includes
`
`“content data memory” and “use rule memory” and a “processor” capable of
`
`storing content data and use rules.
`
`That particular configuration of elements provides distinct advantages over
`
`alternatives. For example, by storing “use rules” in a “use rule memory” on the
`
`data carrier—rather than (for example) including any use rules as part of the
`
`content file—the invention allows for different levels of usage of the same digital
`
`concern the patents related to the ’598 patent, even though the challenged claims
`
`varied dramatically in their coverage. See CBM2015-00016 and CBM2014-00194.
`
`
`
`5
`
`
`
`content. This permits, for example, both rental and sale rather than just sale of
`
`particular content data; it also allows for provision of enhanced access without
`
`downloading the content data anew. Ex. 1201, 22:49-51. By including a processor
`
`on the portable data carrier, the claimed invention enhances the functionality of the
`
`data carrier, providing more than just storage. Indeed, the basic insight reflected in
`
`the claims—that a portable data carrier can include functionality to read and write
`
`content data, and use rules in distinct memories—is itself inventive.
`
`Because the claims teach specific technical solutions to a problem associated
`
`with distribution of digital content through specific organization of distinct data
`
`types, implemented on a specific device, there is no risk that the patents
`
`monopolize a “fundamental economic practice,” as the Board held (at 7-8).
`
`Consequently, there is no concern that recognizing the patent-eligibility of these
`
`claims will “impede innovation” or “improperly t[ie] up . . . building blocks of
`
`human ingenuity,” Alice, 134 S. Ct. at 2354. On the contrary, each claim teaches a
`
`“specific way” to control access to stored digital content; the claims do not attempt
`
`to “preempt every application of the idea.” DDR Holdings, 773 F.3d at 1259.
`
`2.
`
`The Board rejected Patent Owner’s reliance on DDR Holdings
`
`(at 15), holding that the challenged claims were not “rooted in computer
`
`technology in order to overcome a problem specifically arising in the realm of
`
`
`
`6
`
`
`
`computer networks.”3 That is incorrect: the claim discusses specific computer
`
`functions and interactions to perform a defined series of operations. Indeed, the
`
`Board’s own summary of the ’598 patent (at 3) states:
`
`The ’598 patent describes providing portable data storage together
`with a means for conditioning access to that data upon validated
`payment. . . . This combination allows data owners to make their data
`available over the internet without fear of data pirates.
`
`The specification further explains that the purpose of the invention is to
`
`“make . . . data available . . . over the internet without fear of loss of revenue.” Ex.
`
`1201, 2:13-15. The specification notes that “the growing prevalence of so-called
`
`data pirates” is a problem that arises by virtue of “increasingly wide use of the
`
`internet.” Id. 1:29-30. Because the Internet facilitates “essentially world-wide”
`
`distribution of flawless, identical copies of content data, the data piracy problems it
`
`creates are qualitatively different from the problem of copying of physical media
`
`(videotapes, CDs, software, books), which necessarily takes time, imparts
`
`imperfections, and imposes incremental costs. See Grokster, Ltd., 545 U.S. at 929-
`
`30. Rather than generically claiming use of the Internet to perform an abstract
`
`
`3 Pursuant to 37 C.F.R. § 42.71(d), the issue of whether the challenged claims were
`
`similar to those in DDR Holdings was previously addressed. See PO Resp. 1, 10-
`
`12.
`
`
`
`7
`
`
`
`business practice, the claims solve problems faced by digital content providers in
`
`the Internet Era and improve the functioning of the computer itself.4
`
`The Board also held (at 15) that the challenged claims contained
`
`limitations—unlike the claims in DDR Holdings—that were “specified at a high
`
`level of generality.” But the challenged claims and the specification discuss
`
`specific data stored in specific places, not mere generalities. There is “content
`
`data” and “use rules” stored on the carrier. See Ex. 1201 25:58-59. These phrases
`
`are uniquely used in the ’598 patent and do not have the broad acceptance that the
`
`words in the DDR Holding patent did. See DDR Holdings, 773 F.3d at 1249
`
`(reciting “links,” “source page,” and “web page”). These limitations are not
`
`“specified at a high level of generality.”
`
`The fact that the patentee uses its own lexicography does not mean that the
`
`claim limitations are not precisely described. Here, the device must be able to
`
`read, write, and store specific data, namely, content data items and associated use
`
`rules. The claim does not “merely recite the performance of some business
`
`4 The claims of the ’598 patent do not directly involve Internet transactions; rather,
`
`they are directed to a portable data carrier for reading and writing content data and
`
`use rules. The claims nevertheless are directed towards an Internet-specific
`
`problem – that is, storing and controlling access to content data sold separately
`
`from a storage medium.
`
`
`
`8
`
`
`
`practice known from the pre-Internet world along with the requirement to perform
`
`it on the Internet.” DDR Holdings, LLC, 773 F.3d at 1257. By ignoring these
`
`limitations, the Board erred in holding that there were not “additional features”
`
`present in the challenged claims that made them patent-eligible.
`
`
`
` Finally, the Board held (at 12) that the claims could be performed by “a
`
`general-purpose computer.” But, again, this ignores the limitations of the claims,
`
`which, as explained above, require specific configurations of distinct memories
`
`and data types and defined interactions to facilitate secure access to content data
`
`items stored on a data carrier. As the specification makes clear, when digital data
`
`is sent over the Internet operating in its normal, expected manner and stored by a
`
`recipient, the content data are insecure; the content owner has no means to exert
`
`further control over access. The claims provide a specific mechanism to ensure
`
`that content, once downloaded and stored, can be accessed only when access is
`
`authorized in accordance with associated use rules. Just as the claims in DDR
`
`Holdings “specify how interactions with the Internet are manipulated to yield a
`
`desired result,” 773 F.3d at 1258, so too the claims here specify how manipulation
`
`of specific data facilitates convenient and secure provision of digital content, a
`
`result that neither the conventional Internet nor unimproved computers can
`
`produce. The patent “improve[s] the functioning” and the functionality of portable
`
`data carriers, which, as the specification makes clear, likewise improves the
`
`
`
`9
`
`
`
`functioning of data communications networks used for digital content distribution.
`
`Alice, 134 S. Ct. at 2359.
`
`B.
`
`The Challenged Claims Do Not Resemble Those in Alice
`
`The claims do not fit the mold of the patent-ineligible claims of Alice. They
`
`do not recite an “abstract idea” and, in any event, teach a specific “combination of
`
`elements” that amounts to “significantly more” than any ineligible concept.
`
`1.
`
`The Challenged Claims Are Directed To A Specific Device,
`Not An Abstract Idea
`
`The Board’s determination that the claims were directed to an abstract idea
`
`is incorrect because the claims are directed to a concrete machine with specific
`
`hardware and software components and not merely to the abstract idea of
`
`conditioning and controlling access to content.5 As the Board acknowledged (at 6)
`
`“the challenged claims recite a ‘machine,’ i.e., a ‘portable data carrier” with
`
`defined components. See Ex. 1201, 25:54-67. It contains an interface, distinct
`
`memories, and a processor. The machine runs specific software to store content
`
`data items and associated use rules governing whether a user may access data on
`
`the data carrier. The patent specification emphasizes that the patent is on a
`
`
`5 Pursuant to 37 C.F.R. § 42.71(d), the issue of whether the claims are abstract
`
`ideas was previously addressed. See PO Resp. 10-22; see also Tr. 46:21-47:11.
`
`
`
`10
`
`
`
`machine. See, e.g., id. 1:21-25; see also 35 U.S.C. § 101 (allowing for patents on
`
`“processes, machines, manufactures, and compositions of matter”).6
`
`In finding this claimed machine was directed to an abstract idea, the Board
`
`apparently focused on the problem that the patented machine was designed to solve
`
`and treated the problem itself as the abstract idea to which the claims were
`
`directed. Specifically, the Board held (at 7-8) that “the challenged claims are
`
`directed to performing the fundamental economic practice of conditioning and
`
`controlling access to content.” But while it is true that the claimed machine
`
`provides a specific mechanism that can be used to condition and control access to
`
`content, thus combatting problems of data piracy, see Ex. 1201, 1:20-55, that does
`
`not provide a fair description of the claims, which, as explained, provide a specific
`
`solution to an aspect of the problem.
`
`There is a fundamental difference between claiming a specific device or
`
`method that can be used to accomplish an economic practice and claiming the
`
`practice itself. See Brookhill-Wilk 1, LLC v. Intuitive Surgical, Inc., 326 F.3d
`
`1215, 1223 (Fed. Cir. 2003) (“Advantages described in the body of the
`
`specification, if not included in the claims, are not per se limitations to the claimed
`
`6 The Board identified the abstract idea without explaining its methodology, which
`
`itself merits rehearing. Cf. Avago Techs. Gen. IP (Singapore) Pte Ltd. v. Asustek
`
`Computer, Inc., No. 15-cv-04525-EMC, at 10-11 (N.D. Cal. Apr. 25, 2016).
`
`
`
`11
`
`
`
`invention.”). As an example, a cash register is a physical device used to perform a
`
`fundamental economic practice, namely, collecting, storing, and tracking payment.
`
`A claim on a specific novel device—with specific circuit boards, keys, and cash
`
`drawers—may be patentable even though a claim on collecting and storing
`
`payment itself would not be. The Board’s decision equates a claim on a machine
`
`that may be used to perform an economic task with a claim on the economic task
`
`itself, which risks turning all devices used in commerce into abstract ideas. This is
`
`the problem that the Supreme Court warned against in Alice. “At some level, all
`
`inventions ... embody, use, reflect, rest upon, or apply laws of nature, natural
`
`phenomena, or abstract ideas. Thus, an invention is not rendered ineligible for
`
`patent simply because it involves an abstract concept.” Alice, 134 S. Ct. at 2354.
`
`2.
`
`The Challenged Claims Contain Numerous “Additional
`Features” That Demonstrate That They Do Not Cover An
`Abstract Idea
`
`In any event, the Board was incorrect to find that the challenged claims did
`
`not contain “additional features” to ensure that they were more than a drafting
`
`effort designed to monopolize the abstract idea.7 On the contrary, because the
`
`
`7 Pursuant to 37 C.F.R. § 42.71(d), the issue of whether the challenged claims
`
`contain “additional features” beyond an abstract idea was previously addressed.
`
`See PO Resp. 11-12.
`
`
`
`12
`
`
`
`challenged claims are not limited to generic computer implementation, they
`
`contain an inventive concept sufficient to establish patent eligibility.
`
`Just as the claims do not purport to cover an abstract idea, the challenged
`
`claims do not “simply stat[e] an abstract idea while adding the words ‘apply it’ or
`
`‘apply it with a computer.’” Versata Development Group, Inc. v. SAP America,
`
`Inc., 793 F.3d 1306, 1332 (Fed. Cir. 2015). It is, of course, true that the claimed
`
`machine has several components, including computer code. Some of that code
`
`allows the machine to store “content data items” and associated “use rules.” And,
`
`after evaluating these specific pieces of data, the machine can provide access to the
`
`content data items. But these limitations specify a way in which the machine
`
`controls access to stored data. It does not claim the general idea of controlling
`
`access to content. The Board came to a different conclusion by failing to consider
`
`the various claim limitations as an ordered combination reflecting distinct
`
`technological choices and advantages.
`
`The Board held (at 10-11) that each specific limitation was a “generic
`
`computer component” such as a program store or a processor and, with respect to
`
`the claimed software limitations, that the claims lack “any inventive concept …
`
`related to the way these data types are constructed or used.” But that basic
`
`methodology is flawed, because it is not proper to look at individual limitations
`
`and determine if each specified component of the machine is conventional in
`
`
`
`13
`
`
`
`isolation. “[I]nventions in most, if not all, instances rely upon building blocks long
`
`since uncovered, and claimed discoveries almost of necessity will be combinations
`
`of what, in some sense, is already known.” KSR Int’l Co. v. Teleflex Inc., 550 U.S.
`
`398, 418-19 (2007). The fact that a machine uses individual well-known pieces
`
`does not mean that the particular combination of elements lacks an inventive
`
`concept. A novel cash register will likely be made of well-known circuitry or
`
`plastics, but that does not mean that the combination is not technological. See
`
`Alice, 134 S. Ct. at 2359 (a claim may be patentable if it “effect an improvement in
`
`any other technology or technical field”).
`
`As explained above, the ’598 patent claims a portable data carrier storing
`
`content data items and associated use rules; that combination enables (for example)
`
`a portable “Smartflash” card to securely store downloaded content—a
`
`technological invention. See Ex. 1201, 24:16-18. Nothing in the Board’s opinion
`
`supports its conclusion that such an approach to data storage and access was
`
`merely conventional—which, in any event, should be a question of substantive
`
`validity, not patent eligibility.
`
`The Board acknowledged (at 12) that a combination of elements may
`
`provide an inventive concept under the Alice analysis. But in doing so, the Board
`
`not only improperly focused on a single aspect of the invention, it also drew the
`
`wrong conclusion. The Board (at 17-18) acknowledged that the claims teach
`
`
`
`14
`
`
`
`storing “two specific types of information—content and the payment data – . . . in
`
`the same place or on the same storage device.” The Board then simply pronounced
`
`itself “not persuaded” that this particular configuration of data is “an inventive
`
`concept” —no reason given.
`
`The Board then asserted that this idea was known in the prior art, citing U.S.
`
`Patent No. 5,629,980 (Ex. 1213) and a1997 European patent application (Ex.
`
`1216). But this hardly suggests that a particular concept, if deployed as part of a
`
`novel configuration, is conventional; just as significant, the references do not
`
`disclose the type of data storage and manipulation that the ’598 patent claims. On
`
`the contrary, both teach having the content owner include or attach usage rights as
`
`part of the content item. See Ex. 1216 10:26 (“rental products are formatted to
`
`include a time bomb”) (emphasis added); Ex. 1213, Abstract (“the owner . . .
`
`attaches usage rights to that work”). That makes it impossible to provide greater
`
`access without downloading the content again. By contrast, the ’598 patent, by
`
`teaching separate storage of content data items, on the one hand, and associated use
`
`rules on the other, solves this very problem. Thus a comparison to that prior art
`
`actually confirms the patent eligibility of the claims.
`
`V. CONCLUSION
`The Board should reverse its original decision and hold challenged
`
`claims 1, 2, and 15 patent-eligible.
`
`
`
`15
`
`
`
` /
`
` Michael R. Casey /
`
`
`Michael R. Casey
`Registration No. 40,294
`Davidson Berquist Jackson & Gowdey, LLP
`8300 Greensboro Dr., Suite 500
`McLean, VA 22102
`Telephone: (571) 765-7700
`Fax : (571) 765-7200
`Email: mcasey@dbjg.com
`
`
`
`
`
`16
`
`
`Dated: April 29, 2016
`
`
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that this PATENT OWNER’S REQUEST
`
`FOR REHEARING was served, by agreement of the parties, by email on April 29,
`
`2016, to the following addresses:
`
`
`
`J. Steven Baughman (steven.baughman@ropesgray.com)
`James R. Batchelder (james.batchelder@ropesgray.com)
`Megan Raymond (megan.raymond@ropesgray.com
`ApplePTABService-SmartFlash@ropesgray.com
`
`
`
`Dated: April 29, 2016
`
`
`
`
`
` /
`
` 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
`
`
`
`17
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