Paper No.
`Filed: July 30, 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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`SONY CORPORATION OF AMERICA,
`Petitioner
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`v.
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`NETWORK-1 TECHNOLOGIES, INC.,
`Patent Owner
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`Case CBM2015-00078
`U.S. Patent No. 6,218,930
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`Petitioner’s Request for Rehearing Pursuant to 37 C.F.R. § 42.71(c)
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`Filed: July 30, 2015
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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
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`
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`
`
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`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
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`SONY CORPORATION OF AMERICA,
`Petitioner
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`v.
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`NETWORK-1 TECHNOLOGIES, INC.,
`Patent Owner
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`
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`Case CBM2015-00078
`U.S. Patent No. 6,218,930
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`Petitioner’s Request for Rehearing Pursuant to 37 C.F.R. § 42.71(c)
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` Case CBM2015-00078
`U.S. Patent No. 6,218,930
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`TABLE OF CONTENTS
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`I.
`
`II.
`
`Introduction: The Panel Erred Thrice in Denying CBM Review ................... 1
`
`In Its Petition, Sony Applied the Guidance of SAP America, Inc. v.
`Versata Development Group, Inc., Which Was Recently Affirmed by
`the Federal Circuit ........................................................................................... 2
`
`A. Under § 18, patent claims need only be broad enough to cover
`methods used in providing a financial product or service .................... 2
`
`B.
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`C.
`
`In its decision, the Panel took a narrower view of the scope of
`CBM review than the Federal Circuit ................................................... 4
`
`The Federal Circuit recently confirmed that the Petition’s view
`on the scope of CBM review was correct ............................................. 6
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`III. There Are Additional Facts that Are Not Addressed in the Decision
`that Further Confirm that the ’930 Patent Is Eligible for CBM Review ......... 7
`
`A.
`
`B.
`
`The Decision overlooked that claim 23 is a method claim broad
`enough to cover activities incidental or complementary to
`financial activities .................................................................................. 7
`
`The Decision overlooked the fact that Patent Owner has
`accused Petitioner’s products, which certainly may and do
`include products that are financial in nature, incidental to a
`financial activity or complementary to a financial activity ................. 12
`
`IV. Conclusion: Due to Misapplication of the Law (Improper Application
`of Scope of CBM Patent Review) and Overlooking the Facts, the
`Decision Erred by Denying Institution of CBM Review in this
`Proceeding ..................................................................................................... 14
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`i
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`TABLE OF AUTHORITIES
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` Page(s)
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`Federal Cases
`Versata Dev. Grp. v. SAP Am., Inc.,
`2014-1194, slip op. (Fed. Circ. July 9, 2015) ..............................................passim
`
`P.T.A.B. Cases
`SAP Am., Inc. v. Versata Dev. Grp., Inc.,
`CBM2012-00001, Paper 36 (P.T.A.B. Jan. 9, 2013) ...................................passim
`
`Sony Comput. Entm’t Am. LLC v. ADC Tech. Inc.,
`CBM2015-00026, Paper 10 (P.T.A.B. July 3, 2015) ........................................... 5
`
`Volusion, Inc. v. Versata Software, Inc.,
`CBM2013-00018, Paper 8 (P.T.A.B. October 24, 2013) ..................................... 9
`
`Wash. Inventory Serv. v. RGIS, LLC,
`CBM2014-00158, Paper 12 (P.T.A.B. January 26, 2015) ................................... 9
`
`Federal Statutes
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`§ 18 of the Leahy-Smith America Invents Act, Pub. L. No. 112-29,
`125 Stat. 284 (2011) .................................................................................. 2, 3, 6, 7
`
`Regulations
`
`37 C.F.R. § 42.71(c) ................................................................................................... 1
`
`Transitional Program for Covered Business Method Patents—
`Definitions of Covered Business Method Patent and Technological
`Invention, 77 Fed. Reg. 48,734 (Aug. 14, 2012) .............................................. 3, 7
`
`Other Authorities
`
`Patent Reform Act of 2011, 154 Cong. Rec. S1360–94 (daily ed.
`March 8, 2011) ................................................................................................ 4, 12
`
`
`
`
`ii
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`Introduction: The Panel Erred Thrice in Denying CBM Review
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` Case CBM2015-00078
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`I.
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`Sony Corporation of America (“Sony”), pursuant to 37 C.F.R. § 42.71(c),
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`respectfully requests rehearing of the July 1, 2015 Decision (Paper 7, “Decision”),
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`denying institution of covered business method patent (CBM) review. The
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`Decision erred in denying institution of CBM review for the following three
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`reasons: (1) in finding that “we do not find—any language in claim 23 relating to
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`a financial product or service,”1 the Decision took an erroneously narrow view of
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`the scope of CBM review, as compared to the appropriate scope in Versata
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`Development Group, Inc. v. SAP America, Inc., which states that “[CBM review] is
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`not limited to products and services of only the financial industry . . . [but] covers a
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`wide range of finance-related activities”2; (2) in finding that claim 23 is “without
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`any particular connection to financial products or services,”3 the Decision took an
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`erroneously narrow view of claim 23, a pure method claim that covers activities
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`incidental and complementary to financial activities and is broad enough to affect
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`finance-related activities; and (3) in finding that “even if Petitioner’s view of the
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`1 Decision 9.
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`2 Versata Dev. Grp., Inc. v. SAP Am., Inc., 2014-1194, slip op. at 35 (Fed. Cir. July
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`9, 2015) aff’g SAP Am., Inc. v. Versata Dev. Grp., Inc., CBM2012-00001.
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`3 Decision 11.
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` 1
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`statute is correct, we are not persuaded that Patent Owner has accused financial
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`products or services of infringing the claims of the ’930 patent,”4 the Decision took
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`an erroneously narrow view of the accused products, which are indeed very
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`commonly used in providing financial activities.
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`Therefore, if the Decision had properly applied the appropriate scope of
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`CBM review, as encompassing “a wide range of finance-related activities,”5
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`consistent with Congressional intent as well as Federal Circuit precedent in
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`Versata, and if the Decision had adequately addressed the key facts demonstrating
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`qualification for CBM institution, the Decision would have concluded that the ’930
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`patent is within the purview of Section 18, because its claims are broad enough to
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`affect finance-related activities. Thus, Sony respectfully requests that the Board
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`change its prior decision, because the ’930 patent qualifies for CBM review.
`
`II.
`
`In Its Petition, Sony Applied the Guidance of SAP America, Inc. v.
`Versata Development Group, Inc., Which Was Recently Affirmed by the
`Federal Circuit
`A. Under § 18, patent claims need only be broad enough to cover
`methods used in providing a financial product or service
`In its Petition, Sony applied the guidance from SAP America, Inc. v. Versata
`
`Development Group, Inc., that “the definition [of § 18] should be broadly
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`4 Decision 13.
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`5 Versata, slip op. at 35.
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` 2
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`interpreted” and that any patents “claiming activities incidental and complementary
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`to a financial activity” are sufficient to qualify for CBM review.6
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`In determining whether a patent qualifies for CBM review, SAP and the
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`legislative history provide several guideposts. As Sony pointed out, “[T]he term
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`financial product or service is not limited to the products or services of the
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`financial services industry as it ran contrary to the intent behind § 18(d)(1).”7 In
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`SAP, Versata tried to limit the definition of financial product or service to products
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`or services that a financial holding company could offer, but such definition was
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`rejected.8 Sony further pointed out that “the patent need not recite a specific
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`financial product or service.”9 Indeed, Versata’s contention that its patent is not a
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`6 See Pet. 12; SAP Am., Inc. v. Versata Dev. Grp., Inc., CBM2012-00001, Paper 36
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`at 21, 23 (P.T.A.B. Jan. 9, 2013) aff’d, 2014-1194, slip op. (Fed. Circ. July 9,
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`2015).
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`7 Pet. 12; see also SAP, Paper 36 at 22 (citing 77 Fed. Reg. 48,734, 48,736 (Aug.
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`14, 2012)).
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`8 SAP, Paper 36 at 22.
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`9 Pet. 13; see also SAP, Paper 36 at 23 (“We do not interpret the statute as
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`requiring the literal recitation of the terms financial products or services.”).
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`CBM patent because “financial products or services are not mentioned anywhere in
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`the claims or specification” was rejected in SAP.10
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`According to the legislative history, the Petition explained that patent claims
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`need only be broad enough to cover methods used in providing a financial product
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`or service, and need not include explicate limitations to a particular financial
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`product or service.11 Thus, “regardless of whether the asserted claims specifically
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`reference the type of product of service accused of infringing,” “if a patent holder
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`alleges that a financial product or service infringes its patent, that patent shall be
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`deemed to cover a ‘financial product or service’ for purposes of this
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`amendment.”12 Accordingly, the claims at issue are CBM eligible.
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`B.
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`In its decision, the Panel took a narrower view of the scope of
`CBM review than the Federal Circuit
`
`In its Decision, the Panel took a narrower view of the scope of CBM review,
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`holding that “claiming activities that are financial in nature, incidental to a
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`financial activity or complementary to a financial activity” means that the language
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`10 SAP, Paper 36 at 23.
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`11 Pet. 13 (citing 154 Cong. Rec. S1360–94, S1365 (daily ed. March 8, 2011)
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`(statement of Sen. Schumer)).
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`12 Pet. 12 (citing 154 Cong. Rec. S1365 (statement of Sen. Schumer)).
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`in the representative claim must “relat[e] to a financial product or service.”13 Based
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`on Federal Circuit precedent, this ruling is erroneous.
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`In the Decision’s analysis of whether the ’930 patent is a CBM patent, it
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`emphasized that the focus of the inquiry is on what the patent claims. And,
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`according to the Decision, it “[did] not find—any language in claim 23 relating to a
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`financial product or service.”14 The Decision further explained that the focus of its
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`inquiry is on “whether the ’930 patent claims a method of performing data
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`processing or other operations used in the practice, administration, or management
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`of a financial product or service.”15 Thus, the Decision misapprehends the law by
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`limiting its decision on whether the claims of the ’930 patent had literal recitation
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`of financial products or services.16
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`13 See Decision at 8, 9 (emphasis in original).
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`14 Decision 9.
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`15 Decision 10.
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`16 Compare Decision 9, 10 (requiring the language in claim 23 to be related to a
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`financial product or service), with Sony Comput. Entm’t Am. LLC v. ADC Tech.
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`Inc., CBM2015-00026, Paper 10 at 12 (P.T.A.B. July 3, 2015) (declining to
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`“interpret the statute as requiring the literal recitation of financial products or
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`services in a claim”).
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` 5
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`By limiting the analysis of claim 23 to a literal recitation of a financial
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`product or service, the Decision improperly read limitations into Section 18; such
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`limitations are absent and contrary to law.17 Indeed, the Federal Circuit rejected
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`this very approach, as noted below.18
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`C. The Federal Circuit recently confirmed that the Petition’s view on
`the scope of CBM review was correct
`In Versata, the Federal Circuit confirmed that the Petition’s view on the
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`scope of CBM review based on SAP was correct. The Federal Circuit affirmed SAP
`
`and expressly recited the proper standard as a matter of statutory construction:
`
`[T]he definition of “covered business method patent” is
`not limited to products and services of only the financial
`industry, or to patents owned by or directly affecting the
`activities of financial institutions such as banks and
`brokerage houses. The plain text of the statutory
`definition contained in § 18(d)(1)—“performing . . .
`operations used in the practice, administration, or
`
`
`17 See Pub. L. No. 112-29, 125 Stat. 284 (2011) (“AIA”).
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`18 Versata, slip op. at 35 (rejecting Versata’s position that the plain meaning of the
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`text of the statute limits the PTAB’s jurisdiction to products or services form the
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`financial sector, because “[t]o limit the definition as Versata argues would require
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`reading limitations into the statute that are not there.”).
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`management of a financial product or service”—on its
`face covers a wide range of finance-related activities.19
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`Therefore, according to the Federal Circuit, “[t]he statutory definition makes no
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`reference to financial institutions as such, and does not limit itself only to those
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`institutions.”20 Under similar reasoning, the statutory definition also does not limit
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`itself to patent claims that “literally recite” some financial products or services.
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`Had the Decision interpreted the definition of “covered business method
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`patents” as encompassing a wide range of finance-related activities, consistent with
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`Congressional intent and consistent with the Federal Circuit’s interpretation, the
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`Decision would have concluded that the ’930 patent is within the purview of
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`Section 18 as its claims are broad enough to affect finance-related activities.
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`III. There Are Additional Facts that Are Not Addressed in the Decision that
`Further Confirm that the ’930 Patent Is Eligible for CBM Review
`A. The Decision overlooked that claim 23 is a method claim broad
`enough to cover activities incidental or complementary to
`financial activities
`
`The Decision overlooked that claim 23 is a method claim, which supports
`
`that the ’930 patent is a CBM patent, because the scope of claim 23 covers
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`activities incidental and complementary to financial activities.
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`19 Id.; see also 77 Fed. Reg. at 48,736; Pet. 12.
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`20 Versata, slip op. at 35.
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` 7
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`The Panel’s inquiry of the claim scope should not end with the lack of
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`recitation of financial product or service, but the inquiry should include what the
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`claim scope actually covers.21 As the Petition has pointed out, the proper inquiry is
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`whether the claims are broad enough to cover methods used in providing a
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`financial product or service.22 The Decision, however, misapprehended the ’930
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`patent claim scope by narrowly requiring the actual recitation of a financial
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`product or service—for example, in its analysis, the Decision referred to an
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`Ethernet cable, a generic computer monitor, or a ballpoint pen.23 Claim 23,
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`however, is not claiming an apparatus or a method performed by or using such
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`apparatus—rather, claim 23 is a pure method claim. As such, claim 23 certainly
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`has broader coverage than an apparatus claim. The Decision overlooked this fact.
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`Moreover, the Decision overlooked that the examples in the Petition are
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`“financial in nature, incidental to a financial activity or complementary to a
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`financial activity.” As Sony pointed out, point-of-sale terminals, such as mag-stripe
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`readers operating as credit card readers, “fit perfectly within the definition of
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`financial product or service, as these PoE devices perform credit card
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` 8
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`21 See Pet. 13.
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`22 Id.
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`23 Decision 12.
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`
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`transactions—activities particular to financial products.”24 Radio Frequency
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`Identification (RFID) readers, used by retailers and their vendors for inventory
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`tracking, are also complementary to a financial activity, because “inventory control
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`is at least complementary to a financial activity, such as operation of a business
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`involving sales.”25 Similarly, IP trading turrets found on the financial trading floors
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`are “a ‘fundamental tool’ for financial traders and [are] part of their electronic
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`trading platform.”26 All of these examples specifically pertain to matters that are
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`“financial in nature, incidental to a financial activity or complementary to a
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`financial activity”; yet the Decision did not consider these examples, as needed.
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`Indeed, as explained in the Petition, the method in claim 23 is certainly
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`broad enough to cover the use of all these products and activities.27 Any end-users,
`
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`24 Pet. 16 (citing Volusion, Inc. v. Versata Software, Inc., CBM2013-00018, Paper
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`8 at 6 (P.T.A.B. October 24, 2013) (noting “financial product” specifically
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`includes “a credit card, an auto loan, or a mortgage”)).
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`25 Id. (quoting Wash. Inventory Serv. v. RGIS, LLC, CBM2014-00158, Paper 12 at
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` 9
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`
`
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`7 (P.T.A.B. January 26, 2015)).
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`26 Pet. 18.
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`27 See Pet. 13–14.
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`
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`such as retailers, or banking or financial services, would allegedly directly infringe
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`by performing the steps in claim 23:
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`(a) providing an access device (e.g., credit card readers,
`RFID readers, or IP turret system),
`(b) connecting the access device to a data signaling pair
`and data node (e.g., an Ethernet switch),
`(c) receiving a low level current at the access device,
`(d) producing a voltage level on the data signaling pair in
`response to the low level current, and
`(e) receiving controlled power at the access device in
`response to a preselected condition of the voltage
`level.
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`Because credit card readers, RFID readers, or IP turret systems are products that
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`are financial in nature, incidental to a financial activity or complementary to a
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`financial activity, the ’930 patent is broad enough to cover financial activities.28
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`Further, whether the claims of the ’930 patent cover a financial product or
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`service may also be determined by what the patent holder alleges to infringe its
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`patent.29 And it is a fact that Patent Owner has broadly asserted that all such
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`devices allegedly infringe the ’930 patent, further supporting that the ’930 patent is
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`28 See Pet. 15–19.
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`29 See Pet. 12.
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`10
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`broad enough to cover activities incidental or complementary to financial
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`activities.30 Specifically, the Petition pointed out that these examples are all
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`allegedly within the purview of the ’930 patent claims, as asserted by Patent
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`Owner, thus qualifying them for Patent Owner’s special licensing program for the
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`’930 patent.31 After all, mag-stripe readers (credit card readers) and RFID readers
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`were specifically identified from Patent Owner’s own list of products that qualify
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`for its licensing program.32 IP trading turrets were also identified from Patent
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`Owner’s ’930 patent licensee as an application of the licensed patent.33 Therefore,
`
`because the ’930 patent claims allegedly cover, and Patent Owner targets and
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`licenses, products incidental or complementary to financial activities, the ’930
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`patent qualifies as a CBM patent. Indeed, to use the examples from the Decision,
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`there is a significant difference between patents limited to an Ethernet cable (not
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`CBM) and a broad patent asserted against banks because banking transactions go
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`30 See Pet. 19.
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`31 See Pet. 15-19.
`
`32 Pet. 16.
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`33 Pet. 18.
`
`
`11
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`over an Ethernet cable (CBM). Congress’s intent to include the latter situation is
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`clear.34 The Decision overlooked this distinction.
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`B.
`
`The Decision overlooked the fact that Patent Owner has accused
`Petitioner’s products, which certainly may and do include
`products that are financial in nature, incidental to a financial
`activity or complementary to a financial activity
`
`The Decision overlooked that Patent Owner has accused additional products
`
`other than “IP telephones and wireless access points”; for example, Petitioner’s
`
`accused products, which support that the ’930 patent is a CBM patent, because
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`Petitioner’s accused products are used for transaction data analysis—an activity
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`incidental or complementary to financial activities.35
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`According to the Decision, “even if Petitioner’s view of the statute is
`
`correct,” the Panel was “not persuaded that Patent Owner has accused financial
`
`products or services of infringing the claims of the ’930 patent.”36 The Decision
`
`based its conclusion on Patent Owner’s statement that “it has accused ‘Ethernet
`
`data nodes (such as switches and hubs) and Ethernet powered devices (such as IP
`
`
`34 154 Cong. Rec. S1365 (statement of Sen. Schumer).
`
`35 Pet. 14–15; see also SAP, Paper 36 at 23 (finding that the term “financial is an
`
`adjective that simply means relating to monetary matters”).
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`36 Decision 13.
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`
`12
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`
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`telephones and wireless access points).’”37 Patent Owner’s statement, however, is
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`demonstrably false (and an improper basis) because, as Sony has pointed out in its
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`Petition, Patent Owner has accused “Sony’s PoE surveillance systems . . . [of]
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`infringing the ’930 patent”: specifically, Sony’s surveillance cameras.38 Thus,
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`contrary to the finding in the Decision, Patent Owner has accused products used
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`for “activities that are financial in nature, incidental to a financial activity or
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`complementary to a financial activity.”39
`
`As pointed out in the Petition, Sony’s accused products are frequently “used
`
`with point-of-sale terminals in retail services, allowing retailers to analyze
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`transaction data using video from the surveillance cameras.”40 Sony’s accused
`
`products allow the retailers to perform “advanced transaction data analysis,”
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`“optimize store operations and increase profit,” and “discover fraud by
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`‘maintain[ing] a complete overview of store operations.’”41 Therefore, because the
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`’930 patent claims affect transaction data analysis, which at a minimum is
`
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`37 Id. (citing Prelim. Resp. 39).
`
`38 Pet. 15 (emphasis added).
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`39 Pet. 14–15.
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`40 Pet. 14.
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`41 Id.
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`13
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`incidental or complementary to financial activities, and which reasonably can be
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`defined as a financial product or service, the ’930 patent certainly qualifies as a
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`CBM patent. The Decision also overlooked this.
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`Accordingly, the proceeding for CBM review should be instituted, because
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`the Decision misapprehended or overlooked these additional facts, all showing that
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`the ’930 patent is subject to CBM review.
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`IV. Conclusion: Due to Misapplication of the Law (Improper Application
`of Scope of CBM Patent Review) and Overlooking the Facts, the
`Decision Erred by Denying Institution of CBM Review in this
`Proceeding
`
`In this proceeding, the Panel misapprehended the law and overlooked facts
`
`that establish that the ’930 patent qualifies as a CBM patent. The Decision
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`erroneously required “literal recitation” of financial products or services in a claim,
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`which is not required, per the Federal Circuit, in Versata. In doing so, the Decision
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`contradicted the intent of Congress as to the proper standard for CBM review, and
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`indeed pursuant to the recent interpretation of the law as applied by the Federal
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`Circuit. The Decision further overlooked important facts that demonstrate that the
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`’930 patent is broad enough to cover a financial product or service, and certainly
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`products that are “financial in nature, incidental to a financial activity or
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`complementary to a financial activity.” Therefore, the claims at issue are within the
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`scope of CBM review as a threshold matter. As a result, the Decision abused its
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`14
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`discretion and thus erred in denying institution of CBM patent review in this
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`proceeding.
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`Accordingly, the Panel should grant this request and institute the proceeding.
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`
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`Dated: July 30, 2015
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`
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`Respectfully submitted,
`
`
`
`By: /Lionel M. Lavenue/
`Lionel M. Lavenue, Lead Counsel
`Reg. No. 46,859
`
`
`
`Finnegan, Henderson, Farabow,
`Garret & Dunner, LLP
`11955 Freedom Drive
`Reston, VA 20190
`
`Attorney for Petitioner
`Sony Corporation of America
`
`
`
`
`15
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a copy of the foregoing Petitioner’s Request
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`for Rehearing was served on July 30, 2015, via email directed to counsel of
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`record for Patent Owner at the following:
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`Charles F. Wieland III, Esq.
`charles.wieland@bipc.com
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`Robert G. Mukai, Esq.
`robert.mukai@bipc.com
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`BUCHANAN INGERSOLL & ROONEY PC
`1737 King Street, Suite 500
`Alexandria, Virginia 22314-2727
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`/Ashley F. Cheung/
`Ashley Cheung
`Case Manager and PTAB Legal Assistant
`Coordinator
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`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, L.L.P.
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