`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`
`
`TRADESTATION GROUP INC.,
`TRADESTATION SECURITIES, INC., IBG LLC, and
`INTERACTIVE BROKERS LLC.,
`Petitioners,
`
`
`v.
`
`
`TRADING TECHNOLOGIES INTERNATIONAL, INC.,
`Patent Owner.
`
`____________
`
`
`Case CBM2015-001611
`Patent No. 6,766,304
`
`___________
`
`
`
`PETITIONERS’ OPPOSITION TO PATENT OWNER’S
`MOTION TO EXCLUDE UNDER 37 C.F.R. 42.64(C)
`
`
`1 Case CBM2016-00035 has been joined with this proceeding.
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`
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`Case CBM2015-00161
`Attorney Docket No. 41919-0005CP1
`TABLE OF CONTENTS
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`I.
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`INTRODUCTION ............................................................................................... 1
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`II. ARGUMENT ...................................................................................................... 3
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`A. The TSE manual has been properly authenticated. ....................................... 3
`
`1. Admissible evidence shows that Exhibit 1016 is what Petitioners purport it to be. ..... 3
`2. Mr Kawashima’s testimony authenticates Exhibit 1016. ............................................. 3
`B. TSE is relevant under Fed. R. Evid. 401. ...................................................... 8
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`1. TSE is a prior art printed publication. .......................................................................... 8
`2. TSE is relevant even though no prior art grounds remain in the proceeding. .............. 8
`C. The O’Connell Affidavit is admissible. ........................................................ 9
`
`1. Ms. O’Connell had personal knowledge of the standard operating procedures used to
`translate the TSE manual. ................................................................................................... 9
`2. Ms. O’Connell’s sworn affidavit need not contain statements for perjury. ............... 10
`D. The testimony in Exhibit 1025 is highly probative and admissible. ........... 11
`
`III. CONCLUSION ................................................................................................. 13
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`i
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`Case CBM2015-00161
`Attorney Docket No. 41919-0005CP1
`
`I.
`
`INTRODUCTION
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`Patent Owner, Trading Technologies International, Inc. (“TT”), moves to ex-
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`clude Exhibits 1016, 1017 and 1025. TT’s objections to Exhibits 1016 and 1017 re-
`
`late to the so-called TSE (or “Tokyo Stock Exchange”) manual. First, TT chal-
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`lenges the authenticity and relevance of the TSE manual. (Exhibit 1016.) Second,
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`TT contends that the affidavit certifying the English translation of the TSE manual
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`(Exhibit 1017) does not comply with the rules. Finally, TT seeks to exclude cross-
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`examination testimony (Exhibit 1025) from TT’s own declarant that TT finds too
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`prejudicial for the Board to hear. Petitioners request that the Board deny TT’s mo-
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`tion because it fails to establish any valid basis to exclude clearly relevant evi-
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`dence.
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`First, no legitimate challenge can be made to the authenticity of the TSE
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`manual. There is unequivocal and reliable evidence to support the finding that Ex-
`
`hibit 1016 is what it purports to be: namely, a 1998 publication issued by the To-
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`kyo Stock Exchange. In a parallel proceeding, CBM2015-00179, TT deposed an
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`employee of the Tokyo Stock Exchange, Atshushi Kawahima, who authenticated
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`the manual during his deposition. (Exhibit 2163.) TT had also deposed Atshushi
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`Kawahima in a district court litigation in 2005. (CBM2015-00179, Ex. 1007.)
`
`Second, Petitioners have presented evidence in a parallel proceeding estab-
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`lishing that TSE is prior art describing a GUI used in electronic trading. TSE is
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`1
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`Case CBM2015-00161
`Attorney Docket No. 41919-0005CP1
`thus relevant to the issue of whether the claims under review are directed to an in-
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`ventive concept.
`
`TT’s attempts to exclude the English translation of TSE (Exhibit 1017) like-
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`wise lack merit. The affidavit submitted certifying the accuracy of the translation
`
`was issued by a manager with personal knowledge of the rigorous standards em-
`
`ployed at every step of the translation of the TSE manual to ensure its accuracy.
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`Further, the law that TT cites to argue that the affidavit is improper does not apply
`
`to the sworn affidavit at issue here.
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`Finally, TT’s efforts to exclude the cross-examination testimony of its own
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`declarant should be rejected. TT’s expert admitted that the claimed inventions do
`
`not improve computers. (See, e.g., Ex. 1025, 57:18-58:13.) That testimony is rele-
`
`vant to whether or not TT’s patent claims are patent eligible. TT had a full and fair
`
`opportunity to try to rehabilitate its witnesses through redirect. It chose not to do
`
`so. Instead, TT uses this motion as a thinly-disguised attempt to argue the merits of
`
`whether “the claimed inventions do not improve computers.” (Paper 104 at 9.) But
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`TT has exhausted its opportunities to submit briefs arguing the merits and could
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`have attempted to rehabilitate its declarants at their depositions. Thus, the Board
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`should deny TT’s motion.
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`2
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`Case CBM2015-00161
`Attorney Docket No. 41919-0005CP1
`
`
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`II. ARGUMENT
`
`A. The TSE manual has been properly authenticated.
`1.
`Admissible evidence shows that Exhibit 1016 is what
`Petitioners purport it to be.
`
`
`2. Mr Kawashima’s testimony authenticates Exhibit
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`1016.
`In a parallel proceeding, Petitioners have produced unequivocal and unrebut-
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`ted evidence showing that Exhibit 1016 is the TSE manual. CBM2015-00179, Ex-
`
`hibit 1007. That evidence meets the requirement for authentication under each of
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`Fed. R. Evid. 901, 902(11), and 901(b)(4). Specifically, CBM2015-00179, Exhibit
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`1007 consists of a deposition transcript of Mr. Kawashima’s testimony establishing
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`that: (1) CBM2015-00179, Exhibit 1007 is “the current futures options trading sys-
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`tem—trade manual” (CBM2015-00179 Ex. 1007, 9:19-10:9); (2) the document
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`was prepared on or around August of 1998 by the Tokyo Stock Exchange
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`(CBM2015-00179 Ex. 1007, 11:3); (3) Mr. Kawashima prepared Exhibit 1007 in
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`the ordinary course of business, as a regular practice of the Tokyo Stock Exchange
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`(CBM2015-00179 Ex. 1007, 11:4-14); and (4) the TSE manual was maintained by
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`the Tokyo Stock Exchange in the ordinary course of business. (CBM2015-00179
`
`Ex. 1007, 11:14-24.)
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`3
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`Case CBM2015-00161
`Attorney Docket No. 41919-0005CP1
`Furthermore, independent of Kawashima’s 2005 deposition testimony Peti-
`
`tioners authenticated the TSE manual during Mr. Kawashima’s second deposition.
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`(CBM2015-00179, Ex. 2163, 45:7-46:3.) And Fed. R. Evid. 901(b)(1) provides
`
`that “a proponent may authenticate evidence through testimony.” See, e.g., SAP
`
`Am., Inc. v. Arunachalam, IPR2013-00195, Paper 60 at 22 (P.T.A.B.
`
`Sept. 18, 2014). Mr. Kawashima “was in charge of preparing the document.”
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`(CBM2015-00179, Ex. 1007 at 11:3.) He is, and was, competent to identify it for
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`purposes of authentication. Rosenberg v. Collins, 624 F.2d 659, 665 (5th Cir.
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`1980) (“Any person in a position to attest to the authenticity of certain records is
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`competent to lay the foundation for the admissibility of the records; he need not
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`have been the preparer of the record, nor must he personally attest to the accuracy
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`of the information contained in the records.”) See, e.g., EMC Corp. v. Personalweb
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`Techs., LLC, IPR2013-00084, Paper 64 at 44 (May 15, 2014) (rejecting argument
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`that a witness cannot authenticate a document unless he himself authored it).
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`TT’s criticism of the way Mr. Kawashima verified his identification of the
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`TSE manual (based on his personal knowledge about how it was prepared), does
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`not undermine authenticity in any legally cognizable way. (CBM2015-00179, Pa-
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`per 114 at 6-7.) Indeed, TT does not cite any legal authority in support of the
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`standard it asks the Board to impose on Mr. Kawashima. Nor does the law require
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`4
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`Case CBM2015-00161
`Attorney Docket No. 41919-0005CP1
`a witness to specify precisely how they would go about confirming their identifica-
`
`tion of a document, given that a witness need not attest to its complete accuracy.
`
`See Rosenberg, 624 F.2d at 665.
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`a)
`
`Exhibit 1016 is self-authenticated under Fed. R. Evid.
`902(11).
`Additionally, Exhibit 1017 is self-authenticated under Fed. R. Evid. 902(11)
`
`because it comes from the business records of the Tokyo Stock Exchange, whose
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`regularly conducted activity of preparing and maintaining manuals, such as the
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`TSE manual, has been established by Mr. Kawashima, who was an employee with
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`the requisite knowledge during the relevant timeframe (CBM2015-00179, Ex.
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`1007 at 5:15-21; 11:4-24). Dataquill Ltd. v. Handspring, Inc., 2002 WL 31870560,
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`at *3 (N.D. Ill. 2002) (finding that “user manuals [] prepared in the ordinary course
`
`of business . . . fall under the business record exception” and “meet the authentica-
`
`tion standard”).
`
`Mr. Kawashima’s testimony stands unrebutted that the TSE manual was pre-
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`pared and maintained as a regularly conducted activity in the ordinary course of
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`business (CBM2015-00179, Ex. 1007, 11:4-24). Fed. R. Evid. 803(6)(B)-(D).
`
`When Mr. Kawashima testified in 2005 as to its authenticity, the TSE manual was
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`only seven years old. (CBM2015-00179, Ex. 1007, 10:21-24.) Fed. R. Evid.
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`803(6)(A). TT has not shown, nor can it, that “the source of information or the
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`method or circumstances of preparation indicate any lack of trustworthiness.” Fed.
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`5
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`Case CBM2015-00161
`Attorney Docket No. 41919-0005CP1
`R. Evid. 803(6)(E). Accordingly, all of the requirements for authenticating the TSE
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`manual (Exhibit 1017) as a record of regularly conducted activity are satisfied in
`
`this case. Fed. R. Evid. 902(11).
`
`b)
`
`Exhibit 1016 is authenticated under Fed. R. Evid.
`901(b)(4).
`And, although not necessary, the TSE manual is also authenticated under
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`Fed. R. Evid. 901(b)(4) which provides that “appearance, contents, substance, in-
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`ternal patterns, or other distinctive characteristics of the item, taken together with
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`all the circumstances” is sufficient to satisfy the Fed. R. Evid. 901(a). Exhibit 1016
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`shows a distinctive layout with a large number of unique illustrations. Exhibit 1016
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`also includes the Bates numbering applied in connection with the related district
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`court action. (Ex. 1017, marked “DX 179” with Bates numbers “TSE 647-981,”
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`and page numbering “1-1” etc.) This branding is distinctive and confirms the au-
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`thenticity of Exhibit 1016. As explained below, the special circumstances here in-
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`clude that Mr. Kawashima made himself available for cross-examination in this
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`proceeding. Therefore, Petitioners have laid a sufficient foundation to establish that
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`Exhibit 1016 is authentic under Fed. R. Evid. 901(b)(4). See, e.g., Ericsson Inc. v.
`
`Intellectual Ventures I LLC, IPR2014-00527, Paper 41 at 12 (P.T.A.B. May 18,
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`2015) (finding collection of papers with sequential pages authenticated).
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`Accordingly, because Petitioners properly authenticated the TSE manual in
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`numerous ways, and TT offers no evidence suggesting the TSE manual is not what
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`6
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`Case CBM2015-00161
`Attorney Docket No. 41919-0005CP1
`Petitioners purports it is, TT’s request to exclude Exhibit 1016 should be denied.
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`But even if TT had raised legitimate questions, which TT has not, “[a]ny doubts. . .
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`[go] to the weight and not the admissibility of the [evidence].” United States v. Al-
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`bert, 595 F.2d 283, 290 (5th Cir. 1979), cert. denied, 444 U.S. 963 (1979).
`
`c)
`
`TT deposed Kawashima twice and still has no basis to
`dispute Exhibit 1016’s authenticity; Kawashima’s tes-
`timony is admissible.
`Mr. Kawashima gave direct testimony and made himself available for cross-
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`examination in this proceeding to answer questions about the TSE manual.
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`TT first deposed Mr. Kawashima in 2005, resulting in the transcript offered in
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`CBM2015-00179, Exhibit 1007. CBM2015-00179, Exhibit 1007 authenticates the
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`TSE manual. On March 9, 2016, TT objected to Petitioners’ proffer of Exhibit
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`1007 on grounds that it amounted to impermissible hearsay. (CBM2015-00179,
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`Paper 30 at 3.) Hoping to resolve TT’s objection and avoid this motion, Petitioners
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`made Mr. Kawashima available for cross-examination in the parallel proceeding
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`specifically to allow TT to ask questions about the TSE manual. (CBM2015-
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`00179, Paper 39; Paper 65; Ex. 2163, 26:22-27:25.) The second deposition took
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`place on June 17, 2016. (CBM2015-00179, Ex. 2163.) During this deposition Mr.
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`Kawashima corroborated his prior testimony. (Ex. 2163, 45:7-61:2; 43:2-21; 51:6-
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`7
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`Case CBM2015-00161
`Attorney Docket No. 41919-0005CP1
`61:2.) Having failed to support a challenge to the veracity or reliability of Mr. Ka-
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`washima’s authentication, despite the opportunity to do so, TT has no reasonable
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`basis to question its authenticity.
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`B. TSE is relevant under Fed. R. Evid. 401.
`1.
`TSE is a prior art printed publication.
`Petitioners have established that TSE was actually disseminated and other-
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`wise available to the interested public in August 1998 in a Reply in a parallel pro-
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`ceeding. (CBM2015-00179, Paper 110 at 13-14.) Specifically, Petitioners pointed
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`to unrebutted evidence that TSE was disseminated to 200 participants in the Tokyo
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`Stock Exchange. (CBM2015-00179, Petition, at 21-22; Ex. 1007.) TT received a
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`full and fair opportunity to cross-examine the witness who testified to these facts,
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`Mr. Aisushi Kawashima. (CBM2015-00179, Ex. 2163.) TT cannot point to any-
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`thing that contradicts his testimony.
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`2.
`TSE is relevant even though no prior art grounds re-
`main in the proceeding.
`Petitioners properly point to TSE as evidence that using an interactive GUI
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`
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`to place an order based on observed market information was well-known in the
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`electronic trading world before the ’304 patents, and thus it cannot serve as an “in-
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`ventive concept” to impart patent eligibility. (Petition, Paper 2 at 36.) The Federal
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`Circuit routinely queries what was well-known art in evaluating patent-eligibility.
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`See, e.g., Content Extraction & Transmission LLC v. Wells Fargo Bank, Nat.
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`8
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`Case CBM2015-00161
`Attorney Docket No. 41919-0005CP1
`Ass’n, 776 F.3d 1343, 1348 (Fed. Cir. 2014), cert. denied, 136 S. Ct. 119, 193 L.
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`Ed. 2d 208 (2015) (finding claims patent ineligible where defendant “conceded at
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`oral argument that the use of a scanner or other digitizing device to extract data
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`from a document was well-known at the time of filing, as was the ability of com-
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`puters to translate the shapes on a physical page into typeface characters.”). More-
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`over, McRO, Inc. v. Bandai Namco Games Am. Inc., No. 2015-1080, 2016 WL
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`4896481, at *8 (Fed. Cir. Sept. 13, 2016), relied on by TT, actually supports the
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`relevancy of TSE. The opinion noted that the defendants failed to point to any evi-
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`dence that persons of skill in the art were employing the type of technology cov-
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`ered by the claims. Id. (“[T]hat information makes no suggestion that animators
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`were previously employing the type of rules required by claim 1.”). Here, Petition-
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`ers are pointing to TSE as evidence that traders were using exactly the type of tech-
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`nology covered by the claims. TSE is thus relevant to this proceeding and should
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`be admitted.
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`C. The O’Connell Affidavit is admissible.
`1. Ms. O’Connell had personal knowledge of the stand-
`ard operating procedures used to translate the TSE manual.
`
`TT argues that the TSE translation (Exhibit 1017) should be excluded be-
`
`cause it is not a credible translation as the person attesting to the accuracy of the
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`TSE translation was not qualified to make the affidavit. Ms. O’Connell testified
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`9
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`Case CBM2015-00161
`Attorney Docket No. 41919-0005CP1
`that (1) the translation of the TSE manual complied with a standard process that
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`had been in place for 20 years and is followed on every single translation project,
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`and that (2) TransPerfect assigns to translation projects only those linguists who
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`have completed a linguist certification program. (CBM2015-00137, Ex.2093 at
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`63:10-13, 66:8-15, 82:20-22.) Ms. O’Connell’s personal knowledge of TransPer-
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`fect’s execution of the translation project qualifies her to certify that the resulting
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`translation was a true and accurate translation.
`
`2. Ms. O’Connell’s sworn affidavit need not contain
`statements for perjury.
`TT further challenges Ms. O’Connell’s affidavit, insisting that it does not
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`comply with the Board’s rules for a proper affidavit. TT cites 37 C.F.R. § 1.68 and
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`28 U.S.C. § 1746 to support the argument that the affidavit is improper because it
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`lacks the required statements for perjury. The authorities that TT cites are inappli-
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`cable as they set forth the requirements for the admissibility of an unsworn decla-
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`ration. See 28 U.S.C. § 1746 (stating that unsworn declarations under penalty of
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`perjury may be used where a matter is required or permitted to be supported by
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`sworn declaration or affidavit); 37 C.F.R. § 1.68 (stating the requirements for a
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`declaration in lieu of an oath). Ms. O’Connell’s affidavit was sworn before a no-
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`tary and bears the signature and stamp of the notary public. The affidavit thus is
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`admissible as a sworn statement. Pfeil v. Rogers, 757 F.2d 850, 859 (7th Cir. 1985)
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`10
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`Case CBM2015-00161
`Attorney Docket No. 41919-0005CP1
`(applying the “clearly recognized rule” that the “absence of the formal require-
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`ments of a jurat in…sworn affidavits does not invalidate the statements or render
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`them inadmissible if they were actually sworn to before an officer authorized to ad-
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`minister an oath.”).
`
`D. The testimony in Exhibit 1025 is highly probative and admissible.
`TT urges the Board to exclude choice portions of a deposition transcript of
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`TT’s own declarant, Dan Olsen. (Exhibit 1025, 57-58.) TT’s argument can be
`
`summed up as seeking to exclude unfavorable testimony and otherwise using this
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`Motion to Exclude as an unauthorized sur-reply to argue the merits of whether “the
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`claimed inventions do not improve computers.” (Paper 104 at 9.)
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`Fed. R. Evid. 403 provides that evidence may be excluded if its probative
`
`value is substantially outweighed by the danger of unfair prejudice, confusing the
`
`issues, misleading the fact-finder, undue delay, wasting time, and/or presenting
`
`needlessly cumulative evidence. Here, the material sought to be excluded consists
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`of factually true admissions explaining how the claims are not directed to various
`
`technological improvements. These admissions are highly probative of patent eligi-
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`bility. In turn, TT appears to rely on the “unfair prejudice,” “confusing” and “mis-
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`leading” aspects of Fed. R. Evid. 403. But there is simply no danger of confusing
`
`or misleading the Board. The Board is perfectly capable of according these admis-
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`
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`11
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`Case CBM2015-00161
`Attorney Docket No. 41919-0005CP1
`sions appropriate weight in view of all the evidence. And TT has failed to demon-
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`strate even a remote likelihood that the statements will be misinterpreted or misun-
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`derstood. TT may disagree with the legal conclusions to be drawn from these ad-
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`missions; however, that is not a cognizable basis for excluding evidence.
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`Indeed, TT has exhausted its opportunities to brief the merits and rehabilitate
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`its experts with such explanations as “[r]ather than admitting the claimed inven-
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`tions do not improve computers, Mr. Olsen was simply stating what was not ex-
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`plicitly recited by the claims.” (Paper 114 at 10, 15.) This argument has nothing to
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`do with balancing probative value and unfair prejudice under Fed. R. Evid. 403; it
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`is an improper attempt to explain away highly probative admissions.
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`And, as a general policy, it is not unfairly prejudicial to place the burden of
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`seeking clarification on the testifying expert. In fact, this has long been the Board’s
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`practice.2 Here, counsel for Petitioners properly instructed the witness. (See, e.g.,
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`2 Cf. U.S. PATENT & TRADEMARK OFFICE, Standing Order of Jan. 3, 2006 Govern-
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`ing Contested Cases Assigned to Trial Division, Board of Patent Appeals and In-
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`terferences, Cross Examination Guidelines, Appendix, p. 71 (Jan. 2006), available
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`https://www.uspto.gov/web/offices/dcom/bpai/Standing-Order.pdf (“Guideline [1]
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`At the beginning of a cross examination, the party conducting the cross examina-
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`tion must instruct the witness on the record to ask deposing counsel, rather than the
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`12
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`Case CBM2015-00161
`Attorney Docket No. 41919-0005CP1
`Ex. 1025, Olsen Dep. Tr., 6:9-17) Having been instructed, and free to seek clarifi-
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`cation as needed, the answers provided are in accordance with the ground rules for
`
`cross-examination. TT’s attempt to erase truthful, albeit unfavorable, responses
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`given by its experts should be denied.
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`III. CONCLUSION
`
`For the above reasons, Petitioners submit that Exhibits 1016, 1017, and 1025
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`should be allowed entry into the proceeding, and Patent Owner’s Motion to Ex-
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`clude should be denied.
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`Dated: October 7, 2016
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`Respectfully submitted,
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`/John C. Phillips/
`John C. Phillips, Reg. No. 35,322
`Attorney for Petitioners
`
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`witness’s own counsel, for clarifications, definitions or explanations of any words,
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`questions or documents presented during the cross examination. The witness must
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`follow these instructions.”) See also Hall v. Clifton Precision, 150 F.R.D. 525
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`(E.D. Pa. 1993) (serving as the model for the Standing Order).
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`13
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`Case CBM2015-00161
`Attorney Docket No. 41919-0005CP1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR §§ 42.6(e)(4) and 42.205(b), the undersigned certifies
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`that on October 7, 2016, a complete and entire copy of this Petitioners’ Opposition
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`to Patent Owner’s Motion to Exclude was provided via email to the Patent Owner
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`by serving the correspondence address of record as follows:
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`Erika H. Arner, Joshua L. Goldberg, Kevin D. Rodkey,
`Rachel L. Emsley, and Cory C. Bell
`Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
`Email: erika.arner@finnegan.com
`joshua.goldberg@finnegan.com
`kevin.rodkey@finnegan.com
`rachel.emsley@finnegan.com
`cory.bell@finnegan.com
`
`Steven F. Borsand
`Trading Technologies International, Inc.
`Email: tt-patent-cbm@tradingtechnologies.com
`
`
`Michael D. Gannon, Leif R. Sigmond, Jr., and Jennifer M. Kurcz
`McDonnell Boehnen Hulbert & Berghoff LLP
`Email: gannon@mbhb.com
`sigmond@mbhb.com
`kurcz@mbhb.com
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`/Diana Bradley/
`
`Diana Bradley
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(858) 678-5667
`
`
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