Case CBM2015-00182
`U.S. Patent 6,772,132
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` Paper No. ____
` Filed: August 16, 2016
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`IBG LLC; INTERACTIVE BROKERS LLC;
`TRADESTATION GROUP, INC.; TRADESTATION SECURITIES, INC.;
`TRADESTATION TECHNOLOGIES, INC.;
`and IBFX, INC.
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`Petitioners
`v.
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` TRADING TECHNOLOGIES INTERNATIONAL, INC.
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`Patent Owner
`_________________
`Case CBM2015-00182
`U.S. Patent 6,772,132
`_________________
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`PATENT OWNER’S MOTION TO SUBMIT SUPPLEMENTAL
`INFORMATION AND BRIEFING UNDER 37 C.F.R. § 42.223(b)
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`U.S. Patent 6,772,132
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` Paper No. ____
` Filed: August 16, 2016
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`IBG LLC; INTERACTIVE BROKERS LLC;
`TRADESTATION GROUP, INC.; TRADESTATION SECURITIES, INC.;
`TRADESTATION TECHNOLOGIES, INC.;
`and IBFX, INC.
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`Petitioners
`v.
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` TRADING TECHNOLOGIES INTERNATIONAL, INC.
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`Patent Owner
`_________________
`Case CBM2015-00182
`U.S. Patent 6,772,132
`_________________
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`PATENT OWNER’S MOTION TO SUBMIT SUPPLEMENTAL
`INFORMATION AND BRIEFING UNDER 37 C.F.R. § 42.223(b)
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`Patent Owner (“TT”) moves to submit supplemental information and
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`Case CBM2015-00182
`U.S. Patent 6,772,132
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`briefing under 37 C.F.R. § 42.223(b), as authorized by the Board. Paper 82.1
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`Although TT has been trying to submit this information for months, Petitioners
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`have objected due to the district court protective order (“PO”) under which the
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`information was produced. Because Petitioners only recently withdrew their PO
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`objections, TT could not have provided this information earlier.
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`It is in the interests of justice for TT to be permitted to submit supplemental
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`information and briefing because Petitioners’ documents and testimony directly
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`support TT’s positions on non-obviousness and patent eligibility, while
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`contradicting the position of Petitioners and their experts. Petitioners’ experts
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`falsely claim that GUIs are not technological in nature, GUIs are not functional and
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`instead are merely an arrangement of known elements on a computer screen that
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`have no purpose beyond aesthetics, and that there is no inventive concept disclosed
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`and claimed in TT’s patents. And yet, evidence from Petitioners’ files tells a
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`different story. There is no burden or prejudice to Petitioners that will result from
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`1 Pursuant to the Board’s order, TT has only summarized the supplemental
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`information without directly filing them and interprets the Board’s order to
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`preclude quoting from the documents as well. However, the language of the
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`documents strongly supports TT’s position and TT would welcome the opportunity
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`to submit quotes, excerpts, and the documents themselves.
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`1
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`TT submitting such information as they may address it in their Reply due
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`Case CBM2015-00182
`U.S. Patent 6,772,132
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`September 9, 2016. Thus, TT seeks to submit the documents described below
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`along with a 10-page supplemental brief.
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`I.
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`THE INFORMATION REASONABLY COULD NOT HAVE BEEN
`SUBMITTED EARLIER DUE TO PETITIONERS’ REPEATED
`CONFIDENTIALITY OBJECTIONS AND THE TIMING OF
`RECEIPT OF THE INFORMATION
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`TT could not have reasonably submitted the information it seeks to
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`supplement the record with earlier. See 37 C.F.R. § 42.223(b). First, TT did not
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`receive all of the documents, testimony, or authentication of the evidence until the
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`second week of June, after TradeStation (“TS”) and IB depositions from June 8-13,
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`2016. See infra § II. Thus, the earliest TT could have possibly submitted this body
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`of evidence (if not for Petitioners’ PO objections) was after those depositions.
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`Second, TT could not submit this information in its Patent Owner Responses
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`(“PORs”) due two weeks later because Petitioners have continuously, and
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`strategically objected to TT’s reliance or filing of any of Petitioners’ confidential
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`information based on the fact that Petitioners produced such information under the
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`district court’s PO2, and not the PTAB’s. Indeed, TT has acted diligently from even
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`2 Petitioners have objected based the district court PO that provides that
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`confidential information “shall not be used for any purpose other than in this
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`Proceeding.” Ex. 2407, ¶11. The PO was entered more than a year before
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`U.S. Patent 6,772,132
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`before the date discovery was completed (June 13) to make this evidence of record,
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`engaging Petitioners numerous times to try to resolve the PO issues to use the
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`documents produced in the litigation in the PTAB. For example, in early May, TT
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`requested that Petitioners produce this information in the PTAB proceedings under
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`the default PO (see Ex. 2395), but Petitioners refused this streamlining, demanding
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`TT instead seek the information as Additional Discovery (see Ex. 2396).
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`In late May, TT’s litigation counsel again requested that Petitioners agree
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`that TT could use the information at the PTAB notwithstanding the PO, but
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`Petitioners again objected, delaying weeks to confer on this point. Ex. 2397. TT’s
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`PTAB counsel repeated its request to Petitioners’ PTAB counsel on May 31 (Ex.
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`2398), and held conferrals on June 2 (Ex. 2399 at 1-3) and June 7 (Ex. 2400). The
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`disagreement culminated with the Board call on June 13, where Petitioners
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`admitted that “documents that are merely proprietary to [TS] could be reproduced
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`separate from the litigation without violating that protective order.” Ex. 2140 at
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`18:22-19:9. The Board authorized TT to file a Motion for Additional Discovery by
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`June 15, but Petitioners’ objections based on the PO still stood in the way of TT
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`filing or referencing Petitioners’ information in that motion.
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`As such, TT filed an emergency motion with the district court, noticed for
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`June 15, seeking permission to bring such documents to the Board’s attention. On
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`enactment of the AIA creating CBM and IPR proceedings, and the PTAB itself.
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`3
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`June 14, Petitioners reached out to TT and offered to “moot” TT’s district court
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`Case CBM2015-00182
`U.S. Patent 6,772,132
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`motion (see Ex. 2401) and later agreed that TT could reference and file a
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`representative sample of the documents in its Motion. TT agreed to the proposal
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`and withdrew its district court motion. However, this Board denied TT’s motion
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`for Additional Discovery on Friday, June 24. As TT’s PORs were due the
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`following Monday, on June 27, there was no time for TT to seek relief from the
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`district court prior to filing the PORs.
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`On July 1, TT sought relief from the district court PO to file the materials in
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`an offer of proof before the PTAB. The district court granted the motion on July 7,
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`stating that the basis was “because the PTAB has to have all material, relevant
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`information, to make its determination. And to have all of this relevant information
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`that I’ve deemed to be appropriate in this litigation and not have it in front of them
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`doesn’t move the proceeding . . . .” Ex. 2402 at 13:17-21.
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`TT requested a call with the Board on July 8 to seek authorization to file an
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`offer of proof. The Board held the call on July 15 and on July 19, the Board denied
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`TT’s request but suggested that TT seek supplemental information and briefing at
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`this stage of the proceeding. Paper 73 at 6.
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`Thus, the week of July 25, TT notified Petitioners that TT would file a
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`motion with the district court seeking leave to file the requested materials with the
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`Board as supplemental information. On July 29, Petitioners notified TT that they
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`would not object to TT’s request to file the transcripts and documents as
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`Case CBM2015-00182
`U.S. Patent 6,772,132
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`supplemental information/briefing on the basis of the PO, and that TT could
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`reference such material in a motion, so long as any confidential material was filed
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`under the default PO for the CBM proceedings. Ex. 2403 at 2-3. On August 1,
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`Petitioners clarified that TT could refer to confidential material on the Board call
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`as well. TT requested a board call on August 8, 2016. Id. at 1. The Board
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`authorized TT’s filing of the present motion on August 10, 2016. Paper 82.
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`Petitioners are responsible for TT’s not submitting the information sooner.
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`Had Petitioners simply agreed earlier that their confidential information could be
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`protected by the default PO, TT could have submitted the documents and
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`arguments with its PORs. It was only after TT already filed its PORs and the
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`district court made clear that it believed this information should be submitted to the
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`PTAB that Petitioners’ concerns with confidentiality have dissolved without
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`explanation. Ex. 2393 at 11. TT cannot now be faulted for respecting the orders of
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`this tribunal denying the Additional Discovery, and seeking to minimize, not
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`duplicate, its efforts to achieve the same result with the district court. TT should be
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`permitted to rely on and affirmatively submit the testimony and documents in
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`supplemental briefing now that the PO issues have been resolved.
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`II. THE INTERESTS OF JUSTICE REQUIRE THAT TT SHOULD
`BE ABLE TO SUBMIT EVIDENCE CONTRADICTING
`PETITIONERS’ POSITIONS
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`5
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`Here, the interests of justice require that TT be permitted to submit evidence
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`Case CBM2015-00182
`U.S. Patent 6,772,132
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`that is highly relevant to this case. The PTAB has explained that “[w]ith respect to
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`the issue of whether submission of the supplemental information is in the interests
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`of justice, we are mindful that a trial is, first and foremost, a search for the truth.”
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`Edmund Optics, Inc. v. Semrock, Inc., IPR2014-00599, Paper 44 (granting request
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`for supplemental information) (citing Nix v. Whiteside, 475 U.S. 157, 166 (1986)).
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`The ten documents and transcripts TT identifies below are unique because
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`they provide the Petitioners’ true perspective on issues central to this proceeding,
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`such as objective indicia of nonobviousness and the technological nature of the
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`claimed invention, all in contravention of Petitioners’ positions before this Board:
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`Ex. # Title
`21503 6/8/16 30(b)(6) Deposition Tr. of TradeStation (John Bartleman,
`CEO)
`6/9/16 30(b)(6) (cont.) & Personal Deposition Tr. of John
`Bartleman, CEO (“6/9/16 Bartleman Tr.”)
`2144 TradeStation Matrix Requirements, dated May 19, 2003
`(TS0107054 – TS0107075)
`Trading Technologies Webpage describing MD Trader, dated
`April 11, 2003 (“PDX 3043”)
`2145 Trading Options with TradeStation OptionStation, dated April 13,
`2010 (TS0024612 – TS0024677)
`2143 Barron’s Presentation dated February 15, 2011 (TS0028765 –
`TS0028808)
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`3 TT has included exhibit numbers for documents that were previously filed with
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`its Motion for Additional Discovery.
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`6
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`U.S. Patent 6,772,132
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`Email from J. Bartleman, dated December 20, 2008 (TS1533975 –
`TS1533976) (“PDX 3046”)
`2154 6/13/16 30(b)(6) Deposition Tr. of IB (Milan Galik, President of
`IB)
`2156 Email from M. Galik, dated June 14, 2010 (IBG_00026004 –
`IBG 00026005)
`2158 Email from M. Galik dated July 19, 2011 (IBG_00014726 –
`IBG_00014731)
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`Many of the documents were produced as a result of the district court’s order
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`in May of 2016, staying the litigation but ordering additional discovery despite the
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`stay because, as the district judge stated: “I believe the discovery materials will be
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`beneficial, both when the case resumes and also before the PTAB.” Ex. 2142
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`(emphasis added). As this Board moved the deadline for TT’s PORs so that this
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`information could be raised in this proceeding, the interests of justice favor
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`consideration. Further, the district court has reiterated that this information should
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`be considered. Ex. 2402 at 13:17-21 (“to have all of this relevant information that
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`I’ve deemed to be appropriate in this litigation and not have it in front of [the
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`PTAB] doesn’t move the proceeding”).
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`There is no burden or prejudice to Petitioners if TT submits this as
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`supplemental information or briefing as Petitioners have known TT’s positions on
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`these documents for months (see, e.g., Ex. 2398-2400), and have prevented TT’s
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`submission due to alleged confidentiality concerns that they have since withdrawn.
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`In any event, as the Board has limited TT’s request to only 10 documents out of 97
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`7
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`that it originally sought to submit, Petitioners should have no issue responding to
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`Case CBM2015-00182
`U.S. Patent 6,772,132
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`this evidence in their Reply. Thus, the interests of justice strongly support that TT
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`be permitted to submit this evidence to provide a full and accurate view of
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`Petitioners’ true perspective on the claimed inventions and their value.
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`Petitioners will likely argue that evidence related to the Matrix and
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`BookTrader are not relevant to the claims-at-issue in this proceeding. However,
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`this is not accurate. By way of background, there can be no dispute that TT’s
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`MD_Trader product embodies the patents-in-suit. See, e.g., Trading Tech. v.
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`eSpeed, Int’l, Inc., 595 F.3d. 1340, 1362 (Fed. Cir. 2010) (“MD_Trader, one of
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`TT’s commercial embodiments of the [‘304 and ‘132] patents-in suit .…”).
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`Likewise, Petitioners’ Matrix and BookTrader windows also embody the patent-in-
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`suit, a fact TT would specifically address in supplemental briefing. Indeed, the
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`Bartleman testimony and documents TT seeks to submit show that
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`, against the Matrix and BookTrader. Thus, the evidence below is
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`directly related to the claims-at-issue. See, e.g., Nike Inc., 812 F.3d at 1339;
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`8
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`Ashland Oil, Inc. v. Delta Resins & Refrac., Inc., 776 F.2d 281, 306 (Fed. Cir.
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`1985) (objective indicia “may be the most pertinent, probative, and revealing
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`evidence available to the decision maker in reaching a conclusion on the
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`obviousness/nonobviousness issue”); In re Cyclobenzaprine Hydrochloride Patent
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`Litig., 676 F.3d 1063, 1079 (Fed. Cir. 2012) (fact finder “must withhold judgment
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`on an obviousness challenge until it considers all relevant evidence, including that
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`relating to objective considerations”). Even Petitioners admitted on the June 13
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`Board call that “most of these requests relate to secondary considerations.…” Ex.
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`2140 at 19.
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`A. TS Testimony and Documents
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`1. 30(b)(6) Deposition Transcripts of TS and Personal Deposition of
`John Bartleman, TS CEO (6/8/16 and 6/9/16 Transcripts)
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`Mr. Bartleman, CEO of TS, gave binding corporate testimony on June 8,
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`2016 (Ex. 2150) and corporate and personal testimony on June 9, 2016. Exhibit
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`2150 authenticates Exhibits 2144 (Tr. at 255:9-25)4 and 2149 (Tr. at 333:2-14).
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`The June 9, 2016 Bartleman Transcript authenticates Exhibits 2143 (Tr. at 658:4-
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`20), 2145 (Tr. at 633:23-635:19), and 2147 (Tr. at 675:24-676:3).
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`TT’s POR explains that the claimed invention is patent eligible because it
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`4 Although TT is not filing exhibits per the Board’s instruction, TT has included
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`pin cites to the documents for the benefit of Petitioners’ response to TT’s motion.
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`improves the computer functionality. Paper 66 at 8. The June 9, 2016 Bartleman
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`Transcript is relevant because Mr. Bartleman admits that
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`. 6/9/16
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`Bartleman Tr. at 472:22-473:2. This supports that the claims are not abstract as the
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`structure, makeup, and functionality of Matrix improves the computer functioning.
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`TT’s POR states that the claimed invention is deeply rooted in technology.
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`Paper 66 at 11. Exhibit 2150 confirms this, as Mr. Bartleman testified that
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`2150 at 90:21-92:2; see also id. at 91:22-25; 6/9/16 Bartleman Tr. at 580:11-24,
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` Ex.
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`559:6-12, 668:22-669:11. At the time Matrix was developed in 2003,
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`6/9/16 Bartleman Tr. at 566:23-567:9, 649:21-650:20.
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`TT’s POR argues that the claimed invention goes against conventional
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`wisdom, and that problems with conventional GUI tools went unrecognized. Paper
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`66 at 30. Exhibit 2150 and the June 9, 2016 Bartleman transcript are directly
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`relevant to this position because Mr. Bartleman describes
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`73:25-74:16, 96:7-97:12, 169:22-173:5, 270:22-272:5. TT’s POR also asserts that
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` Ex.2150 at 22:18-24:7,
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`TT’s invention was demanded by traders and became a commercial success. Paper
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`66 at 41-48. The June 9, 2016 transcript includes admissions by Bartleman that the
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`, showing both commercial success
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`and that it went against conventional wisdom even in 2003. 6/9/16 Bartleman Tr. at
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`689:21-690:16. The June 9, 2016 transcript includes other admissions by
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`Bartleman that show commercial success. Id. at 668:15-669:11, 674:7-675:12.
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`Further, TT argues in its POR that
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`testimony, paired with Exhibits 2144 and PDX 3043 (detailed below), strongly
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`. Paper 66 at 52. Mr. Bartleman’s
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`evidences
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`. 6/9/16 Bartleman Tr. at 604:7-13.
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`2. Exhibit 2144, May 2003 Matrix Requirements & PDX 3043, April
`2003 TT Webpage of TT’s Commercial Embodiment, MD_Trader
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`Exhibit 2144 is a May 2003 Matrix Requirements document that details the
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`technical specifications for TS’s Matrix. TS produced this document to TT on
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`December 23, 2015, but it was not authenticated until June 8, 2016. Additionally,
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`TT seeks to submit PDX 3043, a printout of TT’s website describing and showing
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`U.S. Patent 6,772,132
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`MD_Trader as of April 2003 that TT did not discover the relevance of until June 8,
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`2016. TT’s POR asserts that
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`. Paper 66 at 52.
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`Exhibit 2144 and PDX 3043 are relevant to this assertion because
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`.
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`Exhibit 2144 also touts the claimed features of the commercial embodiment,
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`namely,
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` (id. at TS01707057). Further, the document acknowledges
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`that Matrix (which embodies the claimed invention) is both
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`. This further supports TT’s
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`position that the invention was not obvious and recites an inventive concept, and
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`which went against conventional wisdom at the time.
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`3. Exhibit 2145, “Trading Options with TradeStation OptionStation
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`TS produced Exhibit 2145 on November 5, 2015, and TT authenticated it on
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`June 9, 2016. Exhibit 2145 is a TS Options Manual
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`TS0024612). TT’s POR states that the claimed invention is deeply rooted in
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`technology and that the claimed inventions solve technological problems. Paper 66
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`at 11. Exhibit 2145 supports that position,
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`. Exhibit 2145 further supports that TT’s
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`position that the claimed invention is not abstract, and the benefits from the Matrix
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`are directly attributable to the claimed features, as it highlights that Matrix
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`embodies the claimed combination (id. at TS0024667).
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`4. Exhibit 2143, February 15, 2011 “Barron’s Presentation—2011”
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`TS produced Exhibit 2143 on November 5, 2015 and TT authenticated it on
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`June 9, 2016. Exhibit 2143 is an interview TS gave to Barron’s
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` (id. at TS0028765). TT’s POR discusses that the claimed
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`invention was commercially successful. Paper 66 at 44-48. Exhibit 2143 supports
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`.
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`that contention because it acknowledges that
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`5. PDX 3046, December 20, 2008 Email re “Matrix Taking Over”
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`PDX 3046 is an email from TS employee Hans Stimming to John Bartleman
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`(and others) entitled “Matrix Taking Over” that TS produced on May 4, 2016, and
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`TT authenticated on June 9, 2016. PDX 3046 at 667:7-668:8. TT’s POR states that
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`TT’s claimed invention enjoyed commercial success, including by competitors
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`who adopted it. Paper 66 at 44-48. PDX 3046 supports TT’s argument because the
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`B. IB Testimony and Documents
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`1. Exhibit 2154, 30(b)(6) Deposition Tr. of IB (Milan Galik, President)
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`Exhibit 2154 is the 30(b)(6) deposition testimony of Milak Galik, President
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`and head of software development for IB. Exhibit 2154 authenticates Exhibit 2156
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`(331:10-25), and rebuts Petitioner’s expert, Mr. Román, who opined that electronic
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`trading screens are purely aesthetic. Ex. 1007, ¶71. Specifically, Mr. Galik,
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`. Ex. 2154 at 404:12-407:21.
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`2. Exhibit 2156, June 14, 2010 Email regarding Booktrader
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`Exhibit 2156 is an internal IB email sent by Mr. Galik that IB produced on
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`June 2, 2016. Exhibit 2156 shows that the claimed invention is not abstract, and
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`also that there is a nexus between the claimed inventions’ features and commercial
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`success. Exhibit 2156 discusses that
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`3. Exhibit 2158, June 14, 2010 Email regarding Booktrader
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`Exhibit 2158 is an email sent by Mr. Galik regarding
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`. Exhibit 2158
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`also supports TT’s argument that the claimed GUIs are technological in nature, and
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`not pure aesthetics as argued by Petitioners’ expert, Mr. Roman. Ex. 1007, ¶71.
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`This document is thus directly related to patent eligibility, and is contrary to the
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`position taken by Petitioners.
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`III. CONCLUSION
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`Accordingly, TT requests that the Board grant its motion. As Petitioners’ PO
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`objections have been resolved, TT may finally introduce this information into the
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`Proceeding. It is in the interests of justice that such evidence be made of record in
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`this case. Indeed, the evidence and briefing will show that Petitioners’ infringing
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`GUIs that embody the claimed elements were superior to conventional GUI tools
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`and enjoyed widespread commercial success. Further, the evidence will show that
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`Petitioners viewed their infringing GUI tools as important technology that
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`improves the functioning of the computer over prior art GUI’s, and not just an
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`arrangement of known elements driven by aesthetics.
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`Dated: August 16, 2016
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`Case CBM2015-00182
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`Respectfully submitted,
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`By: /Rachel L. Emsley/
`Rachel L. Emsley, Back-up Counsel
`Reg. No. 63,558
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`Counsel for Patent Owner
`Trading Technologies International, Inc.
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing PATENT
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`OWNER’S MOTION TO SUBMIT SUPPLEMENTAL INFORMATION
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`AND BRIEFING UNDER 37 C.F.R. § 42.223(b) was served on August 16,
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`2016, via email directed to counsel of record for the Petitioners at the following:
`
`Robert Sokohl
`rsokohl-PTAB@skgf.com
`
`Lori Gordon
`lgordon-ptab@skgf.com
`
`Richard Bemben
`rbemben-PTAB@skgf.com
`
`John C. Phillips
`CBM41919-0008CP1@fr.com
`
`PTAB@skgf.com
`
`/Bradley J. Moore/
`Bradley J. Moore
`Litigation Legal Assistant
`
`Finnegan, Henderson, Farabow, Garrett
`& Dunner, LLP
`
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`
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`Date: August 16, 2016
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