Avaya Inc. et al. v. Network-1
`Security Solutions, Inc.
`
`IPR2013-00071
`Avaya’s Oral Argument
`January 9, 2013
`
`
`Security Solutions, Inc.
`
`IPR2013-00071
`Avaya’s Oral Argument
`January 9, 2013
`
`
`
`Introduction
`
` Ground 1: Matsuno anticipates Claim 6
`• “low level current”
`• “on a data signaling pair”
`• “data network”
`
`
` Ground 1: Matsuno anticipates Claim 9
`• “voltage level drops”
`• “indicating removal”
`
`
` Ground 2: De Nicolo and Matsuno
`• De Nicolo does not teach away
`• Matsuno is analogous art and compatible with De Nicolo
`
`
`IPR2013-00071
`
`2
`
`
`
`Ground 1:
`Matsuno Anticipates Claim 6
`
`
`
`Matsuno Anticipates Claim 6
`
`FIG. 5
`
`IPR2013-00071
`
`Reply (Paper 56), p. 7, 11;
`Second Zimmerman
`Declaration (AV-1041) at
`¶39 (cited in Paper 56, p. 7)
`
`4
`
`
`
`Matsuno Anticipates Claim 6
`FIG. 5
`
`“access device”
`
`IPR2013-00071
`
`“data signaling
`pair”
`
`“data node”
`
`Paper 56, p. 7, 11 &
`AV-1041 at ¶39 (cited in
`Paper 56, p. 7)
`
`5
`
`
`
`Matsuno Anticipates Claim 6
`
`“. . . 31a and 31b are voltage detectors and
`32 is a contact breaker point.”
`
`Matsuno (AV-1004) at ¶ (0033).
`
`Petition (Paper 1), p. 25; Paper 56, p. 7, 11;
`AV-1041 at ¶39 (cited in Paper 56, p. 7)
`
`IPR2013-00071
`
`FIG. 5
`
`6
`
`6
`
`
`
`Matsuno Anticipates Claim 6
`
`“. . . the voltages at both terminals of the
`constant-current circuits 21a and 21b are
`detected by the voltage detection
`parts 31a and 31b . . .”
`
`Matsuno (AV-1004) at ¶ (0033).
`
`IPR2013-00071
`
`FIG. 5
`
`7
`
`
`
`Matsuno Anticipates Claim 6
`
`“. . . the contact breaker point 8 is OFF during
`local power supply of the network terminal
`device 2. Thus, a DC loop is not formed . . .
`and current does not flow to the
`digital subscriber line 12 . . .”
`
`Matsuno (AV-1004) at ¶ (0033).
`
`IPR2013-00071
`
`FIG. 5
`
`8
`
`
`
`Matsuno Anticipates Claim 6
`
`“Consequently, in this state, the contact
`breaker point 32 is switched to the low
`voltage V2 of -48 V, and low voltage power
`supply is supplied to the digital
`subscriber line 12.”
`
`Matsuno (AV-1004) at ¶ (0034).
`
`Reply (Paper 56), p. 7, 11;
`AV-1041 at ¶¶ 39-40 (cited in Paper 56, p. 7)
`
`IPR2013-00071
`
`FIG. 5
`
`9
`
`
`
`Matsuno Anticipates Claim 6
`
`“The contact breaker point 8 is thus turned
`ON as a result of shutdown of local power
`supply to the network terminal device 2,
`and a DC loop is formed from the
`standpoint of the power supply
`circuit 1.”
`
`Matsuno (AV-1004) at ¶ (0034).
`
`FIG. 5
`
`IPR2013-00071
`
`10
`
`
`
`Matsuno Anticipates Claim 6
`
`“Consequently, current flows to the digital
`subscriber line 12 via the constant-current
`circuit 21a, 21b, and a voltage is seen on
`both terminals of the constant
`-current circuits 21a, 21b.”
`
`Matsuno (AV-1004) at ¶ (0034).
`
`FIG. 5
`
`IPR2013-00071
`
`11
`
`
`
`Matsuno Anticipates Claim 6
`
`“When the voltage is at or above a set value,
`the voltage detection parts 31a, 31b detect
`loops, the contact breaker point 32 is
`switched to the high voltage V1
`of -120 V, and supply of high
`voltage to the digital subscriber
`line 12 is performed.”
`
`Matsuno (AV-1004) at ¶ (0035).
`
`IPR2013-00071
`
`FIG. 5
`
`12
`
`
`
`“Low Level Current”
`
`The Board’s Construction
`The “low level current” is sufficiently low that, by
`itself, it will not operate the access device.
`Decision (Paper 18, p. 9-10)
`
`Network-1’s Modified Construction
`
`
`Knox Declaration (N1-2015) at ¶ 63 (cited in Paper 42, p. 3).
`
`IPR2013-00071
`
`13
`
`
`
`Matsuno Provides A “Low Level Current”
`
`Network-1’s flawed assumptions include:
`
`1. A line resistance less than 20% of the actual IEEE
`standard ISDN design line resistance.
`
`2. Subscriber service area representing only about
`7.5 % of the ISDN mandated subscriber area.
`
`3. Device power requirement for the very lowest
`power consuming PoE device operating at only
`about 17% of its capacity.
`Paper 56, pp. 2 – 3.
`
`IPR2013-00071
`
`14
`
`
`
`Matsuno Provides A “Low Level Current”
`
`“(0004) When the commercial AC power source 111 is
`functioning normally, for example, an AC current of 100 V is
`rectified in the phantom power supply part 112
`and is converted to a
`prescribed voltage, for
`example, a DC voltage of
`40 V, for use as the local
`power supply that is
`supplied to the
`subscriber terminal 103.”
`
`(cited in Paper 56, p. 4 & Paper
`42 at 8; see also Paper 1 at 19.)
`
`S/T point
`
`IPR2013-00071
`
`U point
`
`FIG. 11
`
`15
`
`15
`
`
`
`Matsuno Provides A “Low Level Current”
`
`The Board’s concern with Network-1’s position
`remains unaddressed.
`
`Dell Decision (IPR2013-00385, Paper 16 at p. 16)
`
`IPR2013-00071
`
`16
`
`
`
`Matsuno Provides A “Low Level Current”
`
`“Power comes from the main power
`source, typically a 48 volt power
`supply. This power supply must
`supply power to the data node and
`provide for the generation of the low
`level current.”
`
`“In each of Defendant’s Accused
`PSEs, current limiting circuit restricts
`power from the 48 V main power
`source to a low level current.”
`
`Knox Infringement Report (AV-1031 at p. 46 & 64) (cited in Paper 56, p. 4).
`
`IPR2013-00071
`
`17
`
`
`
`Matsuno Provides A “Low Level Current”
`
`Matsuno tells us how much voltage is available from
`the high voltage power supply:
`
`Matsuno (AV-1004) at ¶ (0020) (cited in Paper 1; Paper 56 at 4; AV-1041 at 32).
`
`IPR2013-00071
`
`18
`
`
`
`Matsuno Provides A “Low Level Current”
`
`Dr. Zimmerman tells us how much voltage we can
`expect from the low voltage power supply:
`“Since that amount of voltage drop is a function of
`power supply efficiency (in the NT1) and the
`resistance seen on the line, a correspondingly high
`amount of potential would be similarly lost when
`only the low voltage power source (-48 volts) is
`applied. Thus, what Matsuno tells us is that only on
`the order of about 8 V of potential would be
`available to the NT1/DTE . . . .”
`Second Decl. of Zimmerman (AV-1041) at ¶ 32 (cited in Paper 56, p. 5).
`
`IPR2013-00071
`
`19
`
`
`
`Matsuno Provides A “Low Level Current”
`
`Matsuno explains both WHEN and WHY station
`power is switched to the high voltage power supply
`
`Matsuno (AV-1004) at ¶ (0004) (cited in Paper 56, p. 4 & Paper 42 at 8)
`
`
`IPR2013-00071
`
`20
`
`
`
`Matsuno Provides A “Low Level Current”
`
`Again, the Board’s concerns with Network-1’s
`position remains unaddressed.
`
`Dell Decision (IPR2013-00385, Paper 16 at pp. 15-16).
`
`IPR2013-00071
`
`21
`
`
`
`Matsuno Provides A “Low Level Current”
`
`Even Network-1 admits that there are access devices
`in Matsuno which would not be operated using the
`low voltage power supply.
`
`Patent Owner Response (Paper 42, p. 11).
`
`IPR2013-00071
`
`22
`
`
`
`Matsuno Provides A “Low Level Current”
`
`Network-1’s admission is dispositive on the issue that
`Matsuno discloses the claimed “low level current.
`
`Decision (Paper 18, p. 17).
`
`IPR2013-00071
`
`23
`
`
`
`“sensing . . . on a data signaling pair”
`
`The Board’s construction for “on the
`data signaling pair” is correct.
`
`Dell Decision (IPR2013-00385, Paper 16 at p. 12).
`
`IPR2013-00071
`
`24
`
`
`
`“sensing . . . on a data signaling pair”
`
`“In this embodiment, the
`voltages at both terminals of
`the constant-current circuits
`21a and 21b are detected by
`the voltage detection parts
`31a and 31b . . . .”
`Matsuno (AV-1004) at ¶ (0033).
`
`Petition (Paper 1), p. 25; Reply (Paper 56), p. 7, 11;
`AV-1041 at ¶39 (cited in Paper 56, p. 7)
`
`IPR2013-00071
`
`25
`
`
`
`“sensing . . . on a data signaling pair”
`
`Dr. Knox has told us there is nothing special
`about sensing a common mode voltage.
`
`Knox Depo. Transcript (AV-1028 at p. 92, l. 11-16) (cited in Paper 56, p. 7).
`
`IPR2013-00071
`
`26
`
`
`
`Matsuno Discloses A “Data Network”
`
`The ’930 Patent embraces technology
`convergence, which is what ISDN is all about.
`
`’930 patent (AV-1001 at col. 1, lines 33-40) (cited in Paper 56, p. 8).
`
`IPR2013-00071
`
`27
`
`
`
`ISDN Is A “Data Network”
`
`Dr. Knox’s own authoritative reference shows
`us that an ISDN is a “data network.”
`
`Burd, Nick, “ISDN Subscriber Loop,” 1997 (AV-1027)
`(discussed in Paper 56, p. 9 (citing to AV-1041, ¶¶ 9, 10)).
`
`IPR2013-00071
`
`28
`
`
`
`ISDN Is A “Data Network”
`
`Dr. Knox’s own authoritative reference shows
`us that an ISDN is a “data network.”
`
`Burd, Nick, “ISDN Subscriber Loop,” 1997 (AV-1027)
`(discussed in Paper 56, p. 9 (citing to AV-1041, ¶¶ 9, 10)).
`
`IPR2013-00071
`
`29
`
`
`
`ISDN Is A “Data Network”
`
`Dr. Knox has already taken the position that an
`ISDN network is a “data network”
`
`Knox Report (2010) (AV-1030 at p. 141) (cited in Paper 56, p. 8).
`
`IPR2013-00071
`
`30
`
`
`
`ISDN Is A “Data Network”
`
`Dr. Zimmerman explained to us that the network
`in Jenneve is an ISDN network.
`
`Second Declaration of Zimmerman (AV-1041 at ¶ 11) (cited in Paper 56, p. 8).
`
`IPR2013-00071
`
`31
`
`
`
`Ground 1:
`Matsuno Anticipates Claim 9
`
`
`
`Matsuno Anticipates Claim 9
`
`Network-1 incorrectly assumes that Claim 9 recites a
`step of removing the access device and that such
`step must be physically performed, such as by
`physically unplugging.
`(Paper 56 at pp. 9-10).
`
`Claim 9 only recites that a removal of the access
`device, if it were to occur, would result in a voltage
`decrease.
`(Paper 56 at pp. 9-10).
`
`IPR2013-00071
`
`33
`
`
`
`Matsuno Anticipates Claim 9
`
`Matsuno explains that the
`sensed voltage decreases
`when the breakers 8 open.
`
`Reply (Paper 56), p. 7, 11;
`(AV-1041) at ¶39 (cited in
`Paper 56, p. 7)
`
`IPR2013-00071
`
`FIG. 5
`
`34
`
`
`
`Matsuno Anticipates Claim 9
`
`“The contact breaker point 8 turns OFF as a
`result of restarting of the local power supply,
`and, after the current that flows to the digital
`subscriber line 12 goes to zero, the
`voltage at the two terminals of
`the constant-current circuits
`21a, 21b becomes zero or a
`value close to zero.”
`
`Matsuno (AV-1004) at ¶ (0036).
`
`IPR2013-00071
`
`FIG. 5
`
`35
`
`35
`
`
`
`Matsuno Anticipates Claim 9
`
`“Consequently, the voltage detection parts
`31a, 31b control the contact breaker point
`32 so that it is switched from the high
`voltage V1 of -120 V to the
`low voltage V2 of -48 V.”
`
`Matsuno (AV-1004) at ¶ (0036).
`
`FIG. 5
`
`IPR2013-00071
`
`36
`
`
`
`Matsuno Anticipates Claim 9
`
`Dr. Knox confirmed that voltage would decrease
`when the NT1 is removed (in FIG. 5).
`
`Knox Deposition Transcript (AV-1028 at p. 103, lines 8-12)
`(cited in Paper 56, p. 11).
`
`IPR2013-00071
`
`37
`
`
`
`DELETED
`
`DELETEDDELETED
`
`38
`
`3838
`
`
`
`Ground 2:
`De Nicolo and Matsuno
`
`
`
`De Nicolo Does Not Teach Away
`
`De Nicolo does not discourage determining if the
`access device would make use of the remote power.
`
`De Nicolo is at worst silent on the issue.
`
`De Nicolo (AV-1007 at col. 4, lines 1-5)
`
`IPR2013-00071
`
`40
`
`
`
`Matsuno Is Analogous Art
`
`Network-1 argues that Matsuno is non-analogous
`prior art because:
`
`1. It is an ISDN reference (not in the field of art), and
`
`2. It is not directed to the problem addressed by the
`inventors of the ’930 patent.
`
`See Patent Owner Response (Paper 42 at p. 52).
`
`IPR2013-00071
`
`41
`
`
`
`Matsuno Is Analogous Art
`
`Network-1 has taken a directly contradictory position
`in a previous litigation with respect to Jenneve.
`1
`
`2
`
`Knox Report (2010) (AV-1030 at p. 141) (cited in Paper 56, p. 8).
`
`IPR2013-00071
`
`42
`
`
`
`De Nicolo And Matsuno Are Compatible
`
`Dr. Knox confirmed the reason why he believes
`De Nicolo and Matsuno are incompatible.
`
`Knox Deposition (AV-1047 at p. 252, lines 13-20) (cited in Paper 80, p. 11).
`
`IPR2013-00071
`
`43
`
`
`
`De Nicolo And Matsuno Are Compatible
`
`As Dr. Knox confirmed, the combination of De Nicolo
`and Matsuno does not involve ISDN and Ethernet
`transmissions occurring over the same lines.
`
`Knox Deposition (AV-1047 at p. 255, lines 5-9) (cited in Paper 80, p. 11).
`
`IPR2013-00071
`
`44
`
`
`
`REBUTTAL:
`Opposition to
`Motion to Amend
`
`
`
`Opposition to Motion to Amend
`
`Network-1’s motion to amend should be
`denied because it:
`• impermissibly broaden the scope of claim 6,
`• fails to properly consider other known prior art,
`• fails to properly consider the level of skill in the
`art with respect to the features being added,
`• the “Ethernet amendments” fail to distinguish
`Ground 2 or any other Ethernet prior art, and
`• the proposed “determining” step fails to
`distinguish at least Matsuno, Chang or Woodmas.
`
`IPR2013-00071
`
`46
`
`
`
`Network-1 Proposed A Broadening
`Amendment
`
`“sensing a voltage level on the data signaling pair in
`response to the low level current,
`
`determining whether the access device is capable of
`accepting remote power based on the sensed voltage,
`and
`
`controlling power supplied by said secondary power
`source to said access device in response to a
`preselected condition of said voltage level.”
`
`IPR2013-00071
`
`47
`
`
`
`DELETED
`
`DELETEDDELETED
`
`48
`
`4848
`
`
`
`“Voltage” Is Broader Than “Voltage Level”
`
`Dr. Zimmerman and Dr. Knox agree that a “voltage level” is
`particular to a voltage amplitude.
`
`Knox Deposition (AV-1047 at p. 257, lines 9-13) (cited in Motion for
`Observations (Paper 80), p. 2).
`
`IPR2013-00071
`
`49
`
`
`
`“Voltage” Is Broader Than “Voltage Level”
`
`Dr. Knox’s testimony shows that “voltage” and
`“voltage level” do not mean the same thing.
`
`Paper 80 at pp. 1-2.
`
`IPR2013-00071
`
`50
`
`
`
`Network-1 Has Failed To Properly Consider
`The Level Of Skill In The Art
`
`Network-1’s Reply to Avaya’s Opposition shows how
`deficient the Motion to Amend really is.
`
`Paper 65 at p. 5.
`
`PHOSITA
`for the field
`of invention
`
`Discussion of
`only the De Nicolo
`& Chang references
`
`IPR2013-00071
`
`51
`
`
`
`“Ethernet Amendments”
`Dr. Knox confirmed that the “Ethernet amendments”
`do not distinguish the prior art.
`
`Knox Deposition (AV-1028 at p. 143, lines 10-20) (cited in Paper 57, p. 3).
`
`IPR2013-00071
`
`52
`
`
`
`Claim Construction
`
`Network-1 did not propose any claim constructions
`in its Motion to Amend.
`
`
`
`Motion to Amend (Paper 43, p. 4).
`
`IPR2013-00071
`
`53
`
`
`
`Construction of “Capable of Accepting”
`
`Avaya’s Construction:
`“capable of accepting” means the access device
`is able to accept remote power at that time.
`Opposition to Motion to Amend (Paper 57, p. 4).
`
`Network-1’s Construction (Offered in Reply Only):
`“‘Determining whether the access device is capable
`of accepting remote power’ means determining
`whether the device is designed to accept remote
`power”
`Reply to Opposition (Paper 65, p. 2).
`
`IPR2013-00071
`
`54
`
`
`
`Construction of “Capable of Accepting”
`
`Dr. Knox agrees that the proposed “determining”
`step does not know how a device was originally
`manufactured.
`
`Knox Deposition (AV-1047) at p. 307, lines 21-24 (cited in Paper 80, p. 3).
`
`IPR2013-00071
`
`55
`
`
`
`Construction of “Capable of Accepting”
`
`Network-1’s interpretation of its own construction
`(“designed to accept”) of the term “capable of
`accepting” is circular.
`
`Knox Deposition (AV-1047, p. 295, lines 18 – 25) (cited in Paper 80, p. 3).
`
`IPR2013-00071
`
`56
`
`
`
`Construction of “Capable of Accepting”
`
`Dr. Knox confirmed that:
`
`the ’930 patent determines a voltage condition and from
`that infers something about the device being capable of
`accepting remote power, and
`
`the voltage condition assigned to remotely powerable
`devices could in fact be generated by a different type of
`device, i.e., one that is not actually remotely powerable.
`
`See Knox Deposition (AV-1047, p. 342, lines 17 – 25 & p. 344:23 – 345:4)
`(cited in Paper 80, p. 4).
`
` •
`
`•
`
`IPR2013-00071
`
`57
`
`
`
`Matsuno Works In The Same Way
`
`Dr. Knox confirmed that the NT1/DTE is not capable of accepting
`remote power when the breakers are open, and is capable of
`accepting remote power when the breakers are closed.
`
`Knox Deposition (AV-1047, p. 378:18 to 379:1 (cited in Paper 80, pp. 4-5).
`
`IPR2013-00071
`
`58
`
`
`
`Matsuno Works In The Same Way
`
`Knox Deposition (AV-1047, p. 370, lines 3-6 (cited in Paper 80, p. 5).
`
`Knox Deposition (AV-1047, p. 370:22 to 371:3 (cited in Paper 80, p. 5).
`
`IPR2013-00071
`
`59
`
`
`
`Matsuno Works In The Same Way
`
`
`Therefore, Dr. Knox confirmed that Matsuno
`uses a voltage condition (voltage amplitude
`range) to determine if NT1/DTE is in a state
`where it is “capable of accepting remote
`power” (when the breakers are closed), or is in
`a state where it is not “capable of accepting
`remote power” (when the breakers are open).
`Paper 80, pp. 5.
`
`IPR2013-00071
`
`60
`
`
`
`Matsuno Works In The Same Way
`
`Dr. Knox further testified that, in Matsuno:
`
`
`
`
`
`Knox Deposition (AV-1047, p. 379, lines 7-8 (cited in Paper 80, pp. 4-5).
`Thus, even under Network-1’s strained construction
`of “capable of accepting,” the NT1/DTE is:
`• not “designed” to accept remote power when the
`breakers are open, and
`• “designed” to accept remote power when the
`breakers are closed.
`
`Paper 80, pp. 4-5.
`
`IPR2013-00071
`
`61
`
`
`
`Network-1 Failed To Consider Other Known
`And Highly Relevant Prior Art
`
`The only other prior art reference addressed in
`Network-1’s Motion to Amend is Chang.
`
`
`
`Network-1 had undeniable knowledge of at least:
`– references in granted ex parte reexamination, and
`– references in the other related IPR petitions that have
`been filed against the ’930 patent.
`
`Paper 57, p. 8.
`
`IPR2013-00071
`
`62
`
`
`
`Network-1 Failed To Distinguish The
`“Determining” Step From Chang
`
`
`Network-1 concedes that Chang “. . . teaches
`the concept of determining whether an access
`device is capable of accepting power.
`Paper 57, p. 8.; see also Mot. to Amend at 15.
`
`Network-1’s attempts to distinguish Chang
`based only on a “teaching away” argument.
`Paper 57, 8-9.
`
`IPR2013-00071
`
`63
`
`
`
`Chang Does Not Teach Away From The ’930
`Patent
`
`
`Network-1’s relied upon “teaching away” argument
`relates to the “sensing” step, not the “determining”
`step.
`Paper 57 at 8-9.
`
`The later-in-time De Nicolo teachings would have
`dispelled any concern Chang may have had about
`supplying power over the same data signaling pair
`used for data.
`See id. at 9.
`
`IPR2013-00071
`
`64
`
`
`
`Network-1 Failed To Distinguish The
`“Determining” Step From Woodmas
`
`Woodmas (AV-1040) at col. 7:39-52 (cited in Paper 57, p. 10).
`
`IPR2013-00071
`
`65
`
`
`
`Network-1 Failed To Distinguish The
`“Determining” Step From Woodmas
`
`Dr. Knox confirmed that Woodmas discloses a
`“low level current.”
`
`Knox Deposition (AV-1047, p. 402:19 to 403:1 (cited in Paper 80, p. 6-7).
`
`IPR2013-00071
`
`66
`
`
`
`Network-1 Failed To Distinguish The
`“Determining” Step From Woodmas
`Dr. Knox confirmed that Woodmas applies low level power,
`senses a resulting voltage, and then produces the “power status
`signal” in response to the sensed voltage.
`
`Knox Deposition (AV-1047, p. 427, lines 16-25 (cited in Paper 80, p. 7).
`
`IPR2013-00071
`
`67
`
`
`
`Network-1 Failed To Distinguish The
`“Determining” Step From Woodmas
`
`Dr. Knox further confirmed that the power status signal
`(which is representative of the sensed voltage) is used
`to determine the presence and functionality of the remote
`device before applying full power.
`
`Knox Deposition (AV-1047, p. 428, lines 1-7 (cited in Paper 80, p. 7).
`
`IPR2013-00071
`
`68
`
`
`
`Network-1 Failed To Distinguish The
`“Determining” Step From Woodmas
`
`
`Dr. Knox testified that the “power status signal”
`in Woodmas is an analog signal, just as a waveform
`of voltage amplitudes would be an analog signal.
`
`
`
`Knox Deposition (AV-1047, p. 430, lines 3-10 (cited in Paper 80, p. 8).
`
`IPR2013-00071
`
`69
`
`
`
`Network-1 Failed To Distinguish The
`“Determining” Step From Woodmas
`
`In sum, Network-1 has failed to carry its burden of
`distinguishing the proposed “determining” step
`from how Woodmas uses its “power status signal,”
`which is:
`• an analog signal representative of the sensed
`“low level voltage”
`• generated in response to the “low level power”
`• used to determine the functionality of the power
`reception unit 76 before applying full power.
`Paper 80, p. 8.
`
`70
`
`
`
`IPR2013-00071
`
`
`
`
`SUPPLEMENTAL SLIDES
`
`SUPPLEMENTAL SLIDESSUPPLEMENTAL SLIDES
`
`
`
`
`
`Construction of “Capable of Accepting”
`
`Dr. Knox confirmed that what the ’930 patent actually
`determines is a voltage condition from which it then infers
`whether or not the device is capable of accepting remote power.
`
`Knox Deposition (AV-1047, p. 342, lines 17 – 25 (cited in Paper 80, p. 4).
`
`IPR2013-00071
`
`72
`
`
`
`Construction of “Capable of Accepting”
`
`Dr. Knox confirmed that the voltage condition assigned to devices
`that are remotely powerable could be generated by a different
`type of device, i.e., one that is not actually remotely powerable.
`
`Knox Deposition (AV-1047, p. 344:23 – 345:4) (cited in Paper 80, p. 4).
`
`IPR2013-00071
`
`73
`
`
`
`DELETED
`
`DELETEDDELETED
`
`74
`
`7474
`
`
`
`Zimmerman’s Testimony
`
`Zimmerman Deposition (N1-2016), p. 144:2-5 (see N1-2016 at 55:11-24, as
`cited in Paper 56, p. 6).
`
`IPR2013-00071
`
`75
`
`
`
`DELETED
`
`DELETEDDELETED
`
`76
`
`7676
`
`
`
`Zimmerman’s Testimony
`
`Zimmerman Deposition (N1-2016), p. 55:11-24 (cited in Paper 56, p. 6).
`
`IPR2013-00071
`
`77
`
`
`
`Zimmerman’s Testimony
`
`Zimmerman Deposition (N1-2025), p. 233, line 18 to p. 234, lines 6.
`
`IPR2013-00071
`
`78
`
`
`
`Zimmerman’s Testimony
`
`Zimmerman Deposition (N1-2025), p. 234, lines 5 to 10.
`
`IPR2013-00071
`
`79
`
`
`
`Second Decl. of Zimmerman (AV-1041) at ¶¶ 43-48 (cited in Paper 56, p. 6).
`
`IPR2013-00071
`
`80
`
`
`
`Second Decl. of Zimmerman (AV-1041) at ¶¶ 43-48 (cited in Paper 56, p. 6).
`
`IPR2013-00071
`
`81
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
