Filed on behalf of Proxyconn, Inc.
`
`By:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Matthew L. Cutler (mcutler@hdp.com)
`Bryan K. Wheelock (bwheelock@hdp.com)
`Douglas A. Robinson (drobinson@hdp.com)
`Greg W. Meyer (gmeyer@hdp.com)
`Harness, Dickey & Pierce, PLC
`7700 Bonhomme Ave., Suite 400
`Clayton, MO 63105
`Tel: (314) 726-7500
`Fax: (314) 726-7501
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________
`
`MICROSOFT CORPORATION
`
`Petitioner
`
`v.
`
`PROXYCONN, INC.
`
`Patent Owner
`
`_____________
`
`Case IPR2012-00026
`Case IPR2013-00109
`Patent 6,757,717 B 1
`_____________
`
`PROXYCONN’S REMAND BRIEF
`
`
`
`
`
`By:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Matthew L. Cutler (mcutler@hdp.com)
`Bryan K. Wheelock (bwheelock@hdp.com)
`Douglas A. Robinson (drobinson@hdp.com)
`Greg W. Meyer (gmeyer@hdp.com)
`Harness, Dickey & Pierce, PLC
`7700 Bonhomme Ave., Suite 400
`Clayton, MO 63105
`Tel: (314) 726-7500
`Fax: (314) 726-7501
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________
`
`MICROSOFT CORPORATION
`
`Petitioner
`
`v.
`
`PROXYCONN, INC.
`
`Patent Owner
`
`_____________
`
`Case IPR2012-00026
`Case IPR2013-00109
`Patent 6,757,717 B 1
`_____________
`
`PROXYCONN’S REMAND BRIEF
`
`
`
`
`
`
`
`INTRODUCTION
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`Logically, a Petitioner should assert claim constructions just broad enough to
`
`result in the invalidation of the challenged claims over the available prior art. In
`
`these proceedings Microsoft’s “just broad enough” claim constructions were found
`
`unreasonable and rejected in two respects: the construction of “sender/computer”
`
`and “receiver/computer” and the construction of “at least two other
`
`computers.” These erroneously broad constructions underpinned the determination
`
`of unpatentability of claims 1, 3, 6, 7, 9, 10 and 22–23, and without these
`
`unreasonably broad constructions what remains of Microsoft’s grounds is
`
`insufficient to show that these claims are unpatentable.
`
`At no point during these proceedings did Microsoft ever explain (let alone
`
`assert) that these claims were unpatentable under any other claim construction. It
`
`cannot do so for the first time on remand, long after these proceedings were to
`
`have terminated, when Proxyconn does not even have a chance to defend the
`
`claims. By definition any claim construction or argument that Microsoft presents
`
`for the unpatentability of claims 1, 3, 6, 7, 9, 10 and 22–23 is new, and should be
`
`rejected as untimely and unfair.
`
`Inter Partes Review is not examination – unlike an ex parte appeal there is
`
`no provision for the Board to modify the grounds of unpatentability submitted by
`
`the Petitioner. Inter Partes Review is an adjudication of those grounds properly
`
`
`
`1
`
`
`
`
`before the Board, i.e., the grounds as presented by the Petitioner that the Board
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`instituted. Microsoft chose to present grounds that required expansive claim
`
`constructions that the Federal Circuit found unreasonable. Because Microsoft
`
`relied exclusively on those constructions, without arguing any other
`
`constructions, there is no other option but to conclude that Microsoft failed to
`
`prove these grounds. There is no provision for changing the instituted grounds
`
`whether that change is the result of new prior art, new evidence, or new claim
`
`constructions. The Inter Partes Review proceeding is already skewed in favor of
`
`Petitioner, but to allow a patent to be invalidated based upon claim constructions or
`
`arguments that the Patent Owner was never permitted to address is not only unfair,
`
`but a denial of due process.
`
`Microsoft has had a full and fair chance to present its chosen claim
`
`construction and arguments for unpatentability, and it has lost. The Board is
`
`respectfully requested to merely modify its Final Written Decision to remove the
`
`findings of unpatentability of claims 1, 3, 6, 7, 9, 10, and 22–23, in view of the
`
`Federal Circuit’s vacatur. Nothing more is required, warranted or permitted.
`
`ARGUMENT
`
`
`
`Microsoft’s arguments in its two Petitions, and the Board’s Final Written
`
`Decision (IPR2012-00026, Paper 73 and IPR2013-00109, Paper 16, (“FWD”))
`
`depend upon the claim constructions now rejected by the Federal Circuit. In
`
`
`
`2
`
`
`
`
`modifying its Final Written Decision1, the Board should find that Microsoft failed
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`to show, by a preponderance of evidence, that claims 1, 3, 6, 7, 9, 10, and 22–23
`
`are unpatentable on the instituted grounds.
`
`Claims 6, 7, and 9
`
`
`
`Unpatentability over DRP
`
`
`
`The Board’s decision that claims 6, 7 and 9, were unpatentable over DRP
`
`was based upon its rejection of Proxyconn’s argument that “two other computers”
`
`excluded the caching computer. FWD at 47. The Federal Circuit held that this was
`
`error:
`
`The Board erred in concluding that the “two other computers” could include
`
`the caching computer.
`
`Microsoft Corp. v. Proxyconn, Inc, 789 F.3d 1292, 1299 (Fed. Cir. 2015). The
`
`proper construction is at odds with Microsoft’s reading of DRP. The protocol of
`
`DRP provides an efficient transfer of data from the server to the client. As shown
`
`
`1
`The Board’s finding of unpatentability of claims 1, 3, 6, 7, 9, 10, and 22–23
`
`has been vacated. Because that time period permitted for the Board to make a final
`
`determination has expired (i.e., at most 18 months from institution), the Board is
`
`without authority to take further action. 35 U.S.C. § 316 (a)(11); 37 C.F.R. §
`
`42.100(c).
`
`
`
`3
`
`
`
`
`below, the proxy cache (or caching computer) is intermediate between the server
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`and client. With this construction of DRP, only the proxy cache is connected
`
`between two “other” computers, as construed by the Federal Circuit – yet the
`
`proxy cache does not include a “means for calculating” as required by claims 6, 7
`
`and 9.
`
`The only disclosed parts of DRP
`
`
`
`Because Microsoft’s construction was in error and forms the only basis for
`
`its argument of anticipation of claims 6, 7 and 9 based on DRP, and further at no
`
`point did Microsoft ever attempt to show that DRP anticipated claims 6, 7 and 9 if
`
`the “two other computers” excluded the caching computer, the only possible
`
`conclusion is that Microsoft has failed to show that claims 6, 7 and 9 are
`
`unpatentable as anticipated by DRP.
`
`
`
`
`
`
`
`Unpatentability over Mattis and DRP
`
`Microsoft indicated in the August 27, 2015, conference call that on remand
`
`it wanted to raise the unpatentability of claims 6, 7 and 9 in view of Mattis and
`
`DRP, which the Board’s Final Written Decision found to be moot. FWD at 53.
`
`
`
`4
`
`
`
`
`Microsoft did not raise the combination of Mattis and DRP on appeal to the
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`Federal Circuit, and thus waived any appeal of the Board’s decision. Issues in the
`
`Board’s Final Written Decision, that were not appealed, are concluded. There is
`
`nothing more for this Board to do.
`
`Moreover, even if the Board were to reconsider Mattis and DRP, Microsoft
`
`failed to establish the obviousness of claims 6, 7 and 9 in view of Mattis and DRP.
`
`The Board instituted on the grounds of Mattis and DRP because it agreed that
`
`“when combined the references meet all requirements of these claims.” Institution
`
`Decision in IPR2013-00109, Paper 14 at 18. However this was under the
`
`erroneous belief that DRP anticipated the claims. Now that the Federal Circuit has
`
`corrected the claim construction of the ‘717 patent and DRP no longer anticipates
`
`the correctly construed claims, the combination of Mattis and DRP likewise does
`
`not make the claims obvious. It is beyond dispute that DRP lacks the required two
`
`other computers when the caching computer is not considered. Microsoft never
`
`showed how Mattis makes up for this deficiency of DRP because Microsoft never
`
`appreciated this deficiency of DRP.
`
`Similarly, the Board held that Mattis lacked “means for comparison between
`
`a digital digest on data in its network cache memory and a digital digest received
`
`from said packet switched network through said gateway.” Institution Decision in
`
`IPR2013-00109, Paper 14 at 17. Microsoft cannot contest this finding because it
`
`
`
`5
`
`
`
`
`failed to appeal it, and Microsoft never showed how DRP makes up for this
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`deficiency of Mattis because Microsoft never appreciated this deficiency of Mattis.
`
`
`
`For at least these reasons, even if Microsoft were entitled to reconsideration
`
`of the unpatentability of claims 6, 7 and 9 in view of Mattis and DRP, Microsoft
`
`has not shown how these claims are unpatentable from Mattis and DRP, and it
`
`cannot do so now.
`
`
`
`
`
`
`
`Claims 1 and 3
`
`
`
`Unpatentability over Santos
`
`The Board’s decision that claims 1 and 3 are unpatentable over Santos was
`
`based upon the Board’s rejection of Proxyconn’s argument that describes a
`
`Receiver/Computer as that term is used in these claims:
`
`Microsoft counters that Proxyconn’s argument rests upon an incorrect
`
`interpretation of “receiver/computer.” We agree. We have interpreted
`
`“receiver/computer” to refer to a “computer that receives data.” We also
`
`concluded that each of these respective computers can encompass multiple
`
`devices including intermediaries.
`
`FWD at 40, emphasis added. The Federal Circuit held that this was error:
`
`The Board erred in concluding that the terms “sender/computer” and
`
`“receiver/computer” were broad enough to include the intermediary gateway
`
`and caching computers . . .
`
`
`
`6
`
`
`
`
`Microsoft, 789 F.3d at 1300.
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`In its anticipation arguments, Microsoft relied on the compressor and
`
`decompressor of Santos for the recited “sender” and “receiver.” Santos, however,
`
`makes clear that the compressor and decompressor are intermediate computers,
`
`and not senders or receivers (when properly construed). See EX1004 FIG. 3
`
`below. Specifically, Santos expressly states the compressor, for example, is a
`
`“router” (EX1004 at § 3.1), which the ‘717 patent defines as an intermediary (“…
`
`term ‘gateway’ as used herein also includes network proxies and routers….”)
`
`EX1002 at 2:14–15 (emphasis added). The “compressors” and “decompressors”
`
`are routers separate in from any servers or clients and function independently.
`
`They act as a “go-between” from the “many” servers and clients. EX1004 at
`
`§§2.1, 3.1.2 and FIG. 3. The functionality of the compressors and decompressors,
`
`as relied on by Microsoft, thus are not present in any “sender” or “receiver” as is
`
`recited in claims 1 and 3 of the ‘717 patent.
`
`FIG. 3, annotated with Server(s) and Client(s)
`
`
`
`
`
`7
`
`
`
`
`
`Because Microsoft’s construction was in error and forms the only basis for
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`its argument of anticipation of claims 1 and 3 by Santos, and further at no point did
`
`Microsoft ever attempt to show that Santos anticipated claims 1 and 3 if receiver
`
`computer did not include intermediaries (i.e., the compressor or the decompressor),
`
`the only possible conclusion is that Microsoft has failed to show that claims 1 and
`
`3 are unpatentable as anticipated by Santos.
`
`
`
`
`
`Unpatentability over Yohe and Perlman
`
`The Board’s decision that claims 1 and 3 were obvious from Yohe and
`
`Perlman was likewise based upon a rejected claim construction. The Board said
`
`that “[t]he only limitation recited in claims 1 and 3 not described by Yohe is the
`
`‘means for comparison of digital digests on data’ located in the
`
`receiver/computer.” FWD at 51. However this statement was based upon the
`
`Board’s agreement with Microsoft that “the combination of Yohe’s cache
`
`verifying computer 14 and file server 18 constitutes the claimed sender/computer.”
`
`FWD at 36. The Federal Circuit rejected the construction that the sender/computer
`
`includes the cache verifying computer:
`
`The Board erred in concluding that the terms “sender/computer” and
`
`“receiver/computer” were broad enough to include the intermediary gateway
`
`and caching computers . . .
`
`Microsoft, 789 F.3d at 1300.
`
`
`
`8
`
`
`
`
`
`
`Moreover, in support of its obviousness argument, Microsoft presented
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`testimony from Dr. Long based on his understanding of “sender” and “receiver”
`
`which was found to be erroneous by the Federal Circuit. In particular, Dr. Long
`
`refers to “Yohe’s sender” or “Yohe’s receiver” in categorizing the prior art. Ex.
`
`1007, Dec. of Long at 15:11–16:13. And, in deposition, in response to the question
`
`“In the Perlman reference, what is the sender computer?” Dr. Long states “It’s
`
`going to be the routers [an intermediate computer].” EX1026 at 142:22–25
`
`(emphasis added). Microsoft’s challenge to claims 1 and 3 was premised on Dr.
`
`Long’s testimony, which, in turn, was founded entirely in Microsoft’s erroneous
`
`construction. Thus, by finding error in Microsoft’s construction, the Federal
`
`Circuit destroys the probative value of Dr. Long’s testimony.
`
`Because Microsoft’s construction was in error and forms the only basis for
`
`its arguments as to obviousness (i.e., Dr. Long’s declaration), and at no point did
`
`Microsoft ever attempt to show that Yohe and Perlman met the claim limitations if
`
`the caching computer was not considered part of the sender/computer, the only
`
`possible conclusion is that Microsoft has failed to show that claims 1 and 3 are
`
`unpatentable as obvious from Yohe and Perlman.
`
`9
`
`
`
`
`
`
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`
`
`
`
`
`Claim 10
`
`
`
`Unpatentability over Yohe
`
`The Board’s decision that claim 10 was anticipated by Yohe depended upon
`
`the Board’s agreement with Microsoft that “the combination of Yohe’s cache
`
`verifying computer 14 and file server 18 constitutes the claimed sender/computer.”
`
`FWD at 36. The Federal Circuit rejected the construction that the sender/computer
`
`includes the cache verifying computer:
`
`The Board erred in concluding that the terms “sender/computer” and
`
`“receiver/computer” were broad enough to include the intermediary gateway
`
`and caching computers . . .
`
`Microsoft, 789 F.3d at 1300.
`
`Because Microsoft’s construction was in error and forms the only basis for
`
`its argument of anticipation of claim 10 by Yohe, and at no point did Microsoft
`
`ever attempt to show that Yohe met the claim limitations of claim 10 if the caching
`
`computer was not considered part of the sender/computer, the only possible
`
`conclusion is that Microsoft has failed to show that claim 10 is unpatentable as
`
`anticipated by Yohe.
`
`Unpatentability over Santos
`
`
`
`The Board’s decision that claim 10 is unpatentable over Santos was based
`
`upon the Board’s rejection of Proxyconn’s argument that Santos fails to describe a
`
`
`
`10
`
`
`
`
`Receiver/Computer as that term is used in this claim. FWD at 43, see also FWD
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`40–42. The Federal Circuit held that this was error:
`
`The Board erred in concluding that the terms “sender/computer” and
`
`“receiver/computer” were broad enough to include the intermediary gateway
`
`and caching computers . . .
`
`Microsoft, 789 F.3d at 1300. As explained above, with reference to claims 1 and 3
`
`(which, like claim 10, require a “sender/computer” and a “receiver/computer”),
`
`Santos fails to disclose the sender and receiver recited in claim 10, when those
`
`terms are properly constructed.
`
`Because Microsoft’s construction was an error and forms the only basis for
`
`its argument of anticipation by Santos, and further at no point did Microsoft ever
`
`attempt to show that Santos anticipated claim 10 if “receiver/computer” did not
`
`include intermediaries (i.e., the compressor or the decompressor), the only possible
`
`conclusion is that Microsoft has failed to show that claim 10 is unpatentable as
`
`anticipated by Santos.
`
`Unpatentability over Yohe and Perlman
`
`The Board’s decision that claim 10 was obvious from Yohe and Perlman
`
`was based upon a rejected claim construction, that resulted in a finding that claim
`
`10 was anticipated by Yohe. This was based upon the Board’s agreement with
`
`Microsoft that “the combination of Yohe’s cache verifying computer 14 and file
`
`
`
`11
`
`
`
`
`server 18 constitutes the claimed sender/computer.” FWD at 36. The Federal
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`Circuit rejected the construction that the “sender/computer” includes the cache
`
`verifying computer:
`
`The Board erred in concluding that the terms “sender/computer” and
`
`“receiver/computer” were broad enough to include the intermediary gateway
`
`and caching computers . . .
`
`Microsoft, 789 F.3d at 1300.
`
`Moreover, as explained above with reference to claims 1 and 3, Microsoft’s
`
`challenge to claim 10 was premised on Dr. Long’s testimony, which, in turn, was
`
`founded entirely in Microsoft’s erroneous construction. Thus, by finding error in
`
`Microsoft’s construction, the Federal Circuit destroys the probative value of Dr.
`
`Long’s testimony.
`
`Because Microsoft’s construction was in error and forms the only basis for
`
`its arguments as to obviousness (i.e., Dr. Long’s declaration), and at no point did
`
`Microsoft ever attempt to show that Yohe and Perlman met the claim limitations if
`
`the caching computer was not considered part of the “sender/computer,” and
`
`because the combination is based on expert testimony premised on the erroneous
`
`construction (as explained above), the only possible conclusion is that Microsoft
`
`has failed to show that claim 10 is unpatentable as obvious from Yohe and
`
`Perlman.
`
`
`
`12
`
`
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`
`
`
`
`
`
`
`Claims 22 and 23
`
`
`
`Unpatentability over Santos
`
`The Board’s decision that claims 22 and 23 (which depends from claim 22)
`
`are unpatentable over Santos was based upon the same construction applied to
`
`claims 1 and 3 and discussed above:
`
`For the same reasons described above in connection with claims 1 and 3, we
`
`find that Santos describes the claimed receiver/computer.
`
`FWD at 43. However, as Proxyconn showed above with respect to claims 1 and 3,
`
`the Federal Circuit held that this was error:
`
`The Board erred in concluding that the terms “sender/computer” and
`
`“receiver/computer” were broad enough to include the intermediary gateway
`
`and caching computers . . .
`
`Microsoft, 789 F.3d at 1300. As explained above, with reference to claim 1 and 3,
`
`Santos fails to disclose the “receiver/computer” recited in claims 22-23, when
`
`those terms are properly constructed.
`
`Because Microsoft’s construction was in error and forms the only basis for
`
`its argument of anticipation by Santos, and at no point did Microsoft ever attempt
`
`to show that Santos had a “receiver/computer” without the intermediaries (i.e., the
`
`compressor or the decompressor), the only possible conclusion is that Microsoft
`
`
`
`13
`
`
`
`
`has failed to show that claims 22 and 23 (which depends from claim 22) are
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`unpatentable as anticipated by Santos.
`
`CONCLUSION
`
`
`
`A petitioner has the opportunity to select any claim construction and any
`
`grounds it believes it can prove. Presumably, Microsoft crafted the claim
`
`constructions that were necessary to make out its claim of unpatentability. The
`
`Federal Circuit, in turn, found that the constructions Microsoft deemed necessary
`
`were unreasonable, essentially wiping out each of Microsoft’s arguments as to
`
`claims 1, 3, 6, 7, 9, 10, and 22–23.
`
`Even if Microsoft could show unpatentability under a narrower claim
`
`construction, the fact is that it did not. To permit Microsoft, after presenting the art
`
`and arguments of it choosing to remake and reconstruct the prior art to sidestep the
`
`decision handed down by the Federal Circuit, is not only without authority but is
`
`fundamentally unfair. By definition, any effort by Microsoft to rework the Petition
`
`(and the prior art) are new arguments (to which Proxyconn will be unable to
`
`respond), and should be rejected.
`
`The findings of unpatentability of claim 10 over Yohe, of claims 1, 3, 10 and
`
`22 over Santos, of claims 6, 7 and 9 over DRP, and claims 1, 3, and 10 over Yohe
`
`and Perlman depended upon claim constructions that the Federal Circuit vacated.
`
`Microsoft made no showing (by argument or evidence) how any of these claims
`
`
`
`14
`
`
`
`
`are unpatentable under the correct, narrower construction, and thus Microsoft
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`cannot prevail on these grounds.
`
`In view of the narrower claim construction mandated by the Federal Circuit,
`
`in modifying its Final Written Decision, the Board must find that Microsoft failed
`
`to show, by a preponderance of evidence, that claims 1, 3, 6, 7, 9, 10, and 22–23
`
`are unpatentable on the instituted grounds.
`
`
`
`
`
`Dated: September 11, 2015
`
`Respectfully Submitted by:
`
`
`/s/ Matthew L. Cutler
`MATTHEW L. CUTLER, Reg. No., 43574
`BRYAN K. WHEELOCK, Reg. No., 31441
`DOUGLAS ROBINSON, Reg. No., 59703
`GREG W. MEYER, Reg. No., 59915
`HARNESS, DICKEY & PIERCE, PLC
`7700 Bonhomme Ave., Suite 400
`St. Louis, MO 63105
`Tel: (314) 726-7500
`Fax: (314) 726-7501
`mcutler@hdp.com
`bwheelock@hdp.com
`drobinson@hdp.com
`gmeyer@hdp.com
`
`Attorneys for Patent Owner, Proxyconn, Inc.
`
`
`
`15
`
`
`
`
`
`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
`
`Case No.: IPR2012-00026 & IPR2013-00109
`Patent 6,757,717 B1
`
`It is hereby certified that on this 11th day of September, 2015, a copy of the
`
`foregoing document was served via Electronic mail upon the following:
`
`John D. Vandenberg
`john.vandenberg@klarquist.com
`Stephen J. Joncus
`stephen.joncus@klarquist.com
`Klarquist Sparkman LLP
`One World Trade Center
`Suite 1600
`121 S.W. Salmon Street
`Portland, Oregon 97204-2988
`Tel.: (503) 595-5300
`Fax: (503) 595-5301
`
`
`Attorneys for Petitioner, Microsoft Corporation
`
`
`/s/ Matthew L. Cutler
`
`
`
`
`
`
`
`16
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