UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`Wavelock Advanced Technology Co., Ltd.,
`Petitioner
`
`v.
`
`Textron Innovations Inc.
`Patent Owner
`
`
`Patent No. 6,455,138
`Issue Date: September 24, 2002
`Title: METALLIZED SHEETING, COMPOSITES,
`AND METHODS FOR THEIR FORMATION
`_______________
`
`Inter Partes Review No. IPR2013-00149 (SCM)
`____________________________________________________________
`
`PETITIONER WAVELOCK ADVANCED TECHNOLOGY CO., LTD’S
` REPLY TO PATENT OWNER’S RESPONSE
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`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`Wavelock Advanced Technology Co., Ltd.,
`Petitioner
`
`v.
`
`Textron Innovations Inc.
`Patent Owner
`
`
`Patent No. 6,455,138
`Issue Date: September 24, 2002
`Title: METALLIZED SHEETING, COMPOSITES,
`AND METHODS FOR THEIR FORMATION
`_______________
`
`Inter Partes Review No. IPR2013-00149 (SCM)
`____________________________________________________________
`
`PETITIONER WAVELOCK ADVANCED TECHNOLOGY CO., LTD’S
` REPLY TO PATENT OWNER’S RESPONSE
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`TABLE OF CONTENTS
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`Page
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`I.
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`INTRODUCTION .......................................................................................... 1
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`II. MATERIAL FACTS ...................................................................................... 2
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`III. RESPONSE TO PATENT OWNER’S ARGUMENTS ................................ 4
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`A.
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`B.
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`C.
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`The Proper Legal Analysis ................................................................... 4
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`The Adhesive Of Kuwahara Is A Liquid ............................................. 5
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`The Liquid Adhesive Would Flow Into The Voids In
`Kuwahara’s Metallized Layer .............................................................. 7
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`1.
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`2.
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`3.
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`Patent Owner inaccurately characterizes Kuwahara and
`the claims of the '138 patent ...................................................... 7
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`The viscosity of the adhesive in Kuwahara was low
`enough to flow between the islands ........................................... 8
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`The diameter of the polymer molecules of the adhesive in
`Kuwahara would be below 500 Angstroms ............................... 9
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`D. Kuwahara’s Roller Coats The Liquid Resin Onto The
`Metallized Layer ................................................................................. 11
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`E.
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`F.
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`Kuwahara Does Not Teach Away ...................................................... 14
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`The Adhesive Would Flow ................................................................ 14
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`IV. CONCLUSION ............................................................................................. 15
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`Petitioner’s Exhibit List
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`Exhibit Description
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`Exhibit #
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`U.S. Patent No. 6,455,138 to Murano
`
`Office Action dated October 13, 2000
`
`Amendment dated November 28, 2000
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`Office Action dated February 27, 2001
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`Notice of Allowance dated June 19, 2002
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`Japanese Patent Application Publication No. S63-286337 to
`Kuwahara et al.
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`Translation of Japanese Patent Application Publication No. S63-
`286337 to Kuwahara et al. (with an affidavit of Mr. Eizo Tomono
`attesting to the accuracy of the translation)
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`U.S. Patent No. 4,101,698 to Dunning et al.
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`U.S. Patent No. 4,403,004 to Parker et al.
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`U.S. Patent No. 4,275,099 to Dani
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`U.S. Patent No. 5,532,045 to Wade
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`U.S. Patent No. 4,407,871 to Eisfeller
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`U.S. Patent No. 4,503,189 to Igarashi et al.
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`European Patent Application Publication No. 0 738 580 to Ohta
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`U.S. Patent No. 4,010,297 to Wenrick et al.
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`U.S. Patent No. 4,397,896 to Moran
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`1001
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`1002
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`1003
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`1004
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`1005
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`1006
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`1007
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`1008
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`1009
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`1010
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`1011
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`1012
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`1013
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`1014
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`1015
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`1016
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`Exhibit Description
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`Exhibit #
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`Declaration of Robert Iezzi, Ph.D.
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`Second Declaration of Robert Iezzi, Ph.D.
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`1017
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`1018
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`*Petitioner’s Exhibits 1001 – 1017 were previously filed and are simply listed
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`based on 37 C.F.R. § 42.63.
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`Petitioner provides this Reply under 37 C.F.R. § 42.23 to Patent Owner’s
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`Corrected Response dated October 9, 2013 (Paper 16) (“Response”). With this
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`Reply and its Petition filed on February 15, 2013, Petitioner requests relief through
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`the cancellation of claims 1-3, 8, 10, 16-19, 21, 25-33, 35 and 36 of the '138 patent
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`(Ex. 1001).
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`I.
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`INTRODUCTION
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`The Board instituted inter partes review based on the anticipation of claim 1
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`by Kuwahara (Ex. 1007). (Decision (Paper 8) at 21.) The Board further instituted
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`review of the remaining claims (which all depend from claim 1) as anticipated by
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`Kuwahara or obvious in view of Kuwahara and other references under five
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`grounds. (Id.) Patent Owner initially informed the Board and Petitioner that it did
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`not intend to file a response to the Decision. Then, five days before the response
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`deadline, Patent Owner changed its mind.
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`The filed Response is noteworthy for what it lacks. Patent Owner did not
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`substantively address each of the five grounds. Patent Owner did not provide
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`expert testimony to address the content of any of the references as understood by a
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`one of ordinary skill in the art. Nor did Patent Owner rebut the testimony about
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`these references by Dr. Iezzi, whose declaration (Ex. 1017) was submitted with the
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`Petition. Even though the Board repeatedly credited Dr. Iezzi’s testimony (see,
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`e.g., Decision at 13, 14 and 16), Patent Owner also did not depose him.
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`Instead, Patent Owner has only focused on a single limitation of claim 1:
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`“said discontinuous layer including discrete islands of metal in an adhesive.”
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`Patent Owner does not dispute that Kuwahara discloses a discontinuous layer
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`including discrete islands of metal or even an adhesive. Rather, Patent Owner has
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`plucked a single sentence from Dr. Iezzi’s declaration to contend that the evidence
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`is insufficient to show the discrete islands being in adhesive.
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`Petitioner disagrees. Kuwahara expressly discloses a number of facts – such
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`as roll coating adhesive on the discrete islands, a significant distance between
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`discrete islands and the application of heat and pressure – that as understood by a
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`skilled artisan clearly substantiates the Board’s finding that the discrete islands are
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`in adhesive.
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`II. MATERIAL FACTS
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`Petitioner disputes facts numbered “2” and “11” in Patent Owner’s
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`Response. (Response at 2-5.) In addition, Petitioner provides the following
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`material facts.
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`12. Kuwahara (Ex. 1007) at 4:6-11 discloses: “The distance between the
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`islands is set to between 100 and 5000 Å. If the distance between the islands is
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`smaller than 100 Å, then a tunneling current flows, so that the insulating
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`characteristic degrades. If the distance between the islands is larger than 5000 Å,
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`the amount of metal as a whole is insufficient and fine metallic luster cannot be
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`obtained.”
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`13. Patent Owner’s Ex. 2002 at page 1 (paragraph 1) provides: “Roll
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`coating machines are commonly used for the application of a liquid to the surface
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`of a part. Rollcoaters can be used to apply liquid adhesives, paints, oils, and
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`coatings such as varnish or clear finish coats.” (Emphasis added.)
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`14. Ex. 2002 at page 10 (paragraph 2) further provides: “Certain types of
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`adhesives (such as hotmelts, waxes and certain high viscosity materials) require
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`that the machine or the rollers be heated to melt the material or lower the viscosity
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`to a point where it can be applied.” (Emphasis added.)
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`15. The Adhesives Technology Handbook (Ex. 1018 at ¶ 9 and App. AA)
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`provides: “PVC and copolymers of both vinyl chloride and vinyl acetate with
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`other monomers, such as maleic acid esters, alkyl acrylates, maleic anhydride, and
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`ethylene, are also used to produce solvent-based adhesives.” (Emphasis added.)
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`16. As stated in Ex.1018 at ¶ 17: In a flowing adhesive, the huge number
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`of polymer chains would be oriented in every conceivable direction.
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`17. As shown by Zang, Y.-H and Carreau, P. J., A Correlation Between
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`Critical End-to-End Distance for Entanglements and Molecular Chain Diameter of
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`Polymers, J. Appl. Polym. Sci. (1991), 42: 1965–1968 (Ex. 1018 at ¶ 18 and App.
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`CC), the diameter of a vinyl chloride-vinyl acetate adhesive polymer chain would
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`be 12.9 Angstroms or less, which is less than a 5000 or 500 Angstrom spacing.
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`18. As stated in Ex. 1018 at ¶ 20: Adhesives can be applied “upside
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`down” by roll coating because the driving forces, such as (a) surface tension; (b)
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`capillary action; (b) the adhesive’s polymer chain small molecular diameter,
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`mobility, and orientation; and (c) intrinsic molecular inter-diffusion, cause the
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`adhesive to spread into the crevices of a surface and obtain intimate contact with
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`the surface.
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`19. As stated in Ex. 1018 at ¶ 28: It is known that most of the solvent in
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`an adhesive would evaporate during a lamination process.
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`III. RESPONSE TO PATENT OWNER’S ARGUMENTS
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`A. The Proper Legal Analysis
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`Patent Owner begins with a six page tutorial on anticipation, but at least
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`misses two key points. (Response at 14-20.) First, a reference anticipates if a
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`skilled artisan could take the reference’s teachings in combination with his or her
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`own knowledge of the particular art and be in possession of the claimed invention.
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`In re Graves, 69 F.3d 1147, 1152 (Fed. Cir. 1997); Helifix Ltd. v. Blok-Lok, Ltd.,
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`208 F.3d 1339, 1347 (Fed. Cir. 2000) (same and further discussing “evidence on
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`how a person of ordinary skill in the art would understand” a reference for
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`anticipation). Second, anticipation is “an issue of fact” and “the question of
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`whether a claim limitation is inherent in a prior art reference is a factual issue on
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`which evidence may be introduced.” In re Schreiber, 128 F.3d 1473, 1477 (Fed.
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`Cir. 1997) (internal citations omitted). In reaching anticipation in its Petition,
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`Petitioner explained the relevant facts of Kuwahara and how these facts would be
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`understood by a skilled artisan (who was defined, without objection, as having a
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`bachelor’s degree in chemical engineering, material science or chemistry and at
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`least five years of experience working with or researching thermoplastic films and
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`composites). (Petition (Paper 3) at 7-19; Iezzi First Dec. (Ex. 1017) at ¶¶ 19, 37-39
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`and 50-97.) In contrast, the rebuttal provided by Patent Owner is mere attorney
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`argument, which is insufficient to rebut the factual finding of anticipation by a
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`preponderance of evidence. 35 U.S.C. § 316(e).
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`B.
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`The Adhesive Of Kuwahara Is A Liquid
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`Kuwahara discloses applying its adhesive on the discrete islands by roll
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`coating. (Ex. 1007 at 5:14-27.) Patent Owner contends that Dr. Iezzi erroneously
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`understood the adhesive to be a liquid based on this disclosure of roll coating.
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`(Response at 22-23.) However, Patent Owner’s own Exhibit – Ex. 2002 –
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`confirms Dr. Iezzi’s understanding of Kuwahara to one of ordinary skill in the art.
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`(Ex. 1018 at ¶ 8.)
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`The very first two sentences of Ex. 2002 provide: “Roll coating machines
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`are commonly used for the application of a liquid to the surface of a part.
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`Rollcoaters can be used to apply liquid adhesives, paints, oils, and coatings such as
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`varnish or clear finish coats.” (Emphasis added.) Ex. 2002 further states at 10:
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`“The type of adhesive or coating will influence the way the liquids are brought to
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`the metering point.” (Emphasis added.) There is no mention at all in Ex. 2002 of
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`non-liquids being applied by roll coating. Thus, based on Patent Owner’s own
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`evidence relating to roll coating, the skilled artisan would have understood
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`Kuwahara’s roll coating an adhesive necessarily to be roll coating a liquid. Indeed,
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`the specific type of adhesive disclosed in Kuwahara is applied as a liquid. (Ex.
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`1018 at ¶ 9.)
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`Patent Owner tries to undermine this proper understanding of Kuwahara by
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`pointing to the irrelevant issue of electrostatic printing process of Xerox machines.
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`(Response at 21.) This argument is, once again, belied by Ex. 2002. It provides at
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`page 1:
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`A roll coating machine works by transferring a layer of coating from
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`the surface of a roller to the surface of a part. When this happens, a
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`phenomenon know[n] as ‘film splitting’ occurs. The layer of coating
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`on the surface of the roll splits – part of it stays on the roller, and part
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`sticks to the surface of the part. The percentage of coating that sticks
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`to the part (the substrate) depends on the surface characteristics of
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`both the roller and the substrate.
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`That is, roll coating relies on a liquid’s adhesive properties to itself, to the surfaces
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`of the roller and to the application surface. (Ex. 1018 at ¶ 11.) In comparison,
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`Xerox machines transfer particles from a charged toner drum to paper using
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`electrostatic charge—there is no film splitting in a Xerox machine. (Id.)
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`C. The Liquid Adhesive Would Flow Into The Voids In Kuwahara’s
`Metallized Layer
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`Having failed to undermine the proper understanding of Kuwahara’s
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`adhesive as a liquid, Patent Owner next turns to the operation of the liquid
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`adhesive. Yet again, Patent Owner cannot escape the facts of Kuwahara.
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`1.
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`Patent Owner inaccurately characterizes Kuwahara and the
`claims of the '138 patent
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`Patent Owner states: “Even if the copolymer resin of Kuwahara were roller
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`coated as a liquid onto the surface of the metallized film, Wavelock presents no
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`evidence that the liquid would be capable of filling a 500 Angstrom void.”
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`(Response at 24.)
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`This statement is factually wrong. Kuwahara explicitly discloses distances
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`between islands up to 5000 Angstroms – not 500 Angstroms. Specifically,
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`Kuwahara at 4:6-7 states: “The distance between the islands is set to between 100
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`and 5000 Å.” Knowing that 5000 Angstroms is large on a molecular scale, Patent
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`Owner fails to even mention this disclosure in its Response. It is also
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`conspicuously silent on whether the liquid adhesive would flow around discrete
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`islands with a spacing of 5000 Angstroms.
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`Patent Owner also repeatedly mischaracterizes the '138 patent as requiring
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`the liquid adhesive “fill” the spaces between the discrete islands. (See, e.g.,
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`Response at 5, 20 and 24.) All that is required by the claims is that the
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`discontinuous layer includes “discrete islands of metal in an adhesive.” Any
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`amount of adhesive that flows around the areas between the islands would cause
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`the discrete islands to be “in an adhesive.” (See, e.g., Ex. 1017 at ¶ 39.)
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`2.
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`The viscosity of the adhesive in Kuwahara was low enough
`to flow between the islands
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`Patent Owner argues that Kuwahara’s adhesive could be so viscous that it
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`would not flow and “fill” any voids. (See, e.g., Response at 24.) Patent Owner
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`again fails to take into account how the skilled artisan would understand the facts
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`of Kuwahara. (Ex. 1018 at ¶ 13.) As explained in Section B, the skilled artisan
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`would properly understand that Kuwahara’s adhesive was applied as a liquid given
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`its disclosure of roll coating on the discrete islands. Roll coating, as Patent
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`Owner’s Ex. 2002 explains, is a method of applying a liquid film layer. Further,
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`highly viscous liquids cannot be rolled coated as they would form clumps or bind
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`up the equipment. (Ex. 1018 at ¶ 14.) Once again, Ex. 2002 provides: “Certain
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`types of adhesives (such as hotmelts, waxes and certain high viscosity materials)
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`require that the machine or the rollers be heated to melt the material or lower the
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`viscosity to a point where it can be applied.” (Ex. 2002 at 10 (emphasis added);
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`see also Ex. 1018 at ¶ 14.)
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`Further, Kuwahara states that the “vinyl chloride-vinyl acetate copolymer
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`resin was applied to the deposited Sn layer of the examples to a thickness of 2µm
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`with a roller coater, then heated with a 2002 µm thick polyvinylchloride film and
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`laminated under pressure.” (Ex. 1007 at 5:19-22 (emphasis added).) The skilled
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`artisan would understand from these facts that the purpose of applying heat and
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`pressure during the lamination process is to get the adhesive to flow in order to
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`obtain intimate contact between the adhesive and surface features of the surfaces
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`being laminated in order to create the laminated article. (Ex. 1018 at ¶ 15.)
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`3.
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`The diameter of the polymer molecules of the adhesive in
`Kuwahara would be below 500 Angstroms
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`Patent Owner argues that the discrete islands could not be in Kuwahara’s
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`adhesive because the molecular weight, and hence the length of the polymer
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`chains, of the adhesive are too large to physically fit in the 500 Angstrom spacing
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`between the discrete islands. (Response at 25.) Again, Patent Owner does not
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`mention spacing up to 5000 Angstroms as disclosed in Kuwahara (Ex. 1007) at
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`4:6-7. Moreover, Patent Owner fundamentally errs by only considering the length
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`of the chains and not the polymer diameter and mobility. (Ex. 1018 at ¶ 16.)
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`Typical polymer molecules are very thin and flexible like cooked spaghetti.
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`(Ex. 1018 at ¶ 17.) In a flowing adhesive, the huge number of polymer chains
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`would be oriented in every conceivable direction. The chains that are aligned
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`width-wise with the openings would, therefore, necessarily flow between the metal
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`islands. (Id. at ¶ 17.)
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`This is confirmed when the calculations are applied specifically to a vinyl
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`chloride-vinyl acetate adhesive. (Ex. 1018 at ¶ 18.) As explained by Dr. Iezzi,
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`App. CC to Ex. 1018 provides the cross-sectional area of poly-vinyl-chloride and
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`poly-vinyl acetate and explains that the polymer chain diameter can be estimated
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`by taking the square root of these diameters. (Id.) These calculations provide a
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`polymer diameter of 5.2 Angstroms for poly-vinyl-chloride, and 7.7 Angstroms for
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`polyvinyl acetate. (Id.) Even assuming that these polymer chains appear exactly
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`side by side in a vinyl chloride-vinyl acetate adhesive, the total polymer chain
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`diameter would be 12.9 Angstroms, considerably below both the 5000 and 500
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`Angstrom spacing between the discrete islands disclosed in Kuwahara. (Id.)
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`In short, the facts of Kuwahara completely undercut Patent Owner’s attorney
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`argument. Kuwahara discloses island spacing of up to 5000 Angstroms – a fact
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`ignored by Patent Owner’s attorney argument. Moreover, Kuwahara discloses
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`polymer chains whose diameter would be well below 500 Angstroms – another
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`fact ignored by Patent Owner’s attorney argument.
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`D. Kuwahara’s Roller Coats The Liquid Resin Onto The Metallized
`Layer
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`In response to Dr. Iezzi’s statement that “the adhesive is applied on top of
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`the discontinuous metal layer,” Patent Owner states that Dr. Iezzi “is implying that
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`a liquid is applied to the top of the metallized film as it might be oriented
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`vertically, and consequently, gravity would cause the liquid to seep into the spaces
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`between the islands of metal.” (Response at 27-28.)
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`Dr. Iezzi never stated that gravity is the cause of the adhesive flowing across
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`the surface and seeping into the space between the islands of metal. The term
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`“top” was used relative to the structure in which metal islands are formed on
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`Kuwahara’s PET layer. (Ex. 1018 at ¶ 19.) This term was not meant to identify
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`any positioning with respect to coordinates external to the structure. (Id.)
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`More importantly, the facts of Kuwahara establish that its adhesive would
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`readily wet and flow into the spacings between islands. A liquid adhesive, such as
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`disclosed in Kuwahara, sticks to the metal/PET laminate by its adhesive
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`characteristics. Adhesives can be applied “upside down” by roll coating because
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`the driving forces, such as (a) surface tension; (b) capillary action; (c) the
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`adhesive’s polymer chain small molecular diameter, mobility, and orientation; and
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`(d) intrinsic molecular inter-diffusion, cause the adhesive to spread into the
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`crevices of a surface and obtain intimate contact with the surface. (Ex. 1018 at
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`¶ 20.)
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`These driving forces are present in Kuwahara. For example, with respect to
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`the driving force of surface tension, a liquid adhesive “wets” a solid surface if it
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`comes into with and spreads across all the exposed surfaces (including the exposed
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`surfaces between the islands). (Ex. 1018 at ¶ 21.) A skilled artisan would have
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`known that for a liquid to wet a solid surface, the surface tension of the liquid must
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`be lower than the surface tension of the solid, and that metals have a high surface
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`tension relative to adhesives and are easily coated by polymer adhesives and
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`coatings. (Ex. 1018 at ¶ 22.)
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`As explained by Dr. Iezzi, the surface tension of the tin metal islands in
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`Kuwahara is approximately 587 dyne/cm. (Ex. 1018 at ¶ 23.) The surface tension
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`of vinyl chloride is 41.9 dyne/cm, and of vinyl acetate is 36.5 dyne/cm. (Ex. 1018
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`at ¶ 24.) Thus, the vinyl chloride-vinyl acetate adhesive of Kuwahara will readily
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`wet and flow into the metal islands. Patent Owner also offers a scenario where
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`solvent may be used to dissolve the adhesive. (Response at 14.) Typical solvents
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`used for adhesives have much lower surface tension (about half) than the vinyl
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`chloride-vinyl acetate adhesive. Therefore, if the adhesive of Kuwahara was
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`dissolved in solvent, the surface tension of the adhesive-solvent mixture would be
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`even lower and interact with the metal islands and flow into the spaces between the
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`metal islands even more. (Ex. 1018 at ¶ 25.)
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`With respect to the driving force of capillary action, it too would facilitate
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`the flow of the adhesive into the small space between the metal islands. Capillary
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`action is “[t]he attraction between molecules, similar to surface tension, which
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`results in the rise of a liquid in small tubes or fibers, as can occur in filled
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`compounds or reinforced plastics.” (Ex. 1018 at ¶ 26; App. GG.) Thus, Patent
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`Owner’s depiction of the Kuwahara’s adhesive possibly being applied to the
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`bottom side of the part being coated is irrelevant, because the adhesive would flow
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`into the small space between the metal islands due to capillary forces alone.
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`(Ex. 1018 at ¶ 26.)
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`Finally, after applying the adhesive to the metal island layer, and stacking a
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`polyvinylchloride film on top of the adhesive, Kuwahara discloses applying heat
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`and pressure to the structure to film a lamination. (Ex. 1007 at 5:21-22.) The heat
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`and pressure applied during the lamination procedure would further drive the
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`adhesive into any unfilled spaces between the islands. (Ex. 1018 at ¶ 27.)
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`Thus, Patent Owner’s arguments as to the placement of adhesive
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`inaccurately presents Dr. Iezzi’s testimony, is wrong given the difference in
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`surface tension between the adhesive and metal islands and ultimately irrelevant
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`given that adhesive would flow between the metal islands due to capillary forces.
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`E. Kuwahara Does Not Teach Away
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`Patent Owner argues that Kuwahara teaches away from the presence of
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`adhesive between the islands, because residual solvent would permit electricity to
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`flow between the metal islands, which is to be avoided in Kuwahara. (Response at
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`30-31.) As a preliminary matter, teaching away is inapplicable to an anticipation
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`analysis. Celeritas Techs., Ltd. v. Rockwell Int'l Corp., 150 F.3d 1354, 1361 (Fed.
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`Cir. 1998). In addition, the argument makes no sense, because the adhesive would
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`still electrically connect the metal islands even if it was on top, as the Patent
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`Owner argues. Moreover, it is known that most of the solvent would have
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`evaporated during the lamination process. (Ex. 1018 at ¶ 28.) One skilled in the
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`art would understand that the small amount of solvent that remained would not
`
`have turned a non-conducting polymer adhesive into a conductor as Patent Owner
`
`argues. (Id.)
`
`F.
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`The Adhesive Would Flow
`
`At page 32 of the Response, the Patent Owner refers to Dr. Iezzi’s testimony
`
`as “unsupported opinion testimony.” These statements are incorrect, because Dr.
`
`Iezzi’s testimony was based on the facts disclosed in Kuwahara and thus was fully
`
`supported.
`
`As discussed above, 1) Kuwahara discloses that the adhesive is roll coated,
`
`which the skilled artisan would understand as a liquid adhesive with a viscosity
`
`la-1231065
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`IPR2013-00149
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`low enough to be a mobile liquid; 2) the diameter of the polymer molecules for the
`
`adhesive disclosed in Kuwahara is significantly less than the 500 Angstrom voids
`
`used in the examples of Kuwahara and even more significantly less than the 5000
`
`Angstrom voids also disclosed in Kuwahara; 3) the “wetting” action of the
`
`adhesive and capillary action would pull the adhesive into these relatively large
`
`pores as disclosed in Kuwahara; and 4) Kuwahara discloses applying heat and
`
`pressure during the lamination procedure, which would further drive the adhesive
`
`into any unfilled spaces between the islands. (Ex. 1018 at ¶ 30.) Thus, by a
`
`preponderance of evidence, Kuwahara necessarily discloses that the discrete
`
`islands are in adhesive to the skilled artisan.
`
`IV. CONCLUSION
`
`For at least the foregoing reasons, as well as those set forth in its Petition
`
`dated February 15, 2013, Petitioner respectfully requests the cancellation of claims
`
`1-3, 8, 10, 16-19, 21 and 25-33, 35, and 36 of the '138 patent.
`
`Dated: December 2, 2013
`
`
`
`
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`Respectfully submitted,
`
`By__/Mehran Arjomand/_______
`Mehran Arjomand, Reg. 48, 231
`Jonathan Bockman, Reg. 45,640
`MORRISON & FOERSTER LLP
`707 Wilshire Boulevard
`Los Angeles, California 90017
`(213) 892-5630
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`la-1231065
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`15
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`IPR2013-00149
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`Certificate of Service (37 C.F.R. § 42.6(e)(4))
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`I hereby certify that the attached Petitioner Wavelock Advanced Technology
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`Co., Ltd.’s Reply to Patent Owner’s Response was served as of the below date on
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`the Patent Owner via e-mail (by consent) to patrick.doody@pillsburylaw.com.
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`Dated: December 2, 2013
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`
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`
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`___/Mehran Arjomand/_______
`Mehran Arjomand
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`
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`la-1231065
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