UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Zynga Inc.
`Petitioner
`
`V.
`
`Personalized Media Communications, LLC
`Patent Owner
`
`Case IPR2013-00156
`
`US. Patent No. 7,860,131
`
`PETITIONER’S OPPOSITION TO PATENT OWNER’S MOTION TO
`
`AMEND
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Zynga Inc.
`Petitioner
`
`V.
`
`Personalized Media Communications, LLC
`Patent Owner
`
`Case IPR2013-00156
`
`US. Patent No. 7,860,131
`
`PETITIONER’S OPPOSITION TO PATENT OWNER’S MOTION TO
`
`AMEND
`
`
`
`Table of Contents
`
`Page
`
`11.
`
`HI.
`
`Introduction ...................................................................................................... 1
`
`PMC Fails to Satisfy its Burden of Proof........................................................... 1
`
`PMC’s Proposed Construction for “Advertisement” Is Overly Narrow ............. 3
`
`Higgins invalidates the substitute claim ............................................................. 3
`
`A.
`
`B.
`
`Higgins discloses the “advertisement” limitation ................................. 3
`
`Higgins discloses “selecting a specific datum from said prestored
`data based on subscriber specific data” ................................................. 7
`
`Hedges invalidates the substitute claim ............................................................. 9
`
`A.
`
`B.
`
`Hedges discloses the “advertisement” limitation .................................. 9
`
`Hedges discloses “selecting a specific datum from said prestored
`data based on subscriber specific data” ............................................... 11
`
`VI.
`
`Conclusion ...................................................................................................... 1 4
`
`
`
`I.
`
`Introduction
`
`In response to the Board’s decision to institute this IPR proceeding, Patent
`
`Owner, Personalized Media Communications, LLC (“PMC”), filed a Motion to
`
`Amend (“Motion”) the claims at issue. As required by the Board, PMC has the
`
`burden to show that the proposed claims are patentable over the prior art of record
`
`and prior art not of record but known to PMC. PMC’s Motion, however, fails to
`
`even make a conclusory statement about the prior art not of record. PMC’s Motion,
`
`therefore, should be dismissed for this reason alone. Additionally, the Motion
`
`should be dismissed because the proposed amendments do not overcome the prior
`
`art of record, Higgins (US. Pat. No. 5,270,922) and Hedges (US. Pat. No.
`
`4,339,798), either when viewed individually or in combination with additional art.
`
`Moreover, the proposed amendments are flawed. Specifically, the proposed
`
`construction for the “advertisement” limitation is overly narrow, especially in light
`
`of the Board’s construction of “commercial” in a related IPR proceeding involving
`
`a related patent.
`
`Accordingly, the Board should deny PMC’s Motion to Amend.
`
`II.
`
`PMC Fails to Satisfy its Burden of Proof
`
`In IPR proceedings, a patent owner proposing a substitute claim has the
`
`burden “to persuade the Board that the proposed substitute claim is patentable over
`
`the prior art of record, and over prior art not of record but known to the patent
`
`
`
`owner.”
`
`(Idle Free Systems, Inc. v. Bergstrom, Ina, IPR2012-00027, Paper 66,
`
`Final Written Decision, at p. 34 (quoting Paper 26 at pp. 7-8).) The burden cannot
`
`be satisfied with “just a conclusory remark that no prior art known to the patent
`
`owner renders obvious the proposed substitute claims.” (1d)
`
`PMC’s Motion to Amend fails this burden of proof. With respect to the prior
`
`art of record, PMC fails to establish that the proposed substitute claim is patentable
`
`over Higgins and Hedges for reasons stated in Sections V and VI below. With
`
`respect to the prior art not of record but known to PMC, PMC has not even made a
`
`conclusory statement that its proposed claim is patentable over prior art not of
`
`record, let alone satisfying the higher burden of proof set forth in Idle Free.
`
`Furthermore, PMC cannot claim that it is unaware of any other prior art
`
`relevant to the patentability of the ‘131 patent because it was served with detailed
`
`invalidity contentions based on 18 distinct patents during PMC’s litigation against
`
`Zynga. Similarly, PMC is also aware of the 17 patents served against its US. Pat.
`
`No. 7,797,717 patent
`
`(““717 patent”)
`
`to show disclosure of the patent’s
`
`“commercial” limitation, which is closely related to the currently proposed
`
`“advertisement” limitation. Because PMC has made no representation what—so—ever
`
`that the substitute claim is patentable over these known prior art, PMC has failed to
`
`meet its burden set forth in Idle Free.
`
`
`
`III.
`
`PMC’s Proposed Construction for “Advertisement” Is Overly Narrow
`
`PMC proposes that the new term “advertisement” should be construed to mean
`
`“a notice or statement about goods, products or services for the purpose of attracting
`
`customers or supporters.” (Motion at p. 6.) The meaning of “advertisement,” however,
`
`should be at least as broad as “commercial,” which the Board has construed to mean
`
`“information for a particular product or service” in a related IPR proceeding involving
`
`the ‘717 patent, which has the same specification as that of the ‘ 131 patent. (IPR2013-
`
`00164, Paper 10 at p.
`
`’7.)
`
`Instead of arguing for a narrower construction from the
`
`Board, PMC could have incorporated it into its proposed amendment; but it did not.
`
`IV. Higgins invalidates the substitute claim
`
`A.
`
`Higgins discloses the “advertisement” limitation
`
`Higgins discloses a system for providing investors a variety of stock
`
`information to facilitate the purchasing of stocks. One type of information provided
`
`is stock prices.
`
`(Ex. 1007 at 6:1—5.) PMC argues that “just as a person of ordinary
`
`skill
`
`in the art would recognize that price attached to merchandise is not an
`
`advertisement, the price of a stock symbol displayed at display 107 cannot be
`
`interpreted to be an advertisement.” (Motion at p. 11.) Yet during its litigation
`
`against Zynga, PMC read the “commercial” limitation in its
`
`‘717 patent on
`
`precisely a display of “price attached to merchandise,” as evident from Figure 26 of
`
`PMC’s infringement contentions, reproduced below:
`
`
`
`
`
`“I IQ 7“ Crew-a!
`
`46 5 Tom at Clowns "‘-
`Mlmlmml
`In.
`1.000 Tall! [mu-Int
`
`'
`
`
`
`
`
`liiigiu't‘ 136: Delivering (‘tHIllIll‘I'tIlizll from a plurality Ul' ifmutnt‘rt'ials [:C‘E-lHllPVlllt‘}
`
`(Ex. 1013 at p. 86.) These screen shots, which show prices for in-game currencies
`
`(5.6., crowns and coins), are characterized by PMC as “commercials.” (1d. at p. 85,
`
`“Figure 26 shows CastleVille screen shots of the ‘crown’ commercial on the left
`
`along with ‘coins’ commercial on the right.” ) Because a commercial is a narrower
`
`form of advertisement,
`
`the “commercials” shown in Figure 26 of PMC’s
`
`infringement contentions would necessarily be “advertisements” as well. Higgins’
`
`diSplay of stock prices is no different than the display of in-game currencies, which
`
`PMC contends are commercials (129., advertisements.)
`
`Moreover, as discussed in Section IV supra, the Board—using an identical
`
`specification as
`
`i
`that of the ‘131 patent—construed ‘commercial” to mean
`
`“information for a particular product or service.” (IPR2013-00164, Paper 10 at p. 7.)
`
`Higgins” stock quotes, which include price information for stocks, fall squarely under
`
`
`
`this definition. Because a commercial is a type of advertisement, Higgins’ stock quotes
`
`would necessarily also be an “advertisement.” (See Ex. 1021 at 1111 7-9.)
`
`In additional to stock quotes, Higgins also discloses an alert feature that notifies
`
`the user of stock prices that have, for example, dropped below a certain limit.
`
`(See Ex.
`
`1007 at 8:68-9:7, Fig. 2 at label 151; see also Ex. 1021 at 1] 10.) Pricing information
`
`about products—eSpecially when the price is lower than expected—is routinely used,
`
`without more, as a form of advertisement (tag, Subway’s “$5 foot long” promotion,
`
`McDonald’s “Dollar Menu,” etc.). In the context of stocks being the product, Higgins”
`
`out—of—limit notifications “are often used by brokers and investors as buy
`
`conditions
`
`and are of interest both to the broker and to his customers...” (Ex. 1007 at 5:11-15,
`
`emphasis added.) Thus, the out-of-limit alert is a notice about stocks for the pumose of
`
`attracting customers to buy the stock. This satisfies even PMC’s overly narrow
`
`
`construction of “advertisement,” which is “a notice or statement about goods, products
`
`or services for the pu_rpose of attracting customers or supporters.”
`
`(Motion at p. 6,
`
`emphasis added.)
`
`As yet another example of “advertisement,” Higgins discloses displaying
`
`stock dividend information.
`
`(See Ex. 1007 at 4:1-5; see also Ex. 1021 at 11 10.)
`
`Dividend is a payment made by a company to its shareholders and is a significant
`
`enticement for owning stocks. A high dividend—yielding stock attracts investors to
`
`purchase the stock, much like a bank’s high interest rate attracting customers to
`
`
`
`open savings or CD accounts. Thus, just as a bank’s display of “7% interest rate” is
`
`considered an “advertisement,” stock dividend information is
`
`similarly an
`
`“advertisement.”
`
`Other types of advertisements were also known to be delivered through
`
`information systems such as Higgins’.
`
`For example, Parsons (U.S. Pat. No.
`
`4,486,853)(attached at Ex. 1015) discloses an apparatus
`
`for
`
`receiving and
`
`diSplaying continuously updated “investment
`
`information,” much like Higgins.
`
`(Ex. 1015 at Abstract, 5:1-15.)
`
`In Parsons, data blocks carrying securities
`
`information include “promotional messages,” which “may be in the form of advice
`
`as to a particular security.” (Ex. 1015 at 16:8-9, 16:48-49, Fig. 1B.)
`
`Including
`
`such promotional message (corresponding to the claimed “advertisement”)
`
`in
`
`Higgins’ delivery of securities information would have been obvious to a POSITA.
`
`(See Ex. 1021 at ilil 11-14.)
`
`Similarly, Watson (U.S. Pat. No. 4,625,235)(attached at Ex. 1016) discloses a
`
`system allowing communications networks to switch between different sources of
`
`
`content, such as “news
`
`as well as regional and local commercial matter....” (EX.
`
`1016 at 1:1518, emphasis added.) Thus, it would have been obvious for a POSITA
`
`to modify Higgins” news field 149, which “forms a scrolling presentation of the
`
`news reported via the source 24,” to also display advertisements.
`
`(Ex. 1007 at 5:6—
`
`7, Fig. 2; see Ex. 1021 at 111115-17.)
`
`
`
`Accordingly, Higgins alone or in combination with either Parsons or Watson
`
`discloses the new “advertisement” limitation.
`
`B.
`
`Higgins discloses “selecting a specific datum from said prestored
`data based on subscriber specific data”
`
`Higgins’ system is operative to complete the stock information display in
`
`reSponse to the user’s keyboard entry, such that the user’s keyboard entry discloses
`
`the “subscriber Specific data” limitation of the substitute ‘131 claim.
`
`(See, e.g., Ex.
`
`1007 at Figs. 3-4; see also Ex. 1021 at 11 18.) PMC does not contest that the user’s
`
`keyboard entry meets the “subscriber specific data” limitation.
`
`(See Motion at p.
`
`12—13.) Rather, PMC only reiterates the same arguments it presented in its Patent
`
`Owner ReSponse, which does not relate to the new “subscriber specific data”
`
`limitation.
`
`(See Motion at p. 13, fn 2.) The inadequacy of those arguments has
`
`been fully addressed in Section II of Petitioner’s Reply to Patent Owner’s
`
`Response.
`
`Another example of Higgins’ disclosure of the “subscriber specific data”
`
`limitation occurs at block 312, where the system checks whether any limit has been
`
`exceeded.
`
`(1d. at 8:64—67.) The “prestored data” in this case is all the available lists
`
`(e. g, LRU, limit list, etc.), and the selected “specific datum” is the limit list.
`
`(Id. at
`
`8:24—31.) As clearly depicted in Figure 4, in order for the limit list to be selected
`
`for processing at block 312, the test at block 303 must have concluded that the
`
`incoming ticker message is found within “the list associated with limit processing.”
`
`
`
`(See id. at 8:44-51, 8:64-67, Fig. 4.) Thus, the “subscriber specific data” on which
`
`the selection of the limit list is based is the determination made at block 303 or the
`
`state of the computer program logic (1152., the fact that block 312 was reached).
`
`(See
`
`Ex. 1021 atfl 19.)
`
`Moreover, whether the limit
`
`list
`
`is selected and processed depends on
`
`whether the user is interested in displaying the limit information. Higgins” system
`
`allows a user to “specify various kinds of information desired for viewing” and
`
`specify a specific display format (e.g., a single-field or multi-field display).
`
`(Ex.
`
`1007 at 4:24-44; see Ex. 1021 at 1] 20.) A similar customizable display for “stock
`
`market
`
`information” is disclosed in more detail by Casey (US. Pat. No.
`
`3,792,462)(attached at EX. 1017).
`
`(See, e.g., Ex. 1017 at 5:29—34, 6:28-43, Figs. 1-
`
`5.) Casey further explains that, “[i]n addition to varying the size of the segment
`
`groups or areas for various modes, the information displayed in each segment of the
`
`display may also be varied for different modes.” (Ex. 1017 at 6:40—43.) If a display
`
`segment diSplaying one type of data (ag, quotes) is switched to diSplay a different
`
`type of data (e.g., “MIS” data), the system will “inhibit updating” of the non-
`
`displayed data.
`
`(See Ex. 1017 at 13:46—1422.) Thus, in light of Casey, a POSITA
`
`would find it obvious to modify Hedges such that the system selects and processes
`
`the limit list based on whether or not the user has chosen to display the limit field
`
`
`
`151 (12a,
`
`the “subscriber specific data”). Accordingly, Higgins alone or
`
`in
`
`combination with Casey discloses this limitation.
`
`(See Ex. 1021 at W 20-23.)
`
`V.
`
`Hedges invalidates the substitute claim
`
`A.
`
`Hedges discloses the “advertisement” limitation
`
`Hedges discloses a casino gaming system that displays playboards such as the
`
`craps table shown in Figure 5 below:
`
`
`
`1 am?
`
`“Straw""?"‘:
`
`[wifeknot—FriIns]
`
`
`EE N r E a j
`
`i— :5 “comes"
`_____ _r_o mug _
`
`"LC.“1:53
`0003—YIN!"an
`
`
`'£16:£553a
`
`Cash: nvligm
`
`I”
`
`E E
`
`i
`
`.=
`g
`
`é'
`
`1"?
`
`T
`
`_____
`
`9701
`
`“-
`
`_
`
`:QQ “[3leMllfluumumnmp
`
`
`r. ._._ __
`Ere: #313132
`'ZJEIJLJEJ
`
`ist
`“1'3 i
`-
`
`...ie_19_r__ fight}. 3.39)
`‘ 9 '°'
`
`
` r..m .T ' ..._..
`L“
`
`Issues“. m. PAS§_. MEET
`
`
`
`
`3‘0- 1“ j
`
`Flex-45
`
`The playboard displays “payoff odds,” such as in the field labeled “ODDS
`
`THIS BET,” and additional payoff information for different bets (e. g., a “FIELD”
`
`bet “PAYS 2 TO 1”).
`
`(See Ex. 1008 at 4:9-13, Fig. 5.) The payoff odds of a bet
`
`conveys how much a player could win by placing money on that bet. This entices
`
`players to participate in the casino’s gambling service—without any payoff odds
`
`(1’.e., where the payoff is 0 to 1), no one would ever participate.
`
`
`
`The payoff odds also entices players to make bets that are probabilistically
`
`more favorable to the casino. For example, in craps the probability of rolling two
`
`6’s is much lower than the probability of rolling a combined total of “ANY
`
`SEVEN.” The casino is much more likely to win if the user bets on the former
`
`relative to the latter. In order to entice players to make this relatively less favorable
`
`bet (i.e., double 6’s), the casino informs the user that the payoff odds for betting on
`
`double 6’s (116., 30 to 1) is much greater than that of “ANY SEVEN” (£16., 4 to 1).
`
`Thus, even under PMC’s overly narrow definition,
`
`the payoff odds is an
`
`“advertisement” since it is a statement about the casino service for the purpose of
`
`attracting customers to place bets. (See Ex. 1021 at 1111 24-25.)
`
`Furthermore, other types of advertisements were commonly known to be
`
`delivered
`
`at gaming terminals.
`
`For
`
`example,
`
`Small
`
`(US.
`
`Pat. No.
`
`4,815,741)(attached at EX. 1018) disclosed an “automated marketing and gaming
`
`system” comprising a sweepstakes processor, which determines whether a user is a
`
`sweepstakes winner based on his card number.
`
`(See Ex. 1018 at Abstract, Fig. 7
`
`labels 32, 41, 45, and 49.) The prize for winning could take the form of a “coupon
`
`for use at a local store.” (Id. at 9:34-37.) In view of Small, a POSITA would find it
`
`obvious to modify Hedges’ system to use a player’s card data, read by the card
`
`reader,
`
`to enter
`
`the player
`
`into a sweepstake and display a coupon (5.6.,
`
`“advertisement”) if the player wins.
`
`(See Ex. 1021 at 111] 26-28.)
`
`-10-
`
`
`
`As another example, Dubno (U.S. Pat. No. 4,722,053)(attached at Ex. 1019)
`
`disc-loses a “food service ordering terminal with video game capability.” (Ex. 1019
`
`at Abstract, 1:1-3.) During game play the terminal displays food menu items, and at
`
`the end of game play it displays a message “inviting the patron
`
`to return and/or
`
`move to an establishment adjacent the restaurant and provide it with standard coin-
`
`operated computer games.”
`
`(See id. at 2:21-31, 2:54-60.)
`
`In view of Dubno, a
`
`POSITA would find it obvious to modify Hedges’ gaming system to display food
`
`menu items while players gamble and attract players to another establishment when
`
`the player
`
`leaves.
`
`Both the
`
`food menu and the
`
`invitation constitute
`
`“advertisement.” (See EX. 1021 at 1111 29-30.)
`
`B.
`
`Hedges discloses “selecting a specific datum from said prestored
`data based on subscriber specific data”
`
`Hedges’ remote gaming terminal (RGT) includes computer program modules
`
`for performing various gaming operations “in response to a stimulus from
`
`the
`
`player....” (Ex. 1008 at 9:10-14.) The specific operation is based in part on the
`
`data stored in RAM, which contains “information about
`
`the current state of
`
`operation of the RGT.”
`
`(Id. at 9:14—18.) PMC argues that the selection of data
`
`from the game state table is purely driven by the program modules and “there is no
`
`subscriber Specific data that is taken into consideration. . ..” (See Motion at p. 14—
`
`15.) This is an inaccurate, superficial characterization of Hedges’ disclosure, as the
`
`detailed implementation of Hedges shows that subscriber Specific data is used.
`
`-11-
`
`
`
`Hedges discloses that when a player touches the screen, a signal is sensed by
`
`the RGT, which “notes the position of the player’s touch and informs processor 41
`
`of FIG. 2 that a new command is being generated by the player.” (Ex. 1008 at 4:53-
`
`57.)
`
`In reSponse to the touch, the RGT generates a code indicating the touched
`
`location and checks the code “against a table of codes for panel locations which are
`
`allowed for the game or operational mode currently in effect.” (1d. at 11:48-53.)
`
`After determining the command intended by the player’s touch, the appropriate
`
`entry is placed into the task queue 166, which “prioritize[s] lists of task
`
`to be
`
`performed as maintained in RAM 92 of FIG. 9.” (Id. at 11:57-66, 9:18-21, 10:10—
`
`19.) Thus, while a player’s touch (the claimed “control signal”) triggers execution
`
`of the computer program, the eventual processing of the command is based on the
`
`command’s priority within the task list 166, which corresponds to the claimed
`
`“subscriber specific data.” (See Ex. 1021 at ii 31.)
`
`Further, the player’s command, which is determined by checking the user’s
`
`touch (“control signal”) location against the table of codes,
`
`is also “subscriber
`
`specific data.” (See Ex. 1021 at Ti 32.) For example, in a scenario where a player
`
`makes a wager, the command to bet is “subscriber specific data.” Based on this bet
`
`command, the RGT checks whether “it represents a valid input” (id. at 11:53),
`
`which may involve determining whether the wager “exceeded cash available” (id. at
`
`Fig. 4-6.). While Hedges does not provide implementation detail for this feature,
`
`-12-
`
`
`
`Levy (US. Pat. No. 3,810,627)(attached at Ex. 1020) does. Like Hedges, Levy
`
`discloses a “system for placing wagers from a remote location...” (Ex. 1020 at
`
`1:6-12.) When a player places a bet, the Levy system checks whether the bet
`
`“exceed[s] the available credit balance” and signals the player accordingly.
`
`(See id.
`
`at 18-22.)
`
`“If the player’s credit balance is sufficient the amount of the wager is
`
`reduced immediately upon the registering of the wager.” (1d. at 22—24.)
`
`In View of
`
`Levy, Hedges’ system—upon detecting a bet command (as opposed to other types
`
`of commands)—would select the player’s credit balance (tie, the selected “specific
`
`datum”) from the game status table (126., “prestored data”) and check if the player
`
`has sufficient credit to place the bet.
`
`If so, Hedges’ system calculates the ending
`
`balance and completes
`
`the display by placing the processed result
`
`(119.,
`
`“information”) into the display. (See EX. 1021 at W 33-35.)
`
`Accordingly, Hedges alone or
`
`in combination with Levy teaches the
`
`“subscriber specific data” limitation.
`
`-13-
`
`
`
`VI.
`
`Conclusion
`
`In View of the above, Petitioner requests that the Patent Owner’s Motion to
`
`Amend be denied.
`
`Date: 131mm 24, 2014
`
`
`
`oehran, Reg. No. 39,142
`David B.
`Joseph M. Sauer, Reg. No. 47,919
`JONES DAY
`
`North Point, 901 Lakeside Avenue
`Cleveland, Ohio 441 14
`
`(216) 586-3939
`
`-14-
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Petitioner’s
`
`Opposition to Patent Owner’s Motion To Amend, along with all exhibits supporting
`
`and filed with the Opposition, were served on January 24, 2014 via email to:
`
`Thomas J. Scott, Jr.
`
`tscott
`
`oodwin rocter.com
`
`and
`
`Stephen Sc-hreiner
`
`sschreiner_@goodwinprocterc
`
`Dated: January 24, 2014
`
`By:
`
`
`
`APPENDIX OF EXHIBITS
`
`
`EXHIBIT
`
`NO.
`
`TITLE
`
`1001
`
`U.S. Patent No. 7,860,131 (“the Harvey ‘131 Patent”)
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`PMC Infringement Contention Claim Charts against Zynga for the
`Harvey ‘l3l Patent, Personalized Media Communications, LLC v.
`Zynga, Inc, Civil Action No. 2:12-cv-68 (ED. Texas)
`
`Excerpt from the file history of the Harvey ‘131 Patent: March 15,
`1999 Supplemental Amendment
`
`Excerpt from the file history of the Harvey ‘ 131 Patent: September
`
`3, 2002 Office Action
`
`Excerpt from the file history of the Harvey ‘131 Patent: March 3,
`
`2003 Amendment
`
`Plaintiff 5 Disclosure of Asserted Claims and Infringement
`Contentions, Personalized Media Communications, LLC v. Zynga,
`Ina, Civil Action No. 2:12—cv—68 (ED. Texas)
`
`
`
`
`
`l
`
`I
`
`
`
`1007
`U.S. Patent No. 5,270,922 (“Higgins”)
`
`
`
`
`
`
`
`U.S. Patent No. 4,339,798 (“Hedges”)
`
`U.S. Patent No. 4,572,509 (“Sitrick”)
`
`Declaration of Dr. Charles J. Neuhauser Under 37 C.F.R. § 1.68 in
`Su ort of Petition for Inter Fortes Review of U.S. Patent No.
`
`
`
`
`
`7,860,131
`
`
`
`101 1
`
`Appendix to the Declaration of Dr. Charles J. Neuhauser: Dr.
`Neuhauser’s current curriculum vitae
`
`
`1012
`
`Rebuttal Declaration of Charles J. Neuhauser, PhD. Under 37
`
`OF .R. § 1.68
`
`
`
`
`1013
`
`Excerpt from Expert Report of Mark Claypool, Ph.D., July 19,
`2013, Personalized Media Communications, LLC v. nga, Inc,
`Civil Action No. 2:12-cv-68 (ED. Texas)
`
`1014
`
`Deposition transcript of Samuel H. Russ, PhD (January 10, 2014)
`
`1015
`
`U.S. Patent No. 4,486,853 (“Parsons”)
`
`1016
`
`U.S. Patent No. 4,625,235 (“Watson”)
`
`1017
`
`U.S. Patent No. 3,792,462 (“Casey”)
`
`1018
`
`U.S. Patent no. 4,815,741 (“Small”)
`
`1019
`
`U.S. Patent No. 4,722,053 (“Dubno”)
`
`U.S. Patent No. 3,810,627 (“Levy”)
`
`1021
`
`Declaration of Charles J. Neuhauser, PhD. Under 37 C .F.R. § 1.68
`in Support of Opposition to Patent Owner’s Motion to Amend
`
`
`
`
`
`
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
