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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MOBOTIX CORP.
`Petitioner
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`v.
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`E-WATCH, Inc.
`Patent Owner
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`
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`Case IPR2013-00255
`Patent No. 6,970,183
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` PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE
`UNDER 37 C.F.R. § 42.23
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`1
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`INTRODUCTION
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`The Board instituted Inter Partes Review as to claim 1-25 and 32-34 of the ‘183
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`Patent based on the following references: Claims 1-9, 12-17, 25 and 32 as obvious over Ely
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`(Document 5: Exhibit 1004) and Fernandez (Document 9:Exhibit 1008)(Ground 1); Claims
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`10, 11 and 18-23 as obvious over Ely, Fernandez and Imaide (Document 10: Exhibit
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`1009)(Ground 2); Claim 24 as obvious over Ely, Fernandez and Barzdins (Document
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`11:Exhibit 1010)(Ground 3); Claims 25 and 33 as anticipated by Kogane (Document
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`8:Exhibit 1007)(Ground 4); and Claims 32 and 34 as obvious over Kogane and Fernandez
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`(Ground 5). Decision (Document 27), p. 34.
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`
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`E-Watch’s Patent Owner Response (“POR”) fails to make a prima facie case for
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`patentability of any of claims 1-25, or 32-34 of the ’183 patent. As a threshold matter, the
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`POR is basically a copy of the Patent Owner’s Preliminary Response (POPR)(Document
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`26). The Board already reviewed the POPR and decided to institute the Inter Partes
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`Review. Since no material new facts or substantive new arguments are provided by Patent
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`Owner (PO) in the POR the Board should come to the same conclusion as it did when the
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`Inter Partes Review was instituted.
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`ARGUMENT
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`PO argues only the independent claims 1, 18 and 25 and submits that the dependent
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`claims stand and fall with the independent claims, and PO has failed to separately address
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`2
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`the dependent claims. POR, p. 6. Accordingly, Petitioner will address only the independent
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`claims herein.
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`A.
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`PO has Failed to Overcome the Showing that Claim 1 (and 2-9, and 12-17) and
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`Claim 25 are Unpatentable Over Ely and Fernandez (Ground 1)
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`1. Ely alone and Ely and Fernandez show a network based server storing data
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`digitally
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`Claim 1 requires “a surveillance sensor appliance controlled by the (network based)
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`server for monitoring an area and generating a signal indicating a condition in the monitored
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`area in a programmed response mode controlled by the server, whereby the server receives
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`and logs data transmitted by both the conventional sensor and the sensor appliance.”
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`Claim 25 likewise requires “a plurality of sensor appliances adapted to [be] connected to a
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`network based server for monitoring, logging, and transmitting data to the server”
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`(parenthetical added).
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`The POR states that Ely does not include a network based server and does not have
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`a central storage for storing data from all cameras digitally. POR, pp. 7 and 8. In particular,
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`PO states that the retrieved video data are recorded on a VCR, not a server or computer.
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`POR, p. 8. These arguments are nearly verbatim repeats of the arguments made in the
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`POPR.
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`The Board has previously recognized that Ely individually and in combination with
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`3
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`Fernandez show a network based server. Decision, p. 18. PO has provided no new
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`evidence or substantive arguments to rebut the Board’s decision.
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`As Petitioner has previously demonstrated, the host computer 104 of Ely comprises
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`hardware and software providing the same functionalities as the server in the ‘183 Patent.
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`The host computer 104 communicates with the camera units 114 and sensor devices 120
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`over the LAN 112. Ely, 9, 12-181; Figure 2. The camera units 114 capture and transmit
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`(compressed) surveillance data (video data) to the host computer 104 and the host
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`computer 104 controls the camera units 114. The host computer 104 receives the
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`compressed video data from the camera unit 114 through the LAN 112 and provides these
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`data in an appropriate manner to the DVTR 110 for digital recording. Ely, 16, 9-14 and 24-
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`31. Further, the DVTR 110 or the data recorder can be considered part of the host
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`computer 104 because it is controlled by the host computer 104. Ely, 16, 4-6 and 35-36.
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`Finally, Fernandez teaches a central controller 6 as a network based server including a
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`digital storage 49 for storing the data digitally. Fernandez, 2:23-272; 8:27-30; Figure 3.
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`Accordingly, Ely and the combination of Ely and Fernandez show a network based
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`server storing data digitally.
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`2. Ely alone and Ely and Fernandez show receiving and logging data from both
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`the conventional sensors and the sensor appliances.
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`1 Page 9, lines 12-18
`2 Column 2, lines 23-27
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`4
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`Claim 1 further requires “whereby the server receives and logs data transmitted by
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`both the conventional sensor and the sensor appliance.”
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`PO erroneously states that Ely does not show receiving and logging data from both
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`the conventional sensors and the sensor appliances. POR, p. 8. In particular, PO contends
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`that the lack of a server in Ely precludes logging data on a host, particularly alarm data. Id.
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`This position is, again, nearly identical to the unpersuasive arguments raised by PO in the
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`POPR.
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`The Decision addresses this issue on pages 19-20 and comes to the conclusion that
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`Ely shows a server receiving and logging data transmitted by both the conventional sensor
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`and the sensor appliance. In the absence of any new evidence or even argument by PO,
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`the Board’s decision should stand.
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`As the Board has recognized, Ely shows receiving and logging alarm data on the
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`server. In his declaration, the Expert Dr. Tal Lavian states that Ely inherently teaches a
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`server receiving and logging conventional sensor data and video data because the main
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`operational function of a computer in the security application environment is to receive and
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`log alarm data, sensor data, video data and other relevant security data. Declaration
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`(Document 4), ¶ 29. Receiving video data without knowing when, where and under what
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`condition they were taken is useless in a security setting.
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`Moreover, Ely expressly discloses a server as a host computer 104 and a data
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`recorder. Ely, 16, 32-17, 2; Figure 2. The data recorder (under the control of the host
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`5
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`computer 104) records all traffic on the LAN 112 which necessarily includes also sensor
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`data.
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`Finally, Fernandez teaches that the storage 49 of the central controller receives and
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`logs video and sensor data. Fernandez, 2:66-3:15; 3:23-25; 4:23-36; 6:41-44 and 16:52-56.
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`Accordingly, Ely alone and Ely combined with Fernandez show receiving and logging
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`data from both the conventional sensors and the sensor appliances.
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`3. Ely shows a converter for converting the conventional sensor signal in a
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`network based signal
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`Claim 1 further requires “a convertor for converting the conventional sensor signal
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`into a network compatible signal and adapted for sending the converted signal via the
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`network to the server.”
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`PO, without any reasoning, states that the conversion is not taught or suggested
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`anywhere in Ely. POR, p. 12.
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`The Decision addresses this issue on page 20 and recognizes that Ely shows a
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`convertor for converting the conventional sensor signal into a network compatible signal.
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`It is clear and unrebutted that an empirical (analog) sensor signal must be converted
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`to a (digital) network based signal after it is received by a sensor to be sent over the digital
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`network. Declaration, ¶¶ 27, 28.
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`Accordingly, Ely shows a converter for converting the conventional sensor signal in a
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`network based signal.
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`6
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`4. Neither Claim 1 nor Claim 25 Requires a Computer to Display Video
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`PO states that Ely does not use a computer to display video. POR, p. 8. However,
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`neither claim 1 nor claim 25 requires a computer displaying video. Further, as noted by the
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`Board, one skilled in the art would recognize that Ely’s teaching of video data makes
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`obvious that video data is transmitted to a monitor for viewing. Decision, p. 22.
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`5. Neither Claim 1 nor Claim 25 Requires Transmission of Signals of All Cameras
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`Simultaneously In or at Real Time
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`PO argues a “key omission” of Ely is the ability to transmit all cameras
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`simultaneously in or at real time. POR, p. 8. Neither claim 1 nor claim 25, however,
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`requires transmission of signals of all cameras simultaneously in or at real time. Moreover,
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`contrary to the contentions of PO, Ely shows real time transmission of captured video data
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`to the central station. Ely, 12, 9-17; Block 152 of Figure 4. As also noted by the Board, Ely
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`teaches simultaneously transmitting video data because Ely describes a conventional split
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`screen technique including video multiplexers to display video streams from different
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`cameras. Ely, 15, 36-16, 3; Decision, p. 19.
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`6. Neither Claim 1 nor Claim 25 Requires Distinguishing Multiple Cameras and
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`Multiple Sensors from One Another
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`PO states that Ely does not disclose how each of the cameras (114) and sensors
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`(120) provides a signal distinguishing the multiple cameras and the multiple sensors from
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`one another. POR, p. 12. However, neither claim 1 nor claim 25 requires a signal
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`distinguishing the multiple cameras and the multiple sensors. Furthermore, as the Board
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`has recognized, Ely teaches that cameras are differentiated because video data may be
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`routed from a selected camera and that selected cameras may be instructed not to transmit
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`video data. Decision, p. 22.
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`7. Neither Claim 1 nor Claim 25 Requires “Full Motion Video”
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`PO states that Ely fails to deal with full motion video. POR, p. 6. However, neither
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`claim 1 nor claim 25 requires full motion video. Further, the Board has previously
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`recognized that Ely’s disclosure of the H.261 video compression standard teaches full
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`motion video to one skilled in the art. Decision, pp. 22-23.
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`8. Claim 25 does not require storing still images.
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`PO asserts that Ely does not anticipate claim 25 because it does not teach or
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`suggest that both stills and video are recorded and logged. POR, p. 13. However, claim 25
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`does not require that both stills and videos be recorded and logged.
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`PO has Failed to Overcome the Showing that Claim 18 (and 19-23) are
`B.
`Unpatentable Over Ely, Fernandez and Imaide (Ground 2)
`1. Ely alone and Ely and Fernandez show a network based server storing data
`digitally
`Claim 18 recites in the preamble “a plurality of sensor appliances adapted to [be]
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`connected to a network based server for monitoring, logging, and transmitting data to the
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`8
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`server” (parenthetical added). PO states with regard to both claim 18 and claim 1 that Ely
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`does not include a network based server and does not have a central storage for storing
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`data digitally from all cameras. POR, pp. 7 and 8. In response, Petitioner incorporates by
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`reference the arguments provided above with respect to claim 1 at Sections A.1 and A.2.
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`2. Ely shows (full) motion video images
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`Claim 18 recites “a multi-function image sensor appliance adapted for generating an
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`image signal representing the visual condition of a monitored zone of operation, the image
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`signal comprising both still frame image data and motion video image data.” Here, PO
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`makes contradictory statements by first asserting that Ely fails to teach full motion video and
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`then contending that Ely stores short video clips in each camera. POR, pp. 6 and 7.
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`Regardless, the system 100 of Ely is adapted to use the H.261 standard, which standard
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`includes (full) motion video. Ely, 11, 33. Accordingly the cameras are adapted to generate
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`still frame data and (full) motion video data. Declaration, ¶30.
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`3. Claim 18 does not require storing and retrieval of still frames
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`PO asserts, without citation or evidentiary support, that Ely does not teach collection,
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`storing and retrieval of still frames because a VCR cannot store still frames independently of
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`motion video. POR, p. 8.
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`Once again, the POR provides no new evidence, citation to authority, or even new
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`attorney argument to bolster PO’s position. Hence, PO has failed to offer any basis to
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`9
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`change the Board’s initial conclusion that Ely alone, and Ely and Fernandez, show storing
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`and retrieval of still frames. Decision, pp. 22-23. Petitioner further notes that Ely does not
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`only show a VCR but other image storing devices such as a DVTR. Ely, 16, 9-14 and 24-
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`31.
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`Moreover, claim 18 does not require collection, storing and retrieval of still frames on
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`a server, as PO has apparently alleged. Rather, the relevant portion of claim 18 recites “a
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`multi-function image sensor appliance adapted for generating an image signal …, the image
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`signal comprising both still frame image data and motion video image data” and “a
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`transmitter for sending (the?) image data (signal?) to the server” (parentheticals added).
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`PO has failed to identify any claim element that requires a server storing or retrieving still
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`frame data. Even when the preamble is pulled in the claim refers (only) to data being
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`logged on the server. The preamble does not require still frame (or still frame independent
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`of motion video) data. Rather, Ely (in combination with Fernandez and Imaide) teaches all
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`of the claim elements actually recited in claim 18, as has been demonstrated by Petitioner.
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`Petition, pp. 37-39.
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`4. Other Arguments of PO with Respect to claim 18
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`Similar to the irrelevant arguments made by PO with regard to claim 1, claim 18 does
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`not require a “computer displaying video,” “transmission of signals of all cameras
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`simultaneously in or at real time,” or “providing signals distinguishing the multiple cameras
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`10
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`and multiple sensors from each other.” PO’s reliance upon these non-claim elements is
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`misplaced, as addressed above in Sections A.4-A6.
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`PO has Failed to Overcome the Showing that Claim 25 (and 33) is Anticipated
`C.
`By Kogane (Ground 4)
`1. Kogane shows a server storing digitized video
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`Claim 25 requires “a plurality surveillance sensor appliances controlled by the server
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`for monitoring an area and generating a data signal indicating a condition in the monitored
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`area controlled by the server, whereby the server receives and logs signal data.” PO
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`contends that the control server 5 stores only meta data. POR, p. 10. This is incorrect, as
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`the Board has previously recognized. Decision, pp. 26-27. Kogane shows a control server
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`5 including a data base 47 for storing sets of video data from camera units 1 (1a-1c).
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`Kogane, 6:4-8; Figure 2.
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`2. Kogane shows a server adapted for collecting and managing data
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`transmitted by the plurality of sensor appliances
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`PO asserts that the control server 5 of Kogane is used to “control the camera image
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`and video collection process, not the collection and the management of transmitted data.”
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`POR, pp. 14-15. PO further states that the control server of Kogane” manages the way
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`data is collected, not the way collected data is managed.” POR, p. 14. This cryptic
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`argument is virtually unchanged from the POPR and remains unsupported by citation to
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`11
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`authority, by evidence, or by expert testimony.
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`The plain language of claim 25 requires a server adapted for collecting and
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`managing data (not necessarily video data) transmitted by the sensor appliances. Kogane
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`not only shows that the control server 5 controls lens unit 21 etc. but also that it stores alarm
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`related data and sets of video data from camera units 1 (1a-1c). Kogane, 3:66-4:2; 6:4-8.
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`The storing of sets of alarm related data and video data certainly includes collecting and
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`managing data transmitted by the sensor appliances. For example, control server 5 marks
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`the video data not be searched when there is an error or to transmit alarm related data to
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`the display terminal 4. Kogane, 6:8-21.
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`3. Claim 25 does not require (streaming) motion video
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`PO states that Kogane does not show any (streaming) motion video because it
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`refers to JPEG only. POR, p. 10. Claim 25 does not require (streaming) motion video but
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`rather “signal data.”
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`4. Claim 25 does not require a computer displaying video
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`PO states that Kogane does not use a computer to display video. POR, p. 10.
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`Claim 25 does not require a computer displaying video.
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`D.
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`PO has Failed to Overcome the Showing that Claim 32 (and 34) is Unpatentable
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`Over Kogane and Fernandez (Ground 5)
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`12
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`The only real new submission PO provides in the POR relative to the POPR is the
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`discussion of Fernandez with reference to the teaching of a “dispatch generator” in claims
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`32 and 34 (both of which depend from claim 25). POR, pp. 11-12. PO has failed, however,
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`to distinguish claims 32 or 34 over the prior art and has instead expressly relied solely upon
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`its arguments relating to independent claim 25 to assert patentability of claims 32 and 34.
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`POR, p. 6. PO has simply failed to provide any evidence or rationale or citation to address,
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`much less overcome, the decision of the Board that the combination of Kogane and
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`Fernandez renders obvious claims 32 and 34. Decision, pp. 29-30.
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`Furthermore, PO’s assertion that it is “speculative” whether Fernandez discloses a
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`dispatch generator is wrong. Fernandez unequivocally teaches a surveillance system
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`(Figure 1) that includes a tool 166 (dispatch generator) in the controller 6. Fernandez;
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`15:18-65; Figure 3. There is no speculation that the system “may” include such a tool as
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`PO contents; it “does” include the tool, as at least Figure 3 and the related description
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`establish. Petitioner notes that Fernandez states that dispatch generator tool 166 “may
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`adaptively provide positional or directional functionality.” Fernandez, 15:42-44. Hence,
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`Fernandez establishes that some functionality of the disclosed dispatch generator is
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`optional – but this does not make the disclosure speculative. By describing that a dispatch
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`generator may optionally be included in the described system, Fernandez sufficiently
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`demonstrates that the use of such a dispatch generator in a surveillance system was well
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`known in the art at the relevant time.
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`13
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`E.
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`PO has Failed to Articulate a Rebuttal to Petitioner’s Expert Declaration
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`With the exception of breaking a few long paragraphs into several shorter
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`paragraphs, PO’s challenge to the sufficiency of Dr. Lavian’s Declaration is identical to the
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`Preliminary Response (compare POR, pp. 16-19 to POPR, pp. 13-16). This is true despite
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`the fact that the Board explicitly cited to Dr. Lavian’s Declaration at least three times
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`(Decision, pp. 18 and 22-24) and has both implicitly and explicitly found Dr. Lavian’s
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`positions credible and supported. Rather than providing evidence in the form of competing
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`expert testimony and rather than providing specific rebuttals to Dr. Lavian’s positions, PO
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`chose to simply repeat its previous rhetoric and unsubstantiated conclusions.
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`The Petition and supporting Declaration upon which this proceeding was initiated
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`fully meets the required standards. In a recent decision the Federal Circuit explained:
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`At the time [of the decision in In re Lee], we required the PTO to identify
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`record evidence of a teaching, suggestion, or motivation to combine
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`references because “[o]mission of a relevant factor required by precedent is
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`both legal error and arbitrary agency action.” However, this did not preclude
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`examiners from employing common sense. More recently [in DyStar
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`Textilfarben GmbH v. C.H. Patrick Co., 464 F.3d 1356, 1366 (Fed.Cir.2006)],
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`we explained that use of common sense does not require a “specific hint or
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`suggestion in a particular reference,” only reasoned explanation that avoids
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`conclusory generalizations.
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`14
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`Perfect Web Technologies, Inc. v. InfoUSA, Inc., 587 F.3d 1324, 1329 (Fed. Cir.
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`2009) (citations omitted).
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`Petitioner’s positions and supporting evidence clearly meet and arguably well
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`exceed the standard articulated by the Federal Circuit. As but one example, Dr.
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`Lavian states “[b]oth Ely and Fernandez relate to a surveillance system for
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`monitoring an area by using cameras and sensors” and “[i]t would have been
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`obvious to a person skilled in the art at the time of the invention to modify the
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`surveillance network as taught by Ely with the surveillance network as taught by
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`Fernandez because both references teach using known networks in the same way
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`yielding predictable results. Such a substitution is well known, based on common
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`sense, or the result of routine experimentation.” Declaration, ¶¶ 39 and 40.
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`Accordingly, Dr. Lavian provides evidence that the sensors and cameras of Ely and
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`Fernandez provide predictable use of prior art elements according to their
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`established functions. Other examples where Petitioner and Dr. Lavian provided
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`bases for combining references were recognized by the Board. Decision, p. 24.
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`Rather than re-hashing unsubstantiated attorney argument, PO could have
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`deposed Dr. Lavian to reveal any shortcomings in his testimony. Alternatively, PO
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`could have provided an expert to challenge the findings of Dr. Lavian. However, PO
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`decided not to do so, and hence has offered no evidence with which to rebut Dr.
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`Lavian’s testimony.
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`15
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`F.
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`Hindsight
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`Finally, PO contends that Petitioner provides no explanation of a reason to combine
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`prior art references and therefore concludes that the combination of these references is
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`based on improper hindsight. POR, p. 19. As discussed above, and as recognized by the
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`Board, Dr. Lavian provides sufficient and proper rationale for the asserted combination.
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`Accordingly, the conclusions of obviousness are not based on impermissible hindsight.
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`G.
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`PO’s Response Includes Numerous Moot Points
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`PO raises several moot points that are irrelevant to the Board’s Decision. For
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`instance, PO argues references on which the Inter Partes Review was not instituted,
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`including Bonshihara and Heggie. POR, pp. 9 and 11; Decision, p. 34. Accordingly,
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`Petitioner need not discuss these references. Further, PO argues the application of Kogane
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`to claims 1 and 18. POR, pp. 10 and 11. However, Petitioner did not apply and the Inter
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`Partes Review was not instituted applying Kogane to these claims. Accordingly, Petitioner
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`will not discuss the application of Kogane to independent claims 1 and 18.
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`CONCLUSION
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`For at least the foregoing reasons, Mobotix respectfully requests that the Board
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`maintain the preliminary positions reached in the Decision and issue a final decision
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`cancelling claims 1-25 and 32-34 of the ‘183 patent.
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`16
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`Respectfully submitted,
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`SLATER & MATSIL, L.L.P.
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`/Steven H. Slater/
`Steven H. Slater
`Reg. No. 35,361
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`/Michael Kucher/
`Michael Kucher
`Reg. No. 69,114
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`2014-03-28
`Date
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`2014-03-28
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`Date
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`Slater & Matsil, L.L.P.
`17950 Preston Rd.
`Suite 1000
`Dallas, TX 75252
`972-732-1001
`972-732-9218 (fax)
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`17
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`CERTIFICATE OF SERVICE ON PATENT OWNER
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on March 28, 2013, a
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`complete and entire copy of Petitioner’s Reply to Patent Owner’s Response was provided
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`via electronic mail to the Patent Owner by serving the correspondence email address of
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`record as follows:
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`Robert C. Curfiss
`19826 Sundance drive
`Houston, TX 77345
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`Email: bob@curfiss.com
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`Respectfully submitted,
`SLATER & MATSIL, L.L.P.
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`/Michael Kucher/
`Michael Kucher
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`2014-03-28
`Date
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`Slater & Matsil, L.L.P.
`17950 Preston Rd.
`Suite 1000
`Dallas, TX 75252
`972-732-1001
`972-732-9218 (fax)
`
`
`
`
`18
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