Paper No. 46
` Entered: November 7, 2014
`
`Trials@uspto.gov
`571-272-7822
`
`
` 1 RECORD OF ORAL HEARING
` 2 UNITED STATES PATENT AND TRADEMARK OFFICE
` 3 - - - - - -
` 4 BEFORE THE PATENT TRIAL AND APPEAL BOARD
` 5 - - - - - -
` 6 HAYWARD INDUSTRIES, INC.,
` 7 Petitioner,
` 8 vs.
` 9 PENTAIR WATER POOL AND SPA, INC.,
` 10 Patent Owner.
` 11 - - - - - -
` 12 Cases IPR2013-00285 and IPR2013-00287
` 13 Patent Nos. 8,019,479 B2 and 7,704,051 B2
` 14 Application Nos. 11/286,888 and 11/981,665
` 15 Technology Centers 2100 and 3700
` 16 - - - - - -
` 17 Oral Hearing Held: August 15, 2014
` 18
` 19 Before BRIAN McNAMARA, STEPHEN SIU, and
` 20 JAMES ARPIN (Video Video Conference), Administrative Patent Judges.
`
`
` 21 The above-entitled matter came on for hearing on
` 22 Friday, August 15, 2014 at the U.S. Patent and Trademark
` 23 Office, 600 Dulany Street, Alexandria, Virginia in Courtroom
` 24 A at 1:00 p.m.
` 25
`
`
`
`
`
` Entered: November 7, 2014
`
`Trials@uspto.gov
`571-272-7822
`
`
` 1 RECORD OF ORAL HEARING
` 2 UNITED STATES PATENT AND TRADEMARK OFFICE
` 3 - - - - - -
` 4 BEFORE THE PATENT TRIAL AND APPEAL BOARD
` 5 - - - - - -
` 6 HAYWARD INDUSTRIES, INC.,
` 7 Petitioner,
` 8 vs.
` 9 PENTAIR WATER POOL AND SPA, INC.,
` 10 Patent Owner.
` 11 - - - - - -
` 12 Cases IPR2013-00285 and IPR2013-00287
` 13 Patent Nos. 8,019,479 B2 and 7,704,051 B2
` 14 Application Nos. 11/286,888 and 11/981,665
` 15 Technology Centers 2100 and 3700
` 16 - - - - - -
` 17 Oral Hearing Held: August 15, 2014
` 18
` 19 Before BRIAN McNAMARA, STEPHEN SIU, and
` 20 JAMES ARPIN (Video Video Conference), Administrative Patent Judges.
`
`
` 21 The above-entitled matter came on for hearing on
` 22 Friday, August 15, 2014 at the U.S. Patent and Trademark
` 23 Office, 600 Dulany Street, Alexandria, Virginia in Courtroom
` 24 A at 1:00 p.m.
` 25
`
`
`
`
`
`
` 1 APPEARANCES:
` 2 ON BEHALF OF THE PETITIONER:
` 3 STEVEN E. HALPERN, ESQ.
` 4 SCOTT S. CHRISTIE, ESQ.
` 5 MARK E. NIKOLSKY, ESQ.
` 6 McCarter & English
` 7 Four Gateway Center
` 8 100 Mulberry Street
` 9 Newark, New Jersey 07102
` 10 973-848-5388
` 11
` 12 ON BEHALF OF THE PATENT OWNER:
` 13 CHRISTOPHER J. FAHY, ESQ.
` 14 Quarles & Brady LLP
` 15 300 North LaSalle Street, Suite 4000
` 16 Chicago, Illinois 60654-3422
` 17 312-715-5107
` 18
` 19 RAYE L. DAUGHERTY, ESQ.
` 20 JOEL A. AUSTIN, ESQ.
` 21 Quarles & Brady LLP
` 22 411 East Wisconsin Avenue, Suite 2400
` 23 Milwaukee, Wisconsin 53202
` 24 414-277-5779
` 25
`
` 2
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos. 8,019,479 B2 and 7,704,051 B2
`
` 1 P R O C E E D I N G S
` 2 (1:00 p.m.)
` 3 JUDGE McNAMARA: Please be seated.
` 4 Okay. Good afternoon, everyone. This is the oral
` 5 argument in case IPR 2013-00285 and 2013-00287. I'm Judge
` 6 McNamara. We have Judge Siu, and I want to remind everyone
` 7 that Judge Arpin is in our office in Denver, so please make
` 8 sure that you clearly identify exhibits that you are
` 9 reviewing or displaying, that sort of thing. He can see to
` 10 some extent, but we want to make sure everybody gets a
` 11 complete -- he gets a complete view of everything.
` 12 Could I have the counsel for the Petitioner please
` 13 introduce themselves.
` 14 MR. HALPERN: Your Honor, my name is Steve
` 15 Halpern. I am lead counsel for Petitioner, Hayward
` 16 Industries, who is here with us today. And this is backup
` 17 counsel, Mark Nikolsky and Scott Christie.
` 18 JUDGE McNAMARA: Okay, great. For the Patent
` 19 Owner?
` 20 MR. FAHY: Good afternoon, Your Honor, Christopher
` 21 Fahy for Patent Owner. Along with me are lead counsel, Raye
` 22 Daugherty and backup counsel, Joel Austin.
` 23 JUDGE McNAMARA: Welcome to the Trial and Appeal
` 24 Board. Each party will have 60 minutes of total argument
` 25 time. So we will hear first from the Petitioner. During
`
` 3
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos. 8,019,479 B2 and 7,704,051 B2
`
` 1 that first presentation, the Petitioner will present its case
` 2 with respect to the challenged claims and its arguments in
` 3 support of its motion to exclude.
` 4 Then we will hear from the Patent Owner, who will
` 5 present its opposition to the petitions, its opposition to
` 6 Petitioner's motion to exclude, and then its own case with
` 7 respect to its own motion to exclude. And then finally we
` 8 will hear the Petitioner's rebuttal to the Patent Owner's
` 9 oppositions and the Patent Owner -- and the Petitioner's
` 10 opposition to the Petitioner's -- to the Patent Owner's
` 11 motion to exclude.
` 12 And we will not hear rebuttals on the motion to
` 13 exclude. So let's begin with the Petitioner. Is there any
` 14 amount of time you want me to alert you to?
` 15 MR. HALPERN: We're going to reserve 20 minutes
` 16 for rebuttal, please.
` 17 JUDGE McNAMARA: Okay. Any time you are ready.
` 18 MR. HALPERN: If it please the Board, we're going
` 19 to begin with U.S. Patent Number 7,704,051, which is the
` 20 subject of the 287 proceeding. The slides we're going to be
` 21 referencing is Hayward's Demonstrative 1063.
` 22 What we're going to talk about here today is the
` 23 authorized ground of rejection, which is Struthers and the TI
` 24 DSP Motor Solutions Guide. We respectfully submit that each
` 25 and every feature that's recited by the claim at issue here
`
` 4
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos. 8,019,479 B2 and 7,704,051 B2
`
` 1 is disclosed by the references, that it is appropriate to
` 2 consider the teachings of the references together.
` 3 As a preliminary note, before we dig into the
` 4 claim, we would note that there is this language "at least
` 5 one of" in the claim. And in the Patent Office in this
` 6 proceeding, that is understood to mean the word "or" such
` 7 that if the prior art combination teaches minimum non-zero
` 8 flow speed but not gain value of the motor, the claim can be
` 9 obviated and vice versa is the case.
` 10 So I am going to turn to slide number 4. I would
` 11 first point out that this claim recites structure, and it
` 12 recites functionality. The structure that we see is a
` 13 digital signal processor, and we see a microcontroller.
` 14 And in the specification of the '051 patent, it is
` 15 disclosed that the exemplary digital signal processor would
` 16 be that of Texas Instruments. That's in the C-240 family.
` 17 And the PIC microchip could be used as the microcontroller.
` 18 This is something that we're going to return to
` 19 later on in the discussion, when we get to the level of skill
` 20 in the art in understanding and viewing the authorized
` 21 references, which of course are Struthers and the manual that
` 22 relates to this chip.
` 23 Turning to slide 5, I would note the claim recites
` 24 five functions in addition to the function that the
` 25 microcontroller and the DSP talk to one another. We see that
`
` 5
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos. 8,019,479 B2 and 7,704,051 B2
`
` 1 the digital signal processor performs self-calibration, limp
` 2 mode, and fault detection. We can see that the
` 3 microcontroller has sensor inputs and serial communications
` 4 with a user interface device.
` 5 And continuing with the discussion of the
` 6 structure, turning to slide number 6, we can see in Struthers
` 7 figure 2, a two-chip topography, which is a microprocessor 24
` 8 and control board 22, which has a microcontroller. In an
` 9 unauthorized ground of rejection, we proposed that this
` 10 microprocessor is a digital signal processor that was not
` 11 authorized.
` 12 In this ground of rejection, it is this
` 13 microprocessor 24 which we're proposing one of ordinary skill
` 14 in the art would use in the DSP of the digital signal
` 15 processing guide 1011 from Texas Instruments.
` 16 We can see the two chips are communicating with
` 17 one another. And if we turn to slide number 7, we can see
` 18 the Texas Instruments' digital signal processor Motor
` 19 Solutions Guide talks about the DSP. It is optimized for
` 20 digital motor control. And it has control algorithm
` 21 processing, system monitoring functions. And much like the
` 22 two-chip topography that is shown in Struthers, it can
` 23 communicate with an external microcontroller. That's
` 24 underlined in red.
` 25 So we see the same two-chip topography in
`
` 6
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos. 8,019,479 B2 and 7,704,051 B2
`
` 1 Struthers and as disclosed by the TI DSP manual. And, again,
` 2 it is the microprocessor 24 of Struthers that we're proposing
` 3 one would provide the DSP, the Texas Instruments DSP, the
` 4 same one described in the specification.
` 5 Now, before we jump in on a function-by-function
` 6 basis, I would reference what is from the specification of
` 7 Struthers where it talks about the control board and the
` 8 microprocessor. And, again, control board 22 is the
` 9 reference to the microcontroller. Control board 22 is the
` 10 PCB with the microcontroller. And they can talk to each
` 11 other. And it is understood that the functions that are
` 12 disclosed in Struthers can be assigned to one, the other, or
` 13 them both. And that's explicitly taught by Struthers.
` 14 Now, above and above that, Struthers has
` 15 additional teachings. So we're going to turn to slide number
` 16 9. And we're going to look specifically at the
` 17 microcontroller and the features recited by claim 1 to be
` 18 associated with the microcontroller.
` 19 First, claim 1 recites, there is a sensor input
` 20 associated with the microcontroller. We can see that in
` 21 level sensor 70. And there are other sensors that have been
` 22 discussed in the papers, including --
` 23 JUDGE ARPIN: Counsellor, Counsellor, with regard
` 24 to your slide 8, I see where it says that the functions can
` 25 be assigned to either the microprocessor or the control
`
` 7
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos. 8,019,479 B2 and 7,704,051 B2
`
` 1 board. Are you suggesting that this is just a matter of
` 2 design choice or are you suggesting that there is some reason
` 3 or there has to be some reason why a person of ordinary skill
` 4 in the art would assign them as they are recited in the
` 5 claim?
` 6 MR. HALPERN: Well, we respectfully submit that
` 7 the division of labor that's recited in the claim is
` 8 consistent with what a person of ordinary skill in the art
` 9 understands the typical functions of those chips to be.
` 10 As discussed in the Emadi declaration, 1010,
` 11 paragraphs 21 through 45, the three functionalities that are
` 12 associated with the digital signal processor are typically
` 13 known by those of ordinary skill in the art to be the
` 14 functions that would be performed by a digital signal
` 15 processor.
` 16 Similarly, with the microcontroller, things like
` 17 serial communications and sensor inputs, people of ordinary
` 18 skill in the art understand that those functionalities would
` 19 be associated with a microcontroller.
` 20 Your Honor, if it is a ladder, the people know a
` 21 function is to climb it.
` 22 JUDGE ARPIN: But does that mean that if you have
` 23 functions, as you say, that are commonly assigned to a
` 24 digital signal processor or functions that a person of
` 25 ordinary skill in the art would understand are commonly
`
` 8
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos. 8,019,479 B2 and 7,704,051 B2
`
` 1 assigned to a microcontroller, that it would be within the
` 2 skill or that there is some suggestion that a person would
` 3 mix and match those?
` 4 MR. HALPERN: I think it is within the skill, that
` 5 they, they would present the functions and assign the
` 6 division of labor, exactly how it is recited. Further than
` 7 that, furthermore, I think that the Struthers reference
` 8 additionally goes beyond. And when it talks about the
` 9 microcontroller, it explicitly allocates the microcontroller
` 10 functions to the microcontroller.
` 11 And above and beyond that, the Texas Instruments
` 12 manual itself discusses the functionality of a DSP, which is
` 13 the control algorithms and the monitoring. And as we will
` 14 get to later, the function of self-calibration, which refers
` 15 to itself self-calibrating, there is disclosure in Struthers
` 16 that it is the microprocessor that is actually doing that.
` 17 And there is disclosure in the Texas Instruments' manual that
` 18 it is the Texas Instruments' DSP that is actually doing that.
` 19 And we --
` 20 JUDGE ARPIN: Please continue.
` 21 MR. HALPERN: Thank you. So on slide 9, we see
` 22 that the sensor inputs are associated with the
` 23 microcontroller, as is the programming interface, which is on
` 24 a bus, which at column 3, lines 61 through 63 of Struthers is
` 25 a serial bus.
`
` 9
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos. 8,019,479 B2 and 7,704,051 B2
`
` 1 Additionally, on slide 10 -- and this is discussed
` 2 further in our papers -- fault detection is very clearly
` 3 disclosed by Struthers and performed by the controller 22,
` 4 24, including the microprocessor 24.
` 5 Turning to slide 11, we're now talking about the
` 6 limp mode function. And I think there has been a lot more in
` 7 the papers about limp mode than there has needed to be. I
` 8 think the Board in the previous appeal from the parent case
` 9 adopted a construction of limp mode that is a good
` 10 construction.
` 11 I think the examiner has found that Struthers
` 12 discloses a limp mode. And I think that's a good finding.
` 13 And I think that their expert in the copending litigation
` 14 said that Struthers disclosed the limp mode and then changed
` 15 his views and gave a different position to this Board in the
` 16 papers.
` 17 Now, I think that what is important here is not
` 18 all that -- as my father would say "chazzerei" -- what is
` 19 important is what the specification says. So I think there
` 20 has been too much discussion about that. And I notice they
` 21 have no slides on limp mode today. Nevertheless, let's talk
` 22 about the specification, which is what's important.
` 23 And in slide number 11, on the left side there is
` 24 a passage, page 19, comes out of the Institution Decision.
` 25 And at the bottom, the Board cited column 2 of the patent at
`
` 10
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos. 8,019,479 B2 and 7,704,051 B2
`
` 1 issue. And that was, respectfully, that was insightful
` 2 because that column 2 says the limp mode includes reducing
` 3 output voltage and/or operating frequency.
` 4 Why is that important? As we're going to discuss,
` 5 operating frequency in this context is speed and/or is
` 6 disjunctive. It doesn't require both. And we see this again
` 7 turning to slide 12, in column 18. One or both of the output
` 8 voltage are reduced. And then in the parens, e.g., reducing
` 9 both along this curve.
` 10 Now, we discussed this with Professor Collins. In
` 11 his deposition he admitted that this is a disjunctive test,
` 12 not a conjunctive requirement that you have both. Although
` 13 if you look in his declaration, he cites the conjunctive.
` 14 And he doesn't explicitly articulate in his declaration that
` 15 what the spec says is one or both, and/or.
` 16 Now, again, why is this important? Because
` 17 Struthers, as stated by their expert, Struthers may actually
` 18 say that it is reducing speed but it is synonymous with
` 19 frequency. So I am not going to spend too much on this, but
` 20 what is this example of figure 13?
` 21 In the constant torque system, it is not unusual
` 22 for you to reduce output voltage and the frequency, such that
` 23 you have a constant ratio. And you can see that the slope of
` 24 that line stayed the same. But that's for a constant torque
` 25 system. And that's an example.
`
` 11
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos. 8,019,479 B2 and 7,704,051 B2
`
` 1 And there is nothing in the claim that says this
` 2 is limited to a constant torque system. And discussed this
` 3 with the professor in the deposition, and we're citing the
` 4 claim language. And he says, there is nothing in this claim
` 5 to limit it to a constant torque system. A constant torque
` 6 system is an example, e.g.
` 7 So I am going to turn to slide number 14 about the
` 8 limp mode. So we know that the limp mode is this reduction
` 9 of speed, but we also know the limp mode has a trigger. And
` 10 this trigger is something that we discussed with the
` 11 professor in his deposition.
` 12 And the example triggers can be seen in figure 4
` 13 from the patent, which is if your current is out of range,
` 14 certain currents are out of range, certain voltages are out
` 15 of range, certain heat sink temperatures. Well, we asked
` 16 what is a trigger? What could be a trigger for a limp mode?
` 17 And the professor tells us: Well, it depends on the design.
` 18 It depends what you want your trigger to be.
` 19 And in Struthers, the trigger is excessively high
` 20 torque. And we see the additional parallel to Struthers
` 21 there.
` 22 Now, turning to slide number 15, you know, the
` 23 paramount importance, of course, is on the specification.
` 24 What we're looking at here is the file history. In the
` 25 appeal brief in the parent case, there is that section of the
`
` 12
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos. 8,019,479 B2 and 7,704,051 B2
`
` 1 appeal brief where you have to put the parentheticals for the
` 2 support for the claim. So what you are looking at here is a
` 3 claim element.
` 4 And I have highlighted part of it in blue and
` 5 green and red. And the analogy I would like to make is that
` 6 this blue is a limp mode. This green is an example trigger
` 7 of a limp mode. And the red is the purpose.
` 8 Now, just like -- and, again, this is somewhat
` 9 representative of how the Patent Owner regards the subject
` 10 matter of the specification, same specification. It is an
` 11 omnibus specification. This idea of the limp mode,
` 12 automatically reducing at least one of output voltage or
` 13 operating frequency, so that's the speed, reducing the speed.
` 14 Here is an example trigger, if the current is out
` 15 of range. In Struthers, the trigger is the torque. It is
` 16 excessively high. The purpose: Well, in their papers they
` 17 say that Struthers and, and the '051 patent are completely
` 18 different purposes. Now keep in mind this is the same spec,
` 19 but they say in Struthers the purpose is a blockage.
` 20 What is the purpose here? An attempt to clear a
` 21 foreign object obstruction. It is not just that the claim
` 22 language and the specification of the '051 patent support the
` 23 limp mode and that it is taught by Struthers, but how the
` 24 file history reflects what the Patent Owner regards as their own
` 25 subject matter is exemplified in slide 15.
`
` 13
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos. 8,019,479 B2 and 7,704,051 B2
`
` 1 So, Your Honor, I would turn to slide 16. We're
` 2 going to get into self-calibration. Again, if the prior art
` 3 combination teaches one, but not the other, meaning minimum
` 4 non-zero flow speed versus the gain, that's sufficient in
` 5 this proceeding to invalidate this claim.
` 6 Now, there has been a lot in the papers about,
` 7 well, this is not a minimum speed and, in column 8 in
` 8 Struthers, it is a maximum speed. That's wrong. What we're
` 9 talking about in column 8 is there being a threshold flow
` 10 that the system needs.
` 11 And what you are going to do is in order to
` 12 achieve that threshold flow at the minimum speed possible,
` 13 you are going to start at a low speed. You are going to
` 14 slowly ramp it up. And when you have got that threshold
` 15 flow, finally, and you finally get there, that's your minimum
` 16 non-zero flow speed.
` 17 And I have tried to exemplify this by highlighting
` 18 text in red. This text in green, this is a speed cap. And
` 19 above and beyond whatever is going on in this first
` 20 subroutine about minimum non-zero flow speed is that at any
` 21 given point in time you just can't exceed a maximum.
` 22 So while you are proceeding through the minimum
` 23 non-zero flow speed routine, just don't make sure -- don't
` 24 exceed your ceiling. And that's what this is talking about
` 25 right here.
`
` 14
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos. 8,019,479 B2 and 7,704,051 B2
`
` 1 JUDGE ARPIN: Counsellor, are you then equating
` 2 minimum with threshold? Is that what we should understand
` 3 from your last comment?
` 4 MR. HALPERN: I think that minimum non-zero flow
` 5 speed, to any extent the word -- I think that the minimum
` 6 non-zero flow speed, you are getting the minimum speed and
` 7 you are getting the threshold flow. So I think regardless of
` 8 how the term is construed, any construction would be
` 9 disclosed.
` 10 JUDGE ARPIN: But a minimum can't be anything less
` 11 than the threshold in your analysis?
` 12 MR. HALPERN: I think so.
` 13 JUDGE ARPIN: Continue, please.
` 14 MR. HALPERN: Okay. In the paper, I am going to
` 15 turn to slide 17.
` 16 In the papers, there has been some discussion about
` 17 how a minimum non-zero flow speed requires some type of maybe
` 18 awareness by the DSP. And I believe on page 31 of the
` 19 response, there is no disclosure in Struthers that speed is
` 20 being recognized. And that's not true.
` 21 In column 5, we can see that the speed is
` 22 constantly being checked and monitored and controlled and
` 23 corrected as the speed instructions are being given to the
` 24 motor. So here we have the minimum non-zero flow speed of
` 25 the motor.
`
` 15
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos. 8,019,479 B2 and 7,704,051 B2
`
` 1 And, more specifically, a self-calibration
` 2 procedure to determine a minimum non-zero flow speed of the
` 3 motor.
` 4 Your Honor, I would turn to slide 18 to talk about
` 5 self-calibration of gain. And, actually, I would turn to
` 6 slide 20 first.
` 7 Preponderance of the evidence: There was a
` 8 tremendous amount of expert testimony from Professor Emadi in
` 9 this case about why somebody understands this Texas
` 10 Instruments document discloses a self-calibration gain value
` 11 of the motor. Painstaking detail was taken to provide the
` 12 Board with a tutorial.
` 13 And there is zero expert testimony, none, nothing,
` 14 zero from, from the Patent Owner. We couldn't even question
` 15 their expert on this subject because the questioning would
` 16 have had no nexus with the declaration that they offered. So
` 17 there was no cross-examination we had.
` 18 They didn't open the door. They didn't ask our
` 19 expert any questions. Respectfully, we submit it is because
` 20 we're right, because when you look at the Texas Instruments
` 21 Digital Signal Processor Manual and you are a person of
` 22 ordinary skill in the art, it is talking about a
` 23 self-calibration of gain. It is talking about adaptive
` 24 control.
` 25 It is talking about an algorithm, specifically a
`
` 16
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos. 8,019,479 B2 and 7,704,051 B2
`
` 1 PI algorithm that is not just changing the output in response
` 2 to the input; it is changing the algorithm itself.
` 3 And, more specifically, what that means is the
` 4 gains are changing, the proportional gain, the integral gain.
` 5 The only thing the Patent Owner has done with respect to
` 6 taking a position here is to say: Well, somebody wouldn't
` 7 necessarily understand that when they look at the manual. I
` 8 respectfully submit that there are certain things that lend
` 9 itself to expert testimony.
` 10 And there are certain things where everybody in
` 11 this room will read the expert testimony but kind of, you
` 12 know, can follow along. I think they should have had their
` 13 expert talk about this, and they didn't.
` 14 So I am just going to take a minute and talk about
` 15 it here. Slide number 18, we see in the specification that
` 16 once the minimum non-zero flow speed is obtained, it then
` 17 uses that input to then go and select the gain values, the
` 18 proportional gain and the integral gain.
` 19 We look in the file history, slide number 19. In
` 20 the parent application, there was a swear-behind affidavit
` 21 with an engineering spec that was put in. And it says the
` 22 same thing in the highlighted text. You are going to change
` 23 the gain values by looking at a lookup table.
` 24 The specification is the most important thing.
` 25 This is just the file history, but, you know what, it
`
` 17
`
`
`
`IPR2013-00285 and IPR2013-00287
`Patent Nos.
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