UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`RICOH AMERICAS CORPORATION
`XEROX CORPORATION
`Petitioners
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`v.
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`MPHJ TECHNOLOGY INVESTMENTS LLC
`Patent Owner
`____________________
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`Case IPR2013-00302
`Patent No. 7,986,426 B1
`____________________
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`PETITIONERS’ REQUEST FOR REHEARING
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`RICOH AMERICAS CORPORATION
`XEROX CORPORATION
`Petitioners
`
`v.
`
`MPHJ TECHNOLOGY INVESTMENTS LLC
`Patent Owner
`____________________
`
`Case IPR2013-00302
`Patent No. 7,986,426 B1
`____________________
`
`
`PETITIONERS’ REQUEST FOR REHEARING
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`I.
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`II.
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`IPR2013-00302
`U.S. Patent No. 7,986,426 B1
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`Table of Contents
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`Relief Requested .............................................................................................. 1
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`Overview .......................................................................................................... 1
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`III.
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`Statement of Facts Relevant to Claim 6 .......................................................... 3
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`A.
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`B.
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`C.
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`Trial Institution: Petition demonstrates a reasonable likelihood that
`claim 6 is anticipated by Salgado .......................................................... 4
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`During Trial: The issue of whether Salgado discloses the “startup”
`limitation of claim 6 was never addressed by the Board or MPHJ ....... 6
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`Final Written Decision: Petitioners did not show that Salgado
`discloses the “startup” limitation of claim 6 ......................................... 7
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`IV. The Board should have found that claim 6 is unpatentable as anticipated by
`Salgado............................................................................................................. 7
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`A.
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`B.
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`The Board misapprehended the scope of the “startup” limitation. ....... 8
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`The Board overlooked Salgado’s teaching (relied in the Petition) that
`the first step – i.e., “startup” – in a process to build a document
`workflow is to read the list from “a common file … across the
`network.” ............................................................................................. 10
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`V.
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`Conclusion ..................................................................................................... 14
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`I.
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`Relief Requested
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`IPR2013-00302
`U.S. Patent No. 7,986,426 B1
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`Petitioners Ricoh Americas Corporation and Xerox Corporation (“Ricoh and
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`Xerox”) respectfully ask the Board to reconsider its Final Written Decision (paper
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`52, “Final Decision”) as to the finding that claim 6 of U.S. Patent No. 7,986,426
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`B1 (Ex. 1001, “’426 patent”) is not unpatentable over Salgado (Ex. 1005).
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`II. Overview
`Dependent claim 6, including the limitations of independent claim 5, is a
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`lengthy and convoluted claim with over 500 words and many limitations. Included
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`among those limitations is a “maintain list of available module means” that
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`requires “a list of … input, output, and process modules” to be “read on
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`startup.” The Institution Decision held that Salgado discloses the “maintain list of
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`available module means,” including the list of modules, but the Final Decision held
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`that Salgado does not disclose “said list being read on startup” (“startup
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`limitation”).
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`Yet, the Petition provided evidence that Salgado’s list of modules is read on
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`startup by explicitly directing the Board to a portion of Salgado that shows the list
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`being read on startup of a document workflow process. In the Institution Decision,
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`the Board initially agreed that the “startup limitation” is disclosed by Salgado, and
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`Patent Owner (“MPHJ”) never refuted this initial finding. In the Final Decision,
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`the Board reversed its position as to whether Salgado taught the “startup
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`limitation,” misapprehending the scope of “startup” and overlooking the Petition’s
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`explicit showing that Salgado teaches this limitation.
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`The interest of justice supports reversal of the Board’s finding relative to
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`claim 6. In the Institution Decision, the Board denied five other grounds
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`challenging the claims, including an obviousness ground based on Salgado. This
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`denial was arbitrary and denied Petitioners the opportunity to present obviousness-
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`based arguments based on Salgado, and to present other arguments relative to
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`references, such as Ohkubo (Ex. 1004), which Petitioners and Petitioners’ expert
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`explained have technical strengths over the references asserted in the other
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`grounds.
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`The Patent Owner is not prejudiced by reversal of the Board’s Final
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`Decision, as it was put on notice in the Institution Decision that Salgado discloses
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`the “startup limitation,” and chose not to refute this finding. In fact, Patent Owner
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`had at least three opportunities to raise this issue – in a Preliminary Response
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`(which it did not file), in its Patent Owner Response, and in the Oral Hearing – but
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`failed to raise it each time.
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`On the other hand, Petitioners are prejudiced by the Board’s Final Decision
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`relative to claim 6. Following the Institution Decision, Petitioners never had an
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`opportunity to present new arguments or evidence (nor did they have any notice
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`that they needed to revisit their “startup limitation” arguments) relative to Salgado
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`disclosing the “startup limitation.” Specifically, following the Institution Decision,
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`the Board never again raised an issue with respect to the “startup limitation” and
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`Salgado, and Patent Owner never refuted this point. Thus, under the inter partes
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`review rules, Petitioners were not permitted to revisit its arguments.1
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`For at least these reasons, Petitioners respectfully request that the Board
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`grant this Request and find claim 6 unpatentable.
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`III. Statement of Facts Relevant to Claim 6
`Ricoh and Xerox petitioned (paper 1, “Pet.”) the Board seeking Inter Partes
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`Review of the ’426 patent on the following grounds:
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`Ground 35 USC
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`Index of Reference(s)
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`Claims
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`1
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`2
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`3
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`4
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`5
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`102(b)
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`XNS (inherent features evidenced by GIS 150)
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`1-11
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`102(b)
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`Ohkubo
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`102(e)
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`Salgado
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`102(a)/(e) Harkins
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`1-11
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`1-11
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`1-11
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`103(a)
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`Ohkubo in view of APA
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`3, 5-9, 11
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`1 A petitioner’s reply may only respond to arguments raised in the
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`corresponding opposition. 37 C.F.R. § 42.23. During oral hearing “no new
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`evidence or arguments may be presented at the oral argument.” Office Patent Trial
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`Practice Guide, 77 Fed. Reg. 48,756, 48,768 (Aug. 14, 2012).
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`103(a)
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`Salgado in view of APA
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`103(a)
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`Harkins in view of Motoyama
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`6
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`7
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`Pet. 10.
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`3, 5-9, 11
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`1-8
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`MPHJ did not file a Preliminary Response to rebut the grounds asserted in
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`the Petition. Institution Decision (paper 8, “Inst. Decision”) 2.
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`A. Trial Institution: Petition demonstrates a reasonable likelihood
`that claim 6 is anticipated by Salgado
`The Board instituted review of grounds 1 and 3, finding, inter alia, that the
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`Petition demonstrated a reasonable likelihood that Salgado anticipates claim 6.
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`Inst. Decision 36. Claim 6 is lengthy and convoluted. Including the limitations that
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`claim 6 inherits from independent claim 5, it includes over 500 words and spans
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`more than a column of the issued patent. ’426 patent 86:1-87:4. Despite all those
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`words, the Board found that claim 6 requires nothing more than “standard
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`document management features.” Inst. Decision 27.
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`These “standard document management features” are claimed as means-
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`plus-function limitations, ’426 patent 86:53-87:4, and include a “maintain list of
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`available module means for maintaining a registry containing a list of said input,
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`output, and process modules that can be used in said computer data management
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`system.” Id. at 86:56-59. The “maintain list of available module means” of claim 6
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`requires “said list [to be] read on startup.” Id. at 86:56-59 (“startup limitation”).
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`The Board found that the “‘maintain list of available module means’ corresponds
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`to a generic listing algorithm and memory that stores, or points to, a list of
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`modules.” Inst. Decision 22.
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`The Board also found that Salgado discloses this “generic listing algorithm”:
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`“[the] ‘list of available modules means’ reads on Salgado’s relational database and
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`a common file, which stores profiles and metaphor elements (i.e., the applicable
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`information for each device and process module available) – the relational database
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`and storage file each constitute a ‘list.’” Id. at 34. And finding that Salgado teaches
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`all the other “standard document management” limitations required by claim 6, the
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`Board instituted review of ground 3. Id. at 33-34, 36.
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`However, the Board did not institute review of grounds 2 and 4-7. Inst.
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`Decision 36. It found them “redundant in light of the determination that there is a
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`reasonable likelihood that the challenged claims are unpatentable based on” the
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`instituted grounds. Id. at 35. Petitioners a priori attempted to avoid this type of
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`redundancy-based denial of the grounds, arguing that each reference was
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`particularly relevant for addressing an aspect of claims of the ’426 patent. Pet. 9-
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`14, 24, 33, 42, 56; see also Ex. 1008 (“Melen Decl.”) ¶¶ 83-87.
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`Regarding grounds 2 and 5, the Petition stated that “Ohkubo is not merely
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`cumulative and is particularly relevant for describing how networked machines can
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`interact in a manner that is transparent to an end user.” Id. at 24. The Petition relied
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`on Ohkubo’s disclosure of a “scanner table [being] ‘transferred to a predetermined
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`area of the RAM 23 when the image processor 20 is activated’” to address the
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`“startup” limitation of claim 6. Pet. 29, 31 (emphasis added). And in ground 6, the
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`Petition applied Salgado under § 103, asserting that claim 6 is obvious over
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`Salgado in view of the ’426 patent’s admitted prior art (“APA”). Nonetheless, the
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`Board denied review of grounds 2, 5, and 6, finding Ohkubo and the Salgado/APA
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`combination to be redundant with XNS and Salgado. Inst. Decision 35-36.
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`B. During Trial: The issue of whether Salgado discloses the
`“startup” limitation of claim 6 was never addressed by the Board
`or MPHJ
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`The “maintain list of available module means” of claim 6 requires the
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`“startup” limitation – “said list being read on startup.” ’426 patent, 86:56-59. The
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`issue of whether Salgado discloses the “startup” limitation was never addressed
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`during trial. MPHJ was silent on this issue. In its Substitute Patent Owner
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`Response (paper 30, “PO Resp.”), MPHJ argued that Salgado fails to disclose the
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`“maintain list of available module means” based on its construction of the terms
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`“module” and “application.” PO Resp. 41. But MPHJ’s arguments did not even
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`mention Salgado’s common file – which the Board held to be the list required in
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`claim 6, Inst. Decision 33 – let alone assert that Salgado’s common file is not read
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`on startup, PO Resp. 41. By contrast, MPHJ explicitly argued that XNS does not
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`anticipate a “list being read on startup.” Id. at 31.
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`Furthermore, the issue of whether Salgado discloses the “startup” limitation
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`was not discussed during the Oral Hearing (paper 51, “Hearing”). Yet again, MPHJ
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`was silent on this issue. The Board asked Petitioners to clarify which aspect of XNS
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`meets the “list of said input, output, and process modules” limitation of claim 6,
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`Hearing 15-17, 20, but never asked Petitioners to explain how Salgado discloses
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`the “startup” limitation.
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`C.
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`Final Written Decision: Petitioners did not show that Salgado
`discloses the “startup” limitation of claim 6
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`In the Final Written Decision (paper 52, “Final Decision”), the Board
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`determined that claims 1-5 and 7-11 are unpatentable. Final Decision 51. But the
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`Board reversed its preliminary finding that Salgado anticipates claim 6. Id. at 49.
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`The Board unexpectedly held that Petitioners did “not show persuasively that
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`Salgado discloses the claimed list being read on start-up,” despite the issue never
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`arising during trial. Id. Other than this Request, Petitioners did not have reason or
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`opportunity to address the issue of whether Salgado discloses the “startup”
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`limitation after trial was instituted.
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`IV. The Board should have found that claim 6 is unpatentable as
`anticipated by Salgado.
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`In its Final Decision, the Board misapprehended the scope of the “startup”
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`limitation, applying an overly-narrow interpretation that excludes reading a list
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`upon startup of a process that uses items on the list – which is expressly disclosed
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`by Salgado. The Board also overlooked the Petition’s reliance on this express
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`disclosure of Salgado to meet the “startup” limitation. In the interest of securing a
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`just resolution to this proceeding, the Board should not disturb its initial-unrebutted
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`finding that Salgado anticipates claim 6, especially in light of its decision to deny
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`instituting trial on the Ohkubo and obviousness-based Salgado grounds.
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`A. The Board misapprehended the scope of the “startup” limitation.
`Claim 6 requires, “maintain list of available module means for maintaining a
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`registry containing a list of said input, output, and process modules that can be
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`used in said computer data management system, said list being read on startup,
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`and . . . .” ’426 patent, 86:56-59 (emphasis added). The Board recognized that
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`claim 6 recites nothing more than “standard document management features,” Inst.
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`Decision 27, and found that “the ‘maintain list of available module means’
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`corresponds to a generic listing algorithm and memory that stores, or points to a
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`list of modules,” Id. at 22.
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`This generic listing algorithm of claim 6 requires “said list being read on
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`startup,” but does not specify a specific a system, component, process, etc. that the
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`term “startup” modifies. Cf. ’426 patent 86:53-55 (“enable virtual copy operation
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`means for initiating, canceling, and resetting said computer data management
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`system”). Applying the broadest reasonable interpretation (“BRI”), the term
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`“startup” may apply to the computer data management system, but it may also
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`apply to a process that uses a module from the list or the “startup” of some other
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`system, component, process, etc. – its scope is broad.
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`Petitioners believe that the Board misapprehended the scope of the term
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`“startup” because it was misled by MPHJ’s argument that XNS does not disclose
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`the “startup” limitation. See Final Decision 43 (quoting PO Resp. 31). There,
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`MPHJ argued that XNS does not disclose the “startup” limitation because “XNS
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`states that before a user can use the clearinghouse, the ‘user must first locate a
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`clearinghouse server.’ This suggests that the clearinghouse [server] is used on
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`demand. This is the opposite of reading a list upon startup.” Id. (internal citations
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`omitted).
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`Like other arguments that MPHJ has made throughout this proceeding, this
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`argument is not clear and is not commensurate in scope with the limitation it
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`addresses. See Final Decision 28 (“Mr. Weadock’s challenge, like Patent Owner’s,
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`is not commensurate in scope with claim 1”), 36 (“[Patent Owner’s] arguments are
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`not commensurate in scope with claim 5”), 39 (“[Patent Owner’s] arguments are
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`not clear or not commensurate in scope with claim 5.”). MPHJ’s argument implies
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`that the term “startup” applies to a specific system or component, which – under
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`the BRI – it does not. Petitioners previously explained that MPHJ’s arguments,
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`such as this argument, are without merit, Petitioner’s Reply to PO Resp. 14-15
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`(Paper 39; “Reply to PO Resp.”), and maintain that position.
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`Petitioners respectfully request that the Board reconsider the scope of the
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`“startup” limitation, and find that it encompasses reading a list upon startup of a
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`process that uses items on the list – which is expressly disclosed by Salgado.
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`B.
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`The Board overlooked Salgado’s teaching (relied in the Petition)
`that the first step – i.e., “startup” – in a process to build a
`document workflow is to read the list from “a common file …
`across the network.”
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`The Petition relied on Salgado at column 16, lines 58-67 to address the
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`“startup” limitation. Pet. 38 (citing to the claim chart for element 10.2a-b), 40.
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`This teaching of Salgado describes the first two steps in the process to build a
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`document workflow that is illustrated in FIG. 8 of Salgado:
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`Referring now to FIG. 8, at steps 170, 172, one or more profiles are
`mapped to one or more metaphor elements, respectively. In one
`example, the metaphor elements are conventional pictograms mapped
`with the profiles in a known manner[]. In one application of the Xerox
`6085 workstation, a profile of print attributes is mapped to a printer
`icon. In one embodiment, the user is provided with a selection from a
`plurality of metaphor elements. These may be provided by way of a
`common file which is accessible to users across the network.
`Salgado 16:58-67 (emphasis added).
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`Step 170, the very first step of FIG. 8, teaches: “provide client with
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`metaphor elements.” Id. at 16:58, FIG. 8. These metaphor elements “may be
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`provided by way of a common file which is accessible to users across the
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`network.” Id. at 16:65-67; see Pet. 40 (quoting Salgado and underlying the term
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`“common file”). And in the Institution Decision, the Board found that Salgado’s
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`common file is or includes a list: “[The] ‘list of available modules means’ reads on
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`Salgado’s relational database and a common file, which stores profiles and
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`metaphor elements (i.e., the applicable information for each device and process
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`module available) – the relational database and storage file each constitute a ‘list.’”
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`Institution Decision 34.
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`Thus, in the very first step of the process illustrated in FIG. 8 of Salgado –
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`i.e., on “startup” of the process to build a document workflow – metaphor elements
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`are read from a list, which meets the “startup” limitation of claim 6. Petitioners
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`believe that MPHJ’s unrelated arguments about XNS led the Board to overlook
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`this express teaching in Salgado that was presented in the Petition. Nevertheless,
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`the Petition demonstrates that Salgado discloses the “startup” limitation.
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`And MPHJ never rebutted the Petition’s position that Salgado discloses the
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`“startup” limitation. PO Resp. 41 (omitting the “startup” limitation when
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`addressing Salgado); cf. id. at 31 (expressly addressing the “startup” limitation
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`when addressing XNS). Nor did MPHJ rebut the Institution Decision’s similar
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`finding. Id. at 41; see Institution Decision 33-34. The Final Decision’s only support
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`for its adverse holding was that MPHJ “generally” asserted that Salgado does not
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`disclose the list required by claim 6. Final Decision 49 (emphasis added).
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`But to be clear, MPHJ never argued that Salgado fails to disclose the
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`“startup” limitation. The “general” argument that the Final Decision referred to
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`was merely an extension of MPHJ’s flawed claim construction arguments, not a
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`counter to the Petition’s position that Salgado discloses the “startup” limitation. PO
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`Resp. 41 (arguing that the claimed modules must be part of the same software
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`application). MPHJ’s argument did not even mention Salgado’s “common file,”
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`which the Board found to be a list. Id. And Petitioners fully responded to MPHJ’s
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`flawed claim construction arguments. Reply to PO Resp. 14 (MPHJ’s arguments in
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`its PO Resp. “hinge[d] on its narrow construction of the terms ‘application’ and
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`‘module’”).
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`Petitioners have demonstrated that claim 6 is unpatentable. Claim 6 depends
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`on independent claim 5. ’426 patent 86:51-52. MPHJ “acknowledged that the XNS
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`Manual or Salgado disclose the claimed functions with respect to claims 1-5”
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`during the oral hearing. Final Decision 18 (emphasis added). Since the Petition
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`demonstrated that Salgado discloses the “startup” limitation, and MPHJ did not
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`rebut the Institution Decision’s findings with respect to the other limitations of
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`claim 6, see PO Resp. 41; Institution Decision 33-34, the record supports granting
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`this Request and canceling claim 6.
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`Moreover, the Board is charged with securing a “just, speedy, and
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`inexpensive resolution to every proceeding.” 37 C.F.R. § 42.1(c) (emphasis
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`added). In this proceeding, Petitioners relied on the Board’s initial determination
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`that Salgado anticipates claim 6, and never had reason or opportunity to address
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`whether Salgado discloses the “startup” limitation after trial was instituted. MPHJ
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`did not rebut the Petition or the Board on this issue, and it wasn’t raised at the
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`Hearing – thus, there is no reason to disturb the Board’s initial findings. But the
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`Board did reverse course on claim 6 and Salgado, unduly prejudicing Petitioners.
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`Compounding this prejudice, Petitioners were deprived review of other
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`highly-relevant grounds in the Petition that also show that claim 6 is unpatentable
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`when the Board arbitrarily denied grounds 2 and 4-7 as redundant. In grounds 2
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`and 5, the Petition quoted Ohkubo’s express disclosure of a “scanner table [being]
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`‘transferred to a predetermined area of the RAM 23 when the image processor 20
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`is activated’” to address the “startup” limitation of claim 6. Pet. 29, 31, 52
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`(emphasis added). The Board’s finding that Ohkubo’s clear and unambiguous
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`teaching of reading a list on startup is redundant with Salgado, Inst. Decision 35-
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`36, cannot be reconciled with its finding that Salgado fails to disclose the “startup”
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`limitation of claim 6, Final Decision 49.
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`In ground 6, the Petition asserted that claim 6 is obvious over Salgado. Pet.
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`54-55. The Board found ground 6 to be redundant with anticipation-based grounds,
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`Inst. Decision 35-36, even though anticipation and obviousness are different legal
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`standards, 35 U.S.C. §§ 102-03. And Petitioners were deprived of the opportunity
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`to show that the “standard document management features” of claim 6, Inst.
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`Decision 27 (emphasis added), are obvious in light of Salgado’s teachings.
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`Petitioners respectfully request that the Board grant this Request and find
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`claim 6 to be unpatentable because the Petition demonstrated that Salgado
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`discloses the “startup” limitation and it would be prejudicial to Petitioners to find
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`otherwise.
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`V.
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`Conclusion
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`For these reasons, Ricoh and Xerox respectfully request that the Board grant
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`this Request and find claim 6 of the ’426 patent to be unpatentable.
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`Respectfully submitted,
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`STERNE, KESSLER, GOLDSTEIN & Fox P.L.L.C.
`
`//§V‘V(..¢”"Z2
`
`Michael D. Specht (Reg. No. 54,463)
`Richard M. Bemben (Reg. No. 68,658)
`Counselfor Petitioners, Ricoh and Xerox
`
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`Date: December 19 2014
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`1 100 New York Avenue, N.W.
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`Washington, D.C. 20005-3934
`(202) 371-2600
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`-14-
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`
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`CERTIFICATION OF SERVICE
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`As required by 37 C.F.R. §§ 42.6(e) and 42.205(a)), the undersigned hereby
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`certifies that the foregoing PETITIONERS’ REQUEST FOR REHEARING
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`was served on December 19, 2014, in its entirety Via email on the following:
`
`Vivek Ganti
`
`HILL, KERTSCHER & WHARTON, LLP
`vg@hkw-law.com
`
`Scott A. Horstemeyer
`THOMAS | HORSTEMYER, LLP
`scott.horstemeyer@,thomashorstemeyer.com
`
`N. Andrew Crain
`
`THOMAS | HORSTEMYER, LLP
`andrew.crain@thomashorstemeyer.com
`
`Steven G. Hill (admitted pro hac vice)
`HILL, KERTSCHER & WHARTON, LLP
`sgh@hkw—law.com
`
`STERNE, KESSLER, GOLDSTEIN & Fox P.L.L.C.
`
`By‘ Z.,.'/tuba "*-Q. L:
`
`Richard M. Bemben (Reg. No. 68,658)
`Counselfor Petitioners, Ricoh and Xerox
`
`
`Date: December 19 2014
`
`1100 New York Avenue, N.W.
`
`Washington, D.C.20005—3934
`(202) 3 71-2600
`1944904_2.DOCX
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