UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`CARDIOCOM, LLC
`Petitioner
`v.
`ROBERT BOSCH HEALTHCARE SYSTEMS, INC.
`Patent Owner
`_____________________
`CASE IPR2013-00468
`Patent No. 7,516,192
`_____________________
`
`PATENT OWNER’S MOTION TO EXCLUDE EVIDENCE
`
`
`_____________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`CARDIOCOM, LLC
`Petitioner
`v.
`ROBERT BOSCH HEALTHCARE SYSTEMS, INC.
`Patent Owner
`_____________________
`CASE IPR2013-00468
`Patent No. 7,516,192
`_____________________
`
`PATENT OWNER’S MOTION TO EXCLUDE EVIDENCE
`
`
`
`Patent Owner Robert Bosch Healthcare Systems, Inc. (“Bosch”) hereby
`
`moves the Board to exclude certain evidence submitted and relied upon by
`
`Petitioner Cardiocom, LLC (“Cardiocom”) and its expert, Dr. Robert Stone.
`
`I.
`
`Dr. Stone’s Opinions Relating To Secondary Considerations Of Non-
`Obviousness
`
`Bosch moves to exclude Dr. Stone’s opinions relating to secondary
`
`considerations of non-obviousness set forth in his reply declaration. See Ex. 1022
`
`¶¶ 61-90. Cardiocom relies on these paragraphs in its reply (Paper 52) at 4-5.
`
`Bosch objected to these paragraphs in Ex. 2071 at 9-18. These opinions should be
`
`excluded (a) because they were raised for the first time on reply, in violation of the
`
`Board’s rules of practice and (b) under Federal Rule of Evidence 702 because Dr.
`
`Stone lacks foundation to opine on secondary considerations and because he has
`
`purported to analyze secondary considerations under a flawed legal standard. In
`
`addition, Dr. Stone has offered erroneous claim constructions and selectively cited
`
`to Dr. David’s deposition while ignoring portions that contradict the inferences Dr.
`
`Stone draws, rendering his opinions unreliable under Rule 702.
`
`A.
`
`Dr. Stone’s Opinions on Secondary Considerations Were
`Improperly Raised For The First Time In Rebuttal.
`
`Dr. Stone’s opening declaration contains no testimony regarding secondary
`
`considerations. Dr. Stone admitted during deposition that he did not consider any
`
`secondary considerations in forming his original opinions. See Ex. 2069 (Stone
`
`-1 -
`
`
`
`Reply Dep.), 783:1-15, 784:15-785:3. Dr. Stone withheld his opinions until reply,
`
`depriving Bosch from an opportunity to respond to them.
`
`If Dr. Stone intended to analyze secondary considerations to support his
`
`opinion that U.S. Patent No. 7,516,192 (Ex. 1001, “the ’192 patent”) claims are
`
`obvious, he was required to have raised them in his original declaration. As the
`
`Board recently found, Cardiocom ultimately bears the initial burden of production
`
`for evidence demonstrating that the secondary considerations favor a finding of
`
`obviousness rather than non-obviousness. Gnosis S.P.A. v. South Alabama Med.
`
`Sci. Found., Case IPR2013-00116, Paper 61, at 2-3 (P.T.A.B. Mar. 12, 2014).
`
`Nor can Cardiocom credibly argue that it is simply “responding” to Bosch’s
`
`secondary considerations evidence. Having waived its opportunity to present
`
`secondary considerations evidence in its opening petition, Cardiocom does not
`
`have the right to present such evidence for the first time in rebuttal. In any event,
`
`Cardiocom bears the burden of production and ultimate burden of proof, so its
`
`rebuttals alone are deficient as a matter of law. Infra, Section B.2. Dr. Stone’s
`
`opinions must therefore be excluded. See Office Patent Trial Guide, 77 Fed. Reg.
`
`48756, 48767 (Aug. 14, 2012) (“a reply that raises a new issue or belatedly
`
`presents evidence will not be considered and may be returned”).
`
`B.
`
`Dr. Stone’s Secondary Considerations Opinions Are Unreliable
`Under Rule 702.
`
`1.
`
`Dr. Stone Is Not Qualified.
`
`-2 -
`
`
`
`Dr. Stone purports to rebut Dr. David’s expert testimony—which is
`
`supported by voluminous supporting documents—that the inventions of the ’192
`
`patent helped drive the commercial success of the Health Buddy system they were
`
`incorporated into. Dr. David testified as to the existence of at least the following
`
`commercial secondary considerations for the ’192 patent: (1) the invention’s
`
`commercial success; (2) long felt but unresolved needs; (3) praise by others; (4)
`
`teaching away by others; and (5) copying of the inventions by others. Ex. 2007
`
`¶¶ 70-110. Dr. Stone criticizes these opinions by essentially adopting arguments
`
`made by counsel during Dr. David’s deposition. See generally Ex. 1022 ¶¶ 61-90.
`
`Dr. Stone’s purported rebuttal testimony is irrelevant and unreliable expert
`
`testimony because he has no expertise in evaluating the commercial success of
`
`remote health monitoring devices. Dr. Stone’s only articulated expertise relates to
`
`technical “development” and “application programming” of various systems and
`
`devices. Dr. Stone has not identified expertise regarding the evaluation or
`
`comparison of remote health monitoring devices, any marketing expertise, or any
`
`other comparable expertise that qualifies him to testify as to commercial secondary
`
`considerations. See generally Ex. 1008 ¶¶ 1-6. Nor is any such expertise disclosed
`
`in his curriculum vitae. Ex. 1011.
`
`Dr. Stone’s lack of qualifications is confirmed by the content of his
`
`testimony. As discussed in further detail in Section I.A above, Dr. Stone declined
`
`-3 -
`
`
`
`to provide any affirmative opinions regarding secondary considerations. In
`
`addition, the form of his rebuttal testimony simply mimics counsel’s arguments
`
`and suggestive questioning during Dr. David’s deposition, rather than offering
`
`independent evidence. See generally Ex. 1022 ¶¶ 61-90.
`
`Dr. Stone’s purely technical background stands in stark contrast to Dr.
`
`David, who has a wealth of professional experience in assessing various competing
`
`commercial remote health monitoring devices available in the marketplace, which
`
`he gained in the course of his duties procuring remote health monitoring devices
`
`for the Texas Medical Center in Houston, one of the largest purchasers of remote
`
`health monitoring devices. Ex. 2007 ¶¶ 1-2; Ex. 2008; Ex. 1041, 14:14-15:1.
`
`Accordingly, Dr. Stone lacks the expert foundation to opine on whether the
`
`claims of the ’192 patent are supported by secondary considerations and should not
`
`be considered. See Rambus, Inc. v. Hynix Semiconductor, Inc., 254 F.R.D. 597,
`
`604-605 (N.D. Cal. 2008) (excluding under Rule 702 technical expert’s testimony
`
`on commercial secondary considerations issues); XpertUniverse, Inc. v. Cisco Sys.,
`
`Inc., No. 09-157-RGA, 2013 WL 865974, at *3 (D. Del. Mar. 7, 2013) (same).
`
`2.
`
`Dr. Stone Applied An Unreliable Methodology.
`
`Dr. Stone’s rebuttal methodology is deficient because: (1) Dr. Stone’s
`
`analysis is based on an unsubstantiated legal test; and (2) Dr. Stone merely
`
`attempts to rebut Dr. David rather than affirmatively identifying contrary evidence.
`
`-4 -
`
`
`
`First, Dr. Stone criticizes Dr. David for failing to provide claim charts or
`
`otherwise conducting an “element-by-element analysis” of the claims of the ’192
`
`patent against secondary considerations evidence Dr. David has marshaled. Ex.
`
`2069, 792:18-793:9; Ex. 1022 ¶ 63. Dr. Stone’s “claim chart” test for a nexus is
`
`not founded on Federal Circuit law and appears to have been invented by him.
`
`Contrary to Dr. Stone’s suggested methodology, Dr. David has properly
`
`established a nexus between the particular scripting features claimed in the ’192
`
`patent and the evidence of the Health Buddy’s commercial success. A prima facie
`
`case of nexus “is generally made out when the patentee shows both that there is
`
`commercial success, and that the thing (product or method) that is commercially
`
`successful is the invention disclosed and claimed in the patent.” Demaco Corp. v.
`
`F. Von Langsdorff Licensing, Ltd., 851 F.2d 1387, 1392 (Fed. Cir. 1988).
`
`Moreover, “[a] requirement for proof of the negative of all imaginable contributing
`
`factors would be unfairly burdensome, and contrary to the ordinary rules of
`
`evidence.” Id. at 1394. That prima facie test was met in Demaco, for example,
`
`through evidence of the admitted success of the patented invention. Id. Claim
`
`charts are not required.
`
`As Dr. Stone’s criticisms are based on a legally untenable claim chart test,
`
`they are inadmissible. See Hebert v. Lisle Corp., 99 F.3d 1109, 1117 (Fed. Cir.
`
`1996) (“We encourage exercise of the trial court’s gatekeeper authority when
`
`-5 -
`
`
`
`parties proffer, through purported experts, not only unproven science[,] but
`
`markedly incorrect law”) (citing Daubert v. Merrell Dow Pharms., Inc., 509 U.S.
`
`579 (1993)).
`
`Second, Dr. Stone’s opinion is inappropriate because it is pure rebuttal even
`
`though Cardiocom bears the burden of production of evidence regarding secondary
`
`considerations. As the Federal Circuit made clear in Demaco, it is “the task of the
`
`challenger to adduce evidence to show that the commercial success was due to
`
`extraneous factors other than the patented invention, such as advertising, superior
`
`workmanship, etc.” Demaco, 851 F.2d at 1393. “‘[A]rgument’ and ‘conjecture’
`
`are insufficient.” Id. (quoting Rosemount, Inc. v. Beckman Instruments, Inc., 727
`
`F.2d 1540, 1546 (Fed. Cir. 1984)).
`
`Dr. Stone has elected not to adduce independent evidence to rebut Dr.
`
`David’s testimony, but instead has relied on impermissible “argument” and
`
`“conjecture.” This is legally inadequate and should not be considered.
`
`3.
`
`Dr. Stone’s Characterizations of Dr. David’s Testimony are
`Unreliable.
`
`Bosch also moves to exclude several pieces of testimony from Dr. David’s
`
`deposition that Cardiocom and/or Dr. Stone rely upon in reply. In the alternative,
`
`where indicated below, the Board should consider Dr. David’s testimony on the
`
`same topic or issue under the rule of completeness under Rule of Evidence 106.
`
`1)
`
`Dr. Stone and Cardiocom rely on testimony from Dr. David to argue
`
`-6 -
`
`
`
`that there was no evidence of others copying Bosch’s claimed invention. Paper 52,
`
`6; Ex. 1022 ¶¶ 88-90. However, they completely ignore Dr. David’s later
`
`testimony on copying and have therefore distorted Dr. David’s opinions. Dr.
`
`David testified that, following the initial success of the Health Buddy in the VISN
`
`8 pilot study, the VA modeled its requirements for future remote health monitoring
`
`devices on, amongst other things, the scripting features of the ’192 patent. Ex.
`
`2007 ¶¶ 106-107. Dr. David testified that he did not have access to other vendor
`
`products that complied with the VA RFP and believed that there may be
`
`hypothetical unknown ways to comply with the RFP without infringing the ’192
`
`patent. However, Dr. David opined that, based on his 30 years of experience in the
`
`industry, the VA and other vendors seeking to gain business at the VA would be
`
`strongly incentivized to look to solutions that closely mimicked the Health Buddy
`
`system, including the claimed features of the ’192 patent. See Ex. 1041, 621:24-
`
`625:15. Thus, Dr. David confirmed that it “would make sense for a vendor to see
`
`that the VA system was using the Health Buddy issuing an RFP, [and] present the
`
`same characteristics and try to copy it, sure.” Id., 624:16-20.
`
`2)
`
`Dr. Stone relies upon Dr. David’s testimony at page 161:6-9 of Ex.
`
`1041 to suggest that Dr. David ignored the real drivers of the success of the Bosch
`
`Health Buddy. Ex. 1022 ¶ 64; Paper 52, 4. Bosch objected to this testimony in Ex.
`
`2071 at 10. This testimony from Dr. David should be excluded because it is a
`
`-7 -
`
`
`
`gross mischaracterization, and Dr. Stone’s reliance upon it renders his opinions
`
`unreliable under Federal Rule of Evidence 702. Initially, Dr. David testified that
`
`he did not understand the question from Cardiocom’s attorney that elicited the
`
`testimony Cardiocom relies upon. Ex. 1041, 161:10-17. More importantly, Dr.
`
`David actually testified the opposite of what Dr. Stone suggests, as he stated that
`
`“[w]hat was important for my declaration is that nexus you described yourself
`
`relating to claims in the patent.” Id., 160:25-161:3. Dr. David thus focused on
`
`success attributable to the claimed invention and, having satisfied himself that that
`
`nexus existed, did not attempt to analyze every other factor that could have also
`
`possibly contributed to the success. See also id., 160:2-18, 172:1-7, 621:3-15.
`
`This is consistent with case law. Demaco, 851 F.2d at 1393.
`
`II.
`
`Dr. Stone’s Opinions Relating to “Database”
`
`Bosch moves to exclude any opinions and testimony from Dr. Stone relating
`
`to the “database” claimed in the ’192 patent, including at least Paragraphs 99-104,
`
`121, 136, 142, and 215 of Dr. Stone’s reply declaration. Cardiocom relies on these
`
`paragraphs in its reply (Paper 52) at 11. Bosch objected to these paragraphs in Ex.
`
`2071 at 19-21. In reply, Dr. Stone provides for the first time an extremely broad
`
`construction of “database” in response to Bosch’s arguments that the prior art does
`
`not disclose storing script programs and responses in a database. Ex. 1022 ¶ 100.
`
`Dr. Stone relies upon this previously-undisclosed construction to argue that the
`
`-8 -
`
`
`
`prior art discloses the “database” limitations of claims 1 and 23. Id. ¶¶ 99-104,
`
`121, 136, 142, 215.
`
`There is little question that Cardiocom bore the initial burden of proffering
`
`the claim constructions that it felt the Board should consider in the validity
`
`analysis. 37 C.F.R. § 42.104(b)(3) (requiring petitioner to identify “[h]ow the
`
`challenged claim is to be construed”). These claim constructions were a predicate
`
`for the Board’s determination that an inter partes review proceeding should have
`
`been initiated. Having failed to proffer a construction for “database” at the outset
`
`of these proceedings, Cardiocom should not be permitted to sandbag Bosch by
`
`offering the new construction in reply. As a consequence of Dr. Stone’s late claim
`
`construction, Bosch and Dr. David will not have an adequate opportunity to
`
`respond to this new construction. See Office Patent Trial Guide, 77 Fed. Reg. at
`
`48767 (“a reply that raises a new issue or belatedly presents evidence will not be
`
`considered and may be returned”).
`
`In addition, Dr. Stone’s proposed construction is clearly incorrect; his
`
`opinions related to “database” are thus unreliable and irrelevant under Federal Rule
`
`of Evidence 702. See, e.g., Hochstein v. Microsoft Corp., No. 04-73071, 2009 WL
`
`2022815, at *1 (E.D. Mich. July 7, 2009) (excluding expert opinion based on
`
`clearly erroneous claim construction that conflicted with the court’s construction).
`
`Specifically, Dr. Stone opines in reply that “a database is merely an
`
`-9 -
`
`
`
`‘electronically-stored collection of data.’” Ex. 1022 ¶ 100 (citations omitted).
`
`Using this broad construction, Dr. Stone testified at his deposition that any file
`
`stored in any computer is necessarily stored in a database.
`
`Q. Okay. So anything stored on a computer is necessarily stored in a
`database in your opinion?
`A. Any files stored in a computer are stored in a database; that is
`correct.
`
`*
`*
`*
`Q. And if I misspoke before, let me -- I apologize. Let me ask the
`question so it’s clear. So the construction that you applied in forming
`your opinions with respect to the database element would mean that
`any file stored in a computer is necessarily stored on a database?
`A. Yes.
`Ex. 2069, 1129:21-1130:15.
`
`One of ordinary skill in the art would not understand the term “database” to
`
`be so broad. Under Dr. Stone’s definition, neither the data type nor the electronic
`
`storage medium bear into whether or not information has been stored in a
`
`“database.” An application executable file, such as Microsoft Word, that is
`
`installed on a computer would be contained in a “database” under Dr. Stone’s
`
`construction. Similarly, a file stored on a user’s Window’s desktop would
`
`necessarily be stored in a “database.”
`
`Further, Dr. Stone testified that, based on his definition, the claim term
`
`“database” is “superfluous” and “redundant”:
`
`-10 -
`
`
`
`Q. So when the claims of the ’192 patent refer to one or more
`databases accessible by the data merge program for storing the generic
`script program, it’s your opinion that the term “database” is
`superfluous or redundant because anything stored on a computer is
`necessarily stored on a database?
`[A.] I would agree with that statement. Anything stored on a computer
`in a file is in a database -- in a file system in a database.
`Ex. 2069, 1191:11-21.
`
`Given that Dr. Stone’s construction makes no sense, and because claim
`
`terms should not be construed in a manner that would render them superfluous, Dr.
`
`Stone’s proposed construction is improper as a matter of law. See, e.g., Texas
`
`Instruments v. United States Int’l Trade Comm’n, 988 F.2d 1165, 1171 (Fed. Cir.
`
`1993) (refusing to construe claims in a manner that would “read an express
`
`limitation out of the claims”).
`
`Moreover, Dr. Stone also testified that, based on the construction of
`
`“database” he used to form his opinions, there is no difference in scope between
`
`claim 11 and claim 12, which depends from claim 11.
`
`[Q.] A person of ordinary skill in the art would understand that you
`could not have a monitoring system that would meet all the limitations
`of Claim 11 without also meeting the additional limitations of Claim
`12 … [a]pplying your construction of database.
`[A.] In the broadest construction of database, that’s true.
`Ex. 2069, 1197:1-11. This verifies that Dr. Stone’s construction is incorrect as a
`
`-11 -
`
`
`
`matter of law. Dow Chem. Co. v. United States, 226 F.3d 1334, 1341-42 (Fed. Cir.
`
`2000) (concluding that an independent claim should be given broader scope than a
`
`dependent claim to avoid rendering the dependent claim redundant).
`
`III.
`
`Dr. Stone’s Opinions Relating to “Script Program”
`
`Bosch also requests that the Board exclude any of Dr. Stone’s opinions
`
`relating to “script program” because Dr. Stone has offered conflicting
`
`constructions across Cardiocom’s petitions. In this proceeding, the Board
`
`construed “script program” to mean “a program that contains a set of instructions
`
`capable of being executed and interpreted.” Paper 22, 6-7. However, Dr. Stone
`
`has stated that he disagrees with this construction, as well as the construction he
`
`proffered in his opening declaration, in Medtronic’s recently filed petitions for the
`
`related Bosch ’469 patent and ’249 patent. See 2060 ¶¶ 26-29; Ex. 2061 ¶¶ 60-64;
`
`Ex. 2062 ¶¶ 39-43.
`
`At deposition, Dr. Stone now criticizes the Board’s construction of “script
`
`program” as “overbroad”:
`
`Q. And towards the top of that page you explain that the definition
`from the ’273 reexamination differentiates interpreted software
`programs from compiled programs which is consistent with the
`specification?
`A. I see that.
`Q. And you further wrote, further the definition in the context of the
`specification requires that the program be read by an interpreter to be
`
`-12 -
`
`
`
`executed.
`A. I see that.
`Q. Those are two requirements that are not present in the Board’s
`construction of the term “script program.”
`A. I see that.
`[Q.] Okay. And you then wrote, that is relevant because many type of
`programs can be executed, including programs that are not script
`programs.
`[A.] I see that.
`[Q.] So you are submitting under penalty of perjury that as of at least
`February 13th, 2014, you believed that there were relevant
`distinctions between the construction that you were proposing for
`script program and the construction that the Board has adopted in
`these IPR proceedings.
`[A.] I see that.
`Ex. 2069, 1034:10-1035:19; see also 1012:1-4; 1050:12-22; Ex. 2060 ¶ 29.
`
`Dr. Stone’s recent about-face on “script program” not only raises serious
`
`questions about his credibility, but also renders his opinions unreliable and
`
`excludable under Federal Rule of Evidence 702. Therefore, his opinions relating
`
`to “script program” should be excluded. Hochstein, 2009 WL 2022815, at *1.
`
`IV.
`
`Dr. Stone’s Opinions on Field of Endeavor
`
`Bosch moves to exclude Dr. Stone’s opinions that Wahlquist is “analogous
`
`art” to be considered in the obviousness analysis as unreliable expert testimony
`
`pursuant to Federal Rule of Evidence 702. Ex. 1022 ¶¶ 189-201. Cardiocom relies
`
`-13 -
`
`
`
`on this testimony in its reply (Paper 52) at 2-3. Bosch objected to these paragraphs
`
`in Ex. 2071 at 30-33. In particular, Dr. Stone applied an incorrect legal standard in
`
`identifying the appropriate field of endeavor of the ’192 patent in which to look for
`
`analogous art. Rather than restricting the field of endeavor to the claimed
`
`inventions of the ’192 patent, Dr. Stone testified that he looked throughout the
`
`body of the ’192 patent’s specification, likely considering alternative embodiments
`
`disclosed therein that were not claimed:
`
`Q. Okay. And you have a broader understanding of the field of the
`invention of the ’186 patent than Dr. David and Bosch have?
`A. I do based on the disclosure of the ’186 patent.
`Q. And when you say “based on the disclosure of the ’186 patent,”
`you’re referring to the specification of figures of the ’186 patent?
`A. That’s correct.
`Q. You’re not limiting your understanding of the field of the ’186
`patent to the claims -- the scope of the claims of the ’186 patent, for
`example?
`[A.] I am not limiting it to those claims.
`[Q.] Your understanding of the field of invention of the ’186 patent is
`broader than what’s claimed in the claims of the ’186 patent?
`A. That is correct.
`Q. And you applied that understanding of the field of invention when
`you opined that Wahlquist is analogous prior art?
`A. I did.
`Ex. 2069, 955:24-956:12; 1140:6-23 (Dr. Stone testifying that he “applied the
`
`-14 -
`
`
`
`same legal principles with respect to the ’192 patent” as for the other patents,
`
`including the ’186 patent); see also 959:25-960:4.
`
`Dr. Stone’s field of endeavor analysis fails to comply with Federal Circuit
`
`law. See In re Klein, 647 F.3d at 1348 (“A reference qualifies as prior art for an
`
`obviousness determination under § 103 only when it is analogous to the claimed
`
`invention.”) (emphasis added). As demonstrated by Dr. David, the relevant field
`
`for the ’192 patent is remote monitoring of individuals through communication and
`
`interaction with those individuals, a scope that is commensurate to the actual
`
`claims of the patent. Ex. 2007 ¶ 277. Wahlquist does not fall within this field
`
`because it presumes that the user’s computer is malfunctioning and is designed to
`
`gather information about the computer—not the individual. Id. ¶ 279.
`
`Accordingly, Dr. Stone’s opinions on the field of endeavor, including with
`
`respect to Wahlquist, must be excluded. See Hebert v. Lisle Corp., 99 F.3d 1109,
`
`1117 (Fed. Cir. 1996) (“We encourage exercise of the trial court’s gatekeeper
`
`authority when parties proffer, through purported experts, not only unproven
`
`science, . . . but markedly incorrect law”) (citing Daubert v. Merrell Dow Pharms.,
`
`Inc., 509 U.S. 579 (1993)).
`
`Dated: July 31, 2014
`
`Respectfully submitted,
`
`By:
`
`/Don Daybell/
`Don Daybell, Reg. No. 50,877
`Attorney for Patent Owner Robert Bosch
`Healthcare Systems, Inc.
`
`-15 -
`
`
`
`CERTIFICATION OF SERVICE (37 C.F.R. §§ 42.6(e))
`
`The undersigned hereby certifies that the above-captioned PATENT
`
`OWNER’S MOTION TO EXCLUDE EVIDENCE was served in its entirety on
`
`July 31, 2014, upon the following parties via electronic mail:
`
`Counsel for Petitioner
`
`Daniel W. McDonald
`Andrew J. Lagatta
`Merchant & Gould
`80 South 8th St., Suite 3200
`Minneapolis, MN 55402
`CardiocomIPR@merchantgould.com
`
`By:
`
`/Karen Johnson/
`Karen Johnson
`
`-16 -
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