Paper No. __
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`BROADCOM CORPORATION
`
`Petitioner
`
`v.
`
`WI-FI ONE, LLC
`
`Patent Owner
`
`
`
`Case IPR2013-00636
`U.S. Patent No. 6,424,625
`
`
`
`PETITIONER’S OPPOSITION TO PATENT OWNER’S MOTION TO
`AMEND
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`BROADCOM CORPORATION
`
`Petitioner
`
`v.
`
`WI-FI ONE, LLC
`
`Patent Owner
`
`
`
`Case IPR2013-00636
`U.S. Patent No. 6,424,625
`
`
`
`PETITIONER’S OPPOSITION TO PATENT OWNER’S MOTION TO
`AMEND
`
`
`
`
`
`
`
`
`
`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
`
`TABLE OF CONTENTS
`
`Contents
`
`I. Statement of Relief Requested and Facts in Dispute .......................................... 1
`II. Owner Has Failed to Meet Its Burden of Proof ............................................... 2
`A. There is No Written Description Support for the Amendment ..................... 2
`B. Claim 20 is Anticipated by Vornefeld ........................................................... 6
`C. The Amendments Do Not Further Limit the Claims .................................. 10
`III. Owner Has Failed to Show Patentability Over the Prior Art in General ....... 11
`IV. Conclusion ...................................................................................................... 12
`
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`
`
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`- ii -
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`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
`
`TABLE OF AUTHORITIES
`
`
`
`Cases
`Idle Free Sys., Inc. v. Bergstrom, Inc., IPR2012-00027, Paper 66 at 33 ................. 11
`
`
`In re Kaslow, 707 F.2d 1366, 1375, 217 USPQ 1089, 1096 (Fed. Cir. 1983) .......... 2
`
`
`International Flavors & Fragrances, Inc. v. The United States of America,
`IPR2013-00124, Paper 12 at 11 ............................................................................ 11
`
`
`
`Lockwood v. American Airlines, Inc., 107 F. 3d 1565, 1572 (Fed. Cir. 1997) .......... 2
`
`
`Ralston Purina Co. v. Far-Mar-Co, Inc., 772 F.2d 1570, 1575, 227 USPQ 177, 179
`(Fed. Cir. 1985) ...................................................................................................... 2
`
`
`
`Vas Cath Inc. v. Mahurkar, 935 F.2d 1555, 1563 (Fed. Cir. 1991) .......................... 2
`
`
`ZTE Corp. v. Contentguard Holdings Inc., IPR2013-00136, Paper 33 at 4 ............ 11
`
`
`Statutes
`
`35 U.S.C. §112, .......................................................................................................... 2
`
`- iii -
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`
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`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
`
`I. Statement of Relief Requested and Facts in Dispute
`Owner’s1 Motion to Amend attempts to substitute Claim 1 with a new
`
`
`
`substitute Claim 20. The Motion to Amend should be denied because Owner has
`
`failed to meet its burden of proving that it is entitled to have the substitute claim
`
`entered into the ’625 patent. Owner cannot meet its burden because: (1) Owner’s
`
`proposed amendments are not supported by the ’625 patent; and (2) the proposed
`
`amendments are not patentably distinct from the prior art.
`
`Claim 1 recites, inter alia, “a transmitter in the data network commanding a
`
`receiver in the data network to a) receive at least one packet having a sequence
`
`number that is not consecutive with a sequence number of a previously received
`
`packet and b) release any expectation of receiving outstanding packets having
`
`sequence numbers prior to the at least one packet.” Claim 1 further recites “the
`
`transmitter discarding all packets for which acknowledgment has not been
`
`received, and which have sequence numbers prior to the at least one packet.” The
`
`proposed amendments add a receiver window and limit the transmitter to
`
`commanding the receiver to receive, in step (a), at least one packet having a
`
`sequence number that is outside the receiver window.
`
`
`1
`After institution, Ericsson transferred the ‘625 patent to Wi-Fi One, LLC.
`
`This Reply refers to the current and prior owners as “Owner”.
`
`- 1 -
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`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
`
`II. Owner Has Failed to Meet Its Burden of Proof
`A. There is No Written Description Support for the Amendment
`Claim 20 is not patentable under 35 U.S.C. §112, first paragraph, due to a
`
`
`
`lack of written description support for the claimed subject matter. In particular, the
`
`’625 patent fails to provide support for a transmitter commanding a receiver to
`
`receive a packet “outside of the receiver window.”
`
`
`
`“[T]he test for sufficiency of support in a [patent] application is whether the
`
`disclosure of the application relied upon ‘reasonably conveys to the artisan that the
`
`inventor had possession at that time of the later claimed subject matter.’” Vas Cath
`
`Inc. v. Mahurkar, 935 F.2d 1555, 1563 (Fed. Cir. 1991), quoting Ralston Purina
`
`Co. v. Far-Mar-Co, Inc., 772 F.2d 1570, 1575, 227 USPQ 177, 179 (Fed. Cir.
`
`1985) (quoting In re Kaslow, 707 F.2d 1366, 1375, 217 USPQ 1089, 1096 (Fed.
`
`Cir. 1983)). “A description which renders obvious the invention for which an
`
`earlier filing date is sought is not sufficient.” Lockwood v. American Airlines, Inc.,
`
`107 F. 3d 1565, 1572 (Fed. Cir. 1997).
`
`
`
`Generally, the ’625 patent is directed to a wireless ARQ transmission
`
`scheme in which a transmitter and a receiver are exchanging packets. (’625 at
`
`5:15-17; Ex. 1001). The transmitter maintains a transmit window to keep track of
`
`packets it has sent, and the receiver maintains a separate receiver window to keep
`
`track of packets it has received.
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`- 2 -
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`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
`
`Since each window is maintained by the respective device, a situation can
`
`
`
`arise where the receiver is expecting to receive packets that the transmitter is no
`
`longer going to transmit (e.g., due to a retransmission timeout by the transmitter).
`
`For example, the transmitter can discard (decide to not re-transmit) certain packets
`
`and advance the lower end of its transmit window, but the receiver has not yet
`
`advanced the lower end of its receiver window, because the receiver is still
`
`expecting to receive a packet discarded by the transmitter.2
`
`
`
`The ’625 patent describes a technique for reporting the progress of a
`
`“bottom part of a sender window of the transmitter … to the receiver in order to
`
`allow the receiver to properly skip packets which do not exist anymore because
`
`they have been discarded.” (’625 at 5:18-21; Ex. 1001). In an embodiment, the
`
`’625 patent advances the receiver window by setting a Receiver Packet
`
`Enforcement Bit (“RPEB”) in a packet to TRUE to cause the receiver to receive
`
`the packet and move the receiver window. (’625 at 5:28-32; Ex. 1001).
`
`
`2 As pointed out in the Petition, the named inventors appeared to believe that there
`
`were no methods of discarding in ARQ systems. (Pet. at 11; Paper No. 3). As the
`
`many examples of prior art cited by Petitioner show, the idea of discarding in an
`
`ARQ system had been addressed many times before the ‘625 patent was filed.
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`- 3 -
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`
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`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
`
`Owner alleges that two sections in the specification support its amendment
`
`
`
`“wherein the sequence number of the at least one packet is outside of the receiver
`
`window.” However, neither provides written description support for the proposed
`
`amendments – to the contrary, the ’625 patent discloses that the receiver only
`
`receives packets that fall within the receiver window.
`
`
`
`First, Owner identifies the following portion of the ’625 patent:
`
`If the difference between N(S) and ESN (for example,
`ESN1) is less than 2k−1 and RPEB=TRUE at a packet
`reception, then the packet will be accepted and forwarded
`to higher layer as long as the data carried in the packet is
`also correct.
`(’625 Pat. at 6:32-36; Ex. 1001). But this portion describes the reception of a
`
`packet within the receiver window and thus offers no support whatsoever for
`
`Owner’s proposed amendment regarding reception of a packet outside of the
`
`receiver window. In the ‘’625 patent, the size of the receiver window is 2k−1, N(S)
`
`is the sequence number of the received packet, and ESN1 is the sequence number
`
`of the expected packet (and the lower end of the receiver window). Thus, when
`
`“the difference between N(S) and ESN (for example, ESN1) is less than 2k−1,” the
`
`received packet is within the receiver window. Owner’s first citation therefore
`
`contradicts transmitting a packet outside the receiver window.
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`- 4 -
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`
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`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
`
`When asked why this passage supports Owner’s proposed construction,
`
`Owner’s expert, Dr. Akl, speculated that the receiver window size might not equal
`
`the transmitter window size, and if the receiver window were smaller than the
`
`transmitter window, this portion of the ’625 patent could disclose transmitting a
`
`packet outside the receiver window. (Akl Tr. at 116:3-118:19; Ex. 1021). But Dr.
`
`Akl simply made up this argument out of thin air. He could not identify any
`
`disclosure in the ’625 patent of the receiver window actually being a different size
`
`than the transmitter window. (Akl Tr. at 117:12-118:3). For good reason – the
`
`specification says exactly the opposite:
`
`W [window size] can assume an arbitrary value between
`1 and 2k-1. However, the receiver and transmitter must
`both use the same arbitrary value for W.
`(’625 at 7:19-21; Ex. 1001). Thus the speculative basis for Dr. Akl’s and Owner’s
`
`position that the specification supports the proposed amendment is expressly
`
`contradicted by the specification.
`
`Second, Owner cites the following portion of the Background section of the
`
`patent to support its amendment:
`
`The receiver window size in a Selective Reject scheme
`can include up to 2k−1 positions, instead of just one
`position as in a Go-Back-N scheme. In Selective Reject
`a range of packets can be received since the receiver
`window can include up to 2k−1 positions.
`
`- 5 -
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`
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`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
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`
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`(’625 at 2:60-65; Ex. 1001). This portion of the specification does not lend any
`
`support to Owner’s proposed amendment either. This disclosure simply describes
`
`having a receiver window size of up to 2k−1 positions; it does not describe receiving
`
`a packet outside the receiver window. Further, Owner’s expert admitted that this
`
`section does not disclose transmitting a packet outside the receiver window. (Akl
`
`Tr. at 115:11-18; Ex. 10213). Therefore, the amendment should be rejected as not
`
`being supported by the specification of the ’625 patent.
`
`B. Claim 20 is Anticipated by Vornefeld
`
`Even if the specification of the ’625 patent were found to support Owner’s
`
`
`
`proposed claim amendment (which it does not), claim 20 is invalid over Vornefeld.
`
`Vornefeld (Ex. 2026) was published in July, 1997 and qualifies as prior art to the
`
`’625 patent under 35 U.S.C. § 102(b). Vornefeld describes the Selective Reject
`
`with Discarding (SR/D) ARQ protocol, which includes different methods that can
`
`be used to reject packets in ARQ protocols. (Ex. 2026 at 40). In section 5.3.1.2,
`
`“Implicit discarding through moving the window,” Vornefeld discloses
`
`transmitting cells that are outside of the receiver window:
`
`3 In addition, this cited portion is from the Background description of admitted
`
`prior art, and therefore cannot supply any basis for establishing the patentability of
`
`Owner’s proposed amendment.
`
`- 6 -
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`
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`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
`
`ATM-cells that have already been assigned a sequence number can
`also be discarded without the transfer of discard messages by having
`the transmitter moving their transmission window correspondingly
`when rejecting cells. Through this, I-frames are delivered, which are
`outside of the recipient window and which would be invalid by the
`standard SR-ARQ-protocols.
`(Ex. 2026 at 42 (emphasis added)).
`
`
`
`Owner admits that the concept of receiving packets outside a receiver
`
`window is not, by itself, novel, and identifies this mechanism in Vornefeld. (Paper
`
`No. 36 at 10). Consistent with Owner’s admission, Dr. Akl testified that it is
`
`inherent that one of skill in the art would know to transmit a packet outside the
`
`receiver window. (Akl Tr. at 129:4-14 and 144:12-144:5; Ex. 1021). Therefore,
`
`since transmitting a packet outside a receiver window is itself not inventive, then
`
`Owner’s amendment does not add any inventive aspects to claim 20.
`
`
`
`To distinguish from Vornefeld, Owner only disputes that Vornefeld “creates
`
`rather than releases expectation of cells having a lower sequence number,” and
`
`therefore Vornefeld does not anticipate substitute claim 20. However Vornefeld
`
`states that by receiving an I-frame outside of the window, “the recipient recognizes
`
`that the transmitter has discarded cells, and also moves their window and ends the
`
`waiting for the I-frame of their sequence numbers outside of the window.” (Ex.
`
`- 7 -
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`
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`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
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`2026 at 42). A person of skill in the art would therefore understand Vornefeld to
`
`disclose releasing expectation of any packets outside of the receiver window.
`
`
`
`Figure 5.3 of Vornefeld shows an exemplary implementation where the
`
`transmitter sends a packet outside the receiver window causing the receiver to no
`
`longer wait for a packet.
`
`
`
`(Ex. 2026 at 43).
`
`
`
`
`
`
`
`The receiver in Figure 5.3 has a window size of four (i.e., the receiver is
`
`expecting to receive packets SN1, 2, 3 and 4). Figure 5.3 shows that the receiver
`
`properly receives SN3 and SN4, but is missing SN1 and SN2. The receiver
`
`therefore requests a repeat of SN1. The transmitter in the meantime discarded
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`- 8 -
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`
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`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
`
`SN1, and therefore sends SN5 (which is outside of the receiver’s window SN1-
`
`SN4). The receiver receives SN5 and therefore shifts its window to SN2-SN5,
`
`releasing expectation of receiving SN1. (Ex. 2026 at 43).
`
`
`
`While in the example shown in Figure 5.3 the receiver still waits for SN2,
`
`Dr. Akl testified that in the situation where only SN1 was outstanding, receiving
`
`SN5 as shown in Figure 5.3 would cause the receiver to release expectations for all
`
`outstanding packets (i.e., SN1). (Akl Tr. at 149:1-150:4; Ex. 1021). Prior to
`
`receipt of SN5, the receiver window would be SN1-SN4. (Id. at 145:14-17; Ex.
`
`1021). Since the receiver already received packets SN2-SN4, upon receipt of SN5
`
`the receiver would shift its window to SN2-SN5, releasing expectations of SN1.
`
`(Id. at 148:10-25 and 149:20-22; Ex. 1021). The receiver would then pass received
`
`packets SN2-SN5 up to higher layers. (Id. at 148:20-25 and 149:23-150:1; Ex.
`
`1021). Therefore a person of skill in the art would understand Vornefeld to
`
`disclose that if a receiver is only waiting for one I-frame and the transmitter causes
`
`the receiver to stop waiting for the single I-frame, then the receiver releases
`
`expectation for the one and only outstanding I-frame.
`
`
`
`The ’625 patent relates to reporting the progress of the lower-end of a
`
`transmitter window to a receiver. For example, a transmitter can discard a number
`
`of packets at the lower-end of the window, but the receiver is still expecting to
`
`receive a packet within the discarded range. Although the ’625 patent does not
`
`- 9 -
`
`
`
`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
`disclose transmitting a packet outside the receiver window to report the progress of
`
`the lower end of its window, assuming such is true to address Owner’s argument,
`
`the ’625 patent would release expectation of one or more of the discarded packets
`
`at the lower end of the window. This is exactly what Vornefeld discloses –
`
`Vornefeld delivers frames outside of the transmitter window to cause the receiver
`
`to move the lower end of its window over discarded cells, thus “releasing
`
`expectation” of the discarded cells.
`
`C. The Amendments Do Not Further Limit the Claims
`
`Claim 1 recites a “transmitter” and is directed to a method performed by the
`
`transmitter. Owner’s amendment attempts to claim a receiver window in a
`
`receiver, yet both method steps (a) and (b) in claim 20 are performed by the
`
`transmitter. Claim 1 does not affirmatively recite steps performed by a receiver,
`
`whereas other claims, such as dependent claim 6, do recite such steps (like
`
`rejecting packets outside the receiver window). (’625 patent at 11:23-48; (Ex.
`
`1001).
`
`Owner does not indicate how the claim amendments directed to steps
`
`performed in the receiver would limit a claim to a transmitter method. If the
`
`receiver controls its own window, the proposed amendment fails to limit the
`
`transmitter method of claim 1, and the amendment should be rejected for the same
`
`reasons that claim 1 should be cancelled.
`
`- 10 -
`
`
`
`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
`
`III. Owner Has Failed to Show Patentability Over the Prior Art in General
`
`To demonstrate patentability, the “Owner should discuss, as well as present
`
`evidence, if appropriate, as to the level of ordinary skill in the art, and what was
`
`known regarding the features being relied upon to demonstrate patentability of the
`
`proposed claims.” (International Flavors & Fragrances, Inc. v. The United States
`
`of America, IPR2013-00124, Paper 12 at 11, citing Idle Free Sys., Inc. v.
`
`Bergstrom, Inc., IPR2012-00027, Paper 66 at 33).
`
`Owner’s motion does not once address the level of one of ordinary skill in
`
`the art. Although some of Owner’s arguments mention in passing that “one of
`
`ordinary skill in the art would not combine” references, Owner does not present
`
`any evidence as to the level of ordinary skill in the art. The Akl declaration
`
`provides a definition of the level of ordinary skill in the art, but the Board should
`
`not give this any weight because Owner did not refer to it in its motion. (ZTE
`
`Corp. v. Contentguard Holdings Inc., IPR2013-00136, Paper 33 at 4).
`
`
`
`
`
`
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`- 11 -
`
`
`
`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
`
`
`IV. Conclusion
`For the reasons described above, Owner’s motion to amend should be
`
`
`
`denied.
`
`
`
`Dated: October 1, 2014
`
`
`
`
`
`Respectfully submitted,
`
`/Michael A. Diener/
`
`
`
`Michael A. Diener, Reg. No. 37,122
`
`60 State St.
`
`Boston, MA 02109
`
`- 12 -
`
`
`
`Exhibit
`1001.
`
`1002.
`
`1003.
`
`1004.
`
`1005.
`
`1006.
`
`1007.
`
`1008.
`
`1009.
`
`1010.
`
`1011.
`
`1012.
`
`1013.
`
`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
`
`Table of Exhibits for U. S. Patent 6,424,625
`
`Description
`
`U.S. Patent No. 6,424,625
`
`Garrabrant et al., U.S. Patent No. 5,610,595, entitled “Packet
`Radio Communication System Protocol” (“Garrabrant”)
`
`Hettich Thesis, entitled “Development and performance
`evaluation of a Selective Repeat – Automatic Repeat Request
`(SR-ARQ) protocol for transparent, mobile ATM access,”
`(1996) (“Hettich”) (Certified Translation at Ex. 1007)
`
`Walke et. al., German Patent No. DE 19543280, entitled
`“Process and Cellular Mobile Communication System for
`Wireless Broadband Connection of Mobile Stations with ATM
`Interfaces to Error Protection of an ATM Network” (“Walke”)
`(Certified Translation at Ex. 1008)
`
`Kemp, U.S. Patent No. 6,621,799, entitled “Semi-Reliable Data
`Transport” (“Kemp”)
`
`Declaration of Harry Bims, Ph.D.
`
`Certified Translation of Hettich (Ex. 1003)
`
`Certified Translation of Walke (Ex. 1004)
`
`German to English Translations of the German word
`“weitergeschoben”
`
`REDACTED Rebuttal Expert Report of Scott Nettles, Ph.D.
`
`IEEE Dictionary Definition of “Command”
`
`Bertsekas, et al., DATA NETWORKS, Prentice-Hall, pp. 58-73
`(1987) (“Bertsekas”)
`
`U.S. Patent No. 6,424,625 Patent Prosecution History,
`Amendment of October 31, 2001
`
`- 13 -
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`
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`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
`
`Exhibit
`
`Description
`
`1014.
`
`1015.
`
`1016.
`
`1017.
`
`1018.
`
`1019.
`
`1020.
`
`1021.
`
`1022.
`
`Ericsson Inc. v. D-Link Corp., Case No. 6:10-cv-473 (E. D.
`Tex.), Trial Transcript, Morning of June 5, 2013
`Docket for Ericsson Inc. v. D-Link Corp., Case No. 6:10-cv-473
`(E. D. Tex.)
`Docket No. 415 from Ericsson Inc. v. D-Link Corp., Case No.
`6:10-cv-473 (E. D. Tex., 2013)
`
`Declaration of David Djavaherian
`
`Ericsson’s Emergency Motion for Relief from the Protective
`Order, Case 6:10-CV-473 (LED/KFG), March 8, 2013
`
`Docket for Case 6:10-CV-473 (LED/KFG), printed December
`20, 2013
`
`December 20, 2013 Order Denying Ericsson’s Emergency
`Motion for Relief from the Protective Order in Ericsson Inc. v.
`D-Link Corp. et al., Civil Action No. 10-cv-473 (E. D. Tex.)
`
`Oral Deposition of Robert Akl, D.Sc., September 16, 2014.
`
`Reply Declaration of Harry Bims, Ph.D.
`
`
`
`
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`- 14 -
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`Petitioner’s Opposition to Patent Owner’s Motion to Amend
`IPR2013-00636
`
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`CERTIFICATE OF SERVICE
`
`I hereby certify that, on October 1, 2014, I caused a true and correct copy of
`
`the foregoing Petitioner’s Opposition to Patent Owner’s Motion to Amend and
`
`Exhibits to be served via email on the attorneys identified in Owner’s Updated
`
`Mandatory Notice and Notice of Appearance for John Shumaker, whom consented
`
`Peter J. Ayers
`J. Christopher Lynch, John Shumaker
`EricssonIPR2013-636@leehayes.com
`
`
`/Michael A. Diener/
`Michael A. Diener
`Registration No. 37,122
`
`
`
`to electronic service:
`
`Lead Counsel:
`Back-up Counsel:
`Email Address:
`
`
`
`- 15 -
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