Paper No. 27
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Samsung Electronics America, Inc.
`Petitioner,
`
`V.
`
`B.E. Technology, LLC
`Patent Owner
`
`Patent No. 6,771,290 (Claims 2-3)
`Issued: August 3,‘ 2004
`Filed: April 11, 2001
`Inventors: Martin David Hoyle
`
`Title: COMPUTER INTERFACE METHOD AND APPARATUS WITH
`
`PORTABLE NETWORK ORGANIZATION SYSTEM AND TARGETED
`
`ADVERTISING
`
`Inter Partes Review No. IPR2014-00044
`
`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE TO
`
`PETITION FOR INTER PARTES REVIEW
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Samsung Electronics America, Inc.
`Petitioner,
`
`V.
`
`B.E. Technology, LLC
`Patent Owner
`
`Patent No. 6,771,290 (Claims 2-3)
`Issued: August 3,‘ 2004
`Filed: April 11, 2001
`Inventors: Martin David Hoyle
`
`Title: COMPUTER INTERFACE METHOD AND APPARATUS WITH
`
`PORTABLE NETWORK ORGANIZATION SYSTEM AND TARGETED
`
`ADVERTISING
`
`Inter Partes Review No. IPR2014-00044
`
`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE TO
`
`PETITION FOR INTER PARTES REVIEW
`
`
`
`TABLE OF CONTENTS
`
`I.
`
`II.
`
`INTRODUCTION ........................................................................................ .. 1
`
`ARGUMENT ................................................................................................ .. 1
`
`A.
`
`B.
`
`C.
`
`Kikinis Discloses “Said Program Stored on Said Non-Volatile
`Data Storage Device” that is “Operable
`to Access the Files
`in the User Library” ............................................................................ .. 3
`Kikinis Discloses a “File Associated with [a] Selected User
`Link” ................................................................................................... .. 7
`Kikinis Discloses a “User Profile” ................................................... .. 11
`
`D.
`
`The Broadest Reasonable Construction Standard Is in
`
`Accordance with Law and Not Case-Determinative ........................ .. 13
`
`III.
`
`CONCLUSION ........................................................................................... .. 14
`
`
`
`TABLE OF AUTHORITIES
`
`Federal Cases
`
`Leibel-Flarsheim Co. v. Medrad, Inc.,
`
`358 F.3d 898 (Fed. Cir. 2004) ............................................................................. ..6
`
`Phillips v. AWH Corp,
`
`415 F.3d 1303 (Fed. Cir. 2005).................................................................... .. 8, 10
`
`Other Authorities
`
`SAP America, Inc. v. Versata Development Group, Inc. ,
`
`No. CBM2012-00001, Paper No. 70 (PTAB June 11, 2013) .......................... .. 13
`
`
`
`I.
`
`INTRODUCTION
`
`Petitioner Samsung Electronics America, Inc. (“Samsung”) hereby submits
`
`this Reply to Patent Owner B.E. Technology, L.L.C.’s (“B .E.”) Response to
`
`Petition (Paper No. 25) (“Response”). Samsung’s Petition for Inter Partes Review
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`(Paper No. 02) (“Petition”) describes how PCT International Publication No. WO
`
`97/09682, to Kikinis (Ex. 1007) (“Kikinis”) meets each and every limitation of
`
`Claims 2 and 3 of the ’290 patent, and is supported in detail by the Declaration of
`
`Dr. John M. Strawn. (Ex. 1005 111] 46-57 and Attachment A.) B.E.’s Response
`
`fails to overcome the substantial evidence of invalidity accompanying Samsung’s
`
`petition, and accordingly, the ’290 patent should be held unpatentable.
`
`II.
`
`ARGUMENT
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`In its Response, B.E. does not contest that the vast majority of limitations of
`
`the ’290 patent claims are disclosed by Kikinis. By way of example, B.E. does not
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`contest that Kikinis discloses “[a] computer-readable memory for use by a client
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`computer in conjunction with a server that is accessible by the client computer via
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`a networ ” (Petition at 12; Ex. 1005 at 11 46); “the server storing a
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`user library
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`for each of a number of different users, with the user library containing one or
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`more files...” (Petition at 13; Ex. 1005 at 11 47); “the computer-readable memory
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`comprising: a non-volatile data storage device” (Petition at 13; Ex. 1005 at fi[ 48);
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`“the computer-readable memory comprising:
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`a program stored on said non-
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`volatile data storage device in a computer-readable format” (Petition at 13; Ex.
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`1005 at 11 49); “said program being operable upon execution to display a graphical
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`user interface comprising an application window having a number of user-
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`selectable items displayed therein” (Petition at 14; Ex. 1005 at 1] 50); “wherein
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`each of said items has associated with it a link to an information resource
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`accessible via the network” (Petition at 14-15; Ex. 1005 at 11 51); or “wherein said
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`program is operable upon execution and in response to selection by a user of one of
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`said items to access the associated information resource over the networ ”
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`(Petition at 15; Ex. 1005 at 1] 52). Nor does B.E. make any separate arguments
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`with respect to the validity of dependent Claim 3, including the limitation “wherein
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`said program is operable upon execution and in response to selection by a user of
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`one of said items to access the associated information resource over the network
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`using a browser.” (Petition at 17-18; Ex. 1005 at 11 56.)
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`Instead, B.E. purports to provide three reasons that Kikinis does not
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`anticipate Claim 2: (a) Kikinis allegedly does not disclose a “program stored on [a]
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`non-volatile storage device” that performs the fiinction of “access[ing] the file
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`from the user library” as claimed in claim 2, as, according to B.E., Kikinis
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`discloses that server-side programs are required to do so (Response at 3 and 9-17);
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`(b) Kikinis allegedly does not disclose a “file associated with [a] selected user
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`link,” as, according to B.E., the links in the homepage of Kikinis do not link to
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`specific files in the user library (id. at 3-4 and 17-24); and (c) Kikinis allegedly
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`does not disclose a “user profile” as, according to B.E., the home page disclosed in
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`Kikinis does not contain user-specific information (id. at 4 and 24-26). B.E.’s
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`arguments fail for the reasons described below.
`
`A.
`
`Kikinis Discloses “Said Program Stored on Said Non-Volatile
`Data Storage Device” that is “Operable
`to Access the Files in
`the User Library”
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`B.E. and its expert, Cory Plock, admit that Kikinis discloses a web browser,
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`that the web browser is a program, and that the web browser is stored on a non-
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`volatile storage device.
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`(EX. 2004, 8/19/14 Plock Tr. at 13:9-14-6.) B.E. and Dr.
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`Plock also admit that “a web browser makes requests to a web server and receives
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`responses from the web server, the contents of which are subsequently displayed in
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`the browser window to the user.” (Ex. 2001 at 1] 21.) Further, B.E. and Dr. Plock
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`do not contest Dr. Strawn’s conclusion that “Kikinis discloses that a user may
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`select one of the user-selectable items” m the web browser (e.g., the v-mail button)
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`such that “the voice mail browser window (125) is opened.” (Ex. 1005 at 1] 54 and
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`Attachment A, pp. 12-14.) B.E. concedes that this mechanism constitutes “remote
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`indirect access.”1 (Response at 10.) Thus, by B.E.’s own admissions, the web
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`1 Unless otherwise indicated, all emphasis in this brief has been added.
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`browser of Kikinis (on the non-volatile storage device) is operable on execution to
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`access a file in a user library on the server.
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`B.E. attempts to avoid this conclusion by arguing that “remotely stored
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`programs are necessary to access the electronic document data bases shown in
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`Kikinis” (Response at 9) — i.e., B.E. effectively construes “access” to mean
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`“directly access” and argues that the web browser of Kikinis does not directly
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`access those files. (See also id. at 16 (“The browser does not access the electronic
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`data bases without additional software programs stored on remote servers”); Ex.
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`2001 at fl[ 21 (“a web browser cannot ‘access [a] file’ without the web server, since
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`the web server must execute programs. . .”); Ex. 2004 at 24: 12-23.)
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`B.E.’s argument relies on improperly reading the limitation “directly” into
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`the claim. In fact, in doing so, B.E.’s construction of “access” is inconsistent, and
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`at odds, with the use of the term “access” in the specification, which is used
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`broadly throughout the’290 patent. When the patentee wanted to describe an
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`action taken “directly,” he indicated this by reciting the appropriate adjective
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`(“direct”) or adverb (“directly”) in the specification. (E.g., Ex. 1001 at 11:45-46
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`(“This can include client computers that are connected directly to the
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`Internet. . . .”);15 : 12-14 (“The user has the ability to subscribe the channel by
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`making a direct link to a file, or by combining various files under some
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`category....”); see also id. at 1823-4 and 19:24-27.) However, the term “access”
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`appears in Claim 2 of the ’290 patent without any such qualifying language. Thus,
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`according to the ’290 patent, files may be directly or indirectly accessed.
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`Indeed, the specification of the ’290 patent states that web browsers, such as
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`Opera, Netscape Navigator, Netscape Communicator 4.6 and Microsoft Internet
`
`Explorer, “are useful for accessing desiredfiles. ...” (Ex. 1001 at 3:49-50.) In fact,
`
`Claim 3 of the ’290 patent requires “said program” to “access the associated
`
`information resource over the network using a browser.” (Id., Cl. 3.) But Dr.
`
`Plock admits that third-party, server—side software would be required in order to
`
`achieve this:
`
`Q.
`
`[I]s it true that, at a minimum, the web server, itself, must have
`
`some software to handle some part of the processing of an HTTP
`
`request?
`
`A. Yes, that’s a fair characterization.
`*
`*
`
`*
`
`Q.
`
`Is it correct that there is no way for a web server to serve a file
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`in response to a request without having some software that resides
`
`on that web server?
`
`A. Yes, yes. On a server, software would be required in order to do
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`that.
`
`(Ex. 2005, 8/20/14 Plock Tr. at 53:15-19, 54:13-18.) Thus, “access” as used in the
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`’290 patent must include the type of “access” that is performed by web browsers —
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`i.e., “indirect access” by a client software program using remotely stored programs
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`on the server. Even outside of the web browser/server context, the specification of
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`the ’290 patent contains many other instances of “indirect access” using, in part,
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`other software applications or server-based programs. (See Ex. 1001 at 25:66-26:7
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`(“the user’s existing address books residing in other applications are accessed”);
`
`id. at 36:16-33 (describing an embodiment where “the client software application
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`can work in conjunction with suitable server software to provide a virtual pre-
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`paid cash card,” which can be “represented by afile containing various
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`information”).)2
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`In contrast, neither B.E. nor its expert point to any statements in the
`
`specification or file history that would exclude the indirect access utilized by the
`
`web browser in Kikinis or described in the above embodiments. The ’290 patent
`
`must not “be read restrictively unless the patentee has demonstrated a clear
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`2 Dr. Plock’s attempt to argue that this latter embodiment does not “access a file”
`
`(Ex. 2004 at 27:18—29:4) is not credible. Not only does the specification recite that
`
`the virtual card is stored as a “file,” but Dr. Plock’s testimony about information
`
`not being “sent as a file” (id. at 28:13-18) intrinsically requires access to that file.
`
`Finally, even the information that would be “extracted ... and sent,” according to
`
`Dr. Plock, constitutes a “file” as that term is broadly defined by the ’290 patent.
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`(See Ex. 1001 at 4:25-28.)
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`intention to limit the claim scope using words or expressions of manifest
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`exclusion or restriction.” Leibel-Flarsheim Co. v. Medrad, Inc., 358 F.3d 898,
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`906 (Fed. Cir. 2004). Accordingly, the ’290 patent must be read to include a
`
`client-side program that accesses (i.e., requests and retrieves) files on a server in
`
`any manner, including indirectly via server-side software. Because Kikinis
`
`discloses a web browser on a non-volatile data storage device that is operable to
`
`“access” the files in the user library in this way, Kikinis reads on Claim 2 of the
`
`’290 patent.
`
`B.
`
`Kikinis Discloses a “File Associated with [a] Selected User Link”
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`B.E. describes the ’290 patent as teaching a “‘one—click’ system whereby a
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`user enjoys a direct link from his or her user profile to the files stored in his or her
`
`user library.” (Response at 17.) B.E. then contends that Kikinis teaches links “to
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`data bases from which the user may then access specific electronic documents”
`
`(id.) and therefore concludes that Kikinis does not meet the “file associated with
`
`[a] selected user link” limitation of Claim 2. B.E. is wrong for several reasons.
`
`The ’290 patent does not teach only a “one-click” system. The ’290 patent
`
`discloses a “User Database 46” which “can include a user library that enables the
`
`user to store files (documents, executable programs, email messages, audio clips,
`
`video clips, or other files) ....” (Ex. 1001 at 13:3-7.) Thus, the ’290 patent allows
`
`for files from within a database to be “accessed” even if a database containing
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`those files must be “accessed” first. The ’290 patent also discloses, inter alia, a
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`“toolbar containing bookmark category icons 80” which represents “hyperlink
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`channel categor[ies]” containing related bookmarks; the user “has the ability to
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`subscribe the channel by making a direct link to a file, or by combining various
`
`files under some category, or by providing a drop down list to a subscribed
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`channel.” (Ex. 1001 at 14:1-15.) Indeed, the ’290 patent shows an “alternative
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`embodiment of a window
`
`including icons that represent various files and links
`
`to information resources.” (Id. at 14:48-50.) One of those icons is a “library icon,
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`which, when selected, contains a list of all the files contained in the user library.
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`From here, the user can access any of the files contained in his or her user
`
`library. ...” (Id. at 14:53-57; see also Figs. 5b and 5c.) Thus, B.E.’s argument that
`
`only a “one-click” system is disclosed is incorrect as a matter of both fact (given
`
`the multiple disclosed embodiments) and law. See, e.g., Phillips v. AWH Corp.,
`
`415 F.3d 1303, 1323 (Fed. Cir. 2005) (“[A]lthough the specification often
`
`describes very specific embodiments of the invention, we have repeatedly warned
`
`against confining the claims to those embodiments.”).
`
`In addition, even if only “direct” or “one-click” links are considered, Kikinis
`
`clearly describes direct linking to files in the user library. As Dr. Plock agrees,
`
`Kikinis discloses a “[h]ome page 73
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`having on-screen links to electronic
`
`documents reserved for the home page ‘owner’, such as e-mails and faxes.” (Ex.
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`1001 at 7:32-8:1; Ex. 2005 at 66:15-20.) Accordingly, Kikinis discloses specific
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`links that access (i.e., are associated with) specific files in the user library.
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`Moreover, Dr. Plock agrees that the home page “provides software links to
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`various lower-order data bases,” such as “an e-mail data base 89, a fax data base
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`91, a voice mail data base 93, and other electronic documents in data base 95.”
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`(Ex. 1007 at 6:35-7:4; Ex. 2001 at 11 24.) As Samsung set forth in its Petition, each
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`lower-order data base (89, 91, 93 and 95) is itself a “user-specific file[]” in the user
`
`library (i.e., the “set of lower-order data bases”). (Petition at 13; see also Ex. 1005
`
`at 11 47.) The home page provides “one click” access to those data bases through
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`buttons with links associated with them. (Petition at 16; Ex. 1005 at 1] 54 and
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`Attachment A pp. 12-14; Ex. 1007 at 326-11 and 823-4.)
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`In response, B.E. argues that the “home page software links
`
`access data
`
`bases” (Response at 21) and that data bases are “not files.” (Id. at 20; Ex. 2001 at 1]
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`25.) However, at deposition, B.E.’s expert, Dr. Plock, admitted that the lower-
`
`order data bases (89, 91, 93, 95) of Kikinis meet the expansive definition of “file”
`
`explicitly set forth in the ’290 patent and adopted by the Board: “Any digital item,
`
`including information, documents, applications, audio/video components, and the
`
`like, that is stored in memory and is accessible via a file allocation table or other
`
`pointing or indexing structure.” (Ex. 1001 at 4:25-28.) That is, Dr. Plock admitted
`
`that the data bases of Kikinis (as well as data bases generally) are “stored in
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`memory” (Ex. 2005 at 59:21-23, 62:4-24); that they are “stored in digital form”
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`(id. at 63:15-20) — i.e., digital items; that they “can be accessed” via a “pointing or
`
`indexing structure” (id. at 59:24-60:1, 60:9-11, 62:25-63 :7); and that they “include
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`information” (id. at 60: 12-13). Thus, the data bases (89, 91, 93, 95) disclosed in
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`Kikinis are “files” as defined by the ’290 patent. Whether a person of skill in the
`
`art (“POSA”) might understand data bases to be “files” in some other context is
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`ultimately irrelevant, because where “a special definition [is] given to the claim
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`term by the patentee that differs from the meaning it would otherwise possess,” the
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`“inventor’s lexicography governs.” Phillips, 415 F.3d at 1303.
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`Finally, Dr. Plock belatedly asserts that the data bases of Kikinis (89, 91, 93,
`
`95) contain data relating to several users. (See Ex. 2004 at 3613-14; Ex. 2005 at
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`56:20-57:1.) Thus, B.E. may contend that the set of lower-order data bases in
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`Kikinis do not comprise a “user library” because they are not “a collection of an
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`individual’s stored files,” as construed by the Board. (See Paper 11 at 10.) Again,
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`Dr. Plock’s opinion is inconsistent with the disclosures in Kikinis. Kikinis
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`discloses, for example, “an on-screen active selection area for access to an
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`electronic document data base containing electronic documents addressed
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`specifically to the homepage owner.” (Ex. 1007 at 3:4-6; see also id. at 8:30-31,
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`“In the event that a user accesses his electronic document data bases from a
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`computer other than his own ....”) Thus, a POSA would understand that the
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`lower-order data bases that are linked to a specific user’s home page do not contain
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`documents addressed to anyone else. As the set of lower-order data bases meet the
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`“user library” limitation under the Board’s construction, each lower-order data
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`base within that set is a “file” in the user library for reasons discussed above.
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`Accordingly, Kikinis discloses accessing “the file associated with the
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`selected user link” as that limitation is found in Claim 2 of the ’290 patent.
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`C.
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`Kikinis Discloses a “User Profile”
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`A “profile” is defined in the ’290 patent as “[u]ser-specific information
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`relating to an individual using a computer.” (Ex. 1001 at 4:52-53.) Kikinis
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`discloses that “[a] home page is a graphical user interface unique to an individual
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`user,” (Ex. 1007 at 223-4) and even B.E. concedes that “Kikinis states that the
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`home page is ‘individualized to a specific client.”’ (Response at 4 and 24, citing
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`Ex. 1007 at 6:35-36.) That should be the end of the story; by B.E.’s admissions,
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`Kikinis discloses a “user profile.”
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`Despite obviously meeting the “user profile” limitation, B.E. argues that
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`“there is no disclosure in the reference that identifies any user-specific information
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`contained within the home page.” (Id. at 4; see also id. at 24-25.) Of course, this
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`is incorrect; Kikinis discloses a home page interface “comprising indicia
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`identifying the home page owner,” i.e., user-specific information. Dr. Plock’s
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`assertion that he is unable to discern whether the home page “owner” is also the
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`“user” (see Ex. 2004 at 39:12-40:17) is, yet again, inconsistent with Kikinis which
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`describes the “owner” as using the system — for example, being able to “activate
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`the on—screen window and select and review stored documents therethrough” (Ex.
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`1007 at 3:1-12; see also id. at 8:2-18 and 10:3-12).
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`Moreover, Dr. Plock admitted the ’290 patent discloses that “user hyperlink
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`bookmarks” would be “user-specific information relating to an individual using a
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`computer” (i.e., and thus a component of a “user profile”) (Ex. 2004 at 3828-1 1),
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`and that if the home page is “individualized in the sense that the selection of the
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`links to be included in the home page is done in accordance with the user’s
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`preferences, then that profile would include user-specific information” because
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`“the preferences are user-specific information.” (Ex. 2005 at 94:11-17.)
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`Here, as a POSA would understand, Kikinis discloses a home page in which
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`the links included therein are selected in accordance with the user/owner’s
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`preferences, in that there are “many designs one might use for a home page
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`interface, and many known methods of affording a user selection to alternative
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`control pathways.” (EX. 1007 at 9:28-30.) In one instance, “a traveling Internet
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`user may use his or her home page to link to other data bases, such as a personal
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`multi—lingual dictionary
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`or indeed, almost any other sort ofdigital data or
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`control routines” (Id. at 8: 14-18) — items that, by nature, would be selected in
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`accordance with the preferences of that user. Even with respect to the home page
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`depicted in Fig. 3 of Kikinis, a POSA would understand that a user would have
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`selected those links in accordance with her preferences. As Samsung’s expert, Dr.
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`Strawn, testified as to a POSA’s understanding:
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`Q. So the V-mail button is not user-specific information; correct?
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`A. Well, I’d have to understand that if the user weren’t accessing e-
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`mail or fax ever, that those buttons w0uldn’t appear. It says it’s a
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`user interface for that particular user.
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`(Ex. 2003, 6/24/14 Strawn Tr. at 70:2-7.)
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`For these reasons, Kikinis discloses a home page meeting the “user profile”
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`limitation.
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`D.
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`The Broadest Reasonable Construction Standard Is in
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`Accordance with Law and Not Case-Determinative
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`B.E. argues that the PTO’s use of the “broadest reasonable construction”
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`standard exceeds the PTO’s rule making authority. Samsung disagrees. As
`
`explained in detail by the PTAB in the Final Written Decision in SAP America,
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`Inc. v. Versata Development Group, Inc., No. CBM2012-00001, Paper No. 70, at
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`7-19 (PTAB June 11, 2013), the PTO’s broadest reasonable construction standard
`
`is in accordance with the law.
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`Furthermore, B.E. cannot demonstrate that a different claim construction
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`standard would result in a different outcome. Indeed, even under the district court
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`standard set forth in Phillips, Kikinis still anticipates claims 2-3 of the ‘290 patent.
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`In fact, as shown above, under either claim construction standard, Kikinis discloses
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`all elements of claims 2-3, including the disputed claim elements of (a) “a program
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`stored on the non-volatile storage device” that performs the functions claimed in
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`claim 2, (b) “said program further being operable in response to selection by a user
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`of one of the user links to access the file associated with the selected user link from
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`the user ...”, and (c) the claimed “user profile”.
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`III. CONCLUSION
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`For at least the foregoing reasons, Samsung respectfully submits that claims
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`2 and 3 of the ’290 patent are unpatentable over Kikinis.
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`Respectfully submitted,
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`GREENBERG TRAURIG, LLP
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`Date: September24. 2014
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`3
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`\J \
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`E E
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`Heath J. Briggs
`Registration No. 54,919
`1200 17”‘ Street, Suite 2400
`Denver, CO 80202
`Phone: (303) 572-6500
`Fax:(303)572-6540
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`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 24th day of September 2014, a copy of
`
`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE TO PETITION
`
`FOR INTER PARTES REVIEW has been served on Patent Owner as provided
`
`in 37 C.F.R. § 42.6(e) Via electronic mail transmission addressed to the person(s)
`
`at the below address(es):
`
`Jason S. Angell (Reg. No. 51408)
`1' angell@fawlaw.com
`beiplaw@,fawlaw.com
`FREITAS ANGELL & WEINBERG LLP
`
`350 Marine Parkway, Suite 200
`
`Respectfully submitted,
`
`GREENBERG TRAURIG, LLP
`
` Date: September 24, 2014
`
` Heath J. Briggs
`Registration No. 54,919
`1200 17”‘ Street, Suite 2400
`Denver, CO 80202
`Phone: (303) 572-6500
`Fax: (303) 572-6540
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