Attorney Docket No. FABO‐027/01US
`(309101‐2067)
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`IPR2014‐00052
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
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`PATENT TRIAL AND APPEAL BOARD
`____________________
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`FACEBOOK, INC.,
`Petitioner
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`v.
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`B. E. TECHNOLOGY LLC
`Patent Owner
`
`_______________________
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`Case No. IPR2014‐00052
`Patent No. 6,628,314
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`____________________________________________________________
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`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE
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`(309101‐2067)
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`IPR2014‐00052
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`PATENT TRIAL AND APPEAL BOARD
`____________________
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`FACEBOOK, INC.,
`Petitioner
`
`v.
`
`B. E. TECHNOLOGY LLC
`Patent Owner
`
`_______________________
`
`Case No. IPR2014‐00052
`Patent No. 6,628,314
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`
`____________________________________________________________
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`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE
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`Attorney Docket No. FABO‐027/00US
`(309101‐2067)
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`IPR2014‐00052
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`TABLE OF CONTENTS
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`Page
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`I.
`II.
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`III.
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`IV.
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`V.
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`B.
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`C.
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`INTRODUCTION ............................................................................................. 1
`SHAW DISCLOSES EVERY LIMITATION OF CLAIM 11 ..................................... 2
`A.
`Claim 11 Does Not Require that the Unique Identifier be
`Provided “By The Server” ................................................................... 3
`Claim 11 Does Not Require that the Unique Identifier Identify
`the Computer ..................................................................................... 5
`The Unique Identifier in Shaw “Uniquely Identifies
`Information” Sent Over the Network to the Server ........................... 6
`The PTO Already Rejected the Patent Owner’s Arguments
`About the Lack of a “Unique Identifier” in Shaw ................................ 7
`ALL CHALLENGED CLAIMS ARE OBVIOUS OVER SHAW IN VIEW OF
`W3C .............................................................................................................. 9
`THE PATENT OWNER’S “BROADEST REASONABLE INTERPRETATION”
`ARGUMENTS ARE NOT RELEVANT TO THIS PETITION ................................. 13
`CONCLUSION .............................................................................................. 14
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`D.
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`i
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`IPR2014‐00052
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`TABLE OF AUTHORITIES
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`Page(s)
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`Cases
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`Intamin Ltd. v. Magnetar Techs., Corp.,
`483 F.3d 1328 (Fed. Cir. 2007) ............................................................................ 6
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`K‐2 Corp. v. Salomon S.A.,
`191 F.3d 1356 (Fed. Cir. 1999) ............................................................................ 4
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`On‐Line Techs., Inc. v. Bodenseewerk Perkin‐Elmer GmbH,
`386 F.3d 1133 (Fed. Cir. 2004) ........................................................................ 5, 6
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`Phillips v. AWH Corp.,
`415 F.3d 1303 (Fed. Cir. 2005) (en banc) .......................................................... 14
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`SAP America, Inc. v. Versata Develop. Group, Inc.,
` CBM2012‐00001, Paper 70, 19 (June 11, 2013) ............................................... 13
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`Superguide Corp. v. DirecTV Enters., Inc.,
`358 F.3d 870 (Fed. Cir. 2004) .............................................................................. 4
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`Taurus IP, LLC v. DaimlerChrysler Corp.,
`726 F.3d 1306 (Fed. Cir. 2013) ............................................................................ 4
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`In re Trans Texas Holdings Corp.,
`498 F.3d 1290 (Fed. Cir. 2007) ............................................................................ 4
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`Statutes
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`35 U.S.C. § 103(a) ..................................................................................................... 1
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`Other Authorities
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`37 C.F.R. § 42.65(a) ................................................................................................ 10
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`ii
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`I.
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`INTRODUCTION
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`The Board instituted inter partes review of claims 11‐13, 15, 18 and 20
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`based obviousness over Shaw [Ex. 1103] in view of W3C [Ex. 1105]. The patent
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`owner’s response (“Response”) does not dispute key elements of the Petition.
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`The patent owner does not dispute that Shaw and W3C qualify as prior art to the
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`’314 patent and does not challenge the Board’s claim constructions in the
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`Decision instituting inter partes review. The patent owner also does not dispute
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`that Shaw and W3C disclose every limitation of claims 11‐13, 15, 18 and 20.
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`The patent owner instead rests its entire response on two meritless
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`arguments. First, the patent owner contends that Shaw does not disclose the
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`step of “providing a unique identifier to the computer,” as recited in independent
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`claim 11. But in making this argument, the patent owner seeks to improperly
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`import limitations that do not appear in the claim language. Shaw plainly
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`discloses this limitation.
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`Second, although the patent owner does not dispute that W3C discloses
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`the unique identifier allegedly missing from Shaw, the patent owner asserts that
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`Shaw and W3C cannot properly be combined under 35 U.S.C. § 103(a). The
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`patent owner offers no evidence or meaningful analysis to support this
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`undeveloped argument. Because the patent owner has offered no serious
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`1
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`rebuttal to the obviousness of claims 11‐13, 15, 18 and 20 over Shaw in view of
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`IPR2014‐00052
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`W3C, the Board should find them unpatentable.
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`II.
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`SHAW DISCLOSES EVERY LIMITATION OF CLAIM 11.
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`The patent owner identifies only one limitation allegedly missing from
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`Shaw – the step of “providing a unique identifier to the computer, wherein said
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`identifier uniquely identifies information sent over said computer network from
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`the computer to said server,” as recited in claim 11f. (Response at 5.)1
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`As explained in the Petition, and not disputed by the patent owner, Shaw
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`discloses an identifier in the form of an e‐mail address (also referred to as a user
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`name) that is unique to each member. (Petition at 16 (citing Shaw, Ex. 1103, Col.
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`1:47‐48, 12:6‐13).) The system in Shaw uses this e‐mail address to authenticate
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`the user with the server and to uniquely identify information sent by the user’s
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`computer to the server. (Id. (citing Shaw, Ex. 1103, Col. 18:39‐56).)
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`1 As noted in the text, the patent owner does not dispute that this limitation is
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`disclosed in the W3C Submission, and does not dispute that the combination of
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`Shaw and the W3C Submission discloses all limitations of claims 11‐13, 15, 18 and
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`20. Accordingly, even if the Board were to conclude that this limitation was
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`missing from Shaw, the challenged claims should still be found unpatentable.
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`2
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`The patent owner contends that this e‐mail address “does not meet the
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`claim limitation because the e‐mail address is not ‘provided’ to the computer by
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`the server and the e‐mail address identifies the user, not the computer.”
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`(Response at 5.) Because these arguments depend on an erroneous construction
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`of the providing step in claim 11f, they should be rejected.
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`A.
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`Claim 11 Does Not Require that the Unique Identifier be Provided
`“By The Server”
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`Nothing in the language of claim 11 supports the patent owner’s argument
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`that the server must perform the step of “providing a unique identifier to the
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`computer.” The plain language of claim 11f simply requires that the unique
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`identifier be “provid[ed] . . . to the computer.” It does not mandate that the
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`unique identifier be provided by any particular system, process or entity.
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`The step of “providing” occurs in Shaw when the client program running on
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`the computer is furnished with the user’s e‐mail address when the user signs up.
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`(Petition, at 17 (quoting Shaw, Ex. 1103, Col. 12:6‐13).) The signup process
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`described in Shaw plainly results in the unique identifier being provided to the
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`computer. The fact that the e‐mail address may not have been originally provided
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`by the server is irrelevant because the claim imposes no such requirement.
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`The patent owner argues that that the specification of the ’314 patent
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`describes an embodiment in which “the unique identifier is ‘provided’ to the
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`computer by the server.” (Response at 5.) But the Federal Circuit has repeatedly
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`warned against importing limitations from the specification into the claim. See,
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`e.g., In re Trans Texas Holdings Corp., 498 F.3d 1290, 1299 (Fed. Cir. 2007);
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`Superguide Corp. v. DirecTV Enters., Inc., 358 F.3d 870, 875 (Fed. Cir. 2004)
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`(“Though understanding the claim language may be aided by the explanations
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`contained in the written description, it is important not to import into a claim
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`limitations that are not a part of the claim.”). The patent owner offers no
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`justification for importing a “by the server” requirement into claim 11f.
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`The fact that claim 11 specifically calls out that the unique identifier must
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`be provided “to the computer,” but remains silent on where identifier comes
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`from, provides powerful evidence that the claim imposes no such requirement.
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`Had the inventor intended to limit the entity or computer from which the unique
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`identifier is provided, he certainly could have specified as much in the claim
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`language. The patent owner’s “by the server” argument is little more than an
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`improper attempt to rewrite claim 11f through claim construction that must be
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`rejected. See, e.g., Taurus IP, LLC v. DaimlerChrysler Corp., 726 F.3d 1306, 1321
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`(Fed. Cir. 2013) (“Courts do not rewrite claims; instead, we give effect to the
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`terms chosen by the patentee.”) (quoting K‐2 Corp. v. Salomon S.A., 191 F.3d
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`4
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`1356, 1364 (Fed. Cir. 1999)). Shaw therefore discloses the step of “providing a
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`unique identifier to the computer” as recited in claim 11.
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`B.
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`Claim 11 Does Not Require that the Unique Identifier Identify the
`Computer
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`Nor is there any merit to the patent owner’s assertion that claim 11f
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`requires the “unique identifier” to be a computer identifier. (Response at 6.) The
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`claim language simply recites “providing a unique identifier to the computer,” but
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`does not require that the unique identifier identify the computer itself. The
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`broadest reasonable construction of claim 11 plainly covers a unique user
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`identifier that is provided to the computer, as disclosed in Shaw.
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`This is confirmed by the ’314 specification, which discloses a user identifier
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`in its description of the “unique identifier” recited in claim 11. (’314, Ex. 1101,
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`Col. 17:29‐47 (“The user ID that is stored along with the demographic data is used
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`to anonymously identify the user for the purpose of demographically targeting
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`advertising to that user…. In the illustrated embodiment, the user ID is associated
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`with a user login that is required each time the client software application is
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`executed.”) (emphasis added); see also Ex. 1101, Fig. 8 (item 140: “assign unique
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`ID to user.”).) Federal Circuit law is clear that claims generally should not be
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`interpreted to exclude embodiments disclosed in the specification. See, e.g., On‐
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`5
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`Line Techs., Inc. v. Bodenseewerk Perkin‐Elmer GmbH, 386 F.3d 1133, 1138 (Fed.
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`Cir. 2004). The ’314 specification’s use of “user ID” to describe the claimed
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`unique identifier unequivocally confirms that the user identifier in Shaw meets
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`the unique identifier limitation in claim 11.2
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`C.
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`The Unique Identifier in Shaw “Uniquely Identifies Information”
`Sent Over the Network to the Server
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`Finally, the patent owner presents a cursory and undeveloped argument
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`that the e‐mail address in Shaw “does not uniquely identify information sent from
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`the computer to the server.” (Response at 6.) The patent owner bases this
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`argument on the assertion that “there may be more than one user on a client
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`computer,” and thus, the e‐mail address does not uniquely
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`2 Further support is provided by dependent claim 16, which recites a step in which
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`identify the
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`the software “requires a user to login to use said software and associates a
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`different unique identifier with each of a number of valid users.” (’314, Ex. 1101,
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`Col. 23:20‐24.) Dependent claim 16 therefore makes clear that user identifiers fall
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`within the scope of the “unique identifier” recited in independent claim 11. See
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`Intamin Ltd. v. Magnetar Techs., Corp., 483 F.3d 1328, 1335 (Fed. Cir. 2007)
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`(interpreting independent claim to include subject matter recited in on of its
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`narrower dependent claims).
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`6
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`information sent from the computer to the server. (Id.)
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`This argument fails for reasons similar to the two other arguments
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`addressed above. The claim language merely requires that the information sent
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`by the computer – not the computer itself – be uniquely identified by the unique
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`identifier. As explained above, the ’314 specification makes clear that a user
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`identifier can uniquely identify information sent from the computer to the server.
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`The e‐mail address (unique identifier) in Shaw clearly meets the claim limitation.
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`For example, once Shaw’s unique identifier is issued to the user, it is passed
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`from the client to the server when an e‐mail is sent or received, uniquely
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`identifying the user and connecting the client system to the appropriate mail
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`server. (Shaw, Ex. 1103, Col. 18:34‐56.) The unique user identifier in Shaw also
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`uniquely identifies user profile information and user statistics when those files are
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`sent from the client to the server. (Id., Col. 6:21‐29, Fig. 11.) Shaw therefore
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`discloses this requirement.
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`D.
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`The PTO Already Rejected the Patent Owner’s Arguments About the
`Lack of a “Unique Identifier” in Shaw
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`The patent owner also failed to inform the Board that it previously but
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`unsuccessfully presented substantially the same argument about Shaw that it
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`presents here. In particular, the patent owner filed U.S. Patent Appl. No.
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`7
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`13/107,231 on May 13, 2011, claiming priority as a continuation to the parent
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`application of the ’314 patent. (’231 Appl. Data Sheet, Ex. 1138, 3 (claiming
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`priority to prior application 09/118,351).) The ’231 application contained a single
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`independent claim similar to claim 11 of the ’314 patent that included a
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`requirement of a “unique
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`identifier” that uniquely
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`identifies
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`information
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`transferred over the computer network. (’231 Appl. Non‐Final Rejection, Ex.
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`1139, 2‐4.) The Examiner rejected that claim based on Shaw and the patent
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`owner responded by arguing – as it does here – that Shaw does not disclose a
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`unique identifier used to uniquely identify information sent over the computer
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`network. (’231 Appl. Amendment & Response, Ex. 1140, 4.)3 The Examiner
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`rejected that argument. (’231 Appl. Non‐Final Rejection, Ex. 1139, 3‐5) (citing
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`Shaw, Ex. 1103, Cols. 5:5‐30, 10:36‐63, 12:6‐65, 18:34‐19:43, 20:28‐21:12).) The
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`patent owner responded by abandoning that application. (’231 Application
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`Notice of Abandonment, Ex. 1141, 2.)
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`The patent owner failed to notify the Board of the Examiner’s conclusions
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`3 Although Shaw was discussed during prosecution of the ’231 application, it was
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`not cited or discussed during the prosecution of the ’314 patent challenged in this
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`inter partes review.
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`and the subsequent abandonment of the ’231 application, presumably because
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`these facts undermine the patent owner’s arguments in these proceedings. In
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`any event, as the Examiner correctly concluded in the context of the ’231
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`application, Shaw satisfies the “unique identifier” limitation. Shaw therefore
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`discloses all of the limitations of claim 11, rendering the claim unpatentable.
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`III.
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`ALL CHALLENGED CLAIMS ARE OBVIOUS OVER SHAW IN VIEW OF W3C
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`The patent owner presents an exceedingly narrow challenge to a finding of
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`obviousness based on the combination of Shaw and W3C. Critically, the patent
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`owner does not dispute that Shaw and W3C collectively disclose all limitations of
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`claims 11‐13, 15, 18 and 20. (Response at 5‐6.) The claims must be found
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`unpatentable, therefore, if the Board determines that it would have been obvious
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`for a person of ordinary skill in the art to have combined Shaw and W3C.
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`Based on a series of conclusory statements unsupported by any evidence or
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`reasoned analysis, the patent owner contends a person of ordinary skill in the art
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`would not have found the two references combinable. (Response at 7; Goldstein
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`Decl., Ex. 2001, ¶¶ 23‐24.) None of the patent owner’s arguments has merit.
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`First, the patent owner contends that the personal profile system discussed
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`in W3C would not have been useful to Shaw because “Shaw is not dependent on
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`navigating multiple websites.” (Goldstein Decl., Ex. 2001, ¶ 23.)4 But Shaw
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`specifically teaches that it can be used with web pages. (Petition at 18; Shaw, Ex.
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`1103, Col. 23:64‐24:4.) The patent owner also does not dispute the Petitioner’s
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`unrefuted evidence that Shaw and the W3C Submission are technologically
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`compatible. (Sherwood Decl., Ex. 1111, ¶ 54.)
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`The patent owner’s focus on the multiple web site capabilities of the W3C
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`Submission, in fact, highlights the motivations to combine. As explained in the
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`Petition, the W3C Submission discloses a system for maintaining and sharing
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`profile and demographic targeting information across multiple different websites.
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`(Petition at 18.) Because the demographic profile in the W3C Submission was the
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`result of user interactions with numerous different websites, that profile would
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`have been far more developed than the profile accumulated through use of just
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`one website. As explained in the Petition and not disputed by the patent owner,
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`4 The portions of the Goldstein Declaration cited in the Response consist entirely
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`of conclusory statements unsupported by analysis or citation to evidence.
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`(Goldstein Decl., Ex. 2001, ¶¶ 23‐24.) The Board should give no weight to them.
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`See 37 C.F.R. § 42.65(a) (“Expert testimony that does not disclose the underlying
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`facts or data on which the opinion is based is entitled to little or no weight.”).
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`a person of ordinary skill in the art would have recognized that the more detailed
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`profile in the W3C Submission would have allowed Shaw “to draw upon a richer
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`and more complete set of profile information the user has accumulated,” thus
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`resulting in improved and more accurate targeting advertising. (Id. at 19.) A
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`person of ordinary skill in the art would have also considered the unique identifier
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`in the W3C Submission to be a fully interchangeable and known alternative to the
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`identifier in Shaw. (Sherwood Decl., Ex. 1111, ¶¶ 53‐56.)
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`The patent owner next contends that a person of ordinary skill in the art
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`“would find it imprudent to adopt [the W3C Submission] schema before it was
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`officially approved.” (Goldstein Decl., Ex. 2001, ¶ 24.) But the patent owner
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`apparently did not closely review the W3C Submission, because the document
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`makes clear that it was not the type of formal industry standard that had to go
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`through an official approval process.
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`The first page of the W3C Submission identifies it as an informational
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`“NOTE” submitted by Microsoft “for discussion only.” (Ex. 1105, at 1 (under
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`“Status of this Document”).) The classification as a “NOTE,” according to the
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`document, “indicates no endorsement of its content, nor that the Consortium
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`has, is, or will be allocating any resources to the issues addressed by the NOTE.”
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`(Id. (emphasis added).) The W3C Submission therefore never contemplated any
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`11
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`formal or official approval process by the Consortium. Accordingly, there is no
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`basis for the patent owner’s speculation that a person of ordinary skill in the art
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`“would find it imprudent to adopt [the W3C Submission] schema before it was
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`officially approved.” (Goldstein Decl., Ex. 2001, ¶ 24.)
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`The W3C Submission goes on to further refute the patent owner’s
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`assumption of a formal “approval” process by emphasizing that the proposed
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`profile leveraged existing and well‐established Internet standards. As explained in
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`the W3C Submission: “This document shows that it is possible to leverage
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`existing Internet standards and proposals to provide sites access to demographic
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`and other personal profile information while placing users in control of how this
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`information is disclosed.” (Ex. 1105, at 2 (top of page) (italics in original).) The
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`document explained that “[i]t is important to use existing file formats and
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`protocols to ensure cross‐industry support and to ensure interoperability with
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`existing or new software products.” (Id., at 3, § 1.3 (italics in original).) The fact
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`that the W3C Submission
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`is built atop existing, well‐known and mature
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`technologies refutes the patent owner’s conclusory assertion that a person of
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`ordinary skill in the art would have found it “imprudent” to implement it.
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`Finally, Microsoft issued a press release contemporaneously with the W3C
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`Submission outlining the “broad industry support” for Microsoft’s privacy
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`12
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`proposals, including the profile system disclosed in the document. (Microsoft
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`Announcement, Ex. 1142.) The broad level of support Microsoft received for its
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`W3C proposals fatally undermines the patent owner’s speculation that a person
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`of ordinary skill in the art would have found it “imprudent” to implement them, or
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`would have felt the need to await the completion of a non‐existent approval
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`process. Based on all of the foregoing, therefore, the patent owner has done
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`nothing to refute the ample motivations to combine Shaw and W3C.
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`IV.
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`THE PATENT OWNER’S “BROADEST REASONABLE
`ARGUMENTS ARE NOT RELEVANT TO THIS PETITION
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`INTERPRETATION”
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`The patent owner asserts that the Board’s application of the broadest
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`reasonable interpretation (“BRI”) standard for construing claims exceeds the
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`PTO’s rule‐making authority. (Response at 7‐9.) The Board already rejected this
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`argument in SAP America, Inc. v. Versata Develop. Group, Inc., CBM2012‐00001,
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`Paper 70, 19 (June 11, 2013) (“[T]he broadest reasonable interpretation standard
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`is the one correct standard for post grant reviews.”). No further discussion is
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`warranted here.
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`The patent owner has failed to show that the claim construction standard
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`applied by the Board would have any impact in this proceeding. The patent
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`owner did not specifically address any claim construction issues in its Response
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`and did not, for example, show that the Board would interpret any claim
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`differently if it employed the standards applicable to district court litigation under
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`Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (en banc). The Board
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`therefore need not reach this issue because even if the patent owner’s legal
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`argument about the BRI standard had merit, it would have no impact on the
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`outcome of the trial.
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`V.
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`CONCLUSION
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`For the reasons set forth above, and based on the Petition and all of the
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`evidence of record, claims 11‐13, 15, 18, and 20 of the ’314 patent are
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`unpatentable as obvious in view of Shaw and the W3C Submission. Accordingly,
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`all of the challenged claims should be cancelled.
`
`Date: September 24, 2014
`
`/Heidi L. Keefe/
`Heidi L. Keefe
`Reg. No. 40,673
`
`
`
`
`
`COOLEY LLP
`ATTN: Heidi L. Keefe
`Patent Docketing
`1299 Pennsylvania Ave. NW, Suite 700
`Washington, D.C. 20004
`Tel: (650) 843‐5001
`Fax: (650) 849‐7400
`
`
`
`
`
`
`14
`
`
`
`
`
`Attorney Docket No. FABO‐027/01US
`(309101‐2067)
`
`
`
`
`IPR2014‐00052
`
`CERTIFICATE OF SERVICE
`
`
`I hereby certify, pursuant to 37 CFR section 42.6, that a complete copy of
`
`the attached PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE, including all
`exhibits and related documents, is being served electronically on the 24th day of
`September, 2014, the same day as the filing of the above‐identified document in
`the United States Patent and Trademark Office/Patent Trial and Appeal Board,
`upon the patent owner’s counsel of record as follows:
`
`Jason S. Angell
`Freitas Angell & Weinberg LLP
`350 Marine Parkway, Suite 200
`Redwood Shores, CA 94065
`BEIPRFTK@ftklaw.com
`
`
`/Heidi L. Keefe/
`Heidi L. Keefe
`Reg. No. 40,673
`
`
`
`COOLEY LLP
`ATTN: Heidi L. Keefe
`Patent Docketing
`1299 Pennsylvania Ave. NW, Suite 700
`Washington, D.C. 20004
`Tel: (650) 843‐5001
`Fax: (650) 849‐7400
`
`
`
`
`
`109928336 v4
`
`
`
`
`15
`
`
`
`
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