Paper No. ________
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
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`MOTOROLA MOBILITY LLC, GOOGLE INC. AND APPLE INC.
`Petitioners
`v.
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`ARENDI S.A.R.L.
`Patent Owner
`
`
`
`______________________________
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`Case IPR2014-00203
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`Patent 8,306,993 B2
`______________________________
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`____________________________________________________________
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`REQUEST FOR REHEARING PURSUANT TO 37 C.F.R. § 42.71(c)
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`MOTOROLA MOBILITY LLC, GOOGLE INC. AND APPLE INC.
`Petitioners
`v.
`
`ARENDI S.A.R.L.
`Patent Owner
`
`
`
`______________________________
`
`Case IPR2014-00203
`
`Patent 8,306,993 B2
`______________________________
`
`
`____________________________________________________________
`
`
`REQUEST FOR REHEARING PURSUANT TO 37 C.F.R. § 42.71(c)
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`TABLE OF CONTENTS
`TABLE OF CONTENTS
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`SUMMARY ..................................................................................................... 1
`SUMMARY ................................................................................................... ..l
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`ARGUMENT ................................................................................................... 1
`ARGUMENT ................................................................................................. ..1
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`I.
`I.
`
`II.
`II.
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`A. Grounds 1 and 2 (Bonura in view of Magnanelli) meet the claim
`A. Grounds 1 and 2 (Bonura in view of Magnanelli) meet the claim
`construction proposed by the Patent Owner. .................................................. 1
`construction proposed by the Patent Owner................................................. ..l
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`1. Overview of the argument for Grounds 1 and 2 in the Petition. ................ 2
`1. Overview of the argument for Grounds 1 and 2 in the Petition............... ..2
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`2. Detailed discussion—express motivation to combine. .............................. 3
`2. Detailed discussion—express motivation to combine. ............................ ..3
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`3. Detailed discussion—obviousness under KSR v. Teleflex ......................... 9
`3. Detailed discussion—obviousness under KSR v. Teleflex ....................... ..9
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`B. The Patent Owner's proposed construction is not the broadest reasonable
`B. The Patent Owner's proposed construction is not the broadest reasonable
`construction consistent with the specification..............................................13
`construction consistent with the specification ............................................ .. 13
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`CERTIFICATE OF SERVICE .................................................................................. i
`CERTIFICATE OF SERVICE ................................................................................ .. i
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`ii
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`Petitioners respectfully request rehearing of the "Decision Denying Institution
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`of Inter Partes Review", issued June 5, 2014 ("June 5 Decision"). Petitioners focus
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`on Grounds 1 and 2 to limit the length of the request.
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`I.
`
`SUMMARY
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`Petitioners respectfully ask the panel to consider: (A) whether the panel
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`appreciated the nature of the Petitioners' arguments under 35 U.S.C. § 103 with
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`respect to Grounds 1 and 2 (based on the combination of Bonura and Magnanelli);
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`(B) whether the panel adopted the broadest reasonable construction consistent with
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`the specification for the "allowing the user…." claim limitation.
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`II. ARGUMENT
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`A. Grounds 1 and 2 (Bonura in view of Magnanelli) meet the claim
`construction proposed by the Patent Owner.
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`The June 5 Decision declined to adopt Grounds 1 and 2 based on the limitation:
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`"allowing the user to make a decision whether to store at least part of
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`the first contact information in the contact database as a new contact
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`or to update an existing contact in the contact database".
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`This limitation will be referred to in this request as "the allowing limitation".
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`The June 5 Decision adopted the Patent Owner's construction of the "allowing
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`limitation", finding that it meant "presenting to the user a choice between
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`competing alternatives of storing a new contact or updating an existing contact."
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`(June 5 Decision, p. 11).
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`
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`1
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`
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`The June 5 Decision then found that (1) neither Bonura nor Magnanelli
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`disclosed the allowing limitation in full, and (2) that the Petitioners had not:
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`"provided a reason why a person of ordinary skill in the art would
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`modify the combination to arrive at the claimed invention and, in
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`particular, the single step of making a single decision whether to store
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`contact information as a new contact or, alternatively, to update an
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`existing contact." (June 5 Decision, p. 16).
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`The quoted holding is, respectfully, clearly erroneous. The Petition provided
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`extensive motivation to reach even the Patent Owner's strict construction.
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`1. Overview of the argument for Grounds 1 and 2 in the Petition.
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`The Petition's argument under Grounds 1 and 2 will be presented in detail
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`below, but can be summarized as follows: Bonura is the base system. The Bonura
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`base system scans documents (in a manner that meets the other elements of the
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`claims) for information of a specific types. When these specific types of
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`information are found, Bonura presents the user with a pop-up menu of options to
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`choose from. The user chooses between the options in the pop-up menu—and thus
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`the options are "competing alternatives". The Petition further demonstrated that
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`when the information is contact information, there was motivation to present both
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`"storing" and "updating" options to the user. The storing option was motivated by
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`Bonura itself, while the "updating" option was motivated by Magnanelli. (Petition,
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`pp. 12-21). Thus, while neither Bonura nor Magnanelli, standing alone, taught the
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`2
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`
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`"allowing" limitation as construed in the June 5 Decision, the Petition presented
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`strong motivation to combine Bonura and Magnanelli in a way that meets the
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`"allowing" limitation. The full reasoning and its support in the Petition will be
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`presented in detail in the next section.
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`It is noted that the panel may not have focused on the argument described
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`above. The June 5 Decision only makes reference to the Petition's element-by-
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`element analysis (i.e. its claim chart). (June 5 Decision, p. 15)("The Petition, in its
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`element-by-element mapping, asserts this limitation is taught or suggested by…").
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`The most relevant discussion in the Petition, however, was found in the section of
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`Ground 1 before the claim chart. Petition, pp. 12-21. The June 5 Decision did not
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`address the reasoning presented on pages 12-21 of the Petition. Petitioners
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`respectfully remind the panel that Petitioners were not allowed to put motivation to
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`combine arguments in the claim charts (even though the arguments were double-
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`spaced). See Notice of Filing Date Accorded, Dec. 12, 2013, p. 2.
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`2. Detailed discussion—express motivation to combine.
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`The Petition presented a detailed motivation to reach even the Patent Owner's
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`strict construction of the allowing limitation. The Petition first put forward Bonura
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`as a base system. (Petition, pp. 12, 17). As stated in the Petition, the base system
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`of Bonura recognizes text within a document according to the other elements of the
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`claims, and provides the user with a number of choices that are appropriate for the
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`3
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`context. The Petition stated:
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`"Bonura discloses a base system that provides semantically
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`appropriate choices to a user upon the identification in a document of
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`certain kinds of structures." (Petition, p. 17)(emph. add.).
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`In other words, Bonura recognizes "structures" in a document (like addresses)
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`and offers the user a set of choices. The choices reflect different software actions
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`that could be executed. The choices are presented to the user in the form of a
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`menu. The Petition starting at the bottom of page 12 quoted Bonura, saying:
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`"Small pieces of code can then be associated with each structure to
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`instruct applications to carry out specific user actions on the
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`discovered structures—perhaps to tell a telephony application to 'Dial
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`this phone number.' These actions can then be offered to users by
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`visually highlighting the discovered structures and attaching pop-up
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`menus to the highlights." (Petition, pp. 12-13; 17-18)(emph. add.).
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`Such a pop-up menu is shown in Fig. 2 of Bonura, which was reproduced on
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`page 14 of the Petition. The pop-up menu of
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`Figure 2 is also shown at right, taken from the
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`better copy in the June 5 Decision. The pop-up
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`menu of Figure 2 has four potential choices, and
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`(as shown by red highlighting) instructs the user to "please select an action".
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`Thus, Bonura teaches a system where a document is being analyzed to identify
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`structures (e.g. contact information) as provided by the claims, and where a user is
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`4
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`presented with a menu of potential actions to choose between. This was not found
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`otherwise in June 5 Decision. (pp. 12-13).
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`This alone does not make out a case for obviousness, but Petition went much
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`further. The Petition demonstrated that the choices in the menu triggered the
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`execution of software modules. The Petition stated:
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`"Bonura further teaches that, as an extension of LiveDoc, the
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`disclosed 'Drop Zones' system can cause processing functions
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`(executable code) to be associated with the identification of such
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`contact information." (Petition, p. 17).
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`These processing functions were the "small pieces of code" referred to in the
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`quote on p. 4, above (Petition, pp. 14, 17). These small pieces of code are
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`executed by choices in the menu. (Petition, pp. 12-13 and 17-18)("Small pieces of
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`code can then be associated with each structure… to carry out specific user
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`actions….These actions can then be offered to users by visually highlighting the
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`discovered structures and attaching pop-up menus….")(emph. add.).
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`The Petition next showed that the set of these actions (small pieces of code)—
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`and consequently the items in the pop-up menu—were customizable. The
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`developer could, in fact, add whatever actions she wished. The point of the Bonura
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`system was to help manage the wide variety of actions that developers would think
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`up, by ensuring that the actions made sense for a particular piece of information
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`found in a document. The Petition stated:
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`5
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`"Bonura explains that the code that can be associated with
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`particular structures is more-or-less arbitrary. Ex. 1002 at ¶ 127.
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`In fact, developers could develop so many different functions to be
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`executed based on the identification of a particular structure in a
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`document that the choice between them would threaten to overwhelm
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`the user. Ex. 1006, p. 59, right column. To assist in selecting the
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`appropriate functions for any given situation, Bonura described a
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`contextual, semantic process for choosing functions to associate with
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`certain structures. That is, Bonura teaches extending the functions
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`available to a user upon automatic recognition of structures in a
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`document, while still making sure that the functions available are
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`appropriate for the context. Ex. 1002 at ¶ 127." (Petition, p. 18).
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`Not only did the Petition show that Bonura intended the actions in the pop-up
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`menu to be customizable, the Petition provided extensive evidence showing that
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`the requisite skill existed in the art to add actions to Bonura's set of choices.
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`(Petition, p. 21 at top, citing Allison Decl Ex. 1002, ¶136). Mr. Allison's
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`declaration at ¶¶19-37 (referenced in ¶136) provided a well-substantiated list of
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`skills that a person of ordinary skill would have had. The Patent Owner did not
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`dispute that the requisite skill existed to extend Bonura's set of choices.
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`After demonstrating that Bonura taught a pop-up menu, that the menu was
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`intended to be customized, and that the requisite skill existed for the customization,
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`the Petition next showed that there was express motivation to add both a storing
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`and an updating option. (Petition, pp. 17-21). The "storing" option was motivated
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`6
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`by Bonura itself. The Petition demonstrated that Bonura taught that "thinking
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`about this [contact] information from the perspective of an address book easily
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`leads to the interpretation, 'Add this person to my address book'." (Petition,
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`pp. 18-19). This was accepted by the June 5 Decision (p. 15).
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`The Petition also demonstrated express motivation to add an "updating" option
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`based on Magnanelli. The Petition first noted that Magnanelli was quite similar to
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`(and thus compatible with) Bonura. Magnanelli, like Bonura, identified contact
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`information in a document, and allowed the user to take specific actions. (Petition,
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`pp. 15-16 and 19)("Magnanelli likewise teaches actions that would be appropriate
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`and desirable to carry out when contact information is discovered in a document.").
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`The Petition then showed that Magnanelli provided motivation to add an
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`"updating option". Specifically, the Petition quoted Magnanelli's statement that
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`offering the user an option to update was a value-added service:
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`"'The Academia agent provides a value-added service by using
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`information extracted from Web documents to maintain the database
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`and ensure its currency. The agent may either update the database
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`directly, or consult with the user as to whether or not it should
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`perform the updates.'" (Petition, p. 16)(emph. add.).
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`The Petition also noted that, in the context of contact information, it would have
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`made sense to extend Bonura by "adding another sensible option associated
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`7
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`with locating contact information" (Petition, p. 20). As stated in the Petition,
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`this would have achieved the "value-added" benefit expressly of Magnanelli:
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`"Thus, adding Magnanelli's contact information update option to the
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`system of Bonura represents an extension of Bonura in the manner in
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`which Bonura was intended to be extended (by adding another
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`sensible option associated with locating contact information). Ex.
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`1002 at ¶ 134. Furthermore, Bonura quite reasonably states that
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`considering recognized contact information in the context of an
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`address book "easily leads to the interpretation, 'Add this person to my
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`address book'". Ex. 1002 at ¶ 134. Adding a record to an address book
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`is technically very similar to updating a record in an address book. Ex.
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`1002 at ¶ 134. The combination would have led to the express
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`"value-added" benefit taught by Magnanelli of keeping the
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`address book current. Magnanelli, Ex. 1007, p. 00002, right column;
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`Ex. 1002 at ¶ 134." (Petition, p. 20)(emph. add.).
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`Thus, the Petition provided an express motivation to add a "storing" option to
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`Bonura's menu (i.e. because Bonura itself says that a storing option is "easily"
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`conceived). The Petition provided express and implied motivation to further add
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`"another sensible option" (updating). The express motivation was that
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`Magnanelli taught that an updating option was valuable for maintaining a contact
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`database. (Petition, pp. 19-20). The implied reason was that Bonura taught that
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`"storing" was easily conceived, and updating is technically very similar to storing.
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`(id.).
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`8
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`Given Bonura's presentation of choices in a menu, it is difficult to see how the
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`combination proposed in the Petition would not meet the Patent Owner's
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`construction of "presenting to the user a choice between competing alternatives of
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`storing a new contact or updating an existing contact." The user of the Bonura
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`system (as extended with an updating option per Magnanelli) is presented with
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`menu of choices, which is an offer for the user to choose between the actions in the
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`menu. Hence, the actions are "competing alternatives". This is visible directly
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`from Fig. 2, which directs the user to "Please select an action". (Petition, p. 14).
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`Whatever the panel may ultimately conclude from the reasoning in the Petition,
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`it was clear error to hold that the Petition provided no reason to combine "storing"
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`and "updating" options into a competitive choice. (June 5 Decision, p. 16). The
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`Petitioners further respectfully submit that, even under the Patent Owner's
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`construction, the Petition raises a reasonable likelihood of success for the Ground 1
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`and Ground 2 claims.
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`3. Detailed discussion—obviousness under KSR v. Teleflex
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`The Petition went further by (alternatively) making an obviousness case under
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`KSR v. Teleflex. (Petition, pp. 20-21). The Petition stated:
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`"Furthermore, Bonura was a known system, and Magnanelli's
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`approach to updating contacts represented a known technique
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`that could have been applied to Bonura's system, without any
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`unpredictable results. Ex. 1002 at ¶ 135. At the level of the claims of
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`9
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`the '993 patent, the relevant field is predictable. Id. None of the '993
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`patent, Bonura nor Magnanelli report any unpredictable results. See
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`KSR Int'l Co. v. Teleflex, Inc., 550 U.S. 398, 416-19 (2007). The
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`combination would have been well within the ordinary skill in the
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`art in the relevant timeframe." (Petition, pp. 20-21)(emph. add.)
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`This case meets the Supreme Court's test set forth in KSR. There, the Court
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`held that "[t]he combination of familiar elements according to known methods
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`is likely to be obvious when it does no more than yield predictable results."
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`KSR Int'l Co. v. Teleflex, Inc., 550 U.S. 398, 416 (2007).
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`The Petition demonstrated that the '993 patent was (1) a combination of
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`familiar elements (2) according to known methods that (3) yielded a
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`predictable result. When these three conditions are met, the Supreme Court held
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`that the claim is "likely to be obvious" (id.). This meets the IPR institution
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`threshold of a "reasonable likelihood of success". 37 C.F.R. § 42.108(c).
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`First, the Petition demonstrated that the components of the '993 patent were
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`familiar to a person of ordinary skill ("combination of familiar elements").
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`(Petition, pp. 11-35). Regarding the "allowing" limitation, the Petition
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`demonstrated that Bonura was known as a base system, that Bonura provided pop-
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`up menus, that Bonura taught customizing the pop-up menus, that Bonura taught
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`including a "storing" option when the context was contact information, and that
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`Magnanelli taught an "updating" option when the context was "contact
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`10
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`information". See above, § 2. This does not appear to have been disputed by the
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`Patent Owner, nor held otherwise in the June 5 Decision.
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`The Petition also demonstrated that the elements could be combined according
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`to known methods. Specifically, the Petition stated that the updating option of
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`Magnanelli could have been applied to Bonura, and that the combination was well
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`within ordinary skill. (Petition, pp. 20-21). The Petition cited to the Allison
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`declaration at ¶136. Paragraph 136 of Mr. Allison's declaration incorporates his
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`discussion of the level of skill in the art at ¶¶19-37. In that discussion, Mr. Allison
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`provided extensive testimony—well-substantiated with reference to objective prior
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`art sources—concerning the level of ordinary skill in the relevant timeframe. In
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`particular, Mr. Allison testified that a person of ordinary skill would have been
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`familiar with text-recognition systems that allowed users to make a choice between
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`alternatives in a menu. (Ex. 1002, ¶25). Mr. Allison testified:
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`"25. A person of ordinary skill would further have been familiar with
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`text recognition systems. Such systems evaluated text in a document,
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`looking for useful structures. Once a useful structure was found, the
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`system would allow a user to do something with it by executing code.
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`The mechanism for allowing the user to execute an associated
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`function was often accomplished by means of a context-dependent
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`graphical user interface element, such as a context menu or a pop-up
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`window. The user's selection from the user interface element would
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`lead to a specific code module being executed, to do something
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`11
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`useful with the information." (Ex. 1002, ¶25).
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`Mr. Allison provided several prior art examples of this (including Bonura).
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`(Ex. 1002, ¶26-29). Mr. Allison also testified that persons of ordinary skill (a) had
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`the ability to design graphical user elements (like pop-up menus) (Ex. 1002, ¶22),
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`(b) had familiarity with advanced contact databases (Ex. 1002, ¶¶30-36), again
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`providing several prior art examples, (c) had the ability to write requisite software
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`(Ex. 1002, ¶21), and (d) had the ability to get common applications to
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`communicate with contact databases (Ex. 1002, ¶¶23, 30). Mr. Allison testified
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`that the '993 patent relied on this level of skill (Ex. 1002, ¶20, 136), and was
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`merely automating what people had done manually for some time (Ex. 1002, ¶30).
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`Lastly, the Petition showed that the results were predictable, that the field was
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`predictable. (Petition, p. 20). Neither the '993 patent nor the prior art made any
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`mention of unpredictable results. Mr. Allison verified this. (Ex. 1002, ¶135).
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`It does not appear that the Patent Owner contested any of these factual
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`predicates for a case under KSR v. Teleflex. The KSR predicates rendered the
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`allowing limitation "likely to be obvious". All of the elements were available in
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`the prior art, they could have been combined by a person of ordinary skill, and the
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`results were entirely predictable. The Patent Owner could have rebutted this case
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`with a further showing (e.g. secondary considerations, teaching away, etc.), but
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`elected not to do so. Even if the panel were to find—despite §2, above—that there
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`12
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`was no express motivation to combine a "storing" and "updating" option into
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`Bonura's pop-up menu, KSR would still forbid patenting of mere obvious design
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`choices that are simply too numerous to write down in the prior art.
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`B. The Patent Owner's proposed construction is not the broadest
`reasonable construction consistent with the specification.
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`The Patent Owner's construction of the "allowing" limitation was also not the
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`broadest reasonable construction consistent with the specification. Figure 9 and its
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`related text do not support the Patent Owner's strict construction. This is primarily
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`true because Fig. 9 has a "cancel" button in the lower right corner. The cancel
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`button shows that the user could take no action, which is more consistent with the
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`Petitioners' broader construction that has the system presenting one or both of two
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`possible choices to the user (i.e. "whether to store…[or not] or whether to
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`update…[or not]"). Mr. Allison testified that (cited on page 10 of the Petition):
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`"69. Figure 9 shows a combination of the two interpretations, where
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`the user is given the option to store a new contact or not (cancel
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`button), or to update a contact or not." (Ex. 1002, ¶69).
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`Moreover, Fig. 9 allows the user to "use the above address in my Word
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`document", which is neither "storing" nor "updating", and thus not consistent with
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`the Patent Owner's strict construction. Fig. 9 also assumes that "the user has typed
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`a name and new address of an existing contact 44". (Ex. 1001, 7:28-29). The
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`claims, however, do not require this. The claims are, in this respect, broader than
`
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`13
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`Fig. 9 shows.
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`The fact that Fig. 9 does not support the Patent Owner's strict construction is
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`important, because the June 5 Decision held that Fig. 9 was the only portion of the
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`specification to address the allowing limitation, and then used this holding to
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`exclude the Petitioners' evidence from consideration. Specifically, the June 5
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`Decision found that:
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`"Petitioner’s three citations to the specification are unrelated to
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`Figure 9 and the related disclosure of the ’993 patent, which, as
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`described above, bear directly on the claim language." (June 5
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`Decision, p. 11).
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`Respectfully, this reasoning is clear error. First, as noted above, Fig. 9 does not
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`"bear directly on the claim language"—especially not as the June 5 Decision
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`construed it. Second, even if Fig. 9 did support the Patent Owner's strict
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`construction, it would not mean that Fig. 9 is the only portion of the specification
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`to bear on the claim language.
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`The Petitioners' citations were, in fact, highly relevant and should have been
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`considered. The Petition cited to Ex. 1001 at 6:47-64; 10:17-24; 8:62-9:10, Figs.
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`11 and 13; Ex. 1002 at ¶¶ 67-69. The citation to column 6, lines 47-64 (relating to
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`Figs. 5-6) shows a situation where the user is prompted only with a decision of
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`whether or not to "store" a contact as a new contact, and is not prompted with the
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`possibility of "updating" an existing contact. Likewise, the cite to 10:17-24 states:
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`14
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`"At step 122, the subprogram determines whether or not there are any
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`matching address results. If there are no matching results, the user is
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`given the opportunity to store or not to store the address…."
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`No choice to "update" is offered to the user, which directly supports the
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`Petitioners' proposed construction. The citation to 8:62 – 9:10 and Figs. 11 and 13
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`shows an instance where the user is offered the choice to update a contact (or not),
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`without a "storing" option. Also, this citation is related Fig. 9—contrary to the
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`holding in the June 5 Decision. (Ex. 1001, 8:40-61).
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`The Patent Owner argued in its Preliminary Response that the structure of the
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`phrase "to make a decision whether to X or to Y" demands, grammatically, a strict
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`choice between only X or Y. This is untrue as a general proposition. Whether the
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`two alternatives "X" or "Y" are "competitive" depends on the relationship between
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`X and Y. For example, the statement "I gave him the choice whether to eat or to
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`drink with us" could easily be followed up with "but he said 'no'". This flows from
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`the relationship between the concepts of "eating" and "drinking", not from the
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`abstract structure of the sentence. Likewise, the nature of the relationship between
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`"storing" and "updating", which can and do appear separately in the specification,
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`should govern here, with the proviso that any reasonable interpretation should be
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`included within the scope of the claims in inter partes review.
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`The Petitioners thus respectfully request that Trial on Grounds 1 and 2 be
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`instituted and that claims 1-24 be canceled.
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`15
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`Respectfully submitted,
`
`By: /Matthew A. Smith/
`Matthew A. Smith
`Registration No. 49,003
`Counsel for Petitioners
`Motorola Mobility LLC and
`Google Inc.
`
`
`
`By: /David L. Fehrman/
`David. L. Fehrman
`Registration No. 28,600
`Counsel for Petitioner Apple Inc.
`
`
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`
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`
`
`
`
`
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`
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`Dated: 2014-07-07 (Monday)
`
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`16
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`CERTIFICATE OF SERVICE
`
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`The undersigned hereby certifies that a copy of the foregoing request for
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`rehearing was served on July 7, 2014 by electronic mail (by prior agreement with
`
`the Patent Owner) to the attorneys of record at
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`SUNSTEIN KANN MURPHY & TIMBERS LLP
`125 SUMMER STREET
`BOSTON MA 02110-1618
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`by transmitting the documents to the attorneys' email addresses at:
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`RAsher@sunsteinlaw.com, BSunstein@sunsteinlaw.com,
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`Jstickevers@sunsteinlaw.com, and Dwu@sunsteinlaw.com.
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`
`
`By: /Matthew A. Smith/
`Matthew A. Smith
`Registration No. 49,003
`Counsel for Petitioners
`Google Inc. and
`Motorola Mobility LLC
`
`
`
`
`
`i
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