UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAP AMERICA, INC.
`Petitioner
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`v.
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`PI-NET INTERNATIONAL, INC.
`Patent Owner
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`Case IPR2014-00413
`Patent 8,346,894
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`PETITIONER’S REPLY TO PATENT OWNER’S
`RESPONSE TO PETITION
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`TABLE OF CONTENTS
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`IPR2014-00413
`Patent 8,346,894
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`LIST OF EXHIBITS ................................................................................................ iii
`I.
`Introduction ........................................................................................................ 1
`II. Argument ............................................................................................................ 1
`A. PO’s alternative constructions should not be adopted. ................................. 1
`1.
`“Web Transaction” ................................................................................ 1
`2.
`“Internet” and “(World Wide) Web” .................................................... 2
`3.
`“Web Application” ................................................................................ 3
`4.
`“POSvc Web Application” .................................................................... 4
`5.
`“Facilities Network” .............................................................................. 5
`6.
`“Service Network” ................................................................................ 6
`7.
`“Service Network Running on Top of a Facilities Network” (term 8);
`“[Overlay] Service Network Running on Top of an IP-based Facilities
`Network” (term 9); and “Service Network on the Web; Service
`Network atop the Web” (term 10) ......................................................... 6
`“VAN Service” ...................................................................................... 7
`8.
`“Internet Cloud Application” ................................................................ 7
`9.
`10. “Web Merchant” .................................................................................... 8
`11. “Object” ................................................................................................. 8
`12. “Information Entries and Attributes of an Object” ............................... 9
`13. “Application Layer Routing of the Object Identity with the
`Information Entries and Attributes” ...................................................... 9
`14. “Object Routing” ................................................................................. 10
`15. “Exchange” .......................................................................................... 11
`16. “Back-end Application” ...................................................................... 11
`B. Challenged claims 1-19 of the ’894 patent are unpatentable. ..................... 12
`1. Chelliah teaches a “real-time Web transaction from a Web
`application.” ........................................................................................ 12
`2. Chelliah teaches “object routing on the World Wide Web performed
`as OSI application layer routing.” ....................................................... 13
`3. The combination of Chelliah and Edwards teaches “service network.”
` ............................................................................................................. 15
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`i
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`IPR2014-00413
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`Patent 8,346,894
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`III. Conclusion ........................................................................................................ 15
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`ii
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`LIST OF EXHIBITS
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`IPR2014-00413
`Patent 8,346,894
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`Document Description
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`U.S. Patent No. 8,346,894 to Arunachalam
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`Declaration of Dr. Marvin Sirbu
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`Curriculum Vitae of Dr. Marvin Sirbu
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`U.S. Patent No. 5,710,887 to Chelliah et al.
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`N. Edwards, “Object Wrapping (for WWW) – The Key to
`Integrated Services?,”ANSA Document Identifier
`APM.1463.01 and 1464.01, Architecture Projects Management
`Ltd, April 1995.
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`U.S. Patent No. 5,220,501 to Lawlor et al.
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`Stevenson et al., “Using CompuServe, Special Edition,” Que
`Corp., August 1995.
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`J. Bartlett, “Experience with a Wireless World Wide Web
`Client,” WRL Technical Note TN-46, Digital Western Research
`Laboratory, March 1995.
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`The Common Object Request Broker: Architecture and
`Specification, July 1995.
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`Claim Construction Opinion
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`Currently Filed
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`Declaration of Dr. Marvin Sirbu in Support of Petitioner’s
`Reply to Patent Owner’s Response to Petition
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`Clark, D., “The Design Philosophy of the DARPA Internet
`Protocols,” Computer Communication Review, 18, 4, Aug
`1988.
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`iii
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`Exhibit No.
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`SAP 1001
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`SAP 1002
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`SAP 1003
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`SAP 1004
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`SAP 1005
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`SAP 1006
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`SAP 1007
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`SAP 1008
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`SAP 1009
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`SAP 1010
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`SAP 1011
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`SAP 1012
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`IPR2014-00413
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`Patent 8,346,894
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`Zwimpfer, L. and Sirbu, M., “Standards Setting for Computer
`Communication: The Case of X.25” IEEE Comm Mag,” 23, 3,
`March 1985.
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`Haynes, T., “The Electronic Commerce Dictionary,” The
`Robleda Company, California, 1985, 112 pages.
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`Ashley, Charles C., “IVANS: A vigorous decade,” Bests
`Review, May, 1993.
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`SAP 1013
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`SAP 1014
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`SAP 1015
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`iv
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`I.
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`IPR2014-00413
`Patent 8,346,894
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`Introduction
`The Board, in instituting the instant inter partes review, found that Petitioner
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`SAP presented a compelling case for finding challenged claims 1-19 of U.S. Patent
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`8,346,894 (SAP 1001,’894 patent) unpatentable. In response to the Board’s well-
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`reasoned decision, Patent Owner (“PO”) provides a lengthy, confusing response
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`unsupported by expert testimony or other extrinsic evidence and premised on
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`improper claim constructions and erroneous interpretations of the applied prior art.
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`II. Argument
`A. PO’s alternative constructions should not be adopted.
`Recognizing the weakness in its position, PO premises its Response solely
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`on overly narrow and unsupported constructions of 19 terms. The Board should
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`reject these constructions because they are inconsistent with the broadest
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`reasonable interpretation (BRI) and the specification, import limitations into the
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`claims and introduce further ambiguity into the claims.1 For ease of reference, in
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`discussing the 19 terms, the analysis below uses the same numbering as PO.
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`1. “Web Transaction”
`PO asks the Board to further narrow its construction of the term “Web
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`transaction” by adding “two-way” interaction and capability to do “more than one-
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`1 Unlike Petitioner, PO does not provide expert testimony or extrinsic
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`evidence to support any of its proposed claim constructions.
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`1
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`Patent 8,346,894
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`way browse-only interaction, a Web user can perform.” (See Paper 19, Response,
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`p. 1.) The ’894 patent does not limit the term “Web transaction” as alleged by PO
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`and for this reason, PO’s narrow construction should be rejected. (See SAP 1010,
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`Sirbu Dec., ¶¶ 21-23.) To the contrary, the ’894 patent explains: “a ‘transaction’
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`for the purposes of the present invention includes any type of commercial or other
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`type of interaction that a user may want to perform.” (’894 patent, 5:34-37.)
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`2. “Internet” and “(World Wide) Web”
`PO does not dispute the Board’s construction of the term “Web.” (Response,
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`p. 5.) PO, however, urges the Board to reconsider its construction of the term
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`“Internet.” (See id.) The ’894 patent does not support PO’s narrow construction of
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`“Internet”: “TCP/IP-based Internet, this is the physical Internet with physical
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`hardware components that provides underlying communication services up to layer
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`4 of the OSI model and over which an OSI application layer 7 network operates.”
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`(Id., emphasis in original.) The term “Internet” is a well-known term and should be
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`given its plain and ordinary meaning, as would have been understood by a person
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`of ordinary skill in the art (POSA). (See Paper 12, Decision, p. 16 and Sirbu Dec.,
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`¶¶ 27-29.) The Board should thus reject PO’s construction and maintain its existing
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`construction: “a global computer network providing a variety of information and
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`communication facilities, consisting of interconnected networks using standardized
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`communication protocols.” (Decision, p. 16.)
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`2
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`3. “Web Application”
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`Patent 8,346,894
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`PO urges the Board to reconsider its construction of this term and adopt
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`PO’s new construction. (See Response, p. 6.) The Board should reject PO’s
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`construction because it not supported by the ’894 patent. For example, PO’s
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`proposed construction equates a Web application to a Web client, and specifies that
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`a Web application/Web client “is displayed in a Web Browser.” (Id.) But this
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`contradicts the teachings of the ’894 patent, which explicitly states that “[w]eb
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`browsers are software interfaces that run on Web clients.” (’894 patent, 1:40-42;
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`Sirbu Dec., ¶¶ 30-39.) Moreover, Fig. 1 and supporting text of the ’894 patent
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`illustrate that Web browser 102 runs on a user’s machine and functions as a client,
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`while an application that provides a service (e.g. checking application 152, loan
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`application 154) runs on a machine that hosts a web site and functions as a server.
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`(See also ’894 patent, 1:52-67; Sirbu Dec., ¶¶ 30-39.)
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`PO’s construction and argument also equates and interchangeably uses the
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`terms “Web application” and “POSvc application.” (Response, pp. 8-9.) But there
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`is no support in the ’894 patent for equating these terms. In fact, the use of
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`different terms in claim 1 indicates the terms should have different meanings.
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`(Sirbu Dec., ¶ 36.) Additionally, the ’894 patent demonstrates that a “POSvc
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`application” is not a client that runs in a Web browser, but rather is associated with
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`a server. (Id., ¶¶ 36-37.) For example, Fig. 4B illustrates that the POSvc
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`application is part of an Exchange, which the ’894 patent states can reside on a
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`Web server (e.g. Web server 104) or a separate computer with an Internet address.
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`(’894 patent, 6:28-31 and 6:61-67.)
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`PO also includes the limitation “real-time Web transaction” in its proposed
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`construction of “Web application.” (Response, p. 6). However, this inclusion is
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`redundant given the explicit recitations of claim 1, and further is not supported in
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`the specification. (Sirbu Dec., ¶ 38.) PO also fails to identify any support in the
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`specification for the added limitation “that includes a networked object identity
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`with information entries and attributes.” (Sirbu Dec., ¶ 39.) Accordingly, the Board
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`should reject PO’s construction.
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`4. “POSvc Web Application”
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`PO urges the Board to reconsider its construction of these terms and instead
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`adopt its construction: “a transactional application that is a Web client displayed in
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`a Web browser or a Web page and that executes a real-time Web transaction a Web
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`user performs and that includes a networked object identity with information
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`entries and attributes.” (Response, pp. 6 and 15, emphasis added.) The Board
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`should not adopt this construction for at least two reasons.
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`First, PO’s construction is inconsistent with the ’894 patent specification.
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`(See Sirbu Dec., ¶¶ 30-44.) The specification states that “Web browsers are
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`software interfaces that run on Web clients.” (’894 patent, 1:40-41.) For example,
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`FIG. 1A shows a Web browser 102 running on a user’s machine (e.g., Web client)
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`and a service application (e.g., car dealer Web page) running on a server machine
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`that hosts the web site. (See id., 1:52-67 and Sirbu Dec., ¶¶ 30-44.)
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`Second, PO’s construction is inconsistent with its own arguments. For
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`example, PO states that “[t]he Web client application displayed on a Web browser
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`is distinct from the Web browser, even though the Web browser is itself a Web
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`client.” (Response, p. 8, emphasis added.) PO does not reconcile the glaring
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`inconsistency with this statement: if the “Web browser is itself a Web client,” then
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`how is “a Web client displayed in a Web browser” as alleged by PO in its
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`construction. Additionally, the ’894 patent shows that a “POSvc Web application”
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`is not a Web client displayed on a Web browser; rather, it is associated with a Web
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`server. (See Sirbu Dec., ¶¶ 30-44.) For example, FIG. 4B illustrates that Web pages
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`and POSvc applications are part of an Exchange, which resides on a Web server or
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`another computer with an Internet address. (See id. and ’894 patent, 6:28-31.)
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`5. “Facilities Network”
`The ’894 patent does not support PO’s narrow construction of “facilities
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`network” as a “network with physical hardware components and that provides
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`underlying network communication services up to layer 4 of the OSI model and
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`over which an OSI application layer 7 network operates.” (Response, pp. 23-24;
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`Sirbu Dec., ¶¶ 45-47.) The only discussion of “facilities network” in the ’894
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`Patent 8,346,894
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`patent is “[an] embodiment includ[ing] a service network running on top of a
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`facilities network, namely the Internet, the Web or e-mail networks.” (’894 patent,
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`5:61-63; Sirbu Dec., ¶¶ 45-47.) The ’894 patent does not limit the “facilities
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`network” to particular layers of the OSI model, as alleged by PO. (See Sirbu Dec.,
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`¶¶ 45-47.) Accordingly, PO’s narrow construction of “facilities network” should
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`be rejected and the Board’s construction should be maintained.
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`6. “Service Network”
`PO urges the Board to further narrow its construction of this term by
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`requiring (1) that the “service network” is “[a]n OSI application layer network
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`running on top of a facilities network” and (2) that the “service network” “provides
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`value-added network services (VAN services).” (Response, pp. 24-25.) PO’s
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`proposed construction improperly imports limitations into the claims and is not
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`supported by the specification or plain language of the claims. (Sirbu Dec., ¶¶ 48-
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`51.) Nothing in the ’894 patent requires the “service network” to be limited to “an
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`OSI application layer network.” (’894 patent, 5:61-63; see Sirbu Dec., ¶¶ 48-51.)
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`Rather, the ’894 patent explicitly states that “[d]epending on the type of service,
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`the characteristics of the network elements will differ,” which is consistent with the
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`Board’s construction of this term. (’894 patent, 9:23–24.) Thus, the specification
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`does not support PO’s overly narrow construction. (See Sirbu Dec., ¶¶ 48-51.)
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`7. “Service Network Running on Top of a Facilities Network” (term 8);
`“[Overlay] Service Network Running on Top of an IP-based
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`Patent 8,346,894
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`Facilities Network” (term 9); and “Service Network on the Web;
`Service Network atop the Web” (term 10)
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`PO urges the Board to adopt its construction of claim terms 8-10, relying on
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`PO’s erroneous construction of the term “service network.” (Response, pp. 27-28.)
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`For the same reasons discussed above for the term “service network,” PO’s
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`constructions for these terms should be rejected. (Sirbu Dec., ¶¶ 52-53.)
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`8. “VAN Service”
`PO’s proposed construction of “VAN service” is overly narrow and
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`inconsistent with the specification and thus the BRI standard. (Sirbu Dec., ¶¶ 54-
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`56.) Consistent with the Board’s construction of this term, the ’894 patent
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`describes “VAN service” by way of example, stating that it includes “multi-media
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`messaging, archival/retrieval management, directory services, data staging,
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`conferencing, financial services, home banking, risk management and a variety of
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`other vertical services” and is “designed to meet a particular set of requirements
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`related to performance, reliability, maintenance and ability to handle expected
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`traffic volume.” (’894 patent, 9:16-23.) Accordingly, the specification does not
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`support PO’s narrow construction. (See Sirbu Dec., ¶¶ 54-56.)
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`9. “Internet Cloud Application”
`PO urges the Board to reconsider its construction of this term and adopt its
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`new construction, which is identical to its proposed construction of the term
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`“POSvc Web application.” However, the use of different terms in claim 1 indicates
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`IPR2014-00413
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`Patent 8,346,894
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`the terms should have different meanings. The term “Internet Cloud Application”
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`does not appear in the specification of the ’894 patent. Thus, consistent with the
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`Board’s construction, this term should be given its plain and ordinary meaning, as
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`would have been understood by a POSA. (See Sirbu Dec., ¶¶ 57-59.)
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`10. “Web Merchant”
`PO asks the Board to adopt its narrow construction of this term: “provider of
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`a POSvc application.” (Response, p. 30.) The ’894 patent does not limit this term
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`to “POSvc applications”: “a true ‘Web merchant’ . . . [is] namely a merchant
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`capable of providing complete transactional services on the Web.” (’894 patent,
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`5:54-56.) PO further asserts that the Board “failed to state what ‘using the Web’
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`means and also failed to state how the goods and services are provided.”
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`(Response, pp. 30-31.) The Board however appropriately addressed the
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`construction of the term “Web,” which is not disputed by PO. (See Decision, pp.
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`15-17 and Response, p. 5.) For the above reasons, the Board should reject PO’s
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`construction of the term “Web merchant.” (See Sirbu Dec., ¶¶ 60-62.)
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`11. “Object”
`PO urges the Board to not construe this term and instead construe the term
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`“networked object.” (See Response, p. 32.) PO’s arguments, however, are without
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`merit. PO alleges that “[o]ne of ordinary skill in the art in 1995 knew that the term
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`‘object’ in the patent refers to a data structure specific to an application and
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`Patent 8,346,894
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`consists of data and methods.” (Id., p. 32.) But nothing in the ’894 patent supports
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`such a limiting definition of the term “object.” (Sirbu Dec., ¶¶ 63-65.) Under BRI,
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`the Board’s construction of this term is correct and consistent with the
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`specification which describes an “object” as having a “name, a syntax and an
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`encoding.” (’894 patent, 8:31-32; see Sirbu Dec., ¶¶ 63-65.) PO’s construction
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`should be rejected.
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`Regarding the term “networked object,” PO requests that this term be
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`construed. (See Response, pp. 32-33.) However, PO’s arguments for this term rely
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`on its incorrect construction of the term “object.” (See id.) Thus, PO’s arguments
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`regarding the term “networked object” are equally as flawed, and should not be
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`considered. (See Sirbu Dec., ¶¶ 63-65.)
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`12. “Information Entries and Attributes of an Object”
`PO does not dispute the Board’s construction of the term “attributes” but
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`proposes an alternative construction for the term “information entries.” (See
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`Response, p. 33.) PO provides a single conclusory statement: “[t]hese values
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`represent the Web transaction specified by the Web user corresponding to the
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`attributes specific to the POSvc Web application.” (Id.) However, PO provides no
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`analysis or explanation to support its narrow construction. Therefore, the Board
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`should reject PO’s construction. (See Sirbu Dec., ¶¶ 66-67.)
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`13. “Application Layer Routing of the Object Identity with the
`Information Entries and Attributes”
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`IPR2014-00413
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`Patent 8,346,894
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`PO asks the Board to adopt its narrow construction of this term. (See
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`Response, p. 34.) However, the ’894 patent specification does not support such a
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`narrow interpretation. Instead, the’894 patent describes application layer routing as
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`“routing [that] creates an open channel for the management, and the selective flow
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`of data from remote databases on a network.” (’894 patent, 5:27-29.) This
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`description does not limit “application layer routing” to “OSI application layer
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`routing of the individual networked objects” or to routing “from a POSvc
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`application displayed on a Web page or in a Web browser,” as alleged by PO. PO
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`improperly seeks to bundle language already recited in the claims with its
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`construction of “application layer routing of the object identity with the
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`information entries and attributes,” which is impermissible. (See, e.g., claim 1 of
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`the ’894 patent.) The Board should thus reject PO’s proposed construction. (See
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`Sirbu Dec., ¶¶ 68-69.)
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`14. “Object Routing”
`PO asks the Board to adopt its narrow construction of this term. (See
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`Response, p. 35.) To support its construction, PO merely cites to page 27 of its
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`preliminary response. (See id.) PO again provides no analysis, no explanation and
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`no additional evidence to support its narrow construction. The Board has already
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`rejected these arguments in its Decision and should maintain this position. (See
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`Decision, p. 26; see also Sirbu Dec., ¶¶ 70-73.)
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`15. “Exchange”
`PO urges the Board to adopt its narrow construction of this term: “Web page
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`505, POSvc applications 510 on a Web page, switching service 702, object routing
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`component, also known as object router (which includes the individual networked
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`objects—the information entries and attributes displayed in a POSvc application
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`displayed on a Web browser or Web page).” (Response, p. 36.) The Board should
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`reject PO’s construction for at least three reasons.
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`First, PO relies on conclusory arguments devoid of any support. (See id., pp.
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`36-37.) Second, the proposed construction for “Exchange” relies on PO’s
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`construction of “POSvc Web application,” which is flawed for the reasons
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`discussed above. Third, PO’s construction and analysis do not address the function
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`of the “Exchange” recited in claim 10: “the Exchange manages in real-time the
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`connection between the real-time Web transaction request and any commercial
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`service.” The Board found that “[i]n view of this description in claim 10 itself, no
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`further construction of the term “Exchange” is required.” (Decision, p. 29; see also
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`Sirbu Dec., ¶¶ 74-75.)
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`16. “Back-end Application”
`PO’s construction for this term, “an application not at the front end,”
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`provides no clarity and thus should be rejected. (Response, p. 37.) “Back-end
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`application” is not discussed in the ’894 patent specification and only appears in
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`the claims. (See, e.g., claim 12 of the ’894 patent.) PO argues that “[a] Web user
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`does not ever access a computer system or database in a Back Office, for obvious
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`security reasons, a Bank or other Web merchant or VAN service provider would
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`not allow a user to access the computer system or database in the Back Office,
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`even via an application.” (Id., p. 38.) PO provides no intrinsic evidence or expert
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`evidence to support this conclusory statement. Indeed, PO’s statement is contrary
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`to the understanding of a POSA. If the Web user cannot directly (or even
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`indirectly) access the Bank’s computer system or database in the Back Office, then
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`performing any transactions (e.g., transferring funds) would be impossible. (Sirbu
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`Dec., ¶ 76.) Thus, the Board should reject PO’s proposed construction.
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`B. Challenged claims 1-19 of the ’894 patent are unpatentable.
`PO’s arguments over the Chelliah, Edwards, Lawlor, CompuServe and
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`Bartlett prior art references are premised solely on its improper claim
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`constructions. When considered under the proper constructions, challenged claims
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`1-19 are obvious over the applied prior art references.
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`1. Chelliah teaches a “real-time Web transaction from a Web
`application.”
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`PO argues that “[n]one of the cited art, Chelliah, Edwards, Lawlor,
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`Compuserve or Bartlett disclose a ‘real-time Web transaction from a Web
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`application.’” (Response, p. 38.) Based on its improper construction of “Web
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`application,” PO states that “[t]here is no application displayed in a Web browser
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`or Web page in the cited art.” (Id., p. 39.) Similarly, based on its improper claim
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`construction, PO argues that the applied prior art references do not teach a “POSvc
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`Web application.” (See id.) As set forth in the Petition, when the proper
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`constructions of these terms are applied, Chelliah discloses these limitations.
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`The Board’s construction of “Web application” is “a computer program to
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`perform a certain type of work using the Web” and “POSvc Web application” is “a
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`computer program that can execute the type of transaction the user may be
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`interested in performing.” (Decision, p. 18; see also Sirbu Dec., ¶¶ 79-86.) In other
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`words, a “POSvc Web application” is a specific type of “Web application.”
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`Chelliah teaches these limitations because Chelliah discloses a payment
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`query Web application, a Web-based software program that facilitates the
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`execution of transactions requested by a customer. (See Paper 5, Corrected
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`Petition, p. 20 see also Sirbu Dec., ¶¶ 80-92.) After the customer selects an item to
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`purchase, the payment query Web application “quer[ies] the Customer for a
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`payment method (e.g., VISA card) and [provides] a means of authenticating the
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`identity of the Customer (e.g., a password) . . .” (SAP 1004, Chelliah, 12:57-59;
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`see also Sirbu Dec., ¶¶ 80-92.) Chelliah therefore teaches a “POSvc Web
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`application” and, accordingly, a “Web application.”
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`2. Chelliah teaches “object routing on the World Wide Web performed as
`OSI application layer routing.”
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`PO disagrees with the Board’s analysis on pages 37-39 of the Decision, in
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`which the Board confirms the disclosure of “object routing” in Chelliah. (See
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`Response, pp. 46-51.) PO argues that “Chelliah’s Sales Representative Object is
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`what is called a ‘back-end application’ . . . A back-end transactional application
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`was an island and local to the back-end and did not connect to a non-existent Web
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`application at the front-end.” (Id., pp. 47 and 49.) PO provides no evidence,
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`intrinsic or extrinsic, to support these conclusory statements. As explained by
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`Petitioner and Petitioner’s expert, Dr. Sirbu, PO mischaracterizes Chelliah.
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`The External Payment Handler 126 of Chelliah is a “back-end application”
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`that communicates with a payment query Web application (via Sales
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`Representative Program Object 114 and Payment Handler Interface 124) at the
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`front-end. (See Sirbu Dec., ¶¶ 80-92.) Consistent with the Board’s construction of
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`“back-end application,” External Payment Handler 126 provides an application
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`associated with a computer system or database accessed by Web merchants. (See
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`Decision, p. 29, Chelliah, 8:53-56, and Corrected Petition, pp. 42-45.) For
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`example, after a customer enters an on-line store and selects an item to purchase
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`and its price, a Sales Representative Program Object 114 arranges for payment via
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`the payment query Web application. (See Chelliah, 12:57-59, FIG. 9; see also
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`Sirbu Dec., ¶¶ 80-92.) Sales Representative Program Object 114 “calls Payment
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`Handler Interface 124 to validate the selected method of payment, passing to the
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`Payment Handler Interface 124 the data received from the customer . . .” (Chelliah,
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`16:27-30; see also Sirbu Dec., ¶¶ 80-92.) “Payment Handler Interface 124 . . .
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`serve[s] as a front-end to convert an object-oriented function call, such as a
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`CORBA call, to a call to an External Payment Handler 126, part of External
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`Subsystems 18.” (Chelliah, 11:43-46; see also Sirbu Dec., ¶¶ 80-92.)
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`Thus, Chelliah’s commerce system includes a payment query Web
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`application at the front-end that communicates with an external payment system at
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`the back-end via the routing of objects between computer platforms. (See
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`Corrected Petition, pp. 32-33 and Sirbu Dec., ¶¶ 80-92 and 100-102.)
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`3. The combination of Chelliah and Edwards teaches “service network.”
`PO argues that “Chelliah does not disclose ‘a service network,’ as claimed in
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`claim 1.” (Response, p. 55.) However, Petitioner does not apply Chelliah alone to
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`address this limitation. Rather, the combination of Chelliah and Edwards is used.
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`(See Corrected Petition, pp. 20-24; see also Sirbu Dec., ¶¶ 91-92.) For this reason
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`alone, PO’s opposition fails.
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`III. Conclusion
`Accordingly, challenged claims 1-19 of the ’894 patent should be canceled.
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`Date: February 17, 2015
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`Respectfully submitted,
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`/Lori A. Gordon/
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`Lori A. Gordon (Reg. No. 50,633)
`Attorney for SAP
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`CERTIFICATION OF SERVICE (37 C.F.R. §§ 42.6(e))
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`The undersigned hereby certifies that the above-captioned “PETITIONER’S
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`REPLY TO PATENT OWNER’S RESPONSE TO PETITION” and all
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`accompanying exhibits were served in their entireties on February 17, 2015 upon
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`the following party via email:
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`Dr. Lakshmi Arunachalam (Pro Se)
`222 Stanford Avenue
`Menlo Park, CA 94025
`Tel.: (650) 690-0995
`Fax: (650) 854-3393
`laks22002@yahoo.com
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`Respectfully submitted,
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`/Lori A. Gordon/
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` Lori A. Gordon
` Registration No. 50,633
`Attorney for Petitioner
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`Date: February 17, 2015
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`
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`1100 New York Avenue, NW
`Washington, DC 20005-3934
`(202) 371-2600