UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEALS BOARD
`
`BROSE NORTH AMERICA, INC.
`and
`BROSE FAHRZEUGTEILE GMBH & CO. KG, HALLSTADT,
`Petitioners
`
`v.
`
`UUSI, LLC
`Patent Owner
`
`Case No. IPR2014-00416
`Patent No. 8,217,612
`
`PETITIONERS’ REPLY
`
`
`
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEALS BOARD
`
`BROSE NORTH AMERICA, INC.
`and
`BROSE FAHRZEUGTEILE GMBH & CO. KG, HALLSTADT,
`Petitioners
`
`v.
`
`UUSI, LLC
`Patent Owner
`
`Case No. IPR2014-00416
`Patent No. 8,217,612
`
`PETITIONERS’ REPLY
`
`
`
`
`
`
`
`
`
`
`
`I.
`
`II.
`
`TABLE OF CONTENTS
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`Page
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`INTRODUCTION ........................................................................................... 1
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`THE CHALLENGED CLAIMS ARE INVALID ........................................... 2
`
`A.
`
`B.
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`Claims 1 and 2 are Invalid as (i) Obvious Over Itoh (Ground 1),
`(ii) Anticipated by Itoh Under a Broad Construction (Ground
`2), and (iii) Obvious Over Itoh In View Of Kinzl (Ground 3) ............. 2
`
`Claim 5 is Invalid as Obvious Over Itoh (Ground 1), and
`Obvious Over Itoh In View Of Kinzl (Ground 3) ................................. 4
`
`C.
`
`Claims 6-8 are Invalid and Should Be Cancelled ................................. 7
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`III. MOTIVATION AND ABILITY TO COMBINE ......................................... 13
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`IV. ENABLEMENT ............................................................................................ 14
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`I.
`
`INTRODUCTION
`
`UUSI advocates contrived claim constructions designed to circumvent the
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`prior art, even proposing constructions that contradict those used by UUSI in
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`litigation prior to this IPR. UUSI’s claim constructions not only ignore file
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`histories that UUSI’s proffered expert did not review, but also run afoul of the
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`plain meaning of the claim language. UUSI’s constructions should be rejected.
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`Indeed, UUSI does not dispute that the challenged claims are invalid under Brose’s
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`proper construction. Moreover, they are invalid even under UUSI’s incorrect
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`constructions.1,2
`
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`1 Brose maintains, but does not separately address here, Grounds 7 and 8 because
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`they present no additional issues over Grounds 1 and 3, respectively, as Brose
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`relies on Zuckerman only for the obviousness of rewriting Itoh’s equation, which
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`UUSI does not dispute. See Response (“R”) 14-17. The challenged claims are
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`invalid based on Grounds 7 and 8. See Corr. Pet. 57-60; Ex. 1053 ¶¶ 88-105
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`(claims 1-2), 150; 152-53; 155-60; 163-65 (claim 5).
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`2 UUSI states that the construction of “a control signal . . . to deactivate said
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`motor” as recited in claims 1 and 6 is “irrelevant to the determination of
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`patentability of the present claims.” R. 13. Thus, that issue is not addressed in
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`this brief.
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`
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`1
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`
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`
`
`A.
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`II. THE CHALLENGED CLAIMS ARE INVALID3
`Claims 1 and 2 are Invalid as (i) Obvious Over Itoh (Ground 1),
`(ii) Anticipated by Itoh Under a Broad Construction (Ground 2),
`and (iii) Obvious Over Itoh In View Of Kinzl (Ground 3)4
`In response to Brose’s Grounds 1-3, as to claim 1, UUSI raises only a single
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`purported distinction regarding the prior art. Contrary to its position in the
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`litigation against Brose North America (“BNA”),5 UUSI now contends that the
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`phrases “identifying a collision of the window or panel with an obstacle” and
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`“sensing of a collision between an obstacle or panel” found in subparts (iii) and
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`(iv) of limitation (d) correspond to two separate obstacle detection algorithms that
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`are performed concurrently. R. 10-13. UUSI reads limitations into the claim that
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`have no basis in the intrinsic evidence. Claim 1 should be given its plain and
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`ordinary meaning, and be interpreted to encompass use of a single obstacle
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`3 The claims are invalid under either expert’s understanding of the level of
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`ordinary skill in the art. Indeed UUSI’s proferred expert, Dr. Ehsani, opines that
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`the level of ordinary skill in the art is even higher than what Brose’s expert
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`believes it to be. Ex. 1053 ¶¶ 18-19.
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`4 Dependent claim 2 (which UUSI does not address in its Response) rises or falls
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`with independent claim 1.
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`5 See, e.g., Ex. 1021 18-19 and Ex. 1048 14-16, 40-42 (conflating “identifying”
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`and “sensing” and making no mention of any two distinct algorithms).
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`
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`2
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`
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`detection algorithm used for identifying a collision, followed by deactivating the
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`motor. Under the proper construction of the terms at issue, UUSI has identified no
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`difference between claims 1-2 and the prior art, and the claims are anticipated and
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`obvious. Ex. 1053 ¶¶ 69; 73-74; 77-78; 83-86.
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`Alternatively, even under UUSI’s construction, claims 1-2 still would have
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`been obvious because a person of ordinary skill in the art (“POSA”) would
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`recognize that the obstacle detection algorithms disclosed in Itoh and Kinzl could
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`be easily modified to include a second algorithm (such as Kinzl’s “blocking
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`counter” algorithm). Id. ¶ 87.
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`UUSI relies on an unnatural reading of the claim
`
`1.
`UUSI attempts to draw a line between subparts of limitation (d) of claim 1
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`by contending that it recites two distinct algorithms. R. 12. This cannot be
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`squared with the plain language of the claim. Ex. 1053 ¶¶ 25-30. Subparts (i)-(iii)
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`describe monitoring movement, adjusting an obstacle detection threshold in real
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`time, and identifying a collision of the window. They do not describe any action to
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`be taken as a result of identifying a collision. It is only in subpart (iv) that any
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`action is taken as a result of a collision (outputting a control signal to deactivate the
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`motor). Under UUSI’s proposed construction, the “identifying” limitation (d)(iii)
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`has no purpose (which also means that the “monitoring” and “adjusting”
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`limitations of (d)(i) and (d)(ii) are also void of any purpose or result). See R. 12-
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`
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`3
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`
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`
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`13; Ex. 1053 ¶ 29. Such a reading is illogical. The language of claim 1, read as a
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`whole, unambiguously recites a single algorithm to be performed by the controller
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`to sense a collision and then deactivate the motor.6 Id. 1053 ¶ 24.
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`UUSI’s construction is contrary to the intrinsic evidence
`
`2.
`The intrinsic evidence, including the prosecution history that is ignored by
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`UUSI, further supports Brose’s construction. Ex. 1053 ¶¶ 31-32. In fact, the
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`specification expressly states that only one algorithm is needed to implement the
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`invention. Ex. 1005 18:8-12. Furthermore, the prosecution history demonstrates
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`that UUSI’s new, IPR-inspired construction is inconsistent with the understanding
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`that the Examiner and UUSI shared during prosecution. Ex. 1053 ¶ 32.
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`B.
`
`Claim 5 is Invalid as Obvious Over Itoh (Ground 1), and Obvious
`Over Itoh In View Of Kinzl (Ground 3)
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`In response to Brose’s Grounds 1 and 3, UUSI also raises a purported
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`difference between claim 5 and the prior art: whether it was an obvious design
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`choice, in view of Itoh, for “the immediate past measurements of said signal [to be]
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`sensed within a forty millisecond interval prior to the most recent signal from the
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`6 UUSI relies heavily on the use of the word “a” in limitation (d)(iv), arguing that
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`the word “the” is required for the “collision” in (d)(iv) to relate back to the
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`“collision” in (d)(iii). A reading of the entire claim reveals that applicants were
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`not so careful in this regard. Ex. 1053 ¶ 28.
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`
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`4
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`
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`sensor.” The Board preliminarily found that there is a “reasonable likelihood that
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`claim 5 would have been obvious over Itoh alone,” given that “[t]he ’612 Patent
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`does not describe any particular advantage in selecting the claimed 40 ms time
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`window.” Institution Decision (“ID”) 17. In its response, UUSI fails to address
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`the Board’s finding; indeed it cannot. See R. 23-28; Ex. 1053 ¶¶ 123-42.
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`Although UUSI argues that “Itoh does not teach a 40 ms time window
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`within which past measurements for an obstacle detect threshold are measured” (R.
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`21), Itoh does in fact provide guidance for the design process that would prescribe
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`the time range over which measurements are taken for a given application, some of
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`which would involve taking all of the immediate past measurements within a 40
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`ms time period.7 Ex. 1053 ¶¶ 110-15.
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`UUSI’s argument that the 40 ms time frame would not have been an obvious
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`design choice to a POSA (R. 22-28) is similarly incorrect. Ex. 1053 ¶¶ 116-23.
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`7 UUSI also argues that (1) Kinzl does not teach or suggest the 40 ms limitation,
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`and thus does not “fill[] the void of Itoh with regard to dependent Claim 5”; and
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`(2) Itoh and Kinzl cannot be combined. R. 29. UUSI’s argument is
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`inapposite—Ground 3 does not rely on Kinzl for disclosure of the 40 ms
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`limitation, which is the only limitation at issue for claim 5. Corr. Pet. 41-47. In
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`addition, UUSI’s argument that Itoh and Kinzl cannot be combined is wrong
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`(addressed below in Section II).
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`
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`5
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`
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`UUSI ignores Itoh’s discussion of selecting number of measurements. Ex. 1001
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`¶ 127. Itoh implicitly teaches that the time period for sampled data is a parameter
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`to be selected. Ex. 1053 ¶¶ 110-15. It would have been obvious to a POSA to use
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`any of various values for the time period, depending on the requirements and
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`parameters of the system, utilizing routine experimentation and manipulation of
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`known variables, e.g., window and motor characteristics. Ex. 1053 ¶¶ 118.
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`Further, a POSA “would have understood the need to optimize the number and
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`time span of immediate past measurements based on system requirements and
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`parameters.” Id. at ¶ 119; see also Ex. 1032 298:18-300:4. “[W]here the general
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`conditions of a claim are disclosed in the prior art, it is not inventive to discover
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`the optimum or workable ranges by routine experimentation.” In re Aller, 220
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`F.2d 454, 456 (CCPA 1955); see also Ex. 1053 ¶ 122; Rexnord Indus., LLC v.
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`Kappos, 705 F.3d 1347, 1356 (Fed. Cir. 2013).
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`Additional evidence establishes that 40 ms was an obvious design choice:
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`• Dr. Ehsani, believes the 40 ms time period was “uniquely successful” simply
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`because it was claimed, but admits it is merely “exemplary.” Ex. 1053 ¶¶ 137-
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`39.
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`• The ’612 patent does not discuss the 40 ms limitation. See generally Ex. 1005;
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`Ex. 1053 ¶ 125. It does indicate that the number of stored values to use, and by
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`extension, the time frame, are based on design choices. Id. ¶ 129.
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`
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`6
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`
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`• In the one embodiment the specification describes in detail, the measurements
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`used span 90 ms, with more than 50% outside of 40 ms. Id. ¶¶ 126-28.
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`• The file history for the related ’802 patent notes that “[i]t would have been
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`obvious to one having ordinary skill in the art at the time the invention was
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`made to provide measurements at forty millisecond interval,” since “where the
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`general conditions of a claim are disclosed in the prior art, discovering the
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`optimum or workable ranges involves only routine skill in the art.” Id. ¶ 133.
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`• That the 40 ms limitation did not appear until nearly fifteen years into
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`prosecution, and that the 40 ms limitation is not claimed in any of the related
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`patents (aside from the ’802), also undermine UUSI’s position that this is a
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`“uniquely successful” value. Id. ¶¶ 130-36.
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`In short, the named inventors, the Examiner, and Dr. Ehsani all apparently believe
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`the 40 ms limitation is an obvious design choice. Claim 5 is invalid as obvious.
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`Id. ¶¶ 110, 121, 146-49.
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`C.
`
`Claims 6-8 are Invalid and Should Be Cancelled8
`1.
`Claims 6-8 are invalid as (i) obvious over Itoh (Ground 1),
`(ii) anticipated by Itoh under a broad construction (Ground
`2), and (iii) obvious over Itoh in view of Kinzl (Ground 3)
`
`In response to Brose’s Grounds 1-3, as to claims 6-8, UUSI raises a single
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`purported distinction regarding the prior art. UUSI’s argument is premised on its
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`8 Dependent claims 7-8 rise or fall with independent claim 6. See R. 44.
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`
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`7
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`
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`incorrect construction of the limitation reciting that the controller will “deactivate
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`said motor in response to a sensing said window or panel has stopped moving.”
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`UUSI contends that the proper construction is that “the controller must
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`mechanically or electronically deactivate the motor in response to an abrupt
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`stoppage of the panel (e.g., window) and not simply a deceleration of the panel or
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`the encountering of an obstacle by the panel” and that such deactivation in
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`response to an abrupt stoppage must be performed along the window’s entire travel
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`range. R. 32-34, 39. This construction is not only at odds with the positions UUSI
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`has taken in litigation against BNA,9 it is without support in the claim language or
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`the intrinsic evidence. The claim should be construed to cover the scenario where
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`the sensing that the window or panel has stopped moving can occur by sensing a
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`deceleration or gradual stoppage of the window (and can occur along only a
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`portion of the window’s travel range). Under the proper construction of the terms
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`at issue, UUSI has identified no difference between claim 6 and the prior art, and
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`claims 6-8 are invalid. Ex. 1053 ¶¶ 166, 170-75; 178-81, 187-92. Further, given
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`9 UUSI’s proposed construction, which excludes deactivating the motor in
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`response to deceleration of or encountering of an obstacle by the panel, is
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`inconsistent with its previous positions. During litigation, UUSI contended that
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`this limitation was met by products where, allegedly, “as an object is getting
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`trapped, the window will slow down.” Ex. 1018 34-35; see also id. 49, 71-72.
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`
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`8
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`
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`technical realities of power window systems, the prior art does disclose
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`“mechanically or electronically deactivat[ing] the motor in response to an abrupt
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`stoppage of the panel (e.g., window)” as UUSI argues is required. R. 33; Ex. 1053
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`¶ 181.
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`Moreover, even under UUSI’s incorrect construction, claims 6-8 would be
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`invalid as obvious because a POSA would readily recognize that the obstacle
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`detection algorithms disclosed in Itoh and Kinzl could be modified to respond to
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`abrupt stoppage along the entire travel range, as UUSI argues is required. Ex.
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`1053 ¶ 193.
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`a.
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`UUSI’s unduly narrow construction is contrary to the
`plain language of claim 6 and the intrinsic evidence
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`UUSI contends that the proper construction of the claim is to require that the
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`controller deactivate the motor in response to an “abrupt” stoppage along the
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`window’s entire travel path, and that “abrupt” stoppage means that the claim
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`requires hard (rather than soft) obstacle detection. Ex. 1032 335:8-336:17. As an
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`initial matter, it is unclear what claim 6 would mean under UUSI’s construction—
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`when does stoppage cross the line into “abrupt” stoppage? Ex. 1053 ¶¶ 37-38, 42.
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` Furthermore, UUSI identifies no support in the intrinsic record for its
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`construction. R. 32-34. Such a reading has no basis—the claim, the specification
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`(which does not even contain the word “abrupt”), and the prosecution history are
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`all silent about how abrupt or non-abrupt the stoppage must be. Ex. 1053 ¶¶ 40-45.
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`
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`9
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`
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`Moreover, UUSI’s construction not only reads the word “abrupt” into the claim,
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`but also reads “obstacle detection” into it. Nothing in the language of claim 6
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`requires obstacle detection, much less a specific type (i.e., hard obstacle). Id. ¶ 41.
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`It would be desirable to monitor the motor and deactivate the motor if the motor
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`remained activated while the window stopped moving for many reasons beyond a
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`person being trapped. Id.
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`In addition, there is no support for UUSI’s assertion that stoppage must be
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`sensed along the entire travel path—in fact, the only place the word “along”
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`appears in the claim is in the preamble, which just establishes that a window or
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`panel is moved “along a travel path.” Id. ¶¶ 59-60, 62-66. The specification
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`explains that obstacle detection is not actually performed at every point along the
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`entire travel path of the window. Id. ¶ 64.
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`2.
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`Claims 6-8 are invalid as (i) anticipated by Kinzl (Ground
`4), (ii) obvious over Kinzl (Ground 5), and (iii) obvious over
`Kinzl in view of Itoh (Ground 6)
`
`In response to Brose’s Grounds 4-6, as to claims 6-8, UUSI raises only a
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`single purported distinction regarding the prior art.10 UUSI’s argument is premised
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`on an overly narrow construction of claim 6 without support in the claim language
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`10 UUSI raises one additional issue regarding Ground 6 by referring to Ground 3,
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`ignoring that Grounds 3 and 6 are different. As UUSI’s arguments with respect
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`to Ground 3 fail, they also fail with respect to Ground 6. Ex. 1053 ¶¶ 209-13.
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`
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`10
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`
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`
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`or intrinsic evidence. The claim language is broader than UUSI contends and
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`covers the scenario where the controller is programmed with multiple position
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`limits that define an acceptable travel range, even if those position limits do not
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`include both the “fully open” and “fully closed” position limits defining the entire
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`travel range. Under the proper construction of the terms at issue, UUSI has
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`identified no difference between claims 6-8 and the prior art, and the claims are
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`invalid. Ex. 1053 ¶¶ 197, 202-205, 209-17.
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`Even under UUSI’s improper construction of claim 6, claim 6 is invalid as
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`obvious because a POSA would readily recognize (either in view of Kinzl, or
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`certainly in view of Itoh, which teaches) that the obstacle detection system
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`disclosed by Kinzl could be modified to include storage of the “fully open”
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`position limit that UUSI argues is required by claim 6. Ex. 1053 ¶ 218. The Board
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`preliminarily found as much in its institution decision. ID 24.
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`a.
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`UUSI’s construction has no basis in the language of
`claim 6 or in the intrinsic evidence
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`Although UUSI states that “[t]he limitation ‘controller programmed with
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`multiple position limits that define an acceptable travel range’ of Claim 6 should
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`have its plain and ordinary meaning,” UUSI’s proposed construction actually
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`requires modifying the plain language of the claim to add the limitations that “the
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`controller be programmed with at least (i) a value corresponding to a first end of an
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`acceptable travel range and (ii) a value corresponding to an opposite end of the
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`11
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`
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`acceptable travel range.” R. 35. And, reading even more into the claim, UUSI
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`further argues that the first and second ends of the acceptable travel range must be
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`the “fully open” and “fully closed” position limits, thereby defining the full travel
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`range of the window, not just an acceptable travel range. Id. UUSI’s changes the
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`plain language of the claim, without any effort to square its reading with the
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`intrinsic evidence beyond the empty statement that “[t]his interpretation is
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`consistent” with the specification. See generally id.
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`The claim language “programmed with multiple position limits that define
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`an acceptable travel range” is readily understandable. The words “an acceptable
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`travel range” connote that the claimed travel range may not necessarily be the
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`entire window travel range, but rather any amount of the full possible travel range
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`that is “acceptable”; “multiple position limits” connotes that the claim leaves open
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`the option of defining the “acceptable” travel range through three (or more)
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`position limits, and is not limited to only two specific position limits (fully open
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`and fully closed), as UUSI contends.11 Ex. 1053 ¶¶ 49, 51-56. That is precisely
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`what is described in the specification, and is precisely what UUSI asserted the
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`claim meant during prosecution. Id. ¶¶ 57-58.
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`11 That this plain meaning interpretation of the term is correct also is supported by
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`principles of claim differentiation. Ex. 1053 ¶¶ 54-55.
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`
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`12
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`
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`III. MOTIVATION AND ABILITY TO COMBINE12
`UUSI provides no explanation as to why a POSA would be discouraged
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`from modifying the references as explained in Brose’s Petition. Corr. Pet. 41-47,
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`57-58. As the Board preliminarily found, “one of ordinary skill in the appropriate
`
`art [would have] look[ed] to any and all of Itoh, Kinzl, and Zuckerman for a
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`solution to the ‘pinching’ problem.” ID 22.
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`With respect to the combination of Itoh and Kinzl, UUSI focuses only on an
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`issue that (1) assumes UUSI’s improperly narrow constructions, and (2) has no
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`material relevance to the invention recited in the challenged claims: UUSI asserts
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`that Kinzl and Itoh cannot be combined because using the Hall effect sensor of
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`Kinzl would purportedly defeat a supposed express objective of Itoh to avoid the
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`mounting of a special sensor. See, e.g., R. 15-17, 30, 40, 43-44.
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`As an initial matter, in responding to an obviousness argument, it is not
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`sufficient for UUSI to contend that the prior art teaches away from the claimed
`
`invention in a non-material respect. See In re Peterson, 315 F.3d 1325, 1331 (Fed.
`
`Cir. 2003). With respect to the challenged claims, it makes no material difference
`
`what type of sensor is used because the claims do not specify or limit the sensing
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`12 UUSI’s arguments regarding combining Zuckerman are inapposite, as Grounds 7
`
`and 8 present no additional issues over Grounds 1 and 3. Furthermore, UUSI’s
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`arguments find no support in the language of the claims. Ex. 1053 ¶¶ 234-39.
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`
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`13
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`
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`mechanism to any particular technology. Ex. 1053 ¶¶ 222-24. Further, UUSI’s
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`assertion that Itoh and Kinzl cannot be combined because Itoh “teaches away”
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`from utilizing the type of sensor disclosed in Kinzl is incorrect; Itoh merely
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`explains that it may be preferable to avoid use of a special sensor (e.g., to reduce
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`cost). Id. ¶¶ 220-33. There is nothing in Itoh that suggests that utilizing a special
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`sensor would render the system disclosed in Itoh inoperable or unlikely to function.
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`Syntex (U.S.A.) LLC v. Apotex, Inc., 407 F.3d 1371, 1380 (Fed. Cir. 2005) (“A
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`statement that a particular combination is not a preferred embodiment does not
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`teach away absent clear discouragement of that combination.”); Ex. 1053 ¶ 225.
`
`IV. ENABLEMENT
` UUSI does not argue that Itoh or Kinzl (either alone or in combination with
`
`other references) are not enabling as to any particular challenged claim. Instead,
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`UUSI argues that, in real-world scenarios, the disclosed algorithms would lead to
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`an
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`inordinate amount of false positives or negatives and
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`thus prevent
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`implementation in production vehicles. R. 45. This is a red herring. It suffices
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`that Itoh and Kinzl (alone or in combination) provide sufficient disclosure to allow
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`a POSA to make and use the claimed UUSI inventions as recited in each of the
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`challenged claims of the ’612 Patent. In re Antor Media Corp., 689 F.3d 1282,
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`1290 (Fed. Cir. 2012) (“Enablement of prior art requires that the reference teach a
`
`skilled artisan to make or carry out what it discloses in relation to the claimed
`
`
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`14
`
`
`
`
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`invention. Even if a reference discloses an inoperative device, it is prior art for all
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`that it teaches.”) (internal citations and quotation marks omitted); Symbol Techs.,
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`Inc. v. Opticon, Inc., 935 F.2d 1569, 1578 (Fed. Cir. 1991) (“[A] non-enabling
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`reference may qualify as prior art for the purpose of determining obviousness
`
`under § 103.”). Itoh enables each of the challenged claims, either alone or in
`
`combination with Kinzl and/or Zuckerman. Ex. 1053 ¶¶ 240-49. Kinzl enables
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`claims 6-8 of the ’612 patent, either alone or in combination with Itoh. Ex. 1053
`
`¶¶ 250-55.
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`
`
`Date: February 5, 2015
`
`Respectfully submitted,
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`
`
`
`
`
`
`
`
`/s/ Craig Leavell
`Craig D. Leavell (Reg. No. 48505)
`Alyse Wu (Reg. No. 68926)
`Luke L. Dauchot (pro hac vice)
`KIRKLAND & ELLIS LLP
`300 North LaSalle Street
`Chicago, Illinois 60654
`P: 312.862.2000; F: 312.862.2200
`craig.leavell@kirkland.com
`alyse.wu@kirkland.com
`luke.dauchot@kirkland.com
`
`Attorneys For Petitioners
`
`15
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies
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`that a copy of
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`the
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`foregoing
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`PETITIONERS’ REPLY was served on February 5, 2015 via electronic mail
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`upon the following:
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`Monte L. Falcoff
`Michael R. Nye
`HARNESS, DICKEY & PIERCE, P.L.C.
`5445 Corporate Drive, Suite 200
`Troy, Michigan 48098
`plloyd@hdp.com
`mnye@hdp.com
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`Attorneys for Patent Owner UUSI, LLC
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`16
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`Respectfully submitted,
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`/s/ Craig Leavell
`Craig Leavell (Reg. No. 48505)
`Alyse Wu (Reg. No. 68926)
`Luke Dauchot (pro hac vice)
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`Attorneys For Petitioners
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