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`Paper No. 83
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`MOTOROLA MOBILITY LLC,
`Petitioner,
`
`v.
`
`INTELLECTUAL VENTURES II LLC,
`Patent Owner.
`_____________
`
`Case IPR2014-00504
`Patent 7,382,771 B2
`____________
`
`Record of Oral Hearing
`Held May 1, 2019
`_____________
`
`
`
`Before MICHAEL W. KIM, PATRICK R. SCANLON, and
`KRISTINA M. KALAN, Administrative Patent Judges.
`
`
`
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`571-272-7822
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`Paper No. 83
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`MOTOROLA MOBILITY LLC,
`Petitioner,
`
`v.
`
`INTELLECTUAL VENTURES II LLC,
`Patent Owner.
`_____________
`
`Case IPR2014-00504
`Patent 7,382,771 B2
`____________
`
`Record of Oral Hearing
`Held May 1, 2019
`_____________
`
`
`
`Before MICHAEL W. KIM, PATRICK R. SCANLON, and
`KRISTINA M. KALAN, Administrative Patent Judges.
`
`
`
`
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`
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`
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`IPR2014-00504
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`A P P E A R A N C E S:
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`
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`ON BEHALF OF PETITIONER:
`JOHN C. ALEMANNI, ESQUIRE
`MICHAEL MORLOCK, ESQUIRE
`COURTNEY S. DABBIERE, ESQUIRE
`DAVID A. REED, ESQUIRE
`KILPATRICK TOWNSEND & STOCKTON, LLP
`1100 Peachtree Street NE
`Suite 2800
`Atlanta, GA 30309
`404-420-1724
`
`
` ON BEHALF OF THE PATENT OWNER:
`TED M. CANNON, ESQUIRE
`JOHN R. KING
`KNOBBE, MARTENS, OLSON & BEAR, LLP
`2040 Main Street
`14th Floor
`Irvine, CA 92614
`817-470-7249
`
`ALSO PRESENT
`Mishima Alam - Google
`James Hietala, Esquire - Intellectual Ventures
`Nita Gray, Esquire - Kilpatrick Townsend
`
`
`
`
`
`The above-entitled matter came on for hearing on May 1, 2019,
`commencing at 1:00 p.m., at U.S. Patent & Trademark Office, 600 Dulany
`Street, Alexandria, Virginia 22314.
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` (Proceedings begin at 1:00 p.m.)
` JUDGE SCANLON: Good afternoon and welcome,
`everyone. This is a supplemental hearing for IPR2014-00504
`involving Patent No. 7,382,771. I'm Judge Scanlon. Joining
`me on the panel are Judge Kim and Judge Kalan.
` Let's start with appearances. Could Petitioners'
`Counsel please step to the podium and introduce yourselves?
` MR. ALEMANNI: Yes. Thank you, Your Honor. I'm
`John Alemanni, lead counsel for Petitioners, Motorola, in the
`'504 proceeding and Google in the '787 proceeding.
` With me today are David Reed, who'll be presenting
`in the '504 case on behalf of Motorola. Michael Morlock and
`Courtney Dabbiere will be presenting in relation to the '787.
`This is Ms. Dabbiere's first argument before the PTAB (ph).
`With us on behalf of Google is Ms. Mishima Alam. And also
`helping us today with demonstratives will be Nita Gray.
` Thank you, Your Honors.
` JUDGE SCANLON: Okay. Thank you. Unfortunately,
`I'm currently not hearing anything from the hearing room. So
`I apologize for that. Hopefully, the technical people can
`connect the audio. I'm getting the video, but not the audio.
` (Off the record discussion.)
` THE COURT VIDEOGRAPHER: Can you hear us now?
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` JUDGE SCANLON: Yes, I can. Thank you.
` So -- I mean, why don't we -- so I couldn't hear the
`introductions, but I believe Petitioners' Counsel introduced
`themselves. If you wouldn't mind repeating that really
`quickly, I would appreciate it.
` MR. ALEMANNI: Absolutely, Your Honor. I'm John
`Alemanni on behalf of Petitioners, Motorola, in this case and
`Google in the second case today.
` Mr. David Reed is joining us. He'll be arguing the
`'504 proceeding, the first proceeding. Ms. -- Mr. Michael
`Morlock and Ms. Courtney Dabbiere will be arguing the second
`proceeding today, the '787. This will be Ms. Dabbiere's first
`oral argument. And with us from Google is Mishima Alam. And
`then helping me with demonstratives today is Ms. Nita Gray.
` JUDGE SCANLON: Okay. Thank you.
` MR. ALEMANNI: Thank you, Your Honor.
` JUDGE SCANLON: I apologize for the technical
`glitch.
` MR. ALEMANNI: No problem.
` JUDGE SCANLON: And Patent Owner, please.
` MR. CANNON: Yes, Your Honors. I'm Ted Cannon. I'm
`lead counsel for Patent Owner, Intellectual Ventures, in both
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`proceedings, and I will be arguing both proceedings.
` With me is John King. And also with me is a
`representative of Intellectual Ventures, James Hietala.
` JUDGE SCANLON: Okay. Thank you. This is a
`supplemental hearing and so the arguments will be limited to
`the issues the parties did not have an opportunity to address
`in the previous hearing.
` As set forth in the hearing order, each party will
`have 45 minutes to present arguments. Petitioner will present
`its case first and may reserve time for rebuttal. Patent
`Owner will then present its case. After which Petitioner may
`use any time they reserved for rebuttal. Last, Patent Owner
`may request an opportunity to present a brief sur-reply to
`Petitioner's rebuttal.
` By way of reminder, I ask each presenter to be sure
`to speak into the microphone, now that we have audio, so we
`can hear you clearly. And I also ask that each presenter try
`to identify the demonstrative being referred to by slide
`number so those of us participating remotely can follow along.
`It's also helpful in creating a complete record.
` With that, I'll let Petitioner take the podium.
` Do you intend -- pardon me. Do you intend to
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`reserve any time for a rebuttal?
` MR. REED: Good afternoon, Your Honors. I would
`expect that my presentation will take about 25 minutes,
`depending on questions from the panel. I would reserve the
`remainder of that time for rebuttal.
` JUDGE SCANLON: That's fine. Thank you.
` MR. REED: And --
` JUDGE SCANLON: Please proceed when you're ready.
` MR. REED: Thank you, Your Honor. And before I get
`started, Judge Kim, can I offer you a copy, and the court
`reporter, a copy -- a physical copy of the demonstratives?
` JUDGE KIM: Sure.
` Thank you, sir.
` MR. REED: Thank you, Your Honors. And again, my
`name is David Reed. I'm here on behalf of the Petitioner,
`Motorola Mobility. And I will be discussing the prior art
`challenges to the '771 Patent that is at issue in this
`proceeding.
` The '771 Patent relates to mobile wireless hotspot
`systems. Which may be used, for example, in a vehicle to
`allow client devices, such as passengers' laptop computers or
`mobile phones, to connect to the internet.
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` If we could turn to Slide 3, please, Ms. Gray. I'll
`start with just an overview of the challenges that are at
`issue here today in the supplemental oral hearing. The
`challenge claims are listed here. They're Claims 1 to 4, 7,
`and 18 of the '771 Patent. And the prior art challenges are
`based on four different pieces of prior art, which are also
`listed here.
` And the first three of those four references, Boehm,
`Mitchell, and Veeck (ph), I would note were also at issue in
`the original proceedings in this case and addressed in the
`Board's original final written decision. The Kellerer (ph)
`reference, which is Exhibit 1007, is a new reference for this
`supplemental proceeding. It was not previously addressed, so
`it didn't form a part of those original grounds that were
`instituted.
` After the SAS (ph) decision, the Board instituted on
`all of the grounds presented in the petition that had not
`previously been instituted. And there are 10 of those. And
`as framework for the analysis -- for Your Honors' analysis,
`it's helpful to divide those claims into two groups. First,
`there are six grounds -- six prior art combinations that
`include the Boehm reference. And I refer to those as the Boehm
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`grounds. And there are four grounds that involve prior art
`combinations that do not include Boehm. And I refer to those
`as the non-Boehm grounds.
` The non-Boehm grounds will be the focus of my
`presentation today. But first, I would like to briefly
`address the Boehm grounds. If we could turn to Slide 4,
`please.
` Those six grounds, which are all prior art
`combinations that include Boehm, are listed here on Slide 4.
`Patent Owner concedes here that the challenged claims are
`obvious if the Boehm reference is prior art. So Patent Owner has
`offered no argument attempting to distinguish these grounds
`from the challenge claims, and is rested on its argument that
`Boehm is not prior art. That was the issue that was appealed
`to the federal circuit and that is now on remand and was
`subject to supplement remand briefly before SAS.
` So that issue of whether Boehm is prior art is not
`before the Board. The Board has ordered that these
`supplemental proceedings not include that issue and that that
`issue not be part of the oral hearing today.
` So let's turn to Slide 5 and turn to the non-Boehm
`grounds. And those four grounds are listed here. They're
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`prior art combinations of various combinations of three
`references, Mitchell, Kellerer, and Veeck. And the only disputed
`issue for these grounds is whether Mitchell, Kellerer, and Veeck
`disclosed the stand-alone system limitation of the challenged
`claims. So I will explain during the hearing today that
`Mitchell, Veeck, and Kellerer each do disclose the stand-alone
`system limitation.
` So let's take a look at that limitation and turn to
`Slide 6. Slide 6 is -- lists here Claim 1 -- Challenge Claim
`1 of the '771 Patent. And highlighted on this slide is the
`stand-alone system limitation. And it reads "A stand-alone
`system that enables client devices to access the internet
`without the need to access an external service controller
`server."
` Now, that same limitation was an addressed by the
`Board during the original proceedings. And if we turn to
`Slide 7, we can see where the Board addressed the construction
`of that term in its institution decision; the original
`institution decision, in this case, in Paper 12.
` So the Board, in analyzing this term, first noted,
`this is the highlight at the top of this excerpt, that the
`'771 Patent does not describe the term, "stand-alone system." So
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`why is that important in this proceeding? Well, it's
`important because, as I will discuss in connection with the
`prior art, the prior art teaches all of the elements that are
`required to enable internet access, just like the '771
`Patent.
` And the '771 Patent doesn't use the term. That
`wasn't added until years down the line during prosecution.
`But it describes functionality local to the hotspot that
`enables internet access without the need for an external
`service controller server. And I'll be describing that the
`prior art does just the same.
` So the Board just applied the ordinary and customary
`meaning of "stand-alone system," and the construction is
`highlighted at the bottom. "A system capable of operating
`independently of any other system." After institution, that
`term wasn't disputed further, the construction, so the Board
`maintained that construction in its final written decision.
` Let's turn to Slide 8. In the supplemental
`briefing, Patent Owner is offered a construction of the
`broader stand-alone system limitation set forth here. On the
`left is the term, on the right of this table is the Patent
`Owner's proposed construction. And there's no dispute here
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`about claim construction, I don't believe. All Patent Owner
`does is take the stand-alone system term that was construed,
`which is in red here, and add the additional surrounding
`express language of the term.
` So there's no dispute here that that green language
`is part of the claim, it's a requirement of the claim. And,
`indeed, the Board recognized this in the original final
`written decision, and has applied that claim language in its
`analysis the first go-around. So we don't believe that
`further construction is necessary here.
` And so with that discussion of the claim
`construction issue, I'll now turn to the prior art references,
`Mitchell, Veeck, and Kellerer, and describe how those references
`each disclose this stand-alone system limitation. And I'll
`first take a look at Kellerer before we turn to the Mitchell and
`Veeck references.
` So, Ms. Gray, if we could turn to Slide 16, please.
`And take a look at Kellerer. So again, Kellerer was not part of
`the original grounds, so it wasn't previously considered in
`the Board's final written decision. What Kellerer discloses is
`a vehicle-based hotspot, which Kellerer describes as a gateway.
`And Kellerer further describes that the server architecture for
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`that gateway is located inside the car. And that's
`highlighted here from Kellerer in Exhibit 1007 at Page 4. And,
`indeed, that's the goal of Kellerer is to describe a server
`architecture for a hotspot that's located inside of a vehicle.
`So Kellerer is describing a stand-alone system.
` Now, let's turn to Slide 17 and take a further look
`at what Kellerer teaches about its server architecture. So on
`Slide 17, we have a figure, Figure 4 of Kellerer, that describes
`the components of the Kellerer hotspot. And just to orient Your
`Honors for what this figure is showing, along the top is in --
`is a row of ovals. And those are various client devices, such
`as a PDA or a mobile phone. Those are passenger devices
`within the vehicle. And those client devices are connected to
`the Kellerer hotspot through a short-range wireless access
`point.
` At the bottom is another row of ovals that are
`labeled GSM, UMTS, and the like. And those are outside
`communication networks. Those are long range wireless
`internet access interfaces that allow the hotspot to connect
`to long range mobile data/cellular data networks.
` Everything in the box in the middle are -- is the hotspot
`itself -- the Kellerer hotspot and the components of that
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`hotspot. That Kellerer hotspot has all of the components that
`would be needed to enable a device to access the internet. It
`has -- as we see here, it has routing, address management,
`there are local application servers, and there's a local
`content module, which Kellerer refers to as a proxy cache.
` Let's turn to Slide 18. I mentioned earlier in
`connection with claim construction that the '771 Patent
`doesn't use the term stand-alone system or it doesn't -- and it
`also doesn't use the term external service controller server,
`but what it does do is describes certain functionality that is
`local to the hotspot. Kellerer has the same functionality local
`to its hotspot that the '771 Patent does. The disclosures are
`fundamentally the same. And we explained this in our
`supplemental reply, Paper 71, Pages 13 to 14. Here we've put
`it into a table format, so it's more visual, comparing the
`disclosures of the '771 Patent and Kellerer.
` So as I mentioned, the '771 Patent has local address
`management functions, such as DHCP and network address
`translation, or NAT, that are performed locally at the
`hotspot. Kellerer, likewise, teaches address management
`functionality internally within its hotspot, and that's in
`Figure 4.
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` The '771 Patent also describes a local content
`module that's internal to the hotspot. The Kellerer also has a
`local content module. Kellerer calls that the proxy cache.
`Both the '771 Patent and Kellerer both have application servers,
`such as web servers or e-mail servers. Those are located
`inside the hotspot again.
` And then finally, the last row at the bottom of this
`table explains that both Kellerer and the '771 Patent teach
`communication network manager, which the '771 Patent refers to
`as a WAN manager, that manages that long-range connection
`between the hotspot and a mobile cellular data network,
`specifically, in both the case of the '771 Patent and Kellerer,
`a GPRS cellular network.
` So again, the disclosures of the '771 Patent and
`Kellerer are fundamentally the same. Kellerer teaches a
`stand-alone system that enables client devices to access the
`internet without the need to access an external service
`controller server.
` Let's turn to Slide 19, Ms. Gray. And here we --
` JUDGE SCANLON: Excuse me, Mr. Reed. So can you
`explain how Kellerer actually accesses the internet? I mean,
`you reference the outside networks at the bottom of Figure 4,
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`but does Kellerer explain, you know, how it connects to the
`internet? I guess my question is, does it specifically say it
`doesn't use an external server?
` MR. REED: Your Honor, it does not specifically use
`the terms external service controller server. I would also
`mention that the '771 Patent, likewise, does not use the term
`external service controller server. But like the '771 Patent,
`Kellerer teaches that there's a network manager within the
`hotspot that manages that connection. And that sets up a
`connection, such as a GSM or GPRS connection. There are other
`standards or other networks that are also mentioned in Kellerer.
`But we point out specifically GPRS because it's identical to
`the disclosure of the '771 Patent.
` JUDGE SCANLON: Okay. Thank you.
` MR. REED: So Kellerer expressly discloses the
`stand-alone system on its face. If we could turn to Slide 20.
`I would also note that Petitioner offered expert testimony
`from Dr. Roy (ph). And Dr. Roy further testified regarding
`the understanding of a person of ordinary skill in the art.
` Dr. Roy explained that a person of ordinary skill in the
`art would understand that Kellerer meets the stand-alone system
`limitation. And he was asked about this opinion during
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`cross-examination during the supplemental proceedings.
`Opposing counsel asked Dr. Roy, "Is it your opinion that --
`and this is highlighted on the slide -- Is it your opinion
`that the gateway server enables client devices to access the
`internet without the need to access and external service
`controller server?” And Dr. Roy said, “Yes.” And he explained
`that opinion.
` He said he referenced Kellerer's teaching that the e-mail
`server is located on the car that is implemented on the
`gateway -- the service gateway in the car. So this is further
`evidence that a person of ordinary skill in the art would
`understand those express teachings of Kellerer. Which
`specifically -- again, specifically match those of the '771
`Patent itself.
` So in conclusion on Kellerer, the evidence shows that
`Kellerer discloses a stand-alone system, that it doesn't need to
`access an external service controller server. So if there are
`no further questions on Kellerer, I would like to next turn to
`the Mitchell and Veeck references.
` So, Ms. Gray, if we could turn to Slide 10. Again,
`Mitchell and Veeck were part of the original proceedings, part
`of the originally instituted grounds. So the Board looked at
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`Mitchell and Veeck in its original final written decision and
`determined that those two references also teach a stand-alone
`system -- the stand-alone system limitation. And in doing so,
`rejected Patent Owner's arguments to the contrary. And that
`was at Paper 46, which was the final written decision at Pages
`26 to 28 for Mitchell and 32 to 33 for Veeck.
` Now, Patent Owner appealed the Board's final written
`decision, but Patent Owner's appeal was limited to the Boehm
`reference, and specifically whether that reference is prior
`art. Patent Owner did not appeal any of the Board's findings
`regarding Mitchell or Veeck. So those findings were
`uncontested and decided by the Board previously, and there's
`simply no need here to revisit that same issue and relitigate
`it here for a second time.
` If we could turn to Slide 11, please. And that
`doctrine that is law of the case -- the doctrine law of the
`case, which instructs us that decisions that are once made are
`not to be disregarded unless there are some exceptional
`circumstances that would justify revisiting that earlier
`decision.
` Here, Patent Owner has not offered any
`circumstances, much less exceptional circumstances, that would
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`warrant relitigating the same issue for a second time. And
`the reason for this doctrine is reflected in the quote here at
`the bottom, both of these quotes are from the Toro (ph) case
`that's cited on the slide, on Slide 11. And the reasons for
`this doctrine is to ensure judicial efficiency and to prevent
`the possibility of endless litigation. But even if the Board
`were to revisit the Mitchell and the Veeck references, the
`analysis is the same here. So the Board should reach the same
`decision it did the first time around.
` So let's take a look at Mitchell and Veeck briefly,
`starting with Mitchell. Let's turn to Slide 12, Ms. Gray. So
`the -- so Slide 12 shows Figure 12 of the Mitchell reference.
`This is Exhibit 1006 at Page 12, which is also Figure 12.
`What Mitchell is describing is a hotspot on an airplane that
`receives internet content from a satellite.
` Now, Mitchell has a number of embodiments. Our
`expert, Dr. Roy, also pointed to an embodiment based on an
`automobile in Exhibit 1010. So there are a number of
`embodiments here, but the one that the Board relied on in its
`original final written decision and the one we rely upon here
`today, is an embodiment where Mitchell receives broadcast or
`push internet content from a satellite.
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` And the Board previously found, this is in the final
`written decision, Paper 46 at Page 27, that this push internet
`embodiment is a stand-alone system. It meets the stand-alone
`system limitation and doesn't require an external service
`controller server. And just to show you that push internet
`embodiment, Ms. Gray, if we could zoom on the top right two
`boxes of Figure 12.
` Thank you. So here the satellite is on the far
`right, orbiting the earth, Reference No. 340. That satellite
`is a direct broadcast satellite, as described by Mitchell.
`And it transmits internet content down to the aircraft, which
`is received at the receiver onboard the aircraft, Reference
`No. 260. The receiver receives this internet content from the
`satellite and then transmits that content, passes that content
`to the Aircraft Network Server 271. Which in turn, is
`distributed -- can be distributed wirelessly, which is
`Reference No. 275, to client devices/passenger devices at
`individual passenger seats. And we see here an example of one
`of those devices, a laptop computer at Reference No. 272.
` So I would also mention there's a unique identifier
`that's disclosed in the Mitchell reference at Column 20, Lines
`28 to 34, that's built-in functionality that allows the -- it
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`allows that aircraft network server to send particular content
`to particular passenger devices. So Mitchell, the push
`internet embodiment is a stand-alone system. There can be no
`argument that this embodiment requires an external service
`controller server.
` JUDGE SCANLON: Well, what about the back channel
`that Patent Owner has raised?
` MR. REED: So thank you, Your Honor, for that
`question. At Column 20, around Lines 16 -- 13 to 28, the
`reference describes that, while the back channel is optional
`to -- in order to enable two-way internet, it's not required
`by the push or the broadcast internet embodiment. So the back
`channel is simply an alternative embodiment that enables
`two-way internet communication.
` So that's my first point is that the back channel
`simply isn't required at all here. But even if the Board were
`to consider the back channel, it's -- just to orient Your
`Honors, the back channel has Reference No. 280. The back
`channel does not, in Figure 12, require or disclose an
`external service controller server. Rather, Patent Owner has
`pointed to another embodiment in another figure, in Figure 11
`for that.
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` I also would note that Mitchell, much like the '771
`Patent itself, has this intermediary communication path to the
`internet. So any mobile hotspot is going to connect on the
`other end to another system, such as a base station -- a
`remote base station, which will have a series of nodes or
`servers connected which enable that path to the broader
`internet. That's the same thing that Mitchell is disclosing
`here. And Mitchell doesn't -- it has addressing abilities
`locally, as I just mentioned. There's no need for an external
`service controller server disclosed here.
` So if there are no further questions regarding
`Mitchell, I'll turn, finally, to the Veeck reference. If we
`could turn to Slide 14, Ms. Gray. And Veeck -- and it's a bit
`redundant. This is another example of a hotspot located on a
`vehicle. Veeck discloses that this hotspot could be
`implemented on, for example, an aircraft or a bus or a train.
` And Figure 2 of Veeck shows that hotspot system.
`Well, Patent Owner's argument is that Veeck requires an
`external server to enable internet access. And Patent Owner
`points to Reference No. 60, the service provider
`communications equipment in Figure 2. If we can highlight
`that? But this element of Figure 2 is not external to the
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`hotspot. And how do we know that?
` Well, we know that it teaches -- Veeck specifically
`teaches this in Paragraph 27 that that service provider
`communications equipment is connected to the data server,
`which is Reference No. 30 just above, using a hardwired
`connection, a serial, or a parallel connection. So it's
`apparent from the reference, you can't have a wired connection
`to something outside the vehicle.
` So that teaches us that that service provider
`communications equipment is on the vehicle. It's part of the
`system. So Patent Holder's argument on that point is simply
`incorrect. Veeck, likewise, teaches a stand-alone system that
`doesn't require an external service provider controller
`server.
` If there are no further questions, I would reserve
`the remainder of my time for rebuttal.
` JUDGE SCANLON: Okay. Thank you. You have 21
`minutes remaining.
` MR. REED: Thank you, Your Honor.
` MR. CANNON: Your Honor, while we're switching
`tables, I have hard copy slides for Judge Kim.
` JUDGE SCANLON: Okay. Thank you.
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` JUDGE KIM: Thank you, sir.
` JUDGE SCANLON: Proceed when ready.
` MR. CANNON: Good afternoon, Your Honors. As I
`mentioned, I'm Ted Cannon representing Intellectual Ventures.
`With me is John King and a representative of IV, James
`Hietala.
` I'd like to move to Slide 2 of our presentation.
`And in agreement with counsel on the other side, there are
`some issues that are on remand, but not part of the
`supplemental portion of the hearing. And those are the Boehm
`issues. Moving to Slide 3. An issue that is central to all
`of the grounds that are at stake in this hearing is
`construction of the stand-alone system limitation.
` Moving to Slide 4. The stand-alone system limitation
`has two important parts highlighted here. In yellow, we have
`the actual phrase, stand-alone system. That portion of the
`limitation has been construed by the Board. In orange, we
`have an additional requirement of the limitation that the
`stand-alone system must enable client devices to access the
`internet without the need to access an external service
`controller server.
` Moving to Slide 5. Opposing Counsel indicated, and
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`I believe it's correct, that there's no real substantive
`dispute that both of the portions of the limitation that I
`mentioned are part of the claim, and there's no real
`substantive dispute about what those words of the claim mean.
`As counsel indicated, the Board already construed the phrase,
`stand-alone system.
` Our only recommendation here, our only proposal with
`respect to claim construction, is that for clarity of the
`record that the Board enter an express construction of the
`entire limitation, including the second part of that
`limitation. Which is the requirement to provide internet
`access without the need to access an external service
`controller server. So our proposal is simply to combine those
`two limitations -- those portions of the limitation together
`and make a construction of the entire limitation part of the
`record.
` Moving to Slide 6. We're now going to get into the
`substantive issues. The Kellerer reference, in particular,
`we'll start off with. Just by way of context, the newly
`instituted grounds, every one of them is a combination that
`includes either two or three of the references that Counsel
`talked about, including Kellerer, Mitchell, and Veeck. Every one
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`of them is a combination of two of the three. But
`importantly, as we'll show, neither -- not one of those
`references shows the stand-alone system limitation.
` And because of that, regardless of which way you
`combine them, you can mix them, you can match them, whichever
`way you combine them, every combination is going to have the
`same problem. There's a simple missing limitation here.
`There's no disclosure in any of the references of the
`stand-alone system limitation.
`
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