throbber
Attorney Docket No.
`
`IPR2014-01181
`110797-0004-655
`
`U.S. Patent No. 8,532,641 B2
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`SAMSUNG ELECTRONICS CO., LTD and SAMSUNG ELECTRONICS
`AMERICA, INC.,
`Petitioners
`
`v.
`
`AFFINITY LABS OF TEXAS, LLC
`Patent Owner
`______________
`
`Case IPR2014-011811
`Patent 8,532,641 B2
`______________
`
`Before the Honorable KEVIN F. TURNER, LYNNE E. PETTIGREW, and
`JON B. TORNQUIST, Administrative Patent Judges.
`
`
`
`PETITIONERS’ RESPONSE TO
`PATENT OWNER’S MOTION FOR OBSERVATION ON
`EXAMINATION OF DR. SCHUYLER QUACKENBUSH
`
`
`1 Case Nos. IPR2014-01182 and IPR2014-01184 have been consolidated with the
`
`instant proceeding. See IPR2014-01181, Paper 15; IPR2014-01182, Paper 15; and
`
`IPR2014-01184, Paper 15. In view of this consolidation, Petitioners submit this
`
`single Response in IPR2014-01181.
`
`
`
`

`
`
`IPR2014-01181
`
`U.S. Patent No. 8,532,641 B2
`GLOSSARY OF ABBREVIATIONS
`
`Attorney Docket No.
`110797-0004-655
`
`Shorthand
`PO
`POSA
`ID1
`
`ID2
`
`ID3
`
`R
`RP
`
`Description
`
`Patent Owner
`Person of Ordinary Skill in the Art
`IPR2014-01181, Paper 10, Decision Institution of Inter Partes
`Review
`IPR2014-01182, Paper 10, Decision Institution of Inter Partes
`Review
`IPR2014-01184, Paper 10, Decision Institution of Inter Partes
`Review
`IPR2014-01181, Paper 20, Patent Owner’s Response
`IPR2014-01181, Paper 23, Petitioners’ Reply to Patent Owner’s
`Response
`
`
`Note: All emphasis herein added unless otherwise stated.
`
`
`
`
`

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`Attorney Docket No.
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`IPR2014-01181
`110797-0004-655
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`U.S. Patent No. 8,532,641 B2
`Petitioners have the following responses to each of PO’s observations on the
`
`September 30, 2015 cross-examination testimony of Dr. Quackenbush (Pap. 32):
`
`Response to Observation #1. PO’s observation is improper and should be
`
`expunged or not considered because it contains attorney argument. To the extent
`
`considered, PO argues that Dr. Quackenbush advanced positions “for the first time
`
`in his supplemental declaration” for the claim terms “stream a signal” / “streaming
`
`audio signal,” “communication rate,” and “provides for a CD quality listening
`
`experience”—but Dr. Quackenbush assumed a construction for each of these terms
`
`in his initial declarations (Ex. 1023¶27, 1123¶27, 1223 ¶28); and in direct response
`
`to Dr. Wolf’s opinions, Dr. Quackenbush opined on the proper construction for
`
`these terms in his rebuttal declaration (Ex. 1025 ¶¶47-49, 51-58). See Ex. 2038 at
`
`21:3-22:3. Dr. Quackenbush testified that the proper construction for these terms is
`
`consistent with his initial declarations and the ‘641 patent specification (Ex. 2038
`
`at 8:12-11:13, 21:19-22:3). Further, the testimony PO cites is incomplete—it
`
`should include Ex. 2038 at 8:12-12:5, 12:23-13:6, 25:4-28:17; and contrary to
`
`PO’s assertion, it is not relevant to at least Ex. 1025 ¶¶43-46, 50, 59-61.
`
`Response to Observation #2. PO’s observation is improper and should be
`
`expunged or not considered because it contains attorney argument. To the extent
`
`considered, the Board correctly construed “streaming audio signal.” ID1 at 7-8;
`
`ID2 at 7-8; ID3 at 6-7; Ex. 1015 at 7. PO is wrong that the constructions for
`
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`Attorney Docket No.
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`IPR2014-01181
`110797-0004-655
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`U.S. Patent No. 8,532,641 B2
`“stream a signal” and “streaming audio signal” are “over[broad].” In response to
`
`Dr. Wolf’s declaration, Dr. Quackenbush agreed with the Board that the ordinary
`
`meaning of “streaming audio signal” is an “audio signal that is transferred in a
`
`continuous stream,”—consistent with the ‘641 patent specification. Ex. 1025 ¶47.
`
`During his deposition, Dr. Quackenbush confirmed this understanding. Ex. 2038 at
`
`9:14-18 (“streaming speaks to a transfer of data, and that may result in
`
`downloading as ‘641 informs us.”); see also Ex. 2038 at 9:9-11:13, 14:9-17; Ex.
`
`1001 at 8:31-35; Ex. 1025 ¶47; RP4.
`
`Response to Observation #3. PO’s observation is improper and should be
`
`expunged or not considered because it contains attorney argument and raises new
`
`arguments which constitute improper sur-reply. To the extent considered, the
`
`testimony PO cites does not demonstrate that “Petitioners’ arguments and Dr.
`
`Quackenbush’s opinions regarding the functionality of Bluetooth … are based
`
`upon a selective, hindsight-driven analysis,” as PO argues. During his deposition,
`
`Dr. Quackenbush confirmed the opinions set forth in his declarations that a POSA
`
`would have been motivated to use Bluetooth to wirelessly transfer data and
`
`implementing Bluetooth would have worked, based on the cited references and the
`
`knowledge of a POSA. See Ex. 2038 at 16:9-16, 17:16-18:18; see also Ex. 1023
`
`¶¶74-76, Ex. 1123 ¶¶83-84; Ex. 1025 ¶¶68-79, 117-122, 133-155. And with
`
`respect to the Bluetooth specification, Dr. Quackenbush testified that Bluetooth
`
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`Attorney Docket No.
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`IPR2014-01181
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`U.S. Patent No. 8,532,641 B2
`“has been available and was … widely publicized, widely adopted, and therefore
`
`would be well-known to [a POSA],” and that he reviewed the Bluetooth
`
`specification in preparing his declarations and cited it in his rebuttal declaration.
`
`Ex. 2038 at 16:9-16, 18:19-19:24.
`
`Response to Observation #4. PO’s observation is based on an underlying
`
`premise that is false: Petitioners do not argue “that Abecassis itself teaches a
`
`rechargeable power supply” (see RP10). Thus, this observation is irrelevant.
`
`Consistent with his declarations, Dr. Quackenbush testified that it would have been
`
`obvious to include a rechargeable battery in Abecassis’ multimedia player based
`
`on the knowledge of a POSA or Herrod. Ex. 2038 at 34:21-35:4 (“So that citation
`
`which I just read out, plus one of ordinary -- plus the skill of a person, plus the
`
`knowledge of a [POSA] and then of course I bring in Herrod.”); see also Ex.
`
`2038 at 35:16-22; Ex. 1123 ¶¶41-44; Ex. 1025 ¶¶89-93. And, Dr. Quackenbush
`
`cited Herrod’s disclosure that battery charging technology was “well known to the
`
`skilled person...” (Ex. 1106 at 14:18-24) (not a “single disclosure” in Abecassis, as
`
`PO asserts) to support his opinion that it would have been obvious to a POSA that
`
`Abecassis’ power supply could be rechargeable. Ex. 1123 ¶42; Ex. 2038 at 35:5-15.
`
`Response to Observation #5. PO’s observation is improper and should be
`
`expunged or not considered because it contains attorney argument and raises new
`
`arguments which constitute improper sur-reply. To the extent considered, PO is
`
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`Attorney Docket No.
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`IPR2014-01181
`110797-0004-655
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`U.S. Patent No. 8,532,641 B2
`wrong that Dr. Quackenbush’s opinion is based “only upon … [a] general
`
`interpretation of the Herrod reference.” Dr. Quackenbush opined that the claimed
`
`“physical interface” was well known in the art, and it would have been obvious to
`
`include the claimed physical interface in Abecassis’ multimedia player based on
`
`the knowledge of a POSA or Herrod. Ex. 1123 ¶¶45-52; see also Ex. 2007 at
`
`151:5-156:20. Dr. Quackenbush provided specific citations to support his opinion
`
`that Herrod teaches the claimed physical interface. Ex. 1123 ¶¶47-50 (citing Ex.
`
`1106 at 5:34-38, 6:30-38, 6:43-48, 6:56-64, 7:32-34, 18:66-19:14). He also
`
`confirmed this understanding of Herrod’s teachings during cross-examination. Ex.
`
`2038 at 42:24-43:20, 45:1-20 (“…I see two functionalities, and they are called out
`
`with a physical interface: Data and power…. The functionality which is, in my
`
`opinion, well understood by one of ordinary skill, within the teachings of Herrod
`
`would involve two wires, two conductive paths.”).
`
`Response to Observations #6, #22, #25. PO’s observations are improper
`
`and should be expunged or not considered because they contain attorney argument.
`
`To the extent considered, PO mischaracterizes Dr. Quackenbush’s testimony. Dr.
`
`Quackenbush applied the plain and ordinary meaning of “means for recharging.”
`
`Ex. 1023 ¶¶28, 140, 45-49; Ex. 1123 ¶¶28, 138, 45-52; Ex. 1223 ¶¶29, 140, 52-57;
`
`Ex. 2007 at 42:14-43:15; Ex. 1025 ¶¶93, 177, 238; Ex. 2038 at 48:12-21. PO
`
`incorrectly argues that the term requires construction under §112(6)—Petitioners
`
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`Attorney Docket No.
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`IPR2014-01181
`110797-0004-655
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`U.S. Patent No. 8,532,641 B2
`explained it is not governed by §112(6) because it connotes a known class of
`
`structures, namely battery rechargers (see RP28-29, 39, 51-52); but, to the extent
`
`the Board decides §112(6) applies, the function is “recharging a rechargeable
`
`power supply” and the corresponding structure is a “battery recharger.” Id. Dr.
`
`Quackenbush further testified “a [POSA] would understand the function from the
`
`plain meaning of the language in the claim term recharging a battery” (Ex. 2038 at
`
`51:4-7) and “the structures identified in ‘641 are merely the very well-known
`
`structure of battery charging circuit” (Ex. 2038 at 48:25-49:2). Further, the “battery
`
`recharging circuit” is disclosed by the cited references. RP28-29, 39, 51-52; see
`
`also Ex. 2038 at 48:22-49:4, 49:18-51:7, 52:14-53:2, 139:23-140:21, 141:9-18,
`
`142:22-143:4, 151:22-152:14.
`
`Response to Observation #7. PO’s observation is improper and should be
`
`expunged or not considered because it contains attorney argument. To the extent
`
`considered, PO argues that the cited testimony demonstrates that “Dr.
`
`Quackenbush’s analysis is based upon his selective interpretation of disparate
`
`disclosures within the Abecassis reference rather than a single teaching.” This is
`
`irrelevant as a prior art reference need not teach the claimed limitation in a “single”
`
`teaching or passage. Ex. 2038 at 57:7-22. Moreover, Dr. Quackenbush provided
`
`citations to and explanation about the specific portions of Abecassis that teach the
`
`claimed “selectable menu item.” Ex. 1123 ¶¶54-58; Ex. 1025 ¶¶101-112. Further,
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`Attorney Docket No.
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`IPR2014-01181
`110797-0004-655
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`U.S. Patent No. 8,532,641 B2
`the testimony PO cites is incomplete and should include Ex. 2038 at 61:3-64:7
`
`Response to Observation #8. PO’s observation is improper and should be
`
`expunged or not considered because it contains attorney argument. To the extent
`
`considered, PO is wrong that the cited testimony “demonstrates the select
`
`disclosures … that Dr. Quackenbush relies upon as disclosing [streaming a signal
`
`representing at least a portion of a song].” The cited testimony does not address all
`
`of Dr. Quackenbush’s opinions regarding Abecassis’ teachings of this claim
`
`element. See, e.g., Ex. 1123 ¶¶69-74,131-137; Ex. 1025 ¶¶11-14, 80-88, 114.
`
`Further, the testimony PO cites is incomplete and should also include Ex. 2038 at
`
`75:6-78:4, 78:15-79:24.
`
`Response to Observation #9. PO’s observation is improper and should be
`
`expunged or not considered because it contains attorney argument and raises new
`
`arguments which constitute improper sur-reply. To the extent considered, PO
`
`argues incorrectly that “Dr. Quackenbush testified that Bluetooth includes a
`
`synchronous … data channel.” See Ex. 2038 at 84:10-16 (“Q. … There is a
`
`synchronous data channel for transmitting, data, correct? A. No. That is not
`
`correct.”). Moreover, PO’s assertion that “data may be transmitted in Bluetooth on
`
`either the synchronous and asynchronous data channel” is irrelevant. Dr.
`
`Quackenbush relies on Chennakeshu’s express teachings of transferring data over
`
`the asynchronous channel of Bluetooth. Ex. 1123 ¶¶72-74; Ex. 2038 at 88:9-15
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`Attorney Docket No.
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`IPR2014-01181
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`U.S. Patent No. 8,532,641 B2
`(“Bluetooth is tailored so that data is transmitted over the asynchronous channel,
`
`and that’s taught in Chennakeshu and also Ericsson Review.”), 75:6-77:5; see also
`
`Ex. 1223 ¶¶67-73, 113. Moreover, during his deposition, Dr. Quackenbush
`
`explained that the asynchronous channel “is where one of ordinary skill would
`
`look to transmit data.” Ex. 2038 at 85:2-7. Further, the testimony PO cites is
`
`incomplete and should include Ex. 2038 at 80:11-81:6, 83:9-13, 85:1, 87:24-88:15.
`
`Response to Observation #10. PO’s observation is improper and should be
`
`expunged or not considered because it contains attorney argument. To the extent
`
`considered, PO asserts incorrectly that the testimony “demonstrates the limited
`
`extent to which Dr. Quackenbush’s analysis … is based upon evidence outside of
`
`his own opinions.” Contrary to PO’s assertions, Dr. Quackenbush explained in his
`
`initial declaration why a POSA would have been motivated to use an asynchronous
`
`channel (as taught by Chennakeshu) to transfer data in Abecassis’ system based on
`
`the cited references. Ex. 1123 ¶¶73-74 (citing Ex. 1105, Ex. 1103, Ex. 1108A); see
`
`also Ex. 1025 ¶116; Ex. 1223 ¶¶67-73, 113; Ex. 2038 at 17:16-18:3. He also
`
`testified that his opinions were based on his understanding “as one of ordinary skill
`
`in the art” (Ex. 2038 at 89:24-90:10; see also Ex. 2038 at 90:22-91:6), and
`
`evidence of motivation to combine may be provided by expert testimony.
`
`Response to Observation #11. PO’s observation is improper and should be
`
`expunged or not considered because it contains attorney argument. To the extent
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`Attorney Docket No.
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`IPR2014-01181
`110797-0004-655
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`U.S. Patent No. 8,532,641 B2
`considered, PO’s assertion that Dr. Quackenbush’s opinions are “based upon
`
`statements as to prospective adoption of Bluetooth technology” is irrelevant and
`
`incorrect. It is irrelevant because reduction to practice is not required for
`
`obviousness. It is also incorrect because Ex. 1007 (discussed in the cited testimony)
`
`expressly states that “[m]any companies have since joined the consortium as
`
`adopters of the technology (status as of July 11, 1998)…” (Ex. 1007 at 111).
`
`Moreover, in direct response to Dr. Wolf’s claims, Dr. Quackenbush cited
`
`evidence of working Bluetooth systems in his declaration, as he confirmed during
`
`his deposition. Ex. 1025 ¶¶74, 121-122 (citing Ex. 1041A; Ex. 1042; Ex. 1043; Ex.
`
`1044); Ex. 2038 at 96:4-25; see also Ex. 1025 ¶¶146, 154.
`
`Response to Observations #12, #23, #24. PO’s observations are improper
`
`and should be expunged or not considered because they contain attorney argument
`
`and raise new arguments which constitute improper sur-reply. To the extent
`
`considered, PO’s questioning (Ex. 2038 at 99:11-100:18) specifically concerned
`
`Ex. 1025 ¶116, not ¶¶191, 201. In its Response, PO did not cite the ‘641 patent at
`
`6:34-39 or Ex. 1218 at 529 to support written disclosure of the ‘641 claims with
`
`respect to the priority date issue and has waived the ability to do so now. Moreover,
`
`according to PO, Ex. 2004 is a redline comparison of the specification of the ‘947
`
`patent as compared to the specification of the ‘641 patent, which shows that there
`
`are differences between the specifications of the two patents.
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`Attorney Docket No.
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`IPR2014-01181
`110797-0004-655
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`U.S. Patent No. 8,532,641 B2
`Response to Observation #13. The testimony PO cites is irrelevant because
`
`it is not disputed that Bluetooth operates in the range of 2.4 GHz. In his
`
`declarations, Dr. Quackenbush explained that a POSA would have been motivated
`
`and found it obvious to implement Bluetooth (as taught by Chennakeshu) in
`
`Abecassis’ system, and implementing Bluetooth would have worked. Ex. 1123
`
`¶¶83-84; Ex. 1025 ¶¶68-79, 117-122; see also Ex. 2038 at 17:16-18:10. Dr.
`
`Quackenbush also explained that a POSA would have been motivated and found it
`
`obvious to implement Bluetooth (as taught by Haartsen) in Ito’s system, and
`
`implementing Bluetooth would have worked. Ex. 1023 ¶¶74-76, Ex. 1025 ¶¶133-
`
`155. Dr. Quackenbush also noted that Ito teaches “the present invention is not
`
`limited to [76-90 MHz] but also other frequency can be used.” Ex. 1025 ¶¶24, 142
`
`(citing Ex. 1003 at 25:66-26:6).
`
`Response to Observation #14. PO’s observation is improper and should be
`
`expunged or not considered because it contains attorney argument. To the extent
`
`considered, PO argues incorrectly there is no citation to or analysis of “other, non-
`
`Bluetooth, wireless communications systems.” See, e.g., Ex. 1123 ¶¶72-74, 83-84;
`
`Ex. 1023 ¶¶62-63, 74-76; Ex. 1025 ¶¶68-79, 117-122, 133-155; ID1 at 14; ID2 at
`
`15 (citing Ex. 1108A at 110). Moreover, in direct response to Dr. Wolf’s assertions
`
`regarding the existence of other available wireless standards, Dr. Quackenbush
`
`opined in his rebuttal declaration as to why a POSA would have been motivated to
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`Attorney Docket No.
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`IPR2014-01181
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`U.S. Patent No. 8,532,641 B2
`use Bluetooth even if other wireless standards were available. Ex. 1025 ¶¶75, 147.
`
`Response to Observation #15. PO’s observation is improper and should be
`
`expunged or not considered because it contains attorney argument and raises new
`
`arguments which constitute improper sur-reply. To the extent considered, during
`
`his deposition, Dr. Quackenbush explained that Chennakeshu itself teaches
`
`Bluetooth. Ex. 2038 at 110:10-13. It is irrelevant whether Dr. Quackenbush
`
`compared Chennakeshu’s disclosures (which are presumed enabled) to the
`
`Bluetooth specification. In addition, with respect to the Bluetooth specification, he
`
`testified that Bluetooth “has been available and was … widely publicized, widely
`
`adopted, and therefore would be well-known to one of ordinary skill in the art,”
`
`and that he reviewed the Bluetooth specification in preparing his declarations and
`
`cited it in his rebuttal report. Ex. 2038 at 16:9-16, 18:19-19:24. He also opined that
`
`a POSA would have been motivated and found it obvious to implement Bluetooth
`
`(as taught by Chennakeshu) in Abecassis’ system and the combination would have
`
`worked. Ex. 1123 ¶¶72-74, 81-84; Ex. 1025 ¶¶68-79, 113-116; Ex. 2038 at 17:16-
`
`18:10. Further, contrary to PO’s assertion, the testimony it cites is not relevant to at
`
`least Ex. 1025 ¶¶133-155, 212, 216; RP32-35, 47-49.
`
`Response to Observations #16, #17, #18. PO’s observations are improper
`
`and should be expunged or not considered because they contain attorney argument.
`
`To the extent considered, PO argues incorrectly that Dr. Quackenbush’s opinions
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`IPR2014-01181
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`U.S. Patent No. 8,532,641 B2
`regarding the motivation to implement Bluetooth in Ito’s system lack support. In
`
`his declarations, Dr. Quackenbush explained that a POSA would have been
`
`motivated and found it obvious to implement Bluetooth (as taught by Haartsen) in
`
`Ito’s system and implementing Bluetooth would have worked. Ex. 1023 ¶¶74-76,
`
`Ex. 1025 ¶¶133-155. Dr. Quackenbush explained regarding the second
`
`embodiment that Ito teaches “the present invention is not limited to [76-90 MHz]
`
`but also other frequency can be used” (Ex. 1025 ¶¶24, 142 (citing Ex. 1003 at
`
`25:66-26:6)); and regarding the third embodiment the communication can be
`
`“easily conducted” within a range of several tens MHz to 1 GHz but is not limited
`
`to this (Ex. 2038 at 121:18-124:5). He also explained that Ito teaches “both ends of
`
`the claimed system … so it is irrelevant whether other third-party Bluetooth
`
`enabled vehicle loaded acoustic devices had been ‘widely adopted.’” Ex. 1025
`
`¶146; see also Ex. 2038 at 118:5-21; 119:7-120:5.
`
`Response to Observation #19. PO’s observation is improper and should be
`
`expunged or not considered because it contains attorney argument. To the extent
`
`considered, PO mischaracterizes Dr. Quackenbush’s testimony. In his declaration,
`
`Dr. Quackenbush explained that Ito supports transmissions over the FM band and
`
`“[a] POSA would have understood that the FM band supported the transfer of
`
`digital signals (such as IBOC).” Ex. 1025 ¶142 (citing Ex. 1003 at 25:66-26:15; Ex.
`
`1030 at 421). Dr. Quackenbush confirmed this during his deposition, explaining
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`that “Ito teaches using frequency modulation, but of course it also teaches an RF
`
`communication, which is why I have combined it with Haartsen to motivate using
`
`Bluetooth. And the point of the citation … is one of ordinary skill would know that
`
`IBOC is an example of technology which would also permit digital communication
`
`in the FM band.” Ex. 2038 at 126:25-127:12.
`
`Response to Observation #20. PO’s observation is improper and should be
`
`expunged or not considered because it contains attorney argument and raises new
`
`arguments which constitute improper sur-reply. To the extent considered, Dr.
`
`Quackenbush testified that Haartsen itself teaches Bluetooth. Ex. 2038 at 130:5-9,
`
`131:6-13, 132:11-133:2. It is irrelevant whether Dr. Quackenbush compared
`
`Haartsen’s disclosures (which are presumed enabled) to the Bluetooth specification.
`
`In addition, with respect to the Bluetooth specification, he testified that Bluetooth
`
`“has been available and was … widely publicized, widely adopted, and therefore
`
`would be well-known to one of ordinary skill in the art,” and that he reviewed the
`
`Bluetooth specification in preparing his declarations and cited it in his rebuttal
`
`report. Ex. 2038 at 16:9-16, 18:19-19:24. He also opined that a POSA would have
`
`been motivated and found it obvious to implement Bluetooth (as taught by
`
`Haartsen) in Ito’s system and that the combination would have worked. Ex. 1023
`
`¶¶73-76; Ex. 1025 ¶¶133-155.
`
`Response to Observation #21. PO’s observation is improper and should be
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`Attorney Docket No.
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`IPR2014-01181
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`expunged or not considered because it contains attorney argument and raises new
`
`arguments which constitute improper sur-reply. To the extent considered, Dr.
`
`Quackenbush opines that Haartsen discloses transferring data over an
`
`“asynchronous wireless channel” using Bluetooth. Ex. 1023 ¶61 (citing Ex. 1006 at
`
`3:28-31, 5:52-55, 7:10-12). The “time division duplex link” taught by Haartsen is
`
`an optional feature and is thus is irrelevant to Dr. Quackenbush’s analysis. Ex.
`
`1006 at 4:13-16 (“the asynchronous link may be a Time-Division duplex link….”).
`
`Dr. Quackenbush opined that a POSA would have been motivated and found it
`
`obvious to implement an asynchronous channel (as taught by Haartsen) in Ito’s
`
`system and that the combination would have worked. Ex. 1023 ¶¶59-66; see also
`
`Ex. 2038 at 138:2-20. Contrary to PO’s assertion, the testimony it cites is not
`
`relevant to at least Ex. 1025 ¶¶133-155 and RP32-35.
`
`Respectfully submitted,
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`
`
`
`
`Dated: Oct. 13, 2015
`
`/J. Steven Baughman/
`By:
`J. Steven Baughman (Lead Counsel); Gabrielle E. Higgins (Backup Counsel)
`ROPES & GRAY LLP; Attorneys for Petitioners, Samsung Electronics Co., Ltd.,
`and Samsung Electronics America, Inc.,
`
`
`
`- 13 -
`
`

`
`
`IPR2014-01181
`
`U.S. Patent No. 8,532,641 B2
`CERTIFICATE OF SERVICE
`
`Attorney Docket No.
`110797-0004-655
`
`
`
`The undersigned hereby certifies
`
`that a copy of PETITIONERS’
`
`RESPONSE TO PATENT OWNER’S MOTION FOR OBSERVATION ON
`
`EXAMINATION OF DR. SCHUYLER QUACKENBUSH has been served by
`
`causing the aforementioned document to be electronically mailed, pursuant to
`
`Petitioners’ and Patent Owner’s agreement, to the following attorneys of record for
`
`the Patent Owner listed below:
`
`
`Ryan M. Schultz
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`800 LaSalle Ave.
`2800 LaSalle Plaza
`Minneapolis, MN 55402
`rmschultz@rkmc.com
`
`Thomas R. DeSimone
`ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
`One Atlantic Center
`1201 West Peachtree St., Suite 2200
`Atlanta, CA 30309
`TRDeSimone@rkmc.com
`
`
`
`Oct. 13, 2015
`
`
`/Carolyn L. Redding/
`Carolyn L. Redding
`
`ROPES & GRAY LLP
`
`1
`
`
`
`Dated:

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