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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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` NINTENDO OF AMERICA, INC. and NINTENDO CO., LTD.,
`Petitioner
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`v.
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`BABBAGE HOLDINGS, LLC
`Patent Owner
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`____________
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`Case IPR2015-00568
`Patent 5,561,811
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`____________
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`BABBAGE HOLDINGS, LLC’S PRELIMINARY RESPONSE TO
`PETITION FOR INTER PARTES REVIEW, PER 37 C.F.R. §42.107
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`-i-
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`TABLE OF CONTENTS
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`I. SUMMARY OF PRELIMINARY RESPONSE ................................................ 3
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`II. CLAIM CONSTRUCTION ................................................................................ 7
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`III. THE PETITION SHOULD BE DENIED .........................................................10
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`A. ABSENT JOINDER, THE PETITION IS UNTIMELY ................................................10
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`B. THERE IS INSUFFICIENT PROOF THAT CLAIM 7 IS UNPATENTABLE OVER
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`YOSHINO-GREANIAS ..............................................................................................11
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`CASES
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`TABLE OF AUTHORITIES
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`Page(s)
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`ACTV, Inc. v. Walt Disney Co.,
`346 F.3d 1082 (Fed. Cir. 2003) ...................................................................................5, 10
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`Graham v. John Deere Co.,
`383 U.S. 1 (1966) ........................................................................................................ passim
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`Hockerson-Halberstadt, Inc. v. Converse, Inc.,
`183 F.3d 1369 (Fed. Cir. 1999) ...................................................................................5, 10
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`In re Fine,
`837 F.2d 1071 (Fed. Cir. 1988) .......................................................................................12
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`In re Wilder,
`429 F.2d 447 (CCPA 1970) ..............................................................................................16
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`In re Wilson,
`424 F.2d 1382 (CCPA 1970) ...........................................................................................17
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`KSR Int’l Co. v. Teleflex Inc.,
`550 U.S. 398 (2007) ...........................................................................................................13
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`STATUTES
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`35 U.S.C. §103(a) .....................................................................................................................12
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`35 U.S.C. § 314(a) ....................................................................................................................12
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`35 U.S.C. §315(b) .................................................................................................................4, 11
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`OTHER AUTHORITIES
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`37 C.F.R. §42.101(b) ............................................................................................................4, 11
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`37 CFR §42.20(c) ......................................................................................................................12
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`37 CFR § 42.208(b) ....................................................................................................................7
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`Pursuant to 37 CFR §42.107, Patent Owner, Babbage Holdings, LLC,
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`submits this Preliminary Response to the Corrected Petition for Inter Partes
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`Review (the “Petition”) of claim 7 in U.S. Patent No. 5,561,811 (the “’811 patent,”
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`Exhibit 1001).
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`The ‘811 patent is the subject of IPR2014-00954 (“the ‘954 IPR”). Trial
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`was instituted there on December 15, 2014 (the “Institution Decision”) (Exhibit
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`2008).
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`I.
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`SUMMARY OF PRELIMINARY RESPONSE
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`Petitioner Nintendo of America, Inc. was served with the complaint in the
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`related district litigation on October 11, 2013. The Petition here was filed January
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`14, 2015, more than one year later. As a threshold matter, and because
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`Petitioner’s request for joinder is not yet granted, the Petition is time-barred. See,
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`35 U.S.C. §315(b) (inter partes review may not be instituted if the petition
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`requesting the proceeding is filed more than 1 year after the date on which the
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`petitioner …is served with a complaint alleging infringement of the patent); 37
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`C.F.R. §42.101(b).
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`Turning to the merits, the Petition here does mirror the arguments and
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`evidence that the Board relied upon in determining that petitioners in the ‘954 IPR
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`had demonstrated a reasonable likelihood they would prevail in establishing that
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`claim 7 is obvious over Yoshino and Greanias. That said, the Board’s earlier
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`determination should be reconsidered in view of the additional arguments herein.
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`In particular, the Board’s earlier Institution Decision did not consider
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`explicitly the phrase “under the control of multiple users of a computer system”
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`within the context of the last two steps in claim 7, each of which include the
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`identical phrase “input events from input devices.” Claim terms must be
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`construed in context, not as single elements in isolation. See Hockerson-
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`Halberstadt, Inc. v. Converse, Inc., 183 F.3d 1369, 1374 (Fed. Cir. 1999); ACTV,
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`Inc. v. Walt Disney Co., 346 F.3d 1082, 1088 (Fed. Cir. 2003). Because claim 7
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`recites a “method” that describes a set of operations involving “at least one
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`application program under the control of multiple users,” it follows logically that
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`the “input events” recited in the last two clauses of the claim necessarily come
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`from at least two separate “input devices” being operated concurrently by different
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`“users.” If it were otherwise, the “application program” could not be said to be
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`“under the control of multiple users” of the computer system, let alone “for
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`displaying a visual response of said application program to said input events on a
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`shared display.” Importantly, this notion of “input events from input devices” that
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`are “under the control of multiple users” concurrently is not possible in the
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`Greanias prior art, which the undisputed evidence establishes works with only with
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`a single user at any given time.
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`With due respect, and in its Institution Decision, the Board erred because it
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`appears to have overlooked that the ‘954 petitioners were only relying upon
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`Greanias (and not Yoshino) to attempt to establish the final two “input events from
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`input devices” clauses in the claim. The petitioners’ contention in this regard is
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`clear from the claim chart in the subject Petition (pages 21-36), which was copied
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`from the ‘954 petition; this claim chart identifies only Greanias as the pertinent
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`prior art for elements (c) (“linking any input events from input devices”), and (d)
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`(“translating input events from input devices”). In other words, neither the ‘954
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`petitioners nor the Petitioners here relies on Yoshino for the subject matter of the
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`last two clauses in the claim.
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`Further, the ‘954 petitioners conceded – and it is true -- that “Greanias
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`teaches that only a single user participates at any time, but that multiple users may
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`construct user profiles.” (See, original ‘954 Petition, at 40, Exhibit 2009).
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`Greanias thus does not provide for “input events from input devices” because the
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`system there is not designed for “control of multiple users” concurrently. In
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`Greanias, there is a first user, and then – at some other time - a second user. But,
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`there can never be both a first user and a second user at the same time. With due
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`respect, the Board overlooked this when making its Graham fact findings
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`concerning the scope and content of the Greanias patent. Accordingly, and given
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`the particular manner in which the Petition seeks to combine the references,
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`alleged obviousness is not established.
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`With due respect to the Board, it is no answer that Yoshino meets the “input
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`event from input devices” of “multiple users.” (See, e.g., ‘954 Institution Decision,
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`at 11) (“Patent Owner’s argument ignores Petitioner’s reliance upon Yoshino to
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`teach multiple registered users simultaneously entering input events and ignores
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`Petitioner’s proposed combination of Yoshino and Greanias”). The Board must
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`take the Petition (and, in particular, the invalidity analysis therein) as it finds it. In
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`particular, the Board should address “only the basis, rationale, and reasoning put
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`forth by the Petitioner in the Petition, and resolve all vagueness and ambiguity in
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`Petitioner’s arguments against the Petitioner.” See ORDER - DENIAL OF
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`GROUNDS – 37 CFR § 42.208(b), in Liberty Mutual Ins. Co. v. Progressive
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`Casualty Ins. Co., CBM2012-00003, Paper 10 (October 25, 2012).
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`The chart contends claim 7 is invalid because Greanias meets the final two
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`elements; it does not. The petitioners did not rely upon Yoshino for those
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`teachings, and it is inappropriate for the Board to evaluate the Petition otherwise.
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`For these reasons, the review requested by the Petition should not be
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`instituted.
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`II. CLAIM CONSTRUCTION
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`The Institution Decision addressed three (3) claim construction issues: (i)
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`the phrase “a plurality of input devices connected to a single computer,” (ii) the so-
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`called “user preference” limitations, and (iii) whether the “linking” and
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`“translating” phrases required a method “that allows for the possibility of multiple
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`registered users” and that, when such users are both entering input events, they can
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`do so according to different (“prespecified, individualized”) preferences. The
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`Board accepted the petitioners’ arguments regarding the first two issues, and it
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`declined the Patent Owner’s invitation to construe the linking/translating clauses in
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`the particular manner that the Patent Owner requested. (See, Institution Decision,
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`at 5-9). Without waiver of any contention regarding whether the Board’s prior
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`determinations were correct, the Patent Owner recognizes that the Board has made
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`those initial determinations and will not re-argue them here.
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`That said, a different claim construction issue should be considered, namely,
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`the meaning of “from input devices” in the phrase “input events from input
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`devices” that is present in the last two clauses in the claim1:
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`1 The Board has sanctioned the practice of determining the customary and
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`ordinary meaning for claim terms identified by the Patent Owner. See, e.g., Cisco
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`7.
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`A method for entering simultaneous and sequential input events
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`for at least one application program under the control of multiple users of a
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`computer system and for displaying a visual response of said application
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`program to said input events on a shared display, each of said users having a
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`unique identity; said method comprising the steps of
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`entering simultaneous and sequential input events through user
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`control of a plurality of input devices connected to a single computer,
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`each of said input devices having a unique identity that is linked with
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`any input events that are entered thereby;
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`revokably registering different ones of said users with different
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`ones of said input devices, whereby the identity of each input device
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`that has a user registered therewith is linked with the identity of its
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`registered user;
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`linking any input events from input devices that have users
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`registered therewith with prespecified, individualized preferences of
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`the respective registered users of such input devices, and
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`translating input events from input devices that have registered
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`users into commands that said application program executes in
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`accordance with the preferences of the registered users of the
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`respective input devices.
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`Systems, Inc. v, AIP Acquisition, LLC, IPR2014-00247, Paper No. 14, at page 12
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`(May 17, 2014).
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`Claim terms must be construed in context, not as single elements in
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`isolation. See Hockerson-Halberstadt, Inc. v. Converse, Inc., 183 F.3d 1369, 1374
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`(Fed. Cir. 1999); ACTV, Inc. v. Walt Disney Co., 346 F.3d 1082, 1088 (Fed. Cir.
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`2003). Here, the “input events from input devices” phrase necessarily involves
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`“input devices” that are being operated concurrently by different ones of the
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`“multiple users of a computer system.” FIG. 25 and the related text in the
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`specification show Devices #1 and #2 and their respective Users #1 and #2. The
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`claim recites a “method” that describes a set of operations involving “at least one
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`application program under the control of multiple users,” where the result is “a
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`visual response of said application program to said input events on a shared
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`display.” It follows logically that the “input events” recited in the last two clauses
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`of the claim necessarily come from at least two separate “input devices” being
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`operated concurrently by different “users.” The “from input devices” phrase is
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`stated in the plural, namely, that there are multiple such devices operating at the
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`same time. If it were otherwise, the “application program” could not be said to be
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`“under the control of multiple users” of the computer system, let alone “for
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`displaying a visual response of said application program to said input events.”
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`Further, the ‘811 disclosure refers to several user interface problems that are
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`solved by the subject matter disclosed. The first one listed is the notion of
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`“simultaneous input,” which the specification teaches occurs in “a system where a
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`plurality of users may invoke the same command in the same application by taking
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`comparable actions using comparable, but distinct, input devices …” This context
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`is carried through in the claim preamble and thus the claim as a whole.
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`The phrase “input events from input devices” thus carries with it the notion
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`that there are at least two separate input devices that are under the control of
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`multiple users concurrently.
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`III. THE PETITION SHOULD BE DENIED
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`A. Absent Joinder, the Petition is untimely
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`Petitioner Nintendo of America, Inc. was served with the complaint in the
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`related district litigation on October 11, 2013. (See, Petition, at 36). The Petition
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`here was filed January 14, 2015, more than one year later. As a threshold matter,
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`and because Petitioner’s request for joinder is not yet granted, the Petition is time-
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`barred. See, 35 U.S.C. §315(b) (inter partes review may not be instituted if the
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`petition requesting the proceeding is filed more than 1 year after the date on which
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`the petitioner …is served with a complaint alleging infringement of the patent); 37
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`C.F.R. §42.101(b).
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`B.
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`There is insufficient proof that Claim 7 is unpatentable over
`Yoshino-Greanias
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`Petitioners have the burden of proof at all times to establish a reasonable
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`likelihood of prevailing with respect to the challenged claim. See, 37 CFR
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`§42.20(c). The reasonable likelihood to prevail must be based on “the information
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`presented in the petition.” See, 35 U.S.C. § 314(a).
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`Whether or not particular subject matter “as a whole” would have been
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`obvious to one of ordinary skill in the art at the time an invention was made
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`depends on underlying factual inquiries including: (1) the scope and content of the
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`prior art; (2) the level of ordinary skill in the art; and (3) the differences between
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`the prior art and the claimed invention. Graham v. John Deere Co., 383 U.S. 1, 17
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`(1966). In rejecting claims under 35 U.S.C. §103(a), and given the burden of
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`proof, it is incumbent upon the petitioner to establish a factual basis to support the
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`legal conclusion of obviousness. See, In re Fine, 837 F.2d 1071, 1073 (Fed. Cir.
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`1988).
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`An invention “composed of several elements is not proved obvious merely
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`by demonstrating that each of its elements was, independently, known in the prior
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`art. . . . [I]t can be important to identify a reason that would have prompted a
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`person of ordinary skill in the relevant field to combine the elements in the way the
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`claimed new invention does.” KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 418
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`(2007).
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`The first Graham factor is the scope and content of the cited art.
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`Yoshino (Exhibit 1002) describes a method and apparatus for screen
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`display. In this system, there are multiple users, and each can control a respective
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`cursor using a “cursor control unit.” A plurality of cursors can then be displayed
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`on the screen and controlled individually. A particular cursor can have visual
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`attributes (color, shape and the like) and be associated with a particular user. Two
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`users can also control the same cursor but not at the same time; rather, the system
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`decides which of the users gains control of the shared cursor based on a priority
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`scheme.
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`Greanias (Exhibit 1003) describes an alternative input subsystem (AIS)
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`interface (FIG. 3, at 103) for a computer system that enables “different users who
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`operate a single computer to construct different user interfaces to accommodate
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`individual preferences in inputting data” (C3L 45-48). The system includes an
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`interface profile module 104 that is comprised of sets of application profiles 105,
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`and user profiles 107. The profiles are “files which list input messages produced
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`by the AIS 103 from the input signals received by input devices 36, 38 and 40
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`mapped to keyboard, mouse or other commands which are useable by existing
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`application programs, e.g., mouse clicks, keystroke messages, MACROs, utility
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`programs, etc.” (see, C7L66-C8L5) Different application programs can have
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`different interface profiles (C8L42-43), and each user can have a user profile
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`(C10L7-8). When a particular user logs-on, his or her user profile is retrieved.
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`Based on the applicable profiles, the system then responds to various inputs and
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`executes specific commands.
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`The next Graham factor identifies the differences between the cited art and
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`the claimed subject matter at issue. The Petition is deficient here.
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`Importantly, Petitioners’ claim chart characterizes the Graham differences as
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`follows: Yoshino is relied upon by the Petitioners for the preamble limitations, as
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`well as the limitations in the first two clauses in the body of the claim (see,
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`Petition, at 22-32). Greanias is relied upon by the Petitioners for the limitations in
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`the last two clauses in the body of the claim (see, Petition, at 32-36). The Board
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`overlooked this key point when it concluded that the ‘954 IPR petitioners had met
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`their burden to demonstrate a reasonable likelihood that they would prevail with
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`respect to the challenged claim. The current Petition adds nothing in this regard,
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`and it is deficient for the same reasons.
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`In particular, and for purposes of the Graham analysis, Petitioners are
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`correct that Yoshino does not disclose the subject matter in the last two clauses in
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`the body of claim 7. That said, the Petition errs in finding that the scope and
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`content of Greanias reaches the last two clauses in claim 7; the teachings in that
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`reference do not go this far.
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`As noted above, “input events from input devices” phrase requires at least
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`two separate input devices that are under the control of multiple users concurrently.
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`With this proper construction being applied, the Graham fact findings proposed in
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`Petitioners’ claim chart necessarily are deficient, as Greanias teaches that only a
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`single user participates at any given time.
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`In particular, Greanias does not disclose or suggest any such usage of the
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`user input device and interface there; rather, one user logs-in and uses the
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`computer (and the particular application) according to his or her profile. That user
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`then logs-off and another user logs-in to use the computer and the application.
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`When the second user logs-in, his or her user profile is retrieved and instantiated,
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`etc. At any one time, there is just one “input device” (namely, one single
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`keyboard or mouse) being used with the computer system (and just one table of
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`preferences being used to translate some input into some command). It follows
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`logically then that, while there may be multiple registered users of the Greanias
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`system (operating the computer at different times), the system there cannot operate
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`either to link or translate “input events from input devices” operating by multiple
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`users concurrently, which are the requirements in the last two clauses in the claim.
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`Stated another way, the single input device in Greanias is only used by one user at
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`any given time. As such, there can never be the required “input events from input
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`devices.” The notion of “events from input devices” under the control of multiple
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`users concurrently is not possible in the Greanias teaching, yet this is the very
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`argument set forth in the claim chart to support the conclusion of alleged
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`obviousness.
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`As such, Petitioners’ proposed Graham fact findings for these paragraphs
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`(Petition, at 32-36, for claim elements “7(c)-(d)”) are incorrect.
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`Accordingly, the following are Graham differences with respect to the
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`Greanias teachings:
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`“linking any input events from input devices that have users registered
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`therewith with prespecified, individualized preferences of the respective registered
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`users of such input devices, and
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`translating input events from input devices that have registered users into
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`commands that said application program executes in accordance with the
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`preferences of the registered users of the respective input devices.”
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`“[E]very limitation positively recited in a claim must be given effect in order
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`to determine what subject matter that claim defines.” In re Wilder, 429 F.2d 447,
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`450 (CCPA 1970); see also In re Wilson, 424 F.2d 1382, 1385 (CCPA 1970)
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`(“[a]ll words in a claim must be considered in judging the patentability of that
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`claim against the prior art.”).
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`There is no proof in this record that the above-described Graham differences
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`(as represented in the last two clauses in claim 7) would have been obvious to a
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`skilled person at the time of the invention. While Greanias does provide for
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`“input device customization” (unique “input-to-command mappings”), such
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`customization can only occur (at a given time) with respect to a single input
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`device. This function notwithstanding, in Greanias there are never “input events
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`from input devices” happening concurrently.
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`Stated another way, the Graham fact findings tendered by Petitioners are
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`incorrect. Thus, and with respect to Yoshino-Greanias, Petitioners have not
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`demonstrated that they are likely to prevail in establishing obviousness with
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`respect to the subject matter as a whole of claim 7.
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`With due respect, and in its Institution Decision, the Board erred because it
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`overlooked that the ‘954 petitioners were relying only upon Greanias to attempt to
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`establish the final two “input events from input devices” clauses in the claim. As
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`noted above, the Petitioners’ contention in this regard is clear from the claim chart
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`in the subject Petition (pages 21-36), which was copied from the ‘954 petition.
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`This claim chart identifies only Greanias as the pertinent prior art for elements 7(c)
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`(“linking any input events from input devices”), and 7(d) (“translating input events
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`from input devices”). Yoshino is not mentioned.
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`Neither the ‘954 petitioners nor the Petitioners here relies on Yoshino for the
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`subject matter of the last two clauses in the claim. Further, and as noted above,
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`the ‘954 petitioners conceded – and it is true - that Greanias teaches that only a
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`single user participates at any time. Stated plainly, the Petition is deficient
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`because Greanias does not provide for “input events from input devices,” as the
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`system there is not designed for “control of multiple users” concurrently. In
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`Greanias, there is a first user, and then – at some other time - a second user. There
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`can never be both a first user and a second user at the same time. The Board’s
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`Graham fact findings concerning the scope and content and differences thus were
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`incorrect with respect to the Greanias prior art.
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`Accordingly, and given the (incorrect) Graham findings proposed in the
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`Petition, alleged obviousness is not established here.
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`In the Institution Decision, the Board turned to Yoshino for the “multiple
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`users” element. (See, e.g., ‘954 Institution Decision, at 11) (“Patent Owner’s
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`argument ignores Petitioner’s reliance upon Yoshino to teach multiple registered
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`users simultaneously entering input events and ignores Petitioner’s proposed
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`combination of Yoshino and Greanias”). Further, and in describing the ’954
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`Petition, the Board stated: “Petitioner argues that Yoshino discloses most of the
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`elements of claim 7, [with Greanias filling in the user profile piece].” (See,
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`Institution Decision, at 9, emphasis supplied) The problem with this argument is
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`manifest; the original petitioners only relied on Yoshino for the first two steps of
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`this four-step claim, whereas Greanias was relied upon for the remaining two steps.
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`Stated another way, the Board appears to have afforded the petitioners the benefit
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`of arguments that were not present in their invalidity analysis as presented in the
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`claim chart itself.
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`The Board should take the Petition (the invalidity analysis as presented in
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`the claim chart) as it finds it. This is because Petitioners here bear the burden of
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`proof in the first instance, and the Board should address “only the basis, rationale,
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`and reasoning put forth by the Petitioner in the Petition, and resolve all vagueness
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`and ambiguity in Petitioner’s arguments against the Petitioner.” See, Liberty
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`Mutual Ins. Co. v. Progressive Casualty Ins. Co., CBM2012-00003, Paper 10
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`(October 25, 2012).
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`If the Board relies upon Petitioners’ actual arguments (namely, the claim
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`chart), it must deny the Petition because this “proof” fails to show properly that
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`Greanias indeed meets the final two elements of the claim. The Petitioners did not
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`rely upon Yoshino for those teachings, and it is not appropriate for the Board to
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`evaluate the Petition otherwise.
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`For the reasons stated above, the inter partes review should be denied.
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`Respectfully submitted,
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`/David H. Judson/
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`By: _____________________________
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`David H. Judson
`Reg. No. 30,467
`Law Office of David H. Judson
`15950 Dallas Parkway, Suite 225
`Dallas, Texas 75248
`(214) 939-7659
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`February 20, 2015
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`-19-
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`APPENDIX OF EXHIBITS
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`Institution Decision, December 15, 2015, IPR2015-00568
`Exhibit 2008
`Exhibit 2009 Petition for Inter Partes Review, June 13, 2015, IPR2015-00568
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`-20-
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`CERTIFICATE OF SERVICE
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`I hereby certify that on this 20th day of February, 2015, a true and correct
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`copy of the foregoing Babbage Holdings, LLC’s Preliminary Response, was served
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`via electronic mail upon jsp@nixonvan.com (Joseph S. Presta), and
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`rwf@nixonvan.com (Robert W. Faris).
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`Respectfully submitted,
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`/David H. Judson/
`Registration No. 30,467
`Attorney for Babbage Holdings, LLC
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`-21-
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