DISH Network v. CRFD Research, Inc.
`
`Case IPR2015-00627
`
`Petition for IPR of U.S. Patent No. 7,191,233
`January 19, 2016
`
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
`
`DISH Network
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`1
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`DISH, Ex. 1029 - Page 1 of 32
`
`
`
`Case IPR2015-00627
`
`Petition for IPR of U.S. Patent No. 7,191,233
`January 19, 2016
`
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
`
`DISH Network
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`1
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`DISH, Ex. 1029 - Page 1 of 32
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`
`
`DISH Grounds
`
`Ground 1: Claims 1 and 23 Are Anticipated by Bates (Ex.
`1004)
`
`Ground 2: Claims 1, 4, 23 and 25 Are Unpatentable Over
`Bates (Ex. 1004) and Chan (Ex. 1005)
`
`Ground 3: Claims 1, 4, 23 and 25 Are Anticipated By Phan
`Helsinki ("Phan ICC," Ex. 1020)
`
`Ground 4: Claims 4 and 25 Are Unpatentable Over Phan
`Helsinki (Ex. 1020) and Phan San Jose ("Phan
`WIAPP," Ex. 1019)
`
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH Network
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`DISH, Ex. 1029 - Page 2 of 32
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`
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`Ground 3: Anticipation by Phan Helsinki
`Phan Helsinki Discloses a Computerized Method for Session Redirection
`
`Phan Helsinki (Ex. 1020)
`
`Claim 1[p]:
`1. A method for redirecting an on-
`going, software based session:
`
`Claim 23[p]:
`A computer readable storage medium
`on which is embedded one or more
`computer programs, said one or more
`computer programs implementing a
`method for redirecting a session, said
`one or more computer programs
`comprising a set of instructions for:
`
`Ground 3: Claims 1, 4, 23 and 25 are anticipated by Phan Helsinki
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
`
`Ex. 1020 at 8
`
`Ex. 1020 at 9
`
`Ex. 1020 at 10
`
`Paper 1 at 40-42, 49
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`DISH Network
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`DISH, Ex. 1029 - Page 3 of 32
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`
`
`Ground 3: Anticipation by Phan Helsinki
`Phan Helsinki Discloses “specifying a second device”
`Patent Owner’s sole argument as to anticipation by Phan Helsinki relates to
`the claim element “specifying a second device.”
`
`Claim 1[b]/23[b]:
`specifying a second device
`
`Patent Owner Response:
`
`Ground 3: Claims 1, 4, 23 and 25 are anticipated by Phan Helsinki
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
`
`Paper 14 at 23
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`DISH Network
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`DISH, Ex. 1029 - Page 4 of 32
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`
`
`Ground 3: Anticipation by Phan Helsinki
`Phan Helsinki Discloses “specifying a second device”
`Phan Helsinki specifies a “second device,” “a second machine,” and a “new device.”
`
`Phan Helsinki (Ex. 1020):
`
`Claim 1[b]/23[b]:
`specifying a second device
`
`Ex. 1020 at 9
`
`Ex. 1020 at 10
`
`Ex. 1020 at 9
`
`Ground 3: Claims 1, 4, 23 and 25 are anticipated by Phan Helsinki
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
`
`Paper 1 at 43-45, 50
`
`DISH Network
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`DISH, Ex. 1029 - Page 5 of 32
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`
`
`Ground 3: Anticipation by Phan Helsinki
`Phan Helsinki Discloses “specifying a second device”
`
`Patent Owner's Expert Admits That
`Phan Helsinki Discloses This Step :
`
`Q. Okay. Do you agree, though, that
`in the Phan model – the Phan pull
`model that the second device is
`specified?
`A. Second device is specified at
`some point in time, yes, in the
`pull model.
`
`Ex. 1027 at 67
`
`Phan Helsinki (Ex. 1020):
`
`Ex. 1027 at 67
`
`Ex. 1020 at 9
`
`Paper 1 at 43-45, 50; Paper 16 at 3-4
`Ground 3: Claims 1, 4, 23 and 25 are anticipated by Phan Helsinki
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH Network
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`DISH, Ex. 1029 - Page 6 of 32
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`
`
`Ground 3: Anticipation by Phan Helsinki
`Phan Helsinki Discloses “specifying a second device”
`
`Phan Helsinki (Ex. 1020):
`
`Ex. 1020 at 9
`
`Patent Owner's Expert Admitted
`The Second Device Identifies Itself
`By IP Address When Session
`Resumed:
`Q. Similarly, to resume at that second
`device, the MARC server would
`need to know the IP address of the
`second device in order to send the
`session information from the MARC
`server to the second device?
`A. Yes.
`Q. As part of the message that it wished
`to resume the session, the second
`device would let the MARC server
`know what its IP address is?
`A. Correct.
`
`Ex. 1027 at 41-42
`
`Paper 1 at 43-45, 50; Paper 16 at 3-4
`Ground 3: Claims 1, 4, 23 and 25 are anticipated by Phan Helsinki
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH Network
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`DISH, Ex. 1029 - Page 7 of 32
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`
`
`Ground 3: Anticipation by Phan Helsinki
`Phan Helsinki Discloses “specifying a second device”
`
`The claims do not require that the “specifying”
`occur before the "discontinuing" step.
`
`The patentee knew how to limit the claims to a
`particular order of steps.
`
`Ground 3: Claims 1, 4, 23 and 25 are anticipated by Phan Helsinki
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH Network
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`8
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`Ex. 1001 p. 10; Paper 16 at 4-5.
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`DISH, Ex. 1029 - Page 8 of 32
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`
`
`Ground 3: Anticipation by Phan Helsinki
`Phan Helsinki Discloses “specifying a second device”
`The claims do not recite an order of the
`"specifying" and "discontinuing" steps.
`
`“Unless the steps of a method actually recite an order, the
`steps are not ordinarily construed to require one.”
`Interactive Gift Express, Inc. v. Compuserve Inc.,
`256 F. 3d. 1363, 1342 (Fed. Cir. 2001).
`
`Ground 3: Claims 1, 4, 23 and 25 are anticipated by Phan Helsinki
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH Network
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`9
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`Ex. 1001 p. 10; Paper 16 at 4-5.
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`DISH, Ex. 1029 - Page 9 of 32
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`
`
`Ground 3: Anticipation by Phan Helsinki
`Phan Helsinki Discloses “specifying a second device” After Discontinuing the Session
`Phan Helsinki (Ex. 1020):
`
`Patent Owner focuses solely on
`“push” implementation, which was
`not relied on by Petitioner.
`
`Phan Helsinki’s “pull”
`implementation meets this limitation
`by updating the middleware “upon
`exiting” Mozilla.
`
`Under the Board’s construction of
`“session,” the session is
`discontinued when or before the
`user exits Mozilla.
`
`Ex. 1027 at 41-42
`
`Ex. 1020 at 10
`Paper 1 at 47; Ex. 1020 § 4.1; Paper 16 at 5
`Ground 3: Claims 1, 4, 23 and 25 are anticipated by Phan Helsinki
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH Network
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`DISH, Ex. 1029 - Page 10 of 32
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`
`
`Ground 3: Anticipation by Phan Helsinki
`Phan Helsinki Discloses “specifying a second device” After Discontinuing the Session
`
`Phan Helsinki (Ex. 1020):
`
`Ex. 1020 at 10
`
`Patent Owner focuses solely on
`“push” implementation, which was
`not relied on by Petitioner.
`
`Phan Helsinki’s “pull”
`implementation meets this limitation
`by updating the middleware “upon
`exiting” Mozilla.
`
`Under the Board’s construction of
`“session,” the session is
`discontinued when or before the
`user exits Mozilla.
`
`Paper 1 at 47; Ex. 1020 § 4.1; Paper 16 at 5
`Ground 3: Claims 1, 4, 23 and 25 are anticipated by Phan Helsinki
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH Network
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`DISH, Ex. 1029 - Page 11 of 32
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`
`
`Ground 3: Anticipation by Phan Helsinki
`Phan Helsinki Anticipates Independent Claims 1 and 23
`
`Patent Owner raises no additional arguments for independent claim 23, apart
`from those discussed above.
`
`Phan Helsinki therefore anticipates claims 1 and 23.
`
`Ground 3: Claims 1, 4, 23 and 25 are anticipated by Phan Helsinki
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH Network
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`12
`
`Paper 1 at 40-50; Paper 16 at 2-7
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`DISH, Ex. 1029 - Page 12 of 32
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`
`
`Ground 4: Obviousness by Phan Helsinki and Phan San Jose
`Claims 4 and 25 are Obvious over Phan Helsinki and Phan San Jose
`
`Phan San Jose (Ex. 1016):
`
`Claim 4[p]:
`The method according to claim
`1, further comprising:
`Claim 25[p]:
`The computer readable storage
`medium according to claim 23,
`said one or more computer
`programs further comprising a
`set of instructions for:
`
`Ex. 1016 at 5
`
`Paper 1 at 51-56; Ex. 1016 at 5-6
`Ground 4: Claims 4 and 25 are obvious over Phan Helsinki and Phan San Jose
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH Network
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`DISH, Ex. 1029 - Page 13 of 32
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`
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`Ground 4: Obviousness by Phan Helsinki and Phan San Jose
`Claims 4 and 25 are Obvious over Phan Helsinki and Phan San Jose
`
`Phan San Jose (Ex. 1016):
`
`Claim 4[a]:
`accessing a device profile of said
`second device; and
`Claim 25[a]:
`accessing a device profile of said
`second device; and
`
`Ex. 1016 at 5
`
`Paper 1 at 51-56; Ex. 1016 at 5
`Ground 4: Claims 4 and 25 are obvious over Phan Helsinki and Phan San Jose
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH Network
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`DISH, Ex. 1029 - Page 14 of 32
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`
`
`Ground 4: Obviousness by Phan Helsinki and Phan San Jose
`Claims 4 and 25 are Obvious over Phan Helsinki and Phan San Jose
`
`Phan San Jose (Ex. 1016):
`
`Claim 4[b]:
`restructuring said session data to
`conform with said device profile of
`said second device.
`
`Claim 25[b]:
`restructuring said session to
`conform with said device profile of
`said second device.
`
`Ex. 1016 at 5
`
`Paper 1 at 51-56; Ex. 1016 at 5-6
`Ground 4: Claims 4 and 25 are obvious over Phan Helsinki and Phan San Jose
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH, Ex. 1029 - Page 15 of 32
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`
`
`Ground 4: Obviousness by Phan Helsinki and Phan San Jose
`A Person of Ordinary Skill in the Art Would Combine Phan Helsinki and Phan San Jose
`
`• Both Phan references describe the same iMASH system and have
`common authors.
`
`• The combination of Phan Helsinki and Phan San Jose would produce a
`predictable result.
`• The improvement to the Phan Helsinki system by using Phan San
`Jose’s filtration and/or content adaptation was predictable based on
`the knowledge of a person of ordinary skill in the art, including the
`express teachings of Phan Helisnki.
`
`• The use of Phan San Jose’s filtration and/or content adaptation was one
`of a finite number of solutions available to a person of ordinary skill in the
`art at the time.
`
`Paper 1 at 55-56; Ex. 1020, § 1; Ex. 1019, § 1; Ex. 1018, ¶ 95
`Ground 4: Claims 4 and 25 are obvious over Phan Helsinki and Phan San Jose
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH Network
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`DISH, Ex. 1029 - Page 16 of 32
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`
`
`Ground 1: Anticipation by Bates
`Bates Discloses a Computerized Method for Session Redirection
`
`Claim 1[p]:
`1. A method for redirecting an on-
`going, software based session:
`
`Bates (Ex. 1004):
`
`Claim 23[p]:
`A computer readable storage medium
`on which is embedded one or more
`computer programs, said one or more
`computer programs implementing a
`method for redirecting a session, said
`one or more computer programs
`comprising a set of instructions for
`
`Ground 1: Claims 1 and 23 are anticipated by Bates
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
`
`Ex. 1004 at 10:61-11:8
`
`Paper 1 at 24, 32
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`DISH Network
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`DISH, Ex. 1029 - Page 17 of 32
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`
`
`Ground 1: Anticipation by Bates
`Bates Discloses Transmitting Session History After the Session Is Discontinued
`Patent Owner’s sole argument as to anticipation by Bates relates to the
`claim element “transmitting … after said session is discontinued.”
`
`Bates (Ex. 1004):
`
`Claims 1 & 23:
`1/23[d]. transmitting a session
`history of said first device
`from said first device to a
`session transfer module after
`said session is discontinued
`on said first device;
`
`Ground 1: Claims 1 and 23 are anticipated by Bates
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
`
`Paper 14 at 35; Paper 16 at 7-10
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`DISH, Ex. 1029 - Page 18 of 32
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`
`
`Ground 1: Anticipation by Bates
`Bates Discloses Transmitting Session History After the Session Is Discontinued
`Bates (Ex. 1004):
`
`Claims 1 & 23:
`1/23[d]. transmitting a session
`history of said first device
`from said first device to a
`session transfer module after
`said session is discontinued
`on said first device;
`
`***
`
`Ex. 1004 7:53-8:5; Paper 1 at 28-32; Paper 16 at 8-11.
`Ground 1: Claims 1 and 23 are anticipated by Bates
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH, Ex. 1029 - Page 19 of 32
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`
`
`Ground 1: Anticipation by Bates
`Bates Discloses Transmitting Session History After the Session Is Discontinued
`
`Board's Constructions:
`
`Claims 1 & 23:
`1/23[d]. transmitting a session
`history of said first device
`from said first device to a
`session transfer module after
`said session is discontinued
`on said first device;
`
`* * *
`
`* * *
`
`"discontinuing"
`
`"discontinued"
`
`terminating or otherwise
`stopping, with the ability to be
`resumed
`terminated or otherwise
`stopped, with the ability to be
`resumed
`
`Ground 1: Claims 1 and 23 are anticipated by Bates
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
`
`Paper 9 at 7-8.
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`DISH, Ex. 1029 - Page 20 of 32
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`
`
`Ground 1: Anticipation by Bates
`Bates Discloses Transmitting Session History After the Session Is Discontinued
`
`"discontinued"
`
`terminated or otherwise
`stopped, with the ability to be
`resumed
`
`Ex. 1004 at 7:66-8:1
`
`Transmitting session history “at shutdown”
`necessarily occurs after the session is
`“discontinued.”
`
`Ground 1: Claims 1 and 23 are anticipated by Bates
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`Ex. 1004 7:66-8:1; Paper 1 at 28-32
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`DISH, Ex. 1029 - Page 21 of 32
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`
`
`Ground 1: Anticipation by Bates
`Bates Discloses Transmitting Session History After the Session Is Discontinued
`
`"discontinued"
`
`terminated or otherwise
`stopped, with the ability to be
`resumed
`
`Transmitting session history is also performed “at idle period.”
`Idle occurs after the session is “discontinued.”
`
`Ex. 1004 at 8:1-5
`
`Ground 1: Claims 1 and 23 are anticipated by Bates
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
`
`Ex. 1004 8:1-5; Paper 1 at 28-32
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`DISH, Ex. 1029 - Page 22 of 32
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`
`
`Ground 1: Anticipation by Bates
`Bates Discloses Transmitting Session History After the Session Is Discontinued
`
`Patent Owner’s Expert confirmed that the session would end by the time that the
`idle period occurred:
`
`Q. Moving to figure 5, in your view, what is meant by the term “at
`idle period”?
`A. Idle period is usually configured in the computer that if you
`are – if there is no interaction for, let’s say, an hour or half
`an hour, then it goes to the idle mode. So basically it’s kind
`of a sleep mode that the computer uses to save resources.
`Q. That’s a pretty long time. Would you expect that if a user
`entered the idle mode, then any browsing session they were
`engaged in would have necessarily been torn down based on
`idle time expiring?
`A. Yes.
`
`Ex. 1027 at 89:3-14
`
`Ex. 1027 at 93:3-14; Paper 16 at 10-11.
`Ground 1: Claims 1 and 23 are anticipated by Bates
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH, Ex. 1029 - Page 23 of 32
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`
`
`Ground 1: Anticipation by Bates
`Bates Discloses Transmitting Session History After the Session Is Discontinued
`
`Either of Bates transmission
`of session information
`“at shutdown” or
`“at idle period” take place
`after the “session” is
`discontinued, under the
`Board’s construction.
`
`Institution Decision (Paper 9 at 7)
`
`***
`
`Paper 1 at 26-31; Paper 9 at 7; Paper 16 at 8-11.
`Ground 1: Claims 1 and 23 are anticipated by Bates
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH, Ex. 1029 - Page 24 of 32
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`
`
`Ground 1: Anticipation by Bates
`Bates Anticipates Claim 1 and 23
`
`Patent Owner raises no additional arguments for independent claim 23, apart
`from those discussed above.
`
`Bates therefore anticipates claims 1 and 23.
`
`Paper 1 at 26-31; Paper 9 at 7; Paper 16 at 8-11.
`Ground 1: Claims 1 and 23 are anticipated by Bates
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH, Ex. 1029 - Page 25 of 32
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`
`
`Ground 2: Obviousness by Bates and Chan
`Claim 1, 4, 23, and 25 Are Obvious Over Bates and Chan
`
`Claims 1 & 23:
`1/23[d]. transmitting a session
`history of said first device
`from said first device to a
`session transfer module after
`said session is discontinued on
`said first device;
`
`Once the service, adaptation, and destination are decided,
`processing is performed by the service module. The service
`module plays the important role of providing the notion of a
`single application. For example, when Web browsing is
`transferred to a low-bandwidth network, an Internet service
`gateway can be used to provide an extremely primitive form of
`browsing over a messaging service. Similarly,
`two-way
`messaging service can be used as a substitute for email
`service.
`In
`addition, management
`of
`states
`that
`are
`persistent per user, per application, or per session is also
`performed here. For example,
`in Web browsing persistent
`application states such as bookmarks, history, and cookies
`should be reserved when the user migrates to different devices;
`cache objects can migrate from server to device or vice versa.
`depending
`on
`the
`environment.
`Finally,
`common service semantics like notification, saving, printing,
`and transfer of messages is supported in a uniform way across
`all services.
`
`Ex. 1005 at 6-7 (emphasis added)
`
`Paper 1 at 34-35; Ex. 1005 at 6-7.
`Ground 1: Claims 1,2 4, 23, and 25are obvious over Bates and Chan
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH, Ex. 1029 - Page 26 of 32
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`
`
`Ground 2: Obviousness by Bates and Chan
`Claim 1, 4, 23, and 25 Are Obvious Over Bates and Chan
`
`Chan (Ex. 1015) at 6:
`
`Claim 4[a]:
`accessing a device profile of said
`second device; and
`Claim 25[a]:
`accessing a device profile of said
`second device; and
`
`Ground 1: Claims 1,2 4, 23, and 25are obvious over Bates and Chan
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`27
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`Ex. 1005 at 6
`Paper 1 at 36-38; Ex. 1016 at 6.
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`DISH, Ex. 1029 - Page 27 of 32
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`
`
`Ground 2: Obviousness by Bates and Chan
`Claim 1, 4, 23, and 25 Are Obvious Over Bates and Chan
`
`Chan (Ex. 1015) at 6:
`
`Claim 4[b]:
`restructuring said session data to
`conform with said device profile of
`said second device.
`
`Claim 25[b]:
`restructuring said session to
`conform with said device profile of
`said second device.
`
`* * *
`
`Ground 1: Claims 1,2 4, 23, and 25are obvious over Bates and Chan
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`Ex. 1016 at 6
`
`Paper 1 at 36-38; Ex. 1016 at 6.
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`DISH, Ex. 1029 - Page 28 of 32
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`
`
`Ground 2: Obviousness by Bates and Chan
`A Person of Ordinary Skill in the Art Would Combine Bates and Chan
`
`disclose
`and Chan
`• Both Bates
`for transferring sessions between clients.
`• Bates primarily focuses on the client.
`• Bates discloses the use of servers, as well as certain protocols,
`including email and FTP. Ex. 1004, 3:20-67, 9:27-30, FIG. 1.
`
`client-server
`
`architecture
`
`a
`
`the servers
`in the art would appreciate that
`• One of ordinary skill
`discussed in Bates in conjunction with the disclosed protocols include
`both hardware and software that enable session transfer. Ex. 1003, ¶ 99;
`Ex. 1018, ¶ 69-72.
`
`Paper 1 at 38-40; Ex. 1020, § 1; Ex. 1019, § 1; Ex. 1018, ¶ 95
`Ground 4: Claims 4 and 25 are obvious over Phan Helsinki and Phan San Jose
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH, Ex. 1029 - Page 29 of 32
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`
`
`Ground 2: Obviousness by Bates and Chan
`A Person of Ordinary Skill in the Art Would Combine Bates and Chan
`
`• Bates also addresses the need to reformat session data such that
`sessions may be transferred between different clients running different
`browsers and the session may be continued. Ex. 1004, 11:22-49.
`• Bates highlights that “[i]t is understood that formatting processes may
`be performed regardless of compatibility between browser types.” Id.
`at 11:40-42.
`• Bates notes that “[i]nterfacing two or more applications is well-known
`in the art. Accordingly, a detailed discussion of interfacing methods
`and apparatus is not necessary.” Id. at 11:47-49.
`
`• Thus, one of ordinary skill in the art would have been aware of and
`used prior art techniques like Chan’s involving server-side
`implementation of session transfer between computers and that
`describe reformatting session data to aid session transfer amongst
`heterogeneous devices. Id. at 11:47-49; Ex. 1003, ¶¶ 132-134; Ex.
`1018, ¶ 69-72.
`
`Paper 1 at 38-40; Ex. 1004, 11:22-49, 40-42; Ex. 1003 ¶¶ 132-134; Ex. 1018, ¶ 69-72
`Ground 4: Claims 4 and 25 are obvious over Phan Helsinki and Phan San Jose
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
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`DISH, Ex. 1029 - Page 30 of 32
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`
`
`Ground 2: Obviousness by Bates and Chan
`A Person of Ordinary Skill in the Art Would Combine Bates and Chan
`
`• Both Bates and Chan involve the same field: session transfer. Id. at ¶
`131;Ex. 1018, ¶ 69-72.
`
`• Both seek to solve the same problem: enabling a user to begin a session
`on one client and continue the session on another client. Id.
`
`• The combination would have been predictable and obvious to one of
`ordinary skill in the art. Id.
`
`Paper 1 at 38-40; Ex. 1004, 11:22-49, 40-42; Ex. 1003 ¶¶ 132-134; Ex. 1018, ¶ 69-72
`Ground 4: Claims 4 and 25 are obvious over Phan Helsinki and Phan San Jose
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
`
`DISH Network
`
`31
`
`DISH, Ex. 1029 - Page 31 of 32
`
`
`
`Grounds 2-4: Dependent Claims 2 and 25
`Paper Owner Raises No Separate Arguments for Dependent Claims 4 and 25
`
`Patent Owner raises no separate arguments for dependent claims 4 and 25.
`
`Ground 2: Claims 1, 4, 23 and 25 Are Unpatentable Over
`Bates (Ex. 1004) and Chan (Ex. 1005)
`
`Ground 3: Claims 1, 4, 23 and 25 Are Anticipated By Phan
`Helsinki ("Phan ICC", Ex. 1020)
`
`Ground 4: Claims 4 and 25 Are Unpatentable Over Phan
`Helsinki (Ex. 1020) and Phan San Jose ("Phan
`WIAPP", Ex. 1019)
`
`Paper 14 at 28, 41-43; Paper 16 at 11.
`Ground 2-4: Claims 4 and 25 are anticipated by Bates or Phan Helsinki or Obvious over Bates and Chan or Phan Helsinki and Phan San Jose
`DISH Network
`U.S. Patent No. 7,191,233 | Case IPR 2015-00627
`
`32
`
`DISH, Ex. 1029 - Page 32 of 32
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