Filed on behalf of: Apple Inc., et al.
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`Entered: June 6, 2016
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________________
`
`APPLE INC., MOTOROLA MOBILITY LLC, and
`TOSHIBA AMERICA INFORMATION SYSTEMS, INC.,
`Petitioner
`
`v.
`
`GLOBAL TOUCH SOLUTIONS, LLC,
`Patent Owner
`_______________________
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`
`
`
`
`
`Case IPR2015-01173
`U.S. Patent No. 7,329,970 B2
`_______________________
`
`Before JUSTIN BUSCH, LYNN E. PETTIGREW, and
`BETH Z. SHAW, Administrative Patent Judges.
`
`
`
`PETITIONERS’ REPLY IN SUPPORT OF THEIR PETITION FOR
`INTER PARTES REVIEW OF U.S. PATENT NO. 7,329,970
`
`
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`
`Entered: June 6, 2016
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________________
`
`APPLE INC., MOTOROLA MOBILITY LLC, and
`TOSHIBA AMERICA INFORMATION SYSTEMS, INC.,
`Petitioner
`
`v.
`
`GLOBAL TOUCH SOLUTIONS, LLC,
`Patent Owner
`_______________________
`
`
`
`
`
`
`
`Case IPR2015-01173
`U.S. Patent No. 7,329,970 B2
`_______________________
`
`Before JUSTIN BUSCH, LYNN E. PETTIGREW, and
`BETH Z. SHAW, Administrative Patent Judges.
`
`
`
`PETITIONERS’ REPLY IN SUPPORT OF THEIR PETITION FOR
`INTER PARTES REVIEW OF U.S. PATENT NO. 7,329,970
`
`
`
`Case IPR2015-01173
`U.S. Patent No. 7,329,970
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`TABLE OF CONTENTS
`
`I.
`
`II.
`
`Introduction ...................................................................................................... 1
`
`The Prior Art Renders Obvious Using the Microchip To Control the
`Connection of the Power Source to the Load and the Activation of the
`Indicator. .......................................................................................................... 2
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`III. The Prior Art Discloses a Luminous Visible Location Indicator. ................... 5
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`IV. The Prior Art Discloses “a Function.” ............................................................. 9
`
`A.
`B.
`
`Beard Discloses “Automatically Deactivating a Function.” ............... 10
`Global Touch’s Proposed Construction Should Be Rejected. ............ 12
`1.
`Activating a Visible Indication Is a “Function.” ...................... 12
`2.
`Repeated References to “Activation” Signals Do Not
`Require Different Signals. ........................................................ 14
`
`V.
`
`Conclusion ..................................................................................................... 15
`
`i
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`Case IPR2015-01173
`U.S. Patent No. 7,329,970
`I.
`
`INTRODUCTION
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`Patent Owner Global Touch Solutions, LLC’s opposition is noteworthy for
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`what it does not say. Global Touch does not dispute that all the basic technical
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`elements of its alleged invention were known and used by those skilled in the field
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`of portable, battery-powered devices in the late 1990s: batteries, switches,
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`microchips, touch sensors. Global Touch and its expert also nowhere dispute that
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`there was ample motivation among those in the field to combine references with
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`complementary disclosures to solve the familiar problem of how to readily
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`determine and indicate to a user the remaining battery power in a portable device.
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`Rather, Global Touch attempts to save its patent by arguing, contrary to
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`Federal Circuit precedent, that it would not have been obvious to combine the
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`functions of two general purpose microchips in a single microchip. This is
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`incorrect, and Global Touch confuses the standard for anticipation with that for
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`obviousness. Further, Global Touch attempts to narrowly construe “location
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`indicator” to exclude the activation of such an indicator by a touch sensor—which
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`contradicts the claims and specification, and would not save the claims from
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`invalidity. Finally, Global Touch distorts the word “function” in an attempt to
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`avoid the prior art, relying on a tortured reading of the claims that is factually and
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`legally unsound. These flawed arguments should be rejected and the Board should
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`invalidate all of the challenged claims of the ’970 patent.
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`1
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`Case IPR2015-01173
`U.S. Patent No. 7,329,970
`II. THE PRIOR ART RENDERS OBVIOUS USING THE MICROCHIP
`TO CONTROL THE CONNECTION OF THE POWER SOURCE TO
`THE LOAD AND THE ACTIVATION OF THE INDICATOR.
`
`Claim 52 of the ’970 patent recites “using the microchip to control the
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`connection of the power source to the load and the activation of the indicator.”
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`Global Touch does not dispute that the prior art Beard and Danielson patents,
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`which have common inventors, were assigned to the same company, and which
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`together describe the same Pen*Key device, disclose microchips that perform both
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`functions: controlling the connection of the power source to the load and
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`controlling the activation of the indicator. Instead, Global Touch argues that,
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`because these references do not disclose the same microchip performing both
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`functions, it would not have been obvious to implement both functions in the same
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`microchip. (Id.) This argument is contrary to controlling law, misses the point,
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`and should be rejected.
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`Beard describes an intelligent battery pack with a general purpose
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`microchip. (Paper No. 4, “Petition” at 11-12 (citing Ex. 1005, “Beard” at 1:18-
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`21).) It discloses that this microchip controls activation of the visible indication.
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`(Id. at 56 (citing Beard at 7:59-63, Fig. 7, 11:14-22 and Fig. 11).) Danielson
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`describes a portable electronic device that also has a general purpose microchip
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`and that is powered by an intelligent battery pack like the one disclosed in Beard.
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`(Petition at 17 (citing Ex. 1007, “Danielson” at Fig. 2).) Danielson discloses that
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`2
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`U.S. Patent No. 7,329,970
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`the microchip can be programmed to control the connection of the power source to
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`the load. (Petition at 54 (citing Danielson at 23:27-34, Fig. 22).) Thus, the prior
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`art discloses microchips that perform both required functions, with the microchip
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`in the battery pack performing one function and the microchip in the portable
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`device performing the other.
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`It would have been obvious to implement both functions on the same
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`microchip. In MCM Portfolio LLC v. Hewlett-Packard Company, the Federal
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`Circuit addressed precisely this issue. 812 F.3d 1284, 1293-94 (Fed. Cir. 2015).
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`The relevant claim limitation required implementing “different functionalities in[]
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`a single chip.” Id. at 1293. The prior art disclosed implementing this functionality
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`across two different chips. Id. The Board, in an Inter Partes Review, held that it
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`would have been obvious to combine the functionality “on a single chip.” Id. The
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`Federal Circuit affirmed the Board’s conclusion. Id. at 1294.
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`The same result follows here. Just like in MCM Portfolio, Beard and
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`Danielson disclose the required functionality spread across two general purpose
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`microchips. And just like in MCM Portfolio, it would have been obvious to
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`implement this function in a single microchip—here, the microchip in the battery
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`pack. See MCM Portfolio, 812 F.3d at 1294; see also In re Yufa, 452 F. App’x
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`998, 1001 (Fed. Cir. 2012) (non-precedential) (affirming a conclusion by the
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`B.P.A.I. in a reexamination that it would have been obvious to implement
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`3
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`U.S. Patent No. 7,329,970
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`functionality disclosed in a particular microchip in the prior art in a different
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`microchip because “this simply arranges old elements with each performing the
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`same function it had been known to perform and yields no more than one would
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`expect from such an arrangement”) (internal quotations omitted). As Mr. Beard
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`explained in his initial declaration, the microchip of the battery pack would have
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`been a natural choice to implement both functions. (Ex. 1003, “Beard Decl.” ¶¶
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`254-58.) The prior art discloses “a finite number of identified, predictable
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`solutions,” and so choosing one of those predicable solutions would have been
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`obvious. See KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 421 (2007) (“When
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`there is a design need or market pressure to solve a problem and there are a finite
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`number of identified, predictable solutions, a person of ordinary skill has good
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`reason to pursue the known options within his or her technical grasp. If this leads
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`to the anticipated success, it is likely the product not of innovation but of ordinary
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`skill and common sense.”).
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`Global Touch cites no authority to the contrary. Instead, it argues that the
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`fact that the prior art inventors chose to implement the two features in two different
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`microchips “is the best evidence of what a PHOSITA would have done.” (Paper
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`No. 19, “Response” at 11 (emphasis removed).) But this misses the point. The
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`Board instituted review of claim 52 on the basis of obviousness, not anticipation.
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`The issue is not, as Global Touch would have it, whether either prior art reference
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`4
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`U.S. Patent No. 7,329,970
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`alone discloses the claimed invention. The issue is whether it would have been
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`obvious to combine the prior art references and implement both features in the
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`same microchip. The answer to that, is yes. As discussed earlier, the law is clear
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`that it would have been obvious to take features described in two general purpose
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`microchips in the prior art and instead implement them in a single general purpose
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`microchip. See MCM Portfolio, 812 F.3d at 1294; Yufa, 452 F. App’x at 1001.
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`III. THE PRIOR ART DISCLOSES A LUMINOUS VISIBLE LOCATION
`INDICATOR.
`
`Claim 1 of the ’970 patent requires “a luminous visible location indicator.”
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`The claims and specification disclose that this indicator can be an “LED” on the
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`portable device that activates in response to a touch sensor. (’970 patent at cls. 1,
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`46; 9:60-67, Fig. 11.) The prior art Beard reference discloses exactly such an
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`LED: “four light-emitting diodes which sequentially illuminate” in response to a
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`touch. (Beard at 4:59-67.) This is sufficient to satisfy the claim.
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`Global Touch argues that the LED in Beard does not qualify as a “location
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`indicator” because it is activated using a touch sensor, and so, according to Global
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`Touch, the location of the device “[is] necessarily known such that the location has
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`no reason to be indicated because a user must touch the contacts to operate the
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`indicator.” (Response at 13.) Global Touch essentially seeks to construe the term
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`“location indicator” to depend on the state of mind of the “operator”—as Global
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`5
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`U.S. Patent No. 7,329,970
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`Touch’s expert put it: “[t]he nature of indicating a location is an indication, at least
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`in part, of a thing unknown and not in contact with the operator.” (Ex. 2003,
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`“Morley Decl.” ¶ 69.) This is contradicted by the claims and specification and
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`should be rejected. But even if it were correct, Global Touch’s expert admitted
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`that the LED in Beard would qualify as such a “location indicator.”
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`First, Global Touch’s argument is contradicted by the claims. Claim 1 is
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`reproduced below:
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`1. An electronic module for use with a product comprising an energy
`consuming load and a power source or a connection to a power
`source, said module comprising a microchip, and a switch;
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`said switch being a user interface and does not form a serial link in a
`circuit that transfers power from the power source to power the load,
`and said microchip controlling a luminous visible location indicator
`that is not the load according to at least one configuration selected
`from the following group:
`
`a) wherein the visible indicator at least indicates a condition of the
`product upon receiving a signal from the user interface switch, and
`wherein the switch is a touch sensor type switch;
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`b) wherein the visible indicator is activated at least to indicate an
`activation signal from the switch when the load is not activated; and
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`c) wherein the visible indicator is also used to indicate a power level
`of the power source when the load is switched off and the product is
`not connected to a mains supply.
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`6
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`U.S. Patent No. 7,329,970
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`(’970 patent at cl. 1.) The claim first recites “a luminous visible location
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`indicator.” It then requires that the indicator must be configured according to one
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`of three options. In the first option, the indicator “indicates a condition of the
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`product upon receiving a signal from the user interface switch” where “the switch
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`is a touch sensor type switch.” In other words, rather than barring activation of the
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`location indicator by a touch sensor, as Global Touch contends, the claims
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`expressly contemplate that the luminous visible location indicator activates upon
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`receiving a signal from a touch sensor. This is precisely what is disclosed in the
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`prior art. (Petition at 32-34.) Beard discloses a luminous LED, activated by a
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`touch sensor, that both indicates location and battery charge status. (Id.)
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`Second, Global Touch’s argument is contradicted by the specification. The
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`specification’s only description of a location indicator contemplates that the
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`indicator can be an LED activated by a user switch, like a touch sensor. Figure 11
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`of the ’970 patent is reproduced below:
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`7
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`U.S. Patent No. 7,329,970
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`
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`Element 1111 is a “switch” that can be “closed by the user.” (’970 patent at 9:56-
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`57.) Element 1104 is an “LED.” (Id. at 9:54-55.) This LED can be used to
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`indicate location. (Id. at 9:49-50 (The LED output “may also be suitable to assist
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`in locating a device.”).) As one can see from the diagram, the LED is connected to
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`the switch and “may [] shine when switch 1111 is closed by the user.” (Id. at 9:56-
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`59.) This, again, is precisely what is disclosed by Beard: an LED that is activated
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`by closing a switch. (Petition at 32-34.)
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`Finally, even if Global Touch were correct that the claimed “location
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`indicator” should be construed to require “an indication, at least in part, of a thing
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`unknown and not in contact with the operator” (and as discussed above this is not
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`8
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`U.S. Patent No. 7,329,970
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`correct), Global Touch’s expert testified that the LED disclosed in Beard meets this
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`construction:
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`Q. Let me give you a hypothetical. Let’s suppose you and I were in
`this room and it was totally dark and we couldn’t see each other. And
`in your hand was a battery pack as described in the Beard prior art
`reference. And in the dark, you touched the contacts and illuminated
`the LEDs. Are you with me so far?
`
`A. Yes.
`
`Q. And let’s say they stayed on for a period of ten seconds. If I
`looked at you in the dark and my view was unobstructed, wouldn’t it
`tell me the location of the battery pack that was in your hand?
`
`A. It would.
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`Q. And I didn’t need to touch it for that to happen, did I?
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`A. No, you didn’t.
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`Q. Or to know where the device was beforehand, right?
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`A. Correct.
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`(Ex. 1036, Morley Tr. at 160:15-161:12.) Even under Global Touch’s strained
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`construction of “location indicator,” Dr. Morley admitted that Beard discloses this
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`limitation.
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`IV. THE PRIOR ART DISCLOSES “A FUNCTION.”
`Global Touch argues that the prior art does not disclose a “function” that is
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`“automatically shut off” after period of time, as required by dependent claims 12
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`9
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`U.S. Patent No. 7,329,970
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`and 19. But Global Touch does not dispute that Beard discloses the activation, and
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`automatic deactivation 10 seconds later, of at least two features: the display of
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`battery capacity information and the display of remaining time in response to a
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`user pressing the touch sensor. (Response at 21.) This disclosure is more than
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`sufficient to establish the claims’ obviousness.
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`A. Beard Discloses “Automatically Deactivating a Function.”
`Global Touch argues that “a function” must be construed to exclude the
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`function of activating a visible indication, and therefore this limitation requires
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`activation and deactivation of a second function, different from activating of a
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`visible indication. (Response at 22.) Even if Global Touch’s construction were
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`correct (and, as explained below, it is not), Beard discloses this limitation because
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`it discloses activation and deactivation of two functions: (1) calculation and
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`display of battery capacity (the claimed activation of a visible indication) and
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`(2) calculation and display of a remaining time estimate (the second function
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`required under Global Touch’s construction).
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`Global Touch concedes that Beard discloses these two features. (Response
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`at 21.) And Global Touch’s expert admits that each are “functions.” (Morley Tr.
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`at 124:6-9, 126:2-14.) Global Touch’s expert also concedes that the two are
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`different, separate functions:
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`10
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`U.S. Patent No. 7,329,970
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`Q. Determining remaining time in a battery is a different
`function than just determining battery capacity, right?
`
`A. Correct. The -- determining the time, you would
`need to know what the draw is, and if you know the
`capacity and the draw, you can estimate the time until it’s
`discharged.
`
`(Morley Tr. at 126:16-22.) The expert’s conclusion is not surprising, since the
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`Beard reference describes calculating and displaying battery capacity as a different
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`feature from calculating and displaying a remaining time estimate. (See Beard at
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`Abstract, 10:37-40, 11:45-48, 12:59-65.) Even under Global Touch’s construction,
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`this is all that is necessary to demonstrate that Beard discloses the claimed
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`“function” of claims 12 and 19.
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`In addition, Beard discloses “automatically deactivating a function” under
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`Global Touch’s proposed construction because it discloses the activation and
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`deactivation of a “timing circuit.” Beard discloses that “a timing circuit prevents
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`the contact 155 from holding the display 157 and associated circuitry in an active
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`state for more than a ten (10) second interval.” (Beard at 10:51-54.) This meets
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`each of the claims’ requirements. First, using the timing circuit to prevent the
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`display from being held in an active state for more than ten seconds is a “function”
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`even under Global Touch’s proposed construction, because it is not activation of
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`the visible indication. (Morley Tr. at 125:4-18 (confirming that the “timing”
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`11
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`U.S. Patent No. 7,329,970
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`disclosed in Beard is a function according to the Global Touch patents).) Second,
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`the timing function is activated in response to an activation signal received from
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`the user interface because the circuit is activated when the user presses touch
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`sensor contact 155, thereby sending an activation signal. (Beard at 10:51-54;
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`Beard Suppl. Decl. ¶ 9.) Third, the timing function is automatically deactivated a
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`predetermined period of time (10 seconds) after it was activated. (Beard at 10:54-
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`56; Beard Suppl. Decl. ¶ 10.) Thus, under Global Touch’s incorrect construction,
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`this limitation is still satisfied by Beard.
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`B. Global Touch’s Proposed Construction Should Be Rejected.
`Further, Global Touch’s construction is incorrect. Global Touch makes two
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`flawed arguments: (1) because the claims use two different terms, “function” and
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`activation of a “visible indicator,” the term “function” must exclude the function of
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`activation of a “visible indicator” and (2) because the claims recite an “activation
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`signal,” a “user interface activation signal” and a “switch activation signal,” these
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`three signals cannot be met by Beard’s activation signal from a touch sensor
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`switch. Neither argument is persuasive.
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`Activating a Visible Indication Is a “Function.”
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`1.
`First, Global Touch is correct that two different claim terms should normally
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`be construed to have different meanings. (Response at 21-22.) Petitioners agree
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`that “function” and activation of a “visible indicator” mean different things:
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`12
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`“function” is a broad term that encompasses any kind of function, while activation
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`of a “visible indicator” is a specific type of function. But that does not mean that
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`“function” should be construed to exclude activation of a “visible indicator.” The
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`words “car” and “sedan” have different meanings. That does not mean that a
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`“sedan” cannot be a type of “car.”
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`Global Touch’s own expert candidly admitted that activation of a “visible
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`indicator” is a “function”:
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`Q. So indicating a condition of the battery, whether it’s good or bad,
`is another example of a function according to the Global Touch
`patents, right?
`
`A. Yes.
`
`(Morley Tr. at 118:21-119:3.) And in his declaration supporting case IPR2015-
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`01172, relating to U.S. Patent No. 7,498,749 which is a continuation-in-part sibling
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`of the ’970 patent and shares effectively the same specification, Global Touch’s
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`expert states: “Claim 21 recites two separate function activations in response to an
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`activation signal received via the user interface switch. One is recited as the
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`activation of the visible indicator.” (Ex. 1037, IPR2015-01172 Morley Decl. ¶ 50.)
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`That activating an indicator is an example of a “function” is also supported
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`by the specification. The specification uses the term “function” broadly, and
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`expressly states that “battery strength monitoring” is one example of a function.
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`13
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`(’970 patent at 8:54-59; see also, e.g., id. at 1:31-33.) Nothing in the specification
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`suggests that the broad term “function” excludes any specific function of the
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`invention. Global Touch’s contrary construction of “function” should be rejected.
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`2.
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`Repeated References to “Activation” Signals Do Not
`Require Different Signals.
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`Second, in addition to arguing that the term “function” cannot include
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`activation of a visible indicator, Global Touch also argues that because the claims
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`refer to an “activation signal,” a “user interface activation signal,” and a “switch
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`activation signal,” these must correspond to different signals. (Response at 22-23.)
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`This is wrong. Independent claim 1 recites “an activation signal.” (’970 patent at
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`cl. 1.) Dependent claim 12 recites “a user interface activation signal.” (Id. at cl.
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`12.) Dependent claim 19 recites “a switch activation signal.” (Id. at cl. 19.) The
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`claims are simply defining the signal in a more specific way in each claim: an
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`“activation signal” is the broadest term, and could encompass a signal from a user
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`interface or from some other component. A “user interface activation signal” is a
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`specific type of “activation signal,” one that comes from the user interface. A
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`“switch activation signal” is a specific type of “user interface activation signal,”
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`one that comes from a switch component of the user interface. The activation
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`signal from the touch sensor switch in Beard qualifies as all three: it is an
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`14
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`activation signal, from the user interface, and specifically from a switch component
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`of the user interface. (Petition at 42-44.)
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`V. CONCLUSION
`For the reasons set forth above and in the Petition, Petitioner respectfully
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`requests that the instituted claims be cancelled.
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`Dated: June 6, 2016
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`Respectfully submitted,
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`By: /Robert Steinberg/
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`
`
`Robert Steinberg (Reg. No. 33,144)
`Latham & Watkins LLP
`355 South Grand Avenue
`Los Angeles, CA 90071-1560
`213.485.1234; 213.891.8763 (Fax)
`
`Counsel for Petitioner Apple Inc.
`
`Phillip E. Morton (Reg. No. 57,835)
`Cooley LLP
`1299 Pennsylvania Ave., NW
`Suite 700
`Washington, D.C. 20004
`703.456.8668; 703.456.8100 (Fax)
`
`Counsel for Petitioner Motorola
`Mobility LLC
`
`Doris Johnson Hines
`(Reg. No. 34,629)
`Finnegan, Henderson, Farabow,
`Garrett & Dunner, L.L.P.
`901 New York Avenue, NW
`Washington, DC 20001-4413
`202.408.4250; 202.408.4400 (Fax)
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`Counsel for Petitioner Toshiba
`America Information Systems, Inc.
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`16
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), I hereby certify that on this 6th day of June,
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`2016, true and correct copies of the foregoing Petitioners’ Reply In Support Of
`
`Their Petition For Inter Partes Review Of U.S. Patent No. 7,329,970 and
`
`Exhibits 1035-1037 were served by electronic mail upon the following counsel of
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`record for Patent Owner Global Touch Solutions, LLC:
`
`Lead Counsel
`Steven B. Kelber (Reg. No. 30,073)
`skelber@labgoldlaw.com
`Law Offices of Marc R. Labgold, P.C.
`12005 Sunrise Valley Drive, Suite 203
`Reston, Virginia 20191
`Tel: (240) 506-6702
`Fax: (877) 401-8855
`Backup Counsel
`William H. Mandir (Reg. No. 32,156)
`wmandir@sughrue.com
`SUGHRUE MION PLLC
`2100 Pennsylvania Ave NW
`Suite 800
`Washington, DC 20037
`Tel: (202) 663-7458
`Fax: (202) 293-7860
`Backup Counsel
`Brian K. Shelton (Reg. No. 50,245)
`bshelton@sughrue.com
`SUGHRUE MION PLLC
`2100 Pennsylvania Ave NW
`Suite 800
`Washington, DC 20037
`Tel: (202) 663-7957
`Fax: (202) 293-7860
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`Backup Counsel
`Nathan Cristler (Reg. No. 61,736)
`ncristler@cristlerip.com
`Cristler IP, PLLC
`1801 21st Road North
`Arlington, VA 22209
`Tel: (512) 576-5166
`Fax: (877) 401-8855
`Backup Counsel
`Peter S. Park (Reg. No. 60,719)
`pspark@sughrue.com
`SUGHRUE MION PLLC
`2100 Pennsylvania Ave NW
`Suite 800
`Washington, DC 20037
`Tel: (202) 857-3358
`Fax: (202) 293-7860
`Backup Counsel
`Fadi N. Kiblawi (Reg. No. 61,973)
`fkiblawi@sughrue.com
`SUGHRUE MION PLLC
`2100 Pennsylvania Ave NW
`Suite 800
`Washington, DC 20037
`Tel: (202) 663-7386
`Fax: (202) 293-7860
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`1
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`Case IPR2015-01173
`U.S. Patent No. 7,329,970
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`By: /Robert Steinberg/
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`Robert Steinberg (Reg. No. 33,144)
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`Counsel for Petitioner Apple Inc.
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`Case IPR2015-01173
`U.S. Patent No. 7,329,970
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`CERTIFICATE OF COMPLIANCE WITH 37 C.F.R. § 42.24
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`I hereby certify that this Reply complies with the word count limitation of 37
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`C.F.R. § 42.24(c)(1) because the Reply contains 3,131 words, excluding the cover
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`page, signature block, and the parts of the Reply exempted by 37 C.F.R. §
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`By: /Robert Steinberg/
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`Robert Steinberg (Reg. No. 33,144)
`bob.steinberg@lw.com
`Latham & Watkins LLP
`355 South Grand Avenue
`Los Angeles, CA 90071-1560
`213.485.1234; 213.891.8763 (Fax)
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`Counsel for Petitioner Apple Inc.
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`42.24(c).
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