`By:
`Justin B. Kimble (JKimble-IPR@bcpc-law.com)
`
`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
`
`Bragalone Conroy P.C.
`
`2200 Ross Ave.
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`Suite 4500 – West
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`Dallas, TX 75201
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`Tel: 214.785.6670
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`Fax: 214.786.6680
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`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`K.J. PRETECH CO., LTD.,
`Petitioner,
`
`v.
`
`INNOVATIVE DISPLAY TECHNOLOGIES LLC,
`Patent Owner,
`
`Case IPR2015-01867
`U.S. Patent No. 7,537,370
`
`
`
`PATENT OWNER’S RESPONSE
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`
`
`
`
`
`Case IPR2015-01867
`Patent 7,537,370
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`Patent Owner Innovative Display Technologies LLC (“IDT”) hereby files this
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`response (“Response”) to the Petition (Paper 2) (the “Petition”) for Inter Partes
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`Review of U.S. Patent No. 7,537,370 (the “ʼ370 patent”) in IPR2015-01867 filed by
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`KJ Pretech Co., Ltd. (“KJ” or “Petitioner”).
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`I.
`
`INTRODUCTION
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`The Board should patentability of claims 29 and 47, as Petitioner has failed to
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`carry its burden to demonstrate that those claims are obvoius. Further, Patent Owner
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`renews its argument that Petitioner was time-barred in filing the Petition because it
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`is in privity with LG, the real party in interest who is also time-barred. LG’s conduct
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`in the litigation following institution provides further evidence that Petitioner is
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`acting at LG’s behest.
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`As to the instituted grounds, first, Petitioner has failed to demonstrate that
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`claim 29 is obvious in view of JP H03-189679 (“Suzuki”). Suzuki does not disclose
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`an embodiment in which a light emitting panel has patterns of light extracting
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`deformities on both sides that each vary in a different way or manner than the other.
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`Furthermore, a person of ordinary skill would not be motivated to modify Suzuki’s
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`teachings to create such a panel without impermissibly using the invention of claim
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`29 as a roadmap to do so.
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`Second, Petitioner has not met its burden to establish that claim 47 is obvious
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`in view of Suzuki combined with U.S. Patent 5,005,108 (“Pristash”). Among other
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`2
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`things, Claim 47 requires “a transition region between the at least one input edge and
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`the patterns of light extracting deformities to allow the light from the at least one
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`light source to mix and spread.” Neither Suzuki nor Pristash has such a transition
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`region. Furthermore, a person of skill in the art would not attempt to use Pristash’s
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`“transition device” in Suzuki’s device, because Pristash’s device does not itself
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`satisfy the claim limitation, Suzuki does not need such a device, and it would not fit
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`within Suzuki’s device.
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`II. ARGUMENT
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`Both of Petitioner’s remaining obviousness arguments require impermissible
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`cherry-picking of elements within the references and hind-sight logic. In neither case
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`would a person of ordinary skill be motivated to modify or combine the references
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`based on the references themselves, but only by using the claimed inventions of the
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`ʼ370 patent as a guide. See Abbott Labs. v. Sandoz, Inc., 544 F.3d 1341, 1348 (Fed.
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`Cir. 2008) (“in addressing the question of obviousness a judge must not pick and
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`choose isolated elements from the prior art and combine them so as to yield the
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`invention in question if such a combination would not have been obvious at the time
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`of the invention.”) (citing Dennison Mfg. Co. v. Panduit Corp., 475 U.S. 809, 810
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`(1986)); see Otsuka Pharmaceutical Co., Ltd. v. Sandoz, Inc., 678 F.3d 1280, 1296
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`(Fed. Cir. 2012) (“The inventor’s own path itself never leads to a conclusion of
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`Patent 7,537,370
`obviousness; that is hindsight.”). Thus, the Board should reject Petitioner’s
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`arguments that claims 29 and 47 are obvious.
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`A. Claim 29 is not Obvious in View of Suzuki
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`Suzuki does not describe element [29.e], which requires that both sides of the
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`
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`panel member have a pattern of light extracting deformities and that “at least some
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`of the light extracting deformities on or in one of the sides vary in a different way or
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`manner than the light extracting deformities on or in the other side.” Ex. 1001, ʼ370
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`patent at 11:15-19. Petitioners concede that there is not one embodiment of Suzuki
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`having that requirement, and thus attempt to combine different teachings of Suzuki.
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`See Petition at 41-42. However, a person of ordinary skill in the art would not
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`combine the different teachings of Suzuki, and Suzuki does not have sufficient
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`teaching of how to do so. See Ex. 2006, Declaration of Kenneth Werner (“Werner
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`Dec.”) at ¶¶50-62.
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`
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`The ʼ370 patent describes that “[b]y varying the density, opaqueness or
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`translucence, shape, depth, color, area, index of refraction, or type of deformities 21
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`on an area or areas of the panels, the light output of the panels can be controlled.”
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`Ex. 1001, ʼ370 patent at 4:62-65. The ʼ370 patent also describes that “a greater
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`percentage of and/or larger deformities may be placed on areas of the panels where
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`greater light output is desired.” Id. at 5:2-4. Suzuki does not describe varying
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`deformities on both sides in different ways in view of this disclosure.
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`4
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`In particular, Patent Owner does not agree with the Board’s understanding
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`that the ʼ370 patent’s references to “density” or “percentages” “express a difference
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`in pitch.” Institution Decision, Paper 15, at 15-16. First, it is not disputed that the
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`ʼ370 patent does not discuss the “pitch” of deformities.” Ex. 2007, Deposition of
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`Thomas Credelle (“Credelle Dep.”) at 171:20-172:17.
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`
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`Second, Suzuki uses the word “pitch” to describe the one dimensional spacing
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`of the grid in which the elements are placed. See Werner Dec. at ¶53. Where Suzuki
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`describes that the pitch in Fig. 5 is gradually changed, the grids are only changed in
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`one dimension (horizontally, relative to the page). As shown in Fig. 2A, the pitch is
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`identified as “P,” which is the same in both the horizontal and vertical directions.
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`This is consistent with what Petitioner’s expert, Mr. Credelle, testified was
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`
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`the meaning of pitch in the field of LCD backlighting: “the distance from the center
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`to center of a feature on the backlight.” Credelle Dep. at 169:15-23. Mr. Credelle
`5
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`further confirmed that “pitch” and “density” do not necessarily correlate. See id. at
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`173:11-174:3 (“You could have so many dots per square inch in one section and
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`fewer dots per square inch in another section, and you would say the density of dots
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`is different, but there may not be a real pitch. The pitch tends to imply some
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`periodicity although it doesn’t have to.”). Thus, even if it were described, varying
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`the pitch of deformities does not satisfy the limitation of claim [29.e].
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`
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`Suzuki describes certain embodiments in Table 1, some of which have an
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`embossed pattern on a single side of the light guide layer, and some of which have
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`embossed patterns on both sides. See Ex. 1008, Suzuki at 9. As recognized by the
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`Board, the results of “studies” set forth in Table 1 of Suzuki relate to the embossed
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`pattern shown in Fig. 2A, as also discussed on page 14. See Institution Decision at
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`13; see also, e.g., Suzuki at 9-10; see also Werner Dec. at ¶54. As the Board
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`explained, “Suzuki’s Table 1 shows that where Suzuki discloses using an embossed
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`pattern on both sides of the light guide, the pattern is of the same type.” Institution
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`Decision at 14; see also Werner Dec. at ¶54.
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`
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`As also recognized by the Board, Suzuki explains that “it is not necessary to
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`form the embossed pattern 21 on both sides, and the embossed pattern 21 may instead
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`be formed only one of the front and back surfaces.” Suzuki at 13; Institution Decision
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`at 14; Werner Dec. at ¶55. Furthermore, in the examples discussed in Table 1, Suzuki
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`6
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`describes each as having a pitch that does not vary. See Suzuki at 9; see also Werner
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`Dec. at ¶55. Table 1 is shown below:
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`
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`Suzuki further describes that “[e]mbossed patterns having different pitches
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`may be formed on the front and back surfaces of the transparent light guide layer 2.”
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`Id. This disclosure does not teach that the pattern of deformities in each side of the
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`panel member vary in a different way or manner than the pattern of deformities in
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`the other side, as required by claim 29. See Werner Dec. at ¶52. This does not
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`disclose a panel in which the pitch on both sides may vary; instead they pitches on
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`each side remains the same. See Suzuki at 9; see also Werner Dec. at ¶56.
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`
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`Suzuki describes other embodiments in Table 2, all of which have embossed
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`patterns on only one side. See id. at 17; see also Werner Dec. at ¶58. In Examples 3
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`and 4 of Table 2, the projection areas of the embossed elements is varied, in contrast
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`to Comparative Example 7, in which has a uniform pattern. See Suzuki at 17-18.
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`7
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`Suzuki illustrates embodiments having varying patterns in Figures 10-20. See Suzuki
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`at 14-20; see also Werner Dec. at ¶58-60.
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`
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`Thus, Suzuki’s disclosure of an embossed pattern that can change or vary (s
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`illustrated by Figs. 10 - 20), is limited to panels in which the embossed pattern is
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`only on one side. See Werner Dec. at ¶57. Suzuki’s disclosure of the logarithmic
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`equation to determine the area of the embossed elements is also limited to the studies
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`of Table 2, in which the embossed elements are only on one side. See id.
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`For Table 2, Suzuki describes that “[t]he area of each embossed element does
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`not exceed the area of each cell of the grid at a predetermined pitch” but that “the
`8
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`area of each embossed element is preferably as large as possible.” Suzuki at 15; see
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`also Werner Dec. at ¶60. Suzuki uses coefficients “a” and “b” in a logarithmic
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`equation associated with Table 2 to determine the area of the embossed elements.
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`See Suzuki at 15-16; Werner Dec. at ¶60. Those coefficients are determined by many
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`factors, including “a light diffusion layer, a reflective layer, a light source, a light-
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`source reflective layer, a pitch, and the maximum and minimum areas of embossed
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`elements.” Suzuki at 15-16; Werner Dec. at ¶60. Suzuki provides the coefficients
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`used in Table 2, but does not provide any coefficients to use with Table 1. See Suzuki
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`at 9; see also Werner Dec. at ¶59. A person of ordinary skill would understand that
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`Suzuki only discloses the logarithmic equation with Table 2 because the logarithmic
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`equation does not apply to Table 1where the embossed elements fill the entire cell.
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`See Werner Dec. at ¶59.
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`Thus, there is no disclosure in Suzuki of a panel in which the pitch on both
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`sides may vary. See Werner Dec. at ¶56. Furthermore, even if the pitch on both sides
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`of the panel were to be “gradually changed,” which is not disclosed, that would not
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`be disclosure of deformities on each side varying “in a different way or manner than
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`the pattern of deformities in the other side.” Id. Instead, they would be varying in the
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`same way or manner, and would not meet the limitations of claim 29. Id.
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`Furthermore, Petitioner is incorrect to suggest that the examples discussed in
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`Table 1 (which can have embossed elements on both sides) can be combined with
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`9
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`the examples in Table 2 (which can only have embossed elements on one side). See
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`Werner Dec. at ¶57. The examples in Table 2 and Figures 10-20 are determined
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`using a logarithmic equation that does not apply to the examples in Table 1. See
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`Suzuki at 17; see also Werner Dec. at ¶59. The best luminance results of Table 1 are
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`Examples 1 and 2, but the luminance results of Example 3 in Table 2 is better. See
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`Werner Dec. at ¶57. Further, the luminance variation in Examples 3 and 4 of Table
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`2 are much better than Table 1. See id. Given that (1) Suzuki’s best results are with
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`a single-sided variable pattern, (2) results from Table 1 vary strongly with pitch, and
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`(3) putting patterns on front and back that vary differently would have unpredictable
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`consequences requiring extensive additional study, the results of Suzuki’s examples
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`provide no motivation for using patterns on both sides, much less variable patterns
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`with different variations on both sides. See id.
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`Finally, a person of ordinary skill would understand that Suzuki’s statement
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`on page 20 that “all or some of these examples may also be employed in
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`combination” only applies to the examples described by Table 2 and Figs. 10-20.
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`See Suzuki at 20; Werner Dec. at ¶61. The statement on page 20 follows the
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`discussion of examples described by Table 2 and Figs. 10-20. See id. Second, the
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`logarithmic equation of Table 2 could not be used with the examples of Table 1, and
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`a person of skill in the art would not attempt to do so. See Werner Dec. at ¶61.
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`Thus, Suzuki does not disclose element [29.e], and it would not have been
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`obvious for a person of skill in the art to modify Suzuki so as to disclose it.
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`B. Claim 47 is not Obvious in View of Suzuki and Pristash
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`The combination of Suzuki and Pristash does not render claim 47 obvious
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`
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`because neither reference has the claimed transition region of claim 47, which
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`Petitioner identifies as elements [47.f] and [47.g], and because a person of ordinary
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`skill in the art would not be motivated to combine Suzuki with Pristash.
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`Additionally, the element that Petitioner identifies as [47.e] is substantially identical
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`to element [29.e], which is not disclosed by Suzuki, as explained above. Petitioner
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`does not provide any argument that Pristash discloses element [47.e]; thus, the
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`combination of Suzuki and Pristash also fails to render claim 47 obvious because the
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`combination does not disclose element [47.e].
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`
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`Claim elements [47.f] and [47.g] are: “wherein the panel member has a
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`transition region between the at least one input edge and the patterns of light
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`extracting deformities to allow the light from the at least one light source to mix and
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`spread, and at least one side of the transition region contains optical elements for
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`reflecting or refracting light from the at least one light source.” ʼ370 patent at 12:34-
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`39. The Board correctly rejected the argument that Suzuki alone fails to disclose the
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`claimed transition region. See Institution Decision at 16. However, Patent Owner
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`respectfully submits that the Board incorrectly found that Pristash discloses the
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`claimed transition region.
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`
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`The transition region required by claim 47 must be positioned “between the
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`at least one input edge [of the light emitting panel] and the patterns of light extracting
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`deformities [on the light emitting panel].” See ʼ370 patent at 12:34-36; see also 2:63-
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`64, 3:16-30; 7:6-15; see also Werner Dec. ¶67. The transition “device” of Pristash
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`that Petitioner identifies is not positioned in that way. See Werner Dec. at ¶68.
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`
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`Petitioner offers an incorrect construction of the term “transition region”
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`within claim 47 in order to avoid the positional requirement of the transition region.
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`Petitioner identifies the construction of “transition region” in the Eastern District of
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`Texas, which held that the term means “a region configured to transmit light.” See
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`Petition at 8. Patent Owner agrees with that construction. However, Petitioner then
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`suggested that in claim 47 the term “should include any ‘region configured to
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`transmit light [between the at least one input edge and the patterns of light extracting
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`deformities to allow the light from the at least one light source to mix and spread].’”
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`Id. This construction, taken apart from the context of the remainder of the claim,
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`allows Petitioner to avoid the requirement that the claimed transition region be
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`positioned between the input edge of the optical panel member and the patterns of
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`light extracting deformities on the optical panel member. See Werner Dec. at ¶¶47-
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`12
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`48 and 68. In fact, Mr. Credelle admitted in his deposition that Patent Owner’s
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`construction of the term is correct. See Credelle Dep. at 166:29-167:19.
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`Petitioner identifies the “transition device 5” of Figure 1 of Pristash. See
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`Petition at 52. But Pristash’s transition device 5 is not positioned between the input
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`edge 4 of the light emitting panel 2 and the pattern of deformities 16, as shown in
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`Figure 1 below. See also Werner Dec. at ¶69.
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`
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`Petitioner incorrectly suggests that “input edge 10” is the claimed input edge
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`
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`of the panel member. See Petition at 52. However, Pristash explicitly states that it is
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`“the input end 10 of the transition device 5.” Ex. 1007, Pristash at 3:19-20. Pristash
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`also explicitly identifies the “light emitting panel input edge 4.” Id. at 3:4; see also
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`Werner Dec. at ¶69. While Pristash also identifies a solid transition device (e.g., Fig.
`13
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`19), Pristash never discloses the transition device being positioned between the input
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`edge of the panel and the pattern of deformities.
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`Moreover, even if Pristash did disclose the claimed transition region,
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`Petitioner’s argument that “[i]t would have been obvious to shape the transition
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`region of Suzuki like the transition region of the light guide of Pristash” is incorrect.
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`Petition at 53. First, because Suzuki does not disclose a transition region, as the
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`Board recognized in its Institution Decision, there is not a transition region to
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`“shape” like the transition device of Pristash. See Werner Dec. at ¶71. Second,
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`Petitioner does not explain how the light guide of Suzuki would be “shaped.” Id.
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`Third, a person of skill in the art would not be motived to use Pristash’s transition
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`device with the light guide of Suzuki. Id.
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`
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`Suzuki does not disclose, as Petitioner argues, point light sources as a design
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`choice for the surface light source devices disclosed and claimed by Suzuki. See
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`Werner Dec. at ¶72. Suzuki refers to a point light source only once, in describing the
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`field of the application. See Suzuki at 2 (“[Industrial Field of Application] The
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`present invention relates to surface light source devices used for illumination or the
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`like, and more particularly, to illumination devices used as surface light sources for
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`uniformly illuminating a relatively large area by using light from a point light source
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`or a linear light source.”). Suzuki does not provide any further description of what
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`type of point light source is being referred to (e.g., whether it would include an LED),
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`nor does Suzuki provide any description of an embodiment of the inventions in
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`which a point light source is used. See Werner Dec. at ¶72.
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`Instead, the light source Suzuki describes in connection with the disclosed
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`inventions is a cold-cathode tube having a diameter of 6mm. See Suzuki at 10; see
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`also Werner Dec. at ¶73. Suzuki describes and illustrates these tube light sources as
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`being positioned directly next to each side of the light source. See Suzuki at 10 and
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`Fig. 1A and 1B; see also Suzuki at 1 (“wherein a light source and a light-source
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`reflective layer are arranged on an edge of the transparent light guide layer”); see
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`also Werner Dec. at ¶73.
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`In contrast, Pristash describes that its transition devices are “for use in
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`transmitting light from a remote location to the light emitting panels of the present
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`invention.” Pristash at 7:10-12; see also Werner Dec. at ¶74. Pristash further
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`describes that “the purpose of such transition devices is to transmit light focused on
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`its input surface or surfaces to a light emitting panel by converting a relatively easily
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`focused cross-sectional shape of light to the shape of the panel input surface.” Id. at
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`7:12-17; see also 7:39-42 (describing the transition device as “having an input
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`surface at one end of a cross-sectional shape on which a light source is easily focused
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`such as round or square and having an output surface at the other end in the shape of
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`the panel input surface”); Werner Dec. at ¶74.
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`In Figure 1 of Pristash, the transition device is used with a “collector 9 which
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`collects the light emitted by the radiation source 8 and uniformly focuses the light
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`on the input end 10 of the transition device 5.” Id. at 3:17-20; Werner Dec. at ¶75.
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`And in describing the transition devices of Figs. 18 and 19, Pristash describes that
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`the output surface of the transition devices “may be lens shaped or tapered to alter
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`the input light ray distribution.” Id. at 7:57-59.
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`The chart below shows Suzuki’s surface light source device and Pristash’s
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`transition devices.
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`Suzuki
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`Pristash
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`16
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`The figures from Pristash demonstrate that Pristash uses a collector and a transition
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`device to focus light from a relatively large light source into a thinner panel. See
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`Werner Dec. at ¶77. In addition, Pristash describes that the panel “may be
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`approximately 0.020 inch [approximately 0.5 mm] thick and have an overall height
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`of 0.040 inch [approximately 1.0 mm].” See Pristash at 3:58-60. In contrast, Suzuki
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`discloses a light guide that is “4 mm (thickness) or 5 mm over the entire area
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`thereof.” Suzuki at 8. Thus, Pristash requires the collector and transition device to
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`focus and spread the light from the larger light sources along the edge of the much
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`thinner panel, whereas Suzuki does not. See Werner Dec. at ¶77.
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`Further, if Suzuki were to use the transition devices disclosed by Pristash, it
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`would require that the tubular light source used by Suzuki be located further away
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`from the input edge of the light guide, which would reduce efficiency and increase
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`loss. See Werner Dec. at ¶78. Doing so would also make Suzuki’s device larger and
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`heavier. See id. These are additional reasons why a person of skill in the art would
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`not be motivated to use Pristash’s transition device with Suzuki’s surface light
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`source device. See id.
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`Thus, because neither Suzuki nor Pristash disclose the required transition
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`region, and additionally because a person of skill in the art would not be motivated
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`to combine the teachings of Suzuki and Pristash, claim 47 is not obvious in view of
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`those references.
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`C. The Petition Is Time Barred Under 35 U.S.C. § 315(b)
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`
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`Because of recent events, Patent Owner respectfully urges the Board to
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`reconsider its determination on March 17, 2016 that the Petition was not time barred.
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`See Institution Decision at 24-25. As Patent Owner explained in its Preliminary
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`Response, Petitioner is a supplier to LG (who indisputably is time-barred) and is
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`represented by the same counsel that represents LG both before the PTAB and in the
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`District of Delaware regarding the same patents, and LG and its counsel used this
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`and two other IPR petitions by Petitioner as the basis for their motion to stay the
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`district court proceedings (which was denied). See Preliminary Response, Paper 11
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`at 5-9.
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`
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`One week after the Board’s institution of review in IPR2015-01866, IPR2015-
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`01867, and IPR2015-01868, LG renewed its motion to stay in the District of
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`Delaware. See Ex. 2008, LG’s Reply In Support of Renewed Motion to Stay at 5
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`(C.A. No. 13-2109-RGA, D. Del. April 21, 2016) (“Defendants filed their renewed
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`motion to stay a mere one week after the PTAB issued institution decisions on K.J.
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`Pretech’s IPRs on the remaining patents-in-suit”). In arguing that motion, LG’s
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`counsel, who is counsel to Petitioner here, inadvertently revealed that LG is actually
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`in control of this proceeding, which the district court recognized. Arguing for LG,
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`Mr. Pluta said that “[w]e’ll have one patent that completely – and I’m presuming
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`that we win the IPRs – that KJ Pretech wins the IPRs,” and the court said “I think
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`the ‘we’ was right.” See Hr’g Tr. at 9:11-14 (C.A. 13-2109-RGA, D.I. 348, D. Del.
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`June 2, 2016). The Court denied LG’s renewed motion to stay, but these events
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`reaffirm Patent Owner’s prior argument that Petitioner is acting at LG’s behest in
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`this proceeding.
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`Further, when Patent Owner requested a courtesy extension of the deadline to
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`file this response, Petitioner’s counsel again referred to the litigation between Patent
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`Owner and LG, arguing that the extension was somehow intended to obtain an
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`advantage in the litigation with LG. The Board granted the short extension requested
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`by Patent Owner, but Petitioner’s (and LG’s) counsel’s argument relating to the
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`litigation again revealed that this proceeding is being controlled and coordinated by
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`LG in conjunction with the district court litigation.
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`Therefore, Patent Owner renews its argument that the Board find that this
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`proceeding was time-barred, consistent with policy of the real party in interest and
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`privies requirement “to protect patent owners from harassment via successive
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`petitions by the same or related parties, to prevent parties from having a ‘second bite
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`at the apple,’ and to protect the integrity of both the USPTO and Federal Courts by
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`assuring that all issues are promptly raised and vetted.” Trial Practice Guide at
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`48,759.
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`Case IPR2015-01867
`Patent 7,537,370
`III. CONCLUSION
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`In view of the foregoing, Patent Owner contends that the Board should find
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`that all challenged claims are patentable. Petitioner has not satisfied its burden to
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`demonstrate unpatentability of claims 29 and 47. Further, the evidence shows that
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`the Petition was time-barred, because Petitioner’s customer, LG, who is indisputably
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`time barred, is a real party in interest and privy.
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`Case IPR2015-01867
`Patent 7,537,370
`Respectfully submitted,
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`Dated: July 1, 2016
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`________________________
`Justin B. Kimble
`Attorney for Patent Owner
`Registration No. 58,591
`Bragalone Conroy P.C.
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that document has been served via electronic
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`mail on July 1, 2016, to Petitioner at following email addresses pursuant to its
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`consent
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`in
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`its Mandatory Notices at p. 3:
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`rpluta@mayerbrown.com,
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`bpaul@mayerbrown.com, astreff@mayerbrown.com, alam@mayerbrown.com, and
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`jbeaber@mayerbrown.com, with a courtesy copy to DDGIPR@mayerbrown.com.
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` ________________________
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`Justin B. Kimble
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`Attorney for Patent Owner
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`Registration No. 58,591
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`Bragalone Conroy P.C.
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`2200 Ross Ave.
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`Suite 4500 – West
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`Dallas, TX 75201
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`Case IPR2015-01867
`Patent 7,537,370
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`CERTIFICATE OF COMPLIANCE
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`As required by 37 C.F.R. §42.24(a), the undersigned hereby certifies that the
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`foregoing Petition for Inter Partes Review contains 4,028 words, excluding those
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`portions id entified in 37 C.F.R. §42.24(a)(1)(i) and (b)(1), as measured by the word-
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`processing system used to prepare this paper.
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`________________________
`Justin B. Kimble
`Attorney for Patent Owner
`Registration No. 58,591
`Bragalone Conroy P.C.
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
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