throbber
Case IPR-2016-00135
` 
`United States Patent No. 7,245,874
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`HUGHES NETWORK SYSTEM, LLC,
` Petitioner
`
`v.
`
`ELBIT SYSTEM LAND AND C4I LTD.,
`Patent Owner
`
`––––––––––
`
`Case IPR2016-00135
`Patent No. 7,245,874
`––––––––––
`
`
`
`PETITIONER’S REQUEST FOR REHEARING UNDER 37 C.F.R. §
`42.71(d)
`
`
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`     
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`Case IPR-2016-00135
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`United States Patent No. 7,245,874
`
`TABLE OF CONTENTS
`
`INTRODUCTION ............................................................................................... 1
`I.
`II. LEGAL STANDARD ......................................................................................... 2
`III. MATTERS MISAPPREHENDED OR OVERLOOKED .................................. 2
`A. The Board Erred In Failing to Institute As To The Grounds Based On
`Cox .................................................................................................................... 2
`1. The Board Erred In Denying Grounds 1 and 2 Based on An
`Erroneous Finding that References Did not Disclose a “Synchronous
`Data Protocol [That] Allows Non-Data Carrying Time Slots.” ................. 2
`2. The Board Erred In Denying Grounds 1 and 2 Based on An
`Erroneous Finding that References Did not Disclose a “A Non-Data
`Carrying Time Slot Remover.” ................................................................ 10
`IV. CONCLUSION ................................................................................................. 14
`
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` 
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`

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`Case IPR-2016-00135
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`United States Patent No. 7,245,874
` 
`
`
`CASES
`
`TABLE OF AUTHORITIES
`
`Page(s)
`
`Arnold P’ship v. Dudas,
`362 F.3d 1338 (Fed. Cir. 2004)..................................................................................................2
`
`In re Gartside,
`203 F.3d 1305 (Fed. Cir. 2000)..................................................................................................2
`
`Star Fruits S.N.C. v. United States,
`393 F.3d 1277 (Fed Cir. 2005)...................................................................................................2
`
`STATUTES
`
`35 U.S.C. § 314(a) ...............................................................................................................2, 10, 14
`
`OTHER AUTHORITIES
`
`37 C.F.R. § 42.71(c).........................................................................................................................2
`
`37 C.F.R. § 42.71(d) ........................................................................................................................2
`
`37 C.F.R. § 42.71(d)(2) ....................................................................................................................1
`
`37 C.F.R. § 42.108(c).......................................................................................................................2
`
`FRE 702 .........................................................................................................................................13
`
`
`
`
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`

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`Case IPR2016-00135
` 
`United States Patent No. 7,245,874
`
`I.
`INTRODUCTION
`In response to the Decision Denying Institution of Inter Partes Review
`
`entered April 27, 2016 (Paper No. 8) (“Decision”), Hughes Network Systems, LLC
`
`(“Hughes”) submits this Request for Rehearing Under 37 C.F.R. § 42.71(d)(2) and
`
`respectfully requests that the Patent Trial and Appeal Board (“Board”) reconsider
`
`its decision not to institute Inter Partes Review proceedings on Claims 1 and 8-12
`
`of United States Patent No. 7,245,874 (“the ’874 Patent”) as requested under
`
`Grounds 1-5 in the Petition for Inter Partes Review of United States Patent No.
`
`7,245,874 (Paper No. 1) (“Petition”).
`
`The Petition requested Inter Partes Review of Claims 1-30 of the ‘874
`
`Patent across five grounds. The Petition was supported, in part, by the Declaration
`
`of Dr. Raymond Leopold (Ex. 1003). In the Decision, the Board denied institution
`
`of Inter Partes Review on all grounds. Petitioner respectfully submits that the
`
`Board erred in not instituting Trial. The Decision was based on a misapprehension
`
`of the Petition and supporting evidence
`
`The Petition challenged independent claim 1 on grounds 1 and 2. Ground 1
`
`is based on Cox (Ex. 1004) and Arimilli (Ex. 1006). Ground 2 is based on Cox,
`
`Arimilli, and Silverman (Ex. 1007). The Decision found that the Petition has not
`
`shown that these references disclose two elements of claim 1.
`
` 
`
`1
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`

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`Case IPR2016-00135
` 
`United States Patent No. 7,245,874
`II. LEGAL STANDARD
`A request for rehearing is appropriate when the requesting party believes
`
`“the Board misapprehended or overlooked” a matter that was previously addressed
`
`in the record. See 37 C.F.R. § 42.71(d). In reviewing such a request, the “panel
`
`will review the decision for an abuse of discretion.” 37 C.F.R. § 42.71(c). An
`
`abuse of discretion occurs where the decision is based on an erroneous
`
`interpretation of the law, or on erroneous facts. See Star Fruits S.N.C. v. United
`
`States, 393 F.3d 1277, 1281 (Fed Cir. 2005); Arnold P’ship v. Dudas, 362 F.3d
`
`1338, 1340 (Fed. Cir. 2004); In re Gartside, 203 F.3d 1305, 1315-16 (Fed. Cir.
`
`2000). Abuse also occurs “if a factual finding is not supported by substantial
`
`evidence, or if the decision represents an unreasonable judgment in weighing
`
`relevant factors.” TD Ameritrade v. Trading Techs. Int’l, Inc., CBM2014-00137,
`
`Paper No. 34 (Feb. 2, 2015) at 3.
`
`
`
`Under 35 U.S.C. § 314(a), in order for an inter partes review to be instituted
`
`by the Board, the Petitioner need only show a “reasonable likelihood that the
`
`petitioner would prevail”. Accord 37 C.F.R. § 42.108(c).
`
`III.
`
` 
`
` MATTERS MISAPPREHENDED OR OVERLOOKED
`A. The Board Erred In Failing to Institute As To The Grounds
`Based On Cox
`1. The Board Erred In Denying Grounds 1 and 2 Based on
`An Erroneous Finding that References Did not Disclose a
`“Synchronous Data Protocol [That] Allows Non-Data
`Carrying Time Slots.”
`2
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`

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`Case IPR2016-00135
` 
`United States Patent No. 7,245,874
`The Claim Element Is Disclosed in Both Cox and Silverman
`
`The Decision found that the Petition has not demonstrated that Cox and
`
`Arimilli disclosed the claim limitation of “wherein said synchronous data protocol
`
`allows non-data carrying time slots.” Decision at 7-10. Petitioner submits that the
`
`Board misapprehended important evidence cited in the Petition. In particular, the
`
`Board misapprehended that the disclosure of the T1 and E1 protocols in the prior
`
`art discloses this claim element.
`
`The Petition mapped the claimed “synchronous data protocol” to Cox’s use
`
`T1 and E1 protocols. In particular, with respect to this element 1[e], the Petition
`
`stated that “[t]he T1/E1 protocols supported by Cox allow non-data carrying time
`
`slots.” Petition at 23. This fact was unrebutted by the Patent Owner.
`
`The mapping of Cox’s T1 and E1 protocols to the claimed first synchronous
`
`protocol was first discussed in the petition with respect to the preamble of claim 1
`
`where there claim term “first synchronous protocol” is introduced. The Petition
`
`quoted Cox:
`
`First, the trend in the communications industry is moving
`away from synchronous network technologies and towards
`packet-switched technologies. . . . Packet-switched central
`office switches now exist for providing voice over IP (VOIP)
`networks. But, as noted above, to do so requires that a
`telephone service provider completely change over equipment
`within a central office switch from that which uses the T1 (or
`3
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`Case IPR2016-00135
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`United States Patent No. 7,245,874
`E1) protocol to VoIP-based equipment.
`
`Cox, Ex. 1004 at 12:17-27; Petition at 14 (emphasis supplied).
`
`This mapping was reinforced by Petitioner’s further mapping of claim
`
`element 1[b] to Cox. As stated in the Petition:
`
`Cox discloses a T1(or E1)-to-IP multiplexer for
`interconnecting a synchronous T1/E1 communications system
`with an asynchronous IP-based system. Ex. 1003 at ¶ 108. In
`particular, Cox discloses:
`
`[A] system 400 according to the present invention for
`providing T1/E1 trunk interconnections over a high bandwidth
`packet-switched data network. The system 400 includes a
`plurality of existing T1 (or E1) telecommunications signal
`switches 410 . . . each switch 410 is directly paired with a
`T1(or E1)-to-IP multiplexer 420. T1 (or E1) trunk signals are
`provided to each multiplexer 420 via T1 (or E1) links 411.
`Each T1 (or E1) link 411 shown in the system 400 represents
`what would otherwise be a requirement for a T1 or E1 trunk
`between the switches 410. . . . IP network packets carrying T1
`(or E1) frame information are output from each of the T1(E1)-
`to-IP multiplexers 420 on buses 421 in a format compatible
`with a high speed packet-switched data network.
`
`Ex. 1004 at 12:65-13:20.
`
`[T]he T1(E1)-to-IP multiplexer 500 includes four T1(E1)
`trunk interface logic ports 510. …. Each T1(E1) port 510
`
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`Case IPR2016-00135
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`United States Patent No. 7,245,874
`provides full-duplex connectivity with a corresponding
`synchronous T1 frame stream 501 associated with a T1(E1)
`switch (not shown). Each port 510 transmits and receives
`T1(E1) data to network translation logic 520 via buses 511. . ..
`The network translation logic 520 provides formatted network
`packets to network interface logic 530 via bus 521. The
`network interface logic 530 transmits/receives packets from a
`router (not shown) connected to a packet-switched network
`(not shown) via a gateway.
`
`Ex. 1004 at 14:9-23. Therefore Cox’s truck interface logic
`portion 510 receives T1 or E1 protocol data, which is then
`translated by network translation logic 520 into an IP-based
`protocol. Ex. 1003 at ¶ 111. Network interface logic 530
`interfaces with the IP-based network. Id.; Ex. 1004 at 14:9-23.
`
`Petition, 17-18.
`
`Cox’s T1 and E1 protocols are exactly the same protocols that the ‘874
`
`patent describes as synchronous protocols that allow non-data carrying time slots.
`
`As the ‘874 patent explains:
`
`The E1 or T1 data stream is generally a highly synchronized
`or ordered data stream comprising numerous communication
`channels (transmissions) multiplexed together in different time
`slots within a continuous stream. The time slots comprise both
`data and associated control signaling. The multiplexer
`packages the data stream and associated control signaling into
`TCP/IP data packets as data payload such the packaging can
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`Case IPR2016-00135
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`United States Patent No. 7,245,874
`be removed at the far end to leave the original E1 or T1 data
`stream in its entirety. The TCP/IP data packets are first
`stripped of blank time slots, T0 slots and other user
`predetermined parts of the El signal, by a filter 51.
`
`Ex. 1001, 6:64-7:8 (emphasis supplied).
`
`Indeed, claim 8 of the ‘874 Patent further confirms that the disclosure of the
`
`E1 protocol (as in Cox) satisfies the claim element. That claim states: “wherein
`
`said first synchronous data protocol is the E1 protocol.” Ex. 1001, 16:21-23.
`
`The Petition demonstrated that the E1 protocol was disclosed by Cox
`
`(Petition at 35-37), and the Patent Owner never argued that the E1 protocol
`
`disclosed in Cox is any different from the E1 protocol described in the ‘874
`
`specification and/or claimed in claim 8. The Board erred in concluding otherwise.
`
`Furthermore, with respect to Ground 2, the Petitioner further demonstrated
`
`that Silverman (Ex. 1005) also disclosed the E1 protocol as the first synchronous
`
`protocol. The Petition quoted Silverman:
`
`Cellular carriers' networks are based on TDM technologies.
`Connectivity between the base stations (BTSs), base station
`controllers (BSCs), and the mobile switching center (MSC) is
`achieved using TDM microwave links and T1/E1 leased lines.
`Until recently, ATM was the most logical alternative. Because
`of pressure from environmental groups, cellular carriers are
`looking for an alternative to microwave, and leased lines are
`costly. With the introduction of QoS in Gigabit Ethernet
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`Case IPR2016-00135
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`United States Patent No. 7,245,874
`networks and the availability of TDMoIP, IP is very seriously
`considered as the preferred solution.
`
`Ex. 1005 at 14:55-15:2; Petition at 30.
`
`Again, the Patent Owner did not argue that Silverman’s disclosure of the E1
`
`protocol is any different from the E1 protocol described in the ‘874 specification or
`
`claimed in claim 8. Again, the Board erred in concluding otherwise.
`
`Arimilli Further Demonstrates the Claim Element
`
`The Petition further relied on Arimilli to show this limitation. As explained
`
`in the Petition:
`
`That some voice time slots may be non-data carrying time
`slots is confirmed by Arimilli. Id.
`
`A silence detection algorithm 1205 is also included in the
`programmed code of the DSP 620. The silence detection
`function is a summation of the square of each sample of the
`voice signal over the frame. If the power of the voice frame
`falls below a preselected threshold, this would indicate a silent
`frame. The detection of a silence frame of speech is important
`for later multiplexing of the V-data (voice data) and C-data
`(asynchronous computer data) described below. During silent
`portions of the speech, data processor 318 will transfer
`conventional digital data (C-data) over the telephone line in
`lieu of voice data (V-data).
`
`Ex. 1006 at 28:8-15 (emphasis supplied).
`
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`Case IPR2016-00135
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`United States Patent No. 7,245,874
`A person of ordinary skill in the art would understand that
`Arimilli’s “silent frame is within the broadest reasonable
`interpretation of a “non-data carrying time slot.” Ex. 1003 at
`¶ 125. Furthermore, the passage above further demonstrates
`that voice data is transmitted with a synchronous protocol,
`because it is contrasted with asynchronous computer data. Id.
`The combination of Cox and Arimilli therefore discloses this
`limitation. Id. at ¶ 126.
`
`Petition at 23-24 (emphasis supplied).
`
`As part of its decision, the Board found that Arimilli’s silent frames were not
`
`within the broadest reasonable interpretation of the claimed non-data carrying time
`
`slots. Although Petitioner disagrees, this finding is an insufficient basis on which
`
`to rest the Board’s Decision, because the Petition also demonstrated that Cox and
`
`Silverman disclose this limitation.
`
`The Declaration of Dr. Leopold Further Supported The Conclusion That The
`Prior Art References Disclose the Element
`
`As further evidence that “[t]he T1/E1 protocols supported by Cox allow non-
`
`data carrying time slots,” Petitioner offered a declaration from Dr. Leopold. Ex.
`
`1003 at ¶¶ 124-125. For this claim element, Dr. Leopold explained that:
`
`The T1/E1 protocols supported by Cox may have non-data
`carrying time slots. For example, where the T1/E1 protocols
`are used for telephonic communication T1/E1 time slots may
`correspond to silence and therefore not carry any data. See,
`
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`8
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`Case IPR2016-00135
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`United States Patent No. 7,245,874
`e.g., Ex. 1004 2:18-34; Ex. 1006 at 28:8-15. That some voice
`time slots may be non-data carrying time slots is confirmed by
`Arimilli.
`
`A silence detection algorithm 1205 is also included in the
`programmed code of the DSP 620. The silence detection
`function is a summation of the square of each sample of
`the voice signal over the frame. If the power of the voice
`frame falls below a preselected threshold, this would
`indicate a silent frame. The detection of a silence frame of
`speech is important for later multiplexing of the V-data
`(voice data) and C-data (asynchronous computer data)
`described below. During silent portions of the speech, data
`processor 318 will transfer conventional digital data (C-
`data) over the telephone line in lieu of voice data (V-data).
`
`Ex. 1006 at 28:8-15.
`
`Ex. 1003 at ¶ 124.
`
`The Decision does not dispute any of Dr. Leopold’s findings. Instead,
`
`the Decision states that “[w]e do not find Dr. Leopold’s testimony helpful because
`
`it merely mimics Petitioner’s argument.” Decision at 9, nn. 2. The Patent Owner
`
`did not present any arguments why Dr. Leopold is not an expert on the subject
`
`matter of the ‘874 Patent or any other concrete reason why the declaration of Dr.
`
`Leopold should not be given weight. The Patent Owner may challenge the
`
`methodology and conclusion of Dr. Leopold though post-institution discovery. At
`
` 
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`9
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`Case IPR2016-00135
` 
`United States Patent No. 7,245,874
`this stage of the proceeding, however, Dr. Leopold’s testimony stands as
`
`unrebutted evidence that should be given its full weight. The Board’s failure to
`
`give any weight to Dr. Leopold’s declaration is legally erroneous. The Board’s
`
`action effectively excluded Dr. Leopold’s testimony. However, any such exclusion
`
`should only take place after Patent Owner has objected, and Petitioner has been
`
`provided with the ability to correct any defect in the form of supplemental
`
`evidence. 37 C.F.R. § 42.64(b).
`
`Moreover, the fact that the petition adopted Dr. Leopold’s reasoning
`
`in support of the asserted grounds is not a sufficient basis to disregard the
`
`unrebutted evidence of record. At the very least, Dr. Leopold’s analysis shows that
`
`there is a “reasonable likelihood” that petitioner will be able to show the claims are
`
`invalid. This is all that is required at the institution stage. 35 U.S.C. § 314(a). The
`
`Board erred to the extent it required a higher standard of proof.
`
`2. The Board Erred In Denying Grounds 1 and 2 Based on An
`Erroneous Finding that References Did not Disclose “A
`Non-Data Carrying Time Slot Remover.”
`
`The Board’s Decision was further based on a finding that the references did
`
`not disclose the claimed “said interfaces comprising a non-data carrying time slot
`
`remover for removing said non-data carrying time slots during conversion into said
`
`asynchronous protocol.” Decision at 10-12. The Board first tied this finding to the
`
`earlier finding on the claim element, discussed above:
`
` 
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`10
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`Case IPR2016-00135
` 
`United States Patent No. 7,245,874
`Petitioner has not satisfactorily explained how Arimilli alone,
`or in combination with Cox, teaches or suggests “non-data
`carrying time slots” (emphasis added). Thus, based on the
`same reasoning, we are not persuaded that Arimilli or the
`combination of Arimilli and Cox, teaches or suggests
`“removing” “non-data carrying time slots” (emphasis added).
`
`Decision at 11. As discussed above, the Board’s reasoning on “non-data carry time
`
`slots” was based on a misapprehension the evidence and/or petitioner’s argument.
`
`The Decision also finds that this element was not disclosed by the references
`
`based on the requirement that the non-data carrying time slots be removed during
`
`conversion to the asynchronous protocol. Decision at 11. The Decision states:
`
`In addition, Petitioner does not satisfactorily explain how the
`prior art teaches or suggests removing “nondata carrying time
`slots” “during conversion into said asynchronous protocol,” as
`recited in claim 1 (emphasis added). Specifically, Petitioner
`does not provide sufficient argument as to how Cox can be
`modified to remove “non-data carrying time slots” “during
`conversion into said asynchronous protocol” (emphasis
`added). Petitioner does contend that “Arimilli’s silence
`suppression algorithm could be implemented, for example,
`using the existing processors in the T1(E1)-to-IP Multiplexer
`500 of Cox.” Pet. 28 (citing Ex. 1004, Fig. 2; Ex. 1003 ¶ 133).
`Petitioner, however, provides insufficient factual bases to
`support this assertion.
`
` 
`
`11
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`Case IPR2016-00135
` 
`United States Patent No. 7,245,874
`Decision at 11. This conclusion is based on a misapprehension of Petitioner’s
`
`argument and important evidence. The Petition asserted that Cox, not Arimilli,
`
`performs that conversion from the synchronous protocol to the asynchronous
`
`protocol. Petition at 19-24. Arimilli provided the removal function. Petition at
`
`24-28.
`
`The Combination of Elements from the References Was Supported by the
`Declaration of Dr. Leopold
`
`The declaration of Dr. Leopold further supported petitioner’s position that
`
`the combination of references disclosed this limitation. Ex. 1003 at ¶¶ 127-139.
`
`Neither the Patent Owner nor the Decision offer any evidence to the contrary.
`
`Instead, the Decision states that “[a]lthough Petitioner cites to Dr. Leopold’s
`
`declaration testimony, that testimony merely restates Petitioner’s conclusory
`
`assertion.” Decision at 11.
`
`As an initial matter, the Board erred to the extent it concluded that Dr.
`
`Leopold’s testimony was “conclusory.” The combination of elements from two or
`
`more references is a prime subject on which expert testimony is appropriate. In his
`
`report, Dr. Leopold identified the relevant level of skill in the art, identified the
`
`teachings of the art that would be known to such a person, and provided specific
`
`motivations and reasons why such a person of ordinary skill in the art would
`
`combine those teachings to arrive at the claimed invention. Ex. 1003 at ¶¶ 15-19,
`
`127-139. In particular, Dr. Leopold describes how: (a) the combination of Cox and
`
` 
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`12
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`Case IPR2016-00135
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`United States Patent No. 7,245,874
`Arimilli is a combination of prior art elements according to known methods to
`
`yield predictable results; (b) the combination of Cox and Arimilli is a simple
`
`substitution of one known element for another to obtain predictable results; (c) the
`
`combination of Cox and Arimilli is the use of a known technique to improve
`
`similar devices (methods, or products) in the same way; (d) the combination of
`
`Cox and Arimilli is an application of a known technique (dropping silent frames)
`
`to a known device (method, or product) ready for improvement to yield the
`
`predictable result of a cellular network that performed silence suppression along
`
`with T1/E1 to IP conversion; and (e) Arimilli’s silence suppression algorithm
`
`could be implemented, for example, using the existing processors in the T1(E1)-to-
`
`IP Multiplexer 500 of Cox. Ex. 1004 at Fig. 2. Ex. 1003 at ¶ ¶ 129-133. Dr.
`
`Leopold’s opinions further include citations to the prior art references, which
`
`corroborate his conclusions regarding the level of skill in the art and other analysis
`
`of the Graham factors.
`
`The Board’s failure to give any weight to Dr. Leopold’s declaration is
`
`legally erroneous. The Board’s action effectively excluded Dr. Leopold’s
`
`testimony. However, any such exclusion should only take place after Patent
`
`Owner has objected, and Petitioner has been provided with the ability to correct
`
`any defect in the form of supplemental evidence. 37 C.F.R. § 42.64(b).
`
`Moreover, the fact that the petition adopted Dr. Leopold’s reasoning
`
` 
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`13
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`Case IPR2016-00135
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`United States Patent No. 7,245,874
`in support of the asserted grounds is not a sufficient basis for the Board to
`
`disregard this unrebutted evidence. At the very least, Dr. Leopold’s analysis shows
`
`that there is a “reasonable likelihood” that petitioner will be able to show the
`
`claims are invalid. This is all that is required at the institution stage. 35 U.S.C. §
`
`314(a). The Board erred to the extent it required a higher standard of proof.
`
`For all the foregoing reasons, Petitioner respectfully submits that the Board
`
`erred in its decision not to institute a Trial as to Grounds 1-5.
`
`IV. CONCLUSION
`For at least the reasons set forth above, Petitioner requests rehearing of its
`
`Petition for institution of inter partes review of the ‘874 Patent.
`
`
`
`
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`14
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`Case IPR2016-00135
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`United States Patent No. 7,245,874
`
`
`May 27, 2016
` 
`
`
`/Eliot Williams/
`Eliot Williams (Reg. No. 50,822)
`G. Hopkins Guy III (Reg. No. 35,866)
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`Phone: (650) 739-7510
` 
`ATTORNEYS FOR PETITIONER
`
` 
`
`15
`
`

`
`CERTIFICATE OF SERVICE ON PATENT OWNER UNDER
`37 C.F.R. § 42.205
`
`Pursuant to 37 C.F.R. § 42.205, the undersigned certifies that on the 27th
`
` 
`
`  
`
`day of May 2016, a complete and entire copy of this Request for Rehearing Under
`
`37 C.F.R. § 42.71(d), were provided via email on the following counsel of record
`
`for Patent Owner:
`
`Andrea G. Reister
`areister@cov.com
`Jay I. Alexander
`jalexander@cov.com
`Christopher K. Eppich (Reg. No. 52,868)
`ceppich@cov.com
`Covington & Burling LLP
`One CityCenter, 850 Tenth Street, NW
`Washington, DC 2001
`Phone: (202) 662-5141
`
`
`Respectfully submitted,
`BAKER BOTTS L.L.P.
`
`
`/Eliot Williams/
`Eliot Williams (Reg. No. 50,822)
`G. Hopkins Guy III (Reg. No. 35,866)
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`Phone: (650) 739-7510
` 
`ATTORNEYS FOR PETITIONER
`
` 
`
`   
`
` 

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