IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________
`
`WTS Paradigm, LLC,
`
`Petitioner,
`
`v.
`
`EdgeAQ, LLC,
`
`Patent Owner.
`___________________________
`
`Case IPR2016-00199
`Patent 7,805,461
`___________________________
`
`EDGEAQ, LLC’S PRELIMINARY RESPONSE TO PETITION
`
`
`Filed on behalf of EdgeAQ, LLC
`
`By:
`
`
`
`
`W. Edward Ramage (Lead Counsel)
`Reg. No. 50,810
`BAKER, DONELSON, BEARMAN,
`CALDWELL & BERKOWITZ, P.C.
`Baker Donelson Center
`211 Commerce Street, Suite 800
`Nashville, Tennessee 37201
`Telephone: (615) 726-5771
`Facsimile: (615) 744-5771
`Email: eramage@bakerdonelson.com
`
`
`Samuel F. Miller (Back-up Counsel)
`(pending pro hac vice admission)
`BAKER, DONELSON, BEARMAN,
`CALDWELL & BERKOWITZ, P.C.
`Baker Donelson Center
`211 Commerce Street, Suite 800
`Nashville, Tennessee 37201
`Telephone: (615) 726-5594
`Facsimile: (615) 744-5594
`Email: smiller@bakerdonelson.com
`
`
`
`
`
`

`
`TABLE OF CONTENTS
`
`
`
`I. INTRODUCTION ................................................................................................ 1
`
`II. APPLICABLE LEGAL STANDARDS ............................................................ 2
`
`A.
`
`Institution of Inter Partes Review.......................................................... 2
`
`B. Obviousness under § 103(a). ................................................................. 3
`
`III. CLAIM CONSTRUCTION ............................................................................. 5
`
`IV. ARGUMENT ..................................................................................................... 6
`
`A.
`
`Petitioner Fails to Demonstrate a Reasonable Likelihood of
`Prevailing. .............................................................................................. 6
`
`1.
`
`2.
`
`The Petition Fails to Establish A Reasonable Likelihood
`That Claims 1-11 Of The ‘461 Patent Would Have Been
`Obvious Based on Greef, Bader and Weida. .............................. 6
`
`The Petition Fails to Establish A Reasonable Likelihood
`That Claims 1-11 Of The ‘461 Patent Would Have Been
`Obvious Based on Greef, Bader, Weida and Altman. .............. 12
`
`V. CONCLUSION .................................................................................................. 14
`
`
`
`
`
`
`
`
`ii
`
`

`
`
`CASES
`
`TABLE OF AUTHORITIES
`
`Page(s)
`
`CCS Fitness, Inc. v. Brunswick Corp.,
`288 F.3d 1359 (Fed. Cir. 2002) .........................................................................................3
`
`Graham v. John Deere Co.,
`383 U.S. 1 (1966) ..................................................................................................................3
`
`In re Kahn,
`441 F.3d 977 (Fed. Cir. 2006)............................................................................................4
`
`Inline Connection Corp. v. Earthlink, Inc.,
`684 F. Supp. 2d 496 (D. Del. 2010) .................................................................................4
`
`KSR Int’l Co. v. Teleflex Inc.,
`550 U.S. 398 (2007) .........................................................................................................3, 4
`
`Ortho-McNeil Pharm., Inc. v. Mylan Labs., Inc.,
`520 F.3d 1358 (Fed. Cir. 2008) .........................................................................................4
`
`Oxford Gene Tech., Ltd. v. Mergen Ltd.,
`345 F. Supp. 2d 431 (D. Del. 2004) .................................................................................3
`
`Perfect Web Techs., Inc. v. InfoUSA, Inc.,
`587 F.3d 1324 (Fed. Cir. 2009) .........................................................................................4
`
`Unigene Labs., Inc. v. Apotex, Inc.,
`655 F.3d 1352 (Fed. Cir. 2011) .........................................................................................4
`
`STATUTES
`
`35 U.S.C. § 103(a) ......................................................................................................................3
`
`35 U.S.C. § 313 ...........................................................................................................................1
`
`35 U.S.C. § 314(a) ..................................................................................................................2, 6
`
`OTHER AUTHORITIES
`
`37 C.F.R. § 42.100(b) ................................................................................................................2
`
`
`
`iii
`
`

`
`37 C.F.R. § 42.107 ......................................................................................................................1
`37 C.F.R. § 42.107 .................................................................................................................... ..1
`
`77 Fed. Reg. 48756, 48766 (Aug. 14, 2012) ........................................................................2
`77 Fed. Reg. 48756, 48766 (Aug. 14, 2012) ...................................................................... ..2
`
`U.S. Patent No. 7,805,461............................................................................................... passim
`U.S. Patent NO. 7,805,461 ............................................................................................. .. passim
`
`
`
`iv
`iv
`
`

`
`Patent Owner, EdgeAQ, LLC (the “Patent Owner”), pursuant to 35 U.S.C. §
`
`313 and 37 C.F.R. § 42.107, submits its Preliminary Response to WTS Paradigm,
`
`LLC’s (the “Petitioner”) Petition for Inter Partes Review of U.S. Patent No.
`
`7,805,461 (“the ‘461 Patent”).
`
`I. INTRODUCTION
`
`
`
`This Petition is the third of three post-grant proceedings filed by Petitioner
`
`against a set of patents owned by Patent Owner. CBM2015-0064; CBM2015-
`
`00055. The ‘461 Patent has been involved in pending litigation proceedings before
`
`the United States District Court for the Western District of Wisconsin, WTS
`
`Paradigm, LLC v. EdgeAQ, LLC, Case No. 15-CV-330. However, in that case,
`
`Patent Owner has moved to dismiss its claim of infringement based on the ‘461
`
`Patent. That motion is still pending.
`
`
`
`In this Petition, Petitioner asserts that claims 1-11 (which comprise all of the
`
`claims in the ‘461 Patent) should be invalidated on the basis of obviousness.
`
`Patent Owner intends to vigorously contest the Petition if the Board initiates Inter
`
`Partes Review. However, for purposes of its preliminary response, Patent Owner
`
`submits that the Petitioner has so clearly failed to carry its burden under the
`
`“reasonable likelihood” standard that the Board should not initiate Inter Partes
`
`Review. As demonstrated below, none of the prior art cited by Petitioner discloses
`
`an
`
`induction module configured
`
`to present pre-defined questions about
`
`

`
`specification data to a user to identify a set of SQL queries to be answered to
`
`construct a frame-based knowledge tree. This claim limitation is present in some
`
`form in all claims of the ‘461 Patent, and its absence in the prior art compels the
`
`rejection of the Petition.
`
`
`
`II. APPLICABLE LEGAL STANDARDS
`
`A.
`
`Institution of Inter Partes Review.
`
`
`
`In instituting an Inter Partes Review, the petitioner must show that there is a
`
`“reasonable likelihood that the petitioner would prevail with respect to at least 1 of
`
`the claims challenged in the petition.” 35 U.S.C. § 314(a). In conducting its
`
`review, the standard by which the Board should interpret the claims is not settled.
`
`According to the Office Patent Trial Practice Guide, the Board should interpret
`
`claims using the “broadest reasonable interpretation” as understood by one of
`
`ordinary skill in the art and consistent with the disclosure. Office Patent Trial
`
`Practice Guide, 77 Fed. Reg. 48756, 48766 (Aug. 14, 2012); 37 C.F.R. §
`
`42.100(b). However, the U.S. Supreme Court recently granted certiorari in Cuozzo
`
`Speed Tech. v. Lee on the issue of whether the Board in an IPR proceeding should
`
`construe claims according to their plain or ordinary meaning or their broadest
`
`reasonable interpretation.
`
`
`
`2
`
`

`
`
`
`For purposes of determining whether to institute Inter Partes Review in this
`
`matter, however, the Petition should be rejected under any standard for claim
`
`interpretation. There is a heavy presumption that a claim term carries its ordinary
`
`and customary meaning. CCS Fitness, Inc. v. Brunswick Corp., 288 F.3d 1359,
`
`1366 (Fed. Cir. 2002).
`
`B. Obviousness under § 103(a).
`
`
`
`A patent is invalid under Section 103(a) if the “differences between the
`
`subject matter sought to be patented and the prior art are such that the subject
`
`matter as a whole would have been obvious at the time the invention was made to a
`
`person having ordinary skill in the art.” 35 U.S.C. § 103(a). An obviousness
`
`inquiry requires considering the following four Graham factors: (1) the scope and
`
`content of the prior art; (2) the differences between the prior art and the claimed
`
`invention; (3) the level of ordinary skill in the art; and (4) objective evidence of
`
`nonobviousness. Graham v. John Deere Co., 383 U.S. 1, 17 (1966). See also,
`
`KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 406-07 (2007) (stating that the four
`
`Graham factors continue to define the controlling inquiry). The relevant inquiry is
`
`whether the petition has set forth “some articulated reasoning with some rational
`
`underpinning to support the legal conclusion of obviousness.” KSR Int’l Co., 550
`
`U.S. at 418.
`
`
`
`3
`
`

`
`
`
`Determining the differences between the prior art and the claimed invention
`
`requires an element-by-element comparison of the claim elements with regard to
`
`the prior art. See, e.g., Oxford Gene Tech., Ltd. v. Mergen Ltd., 345 F. Supp. 2d
`
`431, 437 (D. Del. 2004); Inline Connection Corp. v. Earthlink, Inc., 684 F. Supp.
`
`2d 496, 523 (D. Del. 2010).
`
`
`
`The obviousness analysis also must present evidence of a motivation to
`
`combine or modify the prior art to arrive at the invention as claimed. See Unigene
`
`Labs., Inc. v. Apotex, Inc., 655 F.3d 1352, 1360 (Fed. Cir. 2011); Ortho-McNeil
`
`Pharm., Inc. v. Mylan Labs., Inc., 520 F.3d 1358, 1364-65 (Fed. Cir. 2008); In re
`
`Kahn, 441 F.3d 977, 986-88 (Fed. Cir. 2006). There must be “some rationale,
`
`articulation, or reasoned basis to explain why the conclusion of obviousness is
`
`correct.” In re Kahn, 441 F.3d at 986-88. The requirement “remains the primary
`
`guarantor against a non-statutory hindsight analysis.” Ortho-McNeil, 520 F.3d at
`
`1364-65. It is well-established that rejections on obviousness grounds cannot be
`
`sustained by “mere conclusory statements.” KSR Int’l Co., 550 U.S. at 418; see
`
`also, Perfect Web Techs., Inc. v. InfoUSA, Inc., 587 F.3d 1324, 1330 (Fed. Cir.
`
`2009); M.P.E.P. §§ 2141, 2142, 2143.
`
`
`
`
`
`4
`
`

`
`III. CLAIM CONSTRUCTION
`
`Petitioner has proposed claim interpretations for only a single term: “frame.”
`
`However, this term as an independent term does not exist in the claims, and should
`
`not be interpreted as such. Accordingly, the Petitioner’s proposed interpretation is
`
`not made in the context of the claims, and should be rejected.
`
`The claims do contain the limitation “frame-based knowledge tree.” Ex.
`
`1004, claims 1, 6. This limitation is clearly explained in the specification:
`
`Such GUI tools allow the user (typically, a knowledge
`
`engineer) to model the product knowledge in a tree like structure
`
`where each node of the tree is known as a frame. The attributes that
`
`describe and specialize the frame are represented using slots. The
`
`node at each level in a tree inherits properties from its parent node(s)
`
`and allows the user to override, extend or specialize these properties at
`
`the current level. The level in a tree at which certain attributes are
`
`placed depends on the generality of those attributes. For example,
`
`attributes that are common to a number of configurable items are
`
`placed closer to the top of the tree. Attributes that specialize a
`
`configurable item are placed at the lower levels of the tree. This
`
`process of creating a frame based knowledge tree is called the product
`
`
`
`5
`
`

`
`knowledge design process and is implemented by knowledge
`
`engineers.
`
`Ex. 1001, col. 1: 37-52.
`
`
`
`Patent Owner submits that no particular claim construction is necessary.
`
`However, should the Board desire to construe the phrase “frame-based knowledge
`
`tree,” Patent Owner proposes that the phrase should be construed in accordance
`
`with the description in the specification to mean “a model of knowledge in a tree-
`
`like structure where each node of the tree is known as a frame.”
`
`
`
`A.
`
`IV. ARGUMENT
`
`Petitioner Fails to Demonstrate a Reasonable Likelihood of Prevailing.
`
`To have the Board institute an Inter Partes Review, a petitioner must show
`
`that there is a “reasonable likelihood that the petitioner would prevail with respect
`
`to at least 1 of the claims challenged in the petition.” 35 U.S.C. § 314(a). The
`
`Petitioner has failed to meet this standard with regard to its assertions on
`
`obviousness grounds.
`
`1.
`
`The Petition Fails to Establish A Reasonable Likelihood That
`Claims 1-11 Of The ‘461 Patent Would Have Been Obvious Based
`on Greef, Bader and Weida.
`
`
`
`The Petition asserts that claims 1-11 are invalid for obviousness based on
`
`Greef (Ex. 1005) in view of Bader (Ex. 1011) and Weida (Ex. 1009). The Petition
`
`
`
`6
`
`

`
`fails to make a prima facie case of obviousness. Greef, Bader and Weida fail,
`
`either separately or together, to disclose or teach several of the elements in claims
`
`1-11.
`
`
`
`Claim 1 of the ‘461 Patent is directed to a system comprising an induction
`
`module and a processor, where the induction module is configured to:
`
`
`
`(a) access specification data for at least one product from one or more
`
`vendor databases;
`
`
`
`(b) identify attributes of the specification data to be inducted into a frame-
`
`based knowledge tree by querying the one or more vendor databases table for the
`
`specification data regarding the attributes;
`
`
`
`(c) determine a location within the frame-based knowledge tree to place any
`
`inducted attributes of the specification data; and
`
`
`
`(d) present pre-defined questions about the specification data to a user to
`
`identify a set of SQL queries to be answered to construct the frame-based
`
`knowledge tree.
`
`The processor is dimensioned and configured to enable user interaction with the
`
`induction module such that a frame-based knowledge tree is automatically
`
`constructed with the specification data in response to the user interaction, wherein
`
`the interaction comprises receiving input answers from the user in response to the
`
`pre-defined questions about the specification data provided to the user.
`
`
`
`7
`
`

`
`Ex. 1004, claim 1.
`
`
`
`Similarly, claim 6 of the ‘461 Patent contains four method steps for
`
`automatically constructing a frame-based knowledge tree:
`
`
`
`(a) identifying a plurality of attributes within a vendor database to be
`
`inducted into a frame-based knowledge tree by querying at least one vendor-
`
`supplied product knowledge database table for data regarding the attributes;
`
`
`
`(b) presenting pre-defined questions about the data to a user to identify a set
`
`of SQL queries to be answered to construct the frame-based knowledge tree;
`
`
`
`(c) automatically determining respective locations of the plurality of
`
`attributes within the frame-based knowledge tree based upon input answers
`
`received from a user regarding the data, wherein the input answers are provided in
`
`response to the pre-defined questions about the data provided to the user; and
`
`
`
`(d) inserting at least one of the attributes into the frame-based knowledge
`
`tree based on the determined respective locations, whereby the frame-based
`
`knowledge tree is constructed.
`
`Ex. 1004, claim 1.
`
`
`
`Both independent claims 1 and 6 contain the elements of presenting pre-
`
`defined questions about the specification data to a user to identify a set of SQL
`
`queries to be answered to construct the frame-based knowledge tree. Questions
`
`are pre-defined, for example, based upon a particular industry. Id. col. 9: 9-11.
`
`
`
`8
`
`

`
`The input answers provided by the user in response are used to identify the set of
`
`SQL queries that need to be run to organize the data from the vendor’s database
`
`tables into an automatically constructed knowledge tree. Id. col. 9: 43-52.
`
`
`
`Greef (Ex. 1005) does not disclose these elements. Petitioner cites Greef at
`
`col. 29: 39-50, which describes prompting the user to identify the tabular data to be
`
`incorporated into the frame-based hierarchical form. Petition at 35-36. It is clear,
`
`however, that this is merely prompting the user to identify the source of the tabular
`
`data of the table in a conventional fashion, i.e., “by designating a file name and
`
`path for locating the file.” Ex. 1005, col. 29: 48-52. This is not presenting pre-
`
`defined questions about the data to a user to identify a set of SQL queries to be
`
`answered to construct the frame-based knowledge tree, which occurs after the
`
`vendor database table has already been identified and accessed.
`
`
`
`The other sections of Greef cited by Petitioner do no better. One section
`
`describes the method itself identifying category subcategory information, id. col.
`
`30: 33-42, while the other section describes the method at a step enabling the user
`
`to identify a tabular product attribute to act as a general identifier for products, id.
`
`col. 18: 42-46. There is no disclosure here of presenting pre-defined questions
`
`about the specification data to a user to identify a set of SQL queries to be
`
`answered. Further, Figure 17 of Greef simply shows an example of a vendor
`
`product table (i.e., a source of data), while Figure 20 merely shows the “Get Data”
`
`
`
`9
`
`

`
`file name and path location designation as the initial step in the Greef
`
`methodology. As discussed above, this does not disclose the claim limitation in
`
`issue.
`
`
`
`Weida and Bader do not fill the gap with regard to this missing element from
`
`Greef. Bader, for example, describes a process for converting from a relational
`
`database to a hierarchical database with user selection of keywords from the
`
`relational database. Ex. 1011, col. 11:53 through col. 12: 31. This discussion is in
`
`the context of explaining Figures 13a-d, which show nothing to indicate that pre-
`
`defined questions about specification data are being presented to a user to identify
`
`a set of SQL queries to be answered.
`
`
`
`Petitioner does not cite any section of Weida (Ex. 1009) in its Petition as
`
`disclosing these elements. Thus, the proposed combination of Greef, Bader and
`
`Weida does not teach or suggest all of the elements of claims 1-11, and the Petition
`
`should be denied.
`
`
`
`The Petition improperly contains substantive argument based on Carter (Ex.
`
`1010), Petition at 36-37, which is not identified as part of any of the proposed
`
`rejections. Petitioner asserts that Carter is incorporated by reference in Weida, but
`
`no relevant portion of Carter is reproduced or set forth in Weida. Even if
`
`Petitioner had properly proposed Carter on its own merits as part of a proposed
`
`rejection, however, it would not help. Carter discloses a method for modification
`
`
`
`10
`
`

`
`of the contents of a multiple inheritance concept hierarchy database (i.e., the
`
`database is already in a hierarchy with nodes). It allows a user to move nodes in
`
`the hierarchy using a drag-and-drop operation interface. Ex. 1010, Figs. 26-27.
`
`Carter thus addresses modification of an existing hierarchical database, not the
`
`creation of one. There is nothing to indicate that pre-defined questions about
`
`specification data (from a data table) are being presented to a user to identify a set
`
`of SQL queries to be answered to construct a frame-based knowledge tree.
`
`
`
`This section of the Petition also improperly contains a citation to Altman
`
`(Ex. 1012), Petition at 38, which is not included in the first proposed combination
`
`of prior art. However, as Altman is included in the second proposed rejection,
`
`Patent Owner will address the cited section to demonstrate that the addition of
`
`Altman does not fill the gaps left by Greef, Bader and Weida. Altman simply
`
`discloses that a user sends standard knowledge base queries across a distributed
`
`computer system, and the system translates the queries into a language suitable for
`
`querying the database, such as Structured Query Language (SQL). Ex. 1012,
`
`Abstract, col. 5: 65 through 6: 8. Altman does not disclose presenting pre-defined
`
`questions about specification data to a user; instead, the user is forming and
`
`sending the queries, not responding to them. Further, in Altman the user’s queries
`
`are translated directly into SQL. In contrast, in claims 1-11 of the patent-in-issue,
`
`
`
`11
`
`

`
`the responses of the user to the pre-defined questions are used to identify a set of
`
`SQL queries to be answered to construct a frame-based knowledge tree.
`
`
`
`With regard to independent claim 6, the Petition simply references the above
`
`citations with regard to claim 1. See Petition at 50. The cited prior art thus fails to
`
`disclose, teach or suggest all of the elements of independent claims 1 and 6, and
`
`the proposed obviousness rejection must fail. This failure applies to all of the
`
`dependent claims.
`
`
`
`The first proposed combination thus does not disclose, teach or suggest all of
`
`the elements of claims 1-11, and the Petition has failed to make a prima facie case
`
`of obviousness. Accordingly, the Board should deny the Petition’s proposed
`
`ground of obviousness of claims 1-11 based on Greef, Bader and Weida.
`
`2.
`
`The Petition Fails to Establish A Reasonable Likelihood That
`Claims 1-11 Of The ‘461 Patent Would Have Been Obvious Based
`on Greef, Bader, Weida and Altman.
`
`
`
`The Petition asserts that claims 1-11 are invalid for obviousness based on
`
`Greef (Ex. 1005) in view of Bader (Ex. 1011) and Weida (Ex. 1009) and Altman
`
`(Ex. 1012). The Petition fails to make a prima facie case of obviousness. As
`
`discussed above, Greef, Bader, Weida and Altman fail, either separately or
`
`together, to disclose or teach several of the elements in claims 1-11.
`
`
`
`The Petition merely references the discussion of the claim elements from the
`
`first proposed rejection based on Greef, Bader and Weida. Petition at 59-60.
`
`
`
`12
`
`

`
`Further, as discussed above, the Petition improperly included Altman in its
`
`argument regarding the first proposed rejection. Petition at 38. Patent Owner
`
`incorporates its arguments above with regard to Greef, Bader, Weida and Altman.
`
`
`
`The deficiencies of Greef, Bader and Weida have been demonstrated above.
`
`Altman is similarly deficient. Altman simply discloses that a user sends standard
`
`knowledge base queries across a distributed computer system, and the system
`
`translates the queries into a language suitable for querying the database, such as
`
`Structured Query Language (SQL). Ex. 1012, Abstract, col. 5: 65 through 6: 8.
`
`Altman does not disclose presenting pre-defined questions about specification data
`
`to a user; instead, the user is forming and sending the queries, not responding to
`
`them. Further, in Altman the user’s queries are translated directly into SQL. In
`
`contrast, in claims 1-11 of the patent-in-issue, the responses of the user to the pre-
`
`defined questions are used to identify a set of SQL queries to be answered to
`
`construct a frame-based knowledge tree.
`
`
`
`The second proposed combination thus does not disclose, teach or suggest
`
`all of the elements of claims 1-11, and the Petition has failed to make a prima facie
`
`case of obviousness. Accordingly, the Board should deny the Petition’s proposed
`
`ground of obviousness of claims 1-11 based on Greef, Bader, Weida and Altman.
`
`
`
`
`
`13
`
`

`
`
`
`For the reasons above, Patent Owner requests that the Board deny in its
`
`V. CONCLUSION
`
`entirety the Petition for Inter Partes Review of the ‘461 Patent.
`
`
`
`
`
`
`
`14
`
`

`
`
`
`Respectfully submitted,
`
`BAKER, DONELSON, BEARMAN,
`CALDWELL & BERKOWITZ, P.C.
`
`
`
`/W. Edward Ramage/
`W. Edward Ramage, Reg. No. 50,810
`Baker Donelson Center
`211 Commerce Street, Suite 800
`Nashville, Tennessee 37201
`Tel: (615) 726-5771
`Fax: (615) 744-5771
`Email: eramage@bakerdonelson.com
`
`Samuel F. Miller (pending pro hac
`vice)
`Baker Donelson Center
`211 Commerce Street, Suite 800
`Nashville, Tennessee 37201
`Tel: (615) 726-5594
`Fax: (615) 744-5594
`Email: smiller@bakerdonelson.com
`
`Counsel for Patent Owner EdgeAQ,
`LLC
`
`
`
`
`
`Dated: February 17, 2016
`
`
`
`
`
`
`
`15
`
`
`
`
`
`

`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that, on February 17, 2016, the foregoing
`
`Preliminary Response to Petition was served in its entirety via U.S. Express Mail,
`
`postage prepaid, and electronic mail upon the following:
`
`
`
`Michael Jaskolski
`Quarles & Brady LLP
`411 East Wisconsin Ave. Suite 2400
`Milwaukee, WI 53202
`Tel: (703) 412-6297
`Email: michael.jaskolski@quarles.com
`
`Louis A. Klapp
`Quarles & Brady LLP
`300 North LaSalle Street, Suite 4000
`Chicago, IL 60654
`Tel: (703) 412-6297
`Email: louis.klapp@quarles.com
`
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`/W. Edward Ramage/
`W. Edward Ramage, Reg. No. 50,810
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