UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MICROSOFT CORPORATION,
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`Petitioner,
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`v.
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`BRADIUM TECHNOLOGIES LLC,
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`Patent Owner.
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`Case IPR2016-00449
`Patent No. 8,924,506 B2
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`PETITIONER’S RESPONSE TO PATENT OWNER’S
`MOTION FOR OBSERVATIONS ON CROSS EXAMINATION
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`Paper No. 45
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
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`MICROSOFT CORPORATION,
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`Petitioner,
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`v.
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`BRADIUM TECHNOLOGIES LLC,
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`Patent Owner.
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`
`
`
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`
`
`
`
`
`
`Case IPR2016-00449
`Patent No. 8,924,506 B2
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`
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`PETITIONER’S RESPONSE TO PATENT OWNER’S
`MOTION FOR OBSERVATIONS ON CROSS EXAMINATION
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`Paper No. 45
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`PTAB Case IPR2016-00449, Patent 8,924,506 B2
`Petitioner’s Response to Patent Owner's Motion for Observation
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`Petitioner Microsoft timely files this response to Patent Owner’s Motion for
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`Observations on Cross-Examination of Dr. William Michalson (Paper 41). Patent
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`Owner’s Observation Nos. 3-4, 7-8, 11-13, and 20-28 are beyond the permissible
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`scope of Motions for Observations because these Observations do not identify any
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`relevance to Dr. Michalson’s Reply Declaration (Ex. 1016). See 37 C.F.R.
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`42.53(d)(5)(ii) (cross-examination limited to scope of direct testimony); Office
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`Patent Trial Practice Guide, 77 Fed. Reg. 48768 (Aug. 14, 2012) (“[a]n observation
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`(or response) is not an opportunity to raise new issues, re-argue issues, or pursue
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`objections”). Further responses are contained below.
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`RESPONSE TO OBSERVATION 1
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`I.
`PO’s Observation No.1 is misleading and incomplete. The cited document
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`(Ex. 1030) itself states on its face that it was published June 1999 and revised
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`February 2000, which is consistent with Dr. Michalson’s testimony that
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`TerraServer was “introduced in June 1998 and later described in a Microsoft
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`technical report in 1999.” Dr. Michalson further testified that he was “personally
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`familiar” with the TerraServer system in the late 1990s, and that Ex. 1030 is
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`consistent with his personal recollection of the introduction date and operation of
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`the TerraServer system in the late 1990s. Ex. 2078 at 76:11-78:5. Dr. Michalson
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`further testified that Ex. 1030 states that TerraServer was operational for 18
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`months prior to Ex. 1030, which is consistent with his personal recollection. Ex.
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`1
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`PTAB Case IPR2016-00449, Patent 8,924,506 B2
`Petitioner’s Response to Patent Owner's Motion for Observation
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`2078 at 77:14-78:5, citing Ex. 1030 at 5. PO’s Observation No. 1 is also irrelevant
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`to PO’s stated purpose that “it shows Dr. Michalson and Petitioner’s argument is
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`based on a non-prior-art reference” because the earliest claimed priority date of the
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`‘343 Patent (December 27, 2000) is after all dates listed on Ex. 1030, and Dr.
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`Michalson opined on Ex. 1030 only to rebut Bradium’s arguments about the state
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`of the art prior to the alleged inventions in general, but Ex. 1030 is not part of the
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`instituted grounds of obviousness at issue in this IPR.1 Ex. 1016, ¶¶ 74-75, 93.
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`RESPONSE TO OBSERVATION 2
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`II.
`PO’s Observation No. 2 is misleading, incomplete, and irrelevant for
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`substantially the same reasons discussed regarding PO’s Observation No. 1.
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`RESPONSE TO OBSERVATION 3
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`III.
`PO’s Observation No. 3 is irrelevant for the cited purpose because the cited
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`portion of Exhibit 1030 does not refer to VRML.
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`RESPONSE TO OBSERVATION 4
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`IV.
`PO’s Observation No. 4 is misleading and incomplete. Bradium’s citation to
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`15
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`Ex. 2078 omits a portion of Dr. Michalson’s response, which further states that
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`“the last sentence where it discusses military planning, battle damage assessment,
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`emergency relief efforts is implicitly discussing situations where you would not
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`expect to have high bandwidth communications available.” Ex. 2078 at 13:3-9.
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`1 TerraServer, discussed in Ex. 1030, should not be confused with TerraVision,
`discussed in Ex. 1004.
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`2
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`PTAB Case IPR2016-00449, Patent 8,924,506 B2
`Petitioner’s Response to Patent Owner's Motion for Observation
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`Dr. Michalson further testified at length in his opening and reply declarations and
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`his deposition why limited bandwidth communications channels would be obvious
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`to a POSITA in view of teachings of Reddy. See generally Ex. 1005 ¶¶ 131-33;
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`Ex. 1016 ¶¶ 43-45; Ex. 2078 at 13:10-15:7.
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`RESPONSE TO OBSERVATION 5
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`V.
`PO’s Observation No. 5 is misleading and incomplete. Dr. Michalson
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`further testified in Ex. 1016 that “teachings in Reddy are not dependent on specific
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`software” and that “adding the same features found in TerraVision to a VRML
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`browser … would be well within the ability of a person of ordinary skill in the art,
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`using known methods with predictable results.” Ex. 1016, ¶ 55.
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`RESPONSE TO OBSERVATION 6
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`VI.
`PO’s Observation No. 6 is misleading and incomplete for the same reasons
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`discussed in regard to PO’s Observation No. 5. Additionally, Dr. Michalson
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`further testified in Ex. 1016, ¶¶ 52-54 that PC software “could be easily ‘ported’ to
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`a mobile computing device using techniques that would have been well-known to a
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`person of ordinary skill in the art.” Dr. Michalson further testified that Ex. 2066
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`shows that TerraVision was “portable” to platforms such as Windows NT” (Id.,
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`¶ 54; Ex. 2066 at 2), that “there was also NT embedded that was targeted at
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`personal digital assistants,” that “Windows NT existed in a variety of forms”
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`including PCs, handheld portable devices, and laptop computers, that “I personally
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`PTAB Case IPR2016-00449, Patent 8,924,506 B2
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`have installed Windows NT on laptop computers of the day in the mid-1990s,” and
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`that Windows NT “basically would run on pretty much any PC-compatible
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`platform” including “embedded versions,” “handheld devices,” “lower
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`performance laptops and portable devices.” Ex. 2078 at 35:24-36:8, 38:1-40:10.
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`5
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`Accordingly, the cited testimony does not “support[] Patent Owner’s argument that
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`the laptop disclosed by Reddy views VRML data with a standard VRML browser
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`and not with TerraVision II.”
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`RESPONSE TO OBSERVATION 7
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`VII.
`PO’s Observation No. 7 is incomplete for the reasons discussed above in
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`regard to PO’s Observation Nos. 5 and 6.
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`RESPONSE TO OBSERVATION 8
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`VIII.
`PO’s Observation No. 8 is misleading and incomplete because it omits the
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`testimony discussed above in regard to PO’s Observation No. 5.
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`RESPONSE TO OBSERVATION 9
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`IX.
`PO’s Observation No. 9 is misleading and incomplete because it ignores Dr.
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`Michalson’s testimony in Ex. 1016, ¶ 56 that “Ex. 2066 makes it clear that it is
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`‘feasible’ that some of the features identified as additions to TerraVision compared
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`to a ‘standard browser’ (many of which are unrelated to the claims) ‘be
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`implemented for a standard VRML browser through the use of various Java scripts
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`embedded in the scene, or running externally to the browser.’” PO’s Observation
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`PTAB Case IPR2016-00449, Patent 8,924,506 B2
`Petitioner’s Response to Patent Owner's Motion for Observation
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`No. 9 is further incomplete and irrelevant for the stated purpose because it omits
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`the testimony discussed above in regard to PO’s Observation No. 5.
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`RESPONSE TO OBSERVATION 10
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`X.
`PO’s Observation No. 10 mischaracterizes the cited testimony, in which Dr.
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`5
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`Michalson states that certain capabilities “may well be in a standard VRML
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`browser, but those capabilities would be at a lower level of performance.” Ex.
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`2078 at 30:2-20. The cited testimony is also incomplete, in addition to the reasons
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`discussed above in regard to PO’s Observation No. 5, because Dr. Michalson
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`further testified that “If performance is a lower performance level, then that’s
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`lower relative to some higher-performance system. That doesn’t necessarily mean
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`that it’s unacceptable levels of performance relative to the patents at issue because
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`there is no performance requirement in those patents.” Ex. 2078 at 78:13-79:24.
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`RESPONSE TO OBSERVATION 11
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`XI.
`PO’s Observation No. 11 is irrelevant and improper under the Board’s rules
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`because the “testimony” quoted in the observation merely consists of an exhibit
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`excerpt (read by PO’s counsel, not Dr. Michalson- see Ex. 2078 at 31:15-33:17)
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`that PO chose not to discuss when it originally introduced Ex. 2066 with its PO
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`Response, and is therefore an attempt to introduce new issues or re-argue issues.
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`This observation also mischaracterizes the cited testimony. Dr. Michalson testified
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`at Ex. 2078, 33:7-17 that “[t]he portion I cite of Exhibit 2066 is that second
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`PTAB Case IPR2016-00449, Patent 8,924,506 B2
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`sentence under ‘Cross-Platform Capability,’ which reads, ‘[h]owever, we have
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`engineered TerraVision to be easily portable to other platforms, and we have
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`recently performed a port to Microsoft’s Windows NT platform.’ So what that
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`says is that TerraVision has been ported to not only SGI platforms, which they
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`reference previously, but also to Windows NT platforms.” Therefore, the cited
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`testimony is also irrelevant to the cited purpose because the full two-sentence
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`excerpt cited by Dr. Michalson on page 2 of Ex. 2066 does not “support[] Patent
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`Owner’s argument that the ‘PC connected to the internet’ of Reddy is not a limited
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`bandwidth communications device.”
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`RESPONSE TO OBSERVATION 12
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`XII.
`PO’s Observation No. 12 is irrelevant for its stated purpose because it has
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`nothing to do with whether the broader teachings of Reddy or the specific
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`TerraVision II system are operable on a laptop. This Observation is further
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`incomplete without the further testimony of Dr. Michalson discussed in regard to
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`PO’s Observation No. 6.
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`RESPONSE TO OBSERVATION 13
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`XIII.
`PO’s Observation No. 13 is irrelevant for its stated purpose because Dr.
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`Michalson’s cited testimony that a POSITA may “design a piece of software on a
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`particular platform with the expectation that it will run on other platforms,” and
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`that “Windows NT and SGI graphics work stations” were examples of compatible
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`PTAB Case IPR2016-00449, Patent 8,924,506 B2
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`platforms, does not “show[] the distinction between TerraVision II and a standard
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`VRML browser…” as argued by Bradium. In regard to Bradium’s “distinction,”
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`Dr. Michalson further testified that a POSITA would recognize that Reddy’s
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`teachings designed to be broadly applicable to “enable a wide variety of users to
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`access geographic data over the Internet using standard browsing techniques and
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`standard browser software that can be implemented on a wide variety of devices
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`including small clients” (Ex. 1005, ¶¶ 124, 131, 135; Ex. 1016, ¶ 34), that a
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`POSITA would “read Reddy as a whole for all that it teaches or suggests, and not
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`simply for specific embodiments (Ex. 1016, ¶ 38), and that a POSITA would
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`recognize that the features taught by TerraVision could be implemented on other
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`browsers (Id., ¶ 39).
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`RESPONSE TO OBSERVATION 14
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`XIV.
`PO’s Observation No. 14 is irrelevant for the cited purpose because the
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`infringement contentions cited by Dr. Michalson in Ex. 1016, ¶ 30, including the
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`statement in Ex. 1026 accusing “all versions of the Bing Maps Preview App.,
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`operating, for example, as a Microsoft Windows application” of infringing claims
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`reciting a “limited communication bandwidth computer device,” do not state that
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`they are limited to the allegations made in the pleadings or complaint, and
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`therefore do not “show the lack of basis for Petitioner’s claim, based on Dr.
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`PTAB Case IPR2016-00449, Patent 8,924,506 B2
`Petitioner’s Response to Patent Owner's Motion for Observation
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`Michalson’s claim, that Bradium’s position in that litigation contradicts its position
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`in this IPR.”
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`RESPONSE TO OBSERVATION 15
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`XV.
`PO’s Observation No. 15 is irrelevant for the cited purpose because Bradium
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`identifies no evidence or other reason that any “discovery or depositions in the
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`Bradium v. Microsoft litigation” renders Dr. Michalson’s quotation and
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`consideration of Bradium’s own infringement contentions misleading or
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`incomplete.
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`RESPONSE TO OBSERVATION 16
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`XVI.
`PO’s Observation No. 16 is irrelevant for the cited purpose because Bradium
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`identifies no evidence or other reason that any claim construction in the Bradium v.
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`Microsoft litigation renders Dr. Michalson’s quotation and consideration of
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`Bradium’s own infringement contentions misleading or incomplete.
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`RESPONSE TO OBSERVATION 17
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`XVII.
`PO’s Observation No. 17 is irrelevant for the cited purpose because Bradium
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`identifies no evidence or other reason that any “relevant local rules of the Court
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`with respect to contentions in the Bradium v. Microsoft litigation” renders Dr.
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`Michalson’s quotation and consideration of Bradium’s own infringement
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`contentions misleading or incomplete.
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`PTAB Case IPR2016-00449, Patent 8,924,506 B2
`Petitioner’s Response to Patent Owner's Motion for Observation
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`RESPONSE TO OBSERVATION 18
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`XVIII.
`PO’s Observation No. 18 is irrelevant for the cited purpose because Bradium
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`identifies no evidence or other reason that Bradium’s First Amended Complaint in
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`the Bradium v. Microsoft renders Dr. Michalson’s quotation and consideration of
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`Bradium’s own infringement contentions misleading or incomplete.
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`RESPONSE TO OBSERVATION 19
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`XIX.
`PO’s Observation No. 19 is irrelevant for the cited purpose because Ex.
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`1026 contains no indication that Bradium limited its infringement contentions to
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`examples provided in its First Amended Complaint, and therefore the cited
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`testimony does not show a lack of basis for Dr. Michalson’s testimony that
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`Bradium’s infringement contentions accusing “all versions of the Bing Maps
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`Preview app, operating, for example, as a Microsoft Windows application” are
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`inconsistent with its positions taken in this IPR. Ex. 1016, ¶ 30.
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`RESPONSE TO OBSERVATION 20
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`XX.
`PO’s Observation No. 20 is misleading and incomplete. This Observation
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`15
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`omits both the context of the question regarding directly vs. indirectly limited
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`channels, and Dr. Michalson’s full response, which further states that “from the
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`perspective of a user using a channel, they see a result in throughput. They don’t
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`necessarily know what caused that resultant throughput, whether it be a
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`technological limitation on the channel or whether it be a large number of users
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`PTAB Case IPR2016-00449, Patent 8,924,506 B2
`Petitioner’s Response to Patent Owner's Motion for Observation
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`that they’re competing for bandwidth with. So I think that both -- relative to the
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`broadest reasonable interpretation of ‘limited bandwidth communications channel,’
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`I don’t think that the distinction that Bradium and Dr. Agouris are attempting to
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`draw is valid.” Additionally, Dr. Michalson’s testimony in Ex. 1005 and Ex. 1016
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`5
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`did not rely on the assumption that all channels are limited bandwidth. For
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`example, Dr. Michalson testified at length that Reddy in view of Hornbacker
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`teaches a “limited communication bandwidth” channel because Reddy teaches use
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`of its system in bandwidth-constrained environments such as military or
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`emergency response scenarios while Hornbacker further specifically teaches using
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`a 28.8 kilobaud modem. See, e.g. Ex. 1005, ¶¶ 122-126, 129-135; Ex. 1016, ¶¶ 32-
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`37, 39, 43-45; Ex. 2078 at 13:3-9, 13:17-23, 14:8-14, 15:2-11. Dr. Michalson
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`further testified in Ex. 1016 that a similar statement to this Observation by
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`Bradium in the Patent Owner Response (Ex. 1016, ¶ 24, citing Paper 16 at 12
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`(“[t]he Petition argues that Reddy teaches a device that retrieves data over limited
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`bandwidth communications channel [sic] because Reddy uses the Internet”)
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`mischaracterized the Petition because “the Petition contains a much more extensive
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`discussion of how Reddy teaches or suggests a limited bandwidth communication
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`channel and how such a channel would be obvious to a person of ordinary skill in
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`the art, particularly through Reddy’s teachings about accessing data in conditions
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`PTAB Case IPR2016-00449, Patent 8,924,506 B2
`Petitioner’s Response to Patent Owner's Motion for Observation
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`of limited bandwidth that would be encountered in a military or emergency
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`response scenario.” Ex. 1016, ¶ 24, citing Paper 1 at 25-27.
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`RESPONSE TO OBSERVATION 21
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`XXI.
`PO’s Observation No. 21 is misleading and incomplete for the reasons
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`discussed above in regard to PO’s Observation No. 20.
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`RESPONSE TO OBSERVATION 22
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`XXII.
`PO’s Observation No. 22 is irrelevant because it relates to a different
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`proceeding involving different patents and PO does not articulate any relevance to
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`Dr. Michalson’s reply testimony in Ex. 1016.
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`RESPONSE TO OBSERVATION 23
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`XXIII.
`PO’s Observation No. 23 is misleading, incomplete, and irrelevant for the
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`cited purpose. Dr. Michalson further testified that “that, clearly, is not the entirety
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`of my support for the -- for that opinion,” and that “[t]hat’s not correct if you
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`consider the entirety of the declaration supporting those opinions. My issue with
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`Exhibit 2016 for IPR 2016-00448, we were just looking at Paragraph 144, and the
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`heading of that paragraph is ‘no nexus and no evidence.’ If you look at what
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`you’ve provided as Exhibit 2076, and if you read past Paragraph 76, you’ll see
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`Paragraph 77, 78, and 79, at least, discuss specifically the nexus between the
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`claims and the products to which I’m offering opinions.” Ex. 2078 at 65:2-15,
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`66:10-67:5. Dr. Michalson further testified that his opinions in the unrelated
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`PTAB Case IPR2016-00449, Patent 8,924,506 B2
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`Under Armour v. Adidas case cited by PO during Dr. Michalson’s deposition
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`further relied on evidence of nexus between the instituted claims and the alleged
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`secondary indicia of nonobviousness as well as evidence of commercial success
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`relative to the relevant market, and that PO had provided no such evidence in
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`support of its secondary indicia of nonobviousness arguments in this case. Ex.
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`2078 at 84:1-92:1; citing Ex. 2076, ¶¶ 75, 77, 79-83. Therefore, the cited
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`testimony in context does not “show[] that Dr. Michalson previously opined that
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`commercial success supported non-obviousness using the same type of information
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`that Patent Owner relies on in this IPR.”
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`RESPONSE TO OBSERVATION 24
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`XXIV.
`PO’s Observation No. 24 is improper, misleading, incomplete, and irrelevant
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`for the reasons discussed above in regard to PO’s Observation No. 23. PO’s
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`Observation No. 24 is also improper, irrelevant, and incomplete because the quoted
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`testimony (in this matter) consists entirely of counsel reading an exhibit and omits
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`any response from the witness in this proceeding. Dr. Michalson further testified
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`that “in answering this question, I clearly was addressing those two factors that
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`they were asking questions about. And clearly, in Paragraphs 77, 78, and 79, I
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`showed the nexus in answering these questions that clearly was assumed that the
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`nexus had been established. They didn’t ask questions about the nexus. If they
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`did, I would have answered questions about the nexus.” Ex. 2078 at 67:10-69:3.
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`12
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`PTAB Case IPR2016-00449, Patent 8,924,506 B2
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`Therefore, the cited testimony in its full context does not “show[] that Dr.
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`Michalson previously opined that commercial success supported non-obviousness
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`using the same type of information that Patent Owner relies on in this IPR.”
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`RESPONSE TO OBSERVATION 25
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`XXV.
`PO’s Observation No. 25 is improper, misleading, incomplete, and irrelevant
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`for the reasons discussed above in regard to PO’s Observation Nos. 23 and 24.
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`PO’s Observation No. 25 is also improper, irrelevant, and incomplete because the
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`quoted testimony (in this matter) consists entirely of counsel reading an exhibit.
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`RESPONSE TO OBSERVATION 26
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`XXVI.
`PO’s Observation No. 26 is improper, misleading, incomplete, and irrelevant
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`for the reasons discussed above in regard to PO’s Observation Nos. 23 through 25.
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`PO’s Observation No. 26 is also incomplete because it references testimony from
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`an unrelated prior proceeding in which Dr. Michalson based his opinions on
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`additional exhibits which PO failed to introduce in this proceeding. Dr. Michalson
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`further testified that “I also provide a reference. I don’t recall what Exhibit 2020
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`precisely was. But then I go into certain features that were -- that were noted in
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`that article, and I continue on with additional analysis.”
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`RESPONSE TO OBSERVATION 27
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`XXVII.
`PO’s Observation No. 27 is irrelevant for the cited purpose because the only
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`exhibit in this proceeding to which PO claims the testimony is relevant is Ex. 1019
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`PTAB Case IPR2016-00449, Patent 8,924,506 B2
`Petitioner’s Response to Patent Owner's Motion for Observation
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`at 11:6-12:5, which contains neither a question from counsel nor an answer from a
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`witness, and consists entirely of PO’s counsel objecting to questions from
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`Petitioner about Mr. Levanon’s financial interest in the outcome of this proceeding
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`(and failure to disclose that interest to the Board) and Petitioner’s counsel
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`responding to the objection. Dr. Michalson’s non-contingent compensation for
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`expert consulting, which was disclosed by Dr. Michalson in Ex. 1005, ¶ 22, has no
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`relevance to Mr. Levanon’s financial interest in PO and failure to disclose that
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`interest to the Board.
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`XXVIII. RESPONSE TO OBSERVATION 28
`PO’s Observation No. 28 is improper and irrelevant for the reasons
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`discussed above in regard to PO’s Observation No. 27.
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`CONCLUSION
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`XXIX.
`Dr. Michalson's testimony is consistent and should be given weight by the
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`Board.
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`PTAB Case IPR2016-00449, Patent 8,924,506 B2
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`Dated: March 31, 2017
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`Respectfully submitted,
` /Chun M. Ng/
`Lead Counsel
`Chun M. Ng, Reg. No. 36,878
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`Back-up Counsel
`Matthew C. Bernstein, Pro Hac Vice
`Vinay Sathe, Reg. No. 55,595
`Patrick J. McKeever, Reg. No. 66,019
`Evan S. Day, Pro Hac Vice
`
`Attorneys for Microsoft Corporation
`
`
`
`PERKINS COIE LLP
`11988 El Camino Real, Suite 350
`San Diego, CA 92130
`(858) 720-5700
`
`
`
`15
`
`
`
`PTAB Case IPR2016-00449, Patent 8,924,506 B2
`Petitioner’s Response to Patent Owner's Motion for Observation
`
`CERTIFICATE OF SERVICE
`
`
`
`
`
`The undersigned hereby certifies that a true copy of the foregoing
`
`PETITIONER'S RESPONSE TO PATENT OWNER’S MOTION FOR
`
`OBSERVATION has been served in its entirety this 31st day of March, 2017 by
`
`electronic mail on the Patent Owner via its attorneys of record:
`
`BACK-UP COUNSEL
`Michael N. Zachary
`mzachary@kenyon.com
`KENYON & KENYON, LLP
`1801 Page Mill Road, Ste 210
`Palo Alto, CA 94304
`Clifford Ulrich
`culrich@kenyon.com
`KENYON & KENYON, LLP
`One Broadway
`New York, NY 10004-1007
`
`Respectfully submitted,
` /Chun M. Ng/
`Lead Counsel
`Chun M. Ng, Reg. No. 36,878
`
`Back-up Counsel
`Matthew C. Bernstein, Pro Hac Vice
`Vinay Sathe, Reg. No. 55,595
`Patrick J. McKeever, Reg. No. 66,019
`Evan S. Day, Pro Hac Vice
`
`Attorneys for Microsoft Corporation
`
`
`
`LEAD COUNSEL
`Christopher J. Coulson
`ccoulson@kenyon.com
`KENYON & KENYON, LLP
`One Broadway
`New York, NY 10004-1007
`
`Bradiumiprservice@kenyon.com
`
`
`Dated: March 31, 2017
`
`
`
`PERKINS COIE LLP
`11988 El Camino Real, Suite 350
`San Diego, CA 92130
`(858) 720-5700
`
`
`
`1
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