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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.,
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`Petitioners
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`v.
`PERSONALIZED MEDIA COMMUNICATIONS, LLC,
`Patent Owner
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`
`
`Case No.: IPR2016-00754
`Patent No.: 8,559,635
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`REQUEST FOR REHEARING UNDER 37 C.F.R. § 42.71(d)
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`
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`Case No.: IPR2016-00754
`Patent No.: 8,559,635
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`TABLE OF CONTENTS
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`B.
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`
`INTRODUCTION AND STATEMENT OF RELIEF REQUESTED ...... 1
`I.
`II. LEGAL STANDARDS ................................................................................... 2
`III. THE CONSTRUCTION OF THE “DECRYPT” TERMS IS
`ERRONEOUS ................................................................................................. 2
`A.
`The Specification Defines “Decrypt” to Mean a Digital Process on
`Digital Data, Excluding Analog Processes such as the
`Descrambling of Analog Television. ................................................... 4
`The File History Contains Multiple Disclaimers Limiting
`Decryption to Operations on Digital Data and Excluding Analog
`Processes. ............................................................................................... 8
`The Board’s Inquiries into Irrelevant and Tangential Matters Do
`Not Cure Its Failure to Adhere to the Specification and
`Prosecution History. ........................................................................... 12
`IV. CONCLUSION .............................................................................................. 15
`
`
`C.
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`Case No.: IPR2016-00754
`Patent No.: 8,559,635
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`TABLE OF AUTHORITIES
`
`
`Cases
`Builders Concrete, Inc. v. Bremerton Concrete Prods. Co.,
`757 F.2d 255 (Fed. Cir. 1985) ............................................................................... 15
`In re Smith Int’l, Inc.,
`--- F.3d ----, 2017 WL 4247407 (Fed. Cir. Sept. 26, 2017) .................................... 4
`Microsoft Corp. v. Proxyconn, Inc.,
`789 F.3d 1292, (Fed. Cir. 2015) .............................................................................. 2
`Phillips v. AWH Corp.,
`415 F.3d 1303 (Fed. Cir. 2005) ........................................................................... 3, 4
`PowerOasis, Inc. v. T-Mobile USA, Inc.,
`522 F.3d 1299 (Fed. Cir. 2008) ............................................................................. 14
`Southwall Technologies, Inc. v. Cardinal IG Co.,
`54 F.3d 1570 (Fed. Cir. 1995) ............................................................................... 15
`Tempo Lighting, Inc. v. Tivoli, LLC,
`742 F.3d 973 (Fed. Cir. 2014) ........................................................................... 2, 15
`
`
`
`Rules
`
`37 C.F.R. § 42.100 ...................................................................................................... 2
`37 C.F.R. § 42.71(d) ................................................................................................... 2
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`Case No.: IPR2016-00754
`Patent No.: 8,559,635
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`
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`I.
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`INTRODUCTION AND STATEMENT OF RELIEF REQUESTED
`The Board’s Final Written Decision (“Decision” or “Dec.”) of September
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`19, 2017 (Paper 41), was largely decided on a claim construction issues that is
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`contradicted by the specification and other intrinsic evidence for U.S. Pat. No.
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`8,559,635 (the “’635 Patent”). Much of the analysis in the Decision is one-sided
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`and appears results-oriented.
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`Patent Owner submits that this Request for Rehearing (“Request”) should be
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`granted because the Decision misapprehended and overlooked evidence provided
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`and arguments made by Patent Owner regarding the proper construction of
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`“decrypt.” The term “decrypt” (or variations such as “decrypting,” “encrypted,”
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`etc.) is found in each of the challenged claims. Patent Owner asks that the Board
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`grant this Request, vacate the Decision and issue a new Final Written Decision
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`correcting the claim construction and confirming the affected claims as patentable.
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`The construction of this term by the Board is incorrect as a matter of law.
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`First, the Decision ignored key passages from the specification, whose meanings
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`are undisputed, and compounded the error by instead focusing on a passage whose
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`meaning is disputed to support its construction.
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`Second, the Board’s claim construction completely disregarded multiple
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`instances of prosecution disclaimer. The prosecution disclaimers could not be
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`1
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`Case No.: IPR2016-00754
`Patent No.: 8,559,635
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`more clear and unequivocal.
`II. LEGAL STANDARDS
`A request for rehearing “must specifically identify all matters the party
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`believes the Board misapprehended or overlooked, and the place where each
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`matter was previously addressed in a motion, an opposition, or reply.” 37 C.F.R.
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`§ 42.71(d)
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`Under the broadest reasonable interpretation standard, “claims should
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` always be read in light of the specification and teachings in the underlying
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`patent,” and the meaning of a claim must “reasonably reflect the plain language
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`and disclosure” instead of being “unreasonably broad.” Microsoft Corp. v.
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`Proxyconn, Inc., 789 F.3d 1292, 1298 (Fed. Cir. 2015); 37 C.F.R. § 42.100.
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`
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`Thus, in construing a term, the PTAB should consider: (1) the ordinary and
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`customary meaning (if one exists); (2) the claim language; (3) the specification;
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`and (4) the prosecution history. Tempo Lighting, Inc. v. Tivoli, LLC, 742 F.3d 973,
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`977 (Fed. Cir. 2014); see Phillips v. AWH Corp., 415 F.3d 1303, 1312-1313 (Fed.
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`Cir. 2005).
`III. THE CONSTRUCTION OF THE “DECRYPT” TERMS IS
`ERRONEOUS
`Each of the challenged claims recite various “decrypt” and “encrypt” type
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`terms (“decrypt terms”).
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`2
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`Patent No.: 8,559,635
`Patent Owner submitted that the “decrypt” terms should be construed to
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`mean “a method that uses a digital key in conjunction with an associated
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`algorithm to decipher (render intelligible or usable) digital data.” Patent Owner
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`Response (“POR”), Paper 15, at 6 [emph. added.] Patent Owner explained that its
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`construction excluded operations on analog information, such as the descrambling
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`of analog television. Id.
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`The Board determined that the “decrypt” terms are not limited to digital
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`processes applied to digital data, but broadly encompass analog processes such as
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`descrambling analog television. Dec. at 18. The Board did not proceed from an
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`ordinary and customary meaning of the “decrypt” terms because there allegedly
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`was no established meaning. Dec. at 13 (“The evidence shows the meaning of the
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`terms to be in flux, with no established convention.”). For all intents and purposes,
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`the Board’s construction of “decrypt” is based entirely on a single sentence in the
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`‘635 Patent specification, described by the Board as “controversial.” Dec. at 9-10
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`(citing Ex. 1003, 160:51–55).
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`The Board erred by failing to consider the specification as a whole,
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`including passages at odds with the Board’s construction. The Board also refused
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`to consider multiple disclaimers in the file history that are independently
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`dispositive of the issue.
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`3
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`Patent No.: 8,559,635
`A. The Specification Defines “Decrypt” to Mean a Digital Process on
`Digital Data, Excluding Analog Processes such as the
`Descrambling of Analog Television.
`The Federal Circuit has stated time and again that the specification is the
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`primary source for ascertaining the meaning of claim terms. In Phillips v. AWH
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`Corp. , the Federal Circuit stated:
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`The specification is, thus, the primary basis for construing the claims.
`On numerous occasions since then, we have reaffirmed that point,
`stating that “[t]he best source for understanding a technical term
`is the specification from which it arose, informed, as needed, by the
`prosecution history.
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`415 F.3d 1303, 1315 (emph. added, cites omitted). This maxim was reaffirmed in
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`the Federal Circuit’s decision reversing the Board in In re Smith Int’l, Inc., --- F.3d
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`----, 2017 WL 4247407 (Fed. Cir. Sept. 26, 2017) at *5 (proper construction is that
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`which “corresponds with what and how the inventor describes his invention in the
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`specification”) [cite omitted].
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`
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`A mere two passages in the specification should have decided the issue for
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`“decrypt.” First, the ‘635 Patent specification describes the “decrypt” term as
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`follows:
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`Decryptors, 107, 224 and 231, are conventional decryptors, well
`known in the art, with capacity for receiving encrypted digital
`information, decrypting said information by means of a selected
`cipher algorithm and a selected cipher key, and outputting the
`decrypted information.
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`4
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`Patent No.: 8,559,635
`Ex. 1003 (‘635 Patent, emp. added) at 148:11-16; see POR at 7.
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`The passage is definitional. The inventors understood the term to have a
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`meaning in the art which they set forth explicitly and adopted as their own. The
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`Decision did not address this first passage.
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`Second, the ‘635 Patent affirmatively defines decryption as being distinct
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`from analog descrambling:
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`In the prior art, various means and methods exist for regulating the
`reception and use of electronically transmitted programming. Various
`scrambling means are well known in the art for scrambling, usually
`the video portion of analogue television transmissions in such a
`fashion that only subscriber stations with appropriate descrambling
`means have capacity to tune suitably to the television transmissions
`and display
`the
`transmitted
`television
`image
`information.
`Encryption/decryption means and methods, well known in the art,
`can regulate the reception and use of, for example, digital video and
`audio
`television
`transmissions, digital audio
`radio and
`phonograph transmissions, digital broadcast print transmission,
`and digital data communications.
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`Ex. 1003 (‘635 Patent) at 144:7-19, POR at 8.
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`
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`This passage establishes a dichotomy: encryption/decryption apply to digital
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`signals, whereas scrambling/descrambling apply to analog signals. It is consistent
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`with the definition of “decrypt” set forth in the passage above. The Decision
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`5
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`Patent No.: 8,559,635
`wholly ignored this passage from the specification in its analysis of the “decrypt”
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`terms.
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`
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`While ignoring the passages that explicitly and indisputably define
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`“decrypt,” the Board myopically focused on a single “controversial” passage at the
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`end of a specific embodiment, Example #7. Example #7 (spanning thirteen
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`columns) describes a complex embodiment for the decryption of a digital
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`television transmission containing encrypted digital video and encrypted digital
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`audio that has been encrypted using three separate keys. Ex. 1003 (‘635 Patent) at
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`144:6-13, 23-31.
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`
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`At the end of the thirteen columns the specification lists a series of
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`modifications that could be made to the Example #7 embodiment. One is:
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`And for example, the “Wall Street Week” transmission
`may be of conventional analog television, and the decryptors,
`107, 224, and 231, may be conventional descramblers, well,
`known in the art, that descramble analog television transmissions
`and are actuated by receiving digital key information.
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`Ex. 1003 at 160:51-55 [emph. added]; POR at 9-10.
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`
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`The Board based its claim construction on this single sentence, which the
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`Board called a “controversial sentence.” Dec. at 10. The Board erroneously
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`asserted that this “controversial sentence” defines “decrypt.”
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`6
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`Patent No.: 8,559,635
`First, this sentence must be understood in the context of the introduction to
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`
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`the paragraph, which states:
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`It is obvious to one of ordinary skill in the art that the foregoing is
`presented by way of example only and that the invention is not to be
`unduly restricted thereby since modifications may be made in the
`structure of the various parts without functionally departing from
`the spirit of the invention.
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`Ex. 1003 at 160:40-45 [emph. added]. Accordingly, the “controversial
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`sentence” can only be understood as a modification to the structure of the
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`Example #7 embodiment: descramblers replace decryptors in the case of
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`analog television. POR 11-13. The Board has improperly conflated a
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`modification to the components of an embodiment with a “definition.”
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`Next, the Board’s reliance on this one sentence is unreasonable. The
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`premise that a “controversial sentence” susceptible to multiple
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`interpretations can be a definition is false, particularly where, as here, the
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`other passages in the specification (discussed above) define the “decrypt”
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`term with clarity and without ambiguity. The Board improperly failed to
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`consider these passages in its zeal to construct the term in a broadest
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`possible construction, rather than the broadest reasonable construction based
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`on what the specification teaches about the invention. The Board thus erred
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`by failing to consider the specification as a whole.
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`7
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`Patent No.: 8,559,635
`The passages at columns 144 and 148 of the ‘635 Patent provide a
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`
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`definition for the term. The “controversial sentence” cannot trump that
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`definition.
`B.
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`The File History Contains Multiple Disclaimers Limiting
`Decryption to Operations on Digital Data and Excluding Analog
`Processes.
`PMC cited to multiple instances of disclaimer during prosecution of the ‘635
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`
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`Patent and related patents with the same specification that limit “decrypt” to
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`operations on digital data and exclude operations on analog information. POR at
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`12-14.
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`Disclaimers in ‘635 Patent
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`First Disclaimer. The first disclaimer was made in an office action response
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`on April 2, 2013, which stated: “Applicants have consistently asserted in their
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`previous Responses . . . that encryption and decryption require a digital signal”
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`and “encryption and decryption are not broad enough to read on scrambling
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`and unscrambling.” POR at 12 (citing Ex. 2016 at 1330, emph. added). The
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`inventors then distinguished the prior art on the basis that it described analog
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`descrambling, not the decrypting recited by the claims that requires digital signals.
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`Id. This disclaimer is clear and unequivocal. The Board did not address this
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`disclaimer in the ‘635 Patent.
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`
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`Second Disclaimer. The inventors disclaimed analog descrambling from
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`“decrypt” the first time these claims were introduced. In the office action response
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`Patent No.: 8,559,635
`submitted on April 5, 2011, the inventors submitted new claims 23, 34, and 43,
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`which correspond to the independent claims at issue. Ex. 2016 at 1008-1016. The
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`inventors stated: “The claims of this amendment, however, claim material relating
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`to the encryption and decryption of signals.” Id. at 1017. They stated that
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`“encryption requires a digital signal” and “[e]ncryption and decryption . . . are
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`not broad enough to read on scrambling and descrambling of analog signals.”
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`Id. at 1018 [emph. added]. They also distinguished the art on the same basis:
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`“Therefore, because [the references] are directed to the unscrambling of analog
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`signals, none teach or suggest a method of controlling the decryption of digital
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`information as is presented in the claims of this amendment.” Id. This disclaimer in
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`the ‘635 Patent is clear and unequivocal.
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`
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`Disclaimers in ‘091 Patent
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`The Board is aware of three separate disclaimers in U.S. 8,191,091 (‘091
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`Patent) (assigned App. Ser. No. 08/485,507) that exclude descrambling of analog
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`information from “decrypt.” Those disclaimers apply here because the ‘635 and
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`‘091 Patents share the same specification and the same claim term is at issue.
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`
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`In an office action response which first introduced claims for the ‘091 Patent
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`with “decrypt” terms, the inventors disclaimed analog descrambling:
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`All [prior art] patents disclose the use of encoded control signals or
`other data to control the unscrambling of an analog video signal. . . .
`Each of the claims of this amendment involves the use of digital
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`Case No.: IPR2016-00754
`Patent No.: 8,559,635
`signals through reference to “decryption” and “encryption.”
`“Encryption and decryption,” . . . “are not broad enough to read on
`scrambling and unscrambling.”
`See Ser. No. 08/485,507, Supplemental Amendment, 4/11/11, at 10-11 [emph.
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`added]. The same disclaimers occurred again in two other papers. See Ser. No.
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`08/485,507, Amendment After Final, 10/3/2011, at 11 (“decryption requires a
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`digital signal” and “encryption and decryption are not broad enough to read on
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`scrambling and unscrambling.”); Ser. No. 08/485,507, Amendment and Request
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`for Consideration, 12/21/11, at 10 (“decryption requires a digital signal” and
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`“encryption and decryption are not broad enough to read on scrambling and
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`unscrambling.”).
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`
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`The above disclaimers regarding the “decrypt” terms are clear and
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`unequivocal.
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`
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`Disclaimers in ‘277 and ‘825 Patents
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`The reexamination file histories of patents sharing the same specifications,
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`U.S. Pat. No. 5,335, 277 (‘277 Patent) and 4,965,825 (‘825 Patent), have the same
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`disclaimers. POR at 13-14. In the appeal briefing in the reexamination of the ‘277
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`and ‘825 Patents, the inventors stated (all emph. added):1
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`1 The Board disregarded the listed statements from the ‘277 briefing. Instead, it
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`selectively plucked from another sentence referring to “decrypt” as “something
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`10
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`Case No.: IPR2016-00754
`Patent No.: 8,559,635
`• ‘277 Appeal Brief: “[D]ecryption … is a digital operation performed on
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`digital signals, not analog signals. Descrambling of analog television
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`signals does not correspond to decryption whatsoever, as is well
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`understood in the art.” Ex. 2031 at 77.
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`• ‘277 Reply Brief: “[O]ne of ordinary skill in the art would understand that a
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`decryptor that decrypts signals as interpreted in light of the specification
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`does not include analog scrambling and descrambling. . . . Here, the
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`inventor expressly distinguished his use of the terminology
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`encryption/decryption’ from the scrambling/descrambling shown in . . .
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`the applied references.” Ex. 2006 at 41.
`
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`beyond the conventional scrambling descrambling relied upon by the Examiner,
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`such as the use of a decryption key . . .” Dec. at 14. The Board then asserted:
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`“Patent Owner argues ‘encryption and decryption’ only differ ‘beyond . . .
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`conventional scrambling/descrambling” by “the use of a decryption key.” Dec. at
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`17. That statement is incorrect. The cited sentence simply reflects that decryption
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`involves the use of a decryption key. Any other reading of that sentence conflicts
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`with the repeated statements in the briefing that “decrypt” requires a digital signal
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`and excludes analog descrambling.
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`
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`11
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`Case No.: IPR2016-00754
`Patent No.: 8,559,635
`• ‘825 Appeal Brief: “Scrambling and encryption are different terms in
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`the art. In particular, encryption relates to digital signals.” Ex. 2009 at 30.
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`
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`The Board Response. The Board does not analyze any of the multiple
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`prosecution disclaimers, including the disclaimer in the prosecution of the ‘635
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`Patent. The Board dismisses all prosecution disclaimers on the basis that such
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`“general statements” disclaiming analog descrambling “do not account for the
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`specific claim terms at issue in this proceeding.” Dec. at 16-17. No explanation is
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`provided. The same encrypt/decrypt terms are at issue in each of the disclaimers. It
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`is arbitrary and capricious for the Board to simply decree that none of the
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`prosecution disclaimers “count.”
`C. The Board’s Inquiries into Irrelevant and Tangential Matters Do
`Not Cure Its Failure to Adhere to the Specification and
`Prosecution History.
`The Decision spends twelve pages addressing the construction of the
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`“decrypt” terms. Dec. at 7-18. The correct result could be provided in a few pages
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`by reference to the specification and prosecution history, which provide a ready
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`answer. But the task of justifying an incorrect result requires more work. Perhaps
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`this explains the Board’s various forays and detours into matters that are irrelevant
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`or peripheral.
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`For example, the Decision has a lengthy discussion about the meaning of the
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`term “programming.” Dec. at 7-9. But the issue is the meaning of “decrypt,” not
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`“programming.” The Board’s effort to use “programming” to bootstrap its
`12
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`Case No.: IPR2016-00754
`Patent No.: 8,559,635
`preferred construction of “decrypt” is wrong at every level. The ‘635 Patent
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`specification defines programming as “everything that is transmitted electronically
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`to entertain, instruct or inform, including television, radio, broadcast print, and
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`computer programming [as] well as combined medium programming.” Ex. 1003 at
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`6:31-34. Programming is thus defined as types of content that “entertain, instruct,
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`or inform.” Other than being transmitted “electronically,” the definition is agnostic
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`as to how the content is delivered. “Programming” is not defined in terms of how it
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`is formatted (e.g., analog or digital) or how it is transmitted (e.g., modulation,
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`frequency, type of transmitter, etc.). Thus, the Board’s tortured argument that (1)
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`“programming” is allegedly defined to include analog transmissions, and thus (2)
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`“decrypting programming” must mean “decrypting analog transmissions,” and thus
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`(3) “decrypting” encompasses descrambling analog transmissions, is erroneous
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`from start to finish. Dec. at 7-9. This convoluted logic cannot overcome the clear
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`teachings in the specification and file history.
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`The Board quotes itself: “[I]f you say you don’t have anything about
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`descrambling in there, then you must be talking about protecting [programs] with
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`decrypting, which is the same thing as descrambling because [the programs
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`include] analog.” Decision at 9 (citing to hearing). With all due respect, that
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`conclusion is based on the incorrect premise that programs can only be “protected”
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`by decryption or descrambling. In fact, there are many other ways to protect
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`13
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`Case No.: IPR2016-00754
`Patent No.: 8,559,635
`programs. See, e.g., Ex. 1004, Fig. 4 (interrupt means); 4:47-54 (special signal
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`words); Ex. 1003 at 7:40-42 (“a variety of means and methods for restricting the
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`use of transmitted communications to only duly authorized subscribers”); 144:19-
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`28 (jamming and disabling unauthorized stations); 151:10-40 (tamper detection
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`and disabling unauthorized stations).
`
`The Board’s discourse on the original patent, U.S. Pat. No. 4,965,490 (Ex.
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`1004, “’490 Patent”) for claim construction is irrelevant.2 The determination of the
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`meaning of claim terms is based only on the appended specification, the ‘635
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`Patent CIP specification. See PowerOasis, Inc. v. T-Mobile USA, Inc., 522 F.3d
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`1299, 1311 (Fed. Cir. 2008) (“[T]he construction of “customer interface’ that must
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`be supported by the written description of the Original Application is the
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`construction given by the district court for the term as used in the ′658 and
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`′400 Patents [CIP Applications].”) [emph. added].
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`The Board also cites Builders Concrete, Inc. v. Bremerton Concrete Prods.
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`Co., 757 F.2d 255, 258 (Fed. Cir. 1985) for the notion that prosecution disclaimer
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`is an “equitable tool” that the Board is free to disregard. Dec. at 18. Builders
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`Concrete involves file history estoppel and is thus inapposite. Prosecution
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`disclaimer is a tool for claim construction; file history estoppel is not. See
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`2 The ‘490 Patent is relevant to whether it provides written decryption support for
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`the priority inquiry (§ 112), but not the prerequisite step of claim construction.
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`14
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`
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`Case No.: IPR2016-00754
`Patent No.: 8,559,635
`Southwall Technologies, Inc. v. Cardinal IG Co., 54 F.3d 1570, 1578 (Fed. Cir.
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`1995) (limit on range of equivalents due to prosecution history estoppel is
`
`irrelevant to interpretation of those claims). The cited comment (id.) from Tempo
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`Lighting, Inc. v. Tivoli, LLC, 742 F.3d 973 (Fed. Cir. 2014) is mere dicta.
`IV. CONCLUSION
`Patent Owner PMC respectfully requests that the Board grant this request
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`for rehearing.
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`
`
`Dated: October 19, 2016
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`
`
`Respectfully submitted,
`
`/Stephen T. Schreiner/
`
`Stephen T. Schreiner
`Registration No.: 43,097
`Goodwin Procter LLP
`901 New York Avenue, NW
`Washington, DC 20001
`Tel: (202) 346-4336
`Fax: (202) 346-4444
`
`15
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`Case No.: IPR2016-00754
`Patent No.: 8,559,635
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`The undersigned certifies that a copy of this Request for Rehearing was
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`CERTIFICATE OF SERVICE
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`electronically served on:
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`msernel@kirkland.com
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`
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`jmerkin@kirkland.com
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`egoryunov@kirkland.com
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`Apple-PMC-PTAB@kirkland.com
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`garovas@kirkland.com
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`arabinowitz@kirkland.com
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`
`
`Under 37 C.F.R. § 42.6(e)(1) and the consent found in Section I.D of the Petition.
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`Dated: October 19, 2017
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`By:
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` /Stephen T. Schreiner/
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`
`
`Stephen T. Schreiner
`Registration No.: 43,097
`Goodwin Procter LLP
`901 New York Avenue, NW
`Washington, DC 20001
`Tel: (202) 346-4336
`Fax: (202) 346-4444
`
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