UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.
`Petitioner
`
`v.
`
`PERSONALIZED MEDIA COMMUNICATIONS, LLC
`Patent Owner
`
`Case No.: IPR2016-00755
`Patent No.: 8,191,091
`
`
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`
`
`PATENT OWNER’S REPLY IN SUPPORT OF MOTION
`TO AMEND
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.
`Petitioner
`
`v.
`
`PERSONALIZED MEDIA COMMUNICATIONS, LLC
`Patent Owner
`
`Case No.: IPR2016-00755
`Patent No.: 8,191,091
`
`
`
`
`
`PATENT OWNER’S REPLY IN SUPPORT OF MOTION
`TO AMEND
`
`
`
`
`
`
`
`
`
`
`
`
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`TABLE OF CONTENTS
`
`Page
`
`I.
`
`INTRODUCTION ........................................................................................... 1
`
`II.
`
`THE PROPOSED SUBSTITUTE CLAIMS ARE PATENTABLE ............... 1
`
`A.
`B.
`
`Substitute Claims are Patentable over 35 U.S.C. §101 ......................... 1
`Substitute Claims are Patentable Over 35 U.S.C. §112 ........................ 3
`
`III. THE SUBSTITUTE CLAIMS ARE NOT OBVIOUS TO A POSA.............. 7
`
`A.
`B.
`C.
`D.
`
`Substitute Claims are Patentable over Gilhousen ................................. 7
`Substitute Claims are Patentable Over Seth-Smith ............................. 10
`Substitute Claims are Patentable Over Other Prior Art ...................... 12
`There is no Meaningful Dispute Regarding Claim Construction ....... 12
`
`IV. CONCLUSION .............................................................................................. 12
`
`
`
`i
`
`
`
`
`
`I.
`
`INTRODUCTION
`
`The Petitioner has not shown that the Substitute Claims are unpatentable.
`
`Apple alleges that the Substitute Claims are § 101 unpatentable, (Paper 29 at 1), but
`
`fails to acknowledge the District Court’s § 101 decision on this very patent. (Ex.
`
`2136 (“R&R”)). Apple contends a lack of specification support, yet many of the
`
`added limitations are almost verbatim from the specification, with only minor
`
`changes. Lastly, Apple argues prior art. PMC analyzed all references cited in the
`
`Apple and Amazon IPRs, affording them broad § 103 combinability, showing how
`
`that art does not invalidate the Substitute Claims. (Paper 21 at 3, Paper 11).
`
`II. THE PROPOSED SUBSTITUTE CLAIMS ARE PATENTABLE
`
`A.
`
`Substitute Claims are Patentable over 35 U.S.C. §101
`
`Apple contends that the Substitute Claims are unpatentable under § 101
`
`because they are “strikingly similar” to claim 1 of US Patent No. 7,801,304, found
`
`unpatentable in Personalized Media Commc’ns, LLC v Amazon.com, Inc., 161
`
`F.Supp.3d 325 (D. Del. 2015). (Paper 29 at 1). Careful analysis, however, shows
`
`the Substitute Claims to be markedly different from those invalidated in Delaware.
`
`Magistrate Judge Payne’s R&R, adopted by the district court (Ex. 2147), to
`
`which Apple did not object, finds Claim 13 of the ‘091 not directed to the abstract
`
`idea of decryption, but to a specific method of using an instruct-to-enable signal to
`
`locate a decryption key. (Ex. 2136 at 16-17; Ex. 2147).
`
`Apple also neglects to address the specific limitations of these Substitute
`
`
`
`1
`
`
`
`
`
`Claims. Substitute Claim 32 is addressed to a key management method in which
`
`(1) an “instruct-to-enable” signal is detected in an encrypted digital information
`
`transmission (2) and processed at the receiver station (3) to determine a fashion for
`
`locating a decryption key at the receiver station to decrypt the information
`
`transmission and (4) to then create a digital record including a unique digital code
`
`identifying the receiver station. Substitute Claim 37 requires (1) a first instruct-to-
`
`enable signal including processor instructions is detected, (2) the detected processor
`
`instructions are then executed to provide a first decryption key, (3) a second
`
`instruct-to-enable signal with different processor instructions is detected, (4) these
`
`new processor instructions are executed to provide a second decryption key, (5) the
`
`two distinct keys are used to decrypt the digital information and also (6) a unique
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`code is stored at the receiver station identifying it. Substitute Claim 41 describes a
`
`method requiring (1) the detected instruct-to-enable signal is processed (2) to tune
`
`the receiver to a remote station (3) to receive enabling information (4) which is used
`
`to decrypt the information transmission and output the decrypted information ([]5)
`
`based on local user input.
`
`Apple further contends that the Substitute Claims lack inventive concepts and
`
`thus fail Alice/Mayo Step 2. However, in the district court, Prof. Weaver described
`
`the state of art in data communication in the 1980’s (when the inventions at issue
`
`here were made) and then further explained that the techniques recited in claims 13-
`
`
`
`2
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`
`
`
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`16, 18, 20, 23-24, 26-27 and 30 of the ‘091 Patent were not conventional at that
`
`time. (Ex. 2145 at 6-16). Apple does not address these conclusions.
`
`Apple’s sole argument on the § 101 issue is that the Patent Owner does not
`
`meet its burden. The Patent Owner has enumerated the concrete, non-conventional
`
`limitations in the Substitute Claims. When these are considered along with Judge
`
`Payne’s uncontested R&R (Ex. 2136), and Prof. Weaver’s declaration
`
`demonstrating non-conventionality (Ex. 2145), the Patent Owner has clearly carried
`
`its burden.
`
`B.
`
`Substitute Claims are Patentable Over 35 U.S.C. §112
`
`Apple cites Facebook for the proposition a “mere citation in a table to various
`
`portions of the original disclosure” is insufficient support for amendment.
`
`Facebook, Inc. v. EveryMD LLC, IPR2014-00242, 2015 WL 2268210 (P.T.A.B.
`
`May 12, 2015). In fact, the Board in Facebook did review the table, but found
`
`support missing. Next, without substantiating its assertion, Apple attacks the
`
`declaration of Dr. Timothy Dorney, calling him “not an expert in the field,” and
`
`“not a PHOSITA at the time of the invention.” (Paper 29 at 6). The declaration
`
`details his expertise in signal processing, which is the very title of the ‘091 Patent.
`
`(Ex. 2130; Ex. 1052 at 125:1-126:11). Being a POSA at the time of the invention is
`
`not required, only “the capability of understanding the scientific and engineering
`
`principles applicable to the pertinent art” Is. (MPEP § 2141.03).
`
`
`
`3
`
`
`
`
`
`Apple cites Respironics, Inc. v. Zoll Med. Corp., IPR2013-00322, Paper 46 at
`
`24 (P.T.A.B. Sept. 17, 2014) implying the amendment word count heightens PMC’s
`
`burden. (Paper 29 at 6). PMC relies on Example #7, and disclosure of the
`
`apparatus’s functionality (specification beginning) that supports all embodiments.
`
`There are no “extensive modifications” in the amendments the “combination with
`
`all the other claim limitations” is difficult to “piece together”. (Cf, Paper 29 at 6-7.)
`
`Apple argues “so-called ‘digital video’ and ‘digital audio’” are not enabled.
`
`(Paper 29 at 7). First, the ‘091 Patent is focused on personalization of content by
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`supplementing known technologies. Second, the ‘091 Patent teaches, “to cease
`
`receiving and decrypting the television information of said cable channel 13 as
`
`digital video and audio, to commence receiving said television information as
`
`conventional analog television”. (Ex. 2050 at 302:2-5). Harvey et al. clearly
`
`understood the differences between digital and conventional (analog / NTSC) TV
`
`(i.e., video and audio). In Example #7, digital messages are incorporated in both
`
`the digital and analog TV transmission. (Id. at 288:30-302:7.) Accordingly, “digital
`
`TV” is not designated digital due to embedded digital messages, but necessarily is
`
`TV encoded in a digital format. Third, the face of the ‘091 Patent lists prior art
`
`teaching digital TV including Huth and Golding as early as 1967. (Ex. 1003 at 14;
`
`see also, Exs. 2025-26, 2031, 2033-37, 2039). Fourth, commercial implementation
`
`is not the threshold when technical knowledge is ubiquitous. Apple’s own expert,
`
`
`
`4
`
`
`
`
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`Mr. Wechselberger (Ex. 1001 at ¶17, ¶45), revealed he fully understood what digital
`
`TV was in 1983 by stating, “[t]he reason true digital video transmission techniques
`
`are not used in (sic) a matter of cost, both in terms of dollars and bandwidth.” (Ex.
`
`1027 at 4). Fifth, even Apple concedes digital TV was known. (Paper 29 at 12-13).
`
`Apple argues the “local-cable-enabling-message (#7)” is transmitted on a
`
`different channel than the program transmitted “on cable channel 13.” (Paper 29 at
`
`8). They ignore that the ‘091 Patent clearly states the “master cable control channel
`
`(that may or may not be cable channel 13).” (Ex. 2050 at 290:28-29). Channel 13
`
`may transmit both the master control channel and Wall Street Week program.
`
`Apple says claims 32-36 lack support for “a digital record including a unique
`
`digital code identifying said receiver station” by questioning whether “the ‘meter
`
`records’ of audio decryption contain such a code.” (Paper 29 at 8-9). All
`
`embodiments of the ‘091 Patent are able to collect information by creating and
`
`transferring records from user stations. “In each example, … signal processor, 200,
`
`telephones … one or more remote monitor information collection station computers
`
`and transfers selected record information to said computers.” (Ex. 2050 at 92:35-
`
`93:18). The signal processor 26 and 200 are the same (Ex. 2050 at 28:6-10),
`
`contain a “unique digital code information capable of identifying … the subscriber
`
`station”, and there is no dispute Example #7 discloses “to create a meter record that
`
`documents the decryption of the cable audio transmission at the station of FIG. 4.”
`
`
`
`5
`
`
`
`
`
`(Ex. 2050 at 295:1-3, emphasis added). Example #7 clearly requires a record that
`
`(1) decryption occurred, and (2) the station identification. Unique digital codes
`
`identify stations (Ex. 2130 at 15), to determine station-specific activity. (Ex. 2050 at
`
`88:19-22). Given the ‘091 Patent’s goal “for identifying … what programming is
`
`… used at each receiver station” (Ex. 2050 at 3:9-20), a POSA would surely
`
`understand Harvey et al. teaches using a unique station identifier in user station
`
`records. (MPEP § 2164).
`
`Apple posits claims 37-40 lack support for “detecting in said encrypted
`
`digital information transmission the presence of a second instruct-to-enable signal”
`
`because the identified “2nd-WSW-program-enabling-message (#7)” (second
`
`instruct-to-enable signal) “is received as part of an analog television transmission.”
`
`(Paper 29 at 9). Apple ignores the Board’s claim construction. (Paper 14 at 7-12).
`
`The Board reasons, “[n]othing in the plain language of claim 13 implies an “entire”
`
`digital or “entire” encrypted transmission.” (Paper 14 at 8-9). Amended claims 37-
`
`40 do not require the encrypted and unencrypted digital information to be exclusive
`
`of analog signals, except for any scrambled analog encoded information, in the
`
`encrypted digital information transmission. PMC’s claims echo the Board’s own
`
`construction.
`
`Apple asserts claims 41-43 lack support by stating, “PMC contends that the
`
`master control channel and cable channel 13 are one and the same, that would
`
`
`
`6
`
`
`
`
`
`render the ‘automatically tuning’ step meaningless.” (Paper 29 at 10). The ‘091
`
`Patent does state, the “master cable control channel (that may or may not be cable
`
`channel 13)” (Ex. 2050 at 290:28-29), where the Wall Street Week program is also
`
`transmitted on cable channel 13 (Ex. 2050 at 290:4-10). However, Apple fails to
`
`recognize tuner 214 (one of three tuners 214, 215, 223 in Fig. 4) as the tuner to
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`retune. (Ex. 2130 at 36). The other tuners may already be on channel 13, but tuner
`
`214 may not. The “automatically tuning” step is clearly not meaningless.
`
`III. THE SUBSTITUTE CLAIMS ARE NOT OBVIOUS TO A POSA
`
`Apple claims PMC “does not analyze the prior art with any specificity.”
`
`(Paper 29 at 11). PMC explicitly highlights the deficiencies of Exs. 1004-6, and
`
`1008, the prior art that led to this IPR. (Paper 21 at 4).
`
`A.
`
`Substitute Claims are Patentable over Gilhousen
`
`As required by Substitute Claims 32-40, Gilhousen fails to teach
`
`“transmission is unaccompanied by any scrambled analog encoded information.”
`
`(Paper 29 at 12). Gilhousen teaches, “scrambling and selectively descrambling
`
`television signals that are transmitted to subscribers' descramblers.” (Ex. 1004 at
`
`Abstract). Apple argued the same in its Petition (Paper 14 at 30-31). Gilhousen
`
`teaches, “[v]ideo scrambling is accomplished by retrieving the active video
`
`information from the memory in a sequence different from that in which it was
`
`stored.” (Ex. 1004 at 7:3-6). Scrambling in the digital domain is not the question.
`
`
`
`7
`
`
`
`
`
`Gilhousen clearly shows “scrambled TV” being transmitted as analog encoded
`
`information. (Ex. 1004, Figs. 1, 3; Ex. 2140, Fig. 4b, incorporated by reference).
`
`Alternatively, Apple argues an all-digital system would cure Gilhousen.
`
`Gilhousen clearly teaches his goal is to “reduce[] costs and increase[] reliability.
`
`The consumer hardware currently available … are compatible with this rate.” (Ex.
`
`1004 at 9:45-49). Gilhousen teaches away from an all-digital transmission based on
`
`Mr. Wechselberger’s statement that cost prevented adoption of an all-digital system.
`
`(Ex. 1027 at 4). Furthermore, Gilhousen selects his sampling rates and transmission
`
`scheme according to the NTSC (analog) standard. Apple leaps to the conclusion
`
`that bolting on an all-digital transmission would inherently achieve Gilhousen’s
`
`design goals overlooking the significant efforts, cost, and undue experimentation.
`
`(KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007); MPEP §§ 2141, 2143.).
`
`For claims 32-36, Apple combines Jeffers with Gilhousen to teach creating
`
`and automatically transmitting a digital record with a unique digital code
`
`identifying the receiver station. (Paper 29 at 13-14). Jeffers discloses an identity
`
`key only for decryption, and teaches exactly the contents of the subscriber unit
`
`transmission with the identity key completely absent. (Ex. 1066 at 14:54-68).
`
`Identification could occur through the unique time, date, and/or phone number of
`
`the call in. (Ex. 1066 at Figs. 6B, 6C). Apple’s expert combines Jeffers with other
`
`references using hindsight and conclusory statements, which is per se insufficient.
`
`
`
`8
`
`
`
`
`
`(In re ActiveVideo Networks, Inc., 694 F.3d 1312, 1327 (Fed.Cir.2012)).
`
`For claims 37-40, Apple erroneously identifies four memories in Jeffers,
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`when there are only three. (Paper 29 at 15-17). The decoder’s “non-volatile RAM”,
`
`identified by Apple as the claimed “reprogrammable nonvolatile memory”, is the
`
`BRAM 68 (battery-backed RAM). (Ex. 1066 at 11:9-16, Figs. 2A, 2B). Memories
`
`70, 72 are ROM. Apple fails to identify the distinctly claimed “random access
`
`memory.” (Ex. 2148). Furthermore, against Apple’s arguments (Paper 29 at 16), a
`
`CPU is an instruction-based device (Ex. 2144), not just any “processor.” Also,
`
`CPUs may only interact with RAM and ROM memories absent “reprogrammable
`
`nonvolatile memory.” (Ex. 1067). The combination is not a mere design choice
`
`because functionality determines the needed circuitry. For example, Gilhousen (Ex.
`
`2140 at 7:58-8:33, Fig. 4b, incorporated by reference), and Jeffers (Ex. 1066 at 8:1-
`
`12, 15:49-18:23, Figs. 3-6) both use the HBI; therefore, combining Jeffers into
`
`Gilhousen must result in removing pieces of the HBI. The new system is now
`
`beyond simple substitution with a predictable outcome. (MPEP § 2143). Apple
`
`argues Campbell’s “code 238” transmitted by PCS 50 (head end) (Paper 29 at 16)
`
`teaches a locally entered threshold code. (Ex. 1067 at 13:25-33, 14:9-28, Fig. 11).
`
`Campbell is silent as to entry of a threshold setting using a local input (Ex. 1067 at
`
`16:15-18:49, Fig. 13), or any “reprogrammable nonvolatile memory.” (Ex. 1067 at,
`
`9:62-68, Figs. 6-7). Apple fails to address outputting “said digital programming”
`
`
`
`9
`
`
`
`
`
`and separately claimed “also outputs information dependent on said digital data.”
`
`From the ‘507 Application, PMC supported the two elements as digital audio
`
`(transmitted digital programming) and a user’s stock portfolio performance graph
`
`(resulting from locally entered digital data stored in reprogrammable nonvolatile
`
`memory, and particular to a subscriber). (Paper 21 at 20-21, Ex. 2130 at 28-30).
`
`Contrary to claims 34 and 39, Gilhousen teaches two distinct methods:
`
`descrambling for the audio / video, and decrypting for the keys. (Paper 29 at 17; Ex.
`
`1004 at 19:28-30; Ex. 2141 at 4:20-33, Figs. 4-7). Gilhousen and the Substitute
`
`Claims distinguish the two methods. The Board’s construction of “decryptor” did
`
`not hold the method of decrypting should cover descrambling. (Ex. 2146 at 7-10).
`
`Unlike claims 36 and 40, Gilhousen teaches reception of analog, not digital, video
`
`and audio. (Paper 29 at 18; Ex. 1004 at Fig. 3 (line 47)).
`
`B.
`
`Substitute Claims are Patentable Over Seth-Smith
`
`For claims 32-43, Apple fails to show that digitally scrambled and analog
`
`output video transmission in Seth-Smith anticipates “transmission unaccompanied
`
`by any scrambled analog encoded information.” (Paper 24 at 18; Ex. 1064 at 12:62-
`
`66, 18:15-20, 19:28-30; Ex. 2141 at 1:51-60, 4:20-33, 9:30-37, Figs. 4-7,
`
`incorporated by reference). Next, Apple relies on a three sentence description of
`
`“full field mode” to presuppose that video (scrambled analog) is never sent in the
`
`claimed transmission. (Paper 29 at 19, Ex. 1064 at 16:60-65). Teletext is typically
`
`
`
`10
`
`
`
`
`
`transmitted with the TV signal, so this feature has limited use. (Ex. 1064 at 7:39-
`
`41). Full field mode may only be used for a single field, is not in the preferred
`
`embodiment, and is not necessarily used during the transmission of keys, which
`
`Apple relies on and only occurs hourly for KOM. (Ex. 1064 at 20:43-21:2, 23:16-
`
`52, Fig. 15). Seth-Smith is silent as to any details that may be investigated.
`
`For claims 32-36, Seth-Smith teaches, “it is highly undesirable that a
`
`continuous uplink or landline connection be provided.” (Ex. 1064 at 10:19-27,
`
`21:64-66). Seth-Smith teaches pay-per-view and record keeping using its one-way
`
`system. (Paper 29 at 20-21; Ex. 1064 at 9:38-40, 10:19-27, 17:45-66, 27:34-58).
`
`Seth-Smith teaches away from a user station uplink. Apple fails to show evidence
`
`the claims as a whole are obviated other than their own opinion and hindsight.
`
`Claims 37-40 require a CPU interacting with RAM. (Ex. 2143). The
`
`microprocessor 114 only receives information stored in RAM sent by the MATS
`
`processor. (Paper 29 at 22; Ex. 1064 at 28:34-40, Fig. 17). Seth-Smith fails because
`
`there is no reciprocal act. Next, Apple argues a passcode (Paper 29 at 22-23; Ex.
`
`1065 at 24:15-27) meets the claimed limitation “storing digital data … originated at
`
`said receiver station, … reprogrammable nonvolatile memory storing said digital
`
`data.” Seth-Smith is silent about how the passcode originates (possibly by PCS 50
`
`(headend)), where it is stored, and “also outputs information dependent on said
`
`digital data”, which is different from “outputting said digital programming.” For
`
`
`
`11
`
`
`
`
`
`claims 34 and 39, “full field mode” is addressed supra. (Section III. B.). For claims
`
`41-43, Apple’s identified single-bit “source switch” command does not designate a
`
`channel as claimed. The Board concurs. (Paper 14 at 45). For claims 36, 40, and
`
`43, Seth-Smith teaches audio assembled with scrambled video in a preferred
`
`embodiment, but is silent as to the audio in the non-preferred embodiment of the
`
`“full field mode” teletext relied upon by Apple. (Paper 29 at 25; Ex. 1064 at 9:46-
`
`55, 16:60-65). Teletext output does not have an audio component. (Ex. 2100).
`
`C.
`
`Substitute Claims are Patentable Over Other Prior Art
`
`Apple throws up Exs. 1005, 1028, and 1068-1070 as additional prior art;
`
`however, these references fall short and were already considered by PMC. They all
`
`fail even to suggest at least one of a two-way transmission system unaccompanied
`
`by scrambled analog, automatic tuning, an instruct-to-enable signal, video, audio,
`
`creating at a receiver station a digital record including a unique digital code for
`
`transmission from the receiver station, storing digital data comprising information
`
`particular to a subscriber originated at said receiver station, and outputting the
`
`digital programming and also information dependent on the digital data.
`
`D. There is no Meaningful Dispute Regarding Claim Construction
`
`There is no dispute between the parties as to the construction of claim terms.
`
`IV. CONCLUSION
`
`If all issued claims are deemed unpatentable, the motion should be granted.
`
`
`
`12
`
`
`
`
`
`
`
`Dated: April 12, 2017
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/ Thomas J. Scott, Jr. /
`By
`Thomas J. Scott, Jr.
`Registration No.: 27,836
`Senior Vice President & General Counsel
`
`Personalized Media
`Communications, LLC
`
`11491 Sunset Hills Road, Suite 340
`Reston, Virginia 20190
`Telephone: (281) 201-2213
`tscott@pmcip.com
`
`
`
`13
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing
`
`PATENT OWNER’S REPLY IN SUPPORT OF MOTION TO
`AMEND AND EXHIBITS 2140-2148
`
`was served on April 12, 2017 to the following attorneys of record by electronic
`transmission:
`
`Marcus E. Sernel, Joel R. Merkin, and Eugene Goryunov
`KIRKLAND & ELLIS LLP
`300 North LaSalle Street
`Chicago, Illinois 60654
`P: (312) 862-2000; F: (312) 862-2200
`marc.sernel@kirkland.com
`joel.merkin@kirkland.com
`eugene.goryunov@kirkland.com
`Apple-PMC-PTAB@kirkland.com
`
`Gregory S. Arovas
`KIRKLAND & ELLIS LLP
`601 Lexington Avenue
`New York, New York 10022
`P: (212) 446-4800; F: (212) 446-4900
`greg.arovas@kirkland.com
`
`Date: April 12, 2017
`
`
`
`/ Thomas J. Scott, Jr. /
`Thomas J. Scott, Jr.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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