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`Paper No.
`Filed: October 3, 2019
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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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`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
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`v.
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`UUSI, LLC d/b/a NARTRON
`Patent Owner
`____________________
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`Case IPR2016-00908
`Patent No. 5,796,183
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`Petitioner’s Opening Brief on Remand
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`Case No. IPR2016-00908
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`TABLE OF CONTENTS
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` Page
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`B.
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`C.
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`I.
`INTRODUCTION ........................................................................................... 1
`II. ARGUMENT ................................................................................................... 2
`A.
`Samsung’s Uncontested Evidence Demonstrates That a
`POSITA Would Have Expected Reasonable Success in
`Combining the Teachings of Gerpheide with the Ingraham I-
`Caldwell Combination ........................................................................... 2
`Samsung’s Uncontested Evidence Demonstrates That a
`POSITA Would Have Expected Reasonable Success in
`Combining the Teachings of Wheeler with the Ingraham I-
`Caldwell-Gerpheide Combination......................................................... 6
`“Supply Voltage” in Claim 37 Should Not Be Limited To the
`Oscillator Supply Voltage ..................................................................... 7
`1.
`The Plain and Ordinary Meaning of “Supply Voltage” Is
`Not Limited to the Oscillator Supply Voltage ............................ 8
`Nothing in the Specification or the Prosecution History
`Compels Limiting “Supply Voltage” Beyond Its Plain
`and Ordinary Meaning ..............................................................10
`Petitioner’s Evidence Shows That Claims 37-39 Are
`Unpatentable ........................................................................................14
`III. CONCLUSION ..............................................................................................15
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`2.
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`D.
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`i
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`Case No. IPR2016-00908
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`TABLE OF AUTHORITIES
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` Page(s)
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`Cases
`Apple Inc. v. UUSI, LLC d/b/a Narton,
`IPR2019-00358, Paper No. 12 (August 5, 2019) ................................................. 5
`Canon, Inc. v. Intellectual Ventures II LLC,
`IPR2014-00631, Paper No. 50 (Aug. 19, 2015) ................................................. 13
`Enzo Biochem, Inc. v. Applera Corp.,
`599 F.3d 1325 (Fed. Cir. 2010) ............................................................................ 9
`GE Lighting Solution., LLC v. AgiLight, Inc.,
`750 F.3d 1304 (Fed. Cir. 2014), reh’g denied (June 17, 2014) .......................... 10
`Oatey Co. v. IPS Corp.,
`514 F.3d 1271 (Fed. Cir. 2008) .......................................................................... 13
`Phillips v. AWH Corp.,
`415 F.3d 1303 (Fed. Cir. 2005) (en banc) ........................................................ 8, 9
`Samsung Elecs. Co. v. UUSI, LLC,
`775 F. App’x 692 (Fed. Cir. 2019) ............................................................... 1, 2, 3
`Thorner v. Sony Computer Entertainment America LLC,
`669 F.3d 1362 (Fed. Cir. 2012) ...................................................................... 8, 10
`Vitronics Corp. v. Conceptronic, Inc.,
`90 F.3d 1576 (Fed.Cir.1996) ................................................................................ 8
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`i
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`I.
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`Case No. IPR2016-00908
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`INTRODUCTION
`Petitioner submits this opening brief pursuant to the Board’s September 5,
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`2019 Order (Paper 41). This brief addresses the four issues mentioned in the Order,
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`including reasonable expectation of success for the Ingraham I-Caldwell-Gerpheide
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`combination and the construction of “supply voltage,” as recited in claim 37.
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`First, the uncontested evidence (including the teachings of the prior art itself)
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`demonstrates that a POSITA would have had a reasonable expectation of success in
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`combining the teachings of Gerpheide with the Ingraham I-Caldwell combination
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`consistent with well-established precedent, including the Federal Circuit’s decision
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`in Samsung Elecs. Co. v. UUSI, LLC, 775 F. App'x 692, 697 (Fed. Cir. 2019).
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`Second, Samsung’s uncontested evidence also demonstrates the reasonable
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`expectation of success in combining the teachings of Wheeler with the Ingraham I-
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`Caldwell-Gerpheide combination. Third, “supply voltage” in claim 37 should not
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`be limited to the “oscillator” supply voltage because the plain and ordinary meaning
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`of “supply voltage” is simply a voltage supplied to a circuit component but it is not
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`limited to a particular circuit component or device. Likewise, there is no definition
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`or disavowal in the ’183 patent specification or the prosecution history that would
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`compel limiting “supply voltage” to that of the “oscillator” in particular. Finally,
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`Petitioner’s evidence shows that claims 37-39 are unpatentable.
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`Hence, for the reasons set forth below and based on the totality of the evidence
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`in this proceeding, claims 37-41, 43, 45, 47, 48, 61-67, 69, 83-86, 88, 90, 91, 94, 96,
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`97, 99, 101, and 102 of the ’183 patent should be found unpatentable and canceled.
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`II. ARGUMENT
`Samsung’s Uncontested Evidence Demonstrates That a POSITA
`A.
`Would Have Expected Reasonable Success in Combining the
`Teachings of Gerpheide with
`the
`Ingraham
`I-Caldwell
`Combination
`The Federal Circuit held that the reasonable expectation of success test must
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`be tied to the claimed invention and thus Samsung was only required to demonstrate
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`that there was a reasonable expectation that the Ingraham I-Caldwell combination
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`could have been modified to select a frequency from multiple frequencies and
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`provide the selected “frequency” to the entire touch pad. Samsung Elecs., 775 F.
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`App'x at 697. Applying this test, Samsung’s uncontested evidence demonstrates that
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`a POSITA would have expected reasonable success in combining the teachings of
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`Ingraham I, Caldwell, and Gerpheide.
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`For instance, it is uncontested that the Ingraham I-Caldwell combination
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`includes a microcontroller and an oscillator, as shown by the exemplary block level
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`diagram (see below) of the Ingraham I-Caldwell combination set forth in the
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`declaration of Samsung’s expert
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`(Dr. Vivek Subramanian), where
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`the
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`microcontroller selectively provides the oscillator frequency to the input touch
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`terminals (i.e., the touch pad). (Ex. 1002, ¶¶64-68.)
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`(Id., ¶64.) Dr. Subramanian further explained that, in view of Gerpheide’s teachings
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`regarding frequency selection for interference negation, a POSITA would have been
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`motivated1 and capable of configuring the Ingraham I-Caldwell combination such
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`that an oscillator frequency would be selected from a plurality of frequencies and
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`provided to the touch pad array. (Id., ¶¶69-72). He testified that the selection of the
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`frequency would be performed by the microcontroller. (Id., ¶69.) He further
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`testified that the above modification of the Ingraham I-Caldwell combination based
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`on Gerpheide was “predictable” and within the capability of a skilled artisan. (Id.,
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`¶72; Ex. 1017, ¶14.)
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`1 As the Federal Circuit held, a POSITA would have been motivated to combine
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`Gerpheide’s teachings with the Ingraham I-Caldwell combination. Samsung Elecs.,
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`775 F. App'x at 696.
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`Gerpheide’s disclosure corroborated Dr. Subramanian’s above testimony.
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`Specifically, Gerpheide discloses a microcontroller 102 that varies the oscillator
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`signal frequency that is provided to the electrode array (the portions where the user
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`touches). (Ex. 1012, Figs. 4 7, 6:5-8, 6:19-26, 8:22-9:33; Ex. 1002, ¶71.) Gerpheide
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`explains that the microcontroller evaluates the interference and selects a new
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`reference frequency for the oscillator, which is then provided to the touch pad array.
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`(Ex. 1012, 8:22-9:33; Ex. 1002, ¶71.)
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`UUSI never contested the above evidence. For instance, UUSI never argued
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`that at the time of the alleged invention of the ’183 patent, a POSITA could not have
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`configured the Ingraham I-Caldwell combination such that the microcontroller
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`provided “frequencies” to the touch pad by selecting a frequency from available
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`frequencies.2 Instead, via its declarant (Dr. Darran Cairns), UUSI’s argument
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`2 UUSI could not have argued so because the ’183 patent does not disclose some
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`novel configuration for a microcontroller that is able to provide multiple frequencies.
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`In fact, the ’183 patent does not even disclose a microcontroller that provides
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`“frequencies.” (Ex. 1002, ¶69 n.7.) The Board found as much in another IPR
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`involving the ’183 patent, where the Board noted that the disclosed microcontroller
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`in the ’183 patent only provides a singular frequency during operation of the touch
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`focused on the bodily incorporation of Gerpheide’s interference algorithm and the
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`physical differences between the Ingraham I-Caldwell combination and Gerpheide.
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`(Ex. 2010, ¶¶ 115-118). In the four paragraphs of Dr. Cairns’ testimony, he included
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`one citation to Gerpheide and never addressed Gerpheide’s teaching that a
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`microcontroller could select an oscillator frequency from among multiple
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`frequencies. (Id.) His testimony was irrelevant to the proper test for reasonable
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`expectation of success. For instance, he stated, without even a citation to Gerpheide,
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`that the “drift in position used to determine interference would not work with the
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`Ingraham I-Caldwell system because Caldwell has an array of pads, not just one
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`pad.” (Id., ¶ 117). Neither did he explain what he meant by “drift in position.” (Id.,
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`¶¶ 115-18.)
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`Thus, given the evidence of record in this proceeding, the only reasonable
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`conclusion is that a POSITA would have expected reasonable success in combining
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`the teachings of Gerpheide with the Ingraham I-Caldwell combination. Indeed, such
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`a conclusion is consistent with patentee’s admission during its self-initiated
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`reexamination that, based on Gerpheide’s teachings, a POSITA would have found it
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`“obvious” to modify a single frequency touch circuit system to one where multiple
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`circuit. Apple Inc. v. UUSI, LLC d/b/a Narton, IPR2019-00358, Paper No. 12 at 28-
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`29 (August 5, 2019).
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`“frequencies” (i.e., plural frequencies) are provided to the touch terminals. (Ex.
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`1006 at 331; Pet. at 27 n7.) By stating that such a modification is “obvious,” patentee
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`necessarily admitted that there would have been a reasonable expectation of success
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`for making the modification.
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`B.
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`Samsung’s Uncontested Evidence Demonstrates That a POSITA
`Would Have Expected Reasonable Success in Combining the
`Teachings of Wheeler with the Ingraham I-Caldwell-Gerpheide
`Combination
`The Federal Circuit’s decision does not directly address the Ingraham I-
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`Caldwell-Gerpheide-Wheeler combination relevant to claims 47, 48, 62, 63, and 84.
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`But the decision is nonetheless instructive in that it confirms well-settled law that
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`reasonable expectation of success must be shown for the “claimed” invention (not
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`unclaimed features). Samsung Elecs., 775 F. App'x at 697. As explained in
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`Samsung’s petition and supporting evidence, a POSITA would have had a
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`reasonable expectation of success combining the teachings of Wheeler with the
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`Ingraham I-Caldwell-Gerpheide combination.
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`Specifically, claim 47 requires the comparison of the sensed body capacitance
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`change to ground to a “second threshold level to generate the control output signal.”
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`Dr. Subramanian explained that the Ingraham I-Caldwell-Gerpheide combination
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`would be have been modified based on Wheeler to include logic that would prevent
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`generation of the control signal until two input portions 13 (in Ingraham I) are
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`activated in sequence, which would require comparison of the body capacitance
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`change with a first threshold (corresponding to a first input portion 13) and a second
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`threshold (corresponding to a second input portion 13). (Ex. 1002, ¶¶139-141.) He
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`testified that “one of ordinary skill at the time of the alleged invention for the ’183
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`patent would have had the knowledge and capability to make this modification with
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`predictable success . . . .” (Id., ¶142.) UUSI’s declarant simply did not address Dr.
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`Subramanian’s expert opinion and only submitted an unsupportable allegation that
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`Wheeler is in a different field. (Ex. 2010, ¶178.) Thus, Samsung’s uncontested
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`evidence demonstrates that a POSITA would have had a reasonable expectation of
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`success in combining the teachings of Wheeler with the Ingraham I-Caldwell-
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`Gerpheide combination.
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`C.
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`“Supply Voltage” in Claim 37 Should Not
`Be Limited To the Oscillator Supply Voltage
`Claim 37 recites, inter alia, “an oscillator providing a periodic output signal
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`having a predefined frequency, wherein an oscillator voltage is greater than a supply
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`voltage.” (Ex. 1001 at 35 (2:45-47).) In the Institution Decision, the Board
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`construed “supply voltage” as recited in claim 37 as “a supply voltage of the
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`oscillator.” (Paper 12 at 9 (emphasis added).) Samsung respectfully submits that
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`this preliminary construction is not correct. First, the plain and ordinary meaning of
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`“supply voltage” is not limited to a particular device (e.g., oscillator). Second, by
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`limiting “supply voltage” to the oscillator supply voltage, the Institution Decision
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`improperly limited claim 37 to an exemplary embodiment while excluding from the
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`scope of claim 37 other embodiments of the ’183 patent.
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`1. The Plain and Ordinary Meaning of “Supply Voltage”
`Is Not Limited to the Oscillator Supply Voltage
`It is well-settled that “claim terms must be given their plain and ordinary
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`meaning to one of skill in the art.” Thorner v. Sony Comput. Entm’t Am. LLC, 669
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`F.3d 1362, 1367 (Fed. Cir. 2012) (citing Phillips, 415 F.3d at 1316). “There are only
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`two exceptions to this general rule: 1) when a patentee sets out a definition and acts
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`as his own lexicographer, or 2) when the patentee disavows the full scope of a claim
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`term either in the specification or during prosecution.” Id. at 1365 (citing Vitronics
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`Corp. v. Conceptronic, Inc., 90 F.3d 1576, 1580 (Fed.Cir.1996)).
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`The plain and ordinary meaning of “supply voltage” is simply the voltage
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`supplied to a circuit component. But claim 37 does not specify whether the claimed
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`“supply voltage” is limited to the voltage supply of a particular component (e.g., a
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`microcontroller or oscillator). The claim simply recites that “an oscillator voltage is
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`greater than a supply voltage” of any unspecified component, not that the oscillator
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`voltage is greater than a supply voltage “of the oscillator” in particular, as construed
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`in the Institution Decision. Moreover, the presence of “a” before “supply voltage”
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`suggests that the claimed “supply voltage” is not referring to a particular component.
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`Thus, Samsung respectfully disagrees that the construction set forth in the Institution
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`Decision is “grounded in the plain language of the claim.” Decision on Rehearing
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`(Paper 17) at 5. While it is true that “punctuation and transition term[s]” should be
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`Case No. IPR2016-00908
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`considered in determining the meaning of a claim term, the presence of a
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`“semicolon” after “supply voltage” and the use of the transition term “wherein” do
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`not compel the preliminary construction. Id. at 5.
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`Moreover, the language of other claims of the ’183 patent counsels against the
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`narrow interpretation of “supply voltage” in the Institution Decision. For instance,
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`claims 54 and 55 recite that the “supply voltage is a battery supply voltage” and “the
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`supply voltage is a voltage regulator supply voltage,” respectively. (See also Ex.
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`1001 at claims 81, 82, 90, 91, 101, 102.) These claims indicate that if patentee
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`wanted to be more specific regarding the scope of “supply voltage” in claim 37, it
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`would have done so. Phillips v. AWH Corp., 415 F.3d 1303, 1314 (Fed. Cir. 2005)
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`(en banc) (“the usage of a term in one claim can often illuminate the meaning of the
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`same term in other claims.”) Given the patentee did not limit the “supply voltage”
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`in claim 37 in any fashion when it could have easily done so, the term should not
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`now be limited to a supply voltage “of the oscillator.” See Enzo Biochem, Inc. v.
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`Applera Corp., 599 F.3d 1325, 1333 (Fed. Cir. 2010) (rejecting construction that
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`added limitation where “applicants knew how to claim . . . but specifically omitted
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`that language from the claims”). Here, patentee intentionally sought and obtained
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`from the patent office a broad claim scope for the “supply voltage” term; it is only
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`fair that patentee bear the consequences of that choice.
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`2. Nothing in the Specification or the Prosecution History
`Compels Limiting “Supply Voltage” Beyond Its Plain
`and Ordinary Meaning
`The Institution Decision reads in an added limitation “of the oscillator” to the
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`otherwise broad term “supply voltage” because, according to the decision, “[s]uch
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`an understanding is consistent with the Specification, which discloses voltage
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`regulator 100 provides supply voltages 104, 105, and 106 to oscillator 200.”
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`(Paper 12 at 9, citing Ex. 1001, 11:64-12:29, Figs. 4, 5.) But an exemplary
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`embodiment cannot limit the claim “absent a clear indication in the intrinsic record
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`that the patentee intended the claims to be so limited.” GE Lighting Sols., LLC v.
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`AgiLight, Inc., 750 F.3d 1304, 1309 (Fed. Cir. 2014), reh’g denied (June 17, 2014)
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`(citations omitted). Indeed, in the absence of definition or disavowal, claim terms
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`must be given their plain and ordinary meaning. Thorner, 669 F.3d at 1365. Here,
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`there is no clear indication (e.g., a definition or disavowal or disclaimer) in the
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`specification or the prosecution history that would compel limiting “supply voltage”
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`beyond its plain and ordinary meaning. The portion of the specification cited by the
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`Board (Ex. 1001, 11:64-12:29, Figs. 4, 5) only provides an example in which the
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`oscillator output voltage is greater than the oscillator supply voltage. It does not
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`purport to define “supply voltage” as limited to that “of the oscillator” and thus
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`cannot serve to limit the otherwise broader “supply voltage” limitation beyond its
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`plain meaning. Thorner, 669 F.3d at 1365.
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`If anything, the specification shows that the term “supply voltage” should not
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`be limited to the oscillator supply voltage because doing so would exclude from the
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`claim scope other embodiments in which the claimed “supply voltage” is the supply
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`voltage of other components (e.g., microcontroller and voltage regulator).
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`Specifically, the limitation at issue requires “wherein an oscillator voltage is greater
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`than a supply voltage.” (Ex. 1001 at 35 (2:45-47).) The embodiment described with
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`reference to Figure 4 (reproduced below) discloses that the output voltage of the
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`oscillator 200 is 26V. (Id. at 12:6-8, FIG. 4.) In that embodiment, a floating
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`common generator 300 receives the 26V signal from oscillator 200 and “supplie[s]”
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`a 21V signal to microcontroller 500 on line 301. (Id. at 12:13-22, FIG. 4.) The
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`embodiment of Figure 11 retains this aspect of the Figure 4 embodiment. (Id. at
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`18:34-43; compare id. at FIG. 4, with FIG. 11.) Therefore, in both the Figure 4 and
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`Figure 11 embodiments, the “supply voltage” for microcontroller 500 is a 21V
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`signal. Because the oscillator output voltage (i.e., 26V) is greater than the
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`microcontroller 500 supply voltage (i.e., 21V), the microcontroller 500 supply
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`voltage satisfies the requirement of claim 37 that “an oscillator voltage is greater
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`than a supply voltage.”
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`(Id. at FIG. 4 (annotated).)
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`Similarly, voltage regulator 100 includes “input lines 101 and 102 for
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`receiving a 24 V AC line voltage.” (Id. at 11:64-66 (emphasis added), FIG. 4.) The
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`oscillator 200 output voltage (i.e., 26V) is also greater than the 24V supply voltage
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`provided on lines 101 and 102 as a result of which the voltage regulator 100 “supply
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`voltage” also satisfies the requirement of claim that “an oscillator voltage is greater
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`than a supply voltage.” Therefore, the ’183 patent discloses a supply voltage for
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`each of microcontroller 200 and voltage regulator 100 that satisfies the plain
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`language of claim 37.
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`As such, “supply voltage” should not be limited to the oscillator supply
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`voltage because doing so would exclude other embodiments of the specification.
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`12
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`Oatey Co. v. IPS Corp., 514 F.3d 1271, 1276 (Fed. Cir. 2008) (“We normally do not
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`Case No. IPR2016-00908
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`interpret claim terms in a way that excludes embodiments disclosed in the
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`specification.”); Canon, Inc. v. Intellectual Ventures II LLC, IPR2014-00631, Paper
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`No. 50 at 12-13 (Aug. 19, 2015) (not limiting scope of “selecting” to selecting by a
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`“user” when specification suggested that the selection could also be performed by
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`the “image capture device”).
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`Nor does the prosecution history compel the narrow construction in the
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`Institution Decision. The limitation “wherein an oscillator voltage is greater than a
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`supply voltage” was added during reexamination without any indication that “supply
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`voltage” should be limited to the oscillator supply voltage. (Ex. 1005 at 16-52.) In
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`fact, the prosecution history supports Petitioner’s interpretation that “supply
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`voltage” is not limited to the oscillator supply voltage. This is because when
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`describing the support in the ’183 patent for this limitation, patentee referenced
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`portions of the ’183 specification that discuss the voltage regulator supply voltage.
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`(Id. at 42 (citing Ex. 1001 at 12:50-57, 12:58-13:31).)
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`Thus, Petitioner respectfully submits that in contrast to the Institution
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`Decision’s limiting construction, the plain and ordinary meaning of the claimed “a
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`supply voltage,” as applied by Petitioner in the Petition (Paper 2 at 11-15 (no
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`construction offered), 18-19 (Ground 1, claim element 37(c)), is consistent with and
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`supported by evidence of record, namely the ’183 patent (Ex. 1001) and the
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`13
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`prosecution history (Ex. 1004). Consequently, Petitioner respectfully requests that
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`the Board reconsider its preliminary construction of “supply voltage” and interpret
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`the term consistent with the ’183 patent specification and the term’s plain and
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`ordinary meaning, which can include “a supply voltage” of components other than
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`the oscillator.
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`Petitioner’s Evidence Shows That Claims 37-39 Are Unpatentable
`D.
`The Board denied institution (and hence, found that Petitioner could not
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`prevail with respect to claims 37-39) by erroneously limiting “supply voltage” in
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`claim 37 to the supply voltage of the oscillator. As discussed above in Section II.A,
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`“supply voltage” is not so limited and when given its proper breadth, Ingraham I in
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`combination with Caldwell discloses “an oscillator voltage [that] is greater than a
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`supply voltage” as claimed. (Paper 2 at 18-19; Ex. 1002 at ¶ 50.) For instance,
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`Ingraham I, via the incorporated teachings of Ingraham II, discloses that an
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`oscillator voltage (115V) is greater than a supply voltage (15V) of the
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`microcomputer 80 in the combined Ingraham I-Caldwell system. (Pet. at 19; Ex.
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`1002 at ¶¶ 50-51.) Moreover, the remaining claim limitations of claims 37-39 are
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`disclosed by the Ingraham I-Caldwell-Gerpheide combination and the evidence of
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`record in this proceeding demonstrates that a POSITA would have been motivated
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`to combine the teachings of these references to reach the claimed invention with a
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`reasonable expectation of success. (Pet. at 15-39; Ex. 1002 at ¶¶41-88.)
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`III. CONCLUSION
`For the foregoing reasons and based on the evidence of record in this
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`Case No. IPR2016-00908
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`proceeding, Petitioner submits that the challenged claims are unpatentable and
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`should be canceled.
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`Dated: October 3, 2019
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`Respectfully submitted,
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`By: /Naveen Modi/
` Naveen Modi
` Reg. No. 46,224
` Counsel for Petitioner Samsung
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`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), I certify that I caused to be served on the
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`counsel for Patent Owner a true and correct copy of the foregoing Petitioner’s
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`Opening Brief on Remand by electronic means on the date below at the following
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`address of record:
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`sunderwood@glaserweil.com
`jweir@glaserweil.com
`lhadley@glaserweil.com
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`Dated: October 3, 2019
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`Respectfully submitted,
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`By: /Naveen Modi/
` Naveen Modi
` Reg. No. 46,224
` Counsel for Petitioner Samsung
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