U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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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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`RUBICON COMMUNICATIONS, LP
`Petitioner,
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`v.
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`LEGO A/S
`Patent Owner.
`____________
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`Case IPR2016-01187
`Patent 8,894,066
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`MOTION FOR OBSERVATIONS ON CROSS-EXAMINATION
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`OF PETITIONER’S REPLY WITNESS
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`Motion for Observations on Cross-Examination
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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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`RUBICON COMMUNICATIONS, LP
`Petitioner,
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`v.
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`LEGO A/S
`Patent Owner.
`____________
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`Case IPR2016-01187
`Patent 8,894,066
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`MOTION FOR OBSERVATIONS ON CROSS-EXAMINATION
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`OF PETITIONER’S REPLY WITNESS
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`U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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`Patent Owner respectfully submits this Motion for Observation on Cross-
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`Examination of Petitioner’s Reply Witness, Dr. Jay P. Kesan, conducted on
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`September 28, 2017. Patent Owner’s observations on cross-examination set forth
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`the following portions of the Transcript of the Testimony of Jay Kesan (Ex. 2030)
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`for the Board’s consideration:
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`1.
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`In Ex. 2030, on page 5, lines 10–13, the witness testified “I started out
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`studying electrical engineering and got my Bachelor’s and Master’s and Ph.D.,
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`finishing with a Ph.D. in electrical and computer engineering . . . .” This testimony
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`relates to Dr. Kesan’s declaration wherein he states that he has been retained as an
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`expert regarding the ’066 Patent, stated in Ex. 1036 ¶ 2. The testimony is relevant
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`because Dr. Kesan’s educational background and qualifications are inconsistent
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`with the uncontested definition of a person of ordinary skill in the art as of the time
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`of the invention.
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`2.
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` In Ex. 2030, on page 9, lines 1–4, the witness testified “we were interested
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`in high speed circuitry. We were interested in integrated circuits of various kinds.
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`We did some processing, some material science.” This testimony relates to Dr.
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`Kesan’s declaration wherein he states that he has been retained as an expert
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`regarding the ’066 Patent, stated in Ex. 1036 ¶ 2. The testimony is relevant because
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`Dr. Kesan’s educational background and qualifications are inconsistent with the
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`uncontested definition of a person of ordinary skill in the art as of the time of the
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`U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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`invention.
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`3.
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`In Ex. 2030, on page 10, lines 2–13, the witness testified “Basically, at that
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`time, it was mostly sort of integrated circuits and packaging of those. . . . You
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`know, you have all sorts of, you know, dual inline packages and various kinds of—
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`you know, you have a semiconductor chip and, you know, you have a die, and then
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`you have some sort of plastic or some sort of synthetic material that you place the
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`die in, and there’s usually—there’s some electrical leads that have to be
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`accommodated and properly packaged.” This testimony relates to Dr. Kesan’s
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`declaration wherein he states that he has been retained as an expert regarding the
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`’066 Patent, stated in Ex. 1036 ¶ 2. The testimony is relevant because Dr. Kesan’s
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`educational background and qualifications are inconsistent with the uncontested
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`definition of a person of ordinary skill in the art as of the time of the invention.
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`4.
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`In Ex. 2030, on page 12, lines 13–19, the witness testified “So it has
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`involved sometimes utility patents, sometimes design patents in things like, for
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`example, you know, regular power supplies that people use for laptops,
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`smartphones, set-top boxes, wireless audio equipment. These are just some of the
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`things that come to mind right now, but they all involve, you know, things like
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`product design or packaging.” This testimony relates to Dr. Kesan’s declaration
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`wherein he states that he has been retained as an expert regarding the ’066 Patent,
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`stated in Ex. 1036 ¶ 2. The testimony is relevant because Dr. Kesan’s educational
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`U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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`background and qualifications are inconsistent with the uncontested definition of a
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`person of ordinary skill in the art as of the time of the invention.
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`5.
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`In Ex. 2030, on page 13, lines 17–21, the witness testified “Yeah, I’ve not
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`been in the position where I was responsible for a particular consumer product, but,
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`I mean, obviously things like—as I mentioned before, things like how chips are
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`packaged and so on, it’s found in every consumer product.” This testimony relates
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`to Dr. Kesan’s declaration wherein he states that he has been retained as an expert
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`regarding the ’066 Patent, stated in Ex. 1036 ¶ 2. The testimony is relevant
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`because Dr. Kesan’s educational background and qualifications are inconsistent
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`with the uncontested definition of a person of ordinary skill in the art as of the time
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`of the invention.
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`6.
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`In Ex. 2030, on page 23, lines 5–7, the witness testified “I think the word
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`‘conformably fit’ suggests that it comes together in a snug fit or, you know,
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`friction fit.” This testimony relates to Petitioner’s position that the term
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`“conformably fit” must encompass joining by abutment, stated on pages 4–5 of the
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`Reply. The testimony is relevant because it concerns Dr. Kesan’s understanding of
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`the term “conformably fit.”
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`7.
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`In Ex. 2030, on page 24, line 21–page 25, line 2, the witness testified “You
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`have corresponding portions in one respect or the other, so one is—one
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`conformably fits with the other—the casing conformably fits with the housing.”
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`U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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`This testimony relates to Petitioner’s position that the term “conformably fit” must
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`encompass joining by abutment, stated on pages 4–5 of the Reply. The testimony is
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`relevant because it concerns Dr. Kesan’s understanding of the term “conformably
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`fit.”
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`8.
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`In Ex. 2030, on page 25, line 19–page 26, line 1,when asked “You would
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`agree, would you not, that conformably fit requires more than two objects simply
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`touching?”, the witness testified “Yeah. I mean, it would need to be—they would
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`need to conform with each other.” This testimony relates to Petitioner’s position
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`that the term “conformably fit” must encompass joining by abutment, stated on
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`pages 4–5 of the Reply. The testimony is relevant because it concerns Dr. Kesan’s
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`understanding of the term “conformably fit.”
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`9.
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`In Ex. 2030, on page 28, line 19–page 29, line 1, the witness testified
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`“you’re definitely trying to capture the user’s preference for how those symbols or
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`images on the display are to be manipulated. That’s certainly what you’re trying to
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`do when you have, you know, a manual controller like this one.” This testimony
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`relates to Petitioner’s position that the term “manipulate” means “changing with or
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`as if with the hands, or by mechanical or electronic means,” stated on pages 5–7 of
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`the Reply. The testimony is relevant because it concerns Dr. Kesan’s
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`understanding of the term “manipulate.”
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`10.
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`In Ex. 2030, on page 29, lines 12–15, when asked “When you say
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`U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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`‘changing’ in your definition, what manner of change do you intend by that?”, the
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`witness testified “Typically in these sort of things, you’re just moving those
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`symbols and images on the display.” This testimony relates to Petitioner’s position
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`that the term “manipulate” means “changing with or as if with the hands, or by
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`mechanical or electronic means,” stated on pages 5–7 of the Reply. The testimony
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`is relevant because it concerns Dr. Kesan’s understanding of the term
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`“manipulate.”
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`11.
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`In Ex. 2030, on page 45, line 22–page 46 line 2, when asked “Did you rely
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`on the petition in forming your opinion?”, the witness testified “No I didn’t.” This
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`testimony relates to Dr. Kesan’s declaration wherein he states that he considered
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`the Petition, in Ex. 1036 ¶ 8. The testimony is relevant because it explains new
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`arguments not previously raised in the Petition.
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`12.
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`In Ex. 2030, on page 47, line 20–page 48, line 4, when asked if any of the
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`examples of the ’066 patent supported the term “portion” meaning an entirety, the
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`witness testified “Not that I recall, but it certainly doesn't exclude it.” This
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`testimony relates to Petitioner’s position that Philo anticipates Claim 1, stated on
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`pages 11–12 of the Reply. The testimony is relevant because it concerns Dr.
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`Kesan’s understanding of the term “portion.”
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`13.
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`In Ex. 2030, on page 48, lines 11–15, the witness testified “Again, you
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`know, I haven’t done a search for entire or whole or any such thing, but as I
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`U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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`recall—I can’t point to anything right now, but I do recall trying to see if portion
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`was defined in any particular way.” This testimony relates to Petitioner’s position
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`that Philo anticipates Claim 1, stated on pages 11–12 of the Reply. The testimony
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`is relevant because it concerns Dr. Kesan’s understanding of the term “portion.”
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`14.
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`In Ex. 2030, on page 54, lines 3–5, the witness testified “I don’t think it’s
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`rotated, but, you know, the walking pattern goes away and it’s replaced by a
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`number, so that’s what you see.” This testimony relates to Petitioner’s position that
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`Philo anticipates Claim 1, stated on pages 13–14 of the Reply. The testimony is
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`relevant because it concerns the meaning of the term “manipulate.”
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`15.
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`In Ex. 2030, on page 56, lines 2–6, when asked “How do you distinguish a
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`gripping portion from a non-gripping portion?”, the witness testified “Something
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`that is capable of being gripped by a hand. I guess that’s why it’s called a hand grip
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`section.” This testimony relates to Petitioner’s position that Philo anticipates Claim
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`5, stated on pages 15–16 of the Reply. The testimony is relevant because it
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`concerns Dr. Kesan’s understanding of the term “hand grip section.”
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`16.
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`In Ex. 2030, on page 57, lines 8–12, when asked “Is there anything in the
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`disclosure of Philo that would suggest grasping Brick Simon by the stand?”, the
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`witness testified “I mean, not that I recall, but it’s clear that those structural
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`features are disclosed, and they allow the Brick Simon to be grasped.” This
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`testimony relates to Petitioner’s position that Philo anticipates Claim 5, stated on
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`U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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`pages 15–16 of the Reply. The testimony is relevant because it admits that Philo
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`does not disclose a “hand grip section.”
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`17.
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`In Ex. 2030, on page 66, lines 2–3, the witness testified “Yeah, I haven’t
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`compared this declaration of mine to the original petition.” This testimony relates
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`to Dr. Kesan’s declaration that he considered the Petition, stated in Ex. 1036 ¶ 8.
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`The testimony is relevant because it explains new arguments not previously raised
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`in the Petition.
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`18.
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`In Ex. 2030, on page 68, lines 9–13, when asked whether the witness took a
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`position as to the knowledge of one of ordinary skill in the art, the witness testified
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`“It may be a point that I did not contest. In other words, it may have been a point
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`that I was in agreement with the patent owner.” This testimony is relevant to
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`Petitioner’s position regarding what would have been inherent or obvious to one of
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`ordinary skill, stated on pages 13, 15, 19, 24, 25, 26, 28 of the Reply. The
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`testimony is relevant because it concerns the level of one of ordinary skill in the
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`art.
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`19.
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`In Ex. 2030, on page 71, lines 6–18, the witness testified “I mean, I’m not
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`saying that there is specific language in the Brick Simon that says you should grasp
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`this feature or that feature. I’m just simply pointing out that the Brick Simon
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`design is such that there are structural features available that can be grasped during
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`play activity. . . . Like I said, I’m not saying that there’s anything in Brick Simon
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`U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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`that says, you know, you should grasp, you know, this part or some other part.”
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`This testimony relates to Petitioner’s position that Philo anticipates Claim 5, stated
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`on pages 15–16 of the Reply. The testimony is relevant because it admits that Philo
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`does not disclose a “hand grip section.”
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`20.
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`In Ex. 2030, on page 73, lines 15–18, the witness testified “I don’t know
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`how it was used specifically, but I’m just—as a person of ordinary skill in the art, I
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`know what infrared communications is and what it’s used for and how that works.”
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`This testimony relates to Petitioner’s position that combining Philo, Building
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`Robots, and a cellular telephone would have been obvious to one of ordinary skill
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`in the art, stated on pages 18–19 of the Reply. The testimony is relevant because it
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`applies knowledge of a skilled artisan that is inconsistent with the uncontested
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`definition of a person of ordinary skill in the art as of the time of the invention.
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`21.
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`In Ex. 2030, on page 75, lines 12–15, when asked “And in addition to
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`receiving the IR signal, you would have to be able to interpret that signal?”, the
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`witness testified “I’m sure there’s some signal processing, circuitry that goes along
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`with the receiver, yeah.” This testimony relates to Petitioner’s position that
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`combining Philo, Building Robots, and a cellular telephone would have been
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`obvious to one of ordinary skill in the art, stated on pages 18–19 of the Reply. The
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`testimony is relevant because it concerns what is required to combine a cellular
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`U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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`telephone and cited references.
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`22.
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`In Ex. 2030, on page 76, lines 4–8, when asked “Is there any indication that
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`this device could communicate with anything other than another palmOne Treo?”,
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`the witness testified “I don’t think that is discussed in this document, but it doesn’t
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`limit it that way.” This testimony relates to Petitioner’s position that combining
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`Philo, Building Robots, and a cellular telephone would have been obvious to one
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`of ordinary skill in the art, stated on pages 18–19 of the Reply. The testimony is
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`relevant because it admits that Ex. 1043 does not disclose how to combine a
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`cellular telephone with other devices.
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`23.
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`In Ex. 2030, on page 77, lines 11–12, the witness testified “I mean, you have
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`to have the capability to receive an IR signal and process it, yeah.” This testimony
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`relates to Petitioner’s position that combining Philo, Building Robots, and a
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`cellular telephone would have been obvious to one of ordinary skill in the art,
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`stated on pages 18–19 of the Reply. The testimony is relevant because it concerns
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`what is required to combine a cellular telephone and cited references.
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`24.
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`In Ex. 2030, on page 81, lines 14–21, when asked to point to the passages in
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`Philo and Building Robots where images on a display are manipulated in response
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`to commands communicated by infrared transmission, the witness testified “So I
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`don't recall specifically seeing infrared communications being used to manipulate
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`images, but using infrared communications to manipulate images is not required by
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`the claim.” This testimony relates to Petitioner’s position that combining Philo,
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`U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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`Building Robots, and a cellular telephone renders obvious Claim 1, stated on pages
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`18–19 of the Reply. The testimony is relevant because it concerns Claim 1 from
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`which Claim 7 depends.
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`25.
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`In Ex. 2030, on page 82, lines 12–19, when asked to identify other cell
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`phones that use IR communications, the witness testified “I’m not sure, but I want
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`to say that at the time with the palmOne Treo, I think devices such as Handspring,
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`et cetera, also I think had IR ports, but I'm not—I'm going from memory.” This
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`testimony relates to Petitioner’s position that combining Philo, Building Robots,
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`and a cellular telephone would have been obvious, stated in Ex. 1036 ¶¶ 65, 67.
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`The testimony is relevant because it contradicts the assertion that IR
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`communication’s use in cellular telephone devices was widespread.
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`26.
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`In Ex. 2030, on page 82, line 20–page 83, line 5, when asked who located
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`the palmOne Treo reference, the witness testified “I think it was shown to me, I
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`think, by counsel, if I—if I recall.” This testimony relates to Petitioner’s position
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`that combining Philo, Building Robots, and a cellular telephone would have been
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`obvious, stated in Ex. 1036 ¶¶ 65, 67. The testimony is relevant because it
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`contradicts that IR communication’s use in cellular telephone devices was
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`widespread.
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`27.
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`In Ex. 2030, on page 83, line 21–page 84, line 4, when asked whether what
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`he meant by “common knowledge of one of ordinary skill” was the skill that the
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`U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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`witness posses as one in the art, the witness testified “No. I mean, I'm just looking
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`at it as somebody who has some knowledge, probably has a Bachelor's degree in
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`engineering.” This testimony relates to Petitioner’s position regarding what would
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`have been inherent or obvious to one of ordinary skill, stated on pages 13, 15, 19,
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`24, 25, 26, 28 of the Reply. The testimony is relevant because Dr. Kesan states
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`qualifications of one of ordinary skill in the art that is inconsistent with the
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`uncontested definition of a person of ordinary skill in the art as of the time of the
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`invention.
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`28.
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`In Ex. 2030, on page 84, line 8–page 85, line 1, the witness testified that a
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`person of ordinary skill in the art would have “an engineering degree and a couple
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`of years of work experience.” This testimony is relates to Petitioner’s position
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`regarding what would have been inherent or obvious to one of ordinary skill, stated
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`on pages 13, 15, 19, 24, 25, 26, 28 of the Reply. The testimony is relevant because
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`Dr. Kesan states qualifications of one of ordinary skill in the art that is inconsistent
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`with the uncontested definition of a person of ordinary skill in the art as of the time
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`of the invention.
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`29.
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`In Ex. 2030, on page 88, lines 11–12, the witness testified “it’s surrounded
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`on all sides by the casing.” This testimony relates to Petitioner’s position that
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`Anderson anticipates Claim 1, stated on pages 24–27 of the Reply. The testimony
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`U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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`is relevant because it concerns Dr. Kesan’s understanding of the term “portion.”
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`30.
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`In Ex. 2030, on page 89, lines 9–11, when asked whether the controller 606
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`in FIG. 6 or 406 in FIG. 4 is embedded in the casing 602 or 404, the witness
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`testified “the word ‘portion’ simply means some percentage that’s, you know,
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`more than zero and extending to 100.” This testimony relates to Petitioner’s
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`position that Anderson anticipates Claim 1, stated on pages 24–27 of the Reply.
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`The testimony is relevant because it concerns Dr. Kesan’s understanding of the
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`term “portion.”
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`31.
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`In Ex. 2030, on page 90, lines 3–7, when asked “But every example that’s
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`given in the ’066 patent, that portion is less than 100 percent. Is that not correct?”,
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`the witness testified “I believe that is correct. As I recall, the examples were less
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`than 100 percent.” This testimony relates to Petitioner’s position that Anderson
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`anticipates Claim 1, stated on pages 24–27 of the Reply. The testimony is relevant
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`because it indicates the lack of basis for Dr. Kesan’s broad definition of the term
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`“portion.”
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`32.
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`In Ex. 2030, on page 91, lines 9–12, the witness testified “It doesn’t exactly
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`say where because the line is dashed, so we don’t quite know where exactly it is,
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`but—but, yeah, it could be completely inside. Yes, I agree. It could be.” This
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`testimony relates to Petitioner’s position that Anderson anticipates Claim 1, stated
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`on pages 24–27 of the Reply. The testimony is relevant because it explains Dr.
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`U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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`Kesan’s understanding of FIG. 4 of Anderson.
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`33.
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`In Ex. 2030, on page 91, lines 13–19, discussing the correspondence of the
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`Anderson disclosure with the ’066 Patent, the witness testified “What I'm simply
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`saying here is that the casing and the housing conformably fit in Anderson, just
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`like the casing and the housing conformably fit in the ’066 patent. That's all I'm
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`saying. It's just a question of matching forms and dimensions.” This testimony
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`relates to Petitioner’s position that Anderson anticipates Claim 1, stated on pages
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`24–27 of the Reply. The testimony is relevant because it concerns FIG. 4 of
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`Anderson.
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`34.
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`In Ex. 2030, on page 92, line 21–page 93, line 3, discussing the relationship
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`between elements 606 and 602 in FIG. 6 of Anderson, the witness testified “Yeah,
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`I mean I’m just simply saying that the way 606 and 602 relate to each other shows
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`that they—their forms and dimensions match, and so one conformably fits around
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`the other.” This testimony relates to Petitioner’s position that Anderson anticipates
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`Claim 1, stated on pages 24–27 of the Reply. The testimony is relevant because it
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`concerns FIG. 6 of Anderson.
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`35.
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`In Ex. 2030, on page 93, line 17–page 94, line 3, when asked whether, if a
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`judge were to find that “portion” meant less than 100 percent, then element 602 of
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`FIG. 6 of Anderson would not “conformably fit” around only a portion of device
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`606, the witness testified “I think there is still some ambiguity, but the figures do
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`seem to show that it’s surrounded on all four side, yes.” This testimony relates to
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`U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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`Petitioner’s position that Anderson anticipates Claim 1, stated on pages 24–27 of
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`the Reply. The testimony is relevant because it concerns FIG. 6 of Anderson.
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`36.
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`In Ex. 2030, on page 105, lines 18–21, the witness testified “The reference
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`itself does not say, yes, you can replace the computer with a cell phone, but it
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`doesn’t need to. You know, a person of ordinary skill in the art would understand
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`that.” This testimony relates to Petitioner’s position that combining Philo,
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`Building Robots, and a cellular telephone would have been obvious to one of
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`ordinary skill in the art, stated on pages 18–19 of the Reply. The testimony is
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`relevant because Dr. Kesan admits that Ex. 1043 does not disclose how to combine
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`a cellular telephone with other devices and applies knowledge of a skilled artisan
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`inconsistent with the uncontested definition of a person of ordinary skill in the art
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`as of the time of the invention.
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`Respectfully submitted,
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`Dated: October 2, 2017
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`/Andrew M. Riddles/
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` Andrew M. Riddles
` Reg. No. 31,657
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`U.S. Patent No. 8,894,066
`Motion for Observations on Cross-Examination
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on October 2,
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`2017, a true and correct copy of the foregoing, via UPS Overnight, was served on
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`the following counsel of record:
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`Anthony M. Petro
`Dean M. Munyon
`Ryan T. Beard
`Geoffrey W. Heaven
`1120 S. Capital of Texas Hwy.
`Building 2, Suite 300
`Austin, Texas 78746
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`/ Andrew M. Riddles /
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`Andrew M. Riddles
`Registration No. 31,657
`ariddles@daypitney.com
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`Elizabeth A. Alquist
`Admitted Pro Hac Vice
`eaalquist@daypitney.com
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`Day Pitney LLP
`7 Times Square
`New York, NY 10036
`Tel: (212) 297-5855
`Fax: (203) 202-3896
`Counsel for Patent Owner
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`-16-
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