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`Filed on behalf of:
`Patent Owner Voip-Pal.com Inc.
`By: Kerry Taylor
`John M. Carson
`KNOBBE, MARTENS, OLSON & BEAR, LLP
`2040 Main Street, 14th Floor
`Irvine, CA 92614
`Tel.: (858) 707-4000
`Fax: (858) 707-4001
`Email:
`BoxDigifonica@knobbe.com
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.
`
`Petitioner,
`
`v.
`
`PATENT OWNER’S REQUEST FOR REHEARING
`PURSUANT TO 37 C.F.R. § 42.71(d)
`
`
`
`
`
`
`
`VOIP-PAL.COM, INC.,
`
`Patent Owner
`
`
`
`
`Case No. IPR2016-01198
`U.S. Patent 9,179,005
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`I.
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`II.
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`TABLE OF CONTENTS
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`Page No.
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`STATEMENT OF THE PRECISE RELIEF REQUESTED ........................ 1
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`LEGAL STANDARD FOR REHEARING .................................................. 1
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`III. REASONS FOR THE REQUESTED RELIEF ............................................ 2
`
`A.
`
`B.
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`THE PETITION DID NOT CONSIDER ORDER OF
`STEPS.................................................................................................. 3
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`THE PETITION DOES NOT PROVIDE A VALID
`MOTIVATION TO COMBINE REFERENCES ............................... 8
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`IV. CONCLUSION ............................................................................................ 14
`
`
`
`i
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`
`
`TABLE OF AUTHORITIES
`
`Page No(s).
`
`Avigilon USA Corp., Inc. v. JDS Technologies, Inc.,
`IPR2016-00511 Paper 16 (P.T.A.B. July 15, 2016) ............................................. 4
`
`Dynamic Drinkware v. National Graphics,
`800 F. 3d 1375 (Fed. Cir. 2015) ........................................................................... 8
`
`Heart Failure Technologies, LLC v. Cardiokinetix, Inc.,
`IPR2013-00183, Paper 12 (P.T.A.B. July 31, 2013) .......................................... 13
`
`Intelligent Biosystems v Illumina Cambridge,
`821 F.3d 1359 (Fed. Cir. 2016) ........................................................................ 8, 9
`
`Kinetic Technologies, Inc. v. Skyworks Solutions, Inc.,
`IPR2014-00529, Paper 8 (P.T.A.B. Sept. 23, 2014) ..................................... 12, 13
`
`KSR Int'l Co. v. Teleflex, Inc.
`550 U.S. 398 (2007) ............................................................................................ 13
`
`K-TEC, Inc. v. Vita-Mix Corp.,
`696 F.3d 1364 (Fed. Cir. 2012) .......................................................................... 13
`
`Mantech Envtl. Corp. v. Hudson Envtl. Servs., Inc.,
`152 F.3d 1368 (Fed. Cir. 1998) ............................................................................ 4
`
`O’Keefe v. U.S. Postal Service,
`318 F.3d 1310 (Fed. Cir. 2002) ........................................................................ 2, 8
`
`TRW Automotive US LLC v. Magna Elecs., Inc.,
`IPR2014-00266, 2014 WL 3899428 (P.T.A.B. Aug. 11, 2014) ........................... 2
`
`
`
`OTHER AUTHORITIES
`
`35 U.S.C. § 316 .......................................................................................................... 8
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`37 C.F.R. § 42.65 ............................................................................................... 11, 12
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`-ii-
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`
`
`TABLE OF AUTHORITIES
`(cont’d)
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`Page No(s).
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`37 C.F.R. § 42.71 ................................................................................................... 1, 2
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`37 C.F.R. § 42.104 ................................................................................................... 11
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`
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`-iii-
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`IPR2016-01198
`Apple Inc v. Voip-Pal
`
`Pursuant to 37 C.F.R. § 42.71(d), Patent Owner Voip-Pal.com, Inc. (“Voip-
`
`Pal”) respectfully requests reconsideration of the Board’s November 21, 2016
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`Decision Granting Institution of Inter Partes Review (“Decision,” Paper 6). The
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`Board’s decision overlooked two key arguments of the Patent Owner, either of
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`which is sufficient to show that Petitioner failed to carry its burden of proof.
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`STATEMENT OF THE PRECISE RELIEF REQUESTED
`
`I.
`The Board’s Decision overlooked that the challenged claims require a
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`specific ordering of steps yet the Petition fails to use a claim construction that
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`accounts for this ordering of steps. The Decision also overlooked that the
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`Petitioner ascribed—without any substantial evidence—an alleged deficiency to
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`Chu ‘684 as its key motivation to combine Chu ‘684 with Chu ‘366 or Chen. Both
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`deficiencies were explained in the Patent Owner’s Preliminary Response but were
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`not addressed by the Board’s reasons in its Decision. In view of these oversights,
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`Voip-Pal respectfully requests that the Board reconsider the Decision and deny
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`institution of Inter Partes Review of claims 1, 24–26, 49, 50, 73–79, 83, 84, 88,
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`89, 92, 94–96, 98, and 99 of U.S. Patent No. 9,179,005.
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`II. LEGAL STANDARD FOR REHEARING
`A patent owner may request rehearing of a decision granting institution of
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`inter partes review. 37 C.F.R. § 42.71(d). A rehearing request “must specifically
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`identify all matters the party believes the Board misapprehended or overlooked,
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`-1-
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`IPR2016-01198
`Apple Inc v. Voip-Pal
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`and the place where each matter was previously addressed in a motion, an
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`opposition, or a reply.” Id. The Board reviews its decision for an abuse of
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`discretion. 37 C.F.R. § 42.71(c). An abuse of discretion occurs when a “decision
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`was based on an erroneous conclusion of law or clearly erroneous factual findings,
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`or... a clear error of judgment.” TRW Automotive US LLC v. Magna Elecs., Inc.,
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`IPR2014-00266, 2014 WL 3899428, at *1 (P.T.A.B. Aug. 11, 2014) (quoting PPG
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`Indus. Inc. v. Celanese Polymer Specialties Co., 840 F.2d 1565, 1567 (Fed. Cir.
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`1988)). “The Board necessarily abuses its discretion when it rests its decision on
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`factual findings unsupported by substantial evidence.” O’Keefe v. U.S. Postal
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`Service, 318 F.3d 1310, 1314 (Fed. Cir. 2002).
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`III. REASONS FOR THE REQUESTED RELIEF
`Voip-Pal submits that the Board has overlooked two key arguments made in
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`the Patent Owner’s Preliminary Response (“POPR”), either of which is a sufficient
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`basis for the Board to reconsider its decision to institute Inter Partes Review.
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`First, the Board overlooked Patent Owner’s argument that a proper
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`construction of the claims requires a particular ordering of steps, whereas the
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`Petitioner’s obviousness argument is based on the performance of these steps in a
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`different order. Petitioner did not provide a construction of the claims regarding
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`the ordering of steps and presented combinations of references that do not lead to
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`the order of steps recited in the claims.
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`IPR2016-01198
`Apple Inc v. Voip-Pal
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`Second, the Board overlooked Patent Owner’s arguments demonstrating the
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`Petition’s failure to provide a valid motivation for why a skilled person would
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`combine Chu ‘684 with either Chu ‘366 or Chen. As stated in the POPR,
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`Petitioner’s reasoning for why these references would be combined is premised on
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`an unproven deficiency in the primary reference, and Petitioner’s arguments for
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`this reason to combine are unsupported (i.e., not based on substantial evidence).
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`A. THE PETITION DID NOT CONSIDER ORDER OF STEPS
`The Decision overlooked Patent Owner’s argument in the POPR pointing
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`out that a proper construction of the challenged claims requires a particular
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`ordering of steps yet the Petition fails to provide, let alone to apply, a claim
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`construction which accounts for the required ordering of the steps Petition. POPR
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`at 17-20. The Petitioner’s obviousness analysis fails when a claim construction of
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`the ordering of steps is carried out and the obviousness case considered in view of
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`the construed claims.
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`Claim 1 of the ‘005 Patent recites, inter alia, a step of “locating” ([1a]
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`“using caller identifier associated with the caller to locate […]”) and two steps of
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`“producing” ([1b] “when at least one of said calling attributes and at least a portion
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`of a callee identifier associated with the callee meet private network classification
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`criteria, producing […]”; and [1c] “when at least one of said calling attributes and
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`at least a portion of said callee identifier meet a public network classification
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`IPR2016-01198
`Apple Inc v. Voip-Pal
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`criterion, producing […]”), in that order. As pointed out in the POPR, because the
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`steps of “producing” ([1b]-[1c]) depend on results from the step of “locating”
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`([1a]), claim 1 requires that the “producing” steps be performed after the “locating”
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`step. POPR at 17, citing Mformation Techs., Inc. v. Research in Motion Ltd., 764
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`F.3d 1392, 1398 (Fed. Cir. 2014) (citations omitted) (“[A] claim ‘requires an
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`ordering of steps when the claim language, as a matter of logic or grammar,
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`requires that the steps be performed in the order written, or the specification
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`directly or implicitly requires’ an order of steps.”). Subsequent steps referencing
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`components of prior steps lead to a construction requiring an ordering of steps.
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`Avigilon USA Corp., Inc. v. JDS Technologies, Inc., IPR2016-00511 Paper 16 at 8
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`(P.T.A.B. July 15, 2016) (denying institution, stating “[T]he claim language
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`requires step 2 to be performed after step 1 because step 2 requires the computer to
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`receive a unique identifier from the specific video server to which a request is sent
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`in step 1. See Mantech Envtl. Corp. v. Hudson Envtl. Servs., Inc., 152 F.3d 1368,
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`1375–76, (Fed. Cir. 1998) (holding that the steps of a method claim had to be
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`performed in their written order because each subsequent step referenced
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`something indicating the prior step had been performed)”).
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`The Petitioner failed to construe the ordering of steps in claim 1 and
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`premised its obviousness theory on Chu ‘684’s ordering of steps, which are distinct
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`from those in claim 1. POPR at 17-19. In particular, the Petitioner relies on Chu
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`-4-
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`IPR2016-01198
`Apple Inc v. Voip-Pal
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`‘684’s steps that take place on server 110 for the steps of “producing,” and relies
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`on steps that take place later on soft-switch 220 for the step of “locating.” Petition
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`at 17-20, 43-45; POPR at 17-20, 48-49. Such a sequence of steps cannot meet the
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`limitations of claim 1 because it is not in the order required by the claim. POPR at
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`17-20, 48-49. That is, Chu ‘684 teaches a method distinct from that of claim 1
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`because Chu ‘684 performs its method in an order different from that required by
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`claim 1. Id.
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`The Petitioner did not construe the order of steps in Patent Owner’s claims
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`and instead expressly based its arguments on the ordering of steps within Chu
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`‘684. The Petitioner also did not attempt to reconcile the difference between the
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`claimed ordering of steps and Chu ‘684’s ordering of steps when it proposed the
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`combination of Chu ‘684 with either Chu ‘366 or Chen.
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`The Board’s Decision overlooked the significance of the Patent Owner’s
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`claim construction explaining the required ordering of steps and the Patent
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`Owner’s arguments showing that the Petition’s obviousness arguments fail due to
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`Chu ‘684’s distinct ordering of steps. Even assuming, for purposes of this
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`Request, that all facts asserted in the Petition are true, the necessary task of claim
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`construction was not performed in the Petition or the Decision, and, consequently,
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`the Board misapprehended the distinction between the claims and the cited
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`references with respect to the order of steps. The Decision states:
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`IPR2016-01198
`Apple Inc v. Voip-Pal
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`“We determine that Petitioner has made a sufficient showing at this
`stage. Petitioner does not rely exclusively on Chu ’684 for teaching
`the classification criteria limitations. Rather, Petitioner contends that
`Chu ’684’s disclosure of classifying the call based on a dial plan
`combined with Chu ’366’s teaching of reformatting dialed digits
`based on matching dialed digits to caller attributes teaches producing
`a private or a public network routing message when a calling attribute
`and a portion of a callee identifier associated with the callee meet
`private or public network classification criteria, respectively. Pet. 18–
`19. [Decision at 19; emphasis added]
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`The Decision’s explanation of the Petitioner’s “showing” focuses solely on
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`the issue of whether the “producing” steps of claim 1 (which include the notion of
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`classifying) are met by “Chu ‘684’s disclosure of classifying” combined with “Chu
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`‘366’s teaching of reformatting”. What is missing in the Board’s explanation is
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`any consideration of the order of these steps with respect to the “locating” step.
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`The POPR specifically argued, “[t]hus the ‘classification criteri[a]’ in [1b]-[1c]
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`must be based on the step of ‘using a caller identifier … to locate’ in claim [1a]
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`because features recited in [1b]-[1c] find antecedent basis in step [1a].” POPR at
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`17 (emphasis added). The Board overlooked this argument of the POPR, and thus
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`overlooked that the Petitioner’s identification of elements in Chu ‘684, Chu ‘366
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`and Chen fails to account for performing the “locating” step [1a] before the
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`“producing” steps [1b]-[1c] as required by the claims. POPR at 17.
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`-6-
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`IPR2016-01198
`Apple Inc v. Voip-Pal
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`Thus, even if the combination of Chu ‘684’s “classifying” and Chu ‘366’s
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`“reformatting” was made, this does not resolve the ordering problem inherent in
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`Petitioner’s reliance on Chu ‘684’s soft-switch 220 for the step of “locating”,
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`which, in the proposed combination, takes place after the step relied on for
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`“producing”, contrary to the requirements of claim 1. Combining Chu ‘684 with
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`Chu ‘366 or Chen, even as proposed in the Board’s explanation, cited above, does
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`not negate the clear distinction between the combined references and claim 1.
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`Thus, the proposed combination of Chu ‘684 with Chu ‘366 would still fail
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`to practice the claim steps in the proper order. The Petition did not construe the
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`order of steps in claim 1, much less articulate any reason why Chu ‘684 would be
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`combined with Chu ‘366 in such a way that the ordering of the steps would be
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`rearranged from how they are disclosed in Chu ‘684. POPR at 17-20, 48-49.
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`For the reasons stated above, the Institution Decision overlooked the
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`construction of claim 1 as stated in the POPR in evaluating the Petition’s
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`obviousness challenges. The Board overlooked the Patent Owner’s argument that
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`the Petitioner failed to construe the ordering requirements in the claims of the ‘005
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`Patent, and, consequently, failed to show how the combined references meet the
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`requirements of the construed claims. POPR at 17-19. Because the Petitioner’s
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`proposed combination of references does not practice the order of steps as claimed,
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`the Petitioner has failed to carry its burden, and thus the Petition should be denied.
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`IPR2016-01198
`Apple Inc v. Voip-Pal
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`B.
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`THE PETITION DOES NOT PROVIDE A VALID MOTIVATION TO
`COMBINE REFERENCES
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`The Petitioner’s proposed motivation for combining Chu ‘684 with Chu
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`‘366 incorrectly assumes that certain features are lacking in Chu ‘684 without
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`providing substantial evidence that such features are actually lacking. The Board’s
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`Decision relied on this assumption without recognizing any of Patent Owner’s
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`arguments showing that this assumption is unsupported. O’Keefe, 318 F.3d at
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`1314 (“The Board necessarily abuses its discretion when it rests its decision on
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`factual findings unsupported by substantial evidence.”).
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`Petitioner bears the burden of demonstrating that there was a motivation to
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`combine the references. Intelligent Biosystems v Illumina Cambridge, 821 F.3d
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`1359, 1367-1368 (Fed. Cir. 2016) (“It was [Petitioner]’s burden to demonstrate
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`both ‘that a skilled artisan would have been motivated to combine the teachings of
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`the prior art references to achieve the claimed invention …’”) (internal citations
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`omitted). Dynamic Drinkware v. National Graphics, 800 F. 3d 1375, 1378-1379
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`(Fed. Cir. 2015) (“In an inter partes review, the burden of persuasion is on the
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`petitioner to prove ‘unpatentability by a preponderance of the evidence,’ 35 U.S.C.
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`§ 316(e), and that burden never shifts to the patentee. ‘Failure to prove the matter
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`as required by the applicable standard means that the party with the burden of
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`persuasion loses on that point—thus, if the fact trier of the issue is left uncertain,
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`IPR2016-01198
`Apple Inc v. Voip-Pal
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`the party with the burden loses.’” (citing Technology Licensing Corp. v. Videotek,
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`Inc., 545 F.3d 1316, 1327 (Fed. Cir. 2008)).
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`As discussed in the POPR and below, because Petitioner’s asserted
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`motivation to combine the references is unsupported by substantial evidence, the
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`Petition failed to carry the burden of establishing “that a skilled artisan would have
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`been motivated to combine the teachings of the prior art references” as required by
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`Intelligent Biosystems, and thus failed to meet its burden of establishing a prima
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`facie case of obviousness. POPR at 38-42. The Decision states:
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`“Petitioner contends that it would have been obvious to a skilled
`artisan to modify the system described in Chu ’684 with the specific
`dialed digit reformatting teachings of Chu ’366 and that a skilled
`artisan would have recognized that allowing users to place calls as if
`they were dialing from a standard PSTN phone would be desirable,
`creating a system capable of supporting a more intuitive and user
`friendly interface. Pet. 15-16 (citing Ex. 1009 (Houh Decl.) ¶¶ 35–39).
`[Decision at 16, emphasis added]. And:
`
`“Petitioner cites evidence showing that (i) one of ordinary skill in the
`art would have recognized upon reading Chu ’684 that allowing users
`to place calls as if they were dialing from a standard PSTN phone
`would have been desirable, creating a system capable of supporting a
`more intuitive and user-friendly interface; …. See Pet. 19 [sic]; Ex.
`1009 ¶¶ 37, 38.” [Decision at 22-23, emphasis added]
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`IPR2016-01198
`Apple Inc v. Voip-Pal
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`These allegations presume that Chu ‘684 lacks the ability to allow users to
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`place calls as if they were dialing from a standard PSTN phone and thus that its
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`interface is somehow deficient. These allegations originate from the Petition at 16:
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`“Upon reading the disclosure of Chu ’684, a person of ordinary skill
`in the art would have recognized that allowing users to place calls as
`if they were dialing from a standard PSTN phone would be desirable,
`creating a system capable of supporting a more intuitive and user-
`friendly interface. See Ex. 1006, Houh Decl. at ¶¶ 35-39.” [Petition at
`16, emphasis added; similarly, see Petition at 40]
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`The Petition does not cite any portion of Chu ‘684 for support, citing only to
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`the Declarant in support of this assertion. The Houh Declaration states that:
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`“Upon reading the disclosure of Chu ’684, a person of ordinary skill
`in the art would have recognized that allowing users to place calls as
`if they were dialing from a standard PSTN phone would be desirable,
`creating a system capable of supporting a more intuitive and user-
`friendly interface.” [Houh Declaration at ¶¶38, 43, emphasis added]
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`The Decision has therefore relied upon an allegation from the Petition,
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`which relied solely upon the Declarant’s identical allegation for support. However,
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`paragraphs 38 and 43 of the Houh Declaration do not rely upon any evidence for
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`support. These paragraphs contain no citations to Chu ‘684 and offer no
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`explanation or reasoning for their allegations. In the preceding paragraphs, the
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`Declarant provides citations to Chu ‘684 in arguing for other unrelated features in
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`IPR2016-01198
`Apple Inc v. Voip-Pal
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`Chu ‘684. See Houh Declaration at ¶¶36-37, 41-42. But none of these paragraphs
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`provide any evidentiary basis or underlying rationale for the Declarant’s allegation
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`in paragraphs 38 and 43 that the system of Chu ‘684 does not allow users to place
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`calls as if they were dialing from a standard PSTN phone. As was explained in the
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`POPR, Chu ‘684 never states or suggests that users are not able to place calls as if
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`they were dialing from a standard PSTN phone, thus there is no evidence that Chu
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`‘684 fails to support such dialing. POPR at 38-45.
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`The Board overlooked the POPR’s arguments pointing out these evidentiary
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`deficiencies in the Petition and Houh Declaration.
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`The Board also overlooked the POPR’s argument that the Board’s Rules
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`require that the Houh Declaration “should be entitled to little or no weight.” POPR
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`at 41 and 61, citing 37 C.F.R. § 42.65(a): “Declarant testimony that does not
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`disclose the underlying facts or data should be entitled to little or no weight.”
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`Although the Decision states that the Petition cites “evidence” of a motivation to
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`combine the references, the Petition fails to cite any portion of the cited art to
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`support the alleged motivation to combine, contrary to 37 C.F.R. § 42.104(b). See
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`Petition at pages 16, POPR at 40-42, 61-62. Petitioner only cites ¶¶ 35-39 or 40-44
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`of the Houh Declaration, which provide no substantial evidence since paragraphs
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`38 and 43 make identical statements as contained in the petition without disclosing
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`any underlying facts or even citing to Chu ‘684. An unsupported allegation is not
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`IPR2016-01198
`Apple Inc v. Voip-Pal
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`substantial evidence and cannot, absent more, carry the Petitioner’s burden. 37
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`C.F.R. § 42.65(a). POPR at 41-42, 61-62. See also Kinetic Technologies, Inc. v.
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`Skyworks Solutions, Inc., IPR2014-00529, Paper 8 at 15 (P.T.A.B. Sept. 23, 2014):
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`“...Dr. Mohapatra’s Declaration does not provide any factual basis for its
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`assertions. [...] Dr. Mohapatra also fails to explain why a person of ordinary skill in
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`the art would have combined elements from specific references in the way the
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`claimed invention does. [...] Accordingly, we give Dr. Mohapatra’s Declaration
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`no probative weight.”
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`The Board’s Decision overlooked the Patent Owner’s arguments that the
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`Petition’s key motivation to combine the references is unsupported by substantial
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`evidence. POPR at 38-45, 59-64.
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`The Board briefly cites two other Petitioner arguments in its Decision, but
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`neither cures the Petitioner’s failure to provide a motivation to combine the
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`references. For example, the Board cites the following Petitioner argument:
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`“Petitioner argues with citations to the references that both Chu ’684
`and Chu ’366 teach telecommunications systems in which VoIP
`subscribers can place calls to a callee on the PSTN. See Pet. 15; Ex.
`1006, 8:65–9:1; Ex. 1007, 14:30–33.” [Decision at 22]
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`But this is no more than a “same technological field” argument, which is
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`insufficient to provide a reason to combine references, as was pointed out by
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`IPR2016-01198
`Apple Inc v. Voip-Pal
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`Patent Owner. See POPR at 38, citing Unified Patents Inc. v. William Grecia,
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`IPR2016-00789, Paper 8 at 12 (P.T.A.B. Sept. 9, 2016) and K-TEC, Inc. v. Vita-
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`Mix Corp., 696 F.3d 1364, 1375 (Fed. Cir. 2012). Similarly, Petitioner’s allegation
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`that Chu ‘684’s infrastructure would be able to support digit reformatting, even if
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`true, is not itself a reason to combine the references. See Heart Failure
`
`Technologies, LLC v. Cardiokinetix, Inc., IPR2013-00183, Paper 12 at 11
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`(P.T.A.B. July 31, 2013) (“...that Murphy, Khairkhahan, and Lane all concern
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`human heart repair is not in itself sufficient rationale for making the combination...
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`Petitioner must show some reason why a person of ordinary skill in the art would
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`have thought to combine particular available elements of knowledge, as evidenced
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`by the prior art, to reach the claimed invention.” (citing KSR Int’l Co. at 398, 418;
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`emphasis in original).
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`Without a motivation to combine supported by substantial evidence, the
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`Petition’s obviousness analysis is incomplete and fails to establish a prima facie
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`case of obviousness. POPR at 38-42, 59-62; see also Kinetic Technologies,
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`IPR2014-00529 Paper 8 at 15, citing KSR Int'l Co. v. Teleflex, Inc., 550 U.S. 398,
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`418 (2007): “[A] patent composed of several elements is not proved obvious
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`merely by demonstrating that each of its elements was, independently, known in
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`the prior art.” Petitioner has failed to carry its burden of proof by failing to
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`articulate a valid reason to combine the references.
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`-13-
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`IPR2016-01198
`Apple Inc v. Voip-Pal
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`IV. CONCLUSION
`Patent Owner requests reconsideration of the above two arguments, which
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`the Board did not address when deciding to institute Inter Partes Review. Either
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`of these arguments alone is sufficient to deny institution of Inter Partes Review.
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`In the alternative, the Patent Owner requests a clarification of the Board’s
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`reasoning in order to properly prepare a Patent Owner Response.
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`Respectfully submitted,
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`KNOBBE, MARTENS, OLSON & BEAR, LLP
`
`
`
`By: /Kerry Taylor/
`Kerry Taylor, Reg. No. 43,947
`John M. Carson, Reg. No. 34,303
`Customer No. 20,995
`Attorneys for Patent Owner
`Voip-Pal.com, Inc.
`(858) 707-4000
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`-14-
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`Dated: December 5, 2016
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`IPR2016-01198
`Apple Inc v. Voip-Pal
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`CERTIFICATE OF SERVICE
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`I hereby certify that true and correct copy of PATENT OWNER’S
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`REQUEST FOR REHEARING PURSUANT TO 37 C.F.R. § 42.71(d) is being
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`served on December 5, 2016, via FedEx Priority Overnight pursuant to 37 C.F.R. §
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`42.6(e) and as a courtesy via electronic mail, for Petitioners as addressed below:
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`Paul R. Hart
`ERISE IPA, P.A.
`5600 Greenwood Plaza Blvd., Suite 200
`Greenwood Village, CO 80111
`Telephone: (913) 777-5600
`Paul.Hart@EriseIP.com
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` /Kerry Taylor/
`Kerry Taylor, Reg. No. 43,947
`John M. Carson, Reg. No. 34,303
`Attorneys for Patent Owner
`Voip-Pal.com, Inc.
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`Adam P. Seitz
`Eric A. Buresh
`ERISE IPA, P.A.
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`Telephone: (913) 777-5600
`Adam.seitz@eriseip.com
`eric.buresh@eriseip.com
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`Dated: December 5, 2016
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`-15-