`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`
`CANON INC.; CANON USA, INC.;
`CANON FINANCIAL SERVICES, INC.; FUJIFILM CORPORATION;
`FUJIFILM HOLDINGS AMERICA CORPORATION;
`FUJIFILM NORTH AMERICA CORPORATION; JVC KENWOOD
`CORPORATION; JVCKENWOOD USA CORPORATION;
`NIKON CORPORATION; NIKON INC.; OLYMPUS CORPORATION;
`OLYMPUS AMERICA INC.; PANASONIC CORPORATION;
`PANASONIC CORPORATION OF NORTH AMERICA;
`SAMSUNG ELECTRONICS CO., LTD.;
`SAMSUNG ELECTRONICS AMERICA, INC., AND LG ELECTRONICS, INC.,
`Petitioner,
`
`v.
`
`PAPST LICENSING GMBH & CO. KG
`Patent Owner.
`____________________
`
`Case IPR2016-01213
`Patent 8,504,746
`____________________
`
`PAPST LICENSING GMBH & CO. KG’S ITEMIZED LISTING OF
`OBJECTIONABLE ARGUMENTS AND EVIDENCE FILED WITH
`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
`IPR2016-01213
`U.S. PATENT NO. 8,504,746
`
`Pursuant to the Board’s Order (Paper 23), Patent Owner submits the following
`
`listing of Petitioner’s improper reply arguments and evidence:
`
`• Ex. 1313 at 1:15–19: “A POSITA would have understood that . . . the SCC 20
`
`would output control signals to control the operation of interface circuit 65 and R/D
`
`control circuit 66 . . . .” (See also Reply at 9:9-12.)
`
`• Ex. 1313 at 2:1–8: “A POSITA would have also understood that when in external
`
`hard disk mode, SCC 20 would prevent other circuits of the camera from accessing
`
`hard disk 71. . . .” (See also Reply at 9:15–10:4.)
`
`• Ex. 1313 at 2:8–15: “Additionally, a POSITA would have understood that SCC20
`
`would also prevent other camera circuits from . . . .” (See also Reply at 9:15–10:11)
`
`• Ex. 1313 at 2:15–3:3: “A POSITA would have understood that SCC 20 . . .
`
`manages the different camera operation modes . . . .” and “would therefore have
`
`understood that Yamamoto’s SCC 20 controls data transfer . . .” (See also Reply at
`
`10:12–14.)
`
`• Ex. 1313 at 3:13–4:6: “At the priority dates of the Tasler patents . . . a POSITA
`
`would have known and understood that a broad set of microcomputers and
`
`microprocessors
`
`.
`
`.
`
`. and
`
`that even ales powerful microcomputers and
`
`microprocessors . . . would have been fully capable . . .” (See also Reply at 11:12–
`
`20.)
`
`2
`
`
`
`IPR2016-01213
`U.S. PATENT NO. 8,504,746
`
`• Ex. 1313 at 4:7–19: “A POSITA would have known that . . . many low power
`
`processors available . . . could have performed this command processing . . .” (See
`
`also Reply at 11:14–20.)
`
`• Ex. 1313 at 5:1–14: “. . . a POSITA would have understood that data passing
`
`between the Yamamoto storage medium and an external computer from the image
`
`recording device 67, through the R/D control circuit 66, would be initiated and
`
`controlled by SCC 20, and the data itself may pass through SCC 20. . . .” (See also
`
`Reply at 19:9–20:9.)
`
`• Ex. 1313 at 5:18–6:7: “. . . [a] POSITA would have understood that SCC 20 would
`
`exercise this timing control in order to manage possibly different data flow rates
`
`between the storage medium, the external computer, and logic along that path (e.g.
`
`R/D control circuit 66 and interface circuit 65).” (See also Reply at 19:9–20:9.)
`
`• Ex. 1313 at 6:8–11: “A POSITA would also have understood . . . that the
`
`processors available to implement Yamamoto’s SCC would have been fully capable
`
`of supporting the file transfer process . . . .” (See also Reply at 16:15–21.)
`
`• Ex. 1313 at 7:12–17: “. . . [a] POSITA would have understood that the file system
`
`on Yamamoto’s hard drive may differ in accordance with what the external computer
`
`expects to find. It would be up to the end user to determine which operating system
`
`and file system its external computer uses, and to purchase pre-formatted disks that
`
`comport with that operating systems’ requirements.” (See also Reply at 23:4–12.)
`
`3
`
`
`
`IPR2016-01213
`U.S. PATENT NO. 8,504,746
`
`
`
`Dated: August 9, 2017
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`/Nicholas T. Peters/
`Nicholas T. Peters
`Registration No. 53,456
`Lead Counsel for Patent Owner
`ntpete@fitcheven.com
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on August 9, 2017,
`
`a complete and entire copy of PAPST LICENSING GMBH & CO. KG’S
`
`ITEMIZED LISTING OF OBJECTIONABLE ARGUMENTS AND
`
`EVIDENCE FILED WITH PETITIONER’S REPLY TO PATENT OWNER’S
`
`RESPONSE has been served in its entirety by e-mail on the following addresses of
`
`record for Petitioner:
`
`
`
`PapstPTABPetitioners@Jonesday.com
`
`Dated: August 9, 2017
`
`
`
`
`
`By:
`
`
`
`/Nicholas T. Peters/
`Nicholas T. Peters
`Registration No. 53,456
`Lead Counsel for Patent Owner
`ntpete@fitcheven.com
`
`4
`
`
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