UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`CISCO SYSTEMS, INC.,
`Petitioner
`
`v.
`
`TQ DELTA, LLC,
`Patent Owner
`
`_____________________
`
`Case IPR2016-01466
`Patent No. 8,611,404
`_____________________
`
`PETITIONER’S RESPONSE TO PATENT OWNER’S MOTION FOR
`OBSERVATION ON CROSS-EXAMINATION TESTIMONY
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`16576538_1
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`
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`CISCO SYSTEMS, INC.,
`Petitioner
`
`v.
`
`TQ DELTA, LLC,
`Patent Owner
`
`_____________________
`
`Case IPR2016-01466
`Patent No. 8,611,404
`_____________________
`
`PETITIONER’S RESPONSE TO PATENT OWNER’S MOTION FOR
`OBSERVATION ON CROSS-EXAMINATION TESTIMONY
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`16576538_1
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`Petitioner’s Response to Patent Owner’s Motion for Observation
`IPR2016-01466
`Cisco Systems Inc., (“Petitioner”) submits this response in view of the
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`Scheduling Order (Paper 8) and the Trial Practice Guide, 77 Fed. Reg. 48756,
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`48767–68 (Aug. 14, 2012). This paper responds to TQ Delta, LLC’s (“Patent
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`Owner”) Motion for Observation on Cross-examination (Paper 26 “Mot. Obs.”)
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`filed on October 2, 2017, in the present inter partes review.
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`TQ Delta presented fifteen (15) observations on the September 25, 2017,
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`deposition testimony of Dr. Kiaei (Ex. 2017). Although Petitioner responds to
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`each of the observations below, the Board should deny TQ Delta’s motion because
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`the observations contain at least one of the following deficiencies: (1) they are not
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`relevant to any issue; (2) they include attorney argument, and; (3) they
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`mischaracterize Dr. Kiaei’s testimony.
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`Response to Observation 1:
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`TQ Delta’s observation omits relevant testimony. Specifically, Dr. Kiaei
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`testified that “the ADSL standard in full power mode sets the minimal set of
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`requirement for satisfactory transmission . . . The objective of this paragraph is
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`that standard does not prevent you when needed and when you could improve on
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`the equipment based on your own proprietary information or in design and so forth
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`so that you allow for improvements. In full power mode, the standard says you
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`have to go with this operation. In the low power mode, it allows you for
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`improvements. And there were actually groups within the standard of DSL that
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`Petitioner’s Response to Patent Owner’s Motion for Observation
`IPR2016-01466
`worked on G.lite, which was a version of ADSL and many other improvements
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`and variations of this and so on.” Ex. 2017, 91:8-92:7. This testimony is consistent
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`with Dr. Kiaei’s declaration testimony that “the ANSI standard describes
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`requirements for sending data in full power mode but also specifically allows for
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`improvements (e.g., low power mode as in Bowie and Yamano).” Ex. 1012, ¶23.
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`Further, TQ Delta’s observation is not relevant to Petitioner’s combination since
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`Bowie “shut[s] off…sections of signal processing 111, transmitting 112, and
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`receiving 113 circuitry” and places the loop “in an inactive state,” which means
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`that superframes are not sent during Bowie’s low power mode. Mot. Obs. 1;
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`Ex.1005, 5:26-28.
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`Response to Observation 2:
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`TQ Delta’s cited deposition testimony pertains to a PLL synchronization
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`example in the ‘404 patent that is not relevant to Dr. Kiaei’s declaration, which
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`relied on other portions of the ‘404 patent. Specifically, Dr. Kiaei explained that
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`the ‘404 patent’s disclosure is broad since it teaches that “[o]ther forms of timing
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`signal may, of course, be used” for synchronization. Ex. 1012, ¶5 (citing Ex.1001,
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`5:47-50). Further, TQ Delta’s observation omits relevant testimony where Dr.
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`Kiaei explains that “the PLL, that is one example of synchronization used here.
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`And DSL we have many different types of synchronization. Anyway, in [the ‘404]
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`patent it talks about different -- in the claim language talks about different
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`synchronization. May not necessarily fall to that, because if you only look at the
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`timing error differences, assume that the PLL has a division by two, and even if it
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`locks the phase on the output, which is changing the time, minimizing the timing
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`error between them, the frequency is twice as much, and this will not work for
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`DSL.” Ex. 2017, 50:19-51:5. This testimony is consistent with Dr. Kiaei’s
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`declaration testimony that “[t]he claims at issue never limit synchronization to any
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`specific type and much less do they require correcting errors.” Ex. 1012, ¶5.
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`Response to Observation 3:
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`TQ Delta’s observation is redundant with and cites the same testimony as
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`observation 2. Also, TQ Delta’s observation omits relevant testimony pertaining to
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`the term “synchronization signal.” Specifically, Dr. Kiaei testified that in the ‘404
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`patent’s disclosure “the PLL, that is one example of synchronization used here.
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`And DSL we have many different types of synchronization. Anyway, in this patent
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`it talks about different -- in the claim language talks about different
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`synchronization.” Ex. 2017, 50:19-23. Dr. Kiaei’s deposition testimony is
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`consistent with his declaration testimony since the ‘248 patent, “broadly recognize
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`that ‘[o]ther forms of timing signal may, of course, be used’ for synchronization.”
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`Ex.1001, 5:47-50. Since the specification encompasses other forms of timing
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`signals for synchronization and not just a pure tone, a POSITA would have
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`understood that the claims are not limited to correcting errors or differences in the
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`Petitioner’s Response to Patent Owner’s Motion for Observation
`IPR2016-01466
`timing references of the transmitter and receiver.” Ex. 1012, ¶5. Furthermore, as to
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`the relevance to Yamano, Dr. Kiaei explained that Yamano’s disclosure of using a
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`timing signal “to maintain synchronization [] of time intervals” between receiver
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`and transmitter circuits teaches the claimed “maintaining synchronization with a
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`second transceiver,” even under TQ Delta’s narrow construction. Ex. 1012, ¶17.
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`Response to Observation 4:
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`TQ Delta’s observation is consistent and actually reaffirms Dr. Kiaei’s
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`declaration testimony that “SNR and attenuation are measured and used during full
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`power mode” and that “a POSITA would have understood that in the context of the
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`patents at issue, the parameters associated with full power mode not only include
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`parameters used for transmission and reception of data (e.g., bits, gains, and
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`equalizer values) but also include parameters from which the transmission and
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`reception parameters are derived (e.g., attenuation, SNR).” Ex. 1012, ¶9. Further,
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`TQ Delta’s attorney argument mischaracterizes the record since in Wi-Lan
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`considered Bowie’s disclosure at 4:64-5:4 whereas here the Petition relied on other
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`portions of Bowie, which expressly disclose storing “loop transmission
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`characteristics” and using these transmission characteristics “to enable data
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`transmission to resume quickly.” Petition, 14-15, 36; Ex. 1004, ¶51. Further still,
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`TQ Delta’s observation is not relevant to this proceeding since the legal question
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`that TQ Delta raises from the Wi-Lan case pertains to a how a term in Bowie’s
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`Petitioner’s Response to Patent Owner’s Motion for Observation
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`claims is construed, not whether the combination of Bowie and Yamano render the
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`challenged claims of the ‘404 patent obvious. Moreover, this observation is not
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`relevant because the ‘404 patent was not involved in the WiLan case, the evidence
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`presented in that case is not of record in this proceeding, and Petitioner was not a
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`party in that case.
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`Response to Observation 5:
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`
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`TQ Delta’s observation regarding Dr. Kiaei involvement in the Wi-Lan case
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`is consistent with his CV; namely, that he was engaged in “Wi-LAN, Inc. vs.
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`Wesrell Technologies, Mckool Smith, Representing Wi-LAN DSL Modem,
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`Communications, Signal Processing.” Ex. 1004, p. 4. Dr. Kiaei’s makes no
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`representation in his CV as to the extent of his work and this disclosure was
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`included in Dr. Kiaei’s CV for completeness. The fact that he acted as a consultant
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`is irrelevant as to any issue in this proceeding. Further, TQ Delta’s observation is
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`not relevant to this proceeding since the legal question that TQ Delta raises from
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`the Wi-Lan case pertains to a how a term in Bowie’s claims is construed, not
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`whether the combination of Bowie and Yamano render the challenged claims of
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`the ‘404 patent obvious. Moreover, this observation is not relevant because the
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`‘404 patent was not involved in the WiLan case, the evidence presented in that case
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`is not of record in this proceeding, and Petitioner was not a party in that case.
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`Response to Observation 6:
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`TQ Delta’s observation omits relevant testimony. Dr. Kiaei testified that “I
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`believe the POSITA will clearly understand how the polling mechanism is -- or
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`developing a synchronization between transmitter and receiver and other timing
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`signals . . . What I'm saying is that a POSITA will know what the nature and
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`implementation of that poll or synchronous signal could be depending on the
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`implementation . . . I think polling mechanism is a well-known mechanism in
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`computer science . . . And actually, the reference that you had provided, the 1977
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`version -- not the 1966 version, the 1977 version -- of a dictionary got provided
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`that discusses those pollings.” Ex. 2017, 121:21-122:18. This testimony is relevant
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`because it confirms that Yamano need not teach synchronization details that are
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`well-known in the art. See In re Buchner, 929 F.2d 660, 661, (Fed. Cir. 1991).
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`Also, Dr. Kiaei’s position that synchronization was well known is confirmed by
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`the ‘404 patent, which simply states that “[o]ther forms of timing signal may, of
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`course, be used,” without elaboration. Ex.1001, 5:47-50. Further, the testimony is
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`relevant because it reaffirms Dr. Kiaei’s position that “modifying . . . Bowie to also
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`detect Yamano’s timing signal would be well within the level of a POSITA” and
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`that the combination would have yielded a predictable result. Reply at p. 24, 43.
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`Further still, as to the relevance, TQ Delta’s attorney argument that “Petitioner and
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`Dr. Kiaei have failed to addressed [sic] the specifics . . . to render the claims
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`obvious” mischaracterizes the prior art, since Yamano plainly discloses using a
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`“poll or other timing signal . . . to maintain synchronization of these time intervals
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`between receiver circuit 400 and the remote transmitter circuit.” Mot. Obs. 7; Ex.
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`1012, ¶16; Ex.1006, 15:29-32.
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`Response to Observation 7:
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`
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`TQ Delta’s cited deposition testimony pertains to how the claims do not
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`require any specific type of synchronization and is consistent with Dr. Kiaei’s
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`declaration that “[t]he claims at issue never limit synchronization to any specific
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`type.” Ex. 1012, ¶5. Further, as to the relevance, TQ Delta’s attorney argument
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`that “the entirety of Dr. Kiaei analysis is based on hindsight” mischaracterizes Dr.
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`Kiaei’s declaration which cites to Yamano’s express teachings of using a “poll or
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`other timing signal . . . to maintain synchronization.” Ex. 2017, 120:23-24; Ex.
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`1012, ¶16; Ex.1006, 15:29-32. Further, TQ Delta omits clear testimony from Dr.
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`Kiaei that it was well known how to perform synchronization. Ex. 2017, 122:6-10
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`(“What I'm saying is that a POSITA will know what the nature and implementation
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`of that poll or synchronous signal could be depending on the implementation.”)
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`Response to Observation 8:
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`TQ Delta’s observation includes attorney argument, which mischaracterizes
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`Dr. Kiaei’s testimony in asserting that it “confirms Dr. Chrissan’s deposition
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`testimony that Yamano is a single carrier system that is not readily adaptable to
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`multicarrier ADSL system.” Mot. Obs. 8. Dr. Kiaei’s testimony indicates that
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`Petitioner’s Response to Patent Owner’s Motion for Observation
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`Yamano is in fact directed to multicarrier ADSL systems. Ex. 2017, 85:13-20.
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`(“[Yamano] says that conventional modem protocol such as xDSL and received.
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`So reading this, looking at this, looking at Figure 4 and what's discussed in Figure
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`4 in terms of column 14, it is discussing the same thing.”) ; id. 96:11-13 (“MCM,
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`multi-carrier modulation, in here includes xDSL as well. When it talks about the --
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`in column 14, and 13 talking about multichannel.”). Further, the deposition
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`testimony is consistent with Dr. Kiaei’s declaration testimony that
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`“Yamano…describe[s] DSL systems.” Ex. 1003, p. 38.
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`Response to Observation 9:
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`The cited testimony in TQ Delta’s observation is consistent with Dr. Kiaei’s
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`declaration. Particularly, Dr. Kiaei in his declaration testified that “modifying
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`[Bowie’s] circuitry to also detect a timing signal, as taught in Yamano, would be
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`well within the level of a POSITA.” Ex. 1012, ¶21. As to the relevance, even
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`though Bowie’s signal detector circuitry and Yamano’s non-idle detector are “two
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`different things,” Dr. Kiaei explained that a “POSITA will know how to modify
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`the Bowie's circuits [so] it can also detect a synchronized – synchronization signal
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`and detect resume signal.” Ex. 2017, 65:9-13.
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`Response to Observation 10:
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`TQ Delta’s observation mischaracterizes Dr. Kiaei’s testimony. Specifically,
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`the cited deposition testimony pertains to “poll” while his declaration testimony
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`pertains to “timing signal,” which are two distinct approaches to performing
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`synchronization. Mot. Obs. 9-10; compare Ex. 1017, 105:13-21 with Ex. 1012,
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`¶20. Regarding the “poll,” Dr. Kiaei testified that “my opinion is that the periodic
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`poll is the synchronization signal during the low power mode, and again, it
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`depends on the implementation. Depends on how you implement, how you are
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`performing the polling and how the implementation is done” and that “polling
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`mechanism is a well-known mechanism.” Ex. 1017, 112:12-17, 122:12-13; see
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`also id. 119:25-120:4 (“Q So some -- some box between the transmitter and the
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`receiver transmits or receives this periodic poll? A And it synchronizes between
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`the two.”) Further, regarding the “timing signal,” Dr. Kiaei testified that “during
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`these times that the non-idle detector is on periodically that it's able to detect a
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`timing signal, some sort of a timing signal between transmitter and a receiver or
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`vice versa that would indicate the data is coming,” which is consistent with his
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`declaration testimony. Ex. 1017, 110:2-6; Ex. 1012, ¶20. Regardless, the
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`observation is not relevant because the claims do not require any particular
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`component within the claimed transceiver to receive the synchronization signal.
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`Additionally, as to the relevance, TQ Delta’s observation includes attorney
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`argument that “Dr. Kiaei has no basis for his assertion in Ex. 1003 at p. 56 that
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`Yamano ‘teaches that the receive circuit receives a synchronization signal.’” Mot.
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`Obs. 10. TQ Delta’s attorney argument mischaracterizes the record since Dr.
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`Kiaei’s basis is founded in Yamano, which expressly discloses using a “poll or
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`other timing signal . . . to maintain synchronization of these time intervals between
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`receiver circuit 400 and the remote transmitter circuit.” Ex. 1012, ¶16; Ex.1006,
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`15:29-32.
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`Response to Observation 11:
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`TQ Delta’s observation includes attorney argument which mischaracterizes
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`the cited testimony. Dr. Kiaei never testified or agreed that “the far-end
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`‘transmitter does not transmit any signals on the communication channel’ other
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`than the non-idle signal or packet data.” Mot. Obs. 11. On the contrary, when
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`asked if “the far end transmitter transmit the periodic poll that is then received by
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`the receiver 400?” Dr. Kiaei answered that “[m]y opinion, a periodic poll or other
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`types of synchronization is done between the two.” Ex. 2017, 107:12-16. Dr. Kiaei
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`further explained that “[t]he synchronization signal is being exchanged” and that
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`“[t]he synchronization is – is done in these time intervals to assure that the receiver
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`is able to receive the data, the packet data in synchronism with the transmitter.” Ex.
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`2017, 108:5-12. This is further consistent with Dr. Kiaei’s testimony that the
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`“non-idle detector is periodically enabled during predetermined time, and a
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`periodic poll is done to synchronize when the non-idle detector is on with the
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`transmitter such that it is able to receive a data or packet data from transmitter.”
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`Ex. 2017, 111:8-13. TQ Delta’s attorney argument that “Dr. Kiaei’s conclusion”
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`Petitioner’s Response to Patent Owner’s Motion for Observation
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`regarding Yamano’s synchronization signal is “impossible and incorrect” blatantly
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`mischaracterizes Yamano which discloses using a “poll or other timing signal . . .
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`to maintain synchronization of these time intervals between receiver circuit 400
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`and the remote transmitter circuit.” Mot. Obs. 11; Ex.1006, 15:29-32.
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`Response to Observation 12:
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`TQ Delta’s observation includes attorney argument which mischaracterizes
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`the cited testimony. Dr. Kiaei never testified that “the conclusion at ¶ 22 in his
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`Reply Declaration” “is an out of context citation to Yamano and does not concern
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`the burst-mode protocol.” Mot. Obs. 11. To the contrary, Dr. Kiaei testified that
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`“even though it's a different figure, throughout the patent from the beginning on to
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`the end, it actually talks and discusses in Figure 3, it says that conventional modem
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`protocol such as xDSL and received. So reading this, looking at this, looking at
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`Figure 4 and what's discussed in Figure 4 in terms of column 14, it is discussing
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`the same thing.” Ex. 2017, 85:13-20.
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`Response to Observation 13:
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` TQ Delta’s observation omits relevant testimony where Dr. Kiaei explains
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`that “my opinion is that the periodic poll is the synchronization signal during the
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`low power mode, and again, it depends on the implementation” and that “[t]he
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`synchronization between the two is done via the polling or other type of a
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`synchronization signal. During the time that the non-idle detector is on, at this
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`predetermined time period, it performs the polling mechanism and is able to
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`potentially receive data or not receive data.” Ex. 2017, 112:12-17, 115:15-20.
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`Further, this testimony is consistent with Dr. Kiaei’s declaration testimony that
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`“Yamano states that ‘receiver circuit 400 can periodically enable the non-idle
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`detector 401 during predetermined time intervals which can be used by the remote
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`transmitter circuit to signal the transmission of a packet. A periodic poll or some
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`other timing signal would be used to maintain synchronization of these time
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`intervals between receiver circuit 400 and the remote transmitter circuit.’” Ex.
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`1012, ¶20 (citing Ex. 1006, 15:26-29).
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`Response to Observation 14:
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`
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`TQ Delta’s observation omits relevant testimony. Dr. Kiaei testified that “I
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`believe the POSITA will clearly understand how the polling mechanism is -- or
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`developing a synchronization between transmitter and receiver and other timing
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`signals . . . What I'm saying is that a POSITA will know what the nature and
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`implementation of that poll or synchronous signal could be depending on the
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`implementation . . . I think polling mechanism is a well-known mechanism in
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`computer science . . . And actually, the reference that you had provided, the 1977
`
`version -- not the 1966 version, the 1977 version -- of a dictionary got provided
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`that discusses those pollings.” Ex. 2017, 121:21-122:18. This testimony is relevant
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`because it confirms that Yamano need not teach synchronization details that are
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`well-known in the art. See In re Buchner, 929 F.2d 660, 661, (Fed. Cir. 1991).
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`Also, Dr. Kiaei’s position that synchronization was well known is confirmed by
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`the ‘404 patent, which simply states that “[o]ther forms of timing signal may, of
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`course, be used,” without elaboration. Ex.1001, 5:47-50. Moreover, as to the
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`relevance, TQ Delta’s attorney argument that “Yamano does not describe any type
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`of synchronization signal” mischaracterizes the prior art, since Yamano expressly
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`discloses using a “poll or other timing signal … to maintain synchronization of
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`these time intervals between receiver circuit 400 and the remote transmitter
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`circuit.” Mot. Obs. 13; Ex. 1012, ¶16; Ex.1006, 15:29-32.
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`Response to Observation 15:
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`TQ Delta’s observation includes attorney argument which asserts that Dr.
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`Kiaei is “consistently inconsistent about Yamano’s periodic poll.” Mot. Obs. 14.
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`In making this argument, TQ Delta’s attorney points to nothing with the cited
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`testimony that is inconsistent. Moreover, TQ Delta omits Dr. Kiaei’s deposition
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`testimony where he explains that “the polling as it said here in line 25, column 15
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`onwards, is that a periodic poll or some other signal is used between the receiver
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`and transmitter to synchronize the time period -- the time periods where non-idle
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`detector is on polling the transmitter” and that “I said that it periodically turns on
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`the non-idle detector, and during these time periods, a periodic poll is happening
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`between the transmitter and the receiver, or the receiver and the transmitter during
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`these time intervals, which is the non-idle detector is on, by which it is able to get
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`the data -- the packet data from transmitter to receiver.” Ex. 2017, 105:16-21,
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`106:10-17. Moreover, the cited testimony is consistent with Dr. Kiaei’s
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`declaration that “Yamano describes transmit and receive circuitry in a modem that
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`can operate in a reduced power consumption mode while a synchronization signal
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`is transmitted and received while in this reduced power mode.” Ex. 1003, ¶71.
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`October 16, 2017
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`Respectfully submitted,
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`/David L. McCombs/
`David L. McCombs
`Counsel for Petitioner
`Registration No. 32,271
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`CERTIFICATE OF SERVICE
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`The undersigned certifies, in accordance with 37 C.F.R. § 42.205, that
`service was made on the Patent Owner as detailed below.
`
`Date of service
`
`October 16, 2017
`
`
`
`Manner of service
`Email: pmcandrews@mcandrews-ip.com;
`twimbiscus@mcandrews-ip.com; smcbride@mcandrews-ip.com;
`cscharff@mcandrews-ip.com; rchiplunkar@mcandrews-ip.com;
`dpetty@mcandrews-ip.com; TQD-IPR2016-01466@mcandrews-ip.com
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`Documents served
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`Petitioner’s Response to Patent Owner’s Motion
`for Observation on Cross-examination Testimony
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`Peter J. McAndrews
`Thomas J. Wimbiscus
`Scott P. McBride
`Christopher M. Scharff
`David Z. Petty
`Rajendra A. Chiplunkar (admitted PHV)
`MCANDREWS, HELD & MALLOY, LTD
`500 West Madison Street, 34th Floor
`Chicago, IL 60661
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`
`
`/David L. McCombs/
`David L. McCombs
`Counsel for Petitioner
`Registration No. 32,271
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