`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________
`
`I.M.L. SLU,
`
`Petitioner,
`
`v.
`
`WAG ACQUISITION, LLC,
`
`Patent Owner.
`_________________________
`
`Case IPR2016-01656
`Patent 8,122,141
`________________________
`
`
`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE TO
`PETITION
`
`
`
`
`IPR2016-01656
`I.M.L. SLU
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`TABLE OF CONTENTS
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`Page
`
`
`I.
`
`INTRODUCTION ........................................................................................... 1
`
`II. DISCUSSION .................................................................................................. 2
`
`A.
`
`Patent Owner’s Proposed Claim Construction Is Untenable ................ 2
`
`B.
`
`C.
`
`Claims 19-23 Fall With Patent Owner’s Claim Construction .............. 8
`
`Chen Discloses a “Pull Mechanism” ..................................................... 9
`
`D.
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`Claim 21 Falls With Patent Owner’s "Pull" Critique of Chen
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`
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`III. CONCLUSION .............................................................................................. 12
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`
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`IPR2016-01656
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`i
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`TABLE OF AUTHORITIES
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` Page(s)
`
`Cases
`
`Deere & Co. v. Bush Hog, LLC,
`703 F.3d 1349 (Fed. Cir. 2012) ............................................................................ 3
`
`Icon Health & Fitness, Inc. v. Strava, Inc.,
`849 F.3d 1034 (Fed. Cir. 2017) ............................................................................ 2
`
`Kara Technology Inc. v. Stamps.com Inc.,
`582 F.3d 1341 ....................................................................................................... 7
`
`Phillips v. AWH Corp.,
`415 F.3d 1303 (Fed. Cir. 2005)(en banc) ............................................................. 4
`
`SRI Int’l v. Matsushita Elec. Corp. of Am.,
`775 F.2d 1107 (Fed. Cir. 1985) ............................................................................ 4
`
`Thorner v. Sony Comput. Entm’t Am. LLC,
`669 F.3d 1362 (Fed. Cir. 2012) ............................................................................ 3
`
`United States v. Adams,
`383 U.S. 39 (1966) ................................................................................................ 2
`
`
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`IPR2016-01656
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`ii
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`I.
`
`INTRODUCTION
`
`Patent Owner’s assertion that claims 19-23 of the ’141 Patent are patentable
`
`fails in multiple respects since it is built on (i) an unsupported claim construction
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`and (ii) faulty characterizations of the prior art. Patent Owner rests its patentability
`
`arguments on unsupported assertions that the claims should be construed to require
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`“a ‘pull’ mechanism” for streaming media “in response to repeated requests by the
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`client. . .” “by breaking the streaming media into serially identified elements. . .”
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`which elements are not “too small. . .” to work with the pull mechanism and which
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`will “achieve uninterrupted playback.” Patent Owner Response (“POR”), Paper
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`No. 20 at 2, 7, 8, 10 (emphasis added). None of the underlined terms are found in
`
`the claims at issue and there is no support for them in the patent specification
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`(except for the term “uninterrupted playback” which is expressly included in
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`claims not at issue, e.g., claim 1, and excluded from claims 19-23). Nor does
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`Patent Owner rationally explain why any of these terms should be imported into
`
`the claims even if they could draw support from the specification.
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`The error of Patent Owner’s overreaching claim construction is compounded
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`by its mischaracterization of the primary prior art reference, Chen. Contrary to
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`Patent Owner’s assertions, even if the challenged claims could be construed to
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`expressly require a “pull mechanism,” Chen discloses one.
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`IPR2016-01656
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`II. DISCUSSION
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`A.
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`Patent Owner’s Proposed Claim Construction Is Untenable
`
`Patent Owner seeks to have the claim phrase “in a format capable of being
`
`served to users by said server” to mean “a format whose characteristics make it
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`possible to serve the multimedia program comprised of those elements via the
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`recited ‘pull’ mechanism in order to achieve uninterrupted playback.” POR, Paper
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`No. 20, at 7. The Patent Owner fails to provide any, much less adequate, support
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`in the evidentiary record for this construction.
`
`The Board already considered and rejected the exact construction Patent
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`Owner proposes for a second time in the Patent Owner Response. Institution
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`Decision, Paper No. 11 at 9-10. Patent Owner does not adequately address any of
`
`the points made by the Board when it rejected the proposed construction for the
`
`first time in its Institution Decision. If not completely determinative, this weighs
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`heavily against Patent Owner's proposition.
`
`A proposed construction of a claim term must be supported by some
`
`evidence, not just attorney argument. See United States v. Adams, 383 U.S. 39, 49
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`(1966) (“it is fundamental that claims are to be construed in the light of the
`
`specifications and both are to be read with a view to ascertaining the invention.”);
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`Icon Health & Fitness, Inc. v. Strava, Inc., 849 F.3d 1034, 1046 (Fed. Cir. 2017)
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`(“Attorney argument is not evidence or explanation in support of a conclusion.”).
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`The only evidence that Patent Owner points to in the discussion of its proposed
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`construction is column 4, lines 55-56 of the ’141 Patent to quote the phrase
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`“Internet streaming media composed of a plurality of time-sequenced data
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`elements.” POR, Paper No. 20, at 8. This statement in the ’141 Patent is
`
`immaterial to the proposed construction. Apart from this single quotation, the
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`Patent Owner points to nothing in the intrinsic record, i.e., the claims, specification
`
`and prosecution history, that support the proposed construction. Nor does Patent
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`Owner rely on any extrinsic evidence in support of its proposed construction.
`
`Patent Owner’s entire discussion in support of its proposed construction relies on
`
`nothing more than attorney argument about what certain terms in claim 19 should
`
`mean. Patent Owner’s construction must be rejected as a matter of law.
`
`Even if it were capable of supporting the proposed construction as a matter
`
`of law, which it is not, Patent Owner’s argument is not only unconvincing, but also
`
`improperly imports narrowing limitations into the claim and conflicts with the
`
`doctrine of claim differentiation. Narrowing limitations should not be arbitrarily
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`imported into a claim via claim construction. See Deere & Co. v. Bush Hog, LLC,
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`703 F.3d 1349, 1354 (Fed. Cir. 2012) (“While claim terms are understood in light
`
`of the specification, a claim construction must not import limitations from the
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`specification into the claims.”). “The words of a claim are generally given their
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`ordinary and customary meaning as understood by a person of ordinary skill in the
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`3
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`art when read in the context of the specification and prosecution history.” Thorner
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`v. Sony Comput. Entm’t Am. LLC, 669 F.3d 1362, 1365 (Fed. Cir. 2012). “There
`
`are only two exceptions to this general rule: 1) when a patentee sets out a definition
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`and acts as his own lexicographer, or 2) when the patentee disavows the full scope
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`of a claim term either in the specification or during prosecution.” Id. Construction
`
`of a claim term is only warranted under these exceptions. When a construction is
`
`warranted, it must be supported by facts found in the intrinsic and/or extrinsic
`
`record. See Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (en banc). A
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`claim construction should also avoid introducing a narrowing limitation that is
`
`expressly recited in another claim but not in the claim being construed. See SRI
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`Int’l v. Matsushita Elec. Corp. of Am., 775 F.2d 1107, 1122 (Fed. Cir. 1985) (“It is
`
`settled law that when a patent claim does not contain a certain limitation and
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`another claim does, that limitation cannot be read into the former claim in
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`determining either validity or infringement.”)
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`Proposed “multimedia program” limitation: Claim 19 recites “streaming
`
`media content” and “media data element” and should not employ a construction
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`which unexplainably is limited to a “multimedia program.” Ex. 1001, ’141 Patent,
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`14:49-58; POR, Paper No. 20, at 7.
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`Proposed “those elements” limitation: Claim 19 refers to “media data
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`elements” and “sequential data elements,” respectively, as elements that are
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`requested and capable of being serially identified. Ex. 1001, ’141 Patent, 14:49-
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`58. There is no reason to introduce a new “those elements” limitation which is
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`indefinite because it may refer back to one or both of the expressly recited
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`“elements.” Including an ambiguous term in a construction would only leave the
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`Board to guess at which of the “elements” are being referenced.
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`Proposed “recited ‘pull’ mechanism” and “uninterrupted playback”
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`limitations: To start, Patent Owner’s assertion that the term “‘pull’ mechanism” is
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`“recited,” is misleading. POR, Paper No. 20, at 7 (“Patent Owner asserts that the
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`proper construction of the italicized portion in this claim language means a format
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`whose characteristics make it possible to serve the multimedia program comprised
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`of those elements via the recited ‘pull’ mechanism. . .”) (emphasis added). The
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`word “pull” is not recited anywhere in the ’141 Patent, including claim 19. The
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`only place the term “pull” is “recited” is in Patent Owner’s attorney argument.
`
`Patent Owner’s argument, that the term “‘pull’ mechanism” (where the term
`
`“pull” is always delineated by quotation marks, implying it is being used
`
`figuratively in today’s parlance) should be included in the proposed construction,
`
`is a bootstrap. The Patent Owner starts with the unsupported argument that
`
`“[c]laim 19 and its dependents are directed at preparing streaming media for pull
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`transmission by breaking the streaming media into serially identified elements and
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`appropriately formatting the elements for transmission.” POR, Paper No. 20, at 8
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`(emphasis added). No support in the record is provided for this premise generally,
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`or for the use of the specific terms “pull transmission” or “appropriately
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`formatting” as describing the subject matter of claim 19.
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`Patent Owner next argues that the claim phrase “format capable of being
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`served to users by said server” should mean “a format that can be served by the
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`server for which the stream is being prepared in accordance with claim 19.” Id.
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`(emphasis added). Again, no factual support is identified for this transitional
`
`construction which Patent Owner uses to bridge the claim language to its final
`
`construction. Notably, by adding the catch-all “in accordance with claim 19”
`
`phrase to the evolving construction, Patent Owner sets up its introduction of the so-
`
`called “recited ‘pull’ mechanism” into the final construction.
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`In the penultimate step of forming its proposed construction, Patent Owner
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`slips in a new component - namely that the claimed formatted elements must
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`support “‘streaming’ a plurality of ‘time-sequenced data elements’ comprising a
`
`multimedia program in the uninterrupted manner normally expected of such
`
`streaming.” Id. (emphasis added). No factual support, or rational explanation, is
`
`provided for this generation of the proposed construction in general, or for the
`
`underlined terms specifically.
`
`In the final step to its proposed construction, Patent Owner argues that from
`
`the foregoing progression, a PHOSITA would have understood that the term
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`“capable of being served to users by said server,” means “a data format that is
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`capable of being served in accordance with the features of a ‘pull’ server; that is, a
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`format whose characteristics make it possible to serve the multimedia program
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`comprised of those elements via the recited ‘pull’ mechanism (client request by
`
`specified serial identifier) in order to achieve uninterrupted playback.” Id. at 9.
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`Patent Owner’s assertion of what would have been understood by a PHOSITA at
`
`the time is not supported by any reference to testimony from its own expert.
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`The foregoing step-by-step breakdown of Patent Owner’s explanation of its
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`proposed construction reveals that it is nothing more than multiple layers of
`
`attorney argument. Pure argument without support in the record cannot provide a
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`basis to adopt the proposed construction, and accordingly it should be rejected as a
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`matter of law.
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`The proposed instruction, by including the requirement that the claimed
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`format “achieve uninterrupted playback,” is unwarranted for one additional reason
`
`to those stated above. Claims 1 and 24 of the ’141 Patent expressly recite the
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`requirement of providing uninterrupted playback. Ex. 1001, ’141 Patent, 13:44,
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`16:3. The inventor could have included this limitation in the claim if he so desired,
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`but choose to exclude it. It is inappropriate to import the "uninterrupted playback"
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`limitation into a claim construction of claim 19 when the limitation was known to
`
`the inventor, expressly recited in other claims, and excluded from the claim being
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`7
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`
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`construed. See Kara Technology Inc. v. Stamps.com Inc., 582 F.3d 1341, 1347
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`(“Here, when the inventor wanted to restrict the claims to require the use of a key,
`
`he did so explicitly. None of the claims at issue on appeal recite the term ‘key.’ By
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`contrast, all of the other independent claims require either an ‘encryption key’ or
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`‘key data.’”). This principal provides an independent basis for refusing to adopt
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`Patent Owner's proposed construction.
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`In summary, the construction advanced by Patent Owner for the phrase
`
`“format capable of being served to users by said server” is unsupported and
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`overreaching. Patent Owner provides no reasonable basis to construe this claim
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`language as proposed, and even if it did, it must be rejected since it lacks any
`
`evidentiary support.
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`B. Claims 19-23 Fall With Patent Owner’s Claim Construction
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`Patent Owner’s argument in favor of the patentability of claims 19-23 is
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`dependent upon its proposed construction of “format capable of being served to
`
`users by said server.” POR, Paper No. 20, at 9-13. Patent Owner contests
`
`anticipation by Chen based on the assertion that “Chen’s packets are not ‘in a
`
`format capable of being served to users’ in the ‘pull’ configuration contemplated
`
`by claim 19.” Id. at 11. Likewise, Patent Owner’s expert’s opinion in support of
`
`patentability depends upon the faulty claim construction. Ex. 2003, Teruya Decl.,
`
`¶11 (Teruya states that to ensure data elements “are ‘capable of being served to
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`users by said server’ as stated in claim 19, these media data elements must be in a
`
`format that is satisfactory for the underlying ‘pull’ mechanism between the server
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`and the client.” Id. Thus, if Patent Owner’s proposed construction is not adopted,
`
`its arguments in favor of patentability, as well as those of its expert, fall with it.
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`C. Chen Discloses a “Pull Mechanism”
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`Even if Patent Owner’s defense was not fatally hitched to its claim
`
`construction, which it is, the argument and the opinion testimony it submitted in
`
`favor of patentability are contradicted by the express content of Chen.
`
`Notwithstanding Patent Owner’s and its expert’s opinions, there can be no dispute
`
`that Chen discloses a “pull” architecture, i.e., an architecture that according to
`
`Patent Owner’s expert is “a media streaming architecture that responds to user
`
`requests for media data elements identified by a serial identifier.” Ex. 2003,
`
`Teruya Decl., ¶12. Claim 19 expressly recites the requirement that Patent Owner's
`
`expert uses to define a pull architecture, i.e., “wherein said server responds to user
`
`requests for media data elements identified by a serial identifier.” Ex. 1001, ’141
`
`Patent, 14:52-54. Neither Patent Owner nor its expert contest that this element of
`
`claim 19 is disclosed by Chen. Instead, Patent Owner’s entire argument in favor of
`
`patentability grows out of its already rejected construction of the phrase “format
`
`capable of being served to users by said server.” POR, Paper No. 20, at 9-13.
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`
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`The disclosure in Chen of a “server [that] responds to user requests for
`
`media data elements identified by a serial identifier” is explained at length in the
`
`Petition (referred to as element 19[b] therein), which explanation need not be
`
`repeated here. See e.g., Petition, Paper No. 2, at 23-27, 45. Suffice it to say that
`
`Chen states repeatedly that the client in its system retrieves multimedia data from
`
`the server as the result of sending requests for the data and that packet sequence
`
`numbers are used for such “retrieval” which is the hallmark of a pull architecture
`
`as described by Patent Owner and its expert. See e.g., Ex. 1002, Chen, 5:17-20,
`
`7:24-45.
`
`Careful perusal of Patent Owner’s arguments and the assertions of its expert
`
`reveal that their case for patentability, like that for claim construction, is built upon
`
`an unsupported foundation. For example, Patent Owner asserts that Chen’s
`
`packets are purportedly “too small” to be capable of being served as intended by
`
`Chen’s lost-packet mechanism and “too small” to support a “pull” architecture.
`
`POR, Paper No. 20, at 9-10; Ex. 2003, Teruya Decl., ¶¶12-19. Patent Owner’s
`
`argument is based entirely on opinion testimony, which in turn cites nothing in
`
`support. See id. Indeed, to support his opinion that Chen discloses packets that are
`
`too small, Teruya opines that “Chen transmits video frames that have been further
`
`packetized with each packet holding only a portion of a frame.” Ex. 2003, Teruya
`
`Decl., ¶13. Yet, no citation to Chen is provided in support of this predicate for
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`10
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`Teruya’s opinion. Later, Teruya states “Chen packetizes each frame into multiple,
`
`smaller packets. . .” but the citations to Chen do not support this characterization in
`
`that they refer instead to frame timing and frame transmission. Id., ¶15, citing Ex.
`
`1002, Chen, 9:53-59, 10:10-19. Thus, Teruya’s opinion that Chen’s packets are
`
`too small is not based on any disclosure in Chen about packet size, but rather
`
`Teruya’s assumption about the size of Chen’s packets.
`
`As it turns out, Teruya’s assumption that Chen discloses packets of less than
`
`a frame size is belied by his own testimony, which if anything, supports
`
`Petitioner’s position. Teruya admits that “a PHOSITA would not have considered
`
`‘pull’ packet sizes of less than a frame because such small packets would require
`
`excessive amounts of signaling from the client.” Ex. 2003, Teruya Decl., ¶14.
`
`Applying this precept from Teruya, a PHOSITA reading Chen would have
`
`understood that it could use frame-sized packets since Chen indisputably discloses
`
`a pull architecture.
`
`D. Claim 21 Falls With Patent Owner’s “Pull” Critique of Chen
`
`Patent Owner’s argument in favor of the patentability of claim 21, like its
`
`other arguments, is based on the proposition that Chen does not disclose a “pull
`
`architecture.” See POR, Paper No. 20, at 13-17. This argument fails for two
`
`reasons: the claim does not require a pull architecture, and even if it did, Chen
`
`discloses one. See Section II.C., above.
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`IPR2016-01656
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`11
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`Patent Owner quibbles with the combination of Chen and Willebeek and that
`
`of Chen and Carmel based on its argument that Chen's packets are too small for use
`
`in a pull architecture. POR, Paper No. 20, at 15-16. As before, Patent Owner's
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`argument grows from the presumptions that claim 19 requires a pull architecture
`
`and that, if it does, that Chen does not disclose a pull system. Patent Owner is
`
`wrong on both points.
`
`Patent Owner and its expert do not contest that Chen meets the claim
`
`limitation that they use to define a pull architecture. See Ex. 2003, Teruya Decl.,
`
`¶12. Claim 19 recites, and Patent Owner does not contest that Chen discloses, a
`
`"server [that] responds to user requests for media data elements identified by a
`
`serial identifier." Ex. 1001, '141 Patent, 14:52-54; According to Patent Owner's
`
`expert, a PHOSITA would have understood that a pull architecture (like Chen's)
`
`would have used frame sized packets (assuming, arguendo, that Patent Owner's
`
`expert is correct on this point). Thus, Patent Owner's points made in connection
`
`with claim 21 are unpersuasive.
`
`III. CONCLUSION
`
`For the foregoing reasons, Petitioner respectfully requests that claims 19-23
`
`be cancelled as unpatentable.
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`
`/David R. Yohannan/
`David R. Yohannan
`Reg. No. 37,480
`Lead Counsel for Petitioner
`QUARLES & BRADY LLP
`1701 Pennsylvania Avenue NW
`Washington, D.C. 20006
`David.Yohannan@quarles.com
`Phone: 202-780-2637
`Fax: 202-372-9599
`
`Steven Yovits
`Reg. No. 48,055
`Backup Counsel for Petitioner
`Kelley Drye & Warren LLP
`333 W Wacker Dr # 2600
`Chicago, IL 60606
`syovits@kelleydrye.com
`
`
`Beth D. Jacob
`Admitted pro hac vice
`Kelley Drye & Warren LLP
`101 Park Avenue
`New York, NY 10178
`bjacob@kelleydrye.com
`Phone: 212-808-7624
`Fax: 212-808-7897
`
`
`Dated: August 28, 2017
`
`
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`IPR2016-01656
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`CERTIFICATION UNDER 37 CFR § 42.24(d)
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`Under the provisions of 37 CFR § 42.24(d), the undersigned hereby certifies that
`the word count for the foregoing Reply to Patent Owner’s Response To Petition
`totals 2,953, which is less than the 5,600 words allowed under 37 CFR
`§42.24(c)(i).
`
`
`Dated: August 28, 2017
`
`/David R. Yohannan/
`David R. Yohannan
`Reg. No. 37,480
`Lead Counsel for Petitioner
`QUARLES & BRADY LLP
`1701 Pennsylvania Avenue NW
`Washington, D.C. 20006
`David.Yohannan@quarles.com
`Phone: 202-780-2637
`Fax: 202-372-9599
`
`
`
`IPR2016-01656
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`CERTIFICATE OF SERVICE
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`I certify that, on August 28, 2017, I caused to be served true and correct
`
`copies of the foregoing “PETITIONER’S REPLY TO PATENT OWNER’S
`
`RESPONSE TO PETITION” on Patent Owner by filing through the PTAB E2E
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`System and by electronic mail on the following attorneys, as authorized in Patent
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`Owner’s Mandatory Notices:
`
`
`
`Ernest D. Buff
`Ernest D. Buff & Associates, LLC
`231 Somerville Road
`Bedminster, NJ 07921
`ebuff@edbuff.com
`
`
`
`
`
`
`
`
`
`Dated: August 28, 2017
`
`IPR2016-01656
`I.M.L. SLU
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`Ronald Abramson
`David G. Liston
`Ari J. Jaffess
`M. Michael Lewis
`Lewis Baach PLLC
`The Chrysler Building
`405 Lexington Avenue
`New York, NY 10174
`ronald.abramson@LBKMLAW.com
`David.Liston@LBKMLAW.com
`Ari.jaffess@LBKMLAW.com
`Michael.lewis@LBKMLAW.com
`
`
`
`/David R. Yohannan/
`David R. Yohannan
`Reg. No. 37,480
`Lead Counsel for Petitioner
`QUARLES & BRADY LLP
`1701 Pennsylvania Avenue NW
`Washington, D.C. 20006
`David.Yohannan@quarles.com
`Phone: 202-780-2637
`Fax: 202-372-9599
`
`
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