`
`I N T E R P A R T E S R E V I E W C A S E N O .
`
`I P R 2 0 1 6 - 0 1 6 8 8 : U . S . P A T E N T N O . 9 , 3 0 0 , 7 9 2
`
`TWILIO INC.
`TWILIO INC.
`PETITIONER
`
`©
`
`O C T O B E R 2 5 , 2 0 1 7
`
`Twilio Inc., EX 1036
`
`
`
`Instituted Claims
`1, 2, 4, 6, 8, 10, 11, 13, 15,
`and 17
`
`Disclaimed Claims
`3, 5, 7, 12, 14, and 16
`
`2
`
`
`
`The only elements in dispute
`
`EX. 1001 at cl. 1
`
`3
`
`
`
`Previous IPRs denied—lack of “notification event”
`
`Paper 10, Decision to Institute at 17
`
`4
`
`
`
`Construction of “notification event”
`
`Paper 10, Decision to Institute at 10
`
`5
`
`
`
`Bennett teaches everything besides “notification events”
`
`Paper 10, Decision to Institute at 19
`
`6
`
`
`
`PO makes four arguments
`
`Paper 15, PO Response at ii
`
`7
`
`
`
`PO’s first argument
`
`Paper 15, PO Response at ii
`
`8
`
`
`
`Bennett teaches “actions”
`
`From Bennett:
`
`Petition at 38; EX 1003 (Bennett) at 15:66-16:1
`
`9
`
`
`
`Bennett teaches “actions”
`
`EX 1003 at 13:1-23, Petition at 38
`
`10
`
`
`
`PO’s expert on “actions”
`
`EX 1035 at 21:12-22, Paper 18 (Reply at 16-17)
`
`11
`
`
`
`PO’s expert on “actions”
`
`EX 1035 at 18:13-23, Paper 18 (Reply at 10)
`
`12
`
`
`
`PO’s expert on “actions”
`
`EX 1035 at 18:24-19:5, Paper 18 (Reply at 10)
`
`13
`
`
`
`Bennett teaches “actions”
`
`Petition at 38; EX 1003 (Bennett) at 15:66-16:1
`
`14
`
`
`
`Bennett teaches “actions”
`
`EX 1003 at 13:1-23, Petition at 38
`
`15
`
`
`
`PO on “actions”
`
`Paper 15, PO Response at 19 and 21.
`
`16
`
`
`
`PO on “actions”
`
`Paper 15, PO Response at 26
`
`17
`
`
`
`Bennett teaches “actions”
`
`From Bennett:
`
`Petition at 38; EX 1003 (Bennett) at 15:66-16:1
`
`18
`
`
`
`Bennett teaches “actions”
`
`EX 1003 at 13:1-23, Petition at 38
`
`19
`
`
`
`Bennett teaches “actions”
`
`Petition at 38-39; EX1003, Fig. 3
`
`20
`
`
`
`Campbell discloses “actions”
`
`Petition at 44.
`
`21
`
`
`
`Campbell discloses “actions”
`
`Petition at 44; EX1004 at [0015]-[0018]
`
`22
`
`
`
`Campbell discloses “notification events”
`
`Paper 10, Decision to Institute at 10
`
`23
`
`
`
`Campbell discloses “notification events”
`
`Petition at 44-47; Reply at 12; EX1004 at [0041]; EX1002 at ¶¶114-118
`
`24
`
`
`
`PO’s expert on “notification events”
`
`EX 1035 at 21:12-22, Paper 18 (Reply at 16-17)
`
`25
`
`
`
`PO’s expert on “notification events”
`
`Reply at 11-12; EX1035 at 21:23-22:16
`
`26
`
`
`
`PO’s second argument
`
`Paper 15, PO Response at ii
`
`27
`
`
`
`Bennett discloses requiring acknowledgment
`
`Paper 10, Decision to Institute at 19.
`
`28
`
`
`
`Bennett discloses requiring acknowledgment
`
`Petition at 38
`
`29
`
`
`
`Bennett discloses requiring acknowledgment
`
`Petition at 38; EX1003 at 12:33-41, 14:29-36
`
`30
`
`
`
`Bennett discloses requiring acknowledgment
`
`Petition at 38-39; EX1003, Fig. 3
`
`31
`
`
`
`Bennett discloses requiring acknowledgment
`
`Petition at 38; EX1003 at 16:1-10
`
`32
`
`
`
`Campbell discloses requiring acknowledgment
`
`Petition at 44-45
`
`33
`
`
`
`Campbell discloses requiring acknowledgment
`
`Petition at 45; EX1004 at [0027]
`
`34
`
`
`
`PO’s third argument
`
`Paper 15, PO Response at iii
`
`35
`
`
`
`Petition: Bennett-Campbell
`
`Petition at i and 4.
`
`36
`
`
`
`Decision: Bennett-Campbell
`
`Paper 10, Decision to Institute at 12 and 23.
`
`37
`
`
`
`Campbell used for “notification event”
`
`Petition at 44 and 50.
`
`38
`
`
`
`Receiving an acknowledgement element
`
`EX 1001 at cl. 1
`
`39
`
`
`
`Transmitting a message and receiving acknowledgement
`
`EX 1001 at cl. 1
`
`40
`
`
`
`PO’s fourth argument
`
`Paper 15, PO Response at iii
`
`41
`
`
`
`Bennett, Campbell, and the ’792 are analogous
`
`Petition at 44; Paper 15, Reply at 3; EX1003 at Abstract; EX1004 at Abstract; EX1002 at ¶¶67-69, 114-118.
`
`42
`
`
`
`Bennett can and would use Campbell’s informative
`message to inform the user why she is receiving a code
`
`Petition at 54; Paper 15, Reply at 4; EX1002 at ¶125
`
`43
`
`
`
`Combining Bennett and Campbell would have been
`obvious to a POSA
`
`Paper 15, Reply at 5; EX1002 at ¶68
`
`44
`
`
`
`Combining Bennett and Campbell would have been
`obvious to a POSA
`
`Paper 15, Reply at 5; Petition at 55-56; EX1002 at ¶130; EX1003 at 16:39-43
`
`45
`
`
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