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`Case IPR2016-01756
`Patent 8,571,194
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`FACEBOOK, INC. and WHATSAPP INC.,
`Petitioners,
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`v.
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`UNILOC USA, INC., UNILOC LUXEMBOURG, S.A.,
`Patent Owner(s).
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`Case IPR2016-01756
`Patent No. 8,571,194
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`PETITIONERS’ REPLY
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`(309101-2137)
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`Case IPR2016-01756
`Patent 8,571,194
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`FACEBOOK, INC. and WHATSAPP INC.,
`Petitioners,
`
`v.
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`UNILOC USA, INC., UNILOC LUXEMBOURG, S.A.,
`Patent Owner(s).
`
`
`
`
`Case IPR2016-01756
`Patent No. 8,571,194
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`PETITIONERS’ REPLY
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`Table of Contents
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`Page
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`2.
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`Introduction ..................................................................................................... 2
`I.
`II. Wu and Howard Disclose “Without Requiring Registration” ....................... 3
`A. Wu ........................................................................................................ 4
`1. Wu’s Login Process Does Not Involve Registration
`“With A Conference Call Server”.............................................. 4
`The Authentication Processes in Figure 6 Do Not
`Require “Registration… By the Potential Members
`Including the First Party and the At Least One Other
`Party”.......................................................................................... 8
`The Patent Owner’s Claim Construction Arguments Are
`Irrelevant .................................................................................. 14
`B. Howard ............................................................................................... 18
`III. Wu Discloses “Without Requiring Individual Selection” ............................ 22
`IV. Conclusion .................................................................................................... 26
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`3.
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`List of Exhibits
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`Exhibit No.
`1022
`1023
`1024
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`Title of Document
`Deposition Transcript of Dr. DiEuliis (“DiEuliis Depo.”)
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`Excerpts from Stevens, TCP/IP Illustrated, Volume 1 (1994)
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`U.S. Patent Pub. No. 2004/0013254 to Max Hamberg et al.
`(“Hamberg”)
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`1025
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`Reply Declaration of David Klausner (“Klausner Reply”)
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`I.
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`INTRODUCTION
`The Patent Owner’s lengthy response spends very little time actually
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`addressing the Wu and Howard references. The Patent Owner spends dozens of
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`pages on irrelevant digressions about claim construction (while offering no actual
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`constructions), but does not connect those arguments to the prior art. It is not until
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`page 44 that the Patent Owner makes its first attempt to directly address the “without
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`requiring registration” limitation as disclosed in Wu. The Patent Owner argues that
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`Wu discloses multiple instances of “registration” (a term that the Patent Owner does
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`not construe and its expert refused to define), but those instances do not involve
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`registration “with a conference call server,” “by the potential members,” as the plain
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`language of the claims require.
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`With respect to instituted Ground 2, which adds the Howard reference, the
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`Patent Owner essentially has no answer. It is undisputed that under the combination
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`of Wu and Howard, users register only with authentication server 110 of Howard,
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`which sits entirely outside of the cluster of (AOL) servers in Wu. There is also no
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`serious dispute that the authentication server in Howard is not a “conference call
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`server,” under any conceivable construction of the term, because it has no
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`involvement in requesting or providing the voice communication features of Wu.
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`The Patent Owner is thus left arguing that the two references cannot be combined,
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`but ignores the extensive analysis and multiple motivations to combine set forth in
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`the Petition and acknowledged in the Institution Decision. For the reasons set forth
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`below and in the Petition, the Petitioners respectfully request that the Board find the
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`challenged claims unpatentable.
`II. WU AND HOWARD DISCLOSE “WITHOUT REQUIRING REGISTRATION”
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`The Patent Owner’s arguments gloss over the claim language, which recites
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`an “option” to automatically initiate voice communication “without requiring
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`registration with a conference call server for establishing the voice communication
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`by the potential members including the first party and the at least one other party.”
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`(’194, Claim 1.) This negative claim limitation imposes at least three separate
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`components: initiation of voice communication using the “option” must not require
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`(1) “registration,” (2) “with a conference call server,” (3) “by the potential members
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`including the first party and the at least one other party.” A prior art reference can
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`therefore disclose this negative limitation if it lacks even one of these three
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`components. For example, a prior art reference will satisfy this limitation even if it
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`requires registration, if that registration is not “with a conference call server.” A
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`prior art reference can also satisfy the limitation if it requires “registration with a
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`conference call sever,” but the registration is not performed “by the potential
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`members.” As shown below, all of the Patent Owner’s arguments about Wu ignore
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`one or more of the three components of the “without requiring registration”
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`limitation listed above.
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`This section will first address the Patent Owner’s arguments with respect to
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`Wu. This section will then address the disclosures of Howard, cited in combination
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`with Wu in instituted Ground 2.
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`A. Wu
`1. Wu’s Login Process Does Not Involve Registration “With A
`Conference Call Server”
`The Patent Owner contends that the login process in Wu, in which the user
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`enters her screen name and password to gain access to the system, involves
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`“registration with a conference call server.” But the Petition explained in great detail
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`why that login process requires the user to interact only with a “login server,” which
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`is not a “conference call server” because it has no involvement in establishing voice
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`communication. (Petition, at 40-48; Ex. 1002, ¶¶103-116.)
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`The Patent Owner relies on Paragraph 63 of Wu, which describes a logon
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`process that users follow to gain access to a service provider such as AOL.
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`(Response, at 44-45; DiEuliis Decl., Ex. 2003, ¶¶97-98 (citing Wu, ¶0063); see also
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`Wu, ¶¶0003-4.) That paragraph describes a process in which a user inputs a screen
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`name and password, which “host 604” uses to determine if the user is authorized to
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`access the system. (Wu, ¶0063.) The Patent Owner appears to argue that because
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`“host 604” performs the login process, and “host 604” also performs steps required
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`to initiate voice communication, Wu discloses registration “with a conference call
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`server” and thus does not satisfy the negative limitation. (Response, at 43-48.)
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`But the “host” device in Wu relied upon by Petitioners is not a monolithic
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`server, but a collection of discrete components and systems – including a separate
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`login server. The Petition explained in great detail, including with annotations to
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`Figures 3 and 5 of Wu, why the login server (350, 570) of the host device (335, 535)
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`is both physically and functionally separate from the “conference call server” that is
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`responsible for voice communication services. (Petition, at 41-46; see also Wu,
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`¶0032 (“The host device 335 [of Figure 3] includes a login server 370…”), ¶¶0049-
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`0050 (same; Figure 5 including login server 570).)
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`Wu makes clear that the “host 604” relied upon by the Patent Owner shares
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`those same characteristics. For example, three paragraphs up from the passage cited
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`by the Patent Owner, Wu states that “[t]he host 604 [of Figure 6] typically has
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`attributes comparable to those described with respect to host device 135, 235, 335,
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`435, and 535” (Wu, ¶0060), explicitly referring back to the more detailed depictions
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`of the host device 335 and 535 that were discussed in the Petition.1 One of ordinary
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`skill would thus have understood that the login process in Paragraph 63 would be
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`performed by the login server component of “host 604,” consistent with every other
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`1 All underlining has been added for emphasis.
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`5
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`embodiment in Wu. (Klausner Reply, Ex. 1025, ¶¶26-29.)2
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`The Patent Owner also has no answer to the disclosure in Paragraph 51 of Wu
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`(described in detail in the Petition), which explains that the login server 570 of Wu
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`“breaks the connection” with the client after login authentication is completed,
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`allowing the client to connect directly to the IM server using the IP address provided
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`by the login server. (Petition, at 43-46; Ex. 1002, ¶¶110, 111; Wu, ¶0051.)3 The
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`2 The Patent Owner’s mischaracterization of the “host” as a monolithic entity also
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`ignores Wu’s teaching that “[f]or brevity, several elements in the figures described
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`[] are represented as monolithic entities. However, as would be understood by one
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`skilled in the art, these elements each may include numerous interconnected
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`computers and components designed to perform a set of specified operations.” (Wu,
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`¶0014.) Indeed, the Patent Owner appears to concede that there is “express
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`disclosure in Wu that the host may be implemented as multiple computing devices.”
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`(Response, at 53 (citing Wu, ¶20).)
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`3 Instead, the Patent Owner can only quibble that Wu does not expressly list
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`“establishing a talk session” as one of the functions performed by the IM host
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`complex 590. (Response, at 55-56.) But one of ordinary skill would have certainly
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`understood that it is performed by one of the servers within the IM host complex 590
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`based on Wu’s teachings, although Wu may not refer to any particular server using
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`Patent Owner suggests that the login server is somehow still involved with the voice
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`communication (Response, at 56), but the Patent Owner’s own expert agreed at his
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`deposition that by the time users in Wu have entered into an IM session, any
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`connection between the users and the login server has been broken. (Ex. 1022,
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`84:25-85:2, 86:2-8.) Wu does not suggest that the login server 570 has any role in
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`providing any services to the client (including IM and voice communication
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`services) after that connection is broken. Moreover, any contention that the login
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`server in Wu must be mapped as part of the claimed “conference call server” – no
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`matter how tangential its “role in establishing a talk session” (Response at 59, 60) –
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`is without merit. (See also id., at 51-54.) The ’194 specification contemplates that
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`even components that play a role in establishing a talk session can nevertheless be
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`“discrete from” the conference call server. (’194, 6:14-29.)
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`Finally, the Patent Owner’s own arguments confirm that the login process in
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`the nomenclature “conference call server.” (Klausner Reply, ¶29 (citing Wu,
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`¶¶0052, 0059, 0065, Fig. 6).) Moreover, while the Patent Owner contends that Wu’s
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`process is “analogous to the registration required in Hamberg and successfully
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`distinguished from the claims during prosecution” (Response, at 48), Hamberg,
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`unlike Wu, does not use a separate login server that “breaks the connection” with
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`the client after login authentication. (See Hamberg, Ex. 1024.)
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`Wu is irrelevant to the “without requiring registration” limitation. The Patent
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`Owner’s own expert concedes that the “without requiring registration” limitation
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`only becomes operative when the claimed “option” to initiate voice communication
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`is displayed to the user. (Klausner Reply, ¶30 (quoting DiEuliis Decl., Ex. 2003,
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`¶40).) This is further confirmed by a passage in the ’194 specification that the Patent
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`Owner cites as a “teaching[] concerning automatic
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`initiation of voice
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`communication” without requiring registration. (Response, at 21-22 (citing ’194
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`patent, 4:25-38).) That passage expressly contemplates that potential participants
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`may have registered with “the instant messaging service” prior to the initiation of
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`the voice communication. (’194, 4:33-38.) Because the login process in Wu
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`similarly occurs before the “option” (the “START TALK” button in Figure 7) even
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`appears, that process is irrelevant to the “without requiring registration” limitation.
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`(Klausner Reply, ¶30.)
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`2.
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`The Authentication Processes in Figure 6 Do Not Require
`“Registration… By the Potential Members Including the
`First Party and the At Least One Other Party”
`The Patent Owner also argues that, beyond the initial login process addressed
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`above, the process in Figure 6 of Wu “requires two registrations: one to authenticate
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`a text message and another just prior to initiating voice communication.” (DiEuliis
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`Decl., Ex. 2003, ¶99; see also id., ¶¶80-81; Response, at 45-48.) The first purported
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`“registration” identified by the Patent Owner appears in Paragraph 67 of Wu in
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`which the host authenticates a text message by a sender (Step 610), and the second
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`appears in Paragraph 72 in which the host authenticates a “talk request” from the
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`sender (Step 650). (See Wu, ¶¶0067, 0072; Response, at 45-49; DiEuliis Decl.,
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`¶¶79-80.) But neither of these purported “registrations” takes Wu out of disclosing
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`the “without requiring registration” requirement.
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`The Patent Owner does not provide any reasoned explanation as to why either
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`of these two authentication steps involve “registration… by the potential members,”
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`as claimed. This is not surprising considering that the Patent Owner provides no
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`construction for the “registration” term. The Patent Owner’s expert, in fact, refused
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`at his deposition to explain how he was interpreting “registration” and testified that
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`he had formed no opinion on the subject. (DiEuliis Depo., Ex. 1022, 41:14-42:13.)
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`The Patent Owner’s arguments thus reduce to nothing more than attaching the label
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`“registration” to authentication processes in Wu, without any accompanying
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`explanation as to how those processes apply to the claim language.
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`Nevertheless, as explained above and in the Petition, the only time a user
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`registers in Wu is during the initial login with the separate login server, which is not
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`a conference call server. The authentications in Steps 610 and 650 of Figure 6 reflect
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`steps that occur after login with the login server has completed. (Wu, ¶¶0063, 0067,
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`0071.) Those do not show additional “registration[s]… by the potential members,”
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`as the Patent Owner asserts, but describe how the system responds to requests from
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`a user to initiate communications among already-registered members. Neither of
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`those authentication steps requires the user to reenter username and password
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`information, or supply any other personal information to gain access to the system,
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`because that process already took place when the user logged in using the login
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`server. (Petition, at 45-48; Ex. 1002, ¶¶111-116; Klausner Reply, ¶36.)
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`The Patent Owner’s arguments conflate “registration… by the potential
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`members” with “authentication,” but the two are not the same thing. Networked
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`computer systems will often – without requiring further input from the user –
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`perform authentication processes when requests are received to ensure that the user
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`continues to have proper access to the system. (Klausner Reply, ¶36.) But the act
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`of authentication by the server in Wu is not the same thing as registration by the
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`potential members, which is what the claim recites.4 As noted, these authentications
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`do not involve the user reentering the registration information it used to login to the
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`service. (Id., ¶¶36, 37.)
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`To the extent any construction can be discerned from the Patent Owner’s
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`response, it appears to be so broad as to exclude every embodiment in the
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`4 Note the claimed requirement of registration “by the potential members” does not
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`depend on any construction of “registration” itself, as discussed further below in the
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`text.
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`specification of the ’194 patent. As explained in the Petition, the applicant stated
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`during prosecution that:
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`The embodiments described above with respect to paragraphs 22, 23
`and 50-53 [of U.S. Pub. No. 2011/0033035, Ex. 1009] clearly do not
`require prior registration with a conference call server by potential
`members of a voice communication. Indeed, the conference server may
`simply strip telephone numbers from the conference request message
`sent from the instant messaging service and establish the voice
`communication directly therefrom.
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`(Petition, at 27-28 (quoting Ex. 1010, p.10).) The applicant did not identify any
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`other embodiment as support for this claim limitation.
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`Those embodiments describe a process in which a conference call requester
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`sends a “conference request message” to the conference call server – a message that
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`mirrors the talk request in Wu. As explained in Paragraph 52 of the applicant’s
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`published application (which appears verbatim in the issued patent):
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`When a conference call requester desires to initiate a conference call,
`the conference call requester may generate 106 a message (hereafter
`referred to as the ‘conference request message’) to the conference
`server identifying the parties who are potential recipients (‘potential
`targets’) to a conference call.
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`(Ex. 1009, ¶52; see also ’194, 6:44-51 (same disclosure as ¶52).) Paragraph 53 goes
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`on to explain that “[t]he conference request message may then be received 110 by
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`the conference server. The conference server may parse 112 the received message to
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`determine the address of the selected conference call targets.” (Ex. 1009, ¶53; see
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`also ’194, 6:59-62 (same disclosure as ¶53).)
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`Thus, just like the talk request in Wu, the “conference request message” in the
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`’194 patent – an integral part of the very embodiment that the applicants identified
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`as support for the “without requiring registration” requirement – identifies the
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`potential participants to the communication. There is no material difference between
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`the “conference request message” in the specification and the “talk request” in Wu.
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`(Compare Wu, ¶0071 (“The talk request may contain information including, but not
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`limited to, the message type, the screen name and/or IP address of the sender and
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`recipient, and a randomly generated security number”), with ’194, 6:44-51 (“[T]he
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`conference call requester may generate 106 a message (hereafter referred to as the
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`‘conference request message’) to the conference server identifying parties who are
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`potential participants (‘potential targets’) to a conference call. The potential call
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`targets may be identified by an alias, such as a user name associated with the
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`conference call targets in the conference call requester’s NAD.”); see also Klausner
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`Reply, ¶¶39-41.)
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`Thus, to the extent sending the “talk request” of Wu involves registration by
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`the potential members (which it does not as discussed above), then so too would
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`transmission of the “conference request message” to the conference call server as
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`described in the specification of the ’194 patent.
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`Federal Circuit law is clear that a “claim construction that excludes a preferred
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`embodiment… is rarely, if ever correct and would require highly persuasive
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`evidentiary support.” Epos Techs. Ltd. v. Pegasus Techs Ltd., 766 F.3d 1338, 1347
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`(Fed. Cir. 2014) (citation omitted). The Patent Owner has not even addressed the
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`preferred embodiment discussed above, let alone offered any “highly persuasive
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`evidentiary support.”5 The Patent Owner’s apparent interpretation of “registration”
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`would exclude not only a preferred embodiment, but the sole embodiments the
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`applicant identified during prosecution as providing support for the “without
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`requiring registration” limitation. (Ex. 1010, p.10.) Accordingly, the Board should
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`reject the Patent Owner’s suggestion that “registration…by the potential members”
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`5 The Patent Owner and its expert instead point to other embodiments in the
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`specification, including the very embodiments the Examiner found (and the
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`applicant did not dispute) disclosed prior registration. (Response, at 21-23; DiEuliis
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`Decl., ¶¶57-59.) Those embodiments either affirmatively require registration with a
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`conference call server, or are irrelevant to the “without requiring registration”
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`limitation. (Klausner Decl., ¶¶10-13.)
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`takes place when a talk request is sent identifying the participants to a conference.6
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`3.
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`The Patent Owner’s Claim Construction Arguments Are
`Irrelevant
`The Patent Owner spends an inordinate number of pages arguing about the
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`meaning of the terms “registration” and “conference call server,” but offers no
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`interpretation of its own and urges the Board not to adopt any construction. The
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`Patent Owner’s meritless arguments have nevertheless simplified the claim
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`construction process, as explained below.
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`a.
`“conference call server”
`With respect to the term “conference call server,” the Patent Owner goes on
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`at length about how the claimed conference call server need not directly and
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`6 The Patent Owner’s expert attempted to dismiss the relevance of the applicant’s
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`discussion of “registration” in the prosecution history by noting that the claim was
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`later amended to remove the word “prior” from the phrase “prior registration.”
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`(DiEuliis Decl., Ex. 2003, ¶51.) This argument is meritless, as reflected in the fact
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`that it is not mentioned or cited anywhere in the Patent Owner’s response. Indeed,
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`the prosecution history reveals that the word “prior” was later removed from the
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`claims for reasons unrelated to the applicant’s arguments discussed in the text.
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`(Klausner Reply, ¶¶6-8.) The applicant never attempted to disavow or augment the
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`remarks in its July 9, 2012 response (Ex. 1010) discussed in the text. (See Ex. 2005.)
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`independently establish the voice communication itself and may use a physically-
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`separate component or system to do so. (Response, at 29-35; DiEuliis Decl., ¶¶68-
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`70.) The Petition did not take a position as to whether a “conference call server” can
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`indirectly establish a conference call. The Patent Owner’s own arguments have
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`confirmed that this issue is wholly irrelevant to the resolution of this IPR.
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`The Petition’s analysis made clear that the prior art cited in Ground 1 and
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`Ground 2 discloses the “without requiring registration” limitation regardless of
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`whether a “conference call server” can indirectly establish a conference call. With
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`respect to Ground 1, the only server in Wu with which users might have to register
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`is the login server, and that server has no role in initiating or establishing voice
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`communication – either directly or indirectly. (Petition, at 40-45; Ex. 1002, ¶¶107-
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`111.) The same is true with respect to the Howard reference cited in Ground 2. The
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`only “registration” that takes place under the combination of Wu and Howard is with
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`the “authentication server” in Howard, which sits entirely outside the (AOL)
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`network and servers of Wu that provide IM and voice communication services.
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`(Petition, at 63, 67; Ex. 1002, ¶124.) Under either combination, there is no
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`registration with any server that establishes – either directly or indirectly, by itself
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`or in combination with other components – the voice communication in the claims.
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`As noted, any suggestion that the login or authentication server must somehow be
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`mapped as part of the claimed “conference call server” is meritless because the ’194
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`patent expressly contemplates that even components having a role in the
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`Case IPR2016-01756
`Patent 8,571,194
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`establishment of voice communication can nevertheless be “discrete from” the
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`conference call server. (’194, 6:14-29.)7
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`b.
`“registration”
`In light of the Patent Owner’s response, the dispute about the “without
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`requiring registration” limitation with respect to Wu has narrowed to whether the IM
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`and talk requests in Wu (¶¶0067, 0072) involve “registration… by the potential
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`members.” None of arguments presented above rely on any particular construction
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`for “registration.” For example, even assuming that the term “registration” is itself
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`not limited to personal information supplied by users (Response, at 16), the
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`limitation “registration… by the potential members” would nevertheless impose
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`such a requirement. Thus, if the Board were to simply find that the IM and talk
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`requests in Wu do not involve “registration… by the potential members,” that
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`7 The Patent Owner is presumably pressing the construction of “conference call
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`server” in order to impact later-filed IPR petitions filed by other petitioners on
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`different prior art (such as IPR2017-00597), where the claim construction issue is
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`potentially more relevant. The Petitioners respectfully submit that the “conference
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`call server” issues should be resolved in the context of the later-filed IPR
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`proceedings where the differences in construction would make a difference.
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`16
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`finding would obviate the need for an explicit construction of “registration.”
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`Patent 8,571,194
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`With respect to Ground 2, discussed below, no definition of “registration” is
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`required because the Patent Owner does not appear to dispute that Howard discloses
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`the “without requiring registration” limitation and instead relies on arguments about
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`combinability. (Response, at 65-67; DiEuliis Decl., Ex. 2003, ¶¶115-121.)
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`Nevertheless, to the extent an explicit construction is needed, the Board
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`should adopt the one offered by the Petitioners. As explained above and in the
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`Petition, the registration process in the specification (to which the Examiner pointed
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`during prosecution) is consistent with the definition of “registration” provided in
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`Newton’s Telecom Dictionary. Both descriptions even use common terminology of
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`“subscriber” and recite the same process of gaining access to a service by providing
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`personal information. (Compare Newton’s Telecom Dictionary, Ex. 1008, p.763
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`(“The process of supplying personal information needed to establish a subscriber
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`account and get access into a network or a server.”), with ’194, 7:57-64 (“If User A
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`is not a subscriber to the service, User A may be informed 316 that he is not allowed
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`to use the service… User A may be provided with the opportunity to subscribe to
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`the service at this point… [and] may be queried to provide information identifying
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`a method for paying for the proposed conference call, such as through use of a credit
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`card.”).) The Patent Owner does not identify anything else in the ’194 specification
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`that discloses a registration process. (Klausner Reply, ¶¶10-12.) The dictionary
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`17
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`definition offered by the Petitioners thus represents the plain and ordinary meaning
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`of “registration” at the time of the alleged invention, and is consistent with the
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`intrinsic evidence. See Interval Licensing LLC v. AOL, Inc., 766 F.3d 1364, 1377
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`(Fed. Cir. 2014) (“We have recognized that technical dictionaries can assist the court
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`in determining the meaning of particular terminology to those of skill in the art of
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`the invention.”) (citation omitted). And to the extent this definition can be
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`characterized as limiting (Response, at 16-18), it would, in fact, provide for broader
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`claim scope as the term “registration” is part of the negative limitation “without
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`requiring registration.” Petitioners’ proposed construction is thus further consistent
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`with the BRI standard.
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`B. Howard
`The Patent Owner devotes only a small portion of its response to addressing
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`the Howard reference cited in Ground 2. (Response, at 66-67.) This is because the
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`Patent Owner has no meaningful response to Howard.
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`As explained in the Petition, the process in Howard begins with the user
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`registering with the authentication server 110. (See Petition at 65-66 (quoting
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`Howard, Ex. 1007, 5:44-47).) “This registration is a one-time process which
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`provides necessary information to the authentication server.” (Id. (quoting Howard,
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`5:47-49).) “After registering and logging into the authentication server,” Howard
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`explains, “the user can visit any affiliate server (i.e., affiliate servers that are also
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`18
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`registered with the same authentication server) without requiring any additional
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`authentication and without re-entering user information that is already contained in
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`the user profile.” (Id. (quoting Howard, 5:57-63).)
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`The Patent Owner’s arguments about Wu addressed above rely on the
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`assertion that three authentication processes in Wu constitute “registration” with a
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`conference call server by the potential members. But under the combination of Wu
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`and Howard, “registration” occurs only with the authentication server 110 of
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`Howard, and that server sits entirely outside the system of Wu. (Petition, at 67.)
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`The affiliate server 110 of Howard is not a “conference call server” because it has
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`no involvement in establishing voice communications. The Patent Owner concedes
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`in its response that “Howard makes no mention of either instant messaging or voice
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`communication” (Response at 67), so the authentication server 110 in Howard
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`obviously does not “request[] a remote affiliate server… to initiate a bridge for the
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`voice communication” (Response, at 66), much less establish (directly or indirectly)
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`voice communication in the manner described in Wu.
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`This combination is thus fatal to the Patent Owner’s claims, and for that
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`reason, the Patent Owner has no meaningful response to it. Under the proposed
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`combination of Wu and Howard, after a user has registered and logged-into the
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`authentication server 110 of Howard, the user can then access the affiliate servers –
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`which include all of the servers in Wu – “without requiring any additional
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`19
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`authentication” (Howard, 5:60-61), thus eliminating all of the authentications and
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`so-called “registrations” in Wu that the Patent Owner relies upon. Accordingly, even
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`if the Patent Owner’s arguments about Wu and the “without requiring registration”
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`limitation had any merit, Howard remedies them.
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`The Patent Owner did not address any of the multiple motivations to combine
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`described in the Petition. (Petition, at 67-69; Ex. 1002, ¶¶119-126.) The Patent
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`Owner instead makes misguided challenges to the combination.
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`First, the Patent Owner confusingly argues that “[a]pplying Petitioner’s
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`flawed reasoning to the teachings of the ’194 Patent, one would erroneous [sic]
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`conclude the disputed claim language could be satisfie
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