UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`KAWASAKI RAIL CAR, INC.
`Petitioner,
`
`v.
`
`SCOTT BLAIR,
`Patent Owner.
`
`
`
`
`Case No. IPR2017-00117
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`Patent No. 6,700,602
`
`Issue Date: March 2, 2004
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`Title: Subway TV Media System
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`PETITIONER’S RESPONSE TO PATENT OWNER’S
`OBSERVATIONS ON LOWELL MALO’S DEPOSITION
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`KAWASAKI RAIL CAR, INC.
`Petitioner,
`
`v.
`
`SCOTT BLAIR,
`Patent Owner.
`
`
`
`
`Case No. IPR2017-00117
`
`Patent No. 6,700,602
`
`Issue Date: March 2, 2004
`
`Title: Subway TV Media System
`
`
`
`PETITIONER’S RESPONSE TO PATENT OWNER’S
`OBSERVATIONS ON LOWELL MALO’S DEPOSITION
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`I.
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`RESPONSE TO OBSERVATION 1:
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`At p. 100, 89:9-90:18,1 Mr. Malo testified that the cavity space behind the
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`interior wall of Namikawa can include wires and conduits and also provide for
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`ventilation of the televisions.
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`Q. Do you believe at the time of the publication of Namikawa,
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`which is 1992, and the application was filed, I'm looking at Exhibit 2
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`on the front of it, was filed in 1990 --
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`A. Um hum.
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`Q. And the kind of TV's that existed in 1990 --
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`A. Um hum.
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`Q.
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`-- would there have likely have been ventilation through
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`openings in the TV monitors at that time, 1990 and a little bit prior to
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`that, because that was what presumably the inventors had to look at
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`and think about at that time?
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`A. There could well be, and this provides very nicely for it
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`[indicating].
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`Q. What does, you're looking at Figure 1?
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`A. Yes.
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`Q. Could you explain what you're pointing at?
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`A. Again, you have a slanted surface here [indicating].
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`Q. Yes?
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`A. That builds an opening or cavity on the back side of the wall so
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`it gives you a place to ventilate.
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`Q. Where is the ventilation happening?
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`1 All the citations to page numbers are to Exhibit 2006.
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`- 1 -
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`A.
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`It happens right behind the back along with all the conduits and
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`wiring that runs along this part of the car.
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`In Ex. 1025 ¶11, Mr. Malo testified that “Namikawa [discloses] a subway
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`car having space beyond the wall, including the availability of space beyond the
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`wall at the junction of the sidewall and the ceiling to allow for the screen of the
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`monitor to be substantially flushed with the adjacent wall surface structure . . . .”
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`Mr. Malo’s testimony is relevant to Patent Owner’s first observation because
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`it rebuts Patent Owner’s notion that the existence of piping and conduits at the
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`junction of the sidewall and ceiling would indicate to a POSITA that there is no
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`additional space beyond the wall.
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`II. RESPONSE TO OBSERVATION 2:
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`At p. 33, 29:20-30:10, Mr. Malo testified that, based on his experience, a
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`subway car normally has a cavity between its interior wall and exterior shell.
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`Q. And you say that "a subway car was normally constructed such
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`that it had had a cavity between its interior wall and exterior shell."
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`A. Yes.
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`Q. Do you agree with that statement today?
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`A. Yes.
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`Q. You don't have any references for that. Do you have any
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`references that you have in mind or any support for that proposition?
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`A. Well, it's mainly based on my personal experience with the
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`construction of rail cars.
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`- 2 -
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`At p. 35, 31:2-16, Mr. Malo testified that the prior art references disclose a
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`cavity between the inner wall and the outer wall to a POSITA.
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`Q. Do you believe any of those patents that the petitioner that you
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`are working with has provided the -- did those references provide or
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`disclose cavities within the wall as you describe in paragraph 10?
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`A. Looking at the construction of the patents, some of the
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`illustrations show or indicate that there would be construction of that
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`type, yes.
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`At p. 36, 32:13-33:16, Mr. Malo testified that Namikawa discloses a cavity
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`between the interior and exterior walls.
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`Q. Where do you see an indication that this figure discloses a
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`cavity in the wall between the interior wall and the exterior wall?
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`A. Actually in this case it brings the cavity interior to the interior
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`wall as well ….
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`Q. Okay.
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`A. But if you look at the wall here and the juncture that comes up,
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`this is at a different angle. It's very, very common construction to
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`come down from the roof and cut across at a diagonal, that allows you
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`to turn the screens down to be able to be seen, and that forms a cavity
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`back behind this area as well [indicating]. Great place for conduits,
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`piping and such.
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`At p. 40, 35:23-36:8, Mr. Malo also testified that Figure 2 of Namikawa
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`discloses a cavity between the inner wall and the outer shell.
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`At p. 42, 37:19-24, Mr. Malo testified that the figures of Amano disclose a
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`- 3 -
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`cavity between the inner wall and the outer shell.
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`At p. 51, 46:4-21, Mr. Malo testified that Maekawa discloses a cavity as a
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`door pocket which extends to the junction.
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`At p. 107, 95:3-14, he testified that the references disclose some features
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`inherently.
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`Q.
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`I'm asking you a question. Are you saying that if it's not
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`actually shown in the figure that you cannot conclude that it's there or
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`would likely be there? If something is not actually shown in a figure
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`in these patents then you would say that the best way to interpret it is
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`likely it is not there?
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`A. There are things in other patents that were not shown that I
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`inherently know were there.
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`At p. 129, 114:19 -115:12, Mr. Malo testified that Miyajima too discloses a
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`cavity between the interior and exterior walls.
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`Q.
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`It says a cooling air passage gap. That is -- that is proof to you
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`that there is a cavity between the exterior and internal walls of the rail
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`car?
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`A. Yes, how would air flow.
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`In Ex. 1025 ¶10, Mr. Malo testified that “the ’602 Patent itself states that ‘A
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`subway car is normally constructed so that it has a cavity wall, defined between its
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`outer structural shell and its inner lining wall, the cavity providing for wiring and
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`cables and other mechanical functions, and, at places, containing insulation.’”
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`- 4 -
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`Mr. Malo’s testimony is relevant because it rebuts Patent Owner’s second
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`observation that incorrectly suggests that a POSITA would not have understood
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`any of the references to disclose a cavity between the inner wall and the outer wall.
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`III. RESPONSE TO OBSERVATION 3:
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`At p. 83, 73:23-74:7, Mr. Malo testified that in addition to preventing fire,
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`the intent of the FRA proposed rules was to mount interior fittings properly to
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`avoid injury to passengers.
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`A. You want to make sure that people cannot get their arms into
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`things that are dangerous. You want to make sure they don't bump
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`their heads or bump their shoulders just as best you can walking
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`through the car. You do pay attention to fire hazards, which is
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`extremely important in order for people to be safe.
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`At p. 108, 96:12-19, Mr. Malo also testified that LCD televisions generate
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`little heat and do not require ventilation.
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`Q. What do -- what did your -- what you believe is the way
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`ventilation was mostly done as one of ordinary skill in the art would
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`have probably done?
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`A. Let's see what type of monitor it is. Yes, so this is back in 1990
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`and they're talking about liquid crystal displays, which was very low
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`heat output.
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`At p. 108, 96:25-97:16, Mr. Malo testified the same.
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`Q. How about in Maekawa, which is exhibit -- Maekawa -- Exhibit
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`PO 6, take a look at this. How do you believe that the TV monitors in
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`- 5 -
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`this patent were being ventilated?
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`A.
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`I'm looking for the screen type. This refers to liquid crystal
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`displays, which are very low heat.
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`Q. Okay. And so is there no concern about ventilating liquid
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`crystal displays?
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`A. Generally, no.
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`At p. 112, 100:4-24, he testified the same.
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`Q. Are these guidelines that we just discussed and went over, do
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`they not apply to those type of TVs, in your opinion? I don't know if
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`it's an expert opinion, but in your opinion?
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`A. Generally speaking the heat is so low that's being generated out
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`of this you don't worry about it. We have much higher heat sources in
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`a car besides a TV.
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`Q. With respect to what type of TVs would you then, in your
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`opinion, be concerned about having not covered ventilation?
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`A. Any vacuum tube television.
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`Q. What other kind of televisions, televisions like a Namikawa
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`type of television where it's not an LCD or liquid crystal display, as
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`you say?
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`A. Generally LCD or liquid crystal displays, again very, very low
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`heat.
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`At p. 114, 101:14-102:3, he testified the same.
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`Q. What kind of a TV is disclosed in Maekawa in the rail car
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`display monitor?
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`A.
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`I believe it's also liquid crystal. Let me look. Okay. This is the
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`- 6 -
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`television receivers are thin using liquid crystal panels or the like.
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`Q. And so you don't think there was concerns about heating for the
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`same reasons you discussed before in Maekawa in terms of -- in terms
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`of ventilation of a TV monitor?
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`A. Monitors, it appears to be very small. No, I wouldn't worry
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`about it.
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`Mr. Malo’s testimony is relevant to Patent Owner’s third observation
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`because it rebuts Patent Owner’s suggestion that flush-mounted LCD TVs would
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`be a fire safety issue under the proposed FRA rules, and that fire safety concerns
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`would trump the proposed FRA requirement for flush-mounting interior fittings.
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`Mr. Malo testified several times that LCD TVs generate little heat and thus would
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`not require ventilation.
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`IV. RESPONSE TO OBSERVATION 4:
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`At p. 110, 98:6-99:8, Mr. Malo testified that LCD televisions do not require
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`ventilation because they generate little heat.
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`Q.
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`I guess are you -- do you consider yourself qualified to testify
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`about what is the appropriate way for a particular type of TV to be
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`ventilated or to avoid overheating?
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`A.
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`I would say that if you told me how much heat was generated I
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`would be qualified in dissipating the heat.
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`Q. Well, you just testified a moment ago about a certain type of
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`TV, you said liquid crystal?
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`A. Yes.
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`- 7 -
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`Q. And you didn't think that that needed to be ventilated?
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`A. Very, very low heat.
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`Q. What is your basis for that statement; do you have any
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`expertise?
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`A.
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`It's just not TV's it's any displays. The displays we have that use
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`LCDs we don't ventilate.
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`Q. And you base that on what conclusion?
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`A.
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`Installation of LCDs in cars.
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`Q. Any particular expertise other than installing them in cars?
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`A. Measuring heat output, making sure they don't get too hot.
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`See also p. 111, 96:25-97:16; p. 112, 100:4-24; p. 114, 101:14-102:3.
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`Mr. Malo’s testimony is relevant to Patent Owner’s fourth observation
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`because it rebuts Patent Owner’s suggestion that overheating was a concern for
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`LCD TV monitors installed inside railcars, and that such monitors had to be
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`ventilated. Mr. Malo’s testimony rebuts this point because he testified that LCD
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`TVs do not generate much heat and thus do not need ventilation.
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`At p. 93, 83:10-19, Mr. Malo testified that, if necessary, heat could be
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`dissipated using a heat sink.
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`Q. And how would it do that? How would a TV monitor dissipate
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`heat generally?
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`A. Okay. Do it through an enclosure case, basically an aluminum
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`heat sink.
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`Q.
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`I'm sorry, a what?
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`A. You do it through an aluminum heat sink, just is a way of
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`- 8 -
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`dissipating the heat that's all.
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`Mr. Malo’s testimony is relevant to Patent Owner’s fourth observation
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`because it rebuts Patent Owner’s incorrect statement that mounting a TV at a
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`junction of the sidewall and ceiling would pose a fire hazard and that a tunnel
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`would be required to ventilate the TV, which would require additional space. Mr.
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`Malo explains that if a TV needs to be cooled, a heat sink enclosure can be used.
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`V. RESPONSE TO OBSERVATION 5:
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`At p. 89, 79:13-23, Mr. Malo testified that heat would need to be dissipated
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`only if a television generated too much heat.
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`Q. How do the concerns about heating of these monitors,
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`ventilation of these monitors play, for safety reasons, play into the
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`disposition of the monitoring in the rail car?
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`A. We would have to take a look at how much heat the monitor
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`itself generates and then see how we would dissipate. If it was a
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`number large enough we would have to be able to dissipate the heat.
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`This testimony is relevant to Patent Owner’s fifth observation because it
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`rebuts Patent Owner’s incorrect assertion that Mr. Malo testified that it is important
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`to dissipate heat for all TV monitors. However, Mr. Malo testified that LCD TVs
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`produce little heat, and that, in any event, a POSITA would know how to dissipate
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`any heat that was generated. See, e.g., p. 108, 96:12-19; p. 109, 96:25-97:16; p.
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`110, 98:6-99:8; p. 112, 100:4-24; p. 114, 101:14-102:3; p. 140, 125:4-24.
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`- 9 -
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`VI. RESPONSE TO OBSERVATION 6:
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`At p. 95, 84:14-85:4, Mr. Malo testified that the consumer product safety
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`commission (“CPSC”) guidelines do not apply to TVs in railcars.
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`Q. Are you familiar with the Consumer Product Safety
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`Commission?
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`A. Yes.
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`Q. Can you tell us what that is?
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`A.
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`It's a commission that just looks out for the safety and
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`wellbeing of the consumer and public.
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`Q.
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`Is it concerned about, for example, safety of products that are in
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`rail cars as well or items that are in rail cars?
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`A.
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`I am not aware of any time I've ever seen a Consumer Product
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`Safety indoors or checking anything in a rail car.
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`At p. 98, 87:7-17, Mr. Malo testified that ultimately the specification of the
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`individual TV unit, and not the CPSC guidelines, determines whether the unit
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`would have to be ventilated.
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`Q. Could that cover the ventilation on TV monitors to prevent
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`from ventilating and cause the kind of overheating that's described in
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`the Commission's recommendations?
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`A.
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`I'd have to look at the individual unit. I mean, these are very
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`good general guidelines, but I'd have to look at the individual unit to
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`see if it's set up for self-ventilation, self-cooling or not.
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`At p. 111, 99:9-23, Mr. Malo testified that the consumer product safety
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`guidelines would not apply to televisions in railcars.
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`- 10 -
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`Q. Are you testifying today that the guidelines on the Commission
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`that we just went over, the Consumer Product Safety Commission,
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`does not apply to, was it crystal LCD TV; is that what you called it?
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`A. Liquid crystal display.
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`Q. So it doesn't apply to liquid crystal display TV monitors?
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`A.
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`I would say that the guidelines are very good general
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`guidelines, ultra-safe guidelines. I think you would not have these
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`guidelines if you put a TV in an aircraft or an automobile or a rail car.
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`This testimony is relevant to Patent Owner’s sixth observation because it
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`rebuts Patent Owner’s premise that the CPSC guidelines apply to TVs in railcars.
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`Additionally, as discussed above, Mr. Malo testified that LCD TVs generate
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`low heat and do not require heat to be dissipated through ventilation or other
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`means. See, e.g., p. 108, 96:12-19; p. 109, 96:25-97:16; p. 110, 98:6-99:8; p. 112,
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`100:4-24; p. 114, 101:14-102:3. This testimony is relevant to Patent Owner’s sixth
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`observation because it rebuts Patent Owner’s incorrect statement that a POSITA
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`would not have been motivated to “insulate” a TV in the wall and that any heat
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`generated by the TV must be dissipated.
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`Furthermore, as discussed above, Mr. Malo testified that the cavity space of
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`Namikawa can include wires and conduits and at the same time it can provide for
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`ventilation of the televisions. See Response to Observation 1.
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`VII. RESPONSE TO OBSERVATION 7:
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`As discussed above, Mr. Malo testified that LCD televisions do not generate
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`- 11 -
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`much heat and therefore do not require heat to be dissipated through ventilation or
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`other means. See, e.g., p. 108, 96:12-19; p. 109, 96:25-97:16; p. 110, 98:6-99:8; p.
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`112, 100:4-24; p. 114, 101:14-102:3.
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`At p. 140, 125:4-24, Mr. Malo testified that flush mounting and ventilation
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`can be achieved in the cavity space of Namikawa.
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`Q. Looking at the drawing, Figure 1 in Namikawa, if you assume
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`that the television disclosed here required ventilation, how could you
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`completely flush-mount the TVs with the side walls and provide for
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`ventilation for the TVs?
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`A. You could ventilate the televisions back behind the wall. In
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`other words it can be set in -- actually I would have taken the side
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`wall, come straight down, ventilate back into that area behind the
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`wall. Understand in ventilation you just have to give an area for the
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`heat to dissipate. You don't actually have to send the heat outside. It
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`just has to dissipate.
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`This testimony is relevant to Patent Owner’s seventh observation because it
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`rebuts Patent Owner’s argument that a POSITA would not have been motivated to
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`flush-mount Namikawa’s screens as this would have posed a fire hazard. Mr.
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`Malo’s testimony rebuts this argument because, even if LCD screens did generate
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`heat, a POSITA would have known how to dissipate the heat.
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`VIII. RESPONSE TO OBSERVATION 8 AND 9:
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`As discussed above, Mr. Malo testified that LCD televisions do not generate
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`- 12 -
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`much heat and therefore do not require heat dissipation through ventilation or other
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`means. See, e.g., p. 108, 96:12-19; p. 109, 96:25-97:16; p. 110, 98:6-99:8; p. 112,
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`100:4-24; p. 114, 101:14-102:3.
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`IX. RESPONSE TO OBSERVATION 10:
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`At p. 120, 107:6-14, Mr. Malo testified that Miyajima provides for cooling
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`of televisions in embodiments which have backlighting.
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`Q. Are you suggesting that the cooling system in this patent is only
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`for -- being disclosed only for an embodiment with a backlight?
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`A. That's what the patent says,
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`This testimony is relevant to Patent Owner’s tenth observation. Patent
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`Owner claims that Miyajima supports the argument that LCD televisions should
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`not be flush mounted because that would substantially increase the potential fire
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`hazard. However, in Miyajima, embodiments that do not include backlighting,
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`e.g., Fig. 6 and embodiment 2, are not ventilated, thereby indicating that not all
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`LCD televisions generate heat that must be dissipated.
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`And, at p. 140, 125:4-24, Mr. Malo testified that flush mounting and
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`ventilation can be achieved in the cavity space of Namikawa. Thus, even if LCD
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`screens generate too much heat, a POSITA would have known how to dissipate
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`the heat.
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`X. RESPONSE TO OBSERVATION 11:
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`At p. 107, 95:3-14, Mr. Malo testified that some of the references disclose
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`- 13 -
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`features inherently.
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`Q.
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`I'm asking you a question. Are you saying that if it's not
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`actually shown in the figure that you cannot conclude that it's there or
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`would likely be there? If something is not actually shown in a figure
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`in these patents then you would say that the best way to interpret it is
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`likely it is not there?
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`A. There are things in other patents that were not shown that I
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`inherently know were there.
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`This testimony is relevant to Patent Owner’s eleventh observation because it
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`rebuts the assertion that Namikawa does not disclose any mounting structure.
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`XI. RESPONSE TO OBSERVATION 12:
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`At p. 69, 61:12-63:3, Mr. Malo testified that because Namikawa has a
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`cavity, it would not be reasonable for a POSITA to mount the television outside the
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`wall.
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`Q.
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`Could one of ordinary skill in the art also interpret the monitors
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`to be placed on the wall -- as you put, I need to clarify your own
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`language -- to be hanging on the wall in this context?
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`A.
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`It would be bad skill. Could you do it? Yes. But why?
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`Q. Would one of ordinary skill in the art interpret this reference to
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`be teaching a television screen being placed on the wall as opposed to
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`inside the wall, or is that -- would that be unreasonable?
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`A.
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`It would not be reasonable for somebody who is knowledgeable
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`in the best practices to just hang it on the outside someplace.
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`Q. But it would -- but would it have to be in the wall?
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`- 14 -
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`A. Would it have to be in the wall? We have other patents that
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`showed the whole screen could be totally outside of a wall to the point
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`the screens are so thin it looks flat. The other thing to notice in this
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`patent is that they have built another interior wall. So could it go back
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`into the wall, yes, because they have generated the space to do so.
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`This testimony is relevant to Patent Owner’s twelfth observation because
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`Patent Owner incorrectly states that Petitioner’s expert admitted that it was not
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`clear whether Namikawa’s monitors were mounted inside the wall or on the
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`outside. However, Petitioner’s expert stated that it was unreasonable for a
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`POSITA to mount the monitors on the outside wall.
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`XII. RESPONSE TO OBSERVATION 13:
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`At p. 15, 13:24-14:1 and p. 15, 14:2-14, Mr. Malo testified that his
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`employer, Rail Plan, has several clients other than Kawasaki and Alstom, including
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`CAF, Siemens, Stadler and Talgo; at p. 15, 14:2-14, he testified that Rail Plan’s
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`biggest customer is CAF; and at p. 24, 21:11-16, he testified that he currently is
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`“not doing a whole lot” for Kawasaki.
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`This testimony is relevant to Patent Owner’s thirteenth observation. Patent
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`Owner asserts that Mr. Malo is biased because his company works for Kawasaki.
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`However, Mr. Malo and his employer work for many different clients, and there is
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`no basis for suggesting that Mr. Malo’s testimony is not credible.
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`Dated: January 12, 2018
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`Respectfully submitted,
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`/s/ Sheila Mortazavi
`Sheila Mortazavi (Reg. No. 43,343)
` Lead Counsel
`Zaed M. Billah (Reg. No. 71,418)
` Backup Counsel
`Armin Ghiam (Reg. No. 72,717)
` Backup Counsel
`Andrews Kurth Kenyon LLP
`One Broadway
`New York, NY 10004
`Telephone: (212) 425-7200
`Fax: (212) 425-5288
`Email:
`SheilaMortazavi@andrewskurthkenyon.com
`ZaedBillah@andrewskurthkenyon.com
`ArminGhiam@andrewskurthkenyon.com
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that on January 12, 2018, a complete and entire
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`copy of
`
`this PETITIONER’S RESPONSE TO PATENT OWNER’S
`
`OBSERVATIONS ON LOWELL MALO’S DEPOSITION was served via e-
`
`mail on the following:
`
`Jennifer Meredith
`jmeredith@meredithkeyhani.com
`205 Main Street
`East Aurora, New York 14052
`Tel: (212) 760-0098
`Fax: (212) 202-3819
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/s/ Armin Ghiam
`
`Armin Ghiam
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004
`Telephone: (212) 425-7200
`
`
`- 17 -
`
`
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