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`Paper No. 20
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`VALVE CORPORATION,
`Petitioner,
`v.
`
` IRONBURG INVENTIONS LTD.,
`Patent Owner.
`____________
`Case IPR2017-00136
`Patent 8,641,525
`____________
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`
`PETITIONER’S REPLY TO THE PATENT OWNER’S RESPONSE
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`
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`I.
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`II.
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`TABLE OF CONTENTS
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`Page
`Exhibit List ……………………………………………………...….iv
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`INTRODUCTION .............................................................................. 1
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`CLAIM CONSTRUCTION ............................................................... 1
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`A.
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`The statement of intended use “for a game
`console,” in the preamble of claim 20, is not
`limiting. .................................................................................... 1
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`1.
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`2.
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`3.
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`Statements of intended use are not
`limiting, unless used during prosecution to
`distinguish prior art. ....................................................... 1
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`The general rule applies here to the
`statement of intended use “for a game
`console.” ......................................................................... 3
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`The ’525 patent specification is directed to
`an ergonomic improvement that also
`applies to hand-held controllers for
`purposes other than video games. .................................. 3
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`B.
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`The rest of the preamble of claim 20 is also not
`limiting. .................................................................................... 5
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`1.
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`2.
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`3.
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`The body of claim 20 is readily understood
`without consulting the preamble. ................................... 5
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`The preamble does not recite essential
`structure, or breathe life, meaning, and
`vitality into claim 20. ..................................................... 6
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`Contrary to Ironburg’s misrepresentation,
`the Petitioner does not agree that the
`preamble is limiting. ...................................................... 7
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`C.
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`The broadest reasonable interpretation of “for a
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`game console” is not exclusive. ............................................... 8
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`D.
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`The ordinary meaning of hand-held does not
`require “without the need for external support.” .................... 10
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`III.
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`PATENT OWNER’S ARGUMENTS DO NOT
`NEGATE ANTICIPATION BY WÖRN. ........................................ 12
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`A. Wörn does not need to expressly disclose use
`“for a game console,” because that statement of
`intended use in the preamble of claim 20 is not
`limiting. .................................................................................. 12
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`B. Wörn discloses a hand-held controller that can be
`used with a game console. ...................................................... 13
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`IV. CONCLUSION ................................................................................ 14
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`Exhibit No.
`1001
`1002
`1003
`1004
`1005
`1006
`1007
`1008
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`1009
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`1010
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`1011
`1012
`1013
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`1014
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`EXHIBIT LIST
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`
`Description
`U.S. Patent 8,641,525 to Burgess et al.
`U.S. Patent 9,089,770 to Burgess et al.
`U.S. Patent 6,362,813 to Wörn et al.
`U.S. Patent App. Pub. 2010/0073283 to Enright
`U.S. Patent 6,153,843 to Date, et al.
`U.S. Patent 6,364,771 to Lee
`U.S. Patent 4,032,728 to Oelsch
`UK Search and Examination Report for Patent App. No.
`GB1011078.1, 16 May 2011, at 2.
`Expert Declaration of David Rempel, M.D., in Support of Valve
`Corporation’s Second Petition for Inter-Partes Review of U.S.
`Patent 8,641,525.
`Curriculum Vitae of David Rempel, M.D. (also denominated as
`Ex. 1 to Ex. 1009).
`- not used -
`Declaration of Reynaldo C. Barceló.
`Expert Declaration of David Rempel, M.D., in Support of
`Petitioner’s Replies to the Patent Owner Responses in IPR2017-
`00136 and IPR2017-00136. (Rempel Reply Declaration)
`Prosecution history of U.S. Patent 8,641,525.
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`I.
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`INTRODUCTION
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`In the Patent Owner Response in IPR2017-00136 (“PO Response”), the
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`Patent Owner (“Ironburg”) interprets its own patent narrowly – attempting to
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`effectively carve away a substantial portion of the scope of claim 20 of U.S. Pat.
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`No. 8,641,525 (the “’525 patent”) because of alleged limitations in the claim’s
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`short preamble. In this reply, the Petitioner exposes that as an improper result-
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`oriented tactic, rather than being a fair reading of the subject patent under the
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`law.
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`II. CLAIM CONSTRUCTION
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`A. The statement of intended use “for a game console,” in the
`preamble of claim 20, is not limiting.
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`As explained fully below, the language “for a game console” in the
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`preamble of claim 20 of the ’525 patent is merely a statement of intended use
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`that is not exclusive or properly limiting in this case.
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`1.
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`Statements of intended use are not limiting, unless used
`during prosecution to distinguish prior art.
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`The Federal Circuit has explained why longstanding and consistent
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`precedent holds that statements of intended use are almost never limiting in
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`apparatus or composition claims, as follows:
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`[P]reambles describing the use of an invention generally do not limit the
`claims because the patentability of apparatus or composition claims
`depends on the claimed structure, not on the use or purpose of that
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`structure. In re Gardiner, 36 C.C.P.A. 748, 171 F.2d 313, 315-16, 80
`USPQ 99, 101 (CCPA 1948) ("It is trite to state that the patentability of
`apparatus claims must be shown in the structure claimed and not merely
`upon a use, function, or result thereof."). Indeed, "the inventor of a
`machine is entitled to the benefit of all the uses to which it can be put, no
`matter whether he had conceived the idea of the use or not." Roberts v.
`Ryer, 91 U.S. 150, 157, 23 L. Ed. 267 (1875). More specifically, this
`means that a patent grants the right to exclude others from making,
`using, selling, offering to sale, or importing the claimed apparatus or
`composition for any use of that apparatus or composition, whether or not
`the patentee envisioned such use. See 35 U.S.C. § 271 (1994).
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`Catalina Marketing Int., Inc., v. Coolsavings.com, Inc., 289 F.3d 801, 1781,
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`1785 (Fed. Cir. 2002). The Court in Catalina Marketing described a “rare”
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`exception to that general rule, where “statements of intended use or asserted
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`benefits in the preamble may, in rare instances, limit apparatus claims, but only
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`if the applicant clearly and unmistakably relied on those uses or benefits to
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`distinguish prior art.” Id. at 1785 (emphasis added).
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`The Federal Circuit has followed the general rule (to hold statements of
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`intended use to be non-limiting) in much closer cases than the present case. For
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`example, the Court has held that the following claim preamble was a mere
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`statement of intended use and therefore not limiting (emphasis added):
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`A biopsy needle for use with a tissue sampling device having a housing
`with a forward end, a first slide mounted for longitudinal motion within
`said housing, and a second slide mounted for longitudinal motion
`within said housing, said biopsy needle comprising:
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`C.R. Bard, Inc. v. M3 Systems, Inc., 157 F.3d 1340, 1348-49 (Fed. Cir. 1998).
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`The Court explained that even though the body of that claim referred back to the
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`housing structure first identified in the preamble, the preamble merely described
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`what the claimed structures in the body were for (i.e., for coupling to the
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`structure in the preamble). Id.
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`2.
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`The general rule applies here to the statement of intended
`use “for a game console.”
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`Here, there are no exceptional reasons why the statement of intended use
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`“for a game console,” which appears in the short preamble of claim 20 of the
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`’525 patent, should be limiting. For example, it is not referenced anywhere in
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`the body of the claim, and therefore does not provide antecedent basis for any
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`claim limitation. Moreover, the preamble statement of intended use “for a game
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`console” was never used to distinguish the prior art during prosecution of the
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`’525 patent.
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`3.
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`The ’525 patent specification is directed to an ergonomic
`improvement that also applies to hand-held controllers
`for purposes other than video games.
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`A review of the entirety of the ’525 patent reveals that the inventors were
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`working on the problem of inconvenience, loss of control, or delay when the
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`user of a hand-held controller moves his or her thumb from operating one
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`control to operate another. (EX1001, 1:33-45). The inventors of the ’525 patent
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`incorrectly believed that they were the first to include “one or more additional
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`controls located on the back of the controller in a position to be operated by the
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`user’s other fingers.” Id., 1:56-58. For example, the sole independent claim 1
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`as originally filed (but rejected) was conspicuously shorter and broader than any
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`of the independent claims that were eventually allowed over the prior art of
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`record, with the originally filed independent claim 1 attempting to broadly cover
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`any back control (without any elongate, distance, or flexibility limitations). See,
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`Exhibit 1014 at 15.
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`Hence, the specification of the ’525 patent is focused on the superficial
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`ergonomic characteristics of the controller, which affect finger and thumb
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`positioning relative to buttons and levers. Such ergonomic characteristics are
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`potentially applicable to all controllers that are shaped to be held in the hand of
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`a user, not just controllers that are used to control video games. See, Rempel
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`Reply Declaration at ¶ 4.
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`Indeed, none of the structural limitations in the body of claim 20 of the
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`’525 patent is exclusive to only controllers that are used to control video games,
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`but rather each also provides utility to controllers that are used outside of the
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`statement of intended use in the preamble. Accordingly, one of ordinary skill in
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`the art would consider the statement of intended use in the preamble to be
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`exemplary rather than exclusive and limiting. See Rempel Reply Declaration at
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`¶ 5.
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`B.
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`The rest of the preamble of claim 20 is also not limiting.
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`In instituting inter partes review, the Board concluded that the preamble
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`of claim 20 is not limiting. See, Paper 12 at 8-11. The Board’s conclusion is
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`correct for at least the following reasons:
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`1.
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`The body of claim 20 is readily understood without
`consulting the preamble.
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`Ironburg relies on only a selected portion of the holding in Pacing Techs.
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`LLC v. Garmin Intern. Inc., 778 F.3d 1021, 1024 (Fed. Cir. 2015). According to
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`that authority, preambles may be limiting where they “provide antecedent basis
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`for and are necessary to understand positive limitations in the body of the
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`claims.” Id. (emphasis added). Here, Ironburg cannot meet the second part of
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`this requirement because the short preamble of claim 20 is clearly unnecessary
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`to understand the positive limitations of the claim’s body.
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`Merely because the phrase “hand held controller” appears in the
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`preamble, does not mean that the preamble is necessary to understand how the
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`word “controller” is used in body of the claim. On the contrary, the body of
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`claim 20 itself describes a structurally complete device and includes sufficient
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`detail about the claimed controller being hand held, including that it is “shaped
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`to be held in the hand of a user” – which renders the preamble phrase
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`superfluous. See Schumer v. Lab. Computer Sys., Inc., 308 F.3d 1304, 1310
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`(Fed. Cir. 2002) (if the body of the claim “sets out the complete invention,” the
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`preamble is not ordinarily treated as limiting the scope of the claim); see also,
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`Bristol-Myers Squibb Co. v. Ben Venue Labs., Inc., 246 F.3d 1368, 1373-74,
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`(Fed. Cir. 2001).
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`2.
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`The preamble does not recite essential structure, or
`breathe life, meaning, and vitality into claim 20.
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`Ironburg relies on Samsung Elects. Co. Ltd. v. IXI IP, LLC, IPR2015-
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`01442, Paper 8 at 9 (PTAB Dec. 30, 2015) – a case involving a different patent
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`that happens to use the phrase “hand-held.” Ironburg attempts to analogize to
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`that case, to argue that “hand held” in the preamble is essential to place a
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`physical restriction on the size of the claimed device. However, Ironburg
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`overlooks that the body of claim 20 of the ’525 patent includes a complete
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`structural description that limits the size of the claimed device without any resort
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`to the preamble. For example, the body of claim 20 recites that “the controller is
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`shaped to be held in the hand of a user.”
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`Logically, the shorter preamble phrase “hand held controller” adds
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`nothing to further inform the longer and self-sufficient phrase in the body of the
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`claim that “the controller is shaped to be held in the hand of a user.” On the
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`contrary, the longer phrase in the body of claim 20 further informs that holding
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`is by the user. Hence, this is not an exceptional case where the preamble
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`breathes life, meaning, and vitality into the claim, but rather is a typical case
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`where the body of the claim stands without need of the preamble.
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`3.
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`Contrary to Ironburg’s misrepresentation, the Petitioner
`does not agree that the preamble is limiting.
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`Ironburg mischaracterizes the Record of Oral Hearing in the co-pending
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`IPR2016-00948 proceeding. PO Response (Paper 16) at p. 13. Specifically,
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`Ironburg alleges there that “Petitioner agrees that the preamble is limiting,” with
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`citation to Exhibit 2031, 65:11-17. However, that is an exaggeration of the cited
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`portion of that Record of Oral Hearing, in which Petitioner’s counsel was
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`actually agnostically explaining that Petitioner should prevail in IPR2016-00948
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`whether or not the preamble is found to be limiting.
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`The same Record of Oral Hearing at provides ample context to understand
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`and correctly characterize the Petitioner’s non-committal with regard to the
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`preamble, previously in the co-pending IPR2016-00948 proceeding, as follows:
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`JUDGE KAUFFMAN: Even if the preamble is limiting -- it
`doesn't require two hands. But even if you required two
`hands, two hands are shown in the art.
`MR. HARRISON: That is exactly what I'm saying, Your
`Honor. I'm not going to do their job for them and argue that
`the preamble is limiting. But I didn't really argue it wasn't. It
`doesn't matter. It's in the prior art – very clearly in the prior
`art.
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`Exhibit 2031, at 67:2-14. Unlike in the co-pending IPR2016-00948 proceeding,
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`the question of whether the preamble is limiting may actually affect the outcome
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`of the present proceeding. Therefore, the Petitioner has carefully considered the
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`question and agrees with the Board’s conclusion that the preamble of claim 20 is
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`not limiting. See paper 12 at 8-11. See also, the preceding sub-sections herein.
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`C.
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`The broadest reasonable interpretation of “for a game console”
`is not exclusive.
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`Even if the preamble phrase “for a game console” is considered to be a
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`limitation, despite being a mere statement of intended use, then it still must be
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`interpreted in accordance with broadest reasonable interpretation in this
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`proceeding. There is no basis to limit the phrase “for a game console” to mean
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`“for only a game console,” exclusive of all other uses and lacking any other
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`utility. There is also no basis to require that use “for a game console” must
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`always be the intended primary use. Rather, the broadest reasonable
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`interpretation of “for a game console” – if considered limiting at all – would
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`require only that a controller be capable of any use for a game console, whether
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`a primary, incidental, or alternative use.
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`In 2011, hand-held controllers such as those claimed in the ’525 patent
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`provided inputs to a downstream microprocessor, so that it would make no
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`substantial difference to the hand-held controller whether the downstream
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`microprocessor interpreted such controller inputs to operate a game (making that
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`microprocessor a “game console”), or instead interpreted the controller inputs
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`for a non-gaming purpose such as operating a real robot. See, Rempel Reply
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`Declaration at ¶ 6. Indeed it was well known in 2011 that programming the
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`downstream microprocessor could flexibly enable the same hand-held controller
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`to operate many different games, and even to control systems that are not games.
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`See, Rempel Reply Declaration at ¶ 7. For example, it was common in 2011 for
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`programmers to leverage the same inputs from the same hand-held controller for
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`both a primary purpose (e.g. to control a video game), and also for secondary
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`and alternative purposes such as allowing a user to navigate menus for selecting
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`system settings. Id.
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`Moreover, the structural limitations that are positively recited in the body
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`of claim 20 are focused on the ergonomic characteristics of the hand-held
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`controller, which affect finger and thumb positioning relative to buttons and
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`levers. Such superficial mechanical characteristics do not limit the purpose of
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`the downstream electronic system that is ultimately controlled. See, Rempel
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`Reply Declaration at ¶ 4. For example, from an ergonomic viewpoint, and
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`considering the placement and length of buttons and levers relative to fingers
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`and thumbs – which is the focus of both the ’525 patent and its claims – it makes
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`no difference whether the hand-held controller ultimately controls a downstream
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`microprocessor that operates a real robot or a virtual robot in a game. See,
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`Rempel Reply Declaration at ¶ 8.
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`Hence, the broadest reasonable interpretation of “for a game console”
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`contemplates any hand-held controller that is capable of helping control a game
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`as an intended primary use, or as an incidental or alternative use.
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`D. The ordinary meaning of hand-held does not require “without
`the need for external support.”
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`Petitioner agrees that the claim 20 of the ’525 patent is limited to a hand-
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`held controller, not because of the preamble, but rather because the body of the
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`claim recites that “the controller is shaped to be held in the hand of a user.”
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`Ironburg urges the Board to narrowly construe claim 20 to require that the
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`controller be held in and supported by only the user’s hands, “without the need
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`for external support.” However, claim 20 is an open-ended claim, and there is
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`no clear and unmistakable disavowal of claim scope that could exclude
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`additional external support. Indeed, the broadest reasonable interpretation of
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`claim 20 does not require that the controller be held and supported by only the
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`user’s hands, “without the need for external support.” The patent application
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`says no such thing, and nothing in the intrinsic record of this case supports such
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`an added limitation.
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`Ironburg resorts to past court opinions about different and unrelated
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`patents, filed by different applicants, and having different specifications, claims,
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`and prosecution histories, to color its argument that the Board should add the
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`unsupported limitation “without the need for external support” into claim 20 of
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`the ’525 patent. However, the unrelated past cases that Ironburg cites are not in
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`the intrinsic record of this case, nor even relevant to the construction of the
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`specific language, supporting specification, or prosecution of claim 20 in this
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`case.
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`Moreover, Ironburg misrepresents the unrelated past cases that it cites.
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`On page 1 of the PO Response, Ironburg assures the Board that “Prior Board
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`and court decisions” (plural) have construed the term “hand held” to require
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`“without the need for external support” (underlining emphasis by Ironburg).
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`However, a careful review of the prior Board and court decisions that Ironburg
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`summarizes on pages 14-15 or the PO Response reveals that only one adds that
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`language to its construction.
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`Therefore, not only are the prior Board and court decisions irrelevant
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`because they focus on different and unrelated patents, having different
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`specifications, different applicants, and different prosecution histories, but
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`Ironburg has further misrepresented the irrelevant information in its summary to
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`the Board.
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`III. PATENT OWNER’S ARGUMENTS DO NOT NEGATE
`ANTICIPATION BY WÖRN.
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`A. Wörn does not need to expressly disclose use “for a game
`console,” because that statement of intended use in the
`preamble of claim 20 is not limiting.
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`In instituting inter partes review, the Board concluded that the preamble
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`of claim 20 is not limiting. See paper 12 at 8-11. That conclusion was proper,
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`as demonstrated supra herein, and so the claim specifies certain ergonomic
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`characteristics of the controllers without limitation on use. Like the ’525 patent,
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`Wörn is also expressly concerned with the ergonomic characteristics of a hand-
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`held controller, and considers the influence of ergonomic characteristics on hand
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`fatigue, and allowing the switching keys 21 to be operated without moving the
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`thumbs. See, Worn at 2:48-3:13. Hence, one of ordinary skill in the art would
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`look to references and devices like and including that disclosed by Wörn, when
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`solving ergonomic problems with hand-held controllers – whether for the
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`control of robots or for the control of video games – including the specific
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`ergonomic problems addressed by the ’525 patent. See, Rempel Reply
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`Declaration at ¶ 13.
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`Because the preamble of claim 20 is not limiting, Wörn anticipates claim
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`20 of the ’525 patent without needing to disclose use “for a game console.”
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`B. Wörn discloses a hand-held controller that can be used with a
`game console.
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`One of ordinary skill in the art in 2011 would know that the hand-held
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`robot controller disclosed by Wörn would necessarily have an analog or digital
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`electronic output, and such output would inherently have utility to also control a
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`simulated robot as part of a video game running on a game console. See,
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`Rempel Reply Declaration at ¶ 9.
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`Indeed, Wörn expressly discloses that the controller’s output may be
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`transmitted to a conventional personal computer, and it was well known in 2011
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`that such a downstream personal computer could be conventionally programmed
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`to function as a game console to run a video game. See, Rempel Reply
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`Declaration at ¶ 10. For example, Wörn discloses that the “control and program
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`data are transmitted from the programming device to the computer via the said
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`cable connection, they are optionally processed by the said computer, and
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`passed on to the manipulator control.” Wörn at 1:14-17. Wörn also clarifies that
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`the “computer (4), e.g., a personal computer, which may have various designs, is
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`provided to generate and process the control and program data.” Wörn at 1:14-
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`17. Hence, one of ordinary skill in the art would understand that the hand-held
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`controller disclosed by Wörn inherently provides an output that is capable of use
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`for a game console. See, Rempel Reply Declaration at ¶ 9.
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`Therefore, even if the statement of use “for a game console” were
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`assumed – counterfactually and arguendo – to be limiting, still the Wörn
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`disclosure falls within the broadest reasonable interpretation of that statement of
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`use.
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`IV. CONCLUSION
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`The foregoing reply demonstrates that the Patent Owner Response fails to
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`negate the merit of the instituted challenge to claim 20 of the ’525 patent.
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`Dated: August 27, 2017
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`Respectfully submitted,
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`By: /Joshua C. Harrison, USPTO Reg. #45,686/
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`Joshua C. Harrison, USPTO Reg.# 45,686
`BARCELÓ, HARRISON & WALKER, LLP
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`- 14 -
`PETITIONER’S REPLY TO PO RESPONSE IN IPR2017-00136
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`WORD COUNT CERTIFICATE
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`The undersigned certifies that the foregoing PETITIONER’S REPLY
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`TO THE PATENT OWNER RESPONSE has a word count of 3,073, as defined
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`by 37 C.F.R. § 42.24 using the word count feature of Microsoft Word 2010.
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`Dated: August 27, 2017
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`By: /Joshua C. Harrison, USPTO Reg. #45,686/
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`Joshua C. Harrison, USPTO Reg.# 45,686
`BARCELÓ, HARRISON & WALKER, LLP
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`2901 West Coast Hwy, Suite 200
`Newport Beach, CA 92663
`(949) 340-9736
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`Attorneys for Petitioner, Valve Corporation
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`PETITIONER’S REPLY TO PO RESPONSE IN IPR2017-00136
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`CERTIFICATE OF SERVICE
`The undersigned certifies, in accordance with 37 C.F.R. § 42.205, that
`on 2017-08-27 a true copy of the foregoing PETITIONER’S REPLY TO THE
`PATENT OWNER RESPONSE was served in its entirety on the Patent Owner
`via electronic mail and Owner electronically via PTAB E2E to:
`
`Ehab M. Samuel, Reg. No. 57,905
`MANATT, PHELPS & PHILLIPS. LLP
`11355 W. Olympic Blvd. Los Angeles, CA 90064
`Tel: (310) 312-4000 Fax: (310) 312-4224
`ESamuel@manatt.com
`Danielle Mihalkanin, Reg. No. 69,506
`MANATT, PHELPS & PHILLIPS, LLP
`1841 Page Mill Road, Suite 200, Palo Alto, CA 94304
`Tel: (650) 812-1300 Fax: (650) 213-0260
`DMihalkanin@manatt.com
`Yasser El-Gamal, Reg. No. 45,339
`MANATT, PHELPS & PHILLIPS, LLP
`695 Town Center Drive, 14th Floor, Costa Mesa, CA 92626
`Tel: (714) 371-2500 Fax: (714) 371-2550
`YElGamal@manatt.com
`Attorneys for Ironmonger Inventions Ltd., a UK Limited Company
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`Dated: 27 August 2017
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`By: /Joshua C. Harrison, USPTO Reg. # 45,686/
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`
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`Joshua C. Harrison, USPTO Reg. # 45,686
`BARCELÓ, HARRISON & WALKER, LLP
`
`2901 West Coast Hwy, Suite 200
`Newport Beach, CA 92663
`(949) 340-9736
`
`Attorneys for Petitioner, Valve Corporation
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`- 16 -
`PETITIONER’S REPLY TO PO RESPONSE IN IPR2017-00136
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