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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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`APPLE INC., FACEBOOK, INC., and WHATSAPP, INC.,
`Petitioner
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`v.
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`UNILOC USA, INC. and UNILOC LUXEMBOURG S.A.
`Patent Owner
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`
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`Case IPR2017-002221
`Patent 8,243,723
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`DECLARATION OF LEONARD J. FORYS, PH.D.
`IN SUPPORT OF PETITIONER APPLE INC.’S
`REPLY TO PATENT OWNER RESPONSE
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`1 Facebook, Inc. and WhatsApp, Inc., who filed a petition in IPR2017-01635, have
`been joined as petitioners in this proceeding.
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`Apple Ex. 1028
`Apple v. Uniloc
`IPR2017-00222
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`TABLE OF CONTENTS
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`Case IPR2017-00222
`U.S. Pat. No. 8,243,723
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`Introduction ......................................................................................................... 1
`I.
`II. Response to Uniloc’s Patent Owner Response and Mr. Easttom’s Declaration 5
`A. The term “list” means a list of “one or more nodes.” ..................................... 5
`B. Vuori’s SVM watcher is user-facing, therefore Vuori teaches or suggests
`“transmitting a signal to a client including a list of the recorded connectivity
`status…” ................................................................................................................. 8
`III. Conclusion .....................................................................................................16
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`I.
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`Introduction
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`Case IPR2017-00222
`U.S. Pat. No. 8,243,723
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`I, Dr. Leonard J. Forys, declare as follows:
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`1.
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`This declaration supplements my declaration (Ex. 1003) submitted
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`with Apple’s Petition in IPR2017-00222. For the sake of brevity, I rely on and
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`confirm the facts and opinions contained in my Declaration dated November 14,
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`2016 – Ex. 1003. My qualifications and background information can be found in
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`my original Declaration. (Ex. 1003 ¶¶1-2, 6-53.)
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`2.
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`I am making this declaration to respond to certain arguments raised by
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`Uniloc USA Inc. and Uniloc Luxembourg S.A., (“Uniloc” or “PO”) in its Patent
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`Owner Response (“POR”) and the declaration of William C. Easttom II (Ex.
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`2001) submitted therewith. In view of Uniloc’s and Mr. Easttom’s arguments, it is
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`still my opinion that all of the claim elements in the ’723 patent are taught or
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`suggested by Vuori alone or in combination with Malik and the other prior art
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`references presented in the Grounds of the Petition. In my opinion, Uniloc’s
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`arguments rely on overly narrow interpretations of the claim elements, inaccurate
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`explanations of the prior art references, and unfounded concerns about the
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`combinations of prior art references that inflate potential “detriments” and ignore
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`an artisan’s understanding of design tradeoffs. My opinions are set forth below.
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`In preparing this declaration, I have reviewed and am familiar with the
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`3.
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`following documents:
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`Exhibit
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`Description
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`1001
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`1002
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`1003
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`1004
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`1005
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`1006
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`1007
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`1008
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`1009
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`1010
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`1011
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`1012
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`Rojas, U.S. Patent No. 8,243,723 (earliest priority date December 18,
`2003; filed March 4, 2009; issued August 14, 2012).
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`File History for U.S. Patent No. 8,243,723.
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`Declaration of Leonard J. Forys, Ph.D.
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`Curriculum Vitae of Leonard J. Forys, Ph.D.
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`Vuori, U.S. Patent Application Publication No. 2002/0146097 (filed
`July 23, 2001, published October 10, 2002).
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`SMSS, Universal Mobile Telecommunications System (UTMS);
`Technical realization of the Short Message Service (SMS) (3G TS
`23.040 version 3.5.0 Release 1999) (published on August 16, 2000).
`
`Holtzberg, U.S. Patent No. 6,625,261 (filed December 20, 2000,
`issued September 23, 2003).
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`Väänänen, U.S. Patent No. 7,218,919 (filed August 8, 2001, issued
`May 15, 2007).
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`Dahod et al., U.S. Patent Application Publication No. 2004/0022208
`(filed on August 1, 2002, published February 5, 2004).
`
`Hogan et al., U.S. Patent No. 5,619,554 (filed June 8, 1994, issued
`April 8, 1997).
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`Logan et al., U.S. Patent No. 5,732,216 (filed October 2, 1996, issued
`March 24, 1998).
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`Peersman et al., The Global System for Mobile Communications
`Short Message Service, IEEE Personal Communications (June 2000).
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`Exhibit
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`1013
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`1014
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`1015
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`1016
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`1017
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`1018
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`1019
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`1020
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`1021
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`1022
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`1023
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`1024
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`1025
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`
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`Description
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`Case IPR2017-00222
`U.S. Pat. No. 8,243,723
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`SMS Forum, SMPP v3.4 Protocol Implementation guide for GSM /
`UMTS, Version 1.0 (May 30, 2002).
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`Clarke et al., Experiments with packet switching of voice traffic, IEE
`Proceedings G - Electronic Circuits and Systems, Vol.130, Pt. G, No.
`4, pp. 105-13 (August 1983).
`
`Oouchi et al., Study on Appropriate Voice Data Length of IP Packets
`for VoIP Network Adjustment, Proceedings of the IEEE Global
`Telecommunications Conference (GLOBECOM) 2002, V. 2, Taipei,
`Taiwan, 2002, pp. 1618–1622.
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`Lotito et al., U.S. Patent No. 4,625,081 (filed November 30, 1982,
`issued November 25, 1986).
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`Pershan, U.S. Patent No. 5,260,986 (filed April 23, 1991, issued
`November 9, 1993).
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`Old Version of AOL Instant Messenger 2.1 Download, retrieved
`from http://www.oldapps.com/aim.php?old_aim=4#screenshots.
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`Malik, Patent Publication No. 2003/0219104 (filed August 19, 2002,
`published November 27, 2003).
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`Staack et al., WO Patent Publication No. 02/07396 (filed July 13,
`2000, published January 24, 2002).
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`Lerner et al., U.S. Patent No. 6,192,395 (filed December 17, 1999,
`issued February 20, 2001).
`Stubbs, WO Patent Publication No. 99/63773 (filed June 3, 1999,
`published December 9, 1999).
`Abburi, U.S. Patent Application Publication No. 2003/0147512 (filed
`on February 1, 2002, published August 7, 2003).
`File History for U.S. Patent No. 7,535,890.
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`Day et al., A Model for Presence and Instant Messaging, Network
`Working Group, RFC 2778, pp. 1-17 (February 2000).
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`Description
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`U.S. Pat. No. 8,243,723
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`International Telecommunication Union, General Aspects of Digital
`Transmission Systems, Terminal Equipments, Pulse Code
`Modulation (PCM) of Voice Frequencies, ITU-T Recommendation
`G.711., pp. 1-10 (ITU 1993).
`
`Gayomali, C., “The text message turns 20: A brief history of SMS,”
`The Week, December 3, 2012, retrieved from
`http://www.theweek.com/articles/469869/text-message-turns-20-
`brief-history-sms.
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`Deposition transcript of William C. Easttom, II
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`Declaration of William C. Easttom II
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`Deposition of Dr. Leonard J. Forys (September 13, 2017)
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`Description
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`Petition for Inter-Partes Review of U.S. Patent No. 8,243,723
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`Uniloc’s Patent Owner Preliminary Response
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`Decision – Institution of Inter Partes Review
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`Uniloc’s Patent Owner Response
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`Exhibit
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`1026
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`1027
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`1029
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`2001
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`2002
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`Paper
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`2
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`6
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`7
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`11
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`4.
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`To the best of my knowledge, the above Exhibits are true and accurate
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`copies of what they purport to be. An expert in the field would reasonably rely on
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`them to formulate opinions such as those set forth in this declaration.
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`5.
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`I continue to be compensated for my work in this proceeding. My
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`compensation in no way depends upon the outcome of this proceeding.
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`II. Response to Uniloc’s Patent Owner Response and Mr. Easttom’s
`Declaration
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`6.
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`I address certain portions of Uniloc’s POR and Mr. Easttom’s
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`Declaration below. Failure to address any statement or argument presented by
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`Uniloc or Mr. Easttom should not be viewed as an acquiescence to or agreement
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`with that statement or argument.
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`A. The term “list” means a list of “one or more nodes.”
`As I mentioned in my original Declaration, I have applied the plain
`7.
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`and ordinary meaning of the claim terms as understood to a POSITA at the time of
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`invention. (Ex. 1003, ¶101.) Uniloc’s attempt to limit the term “list,” as recited in
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`claim 1, to “more than one,” is inconsistent with the plain and ordinary meaning
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`of the term “list.” In fact, Uniloc’s proposed definition is well outside what a
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`POSITA would have understood the term to mean in light of the specification.
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`Further, Mr. Easttom’s analysis, hinges on the faulty construction, which is
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`divorced from the plain and ordinary meaning of the terms at issue.
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`8.
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`The recited “list” includes the recorded connectivity status of one or
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`more nodes. The Board stated:
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`Patent Owner’s argument appears to take an overly narrow view of
`the term to mean that the ‘list of the recorded connectivity status’
`must include the connectivity status of more than one node. Patent
`Owner cites no factual support in the record for its argument that the
`scope of the term excludes a singular value. Furthermore, based on
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`our review of the ’723 patent, the specification seems to contradict
`Patent Owner’s argument.
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`(Institution Decision, 17-18, emphasis added.)
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`9.
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`Based on the ’723 specification, the term “list” must include the
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`connectivity status of “one or more nodes.”
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`10. Uniloc argues that “[a] plain reading of the claim language itself …
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`unambiguously resolves this issue” and that without the “modifying phrase ‘one
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`or more’… the transmitted ‘list’ must have the recorded connectivity status for
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`multiple ‘nodes’” (POR, 8-9.) This fails to take into account that the ’723 patent
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`specification consistently refers to a list as having “one or more” items: “a list of
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`one or more IVM recipients” (’723 patent, 8:52-56 and 16:61-63) and “[t]he IVM
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`client 208 displays a list of one or more IVM recipients on its display 216,
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`provided and stored by the local IVM server 202” (Institution Decision, citing
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`’723 patent, 7:61-63). So a POSITA would have understood that a “list” in this
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`patent, under its broadest reasonable interpretation (BRI), encompasses “one or
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`more” items.
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`11.
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`In addition to being overly narrow, Uniloc’s analysis is incomplete.
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`For example, Uniloc argues that the omission of the modifying phrase “one or
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`more” confirms that “the transmitted ‘list’ must have the recorded connectivity
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`status for multiple ‘nodes.’” (POR, 9.) Uniloc’s analysis fails to identify other
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`modifying phrases that are also omitted from the claim. For example, if the ’723
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`patent inventor truly intended the transmitted list to include the recorded
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`connectivity status for “multiple nodes,” as Uniloc argues, notably missing from
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`the claim language are phrases including “more than one” or “a plurality of...”
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`12. Because under the Patent Owner’s argument the claim is ambiguous
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`and does not define the term “list” with a modifying phrase, the term must be
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`interpreted according to its BRI in light of the specification.
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`13. Uniloc further argues that, “[v]iewing Claim 1 as a whole further
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`confirms that the phrase ‘one or more’ was explicitly recited when the intent was
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`to encompass both the singular and plural form of a term.” (POR, p. 8.) Uniloc’s
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`analysis is, again, incomplete. Looking at claim 1 as a whole, and even just the
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`limitation as a whole, reveals that the claim recites the phase “a list of the
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`connectivity status of each of the nodes in the sub-set.” The term sub-set is not
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`defined by the ’723 patent, but a POSITA would have understood that the term
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`sub-set means a smaller part of larger set. That is, a POSITA would have
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`understood that the “sub-set of nodes” could be a single node. In such a case, the
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`list of “the connectivity status of each of the nodes in the sub-set” could
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`reasonably include only one node, because the sub-set contains only one node.
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`Thus, under BRI the term “list” must include the connectivity status of “one or
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`more nodes.” The Uniloc position would not consider a network composed of
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`only two subscribers as being within the scope of the claims. However, nothing in
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`the ‘723 patent prohibits such a situation.
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`14. Finally, Uniloc provides that “[i]t is significant that ‘nodes’ is recited
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`in the plural in the phrase ‘each of the nodes in the sub-set.’ Use of the plural form
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`of ‘nodes’ in that context confirms the ‘list’ must record the connectivity status of
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`more than one node.” (POR, 8.) Yet the specification refers to a list as having
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`“one or more” items – and in each case the “one or more” items are identified in
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`plural form. Thus, Uniloc’s argument falls short because the recitation of nodes
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`(in plural form) is consistent with the ’723 patent’s disclosure of a “list of one or
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`more” items (in plural form).
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`15.
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`In view of the foregoing, the term “list” encompasses “one or more.”
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`B. Vuori’s SVM watcher is user-facing, therefore Vuori teaches or
`suggests “transmitting a signal to a client including a list of the
`recorded connectivity status…”
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`16. Mr. Easttom argued that Vuori’s “SVM watcher 256 is not a user-
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`facing ‘client’ and thus does render obvious the claimed ‘transmitting’ step.”
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`(POR, 12; Ex. 2001, ¶29.) But Vuori’s SVM watcher is user-facing and does
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`distribute connectivity status on a line to the user. The directional arrows of
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`Vuori’s Figure 7 are not dispositive, Vuori expressly
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`teaches two-way
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`communication. Vuori teaches that a user interacts with the system using an
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`SVM watcher UA, suggesting two-way communication. Vuori further teaches that
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`“[a] user agent is purely coupling between a principal and some core entity of
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`the system” including the SVM watcher 256. The term coupling, as applied in
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`Vuori, indicates that the SVM watcher is coupled to the user agent, suggesting
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`that the SVM watcher is indeed user-facing. The presence status is distributed so
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`that it can be “interpretable by programs or by persons,” suggesting a person
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`may view and thus interpret shared presence status information. Vuori’s
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`description of a buddy list is evidence that the SVM watcher is user-facing
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`because the sender determines whether the intended recipient is available by
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`means of a presence service. Each of the foregoing reasons is evidence that
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`Uniloc’s arguments fall short.
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`17. Uniloc appears to argue that the arrows of Figure 7 indicate that the
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`presence information is distributed only to the SVM watcher 256 and is not
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`distributed to a “‘user agent’ or ‘UA’ device (276, 278) of either end user.” (POR,
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`12.) Uniloc’s reliance on the “directional communication arrows in Figure 7” fails
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`to consider Vuori’s entire disclosure. A POSITA would have understood that the
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`direction of the arrows illustrated in the Figure are not dispositive and do not
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`exemplify the only embodiments described in Vuori.
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`18. Vuori’s SVM watcher is further illustrated in Figure 8.
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`“As shown in FIG. 8, according to an adaptation of RFC 2778, there
`are two kinds of SVM watchers, called SVM fetchers 258 and SVM
`subscribers 260. An SVM fetcher 258 simply requests the current
`value of some SVM presentity's presence information from the
`presence service 248. In contrast, an SVM subscriber 260 requests
`notification from the SVM presence service 248 of (future) changes in
`some SVM presentity's presence information. A special kind of SVM
`fetcher is one that fetches SVM presence information on a regular
`basis. This is called an SVM poller 262.”
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`(Vuori, [0044], emphasis added.) As is known in the art, “requesting,” “fetching,”
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`and “polling” are done by sending messages from a device 258 (SVM Watcher) to
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`device 248 (SVM presence service), thus in the opposite direction from the
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`indicated arrow in Figure 7. Thus, because Vuori’s SVM watchers are capable of
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`requesting, fetching, and polling information, it suggests two-way communication
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`and/or data transfer. That is the plain and ordinary meaning of the term “interact.”
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`And the SVM watcher’s requesting, fetching, and polling information show that
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`the arrows of Figure 7 are not dispositive, as Mr. Easttom seems to suggest.
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`19. Figure 7 shows each user agent is associated with a principal. As
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`described in Vuori, the term “principal” refers to “people, groups and/or software
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`in the ‘real world’ outside of the system that use the system as a means of
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`coordination and communication.… A principal interacts with the system via one
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`of several user agents (UAs) such as shown in FIGS. 7 and 9.” (Vuori, [0046].)
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`Vuori therefore suggests that when a principal interacts with the system via a user
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`agent, he/she is engaging in a two-way communication and/or data transfer –
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`because that is the plain and ordinary meaning of the term “interact.” Thus, a
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`POSITA would have understood that the described interaction indicates that the
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`SVM watchers are user-facing because data, including connectivity information,
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`may be distributed to and from the user agents via the described interaction.
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`20. Vuori further teaches that “[a] user agent is purely coupling between a
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`principal and some core entity of the system (SVM inbox 274, SVM sender 272,
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`SVM presentity 254, SVM watcher 256). It will therefore be understood that the
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`simple examples shown in RFC 2778 are applicable to the SVM service of the
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`present invention.” (Vuori, [0046].) The term coupling, as applied in Vuori,
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`indicates that the SVM watcher is “coupled” to the user agent. When two entities
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`are coupled, as the user agent and SVM watcher 256, a POSITA would
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`understand that the disclosed coupling suggests a two-way communication
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`between the user agent and SVM watcher 256. Thus, Vuori teaches or suggests
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`that the SVM watcher is indeed user-facing.
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`21. Evidence that the SVM watcher is indeed user-facing, and that Mr.
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`Easttom’s conclusions are misguided, can be found in Vuori’s description of the
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`term “status.” For example, Vuori teaches that each “element comprises a status
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`marker 298, 300 (which might convey information such as on-line/off-
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`line/busy/away/do not disturb).… Status can be interpretable by programs or by
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`persons and can consist of single or multiple values as spelled out in the IETF
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`model of RFC 2778.” (Vuori, [0047], emphasis added.) For status information to
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`be interpretable by a person, the status information must be transmitted to a device
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`capable of, e.g., displaying the information (or otherwise informing them) for the
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`person to see. Thus, Vuori discloses or suggests that the status (i.e. connectivity)
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`information is available to a person and that the SVM watcher is user-facing.
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`22. The term “buddy list” was a well-known term in the art. Vuori
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`describes the term buddy list in the context of a sender determining whether or not
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`the potential recipient is available to receive a message. (See Vuori [0035]).
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`Specifically, “the sender first determines whether the intended recipient is
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`available by means of a presence service and the intended recipient has
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`effectively acquiesced to availability by previously joining a ‘buddy list’ or
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`otherwise subscribing to the service.” The first thing to note is that the term
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`“buddy list” is in quotations which suggest that it is a term of art. The applicant
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`provides “joining a ‘buddy list’” as an example for subscribing to a presence
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`service. Vuori’s presence service
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`tracks presence
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`information
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`including
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`information such as whether a user is on-line/off-line/busy/away/do not disturb.
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`(Vuori, [0047].) So a sender is able to determine whether an intended recipient is
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`available because the recipient has acquiesced to availability by previously joining
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`a buddy list. That is, the connectivity information of a potential recipient
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`connected to the network is distributed to the sender. (Vuori, [0035] and [0047].)
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`23. Vuori additionally teaches:
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`An SVM presence service 248 serves to accept SVM presence
`information e.g. on a line 250, store it, and distribute it, e.g., on a
`line 252. An SVM presentity 254 is a client that provides the presence
`information on the line 250 to be stored and distributed. Another set
`of clients called SVM watchers such as an SVM watcher 256 in FIG.
`7, receives SVM presence information on the line 252 from the SVM
`presence service 248.
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`(Id., [0043], emphasis added.)
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`24. Again, according to Vuori, when a user joins a buddy list, he/she
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`acquiesces in their availability information being shared with others, using, for
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`example, Vuori’s presence service. Thus, a user’s availability is stored and
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`distributed to the clients associated with the buddy list that the potential recipient
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`has joined. A POSITA would have understood that by joining a “buddy list,” a
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`user allows his/her presence information (i.e. connectivity) to be transmitted to all
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`of the nodes associated with the buddy lists he/she has joined. (Ex. 2002, Forys
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`Deposition, 73:7-11.) That is, the “buddy list” is not a list belonging to the
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`recipient, but rather it belongs to the sender who is able to see which recipients are
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`available.
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`25. A POSITA would have understood that Vuori’s SVM watcher is user-
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`facing and that Vuori teaches distributing the presence information because, as the
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`Board agreed, “[d]istributing connectivity information ‘on a line’ means to
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`distribute the information to other users connected to the network,” as recited in
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`claim 1. (Institution Decision, 17-18.)
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`26. Even if the Board determines that the term “list” requires connectivity
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`status of more than one node, a POSITA would have understood that Vuori still
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`teaches the “transmitting” feature of claim 1, including a “list of the recorded
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`connectivity status for each of the nodes in the sub-set corresponding to the
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`client.” For example, Vuori determines the availability of one or more recipients,
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`and “[t]he user 10 then uses the menu key to select one or more intended
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`recipients…” (Vuori, [0033].) And “[t]he SVM is then sent to an SVM service
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`center. This could be a short message service (SMS) service center which
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`determines the availability of the one or more intended recipients.” (Vuori,
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`[0034].) To the extent Uniloc or Mr. Easttom may argue that the short message
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`- 14 -
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`Case IPR2017-00222
`U.S. Pat. No. 8,243,723
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`service center is different than, or does not include, Vuori’s presence service, a
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`POSITA would apply the foregoing teachings (i.e., determining the availability of
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`one or more intended recipients) to the presence service.
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`III. Conclusion
`In signing this declaration, I recognize that the declaration will be
`27.
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`Case IPR2017-00222
`U.S. Pat. No. 8,243,723
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`filed as evidence in a contested case before the Patent Trial and Appeal Board of
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`the United States Patent and Trademark Office. I also recognize that I may be
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`subject to cross-examination in the case and that cross-examination will take place
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`within the United States. If cross-examination is required of me, I will appear for
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`cross-examination within the United States during the time allotted for cross-
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`examination.
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`28.
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`I hereby declare that all statements made herein of my own
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`knowledge are true and that all statements made on information and belief are
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`believed to be true; and further that these statements were made with the
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`knowledge that willful false statements and the like so made are punishable by
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`fine or imprisonment, or both, under Section 1001 of Title 18 of the United States
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`Code.
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`Executed this 18th day of December, 2017.
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`Respectfully submitted,
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`______________________________
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`Leonard J. Forys, Ph.D.
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