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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., SNAP 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
`_____________________
`
`Case IPR2017-002251
`Patent 8,995,433
`_____________________
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`
`PETITIONER APPLE INC.’S REQUEST FOR
`REHEARING OF FINAL WRITTEN DECISION
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`
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`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`O. Box 1450
`Alexandria, VA 22313-1450
`
`
`1 Snap Inc., which filed a petition in IPR2017-01611, as well as Facebook,
`Inc. and WhatsApp, Inc., which filed a petition in IPR2017-01634, have been joined
`as petitioners in this proceeding.
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`
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`
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`TABLE OF CONTENTS
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`Case IPR2015-00225
`U.S. Pat. No. 8,995,433
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`
`I.
`Summary of Issues for Rehearing ..................................................................... 1
`Standard of Review............................................................................................ 2
`II.
`III. Argument and Relief Requested ........................................................................ 2
`A.
`The Board overlooked the Petition’s discussion of Abburi’s
`express desire to store audio messages on its client devices................... 2
`The Board overlooked or misapprehended the Petition’s explicit
`obviousness arguments for combining Abburi and Holtzberg ............... 5
`1.
`The Board misapprehended the Petition’s explicitly
`stated rationale to combine Holtzberg’s database
`structure and organization techniques—not database as a
`whole—into Abburi when the Board relied on bodily
`incorporation of Holtzberg’s database into Abburi ...................... 6
`The Board misapplied obviousness law by improperly
`weighing evidence irrelevant to the Petition’s rationale
`for the combination ....................................................................... 8
`a)
`The Board overlooked that the Petition does not change
`where data is stored in Abburi ..........................................10
`The Board overlooked that the Petition does not require
`distribution or duplication of functionality of Abburi’s
`server-based audio message store .....................................11
`The Board misapprehended Abburi’s teaching of using
`local storage discussed in the Petition’s rationale for
`combining Abburi and Holtzberg .....................................12
`IV. Conclusion ....................................................................................................... 15
`
`
`B.
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`2.
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`b)
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`c)
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`I.
`
`Summary of Issues for Rehearing
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`Case IPR2015-00225
`U.S. Pat. No. 8,995,433
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`In its Final Written Decision (Paper 29), the Board overlooked or
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`misapprehended two primary matters: (1) the Petition showed Abburi2 explicitly
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`expresses a desire to store audio messages on its client devices in addition to its
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`server-based audio message store, and (2) the Petition’s proposed combination
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`does not allege bodily incorporation of Holtzberg’s3 database into the system of
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`Abburi.
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`First, the Board focused on Abburi’s centralized audio message store,
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`determining that even though Abburi discloses recording an audio file on its client
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`device prior to sending, “we are not persuaded that the existence of a memory for
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`recording an audio file suggests either de-centralizing the audio message store or
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`that the audio file would be stored in a database.” (FWD, pp. 35-36.) Here, the
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`Board overlooked the Petition’s discussion of Abburi’s express desire to locally
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`store received audio messages, in addition to Abburi’s centralized storage.
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`Second, the Board determined that the evidence provided by Patent Owner
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`shows “that Abburi would have to be redesigned to account for additional
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`functionality at the user device, where the trade-offs are the complexity of
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`replication of data across the entire system.” (FWD, p. 40.) But the Board
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`2 U.S. Patent Publication No. 2003/0147512 A1.
`3 U.S. Patent No. 6,625,261 B2.
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`overlooked or misapprehended the combination proffered in the Petition, which
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`U.S. Pat. No. 8,995,433
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`only proposes to incorporate Holtzberg’s database structure into a database at
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`Abburi’s client device, avoiding the need for any redesign or additional
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`functionality besides that associated with implementing a generic database. Thus,
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`the purported disadvantages cited by the Board do not apply to the combination
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`presented in the Petition.
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`II.
`
`Standard of Review
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`“A party dissatisfied with a decision may file a request for rehearing,
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`without prior authorization from the Board.” 37 C.F.R. § 42.71(d). The “burden of
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`showing a decision should be modified lies with the party challenging the
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`decision,” and the request “must specifically identify all matters the party believes
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`the Board misapprehended or overlooked, and the place where each matter was
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`previously addressed in a motion, an opposition, or a reply.” Id.
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`III. Argument and Relief Requested
`For the reasons below, Petitioner respectfully requests that the Board
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`reconsider its determination that claims 1-6 and 8 of the ’433 patent have not been
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`shown to be unpatentable over the combination of Abburi and Holtzberg.
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`A. The Board overlooked the Petition’s discussion of Abburi’s
`express desire to store audio messages on its client devices
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`In its Decision, the Board alleged that Patent Owner “correctly points out
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`that Abburi expressly relies on the server-side audio message store, with no
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`indication that a local audio message store is either warranted or desirable.” (FWD,
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`Case IPR2015-00225
`U.S. Pat. No. 8,995,433
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`p. 35.) But the Board overlooked the Petitioner’s discussion of Abburi’s explicit
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`disclosure expressing a desire to store received audio messages:
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`Audio messages are delivered to intended recipients in one
`embodiment via audio streaming through the computer
`network 210 or
`network 212.
`the
`telecommunications
`Alternatively, system 200 delivers an audio message to its
`intended recipient as, e.g., an electronic audio file which
`the recipient can store and subsequently playback at his
`or her option.
`(Abburi, ¶ 32, emphasis added.)
`
`The Petition explicitly relies on this disclosure in its rationale to combine
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`Abburi and Holtzberg: “When an audio file is delivered to its intended recipient,
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`‘the recipient can store and subsequently playback at his or her option.’” (Petition,
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`p. 17 (citing Abburi, ¶ 32).) The Petition (pp. 26, 29) also discusses Dr. Forys’s
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`reliance on this storage at the recipient’s user device to support his rationale to
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`combine Abburi and Holtzberg, where Dr. Forys states:
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`When an audio file is delivered to its intended recipient, “the
`recipient can store and subsequently playback at his or her
`option.” (Abburi, [0032] (emphasis added).) Thus, Abburi
`teaches ‘storing the instant voice message’ at the recipient’s
`device.
`(Forys Decl., ¶ 105 (emphasis in original).)
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`It would have been obvious to incorporate Holtzberg’s
`database structure into Abburi because such incorporation
`amounts to nothing more than applying a known technique
`(e.g., storing voice messages in a database) to a known
`device (e.g., the message recipient’s device in Abburi)
`ready for improvement to yield predictable results (a user
`device storing audio messages in a database). A POSITA
`would have been motivated to implement database storage
`to improve the organization and retrieval of audio messages
`stored on a user’s device.
`(Forys Decl., ¶ 109 (emphasis added).)
`
`The Petition further clarifies that this disclosure of Abburi suggests at least
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`storage of received audio messages in persistent memory, to allow a user to
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`“subsequently playback at his or her option”:
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`When an audio message is sent to a recipient, Abburi
`provides the user with various options to act on the message,
`for example, ‘acknowledging receipt of the message, saving
`the audio message on the system 200, downloading the
`audio message for storage by the recipient, replaying,
`replying to or forwarding the received audio message,
`initiating a new audio message, etc.’
`(Petition, p. 14 (citing Abburi, ¶ 29); see also Forys Decl., ¶ 66.)
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`Importantly, Abburi differentiates between storage in Abburi’s server-based
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`audio message store and storage on the client device (e.g., “saving the audio
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`message on the system 200” vs. “downloading the audio message for storage by
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`U.S. Pat. No. 8,995,433
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`the recipient”), which are separate operations. Yet the Board focused only on
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`storage of audio messages to be sent in Abburi. (See FWD, p. 34 (“Even though
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`Abburi states that an audio message may be recorded locally, the storage of that
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`message, nevertheless, is in the disclosed, centralized audio-message store.”)
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`(emphasis in original).)
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`As such, the Board appears to have overlooked the Petition’s discussion of
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`the disclosure in Abburi related to storage of received audio messages, giving it no
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`consideration in determining that it would not have been obvious to store audio
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`messages in a database at Abburi’s client device. (Id.) And while the Board
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`endeavored to find a reason to de-centralize Abburi’s storage of audio messages
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`(see id.), the proper inquiry is whether it would have been obvious to store locally-
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`resident audio messages—audio messages that are already stored at Abburi’s client
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`device—in a database. And the Petition discussed numerous benefits of database
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`storage vs. traditional file system storage provided by Dr. Forys. Petition, pp. 17-
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`18; Forys Decl., ¶¶ 87-89.
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`B.
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`The Board overlooked or misapprehended the Petition’s explicit
`obviousness arguments for combining Abburi and Holtzberg
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`There are two reasons the Board overlooked or misapprehended the
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`Petition’s obviousness analysis: first, the Board misapprehended that the Petition’s
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`rationale required bodily incorporation of Holtzberg’s database as a whole into
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`Abburi’s client devices; and second, even if the Board did not rely entirely on
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`bodily incorporation of Holtzberg’s database, the Board misapprehended that the
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`purported disadvantages proffered by Patent Owner do not affect or diminish the
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`Petition’s rationale to combine Abburi and Holtzberg.
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`1.
`
`The Board misapprehended the Petition’s explicitly stated
`rationale to combine Holtzberg’s database structure and
`organization techniques—not database as a whole—into
`Abburi when the Board relied on bodily incorporation of
`Holtzberg’s database into Abburi
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`The Petition specifies that “[a] POSITA would have found it obvious to
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`incorporate Holtzberg’s database structure into Abburi…,” rather than Holtzberg’s
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`database. (Petition, p. 29 (emphasis added).) And the Petition states that “a
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`POSITA would have found it obvious how and why to combine the system of
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`Abburi with Holtzberg’s database storage and organization techniques.” (Petition,
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`p. 18 (emphasis added)). So the Board’s reliance on bodily incorporation of
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`Holtzberg’s database misapprehended the Petition. Specifically, the Board stated:
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`“At the outset we note that Petitioner’s contention of obviousness relies on
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`incorporation in Abburi’s user device of a structural element taught in
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`Holtzberg, a voicemail database.” (FWD, p. 33 (italics in original, bolding
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`added); see also FWD, p. 37 (“The Petition alleges a general ‘incorporation’ of
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`Holtzberg’s database into the user device of Abburi without explaining how this
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`would be achieved, especially considering the structural requirement in
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`Holtzberg, of a centralized voicemail database, as paramount to Holtzberg’s
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`operation”) (italics in original, bolding added).)
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`The Petition does not discuss bodily incorporation, but rather the Petition is
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`consistent and explains enhancing Abburi with Holtzberg’s “database structure.”
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`For example, in its description of Holtzberg, the Petition states, “[t]he voicemail
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`database contains a voice mailbox for each user, and the data structure of each
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`voice mailbox stored in the voicemail database is illustrated in Figure 3 of
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`Holtzberg…” (Petition, pp. 27-28 (emphasis added).) The Petition further explains
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`that “a POSITA would have found it obvious how and why to combine the system
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`of Abburi with Holtzberg’s database storage and organization techniques.”
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`(Petition, p. 18 (emphasis added).) That is, the Petition explicitly relies on
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`Holtzberg’s database storage and organization techniques, not on incorporation of
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`Holtzberg’s actual database in full.
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`These storage and organization techniques are clarified by the Petition, for
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`example: (1) assigning a unique message ID in a database, which allows indexing
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`and data redundancy techniques to be employed; and (2) storing metadata
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`associated with an audio message using the database schema (i.e., also referred to
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`in the Petition as the database structure) taught by Holtzberg. (Petition, pp. 17-18.)
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`None of these techniques require anything more than enhancing Abburi through
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`basic implementation of Holtzberg’s database structure and organization
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`Case IPR2015-00225
`U.S. Pat. No. 8,995,433
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`techniques, as illustrated in Holtzberg’s FIG. 3, as part of a database at Abburi’s
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`client device.
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`Indeed, the Petition’s combination applies the “known technique” of
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`“storing voice messages in a database,” enhanced with Holtzberg’s database
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`structure. (Petition, p. 29 (citing Forys Decl., ¶ 109).) There are no arguments in
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`Petitioner’s record that can be construed to be relying on bodily incorporation of
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`Holtzberg’s database into Abburi.
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`2.
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`The Board misapplied obviousness law by improperly
`weighing evidence irrelevant to the Petition’s rationale for
`the combination
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`Even if the Board was not arguing or relying on bodily incorporation of
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`Holtzberg’s database, the Board’s ultimate legal conclusion of nonobviousness
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`relied on weighing the benefits of combining Abburi with Holtzberg against the
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`purported disadvantages alleged by Patent Owner. (FWD, p. 40.) But the Board
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`misapprehended the Petition’s arguments pertaining to the rationale to combine
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`because these purported disadvantages do not affect the combination presented in
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`the Petition.
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`The Board first acknowledged that, at a minimum, “a person of ordinary
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`skill in the art would find organizing voice mails at the user device mildly
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`desirable.” (FWD, p. 40.) But the Board misapprehended the Petition’s
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`combination as requiring distribution of functionality and changes to where data is
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`stored in Abburi. Specifically, the Board alleged that “Abburi would have to be
`
`redesigned to account for additional functionality at the user device, where the
`
`trade-offs are the complexity of replication of data across the entire system.”
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`(FWD, p. 40.) The Board further explained, “[t]o avoid duplication, if functionality
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`of the server-side message store is distributed throughout the devices, the
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`scalability of design and the ease of centralized functionality would be
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`compromised.” (FWD, p. 40.)
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`As explained above, the Board overlooked that the Petition’s explicit
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`rationale for combining Abburi and Holtzberg was not bodily incorporation, i.e.,
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`the incorporation or relocation of Holtzberg’s centralized database into Abburi’s
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`client devices, and the Board went on to further misapprehend that Patent Owner’s
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`supplied evidence (consisting solely of unsupported expert testimony) does not
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`affect the Petition’s actual rationale for the combination. In particular, the
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`Petition’s combination does not require a change to Abburi’s server-based audio
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`message store, nor does the combination change where data is stored in Abburi’s
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`system.
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`a)
`
`The Board overlooked that the Petition does not
`change where data is stored in Abburi
`In the Petition’s combination, audio messages are stored exactly in the
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`locations Abburi already discloses for storage of audio messages. As explained
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`above, Abburi explicitly discloses storage of received audio messages on its client
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`devices: “[S]ystem 200 delivers an audio message to its intended recipient as, e.g.,
`
`an electronic audio file which the recipient can store and subsequently playback at
`
`his or her option.” (Abburi, ¶ 32 (emphasis added); Petition, p. 17.) Abburi also
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`explicitly discloses storage of messages to be sent on its client devices: “Rather
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`than transmitting the audio message to the system 200 for recording as the message
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`is received by the device 300, the device 300 may be configured to record the
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`audio message locally (e.g., into an audio file), and then transmit this prerecorded
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`message to the system.” (Abburi, ¶ 40 (emphasis added); Petition, p. 27.)
`
`The Petition’s rationale to combine Abburi and Holtzberg does not propose a
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`change to Abburi’s current scheme or distribution of any storage employed at
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`Abburi’s server-based audio message store. Rather, the Petition’s combination
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`proposes storage in a database, using Holtzberg’s database structure, of audio
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`messages already stored at Abburi’s client devices. And since the Petition’s
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`combination of Abburi and Holtzberg does not change where audio messages are
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`stored, no additional replication of data is required beyond Abburi’s already
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`disclosed functionality. Audio messages are still stored in Abburi’s server-based
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`audio message store in the way Abburi discloses.
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`b)
`
`The Board overlooked that the Petition does not
`require distribution or duplication of functionality of
`Abburi’s server-based audio message store
`As explained above, at a minimum, Abburi expressly discloses a desire to
`
`store received audio messages in persistent storage at its user device. (Petition, pp.
`
`14, 17; Forys Decl., ¶¶ 66, 105; Abburi, ¶¶ 29, 32.) This does not change the
`
`functionality and storage of Abburi’s server-based audio message store. The only
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`additional functionality required at Abburi’s user devices is that associated with
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`employing a generic database. (See Forys Decl., ¶¶ 87-89 (explaining benefits of
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`implementing Holtzberg’s database structure in a generic database on Abburi’s
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`client devices).) None of the functions of Abburi’s audio message store need to be
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`distributed to Abburi’s client devices.
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`The Petition’s rationale for the combination also does not require duplication
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`or de-centralization of Abburi’s server-based audio message store. The
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`combination only requires basic implementation of Holtzberg’s database structure
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`(i.e., database schema) and organization techniques at Abburi’s user device.
`
`(Petition, p. 18.) And, again, the Petition and Dr. Forys provide numerous reasons
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`why employing Holtzberg’s database structure at Abburi’s user devices would
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`provide benefits over traditional storage, and the Board further acknowledged that
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`there is some benefit to the organization that such a database would provide on
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`Abburi’s user devices. (Petition, pp. 17-18; Forys Decl., ¶¶ 87-89.)
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`For these reasons, the disadvantages proffered by Patent Owner and relied
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`on by the Board do not affect the combination of Abburi and Holtzberg presented
`
`in the Petition.
`
`c)
`
`The Board misapprehended Abburi’s teaching of
`using
`local storage discussed
`in
`the Petition’s
`rationale for combining Abburi and Holtzberg
`
`The Board asserted that “the Petition and the First Forys Declaration neither
`
`state nor explain a rationale based on convenience of local storage or of
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`conservation of server resources.” (FWD, p. 38.) But, again, the Board overlooked
`
`that Abburi expressly discloses the desire to download messages to its local client
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`device and store them for later playback at the user’s option, i.e. for convenience.
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`(Abburi, ¶¶ 29, 32; Petition, pp. 14, 17; Forys Decl., ¶¶ 66, 105.) The Petition’s
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`and Dr. Forys’s rationale then explain further convenience and conservation
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`benefits of employing a database for that local storage. (Petition, pp. 17-18; Forys
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`Decl., ¶ 89.)
`
`For example, Dr. Forys explains that “the database schema taught by
`
`Holtzberg enables simple organization and storage of metadata associated with an
`
`audio message.” (Forys Decl., ¶ 89.) This increases convenience of a user to search
`
`for and view details of audio messages locally, instead of searching traditional file
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`system storage or Abburi’s remote audio message store. As part of employing
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`Holtzberg’s database schema, Dr. Forys also explains that an “index created on the
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`unique message ID can be used to reduce retrieval time of a stored audio message,”
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`and a “message ID can be used to normalize the database and reduce data
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`redundancy, thus increasing storage space on the user’s device.” (Forys Decl., ¶
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`89.) These techniques further increase the convenience of local database storage
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`(e.g., improving search and retrieval costs), and conserve local resources (e.g.,
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`minimizing storage of multiple copies of the same data).
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`Further, the motivation to combine Abburi and Holtzberg need only
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`“identify a reason that would have prompted a person of ordinary skill in the
`
`relevant field to combine the elements in the way the claimed new invention does.”
`
`KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 418 (2007); see also In re Kahn, 441
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`F.3d 977, 987 (Fed. Cir. 2006) (finding that the reason or motivation to modify the
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`reference may often suggest what the inventor has done, but for a different purpose
`
`or to solve a different problem). The Board correctly noted that the claimed
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`“‘instant voice messaging application’ is a client-based program, not limited to
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`only an originating device, as discussed above.” (FWD, p. 20 (emphasis in
`
`original).) Thus, whether a motivation to employ a database on Abburi’s client
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`device is found for reasons of storing received message, as opposed to messages to
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`be sent, those reasons would have still prompted a person of ordinary skill in the
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`art to combine elements in the way the claimed invention does, specifically,
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`employing a database on the client device.
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`IV. Conclusion
`For the reasons set forth above, Patent Owner respectfully requests that the
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`U.S. Pat. No. 8,995,433
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`Board grant rehearing and find claims 1-6 and 8 of the ’433 patent invalid over the
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`instituted Grounds.
`
`
`Respectfully submitted,
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`/Jason D. Eisenberg/
`
`Jason D. Eisenberg
`Registration No. 43,447
`Attorney for Petitioner Apple Inc.
`
`
`
`Date: June 22, 2018
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
`
`9464167.docx
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`U.S. Pat. No. 8,995,433
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`CERTIFICATION OF SERVICE
`The undersigned hereby certifies that the foregoing PETITIONER APPLE
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`INC.’S REQUEST FOR REHEARING OF FINAL WRITTEN DECISION was
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`served electronically via e-mail on June 22, 2018, in its entirety upon the following
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`parties:
`
`ETHERIDGE LAW GROUP
`Brett A. Mangrum (Lead Counsel for Patent Owner) brett@etheridgelaw.com
`Ryan Loveless (Back-up Counsel for Patent Owner) ryan@etheridgelaw.com
`James Etheridge (Back-up Counsel for Patent Owner) jim@etheridgelaw.com
`Jeffrey Huang (Back-up Counsel for Patent Owner) jeff@etheridgelaw.com
`
`Sean D. Burdick (Back-up Counsel for Patent Owner)
`Uniloc USA, Inc.
`sean.burdick@unilocusa.com
`
`
`Heidi L. Keefe (Lead Counsel for Snap Inc.; Facebook, Inc.; and WhatsApp, Inc.)
`Lisa F. Schwier (Back-up Counsel for Snap Inc.)
`Phillip E. Morton (Back-up Counsel for Facebook, Inc. and WhatsApp, Inc.)
`Mark R. Weinstein (Back-up Counsel for Facebook, Inc. and WhatsApp, Inc.)
`COOLEY LLP
`FB_Uniloc2_433_PTAB_IPR@cooley.com
`hkeefe@cooley.com
`lschwier@cooley.com
`pmorton@cooley.com
`mweinstein@cooley.com
`Snapchat-Uniloc@cooley.com
`
`Date: June 22, 2018
`1100 New York Avenue, N.W.
`Washington, D.C.20005-3934
`(202) 371-2600
`
`
`
`
`
`
`
`STERNE, KESSLER, GOLDSTEIN & FOX L.L.C.
`
`/Jason D. Eisenberg/
`
`Jason D. Eisenberg
`Registration No. 43,447
`Attorney for Petitioner Apple Inc.
`
`
`
`
`
`
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