`
`
`
`Filed on behalf of Valencell, Inc.
`By:
`Justin B. Kimble (JKimble-IPR@bcpc-law.com)
`
`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
`
`Daniel F. Olejko (dolejko@bcpc-law.com)
`
`
`Bragalone Conroy PC
`
`2200 Ross Ave.
`
`Suite 4500 – West
`
`Dallas, TX 75201
`
`Tel: 214.785.6670
`
`Fax: 214.786.6680
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`FITBIT, INC.,1
`Petitioner,
`
`v.
`
`VALENCELL, INC.,
`Patent Owner.
`
`Case IPR2017-003192
`U.S. Patent No. 8,923,941
`
`
`PATENT OWNER’S RESPONSE BRIEF TO
`PETITIONER’S OPENING BRIEF ON REMAND
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`1 Petitioner Apple Inc. is no longer a party in this proceeding.
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`2 Case IPR2017-01555 has been joined with this proceeding.
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`Case IPR2017-00319
`U.S. Pat. No. 8,923,941
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`B.
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`Table of Contents
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`Apple’s Petition Fails to Demonstrate that Claims 3-5 Are Obvious. ............. 1
`I.
`II. The Board Should Reject Fitbit’s Arguments Because They Are Not Limited
`to the Challenges in Petitioner Apple Inc.’s Petition. ...................................... 4
`A.
`Fitbit Improperly Attempts to Expand the Petition’s Challenge to
`Claim 3 by Relying on New Disclosures From Craw. ......................... 5
`Fitbit Improperly Attempts to Expand the Challenge to Claims 4-5 by
`Making New Arguments Based on the Correct Dependency. ............. 7
`Fitbit Improperly Attempts to Expand the Challenge to Claim 3 by
`Making New Arguments Regarding Lee. ............................................ 8
`III. Fitbit Fails to Demonstrate that Claim 3 Is Obvious Under the Board’s
`Construction of “Application-Specific Interface.” .......................................... 9
`IV. CONCLUSION ............................................................................................. 10
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`C.
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`Case IPR2017-00319
`U.S. Pat. No. 8,923,941
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`Table of Authorities
`
`
`Cases
`
`adidas AG v. Nike, Inc.,
` IPR2016-00922, 2018 WL 4056113 (P.T.A.B. Aug. 24, 2018) ........................... 4
`
`Alcon Research, Ltd. v. Apotex, Inc.,
` 687 F.3d 1362 (Fed. Cir. 2012) ............................................................................. 3
`
`Atl. Thermoplastics Co. v. Faytex Corp.,
` 5 F.3d 1477 (Fed. Cir. 1993) ................................................................................. 9
`
`Cisco Sys., Inc. v. Oyster Optics, LLC,
` IPR2017-01719, 2019 WL 328734 (P.T.A.B. Jan. 24, 2019) ....................... 4, 8, 9
`
`Fitbit, Inc. v. Valencell, Inc.,
` 964 F.3d 1112 (Fed. Cir. 2020) ......................................................................... 1, 8
`
`Google, Inc. v. SimpleAir, Inc.,
` CBM2015-00019, 2014 WL 8879049 (P.T.A.B. May 19, 2014) ......................... 7
`
`Hartness Int’l, Inc. v. Simplimatic Eng’g Co.,
` 819 F.2d 1100 (Fed. Cir. 1987) ............................................................................. 3
`
`Microsoft Corp. v. Enfish, LLC,
` 662 F. App’x 981 (Fed. Cir. 2016) ...................................................................... 10
`
`SAS Inst., Inc. v. Iancu,
` 138 S. Ct. 1348 (2018) .......................................................................................... 4
`
`Securus Techs., Inc. v. Global Tel*Link Corp.,
` 701 F. App’x 971 (Fed. Cir. 2017) ...................................................................... 10
`
`TQ Delta, LLC v. CISCO Sys., Inc.,
` 942 F.3d 1352 (Fed. Cir. 2019) ............................................................................. 4
`
`TRW Automotive US LLC v. MAGNA Elecs., Inc.,
` IPR2014-00251, 2014 WL 3945912 (P.T.A.B. July 31, 2014) .......................... 10
`
`
`ii
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`Case IPR2017-00319
`U.S. Pat. No. 8,923,941
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`Regulations
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`37 C.F.R. § 42.104(b)(4) .......................................................................................... 4
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`iii
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`Case IPR2017-00319
`U.S. Pat. No. 8,923,941
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`Pursuant to the Board’s September 14 Order, Patent Owner Valencell, Inc.
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`submits this Response Brief to Petitioner Fitbit, Inc.’s Opening Brief on Remand.
`
`I.
`
`Apple’s Petition Fails to Demonstrate that Claims 3-5 Are Obvious.
`The Federal Circuit remanded this proceeding because the Board “did not
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`review the patentability of claim 3, as construed, on the asserted grounds of
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`obviousness.” Fitbit, Inc. v. Valencell, Inc., 964 F.3d 1112, 1117-18 (Fed. Cir. 2020)
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`(emphasis added). Similarly, with respect to claims 4 and 5, the Federal Circuit
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`remanded for the Board to “determine patentability of corrected claims 4 and 5 on
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`the asserted grounds of obviousness.” Id. at 1120 (emphasis added). Thus, the Board
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`is tasked with evaluating whether Fitbit has met its burden of demonstrating that
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`claims 3-5, properly construed, are obvious based on the arguments made and the
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`evidence cited in Apple’s Petition. It has not.
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`In the Petition, Apple asserted that Craw discloses an application-specific
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`interface of claim 3: “Craw teaches that a data dictionary used with data classes acts
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`as an API for managing, extracting, and displaying information from information
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`streams.” Paper 2 at 27 (citing Ex. 1056 ¶ 256) (emphasis added). But neither Apple
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`nor Fitbit demonstrate that Craw discloses “an interface which enables a particular
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`application to utilize data obtained from hardware, such as the at least one motion
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`sensor and the at least one PPG [photoplethysmography] sensor.” See Fitbit, 964
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`F.3d at 1116-17 (emphasis added). As Apple conceded in the Petition, an API has
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`1
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`“broad applicability to different applications—and [is] not ‘application specific’ as
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`such.” Paper 2 at 14 (emphasis added); Ex. 1003 ¶ 62 (same). Indeed, Craw’s data
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`dictionary and data classes are not directed to any “particular application.” Rather,
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`as Apple’s expert explained, they provide “a generic mechanism” to access “all
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`types of definitions” and “a generic interface” used by “any software project.”
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`Ex. 1003 ¶¶ 75-76 (citing Ex. 1056 ¶¶ 253, 255) (emphasis added). Indeed, Craw’s
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`entire aim is interoperability. Ex. 1056 ¶¶ 8-10. Because Craw’s data dictionary and
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`data classes are generically applicable to different applications, they do not disclose
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`an application-specific interface. See Paper 2 at 14; Ex. 1003 ¶ 62.
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`Alternatively, Apple asserted in the Petition that Lee disclosed the
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`application-specific interface of claim 3: “Lee teaches multiple APIs and, in
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`particular, a wireless communications API (i.e., Bluetooth) to provide an interface
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`between a physiological parameter extraction device (i.e., a hemadynamometer) and
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`a mobile device.” Paper 2 at 57-58 (emphasis added). But, again, Lee’s API is
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`designed to work with various applications. As Apple’s expert explains, “[a]fter a
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`connection has been set up …, the mobile phone application programs can easily
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`use a serial port transmission protocol to receive physiological parameter
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`measurement data.” Id. ¶ 161 (citing Ex. 1059 at 511) (emphasis added). Because
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`the Bluetooth API has broad applicability to different applications, it is not an
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`application-specific interface. See Paper 2 at 14; Ex. 1003 ¶ 62.
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`2
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`With respect to claims 4 and 5, Apple’s Petition evaluated obviousness based
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`only on an incorrect dependency from claim 1. See Paper 2 at 29 (“As discussed
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`above, the combination of Luo and Craw suggests all the limitations of claim 1 as
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`arranged in the claim.”). Apple’s expert did the same. Ex. 1003 ¶ 92 (“As discussed
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`above, the combination of Luo and Craw suggests the method of claim 1.”). Because
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`Apple’s Petition did not evaluate obviousness based on the correct dependency of
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`claims 4 and 5 from claim 3, Apple’s Petition failed to show that the combination of
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`Luo, Craw, and Wolf renders obvious all limitations of claims 4 and 5 (i.e., the
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`limitations of claim 3). See Alcon Research, Ltd. v. Apotex, Inc., 687 F.3d 1362,
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`1367 (Fed. Cir. 2012) (“[A dependent claim] must ‘incorporate … all the limitations
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`of the claim to which it refers.’”).
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`Regardless, because the asserted grounds in Apple’s Petition failed to
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`demonstrate the obviousness of claim 3, the asserted grounds of obviousness in
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`Apple’s Petition against claims 4 and 5 necessarily fail as well. See Hartness Int’l,
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`Inc. v. Simplimatic Eng’g Co., 819 F.2d 1100, 1108 (Fed. Cir. 1987) (“[T]he district
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`court was correct in holding that independent claim 1 was nonobvious. A fortiori,
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`dependent claim 3 was nonobvious (and novel) because it contained all the
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`limitations of claim 1 plus a further limitation.”).
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`Apple’s Petition also failed to explain why a skilled artisan would have
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`combined Craw and Wolf with Luo and Lee with Mault and Al-Ali in the way the
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`3
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`inventions of claims 3-5 do (e.g., so that an application-specific interface can perform
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`further data processing). See Paper 2 at 27, 31, 58-59. Although Apple’s expert
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`asserted that it would have been obvious to combine these references to arrive at
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`claims 3-5, his testimony is nothing more than unsupported ipse dixit. See Ex. 1003
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`¶¶ 92-93, 104, 162-63. This is insufficient to support obviousness. See TQ Delta,
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`LLC v. CISCO Sys., Inc., 942 F.3d 1352, 1362 (Fed. Cir. 2019).
`
`II. The Board Should Reject Fitbit’s Arguments Because They Are Not
`Limited to the Challenges in Petitioner Apple Inc.’s Petition.
`A remand “does not change [the Board’s] focus on the Petition as Petitioner’s
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`case-in-chief ….” adidas AG v. Nike, Inc., IPR2016-00922, 2018 WL 4056113, at *3
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`(P.T.A.B. Aug. 24, 2018) (emphasis added). The “petitioner’s contentions [in the
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`petition] ... define the scope of the litigation all the way from institution through to
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`conclusion.” SAS Inst., Inc. v. Iancu, 138 S. Ct. 1348, 1355 (2018). The Petition must
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`identify “[h]ow the construed claim is unpatentable” and “specify where each
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`element of the claim is found in the prior art patents or printed publications relied
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`upon.” 37 C.F.R. § 42.104(b)(4). A petitioner cannot use later briefing as “an
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`opportunity to start anew, to fill in gaps or to remedy omissions in a petition.” Cisco
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`Sys., Inc. v. Oyster Optics, LLC, IPR2017-01719, 2019 WL 328734, at *10 (P.T.A.B.
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`Jan. 24, 2019). Yet that is exactly what Fitbit attempts to do. Faced with the reality
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`that Apple’s Petition does not demonstrate that claims 3-5 are obvious, Fitbit
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`purports to fill in gaps and remedy omissions in the Petition by relying on new
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`disclosures from Craw and making new arguments. As demonstrated herein, each of
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`these arguments should be rejected by the Board.
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`A. Fitbit Improperly Attempts to Expand the Petition’s Challenge to
`Claim 3 by Relying on New Disclosures From Craw.
`In the Petition, Apple argued only that “Craw teaches that a data dictionary
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`used with data classes acts as an API for managing, extracting, and displaying
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`information from information streams.” Paper 2 at 27 (citing Ex. 1056 ¶ 0256)
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`(emphasis added); see also Ex. 1003 ¶ 92 (citing Ex. 1056 ¶ 256). Other than the
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`data dictionary from paragraph 256 of Craw, Apple’s Petition does not identify any
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`other disclosure in Craw that allegedly teaches or discloses the claimed application-
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`specific interface. Notably, Apple never argued in the Petition that Craw discloses
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`the claimed application-specific interface under the Board’s construction of the term.
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`While Apple later attempted to make that argument in its subsequent Request for
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`Rehearing of Institution Decision and post-SAS brief, the Board correctly concluded
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`that it “cannot have overlooked or misapprehended an argument that the Petitioner
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`did not make” in the Petition. Paper 15 at 6-7 (emphasis added). For the same reason,
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`Fitbit cannot make that new argument now.
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`Nevertheless, Fitbit attempts to do just that. Relying on previously uncited
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`portions of Craw, it alleges – with only bare attorney argument – that “Craw’s
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`‘interfaces’ each qualify as an ‘application-specific interface (API)’ under the
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`Board’s narrowing construction.” Paper 60 at 5-6 (emphasis added) (citing Ex. 1056
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`5
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`¶¶ 48, 149, 202-203). Fitbit further relies on previously uncited paragraph 208 and
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`Figure 9A of Craw to argue that “Craw teaches that a health-monitoring application,
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`such as the blood pressure application in Figure 9A, uses the disclosed interfaces in
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`order to display extracted health data.” Id. at 6. Fitbit also relies on a new
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`“interpreter” in paragraph 48 of Craw. Id. at 7.
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`But Apple’s Petition did not rely on any of these disclosures to support its
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`argument that Craw discloses the application-specific interface of claim 3. It relied
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`solely on the combination of the data dictionary and data classes from paragraph 256
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`of Craw. See Paper 2 at 27; see also Ex. 1003 ¶ 92. And Apple and its expert never
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`argued in the Petition that Craw’s “interfaces” “perform the same function” as the
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`claimed application-specific interface under the Board’s construction thereof or that
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`Craw’s “‘interfaces’ … can be specifically tailored to each ‘particular application,’”
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`as Fitbit does in its Opening Brief. See Paper 60 at 6-7.
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`In addition, Fitbit attempts to rely on the Board’s reasoning from a different
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`proceeding (IPR2017-00321) regarding a different claim. See Paper 60 at 7-8. But
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`the challenges asserted in IPR2017-00321 are significantly different from the
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`challenges asserted in this proceeding. In the Petition, Apple relied on the
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`combination of Luo and Craw. In IPR2017-00321, Apple relied on different prior
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`art combinations. See IPR2017-00321, Paper 44 at 57. Thus, Fitbit cannot rely on
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`the final written decision in IPR2017-00321. See Paper 57 at 6. Further, arguments
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`from a prior proceeding “cannot be incorporated by reference in its Petition in this
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`proceeding.” Google, Inc. v. SimpleAir, Inc., CBM2015-00019, 2014 WL 8879049,
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`at *6 (P.T.A.B. May 19, 2014). Tellingly, although the Board’s decision in IPR2017-
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`00321 was mailed well after Apple filed the Petition in this case, Apple never sought
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`authorization to supplement its briefing to address any potential implications of that
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`decision to this proceeding, see Paper 43 at 17, and neither has Fitbit.
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`Fitbit’s attempt to rely on previously uncited portions of Craw is equivalent
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`to the submission of new evidence, which the Board specifically precluded in its
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`September 14 Order. See Paper 57 at 7-8. As the Board noted in its Order, Apple
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`had “expressly argued that, even under our construction of the term ‘application-
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`specific interface (API),’ now affirmed by the Federal Circuit, the Petition is
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`sufficient to show that claim[s] 3–5 are rendered obvious over the combined
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`teachings of the applied references.” Id. at 8 (emphasis added). Thus, Fitbit is bound
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`by the arguments and evidence cited by Apple in the Petition and should not be
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`permitted to rely on different grounds or portions of Craw never cited in Apple’s
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`Petition for the disclosure of the claimed application-specific interface.
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`B. Fitbit Improperly Attempts to Expand the Challenge to Claims 4-
`5 by Making New Arguments Based on the Correct Dependency.
`Claim 4 correctly depends from claim 3, not claim 1. See Fitbit, 964 F.3d
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`at 1120. Yet, Apple argued in the Petition that the combination of Luo, Craw, and
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`Wolf discloses the limitations of claims 4 and 5 based on the incorrect dependency.
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`Paper 2 at 29. As a result, Apple did not assert in the Petition that the combination
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`of these references disclosed an application-specific interface. Instead, Apple’s
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`Petition ignored this key limitation, arguing only that Wolf discloses the additional
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`limitations of claims 4 and 5. See id. Now, Fitbit attempts to rely on its new analysis
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`of claim 3 to support its analysis of claims 4 and 5, but that is improper since it is
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`outside the scope of the challenge in Apple’s Petition. See Paper 57 at 6.
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`Accordingly, the Board should not permit Fitbit to “fill in gaps” and “remedy
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`omissions in a petition” by making new arguments based on the correct dependency
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`of claims 4 and 5. See Cisco, 2019 WL 328734, at *10.
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`C. Fitbit Improperly Attempts to Expand the Challenge to Claim 3 by
`Making New Arguments Regarding Lee.
`In the Petition, Apple never argued that Lee disclosed the claimed application-
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`specific interface under the Board’s construction of the term. See Paper 2 at 55-58.
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`And Apple never argued, as Fitbit does now, that “Lee discloses [sic] ‘application-
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`specific interface (API)’ because Lee’s ‘mobile phone application program’ is a
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`‘particular application’ using the data.” Paper 60 at 10. Indeed, Apple did not make
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`any similar characterizations of Lee’s mobile application programs in the Petition.
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`See Paper 2 at 55-58. Accordingly, the Board should not permit Fitbit to expand the
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`scope of the challenge in the Petition by making new arguments regarding Lee’s
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`disclosures. See Cisco, 2019 WL 328734, at *10.
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`8
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`III. Fitbit Fails to Demonstrate that Claim 3 Is Obvious Under the Board’s
`Construction of “Application-Specific Interface.”
`While the Federal Circuit wrote that “[t]he Board’s narrowing construction
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`may have no significance, where, as here, the claimed ‘application-specific
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`interface’ performs the same function as an application programming interface, i.e.,
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`‘enabl[ing] a particular application to utilize data obtained from hardware,’” this
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`observation is, at best, dicta, and cannot be construed as a finding of fact. See Atl.
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`Thermoplastics Co. v. Faytex Corp., 5 F.3d 1477, 1479 (Fed. Cir. 1993) (“Fact-
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`finding by the appellate court is simply not permitted.”). There is simply no evidence
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`that a generic API performs the same function as an application-specific interface.
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`Fitbit argues that Craw’s “interfaces” and Lee’s Bluetooth API can be used
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`with a particular application. Paper 60 at 6-8, 10. But that does not mean that these
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`APIs are application-specific interfaces. Indeed, the Board previously rejected
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`Apple’s argument that claim 3 requires only that the application-specific interface
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`“can utilize a particular application.” Paper 15 at 7 n.6. It must be “directed to a
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`‘particular application,’ rather than broadly to different applications.” Paper 43 at 15
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`(emphasis added). Fitbit’s claim that Craw discloses tailoring its API to a specific
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`application takes Craw out of context. Paper 60 at 7. Fitbit quotes a statement from
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`Craw’s background that “software may be configured to operate upon a particular
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`subset of data.” Id. But that statement does not concern Craw’s “interfaces.” It
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`concerns the prior art. And while the actions taken by Craw’s interpreter may
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`“depend on the goal of the application,” Craw’s “interfaces” are designed to be
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`interoperable, so that they work with a variety of applications, which is the very
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`opposite of application specific. See Ex. 1056 ¶¶ 10-11, 46-47, 51, 141-43.
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`Moreover, an invention is not obvious merely because it performs the same
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`function as the prior art. There must be no unexpected results. See TRW Automotive
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`US LLC v. MAGNA Elecs., Inc., IPR2014-00251, 2014 WL 3945912, at *3
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`(P.T.A.B. July 31, 2014). Yet, Fitbit provides no analysis, let alone evidence, that
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`the substitution of the claimed application-specific interface for Craw’s or Lee’s API
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`would not give unexpected results.
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`Fitbit’s only reason for combining Craw and Wolf with Luo is their similar
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`technology and problems addressed. Paper 60 at 5, 9. But this alone is not a sufficient
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`rationale to support obviousness. See Securus Techs., Inc. v. Global Tel*Link Corp.,
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`701 F. App’x 971, 977 & n.3 (Fed. Cir. 2017); Microsoft Corp. v. Enfish, LLC, 662
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`F. App’x 981, 990 (Fed. Cir. 2016). Fitbit’s only basis to combine Lee, Mault, and
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`Al-Ali is to allow communicating information to a device. Paper 60 at 10. But that
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`conclusion is supported by nothing more than the hindsight bias of Fitbit’s expert
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`and the expert’s ipse dixit. See Ex. 1003 ¶¶ 162-63.
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`IV. CONCLUSION
`For the foregoing reasons, Valencell requests that the Board find, again, that
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`Fitbit fails to meet its burden of demonstrating that claims 3-5 are unpatentable.
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`Dated: October 26, 2020
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`Respectfully submitted,
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`Justin B. Kimble
`Attorney for Patent Owner
`Registration No. 58,5 91
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that this document was served via electronic
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`mail on October 26, 2020, to Petitioner via counsel, James M. Glass, Sam Stake, and
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`Ogi Zivojnovic
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`at
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`the
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`addresses:
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`jimglass@quinnemanuel.com,
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`samstake@quinnemanuel.com, ogizivojnovic@quinnemanuel.com, pursuant
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`to
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`Petitioner’s consent in its Updated Mandatory Notices at page 2.
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`Justin B. Kimble
`Attorney for Patent Owner
`Registration No. 58,591
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
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`12
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