UNITED STATES PATENT AND TRADEMARK OFFICE
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`———————
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`———————
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`APPLE INC.,
`Petitioner,
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`v.
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`SAINT LAWRENCE COMMUNICATIONS LLC,
`Patent Owner.
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`———————
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`Case IPR2017-01244
`Patent 6,807,524 B1
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`———————
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`
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`PETITIONER’S REQUEST FOR REHEARING
`OF INSTITUTION DECISION UNDER 37 CFR § 42.71(d)
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`———————
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`
`———————
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`APPLE INC.,
`Petitioner,
`
`v.
`
`SAINT LAWRENCE COMMUNICATIONS LLC,
`Patent Owner.
`
`———————
`
`Case IPR2017-01244
`Patent 6,807,524 B1
`
`———————
`
`
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`PETITIONER’S REQUEST FOR REHEARING
`OF INSTITUTION DECISION UNDER 37 CFR § 42.71(d)
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`Petitioner’s Request for Rehearing
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`IPR2017-01244
` U.S. Patent No. 6,807,524
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`TABLE OF CONTENTS
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`I.
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`INTRODUCTION ................................................................................................ 1
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`II. LEGAL STANDARD .......................................................................................... 2
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`III. RATIONALE FOR REHEARING ....................................................................... 2
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`A. The Board overlooked the requirement of 37 C.F.R. § 42.108(c) and
`failed to view testimonial evidence in the light most favorable to
`Petitioner ....................................................................................................... 2
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`1. The Petition and supporting expert declaration establish that
`Salami teaches the claimed filter arrangement .............................................. 3
`
`2. Patent Owner’s testimonial evidence created a genuine issue of
`material fact as to the teachings of Salami .................................................... 5
`
`3. The Board erred when it credited Patent Owner’s testimonial
`evidence over Petitioner’s corresponding testimonial evidence ................... 6
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`B. The Board erred to the extent it substituted its own understanding of
`Salami for the understanding of one of ordinary skill in the art .................. 9
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`IV. CONCLUSION .................................................................................................. 12
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`ii
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`Petitioner’s Request for Rehearing
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`IPR2017-01244
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`TABLE OF AUTHORITIES
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` Page(s)
`
`Cases
`Brand v. Miller,
`487 F.3d 862 (Fed. Cir. 2007) .................................................................. 2, 10, 11
`
`Kingston Tech. Co. v. Polaris Innovations Ltd.,
`IPR2016-01623, Paper 7 (P.T.A.B Feb. 15, 2017) ........................................... 8, 9
`
`Mylan Pharmaceuticals Inc. v. UCB Pharma GmbH,
`IPR2016-00510, Paper 12 (P.T.A.B. July 20, 2016) ............................................ 8
`
`PPG Indus., Inc. v. Celanese Polymer Specialties Co.,
`840 F.2d 1565 (Fed. Cir. 1988) ............................................................................ 2
`
`Perfect Web Techs., Inc. v. InfoUSA, Inc.,
`587 F.3d 1324 (Fed. Cir. 2009) .......................................................................... 10
`
`Realtime Data LLC, v. Oracle Int’l Corp.,
`IPR2016-00695, Paper 8 (P.T.A.B. Sept. 13, 2016) ............................................. 9
`
`Synopsys, Inc. v. Mentor Graphics Corp.,
`814 F.3d 1309 (Fed. Cir. 2016) .................................................................... 10, 11
`
`Other Authorities
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`37 C.F.R. § 42.6(e) ................................................................................................... 13
`
`37 C.F.R. § 42.71(c) ................................................................................................... 2
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`37 C.F.R. § 42.71(d) .............................................................................................. 1, 2
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`37 C.F.R. § 42.108(c) ........................................................ 1, 2, 3, 5, 6, 7, 8, 9, 11, 12
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`Amendments to the Rules of Practice for Trials Before the Patent
`Trial and Appeal Board, 81 Fed. Reg. 18750, 18755 (Apr. 1, 2016) .................. 9
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`
`
`iii
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`Petitioner’s Request for Rehearing
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`IPR2017-01244
` U.S. Patent No. 6,807,524
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`I.
`
`INTRODUCTION
`Petitioner Apple Inc. (“Apple”) respectfully requests rehearing under 37
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`C.F.R. § 42.71(d) of the Board’s October 25, 2017 Decision denying institution of
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`inter partes review of U.S. Patent No. 6,807,524 (“the ’524 Patent”). Specifically,
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`Petitioner requests that the Board reconsider its determination that the Petition
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`failed to establish that the prior art, Salami (Ex-1008), discloses the particular filter
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`arrangement recited in the independent claims. Rehearing is warranted because the
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`Board overlooked 37 C.F.R. § 42.108(c), which requires evidence to be viewed in
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`the light most favorable to Petitioner when there is a genuine issue of material fact.
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`Here, Patent Owner filed expert testimony with its Preliminary Response that
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`directly conflicted with the testimony of Petitioner’s expert that Salami teaches the
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`claimed filter arrangement. The Board erred when it credited Patent Owner’s
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`expert evidence (“we agree with Patent Owner that Salami does not disclose [the
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`claimed filter arrangement],” Inst. Dec. 17) instead of resolving the factual dispute
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`in favor of Petitioner.
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`To the extent the Board relied upon its own understanding of Salami instead
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`of the understanding of a person of ordinary skill in the art, Petitioner respectfully
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`submits that doing so constitutes error in the context of this proceeding. Federal
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`Circuit case law establishes that “in the context of a contested case, it is
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`1
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`Petitioner’s Request for Rehearing
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`impermissible for the Board to base its factual findings on its expertise, rather than
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`on evidence in the record.” Brand v. Miller, 487 F.3d 862, 869 (Fed. Cir. 2007).
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`When the conflicting testimonial evidence in this proceeding is viewed in
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`the light most favorable to Petitioner, as required by§ 42.108(c), the record
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`establishes that Salami discloses the claimed filter arrangement. Petitioner
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`respectfully requests that the Board institute trial in order to resolve this factual
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`dispute with the benefit of a fully developed record.
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`II. LEGAL STANDARD
`The Board’s decision on institution is reviewed for an abuse of discretion. 37
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`C.F.R. § 42.71(c). An abuse of discretion occurs when a “decision was based on an
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`erroneous conclusion of law or clearly erroneous factual findings, or . . . a clear
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`error of judgment.” PPG Indus., Inc. v. Celanese Polymer Specialties Co., 840
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`F.2d 1565, 1567 (Fed. Cir. 1988). Further, a request for rehearing “must
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`specifically identify all matters the party believes the Board misapprehended or
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`overlooked, and the place where each matter was previously addressed in a motion,
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`an opposition, or a reply.” 37 C.F.R. § 42.71(d).
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`III. RATIONALE FOR REHEARING
`A. The Board overlooked the requirement of 37 C.F.R. § 42.108(c)
`and failed to view testimonial evidence in the light most favorable to
`Petitioner
`When a patent owner introduces testimonial evidence with its preliminary
`2
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`Petitioner’s Request for Rehearing
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`response, “a genuine issue of material fact created by such testimonial evidence
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`will be viewed in the light most favorable to the petitioner solely for purposes of
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`deciding whether to institute an inter partes review.” 37 C.F.R. § 42.108(c). In the
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`present proceeding, after Petitioner introduced expert testimony that a person of
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`ordinary skill in the art would understand Salami as teaching the filter arrangement
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`recited in element c) of claim 1 (the “perceptual weighting filter” element), Patent
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`Owner introduced directly conflicting testimonial evidence—and created a genuine
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`issue of material fact. Instead of viewing the evidence in the light most favorable
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`to Petitioner, as required by § 42.108(c), the Board improperly credited Patent
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`Owner’s testimonial evidence and held that Salami does not disclose this claim
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`element. This error warrants rehearing.
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`1.
`The Petition and supporting expert declaration establish
`that Salami teaches the claimed filter arrangement
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`The Petition set forth that the “perceptual weighting filter” element is met by
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`certain disclosures on page 448 of Salami. Pet. at 33. After quoting the relevant
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`portions of Salami, the Petition cites to Dr. Cohen’s expert testimony (Ex-1003)
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`and explains that:
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`Salami states here that the preemphasized wideband speech
`signal is first used for LP analysis, and next, the pre-emphasized
`signal is perceptually weighted and used to compute the
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`excitation codeword. Ex-1003, ¶¶ 114 et seq.
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`Id. This explanation of Salami reflects the understanding of a person of ordinary
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`skill in the art found in the corresponding portion of Dr. Cohen’s declaration. See
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`Ex-1003, ¶ 114 at p. 65. Dr. Cohen testified that:
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`Id. This testimonial evidence does not “merely repeat” the statements in the
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`Petition, as asserted by the Board in the Decision (at 19), but is instead the
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`evidentiary basis for the statements in the Petition. Dr. Cohen analyzes the
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`disclosure on page 448 of Salami and arrives at the conclusion that a person of
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`ordinary skill in the art would understand Salami as teaching a preemphasized
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`4
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`signal input to a perceptual weighting filter.1 This expert testimony is affirmative
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`evidence that Salami discloses the claimed filter arrangement and, under §
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`42.108(c), cannot be ignored at institution.
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`2.
`Patent Owner’s testimonial evidence created a genuine issue
`of material fact as to the teachings of Salami
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`
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`In its Preliminary Response, Patent Owner disputed Dr. Cohen’s
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`understanding of Salami and submitted testimonial evidence to support its position.
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`See POPR 35-37, Ex-2004, ¶¶ 91-92. Specifically, Patent Owner quotes Dr.
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`Gottesman’s analysis of the disclosure on page 448 of Salami and reproduces his
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`diagram of how “a POSITA would have understood Salami’s encoder.” POPR 36
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`(citing Ex-2004 ¶¶ 91-92). Patent Owner provides no other reasons besides Dr.
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`Gottesman’s testimony as to why Salami does not meet the claimed filter
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`arrangement.
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`Importantly, Dr. Gottesman’s testimony as to how a person of ordinary skill
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`in the art would understand the disclosure on page 448 of Salami directly conflicts
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`with Dr. Cohen’s testimony:
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`1 Dr. Cohen explains earlier in his declaration that “my testimony below refers to
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`the knowledge of one of ordinary skill in the speech-coding arts.” Ex-1003, ¶ 24.
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`5
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`Petitioner’s Request for Rehearing
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`Dr. Cohen
`“Salami states that the pre-emphasized
`wideband speech signal is first used for
`linear prediction analysis, and next, the
`signal is perceptually weighted and used
`to compute the excitation codeword –
`i.e., the same preemphasized signal
`used for LP analysis is input to the
`perceptual weighting filter.” Ex-1003,
`65. (emphasis added)
`
`Dr. Gottesman
`“This indicates that the actual encoded
`signal was not preemphasised and
`therefore, the perceptually weighting
`filter was not used for filtering a pre-
`emphasized signal (i.e., the perceptual
`weighting filter is not ‘responsive to
`said pre-emphasised signal,’ as required
`by the independent claims).” Ex-2004,
`47 (emphasis added)
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`In other words, Patent Owner’s testimonial evidence created a material factual
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`dispute as to whether a person of ordinary skill would understand Salami as
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`teaching a perceptual weighting filter that is responsive to a pre-emphasized signal.
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`As such, under § 42.108(c), the Board is required to view this evidence in the light
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`most favorable to Petitioner for the purposes of institution. In this case, that would
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`mean crediting Dr. Cohen’s testimony and finding—at least provisionally—that
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`Salami does in fact teach a perceptual weighting filter that is responsive to a pre-
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`emphasized signal. Rehearing is appropriate because the Board failed to do so.
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`3.
`The Board erred when it credited Patent Owner’s
`testimonial evidence over Petitioner’s corresponding testimonial
`evidence
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`Although Patent Owner’s testimonial evidence created a genuine issue of
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`material fact as to the teachings of Salami, the Board failed to follow § 42.108(c)
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`and view the evidence in the light most favorable to Petitioner. Instead, the Board
`6
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`viewed the evidence in the light most favorable to Patent Owner, explaining in the
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`Decision that “we agree with Patent Owner that Salami does not disclose that the
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`preemphasized input speech signal is used as an input to a perceptual weighting
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`filter as recited in claim 1. See PO Resp. 35–37.” Inst. Dec. 17 (emphasis added).
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`Because Patent Owner’s position is based entirely on the opinion of its expert, Dr.
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`Gottesman, the Board improperly credited Patent Owner’s testimonial evidence
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`over Petitioner’s corresponding testimonial evidence—and thus overlooked
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`§ 42.108(c).
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`The Board’s error appears to stem from a misunderstanding of Petitioner’s
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`evidence with respect to the “perceptual weighting filter” element. For example,
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`after analyzing page 448 of Salami and the corresponding portion of the Petition,
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`the Board asserted that Petitioner’s analysis amounts to “little more than an
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`unsupported conclusory remark.” Inst. Dec. 19. As discussed above, however,
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`Petitioner’s conclusion relies upon Dr. Cohen’s analysis of how a person of
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`ordinary skill in the art would understand page 448 of Salami. Pet. 33 (citing Ex-
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`1003). This expert testimony was directly countered by Patent Owner’s own
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`expert testimony that a person of ordinary skill in the art would not understand
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`Salami as teaching the “perceptual weighting filter” element. See POPR 36 (citing
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`Ex-2004, ¶¶ 91-92).
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`7
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`IPR2017-01244
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`The Board overlooked this factual dispute and the requirements of
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`§ 42.108(c) when it failed to resolve the issue in favor of Petitioner for the
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`purposes of institution. In particular, instead of viewing the evidence about Salami
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`in the light most favorable to Petitioner, the Board credited Dr. Gottesman’s
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`testimony when it “agree[d] with Patent Owner that Salami does not disclose [the
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`claimed filter arrangement].” Inst. Dec. 17. Although the Board disclaimed
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`reliance on Dr. Gottesman’s illustration of Salami’s alleged filter arrangement,
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`Inst. Dec. 20, it nevertheless appears to have adopted his testimony that page 488
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`of Salami does not teach the “perceptual weighting filter” element. This error
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`warrants rehearing.
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`Previous institution decisions in which the Board applied § 42.108(c) to
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`resolve factual disputes are informative. They illustrate that, although the Board
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`may “find Patent Owner’s arguments reasonable,” § 42.108(c) requires factual
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`disputes to be resolved in favor of Petitioner for the purposes of institution. See,
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`e.g., Mylan Pharmaceuticals Inc. v. UCB Pharma GmbH, IPR2016-00510, Paper
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`12 at 17 (P.T.A.B. July 20, 2016). For example, in Kingston Tech. Co. v. Polaris
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`Innovations Ltd., after Petitioner put forth testimony that the prior art taught
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`memory chips “connected in a series,” Patent Owner responded with expert
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`testimony that the prior art memory chips were not connected in series. IPR2016-
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`
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`8
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`Petitioner’s Request for Rehearing
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`IPR2017-01244
` U.S. Patent No. 6,807,524
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`01623, Paper 7 at 26-28 (P.T.A.B Feb. 15, 2017). In deciding to institute, the
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`Board held that, although Patent Owner’s evidence “raises a genuine issue of
`
`material fact” as to how the memory chips are connected, “we must view the
`
`evidence in the light most favorable to the petitioner.” Id. at 28 (citing to 37 C.F.R.
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`§ 42.108(c)). See also Realtime Data LLC, v. Oracle Int’l Corp., IPR2016-00695,
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`Paper 8 at 18 (P.T.A.B. Sept. 13, 2016) (instituting after resolving in Petitioner’s
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`favor a “genuine issue of material fact as to whether [the prior art] teaches or
`
`suggests [the disputed claim element],” as required by § 42.108(c)).
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`In each of these cases, the Board instituted trial after resolving a factual
`
`question of whether a person of ordinary skill would understand the prior art as
`
`teaching a particular claim element. In the present case, the Board should have
`
`done the same, as Patent Owner’s testimonial evidence creates a factual issue that
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`would be best resolved at trial, with the benefit of a full record. See Amendments
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`to the Rules of Practice for Trials Before the Patent Trial and Appeal Board, 81
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`Fed. Reg. 18750, 18755 (Apr. 1, 2016) (explaining that the reasoning behind
`
`§ 42.108(c) is “so that petitioner will have an opportunity to cross-examine [Patent
`
`Owner’s] declarant during the trial.”)
`
`B.
`The Board erred to the extent it substituted its own understanding
`of Salami for the understanding of one of ordinary skill in the art
`In the portion of the Decision addressing the “perceptual weighting filter”
`9
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`Petitioner’s Request for Rehearing
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`IPR2017-01244
` U.S. Patent No. 6,807,524
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`element, the Board states that “[w]e discern no teaching or suggestion in this text
`
`of Salami that the preemphasized signal is used on a perceptual weighting filter.”
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`Inst. Dec. 19. To the extent the Board substituted its own understanding of Salami
`
`for the understanding of one of ordinary skill in the art, Petitioner respectfully
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`submits that doing so constitutes error in the context of this proceeding.
`
`“[A]lthough the Board’s expertise appropriately plays a role in interpreting record
`
`evidence,” “in the context of a contested case, it is impermissible for the Board to
`
`base its factual findings on its expertise, rather than on evidence in the record.”
`
`Brand, 487 F.3d at 869. Further, the Federal Circuit recognizes that “when the
`
`technology is complex and ‘beyond the comprehension of laypersons,’ expert
`
`testimony is ‘sometimes essential.’” Synopsys, Inc. v. Mentor Graphics Corp., 814
`
`F.3d 1309, 1320 (Fed. Cir. 2016) (internal quotations removed); see also Perfect
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`Web Techs., Inc. v. InfoUSA, Inc., 587 F.3d 1324, 1330 (Fed. Cir. 2009) (“If the
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`relevant technology were complex, the court might require expert opinions.”).
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`Here, because Salami’s teachings are both disputed and complex2, Petitioner
`
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`2 Dr. Cohen testified that the level of ordinary skill in the art is “(i) a Master’s of
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`Science (M.S.) degree in Electrical Engineering or equivalent training, and (ii) at
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`least three to five years of relevant industry experience.” Ex-1003, ¶ 26.
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`10
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`Petitioner’s Request for Rehearing
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`IPR2017-01244
` U.S. Patent No. 6,807,524
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`respectfully submits that it is impermissible for the Board to ignore evidence as to
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`the understanding of a person of skill in the art. Such evidence is essential in order
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`to determine whether Salami teaches the elements of the ’524 patent. For example,
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`with respect to the “perceptual weighting filter” element, it is insufficient to read
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`page 448 of Salami in isolation; the background knowledge of a person of ordinary
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`skill in the art is required in order to appreciate its disclosure. See Synopsys, Inc.,
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`814 F.3d at 1320. Accordingly, to the extent the Board relied on its own reading of
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`Salami (“[w]e discern no teaching or suggestion in this text . . .” Inst. Dec. 19),
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`Petitioner respectfully submits that such reliance constitutes error warranting
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`rehearing. See Brand, 487 F.3d at 870-71 (reversing the Board upon a finding that
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`it “improperly substituted its own opinion for evidence of the knowledge of one of
`
`ordinary skill in the art.”)
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`Moreover, because Patent Owner’s testimonial evidence created a material
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`factual dispute in this case, § 42.108(c) requires that the Board rely not just on any
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`expert testimony, but on Petitioner’s expert testimony. When Dr. Cohen’s
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`testimony is properly credited, the factual issue of whether Salami teaches the
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`claimed filter arrangement should be resolved in favor of Petitioner. The Board
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`erred when it failed to do so.
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`11
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`Petitioner’s Request for Rehearing
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`IPR2017-01244
` U.S. Patent No. 6,807,524
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`IV. CONCLUSION
`Because the Board overlooked the requirements of 37 C.F.R. § 42.108(c)
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`and failed to properly credit Dr. Cohen’s expert testimony, Petitioner respectfully
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`submits that rehearing is warranted.
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`Respectfully submitted,
`
`Dated: November 22, 2017
`
`HAYNES AND BOONE, LLP
`2323 Victory Avenue, Suite 700
`Dallas, Texas 75219
`Telephone: 214-651-5116
`
`
`
`
`
`/Andrew S. Ehmke/
`Andrew S. Ehmke
`Registration No. 50,271
`Lead Counsel for Petitioners
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`12
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`Petitioner’s Request for Rehearing
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`IPR2017-01244
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`CERTIFICATE OF SERVICE
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`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e), that
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`service was made on the Patent Owner as detailed below.
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`Date of service November 22, 2017
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`Manner of service Electronic Mail
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`Documents served Petitioners’ Request for Rehearing Of Institution Decision
`Under 37 C.F.R. § 42.71(d)
`
`Persons served Dr. Gregory J. Gonsalves
`(gonsalves@gonsalveslawfirm.com)
`
`Masood Anjom
`(manjom@azalaw.com)
`
`Scott Clark
`(sclark@azalaw.com)
`
`AHMAD, ZAVITSANOS, ANAIPAKOS, ALAVI
`& MENSING P.C.
`1221 McKinney, Suite 2500
`Houston, TX 77010
`(713) 655-1101 (Reception)
`(713) 655-0062 (Facsimile)
`
`
`
`
`
`
`
`/Andrew S. Ehmke/
`Andrew S. Ehmke
`Registration No. 50,271
`Lead Counsel for Petitioners
`
`
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`13
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