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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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`BITDEFENDER INC.
`Petitioner
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`v.
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`UNILOC USA, INC.
`Patent Owner
`____________
`
`Case IPR2017-01315
`Patent 6,510,466
`
`Title: Methods, Systems and Computer Program Products for Centralized
`Management of Application Programs on a Network
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`
`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE
`
`UNDER 37 CFR §42.100 ET SEQ.
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`TABLE OF CONTENTS
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`INTRODUCTION .............................................................................................. 1
`I.
`II. PETITION PROVIDED EVIDENCE AND REASONING TO SUPPORT A
`FINDING OF OBVIOUSNESS FOR THE INSTITUTED CLAIMS ..................... 2
`A. Kasso renders obvious a system including a server that receives login
`requests and installs application programs ............................................................ 2
`1. Legal background ......................................................................................... 2
`2. Petition explains and supports the obviousness of a system performing
`single-server authentication and application program installation ..................... 3
`3. Kasso suggests implementing on a single computer system functionality
`described in another embodiment as implemented by computer systems .......... 5
`4. Petition explains and supports advantages of a single-server
`implementation ................................................................................................... 7
`5. Petition explains why a single-server approach involves a simple
`substitution ......................................................................................................... 9
`6. Kasso does not teach away from a single-server approach ........................ 10
`7. Authentication Offload .............................................................................. 10
`III.
`CONSTITUTIONALITY OF IPR PROCEEDINGS ............................................. 14
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`PATENT OWNER WAIVED THE RIGHT TO CONTEST THE
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`ii
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`IV. CONCLUSION .............................................................................................. 14
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`IV. CONCLUSION .............................................................................................. 14
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`iii
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`iii
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`TABLE OF AUTHORITIES
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`Cases
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`Page
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`Alza Corp. v. Mylan Labs., Inc., 464 F.3d 1286, 1290 (Fed. Cir. 2006) 7,8,11
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`Cross Med. Prods., Inc. v. Medtronic Sofamor Danek, Inc., 424 F.3d, 1293, 1322
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`(Fed. Cir. 2005)
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`In re Etter, 756 F.2d 852, 859 (Fed. Cir. 1985)
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`In re Fulton, 391 F.3d 1195, 1201 (Fed. Cir. 2004)
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`In re Gurley, 27 F.3d 551, 553 (Fed. Cir. 1994)
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`In re Keller, 642 F.2d 413, 425 (CCPA 1981)
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`KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 127 (S. Ct. 2007)
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`8
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`3, 10
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`12
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`10, 12
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`3
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`3,11,13
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`K/S HIMPP v. Hear-Wear Techs., LLC, 751 F.3d 1362, 1365-66 (Fed. Cir. 2014)
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`
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`In re Mouttet, 686 F.3d 1322, 1334 (Fed. Cir. 2012)
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`7, 8, 11
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`3, 12
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`Oil States Energy Servs., LLC v. Greene’s Energy Grp., LLC, 137 S. Ct. 2239
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`(2017)
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`In re Omeprazole Patent Litigation, 536 F.3d 1361 (Fed. Cir. 2008)
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`14
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`12
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`iv
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`I.
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`INTRODUCTION
`Patent Owner’s Response (Paper 11, “POR”) fails to rebut Petitioner’s
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`showing that the instituted claims are obvious in light of Kasso, Raduchel and
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`Olsen.
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`In its POR, Patent Owner reiterates its challenge to Petitioner’s reasoning
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`regarding the limitation “receiving at the server a login request from a user at the
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`client,” found in claim 1. Patent Owner does not raise, and thus has waived, any
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`other challenge as to claim construction, other limitations of claim 1, or any of
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`the dependent claims.
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`The POR does not rely on any new evidence. The POR relies on Dr.
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`DiEuliis’ Expert Declaration (Ex. 2001) filed with the Patent Owner’s
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`Preliminary Response (Paper 6, “POPR”) and previously considered by the
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`Board. Patent Owner did not submit a new expert declaration with its POR, and
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`did not cross-examine Petitioner’s expert witness.
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`Patent Owner’s challenge, in broadly the same form, was previously
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`considered and rejected by the Board. Contrary to Patent Owner’s conclusory
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`contentions, the Petition (Paper 1) provided evidence and reasoning to support a
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`finding of obviousness for the challenged claims, and the Board should find
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`claims 1, 2 and 7-9 of the ‘466 patent invalid for obviousness.
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`1
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`
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`II. PETITION PROVIDED EVIDENCE AND REASONING TO
`SUPPORT A FINDING OF OBVIOUSNESS FOR THE INSTITUTED
`CLAIMS
`A. Kasso renders obvious a system including a server that receives
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`login requests and installs application programs
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`The Petition sets forth two arguments regarding the obviousness of claim
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`1, and in particular of a system using a single server that implements “receiving
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`login requests” and “installing application programs.” See Petition at 32-36,
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`discussing “single-server authentication” and “forwarding login requests to an
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`authentication server.” Each of these arguments was supported by three reasons,
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`each separately sufficient to support a finding of obviousness. Thus, the
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`challenged claims are unpatentable if at least one of the two arguments is
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`supported by at least one sufficient reason.
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`Patent Owner argues that the two arguments set forth by the Petition fail
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`because (1) there is no “reasoning or support for the overall architecture of its
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`proposed modification,” and (2) “there is insufficient reasoning and support for
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`a POSITA to make the alleged modification.” POR at 7. Petitioner disagrees,
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`for the reasons set forth in the Petition and below.
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`1. Legal background
`When considering obviousness of a combination of known elements, the
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`operative question is “whether the improvement is more than the predictable use
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`2
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`of prior art elements according to their established functions.” KSR Int'1 Co. v.
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`Teleflex, Inc., 550 U.S. 398, 418 (U.S. 2007). A person of ordinary skill in the
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`art is also a person of ordinary creativity, not an automaton. Id. at 421. A
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`proper obviousness analysis takes into account “the inferences and creative steps
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`that a person of ordinary skill in the art would employ.” Id. at 418. The test for
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`obviousness is not whether the features of a secondary reference may be bodily
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`incorporated into the structure of the primary reference. […] Rather, the test is
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`what the combined teachings of those references would have suggested to those
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`of ordinary skill in the art. In re Keller, 642 F.2d 413, 425, (CCPA 1981). See
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`also In re Mouttet, 686 F.3d 1322, 1332 (Fed. Cir. 2012), and In re Etter, 756
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`F.2d 852, 859 (Fed. Cir. 1985).
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`2. Petition explains and supports the obviousness of a system
`performing single-server authentication and application
`program installation
`In the first paragraph of section III.A.1.a of the POR, Patent Owner argues
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`that the Petition does not explain “why a POSITA would have been motivated to
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`completely redesign the Kasso system, such that the authentication functionality
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`dedicated to a server designed for that purposes is, instead, implemented in an
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`entirely different server having an expressly different purpose.” POR at 8.
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`First, the Kasso system would not have been completely redesigned. A single-
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`server approach would have merely involved “incorporating authentication
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`3
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`functionality on a delivery server such as the HTTP server 208 of Kasso.”
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`Petition at 33. Second, a POSITA would have had at least three reasons to make
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`the proposed modification, as explained in the Petition: Kasso expressly
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`suggested that functionality described in his disclosure as implemented by
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`multiple systems may be implemented on a single computer system; the
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`proposed modification would have led to advantages in cost and simplification;
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`and the proposed modification would have involved the simple substitution of
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`one known element for another. Petition at 33-34.
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`In the second paragraph of III.A.1.a, Patent Owner states, without citation,
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`that “The Petition even admits that it provides no explanation, reasoning, or
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`support for its proposed modification”. POR at 8. Contrary to the POR’s
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`unsupported assertion, the Petition contains no such admission. A single-server
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`implementation does
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`involve a change
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`in
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`the entities
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`involved
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`in
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`intercommunication relative to the embodiment described by Kasso with
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`reference to Fig. 2. By noting this simple fact, Petitioner made no admission
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`regarding a purported lack of explanation, reasoning or support for the proposed
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`modification.
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`In the third paragraph of III.A.1.a, Patent Owner argues that relying on the
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`challenged ‘466 patent as a guide in an obviousness argument to modify
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`references is impermissible. Id. at 9. The statement in the Petition that the ‘466
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`4
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`patent itself “envisions multiple entities…on a single machine, and does not
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`deem further explanation of such an approach to be necessary” supports treating
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`a single-server implementation as a simple, non-inventive modification. The
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`‘466 patent citation is used in the context of explaining the simplicity of a
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`single-server implementation, and not as a substitute for the asserted reasons
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`why the claimed subject matter would have been obvious. The POR further
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`asserts that “the Petition and Mr. Day cannot even envision or articulate the
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`proposed modification.” To the extent an “envisioning” requirement is legally
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`definable or relevant, Patent Owner’s claim is contradicted by the extensive
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`explanation provided by the Petition for the proposed modification. Petition at
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`34-36. The POR itself indicates that Patent Owner understood the nature of the
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`modification described by the Petition.
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`3. Kasso suggests implementing on a single computer system
`functionality described in another embodiment as
`implemented by computer systems
`Section III.A.1.b of the POR argues that Kasso does not suggest a “single-
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`server” structure. Petitioner does not dispute that Kasso’s disclosures of Figs. 1
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`and 2 refer to different embodiments. See Ex. 1009 (Kasso), 4:46 (“An alternate
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`hardware environment is shown in Fig. 2.”). This fact is compatible with
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`Kasso’s statement at 4:36-38 that “Execution of the sequences of instructions
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`contained in memory 104 causes processor 102 to perform the process steps that
`5
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`will be described hereafter.” Kasso also suggests, at 4:50-51, the possibility of
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`configuring each network computer in the embodiment of Fig. 2 in the form of
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`computer system 100, except without data storage device 107. This alternative
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`suggestion, however, does not negate Kasso’s explicit suggestion in the prior
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`paragraph, with reference to the first embodiment, that a single computer system
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`(computer system 100) may be used to implement functionality described
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`“hereafter” in the specification. Petitioner notes that the Petition made an
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`obviousness argument under 35 USC §103, rather than an anticipation argument
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`under 35 USC §102. Had Kasso expressly described the exact configuration of
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`the claims, Petitioner would have argued anticipation rather than obviousness.
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`In the second paragraph of III.A.1.b, Patent Owner argues that Kasso
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`“distinguishes between its client computer systems and its multiple server
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`systems.” Patent Owner’s argument is not responsive to the explicit suggestion
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`by Kasso identified in the Petition.
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`In the third paragraph of III.A.1.b, Patent Owner again makes a non-
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`responsive argument. Specifically, Patent Owner argues that “nothing in
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`Figures 1 or 2, alone or together provides explanation, reasoning, or support for
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`a POSITA to modify Kasso such that…” The Petition cited Kasso 4:36-38,
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`rather than the diagrams of Fig. 1 and 2 in isolation. And again, the Petition
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`6
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`made an obviousness argument under 35 USC §103, rather than an anticipation
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`argument under 35 USC §102.
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`4. Petition explains and supports advantages of a single-server
`implementation
`In the first paragraph of III.A.1.c, Patent Owner states that “The Petition
`makes the conclusory argument, without explanation, reasoning, or support, that
`“implementing two functions ... on the same server” would have “saved costs
`and potentially simplified the system architecture”. Petitioner notes that a prima
`facie showing of obviousness requires an articulated reason to support a
`proposed modification as viewed from the perspective of a POSITA, rather than
`a rabbit hole of reasons for reasons from the perspective of an automaton. A
`POSITA would have understood that hardware had a cost, and that using one
`computer instead of two would have saved costs and potentially simplified a
`system. This simple explanation was supported by Petitioner’s expert, Mr. Day.
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`Patent Owner’s citations to Alza Corp. v. Mylan Labs., Inc., 464 F.3d
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`1286, 1290 (Fed. Cir. 2006) and K/S HIMPP v. Hear-Wear Techs., LLC, 751
`
`F.3d 1362, 1365-66 (Fed. Cir. 2014) are inapposite. In Alza, the Federal Circuit
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`upheld a holding of invalidity of the relevant claims as obvious, and rejected
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`arguments that there would have been no reasonable expectation of success for
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`7
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`the proposed modification.1 The court noted that a reason to combine need not
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`be found in the prior art, citing Cross Med. Prods., Inc. v. Medtronic Sofamor
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`Danek, Inc., 424 F.3d, 1293, 1322 (Fed. Cir. 2005) (“[T]he motivation to
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`combine need not be found in prior art references, but equally can be found in
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`the knowledge generally available to one of ordinary skill in the art ....”). In K/S
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`HIMPP, the Federal Circuit declined to support using common sense to supply
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`structural features missing from the asserted prior art, specifically “a plurality of
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`prongs that provide a detachable mechanical and electrical connection.” In the
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`present case, there is no dispute that Kasso describes a server.
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`In the second paragraph of III.A.1.c, Patent Owner argues that “nothing in
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`the Petition or Mr. Day’s mere conclusory assertion provides explanation,
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`reasoning, or support for a POSITA to modify Kasso such that the functionality
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`of one specifically-designed server (the NIS server 230) is implemented, instead,
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`within a distinct server designed for an entirely different purpose (the HTTP
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`server 208), as Petitioner proposes.” POR at 12. Patent Owner ignores the
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`Petition and Mr. Day’s Declaration, which explain, inter alia, that “A single-
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`machine implementation would have been particularly desirable on a system of
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`1 The claims at issue in Alza, unlike the instant claims, were directed to subject
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`matter in the unpredictable arts.
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`8
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`limited scale, which would not have required the additional processing power of
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`a dedicated authentication server.” Petition at 34.
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`5. Petition explains why a single-server approach involves a
`simple substitution
`In the first paragraph of III.A.1.d, Patent Owner argues that Petitioner’s
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`simple remark that a single-server implementation involves a change in the
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`entities involved in intercommunication somehow undermines Petitioner’s
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`arguments. Patent Owner apparently finds a contradiction between a “change in
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`entities” and a “simple substitution.” There is no contradiction: a simple
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`substitution does imply a change. Had there been no change from Kasso’s
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`described embodiment(s), Petitioner’s argument would have been one under
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`section 102 rather than section 103.
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`Patent Owner takes issue with the word “potentially” in the Petition’s
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`statement that a single-server implementation “would have saved costs and
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`potentially simplified the system architecture.” POR at 13. The fact that a
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`single-server approach would have potentially simplified a system’s architecture
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`is used in the Petition as an instantly-recognizable reason that a POSITA would
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`have used to modify Kasso’s teachings. Patent Owner’s argument is somewhat
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`cryptic and hard to discern. Petitioner simply notes that a showing of
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`obviousness involves combining or modifying the teachings of one or more
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`references. See e.g. In re Etter, 756 F.2d 852, 859 (Fed. Cir. 1985).
`9
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`6. Kasso does not teach away from a single-server approach
`In Section III.A.1.e Petitioner argues that Kasso teaches away from a
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`single-server approach, repeating verbatim the arguments made in the POPR at
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`20-21. In the Institution Decision, the Board stated that “At this juncture, we
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`disagree with Patent Owner that Kasso’s description of separate, dedicated
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`servers teaches away from a single server.” Institution Decision, Paper 7, at 21.
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`With no new arguments and no new evidence, the Board should find no reason
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`to depart from the Institution Decision.
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`Patent Owner’s reliance on In re Gurley, 27 F.3d 551, 553 (Fed. Cir.
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`1994) is misplaced. Simply describing a different implementation does not
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`constitute teaching away. Moreover, in In re Gurley, the court rejected the
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`patent owner’s teaching-away argument in a fact pattern that involved explicit
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`disparagement of an alternative, rather than the mere description of a different
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`embodiment as in the present case.
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`7. Authentication Offload
`The arguments presented in section III.A.2 of the POR to challenge the
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`“offload” modification are reproduced verbatim from the POPR, except for the
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`first and the last paragraphs of the section. Compare POR, section III.A.2 (POR
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`at 16-19) with POPR, section IV.B.3 (POPR at 22-25). The Board declined to
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`10
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`
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`address the “offload” structure in its Institution Decision (Institution Decision at
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`21).
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`In the first paragraph of III.A.2, Patent Owner cites again Alza Corp. v.
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`Mylan Labs., Inc., 464 F.3d 1286, 1290 (Fed. Cir. 2006) and K/S HIMPP v.
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`Hear-Wear Techs., LLC, 751 F.3d 1362, 1365-66 (Fed. Cir. 2014), addressed
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`above.
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`In the second paragraph of III.A.2, Patent Owner argues that the offload
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`modification would “significantly deviate” from Kasso’s disclosure and that the
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`offload modification uses the ‘466 challenged patent as “a blueprint to
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`fundamentally rewrite the disclosure in Kasso.” POR at 17. It is axiomatic that
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`an obviousness argument deviates in some way from a reference, and adverbs
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`such as “significantly” and “fundamentally” do not add substance to Patent
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`Owner’s argument. Had there been no deviation from Kasso’s described
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`embodiment(s), Petitioner’s argument would have been one under section 102
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`rather than section 103. Patent Owner’s case law citations are inapposite. In re
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`Sang Su Lee is a pre-KSR (2002) Federal Circuit obviousness decision that
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`required a teaching/suggestion/motivation in the reference itself. K/S Himpp,
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`the second case cited, is addressed above.
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`In the third paragraph of III.A.2, Patent Owner argues that Kasso teaches
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`away from the proposed modification, citing again In re Gurley. Patent Owner
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`11
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`states that the modification is “contrary to the express disclosure in Kasso.”
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`Patent Owner also relies on its Expert Declaration to point to a potential
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`bottleneck concern, and to undesirable server-to-server communications that
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`would result from the proposed modification. As noted in section 6 above,
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`simply describing a different implementation does not constitute teaching away.
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`See In re Gurley and In re Mouttet, supra, and In re Fulton, 391 F.3d 1195,
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`1201 (Fed. Cir. 2004).
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`In fact, a potential bottleneck concern identified by Patent Owner’s expert
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`for a distributed system provides a reason supporting a single-server approach,
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`as described above. So does a concern with additional server-to-server
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`communications and associated bandwidth and processing power.
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`In the fourth paragraph of section III.A.2, Patent Owner argues that the
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`NIS server 230 of provides what Kasso considers to be an adequate solution to
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`security. This argument does not rebut the explanation by Petitioner’s expert
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`that an offload approach would have enhanced security by minimizing the
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`number of servers directly exposed to external communications. See Ex. 1008,
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`Day Declaration, at ¶ 33. Patent Owner also stated that “In the case of In re
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`Omeprazole Patent Litigation, 536 F.3d 1361 (Fed. Cir. 2008), the Federal
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`Circuit affirmed a finding of nonobviousness because the alleged flaws in the
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`prior art that ostensibly prompted the modification had not been recognized in
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`12
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`
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`the art itself.” POR at 18. Patent Owner’s argument is undermined by its own
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`expert declaration, which describes security as a known concern. See POR at
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`15, discussing Ex. 2001, the Dr. DiEuliis Declaration.2
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`In the fifth paragraph of Section III.A.2, Patent Owner does not rebut the
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`argument that an offload approach would have involved a selection from a finite
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`number of identified solutions with a reasonable expectation of success, a legal
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`standard set by KSR. POR at 18-19. Patent Owner argues that Petitioner failed
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`to explain the modification. But the Petition identified two specific solutions,
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`direct v. indirect communication with a server, an identification that explains the
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`proposed modification. Patent Owner further argues that Kasso does not leave it
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`to POSITA to decide between two alternatives. In KSR itself there was no
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`allegation that the primary prior art reference made an explicit suggestion, or
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`“left it to POSITA to decide between two alternatives.” There simply were a
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`finite number of locations where a pedal sensor could be affixed, and the court
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`held that mounting an available sensor on a fixed pivot point was well within the
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`grasp of a POSITA.
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`2 While Patent Owner’s statement cited above uses the present tense, Patent
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`Owner’s Declaration used the past tense and referenced a POSITA in its
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`discussion of security. See Ex. 2001, Dr. Di Euliis Declaration, ¶ 17 and 89-
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`92.
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`13
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`
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`III. PATENT OWNER WAIVED THE RIGHT TO CONTEST THE
`CONSTITUTIONALITY OF IPR PROCEEDINGS
`Patent Owner advances a constitutional challenge to IPR proceedings as
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`set forth in Oil States Energy Servs., LLC v. Greene’s Energy Grp., LLC, 137 S.
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`Ct. 2239 (2017). POR at 20. Patent Owner’s argument is new. Patent Owner
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`could have raised this challenge prior to the Institution Decision, in its POPR,
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`and did not do so. Indeed, the Oil States petition for a writ of certiorari was
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`filed in November 2016, well before the filing of the Petition. By not timely
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`raising the constitutional challenge, Patent Owner waived the right to do so later.
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`IV. CONCLUSION
`The subject matter differences at issue are simple and non-inventive, and
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`are such that the claimed subject matter does not constitute more than the
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`predictable use of prior art elements according to their established functions.
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`Petitioner respectfully requests that all the instituted claims be declared
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`unpatentable.
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`Date: February 1, 2018
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`
`By:
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`Respectfully submitted,
`
`/Andrei D. Popovici, Reg. No. 42,401/
`
`/Mihai H. Murgulescu, Reg. No. 72,512/
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`14
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`Andrei D. Popovici (Reg. No. 42,401)
`Lead Counsel for Petitioner
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`Mihai H. Murgulescu (Reg. No. 72,512)
`Backup Counsel for Petitioner
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`Law Office of Andrei D. Popovici
`4030 Moorpark Ave. Suite 108
`San Jose CA 95117
`Tel: 650-530-9989 Email: andrei@apatent.com, mihai@apatent.com
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`15
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`42.24(d) CERTIFICATE OF COMPLIANCE
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`Pursuant to 37 CFR 42.24(d), I hereby certify that this petition complies
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`with the type-volume limitation of 37 CFR 42.24(c)(1) because the brief,
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`excluding the parts exempted by 37 CFR 42.24(a)(1), contains fewer than
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`5,600 words, as determined by the word-processing software used to prepare
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`the brief.
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`/Andrei D. Popovici, Reg. No. 42,401/
`Andrei D. Popovici, Reg. No. 42,401
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`A
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`42.6(e) CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.6(e), we certify that we served an electronic
`copy of the foregoing PETITIONER’S REPLY TO PATENT OWNER’S
`RESPONSE along with the accompanying exhibits via PTAB E2E to Patent
`Owner’s counsel of record at the following addresses:
`
`Brett A. Mangrum brett@etheridgelaw.com
`Lead Counsel for Patent Owner, Reg. No. 64,783
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`Sean D. Burdick sean.burdick@unilocusa.com
`Back-up Counsel for Patent Owner, Reg. No. 51,513
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`Ryan Loveless ryan@etheridgelaw.com
`Back-up Counsel for Patent Owner, Reg. No. 51,970
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`James Etheridge jim@etheridgelaw.com
`Back-up Counsel for Patent Owner, Reg. No. 37,614
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`Jeffrey Huang jeff@etheridgelaw.com
`Back-up Counsel for Patent Owner, Reg. No. 68,639
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`Date of Service: February 1, 2018
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`Law Office of Andrei D. Popovici
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`Telephone: 650-530-9989
`Facsimile: 650-530-9990
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`
`
`/Andrei D. Popovici/
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`
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`Andrei D. Popovici
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`Registration No. 42,401
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`/Mihai H. Murgulescu/
`Mihai H. Murgulescu
`Registration No. 72,512
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`B
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