throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`BITDEFENDER INC.
`Petitioner
`v.
`UNILOC USA, INC.
`Patent Owner
`____________
`Case IPR2017-01315
`Patent 6,510,466
`
`Oral Hearing
`August, 7, 2018
`
`USPTO Texas Regional Office, Dallas, TX
`Petitioner Bitdefender Inc. Demonstrative Exhibits
`
`1
`
`BitDefender Inc.
`Ex. 1025
`BitDefender Inc. v. Uniloc USA, Inc.
`IPR2017-01315
`
`
`

`

`Petitioner’s Institution Response Brief (1)
`
`Pet p iii
`
`POR p2
`
`Petitioner Inst. Response Brief p ii
`
`2
`
`BitDefender Inc.
`Ex. 1025
`BitDefender Inc. v. Uniloc USA, Inc.
`IPR2017-01315
`
`
`

`

`Petitioner’s Institution Response Brief (2)
`
`SAS Institute v ComplementSoft,
`Fed. Cir. 2016 p16
`
`Pet p18
`
`InstDec p10
`
`SAS Institute v ComplementSoft,
`Fed. Cir. 2016 p17
`
`BitDefender Inc.
`Ex. 1025
`BitDefender Inc. v. Uniloc USA, Inc.
`IPR2017-01315
`
`
`3
`
`

`

`POR/POPR and the record
`
`POPR p12
`
`Pet p32-33
`
`POR p8
`
`POR p7
`
`POR p16
`
`4
`
`BitDefender Inc.
`Ex. 1025
`BitDefender Inc. v. Uniloc USA, Inc.
`IPR2017-01315
`
`
`

`

`By 1998, online distribution of software, including Java applets, was
`well known.
`
`Pet p8
`
`Ex. 1005 Kasso 5:54-59
`
`Ex. 1010 Raduchel 3:29-33
`
`Ex. 1006 EDTex Opinion p. 14
`
`Ex. 1006 EDTex Opinion p. 15
`
`BitDefender Inc.
`Ex. 1025
`BitDefender Inc. v. Uniloc USA, Inc.
`IPR2017-01315
`
`
`5
`
`

`

`Ground Kasso in view of Raduchel: reasons to combine
`Ex. 1005 Kasso Fig. 2
`
`Pet p32:
`
`Pet p32-35:
`
`6
`
`BitDefender Inc.
`Ex. 1025
`BitDefender Inc. v. Uniloc USA, Inc.
`IPR2017-01315
`
`
`

`

`“means for installing” construction
`
`‘466 Fig. 8:
`
`‘466 17:55-67:
`
`Petitioner Inst. Response
`Brief p4
`
`‘466 Abstract
`
`InstDec p9
`
`BitDefender Inc.
`Ex. 1025
`BitDefender Inc. v. Uniloc USA, Inc.
`IPR2017-01315
`
`
`7
`
`

`

`If “means for installing” does not come within the In re Katz
`exception, the newly-instituted claims are invalid as indefinite
`
`Petitioner Inst. Response Brief p7:
`
`8
`
`BitDefender Inc.
`Ex. 1025
`BitDefender Inc. v. Uniloc USA, Inc.
`IPR2017-01315
`
`
`

`

`Even under the Board’s construction, Kasso in view of
`Raduchel render obvious systems/CRMs including means for
`installing as claimed
`
`Petitioner Inst. Response Brief p8
`
`Petitioner Inst. Response Brief p9
`
`9
`
`BitDefender Inc.
`Ex. 1025
`BitDefender Inc. v. Uniloc USA, Inc.
`IPR2017-01315
`
`
`

`

`Even under the Board’s construction, Kasso in view of
`Raduchel render obvious systems/CRMs including means for
`installing as claimed (2)
`
`Petitioner Inst. Response Brief p9
`
`Petitioner Inst. Response Brief p9
`
`10
`
`BitDefender Inc.
`Ex. 1025
`BitDefender Inc. v. Uniloc USA, Inc.
`IPR2017-01315
`
`
`

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