UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`UNIFIED PATENTS INC.
`
`Petitioner
`
`- v. -
`
`FALL LINE PATENTS, LLC
`
`Patent Owner
`———————
`
`IPR2018-00043
`
`U.S. Patent 9,454,748
`
`PETITIONER UNIFIED PATENTS INC.’S
`
`ORAL HEARING DEMONSTRATIVE EXHIBITS
`
`
`
`
`
`
`
`
`
`
`
`
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`UNIFIED PATENTS INC.
`
`Petitioner
`
`- v. -
`
`FALL LINE PATENTS, LLC
`
`Patent Owner
`———————
`
`IPR2018-00043
`
`U.S. Patent 9,454,748
`
`PETITIONER UNIFIED PATENTS INC.’S
`
`ORAL HEARING DEMONSTRATIVE EXHIBITS
`
`
`
`
`
`
`
`
`
`
`
`
`
`Petitioner’s Submission of Oral Argument Demonstratives
`IPR2018-00043 (U.S. Patent No. 9,454,748)
`
`
`
`
`In accordance with the Order – Requests for Oral Argument (Paper 14),
`
`Petitioner Unified Patents Inc. hereby submits its oral hearing demonstrative
`
`exhibits.
`
`
`
`December 11, 2018
`
`
`
`
`
`Respectfully submitted,
`
`/David W. OBrien/
`David W. O’Brien
`Lead Counsel for Petitioner
`Registration No. 40,107
`
`
`
`
`
`
`
`2
`
`
`
`Petitioner’s Submission of Oral Argument Demonstratives
`IPR2018-00043 (U.S. Patent No. 9,454,748)
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Unified Patents Inc.
`
`Petitioner
`
`§
`§
`§
`§
`§
`
`Petition for Inter Partes Review
`
`IPR2018-00043
`U.S. Patent No. 9,454,748
`
`
`
`CERTIFICATE OF SERVICE
`The undersigned certifies, in accordance with 37 C.F.R. § 42.6, that service
`was made on the Patent Owner as detailed below.
`Date of service December 11, 2018
`
`Manner of service Electronic Service by E-Mail
`
`Documents served Petitioner Unified Patents Inc.’s Oral Hearing Demonstrative
`Exhibits
`
`Persons served Terry L. Watt (terry.watt@crowedunlevy.com)
`Matthew J. Antonelli (matt@ahtlawfirm.com)
`Michael E. Ellis (michael@ahtlawfirm.com)
`Larry D. Thompson, Jr. (larry@ahtlawfirm.com)
`
`/Raghav Bajaj/
`Raghav Bajaj
`Counsel for Petitioner
`Registration No. 66,630
`
`
`
`
`
`
`
`3
`
`
`
`
`
`
`
`
`PetitionerPetitioner
`
`Unified Patents Inc.Unified Patents Inc.
`
`
`U.S. Patent No. 9,454,748U.S. Patent No. 9,454,748
`
`IPR2018-00043 (claims 16-19 and 21-22)IPR2018-00043 (claims 16-19 and 21-22)
`
`David O’Brien
`Raghav Bajaj
`Haynes and Boone, LLP
`December 14, 2018
`
`1
`
`
`
`
`
`’748 Patent’748 Patent
`
`’748 Patent (EX1001) at claim 19.
`2
`
`
`
`
`
`’748 Patent’748 Patent
`
`’748 Patent (EX1001) at Figure 1.
`3
`
`
`
`
`
`Kari (US Patent 6,154,745)Kari (US Patent 6,154,745)
`
`Kari (EX1006) at FIGs. 2, 7; Petition at 18, 24.
`4
`
`
`
`
`
`Darnell (HTML4 Unleashed)Darnell (HTML4 Unleashed)
`
`Darnell (EX1007) at Cover, xxxvii, 232; Petition at 15, 22, 25.
`5
`
`
`
`
`
`Chan (US Patent 6,381,603)Chan (US Patent 6,381,603)
`
`Chan (EX1010) at 5:21‐27,
`Fig. 3; Petition at 15.
`6
`
`
`
`
`
`Todd (US Patent 6,380,928)Todd (US Patent 6,380,928)
`
`Todd (EX1009) at Abstract, Fig. 4; Petition at 16.
`7
`
`
`
`
`
`Instituted Ground of UnpatentabilityInstituted Ground of Unpatentability
`
`Decision on Institution (Paper 6) at pp. 10, 47.
`8
`
`
`
`
`
`SummarySummary
`
`– The combined teachings render every challenged claim
`1
`obvious.
`– Kari and Darnell are properly combined.
`2
`– Kari teaches reading location/GPS information.
`3
`– The claims encompass “device dependent software.”
`4
`– No claim requires a “loosely networked” environment.
`5
`
`9
`
`
`
`
`
`The Combined Teachings Render Every Challenged Claim Obvious The Combined Teachings Render Every Challenged Claim Obvious
`
`’748 Patent (EX1001) at claim 19.
`10
`
`
`
`
`
`The Combination Renders All Challenged Claims Obvious The Combination Renders All Challenged Claims Obvious
`
`Kari
`
`Chan
`Petition at 16‐20; Reddy Decl. (EX1005) at ¶¶ 81‐90.
`11
`
`
`
`
`
`The Combination Renders All Challenged Claims Obvious The Combination Renders All Challenged Claims Obvious
`
`Kari
`
`Darnell
`Petition at 21‐27; Reddy Decl. (EX1005) at ¶¶ 91‐109.
`12
`
`
`
`
`
`The Combination Renders All Challenged Claims Obvious The Combination Renders All Challenged Claims Obvious
`
`Kari
`
`Todd
`
`Petition at 29‐33; Reddy Decl. (EX1005) at ¶¶ 122‐133.
`13
`
`
`
`
`
`The Combination Renders All Challenged Claims Obvious The Combination Renders All Challenged Claims Obvious
`
`’748 Patent (EX1001) at claim 16.
`14
`
`
`
`
`
`The Combination Renders All Challenged Claims Obvious The Combination Renders All Challenged Claims Obvious
`
`’748 Patent (EX1001) at claim 21.
`15
`
`
`
`
`
`SummarySummary
`
`– The combined teachings render every challenged claim
`1
`1
`obvious.
`– Kari and Darnell are properly combined.
`2
`– Kari teaches reading location/GPS information.
`3
`– The claims encompass “device dependent software.”
`4
`– No claim requires a “loosely networked” environment.
`5
`
`16
`
`
`
`
`
`Kari and Darnell are Properly CombinedKari and Darnell are Properly Combined
`
`A POSITA would have understood that an Internet-type WWW [world wide web] page
`displayed in a WWW browser would have been written in HTML, because HTML was the
`standard language for the Internet and world wide web pages at the time of the ’748 Patent.
`Reddy Decl. (EX1005) at ¶ 94.
`
`Kari (EX1006) at 6:47‐49, 64‐66.
`
`Darnell (EX1007) at xxxvii.
`
`Kari (EX1006) at Fig. 7.
`
`Petition at 21.
`17
`
`
`
`
`
`Kari and Darnell are Properly CombinedKari and Darnell are Properly Combined
`
`Kari (EX1006) at 3:11‐17.
`
`Darnell (EX1007) at 23.
`
`RFC1866 (EX1024).
`
`HTML 4.0 Note (EX1023).
`
`Reply at 3‐6.
`18
`
`
`
`
`
`SummarySummary
`
`– The combined teachings render every challenged claim
`1
`obvious.
`– Kari and Darnell are properly combined.
`2
`– Kari teaches reading location/GPS information.
`3
`– The claims encompass “device dependent software.”
`4
`– No claim requires a “loosely networked” environment.
`5
`
`19
`
`
`
`
`
`Kari Teaches Reading Location/GPS InformationKari Teaches Reading Location/GPS Information
`
`Kari (EX1006) at 7:60‐64.
`
`Kari (EX1006) at 3:37‐38.
`
`Reddy Decl. (EX1005) at ¶¶ 136‐137.
`
`Reply at 6‐7.
`20
`
`
`
`
`
`SummarySummary
`
`– The combined teachings render every challenged claim
`1
`obvious.
`– Kari and Darnell are properly combined.
`2
`– Kari teaches reading location/GPS information.
`3
`– The claims encompass “device dependent software.”
`4
`– No claim requires a “loosely networked” environment.
`5
`
`21
`
`
`
`
`
`The claims encompass “device dependent software.”The claims encompass “device dependent software.”
`
`A handheld device executing a web browser, like the one executed by Kari’s search terminal,
`would receive an HTML document, like an HTML form comprised of device independent
`tokens, as taught by Darnell. Each question of that HTML document would include one or
`more device independent HTML tags. In response to the receipt of that HTML document, the
`handheld device’s web browser may undertake actions that are device-dependent or device-
`specific to cause those device independent tags to be displayed and acted upon…. But while
`that web browser may have used device specific coding or software, the HTML documents
`received by that web browser would still have been comprised of device independent tokens.
`
`Reddy Reply Declaration (EX1021) at ¶¶ 22‐23, ‘748 Patent (EX1001) at claim 19, Reply at 9‐14.
`22
`
`
`
`
`
`SummarySummary
`
`– The combined teachings render every challenged claim
`1
`obvious.
`– Kari and Darnell are properly combined.
`2
`– Kari teaches reading location/GPS information.
`3
`– The claims encompass “device dependent software.”
`4
`– No claim requires a “loosely networked” environment.
`5
`
`23
`
`
`
`
`
`No Claim Requires a “Loosely Networked” EnvironmentNo Claim Requires a “Loosely Networked” Environment
`
`‘748 Patent at claims 19, 16, 21; Reply at 14‐15.
`24
`
`
`
`
`PetitionerPetitioner
`
`Unified Patents Inc.Unified Patents Inc.
`
`
`U.S. Patent No. 9,454,748U.S. Patent No. 9,454,748
`
`IPR2018-00043 (claims 16-19 and 21-22)IPR2018-00043 (claims 16-19 and 21-22)
`
`David O’Brien
`Raghav Bajaj
`Haynes and Boone, LLP
`December 14, 2018
`
`25
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
