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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`
`VILOX TECHNOLOGIES, LLC.
`Patent Owner
`
`Case IPR2018-00044
`
`Patent No. 7,302,423
`
`Patent Owner’s Reply to Petitioner’s Opposition to Patent
`Owner’s Motion to Amend
`
`
`
`
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`Case IPR2018-00044
`Patent No. 7,302,423
`Reply to Pet.’s Opp. to Mot. to Amend
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`
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`TABLE OF CONTENTS
`INTRODUCTION .............................................................................................. 1
`
`PROPOSED CLAIMS ....................................................................................... 1
`
`I.
`
`II.
`
`III. THE PROPOSED CLAIMS ARE FULLY SUPPORTED BY THE
`ORIGINALLY-FILED SPECFICATION ......................................................... 2
`
`A. Disclosure Support of Limitations of Proposed Claims .................................... 2
`
`B. Proposed Claims 24 and 25 Are Supported by the Original Disclosure ........... 2
`
`C. Proposed Claims 26 and 27 Are supported by the Original Disclosure ............ 4
`
`1. On a Single Page of a Terminal ..................................................................... 4
`
`2. Determined Dynamically ............................................................................... 5
`
`IV. THE PROPOSED CLAIMS ARE NOVEL AND NON-OBVIOUS IN VIEW
`OF THE REFERENCES CITED IN THE PETITION ...................................... 6
`
`V. GOLDBERG IS NOT PRIOR ART ................................................................... 7
`
`VI. THE ADDITION OF GOLDBERG, EVEN WERE IT PRIOR ART, DOES
`NOT AFFECT VALIDITY OF THE PROPOSED CLAIMS ........................... 8
`
`VII. THERE CAN BE NO MOTIVATION TO COMBINE GOLDBERG WITH
`THE REFERENCES OF RECORD ................................................................. 10
`
`VIII. CONCLUSION ................................................................................................ 12
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`APPENDIX .................................................................................................................... I
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`CERTIFICATE OF SERVICE .......................................................................................
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`TABLE OF AUTHORITIES
`
`
`
`Cases
`
`In re Gurley,
`
`27 F.3d 551 (Fed. Cir. 1994) ............................................................................ 11
`
`W.L. Gore & Assocs., Inc. v. Garlock, Inc.,
`
`721 F.2d 1540 (Fed. Cir. 1983) ........................................................................ 11
`
`Western Digital Corp. v. SPEX Technologies, Inc.,
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`Case IPR2018-00082 .......................................................................................... 2
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`ii
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`LIST OF EXHIBITS
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`
`
`2001
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`Declaration of Wesley W. Chu, Ph.D. (Patent Owner Preliminary
`
`Response)
`
`2002
`
`2003
`
`2004
`
`2005
`
`2006
`
`2007
`
`2008
`
`2009
`
`2010
`
`Curriculum Vitae of Wesley W. Chu, Ph.D.
`
`Declaration of Dr. Joseph L. De Bellis (Patent Owner
`
`Preliminary Response)
`
`Excel II
`
`U.S. Patent No. 6,593,949 to Chee H. Chew (Chew)
`
`Excerpt from Webster’s Dictionary
`
`Declaration of Cecil E. Key
`
`Patent Owner's Notice of Deposition of Dr., Hsieh-Yee
`
`Curriculum Vitae of Dr. Ingrid Hsieh-Yee
`
`Library of Congress Online Catalog Listing for Microsoft Excel
`
`2000 Bible, Full Record
`
`2011
`
`Library of Congress Online Catalog Listing for Microsoft Excel
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`2000 Bible, MARC Tags
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`2012
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`
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`Wayne State University Library System Listing for Microsoft
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`iii
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`Excel 2000 Bible
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`Deposition Transcript of Dr. Ingrid Hsieh-Yee
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`Excel III (excerpt of Excel 2000 Bible)
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`Deposition Transcript of Philip Greenspun, Ph.D.
`
`U.S. Patent No. 6,760,720 to De Bellis
`
`Declaration of Wesley W. Chu, Ph.D. (Patent Owner Response)
`
`The IEEE Standard Dictionary of Electrical and Electronics
`
`Terms (6th ed.)(excerpt) (Patent Owner Response)
`
`Webster’s New Collegiate Dictionary (excerpt)
`
`Microsoft Press Computer Dictionary (3rd ed.) (excerpt)
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`Declaration of Dr. Joseph L. De Bellis (Patent Owner Response)
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`Declaration of Lucille Marie De Bellis (Patent Owner Response)
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`Warehouse.com Receipt (Dec. 10, 1999)
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`Tallgrass Technologies Receipt (Dec. 15, 1999)
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`Fig. 10 from U.S. Patent No. 6,760,720
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`Letter from Dr. Joseph L. De Bellis to John Harrop (Dec. 28,
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`1999)
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`Declaration of Wesley W. Chu, Ph.D.
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`
`iv
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`2013
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`2014
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`2015
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`2016
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`2017
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`2018
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`2019
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`2020
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`2021
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`2022
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`2023
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`2024
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`2025
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`2026
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`2027
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`2028
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`The IEEE Standard Dictionary of Electrical and Electronics
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`Terms (6th ed.)(excerpt)
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`2029
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`Declaration of Lucille Marie De Bellis
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`
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`v
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`I.
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`INTRODUCTION
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`Petitioner’s Opposition to Patent Owner’s Motion to Amend (Paper 42)
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`(“Opposition”) alleges the proposed claims are invalid in view of the references
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`already of record yet seeks to apply a new reference in an effort to invalidate the
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`proposed claims 26 and 27. The references cited in the Petition do not render the
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`proposed claims invalid. Newly added reference Goldberg (Ex. 1014) is not prior
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`art. Even were Goldberg’s teaching combined with the references cited in the
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`Petition, proposed claims 26 and 27 still would be valid. The Opposition also alleges
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`proposed claims 24 and 25 are not supported in the original application. In fact, each
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`limitation of the proposed claims provided in Patent Owner’s Motion to Amend
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`(“Motion”) is fully supported in the specification as originally filed.
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`II.
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`PROPOSED CLAIMS
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`Patent Owner filed a Motion to Amend the Claims to provide proposed
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`claims 24 and 25 solely in response to the Board’s initial, sua sponte conclusion
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`that challenged claims 1 and 3 incorporate conditional or optional claim
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`limitations. Proposed claims 26 and 27 recite narrowing limitations that are fully
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`supported in the original specification.
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`1
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`III. THE PROPOSED CLAIMS ARE FULLY SUPPORTED BY THE
`ORIGINALLY-FILED SPECFICATION
`A. Disclosure Support of Limitations of Proposed Claims
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`Petitioner alleges Patent Owner’s Motion to Amend is defective because it
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`cites to the specification of the issued patent rather than the specification of the
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`original application. To support this proposition, Petitioner cites to informative
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`Paper 13 in Western Digital Corp. v. SPEX Technologies, Inc., Case IPR2018-00082.
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`Paper 42 at 2.
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`The Appendix to this Reply compares cites from the ‘423 Patent in the Motion
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`to Amend with cites to corresponding patent application 09/935,565 (‘565 App).
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`B. Proposed Claims 24 and 25 Are Supported by the Original Disclosure
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`Proposed claims 24 and 25 are directed to truncating entries in search results,
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`with the final, truncated list or display of entries including a portion of each truncated
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`entry. The claims recite truncation limitations based on determining a number of
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`characters in each entry and then truncating the entry.
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`The Opposition alleges that the cited portions of the ‘423 Patent “do not
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`provide the requisite written description support for the amended limitation” of
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`“displaying a truncated portion of each entry in the selected database field.” Id. at 2-
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`3. The Opposition then lists a section of the cited disclosure that shows truncation of
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`six city names to three entries. Id. at 3. The Opposition concludes that truncating the
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`2
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`six city names should produce six truncated entries, and that, accordingly, the
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`“disclosure,” by showing only three entries, namely “Arm, New, Riv,” fails to
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`support the claim limitations. Id. at 3-4. But the Opposition acknowledges that the
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`disclosure shows “truncation of entries to collapse the number of entries into a
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`smaller or lower number, such that the smaller or lower number of entries can be
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`displayed on a terminal screen” and that “the purpose of ‘truncation’ in the ‘423
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`Patent is to reduce a number of lines in a result list so as to collapse the list vertically
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`by reducing the number of characters in returned entries to common characters.” Id.
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`at 4-5.
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`Patent Owner agrees with Petitioner on this point. The claimed truncation
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`reduces characters and will result in collapsing the result list vertically so that the
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`result list may be displayed on the terminal. Thus, the cities Armandia and Armonk,
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`in the disclosed example, become “Arm,” thereby reducing the number of lines by
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`one. However, “a truncated portion [in the example, “Arm”] of each entry in the
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`selected database field is displayed,” as recited in proposed claims 24 and 25.
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`Nowhere do claims 24 and 25 recite that each entry, once truncated, must be
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`displayed, as the Petitioner apparently assumes. The claim limitation of “a truncated
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`portion of each entry in the selected database field is displayed” is clearly supported
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`in the disclosure cited in the Opposition.
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`Furthermore, a PHOSITA, viewing the disclosure and each of proposed claims
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`24 and 25, would understand that truncation of Armandia and Armonk to three
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`characters and displaying “Arm” on the terminal meets the limitation of “a truncated
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`portion of each entry in the selected database field is displayed.” See Declaration of
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`Dr. Wesley W. Chu (Ex. 2027), ¶¶ 9-10.
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`C. Proposed Claims 26 and 27 Are supported by the Original Disclosure
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`Proposed claims 26 and 27 are amended from corresponding claim 6 to recite
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`the limitation “all entries from the selected data filed are displayed on a single page
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`of a terminal.” Claims 26 and 27 also recite “the specified limit is determined
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`dynamically, based on a characteristic of the terminal”; however, this limitation was
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`in original claim 6.
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`1. On a Single Page of a Terminal
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`The Opposition refers to Petitioner’s arguments related to the alleged lack of
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`disclosure support for proposed claims 24 and 25. Just as that argument fails with
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`respect to claim 24 and 25, it fails with respect to claims 26 and 27.
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`More specifically, the operation of claim 25 generates a result list having
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`truncated entries. The example cited in the Opposition is a result list having three
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`entries “Arm, New, Riv.” Claims 26 and 27 merely recite that the entries are
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`displayed on a single page of a terminal. This limitation is supported in the original
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`disclosure at least at page 11, lines 20-24.
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`
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`2. Determined Dynamically
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`The Opposition asserts that “[t]he identified portion of the ‘423 Patent, column
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`8 line 40 to 52, does not provide written description support for determining a limit
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`dynamically’.” Paper 42 at 7-8.
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`The cited disclosure states “if the size of the resulting result list is larger than
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`some numeric parameter related to the display size of the terminal 14, then the
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`constraints may be modified by the truncator 152 so that the result list can be
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`accommodated (e.g., displayed on one page) by the terminal 14.” Ex. 1001, 8:44-
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`48.
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`A PHOSITA would understand that “dynamically determined,” as recited in
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`proposed claims 26 and 27, in the context of computer operations, refers to “an
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`event or process that occurs during computer program execution.” The PHOSITA
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`would understand the above quoted excerpt from the ‘423 Patent refers to a process
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`(truncation) that occurs during execution of truncator 152, which, a PHOSITA
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`would know, is a computer program. See Ex. 2027, ¶ 12. See also, Ex. 2028, p. 2
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`(defining “dynamically”).
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`IV. THE PROPOSED CLAIMS ARE NOVEL AND NON-OBVIOUS IN
`VIEW OF THE REFERENCES CITED IN THE PETITION
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`The Opposition asserts that proposed claims 24 – 27 are obvious over
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`Maloney in view of Bertram and also are obvious over Excel in view of Bertram.
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`The Opposition repeats the same bases for alleging obviousness of claims 24 – 27
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`as was alleged for claims 1, 3, and 6 in the Petition.
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`
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`For example, the Opposition, referring to the Petition, states “Bertram (in
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`combination with Maloney) was cited as teaching ‘determining a number of
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`characters included in each entry in the selected data field’.” Paper 42 at 9-10.
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`(emphasis added). The Opposition makes similar allegations regarding application
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`of Bertram and Maloney to proposed claim 25.
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`
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`However, as Patent Owner noted in its Response, Petitioner’s own expert
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`admitted that Bertram does not disclose “determining a number of characters.”
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`Paper 26 at 19 - 21, citing Ex. 2015 (“Q. Well, Dr. Greenspun, I'm asking you …
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`Is there any disclosure in Bertram that states ‘determining a number of characters’?
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`A. I don’t think that Bertram uses the phrase, ‘determining a number of characters,’
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`no.”)
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`In a section header, the Opposition purports to show how the combination of
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`Excel and Bertram would render proposed claim 25 obvious. Paper 42 at 9.
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`However, the Opposition provides no explanation for the alleged obviousness of
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`proposed claim 25 other than to state “proposed claims 24 and 25 are therefore
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`obvious over the same art as presented in the Petition.” Id.
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`V. GOLDBERG IS NOT PRIOR ART
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`The Opposition, in footnote 2, anticipating a challenge to Goldberg’s prior
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`art status, states that “none of that evidence” (presumably the evidence provided in
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`Patent Owner’s Response at pages 35 – 45 (citing Exs. 2013, 2021, and 2022)
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`relates to the newly recited limitations of proposed claims 26 and 27.
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`
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`To the contrary, Missy De Bellis testified that she personally viewed the
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`working prototype of the Search-on-the-Fly Search Engine on December 9, 1999.
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`Ms. De Bellis further testified that she saw, during that demonstration, what
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`became Figure 10 of the ‘423 Patent (the same Figure 10 was originally filed with
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`the ‘720 Patent). Ex. 2022, ¶22 (referring to Ex. 2025). The same Declaration
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`states that the example from which Figure 10 was constructed was based on a
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`telephone database constructed by Mr. Freire. Dr. De Bellis’ software engineer.
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`Figure 10 clearly shows displaying result lists whose entries are displayed on a
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`single page. For example, result list 209 shows five state names truncated to two
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`digits. Result list 209 further shows New York (“NY”) was chosen for further
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`searching; the further searching produced a list 211 of three cities in New York.
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`The entire display of Figure 10, including lists 209 and 211 can be seen to occupy
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`a single page.
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`In further support of the conception of this “single page of a terminal”
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`feature, see Ex. 2029, ¶¶ 5 – 7 (stating Dr. De Bellis conceived of displaying
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`results on a single page by May 1999, and then worked to reduce this inventive
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`concept to practice by at least December 9, 1999).
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`VI. THE ADDITION OF GOLDBERG, EVEN WERE IT PRIOR ART,
`DOES NOT AFFECT VALIDITY OF THE PROPOSED CLAIMS
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`The Opposition cites Goldberg as allegedly teaching adjusting the size of
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`information being displayed in order to make the information easily readable,
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`where the “adjustment is based on the size of a display area available.” Paper 42 at
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`15. The Opposition notes that Goldberg discloses fitting other applications such as
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`spreadsheet applications to small screens. Id. However, because Goldberg does
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`not describe such a process as displaying a spreadsheet on a small screen, the
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`Opposition provides no citation to Goldberg that would lead a PHOSITA to
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`understand how such a process could occur.
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`
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`As a PHOSITA would understand, Goldberg clearly describes competing
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`interests, namely making an entry fit on to a small-size display while at the same
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`time, making the entry easily readable so as not to distract a vehicle operator
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`(driver). If the information to be displayed were of too small a size to be easily
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`readable, a driver could be distracted from safe operation of the car. Ex. 1014,
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`1:30 - 35.
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`
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`Goldberg does not disclose how a spreadsheet can be displayed on one page
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`of a small screen and still be “easily readable,” and Petitioner can point to no
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`disclosure in Goldberg that would lead a PHOSITA to conclude that such a
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`spreadsheet, were it to be displayed at all, would not be displayed on multiple
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`pages. Ex. 2027, ¶¶ 15 - 22. Rather, a PHOSITA would understand that Goldberg
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`is directed to adjusting the size of information contained in a single entry, such as a
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`street address where the driver “is supposed to be going to.” Ex. 1014, 1:63; Figs.
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`5a – 5g. Even were Goldberg to be read to apply to a “plurality of entries” (which
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`no PHOSITA would understand from studying Goldberg), a PHOSITA would
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`understand that because Goldberg’s system is directed to making data “readable”
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`to a vehicle operator (driver), Goldberg simply would display each of the entries
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`(adjusted in size or not adjusted) on a separate screen or page so that the driver
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`could readily read (and grasp) the data using only brief glances at the computer
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`screen to avoid distraction from safe operation of the vehicle. See Ex. 1014, 1:30 -
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`35.
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`In summary, a PHOSITA would not understand that Goldberg provides a
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`teaching or suggestion to display “each of a plurality of entries on a single page of
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`the terminal” and certainly provides no teaching or suggestion for displaying a
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`spreadsheet.
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`VII. THERE CAN BE NO MOTIVATION TO COMBINE GOLDBERG
`WITH THE REFERENCES OF RECORD
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`In addition to not teaching or even suggesting the claim limitations of
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`proposed claims 26 and 27, a PHOSITA would not be motivated to combine
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`Goldberg with Maloney, Bertram, and Kanevsky or to combine Goldberg with
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`Excel, Bertram, and Kanevsky. This lack of motivation is based on Goldberg’s
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`express teaching away from the limitations of proposed claims 26 and 27.
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`Specifically, Goldberg explicitly states that “adding lines” to a text entry is
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`an important option to make an entry readable for a vehicle operator so as to avoid
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`distracting the driver, who can only briefly view the display. Ex. 1014, 1:46-52.
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`As Petitioner acknowledges, the challenged claims in this IPR, and by extension,
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`the proposed claims, are directed to compressing the vertical space required for
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`display of multiple entries. Paper 42 at 4-5. Adding lines as taught by Goldberg is
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`the polar opposite of reducing the number of lines to be displayed, which, as noted
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`above, Petitioner explicitly acknowledges happens with the inventions of proposed
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`claims 24 and 25. Accordingly, a PHOSITA would not be motivated to
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`incorporate Goldberg’s teachings of adding lines to improve readability because to
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`do so would have an effect that is unwanted and diametrically opposite to the
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`intended reduction of vertical lines the claims encompass in order to make the
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`entries fit the available display space. Ex. 2027, ¶ 13.
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`
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`Petitioner argues that it is citing Goldberg for its alleged teaching of fitting
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`an entry to a small display, one option for which is to truncate a “caption,” which
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`as Goldberg discloses, does not affect the informative value of the entry to be
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`“adjusted.” However, this argument is another example of Petitioner citing only so
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`much of a reference as Petitioner finds helpful while ignoring portions of the
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`reference that are harmful and that therefore, “teach away,” and must be rejected.
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`See, e.g., W.L. Gore & Assocs. Inc. v. Garlock, Inc. , 721 F.2d 1540, 1550 (Fed.
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`Cir. 1983) (holding the district court erred by “considering the references in less
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`than their entireties, i.e., in disregarding disclosures in the references that diverge
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`from and teach away from the invention at hand”). See also, In re Gurley, 27 F.3d
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`551, 553 (Fed. Cir. 1994) (stating that in general, “a reference will teach away if it
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`suggests that the line of development flowing from the reference's disclosure is
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`unlikely to be productive of the result sought by the applicant.”) Here, “the line of
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`development,” that is, adding lines to a text entry to increase its readability, will
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`produce exactly the opposite effect sought by the Patent Owner.
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`VIII. CONCLUSION
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`For the foregoing reasons, Petitioner’s Opposition to the Patent Owner’s
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`Motion to Amend should be rejected.
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`Dated: October 22, 2018
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`Respectfully submitted,
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`By:
`
`
` /John K. Harrop/
`John K. Harrop
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`Counsel for Patent Owner
`Vilox Technologies LLC
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`APPENDIX
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`
`Proposed Claim 24
`[24.P] A
`computer-implemented method
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`‘423 Patent ‘565 App
`5:18-22
`6:28-33
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`for
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`displaying data comprising:
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`[24.1] determining a database schema for a database; 6:32-42
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`8:17-24
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`[24.2] providing a list of database fields, wherein the
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`6:23-25;
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`8:10-12;
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`list includes a descriptor indicating a data category;
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`7:5-14;
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`9:10-17;
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`Fig. 4
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`Fig. 4
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`[24.3] receiving a search selection for a database field
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`7:19-20
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`9:21-22
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`on the provided list of database fields;
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`[24.4] determining a number of characters included in
`each entry in a plurality of entries in the selected
`database field; [and]
`[24.5] [if the number of characters included in each
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`15:52-61;
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`21;19-25
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`Fig. 18
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`Fig. 18
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`8:48-9:2;
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`11:20-34;
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`entry exceeds a specified amount of characters],
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`9:20-24
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`12:12-14
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`truncating each entry having a number of characters
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`determined to be greater than a specified number of
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`characters and displaying a truncated portion of each
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`entry in the selected database field, [wherein] the
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`displayed truncated portion truncated to reduce a
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`number of characters to be[displayed in each portion
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`is] less than or equal to the specified number
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`[amount] of characters; and
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`[24.6] [if the number of characters included in each
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`8:48-9:2;
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`11:20-34;
`
`entry does not exceed
`
`the specified amount,]
`
`9:19-20
`
`12:12-14
`
`displaying each entry having a number of characters
`
`determined to be less than or equal to the specified
`
`number in its entirety.
`
`Proposed Claim 25
`[25.P] A computer-
`
`implemented method
`
`for
`
`‘423 Patent ‘565 App.
`5:18-22
`6:28-33
`
`formatting data for display, comprising:
`
`[25.1] generating a list of data fields;
`
`6:23-25
`
`8:10-12
`
`[25.2] receiving a first data field selection from the
`
`7:19-20
`
`9:21-22
`
`list of data fields;
`
`[25.3] determining a first [quantity indicative of a]
`
`15:52-61
`
`21:19-25;
`
`number of characters in each entry in a plurality of
`
`Fig. 18
`
`Fig. 18
`
`entries of the selected data field;
`
` II
`
`
`
`
`
`[25.4] [if the first quantity exceeds a specified limit,]
`
`8:48-9:2;
`
`Case IPR2018-00044
`Patent No. 7,302,423
`Reply to Pet.’s Opp. to Mot. to Amend
`
`
`11:20-34;
`
`performing an iterative process to reduce [reducing] a
`
`9:19-24
`
`12:11-14
`
`number of characters to be displayed for each entry
`
`from the selected data field that exceeds a specified
`
`limit on the number of characters to be displayed,
`
`comprising:
`
`[25.5] performing a truncation that reduces the
`
`8:48-9:2;
`
`11:20-34;
`
`number of characters to be displayed from the selected
`
`9:19-24
`
`12:11-14
`
`data field,
`
`[25.6] comparing the reduced number of characters
`
`8:48-9:2
`
`11:20-34
`
`to the specified limit, and
`
`[25.7] [if the reduced number of characters exceeds
`
`8:48-9:2
`
`11:20-34
`
`the specified limit,] repeating the truncation and
`
`comparing steps until
`
`the reduced number of
`
`characters to be displayed from the selected data field
`
`is less than or equal to the specified limit[s]; and
`
`[25.8] displaying the reduced number of characters for
`
`8:48-9:2
`
`11:20-34
`
`each entry from the selected data field.
`
`Proposed Claim 26
`
`‘423 Patent ‘565 App.
`
` III
`
`
`
`
`
`[26] The method of claim 3, wherein [each entry] all
`
`8:40-52
`
`Case IPR2018-00044
`Patent No. 7,302,423
`Reply to Pet.’s Opp. to Mot. to Amend
`
`
`11:20-34
`
`entries from the selected data field [is] are displayed
`
`on a single page of a terminal, and wherein the
`
`specified limit is determined dynamically, based on a
`
`characteristic of the terminal.
`
`Proposed Claim 27
`[27] The method of claim [3] 25, wherein [each entry]
`
`‘423 Patent ‘565 App.
`8:40-52
`11:20-34
`
`all entries from the selected data field [is] displayed
`
`on a single page of a terminal, and wherein the
`
`specified limit is determined dynamically, based on a
`
`characteristic of the terminal.
`
`
`
`
`
` IV
`
`
`
`
`
`Case IPR2018-00044
`Patent No. 7,302,423
`Reply to Pet.’s Opp. to Mot. to Amend
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on the date
`
`indicated below, a complete and entire copy of this submission, including the
`
`exhibits hereto, was provided by email to Petitioner’s counsel via email, as
`
`agreed to by Petitioner’s Service Information in the Petition submission, by
`
`serving the email address of record as follows:
`
`Dated: October 22, 2018
`
`Respectfully submitted,
`
`By:
`
` /John K. Harrop/
`John K. Harrop
`
`for Patent Owner
`Counsel
`Vilox Technologies LLC
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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