LG ELECTRONICS, INC. (Petitioner)
`v.
`KONINKLIJKE KPN N.V. (Patent Owner)
`
`Demonstratives
`Case IPR2018-00558
`U.S. Patent No. 9,014,667
`
`Before Hon. Kevin F. Turner, Joni Y. Chang, and Michelle N.
`Wormmeester, Administrative Patent Judges
`
`1
`
`LG 1021
`LG v. KPN
`IPR2018-00558
`
`
`v.
`KONINKLIJKE KPN N.V. (Patent Owner)
`
`Demonstratives
`Case IPR2018-00558
`U.S. Patent No. 9,014,667
`
`Before Hon. Kevin F. Turner, Joni Y. Chang, and Michelle N.
`Wormmeester, Administrative Patent Judges
`
`1
`
`LG 1021
`LG v. KPN
`IPR2018-00558
`
`
`
`instituted Grounds
`
`Instituted Grounds
`
`2
`
`
`
`Grounds
`
`Grounds Instituted in Inter Partes Review
`
`3
`
`
`
`List of Issues
`
`•
`
`•
`
`Issue 1: KPN’s interpretation of Obhan’s “Good Till” time is incorrect
`
`Issue 2: Obviousness of Claims 31 and 33
`
`– 2.1: Motivation to combine Obhan and Shatzkamer
`
`– 2.2: Obhan’s “Good Till” time is not only associated with a corridor
`
`– 2.3: Obhan’s class is a property of a terminal
`
`– 2.4: Storing the unique identifier of different terminals with respective deny
`access time periods
`
`– 2.5: Denying access for the terminal if the access request is received
`within the time period
`
`•
`
`Issue 3: Obviousness of Claim 35
`
`– 3.1: Motivation to combine Obhan and Taniguchi
`
`– 3.2: Message comprising information relating to a deny access time
`interval
`
`– 3.3: Transmitting an access request to the telecommunications network in
`accordance with the deny access time interval
`
`4
`
`
`
`Issue 1: KPN’s interpretation of Obhan’s “Good Till”
`time is incorrect
`
`Patent Owner Response at 26-27
`
`5
`
`
`
`1) Issue 1: KPN’s interpretation of Obhan’s “Good Till”
`time is incorrect
`
`Obhan’s Disclosure of the “Good Till” Time
`
`Obhan, FIG. 9B (annotated) (Petition at 30)
`
`Obhan, 16:14-21 (Petition at 26)
`
`6
`
`
`
`1) Issue 1: KPN’s interpretation of Obhan’s “Good Till”
`time is incorrect
`
`Obhan’s ACB Updates Without Using the “Good Till” Time
`
`Obhan, 18:1-11 (Petitioner’s Reply at 4)
`
`Obhan, 21:31-43 (Petitioner’s Reply at 4)
`
`“Obhan discusses at length how the ACB is updated. . . . Yet none of these
`sections refer to the update time period as the “good till” time in the ACB.”
`
`Petitioner’s Reply at 4
`
`7
`
`
`
`1) Issue 1: KPN’s interpretation of Obhan’s “Good Till”
`time is incorrect
`
`Obhan’s ACB Updates Without Using the “Good Till” Time
`
`Obhan, 8:2-7 (Petitioner’s Reply at 7)
`
`“Obhan’s update period is linked to
`the Operational Measurement (OM)
`collection period, which is typically
`“a 15-minute period.” Ex. 1005,
`13:25-14:12. At the end of every
`OM collection period, the system
`responsible for updating ACB (i.e.,
`the SYM system) accesses the OM
`units to “obtain the information for
`periodic updates.”
`
`Petitioner’s Reply at 7
`
`Obhan, 13:65-14:12
`(Petitioner’s Reply at 7)
`
`8
`
`
`
`1) Issue 1: KPN’s interpretation of Obhan’s “Good Till”
`time is incorrect
`
`Obhan’s ACB is Updated by a Server Separate from the ACB
`
`Obhan, FIG. 2 (annotated) (Petitioner’s Reply at 8)
`
`Obhan, 9:2-9 (Petitioner’s Reply at 7-8)
`
`9
`
`
`
`1) Issue 1: KPN’s interpretation of Obhan’s “Good Till”
`time is incorrect
`
`KPN’s Expert Could Not Credibly Explain Aspects of Obhan’s Disclosure
`Misaligned with KPN’s Theory
`
`Obhan, FIG. 9A (annotated) (Petitioner's Reply at 6)
`
`Bates’ Deposition,
`38:21-25
`(Petitioner’s Reply
`at 6)
`
`Bates’ Deposition,
`47:25-48:13
`(Petitioner’s Reply
`at 6)
`
`10
`
`
`
`1) Issue 1: KPN’s interpretation of Obhan’s “Good Till”
`time is incorrect
`
`LGE’s Expert Did Not Agree to KPN’s “Good Till” Time Theory
`
`Bishop’s Deposition, 23:15-22 (Petitioner’s Reply at 5)
`
`Bishop’s Deposition, 34:15-21 (Petitioner’s Reply at 8)
`
`Bishop’s Declaration at 81 (Petition at 27)
`
`Bishop’s Declaration at 104 (Petition at 39)
`
`11
`
`
`
`Issue 2: Obviousness of Claims 31 and 33
`
`12
`
`
`
`2) Issue 2: Obviousness of Claims 31 and 33
`
`•
`
`•
`
`•
`
`•
`
`•
`
`Issue 2.1: Motivation to combine Obhan and Shatzkamer
`
`Issue 2.2: Obhan’s “Good Till” time is not only associated with a
`Corridor
`
`Issue 2.3: Obhan’s class is a property of a terminal
`
`Issue 2.4: Storing the unique identifier of different terminals with
`respective deny access time periods
`
`Issue 2.5: Denying access for the terminal if the access request
`is received within the time period
`
`13
`
`
`
`2) Issue 2.1: Motivation to combine Obhan and
`Shatzkamer
`
`Bishop’s Declaration at 45 (Petition at 12)
`
`Shatzkamer at [0025] (Petition at 12)
`
`Bishop’s Declaration at 47 (Petition at 13)
`
`Nylander at 33 (Petition at 14)
`
`14
`
`
`
`2) Issue 2: Obviousness of Claims 31 and 33
`
`•
`
`•
`
`•
`
`•
`
`•
`
`Issue 2.1: Motivation to combine Obhan and Shatzkamer
`
`Issue 2.2: Obhan’s “Good Till” time is not only associated with a
`Corridor
`
`Issue 2.3: Obhan’s class is a property of a terminal
`
`Issue 2.4: Storing the unique identifier of different terminals with
`respective deny access time periods
`
`Issue 2.5: Denying access for the terminal if the access request
`is received within the time period
`
`15
`
`
`
`2) Issue 2.2: Obhan’s “Good Till” Time is Not Only
`Associated with a Corridor
`
`Obhan, FIG. 9B (annotated) (Petition at 30)
`
`Obhan, 16:14-21 (Petition at 26)
`
`16
`
`
`
`2) Issue 2: Obviousness of Claims 31 and 33
`
`•
`
`•
`
`•
`
`•
`
`•
`
`Issue 2.1: Motivation to combine Obhan and Shatzkamer
`
`Issue 2.2: Obhan’s “Good Till” time is not only associated with a
`Corridor
`
`Issue 2.3: Obhan’s class is a property of a terminal
`
`Issue 2.4: Storing the unique identifier of different terminals with
`respective deny access time periods
`
`Issue 2.5: Denying access for the terminal if the access request
`is received within the time period
`
`17
`
`
`
`2) Issue 2.3: Obhan’s class is a property of a terminal
`
`Patent Owner Response at 33
`
`Obhan, 5:55-65 (Petitioner’s Reply at 13)
`
`Obhan, 3:10-21 (Petitioner’s Reply at 13)
`
`Obhan, 14:13-27 (Petitioner’s Reply at 13)
`
`18
`
`
`
`2) Issue 2: Obviousness of Claims 31 and 33
`
`•
`
`•
`
`•
`
`•
`
`•
`
`Issue 2.1: Motivation to combine Obhan and Shatzkamer
`
`Issue 2.2: Obhan’s “Good Till” time is not only associated with a
`Corridor
`
`Issue 2.3: Obhan’s class is a property of a terminal
`
`Issue 2.4: Storing the unique identifier of different terminals with
`respective deny access time periods
`
`Issue 2.5: Denying access for the terminal if the access request
`is received within the time period
`
`19
`
`
`
`2) Issue 2.4: Storing the unique identifier of different
`terminals with respective deny access time periods
`
`Patent Owner Response at 38
`
`Shatzkamer, [0035] (Petition at 32)
`
`Shatzkamer, [0012] (Petition at 32)
`
`20
`
`
`
`2) Issue 2: Obviousness of Claims 31 and 33
`
`•
`
`•
`
`•
`
`•
`
`•
`
`Issue 2.1: Motivation to combine Obhan and Shatzkamer
`
`Issue 2.2: Obhan’s “Good Till” time is not only associated with a
`Corridor
`
`Issue 2.3: Obhan’s class is a property of a terminal
`
`Issue 2.4: Storing the unique identifier of different terminals with
`respective deny access time periods
`
`Issue 2.5: Denying access for the terminal if the access request
`is received within the time period
`
`21
`
`
`
`2) Issue 2.5: Denying access for the terminal if the access
`request is received within the time period
`
`Patent Owner Response at 44
`
`Patent Owner Response at 45
`
`Obhan, 19:44-46 (Petitioner’s Reply at 18)
`
`Bishop’s Deposition, 36:4-8
`
`Obhan, 18:33-37 (Petitioner’s Reply at 18)
`
`Bishop’s Deposition, 46:22-47:4
`
`22
`
`
`
`Issue 3: Obviousness of Claim 35
`
`23
`
`
`
`3) Issue 3: Obviousness of Features of Claim 35
`
`•
`
`•
`
`•
`
`Issue 3.1: Motivation to combine Obhan and Taniguchi
`
`Issue 3.2: Message comprising information relating to a deny
`access time interval
`
`Issue 3.3: Transmitting an access request to the
`telecommunications network in accordance with the deny
`access time interval
`
`24
`
`
`
`3) Issue 3.1: Motivation to combine Obhan and Taniguchi
`
`Obhan, 18:21-23 (Petition at 16)
`
`Taniguchi, 3:41-51 (Petition at 17)
`
`Obhan, 18:47-61 (Petition at 16)
`
`25
`
`
`
`3) Issue 3.1: Motivation to combine Obhan and Taniguchi
`
`Bishop’s Declaration at 51 (Petition at 16)
`
`Bishop’s Declaration at 52 (Petition at 17)
`
`26
`
`
`
`3) Issue 3: Obviousness of Features of Claim 35
`
`•
`
`•
`
`•
`
`Issue 3.1: Motivation to combine Obhan and Taniguchi
`
`Issue 3.2: Message comprising information relating to a deny
`access time interval
`
`Issue 3.3: Transmitting an access request to the
`telecommunications network in accordance with the deny
`access time interval
`
`27
`
`
`
`3) Issue 3.2: Message comprising information relating to a
`deny access time interval
`
`Obhan, 18:21-23 (Petition at 54)
`
`Taniguchi, 3:41-51 (Petition at 56)
`
`Taniguchi, 5:45-46 (Petition at 56)
`
`Obhan, 18:47-61 (Petition at 54)
`
`28
`
`
`
`3) Issue 3: Obviousness of Features of Claim 35
`
`•
`
`•
`
`•
`
`Issue 3.1: Motivation to combine Obhan and Taniguchi
`
`Issue 3.2: Message comprising information relating to a deny
`access time interval
`
`Issue 3.3: Transmitting an access request to the
`telecommunications network in accordance with the deny
`access time interval
`
`29
`
`
`
`3) Issue 3.3: Transmitting an access request to the telecommunications
`network in accordance with the deny access time interval
`
`Bishop’s Declaration at 154 (Petition at 63)
`
`Petition at 62-63
`
`Larson, [0062] (Petition at 62)
`
`Budka, [0062] (Petition at 62-63)
`
`30
`
`
`
`3) Issue 3.3: Transmitting an access request to the telecommunications
`network in accordance with the deny access time interval
`
`Obhan, 18:21-23 (Petition at 54)
`
`Obhan, 18:47-61 (Petition at 64)
`
`Bishop’s Declaration at 158 (Petition at 64)
`
`31
`
`
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