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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`__________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`__________________________
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`UNIFIED PATENTS INC.,
`Petitioner,
`
`v.
`
`BRADIUM TECHNOLOGIES LLC,
`Patent Owner.
`
`__________________________
`
`Case IPR2018-00952
`Patent No. 9,253,239
`
`__________________________
`
`
`PATENT OWNER BRADIUM TECHNOLOGY’S REPLY TO
`OPPOSITION TO MOTION TO AMEND
`PURSUANT TO 37 C.F.R. § 42.121
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`
`
`
`i
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`Reply to Opposition to Motion to Amend, IPR2018-00952
`U.S. Patent No. 9,253,239
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`
`TABLE OF CONTENTS
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`I.
`
`II.
`
`The Claims of Bradium’s Proposed Amendment Are Not Indefinite ........... 1
`
`The Motion To Amend Is Supported .............................................................. 5
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`A. Amended Claim 20 and New Claim 21 Are Not Broadened .............. 8
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`IV. The Proposed Claims Are Non-Obvious ........................................................ 9
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`V.
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`Conclusion ................................................................................................... 12
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`Reply to Opposition to Motion to Amend, IPR2018-00952
`U.S. Patent No. 9,253,239
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`
`TABLE OF AUTHORITIES
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`Page(s)
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`
`
`Cases
`Advanced Display Sys., Inc. v. Kent State Univ.,
`212 F.3d1272 (Fed Cir. 2000 .................................................................................. 5
`Energizer Holdings, Inc. v. Int'l Trade Comm’n,
`435 F.3d 1366 (Fed. Cir. 2006) .............................................................................. 3
`Graham v. John Deere Co.,
`383 U.S. 1, 36, 86 S. Ct. 684, 16 L. Ed. 2d 545 (1966) ........................................ 12
`In re Arnott,
`19 USPQ2d 1049 (Comm’r Pat. 1991) ................................................................... 4
`In re Packard,
`751 F.3d 1307 (Fed. Cir. 2014) .............................................................................. 1
`Nautilus, Inc. v. Biosig Instruments, Inc.,
`572 U.S. 898 (2014) ....................................................................................... 1, 3, 9
`Sonix Tech. Co., Ltd v. Publications Int’l, Ltd.,
`844 F.3d 1370 (Fed. Cir. 2017) .............................................................................. 4
`Wellman, Inc. v. Eastman Chem. Co.,
`642 F.3d 1355 (Fed. Cir. 2011) .............................................................................. 3
`Statutes
`35 U.S.C. § 112 ......................................................................................................2, 8
`35 U.S.C. § 255 .......................................................................................................... 4
`35 U.S.C. § 316(d) ..................................................................................................... 8
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`Reply to Opposition to Motion to Amend, IPR2018-00952
`U.S. Patent No. 9,253,239
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`
`The Claims of Bradium’s Proposed Amendment Are Not Indefinite
`in a
`The basis of Petitioner’s Opposition appears
`to be rooted
`
`I.
`
`mischaracterization of the law and a gross overstatement of the effect of a minor
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`typographical errors in elements 20M and 20P of amended claim 20.
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`Indefiniteness under the Nautilus standard is found when a claim fails to
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`"inform those skilled in the art about the scope of the invention with reasonable
`
`certainty" and considers factors other than the claim language itself such as the
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`written description and prosecution history. Nautilus, Inc. v. Biosig Instruments,
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`Inc., 572 U.S. 898, 910 (2014). The Packard standard, on the other hand, merely
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`looks to whether the claim “contains words or phrases whose meaning is unclear,”
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`In re Packard, 751 F.3d 1307, 1310 (Fed. Cir. 2014) (per curiam).
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`
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`However, Patent Owner believes it is clear, that, to the extent the Packard
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`standard and the Nautilus standard differ, it is the Nautilus standard that controls
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`because it is Supreme Court precedent that issued later in time after Packard.
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`Tellingly, Petitioner does not even try to apply the Nautilus standard in its analysis
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`but, instead merely relies on a superficial application for the wrong (Packard)
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`standard. Opposition at 6-7. This is because, as explained below, under the correct
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`(Nautilus) standard, the claims at issue are clearly not indefinite.
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`According to amended claim 20, the second request is renamed the third
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`request, with a new second request inserted. Corresponding references of the second
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`U.S. Patent No. 9,253,239
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`request are also incremented, except that the third update data parcel still references
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`the second user-controlled image viewpoint. The new second request is for an
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`altered resolution data parcel that references the first user-controlled image
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`viewpoint. Petitioner called to Patent Owner’s attention that the word “second” was
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`not cancelled and replaced with “third”. The corrected clauses should read:
`
`“displaying the second third discrete portion on the user
`computing device using the second third update data parcel, the
`step of displaying the second third discrete portion being
`performed after the step of receiving the second third update data
`parcel;” and
`“a series of K1-N derivative images of progressively lower
`image resolution comprises the first derivative image and the
`second third derivative image, …”
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`It is noted that the “step of displaying” is a reiteration of the initial
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`“displaying” clause, and therefore the antecedent and subsequent clearly should
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`match. This also follows from the amendment structure which provides for
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`“displaying the first discrete portion … “and “displaying the second discrete
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`portion … “each in a fully parallel recitation. Similarly, it is clear that since the
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`second request was incremented to the third request, the “second derivative image”
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`in the “wherein” clause should also be incremented to the “third derivative image.”
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`In accordance with 35 U.S.C. § 112, a clear error in a claim may be legally
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`Reply to Opposition to Motion to Amend, IPR2018-00952
`U.S. Patent No. 9,253,239
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`interpreted as intended. The Supreme Court, in Nautilus makes clear that a patent is
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`invalid for indefiniteness only if its claims, read in light of the patent’s specification
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`and prosecution history, fail to inform, with reasonable certainty, those skilled in the
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`art about the scope of the invention. In this case, the proper interpretation of the
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`claims is readily apparent, with reasonable certainty, from the claim language,
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`written description and file history of this claim. Therefore, when interpreted in
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`accordance with Nautilus, it has a scope defined in reasonable certainty by its terms.
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`Patent Owner’s expert agrees. EX2059 PP 44-54.
`
`Furthermore, Petitioner’s superficial analysis on pages 2-3 and 6-7 of its
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`Opposition fail to account for the proper interpretation of the claim, and seek to
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`compare the “second request” of the original claim with the “second request” of
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`the amended claim, rather than with the “third request.” But there is no third user-
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`controlled image viewpoint, and the new second request is referenced to the same
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`first user-controlled image viewpoint as the first request.
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`A mere failure to provide antecedent basis does not render a claim
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`indefinite. See Energizer Holdings, Inc. v. Int'l Trade Comm’n, 435 F.3d 1366,
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`1370 (Fed. Cir. 2006). If, "despite the absence of explicit antecedent basis . . . the
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`scope of a claim would be reasonably ascertainable by those skilled in the art, then
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`the claim is not indefinite.” Id. at 1370-71; see also Nautilus, 134 S. Ct. at 2129 and
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`see Wellman, Inc. v. Eastman Chem. Co., 642 F.3d 1355, 1366 (Fed. Cir. 2011). .
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`U.S. Patent No. 9,253,239
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`Moreover, in Sonix Tech. Co., Ltd v. Publications Int’l, Ltd., 844 F.3d 1370,
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`1378 (Fed. Cir. 2017) the Court explained, “Even so, the Supreme Court has
`
`recognized that absolute precision is unattainable,” and “[t]he certainty which the
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`law requires in patents is not greater than is reasonable, having regard to their
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`subject-matter.” As demonstrated above, although amended claim 20 is not perfect,
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`perfection is not required, but rather a reasonable certainty is required, which is
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`satisfied here.
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`This type of minor typographical error is the kind of error that is properly
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`corrected by a certificate of correction pursuant to 35 U.S.C. § 255 and MPEP 1481.
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`For example, so long as the error sought to be corrected is: (1) of a clerical nature,
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`(2) of a typographical nature, or (3) a mistake of minor character; and the correction
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`must not involve changes which would: (1) constitute new matter or (2) require
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`reexamination. See In re Arnott, 19 USPQ2d 1049, 1052 (Comm’r Pat. 1991)
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`specifies the criteria of 35 U.S.C. § 255. This is the case here, as the error sought to
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`be corrected is typographical and of minor character and clearly doesn’t constitute
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`new matter or require reexamination1.
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`1 Patent Owner agrees to seek such a certificate of correction for elements[20M]
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`and [20P] should amended claim 20 be allowed to provide absolute clarity on this
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`point.
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`Reply to Opposition to Motion to Amend, IPR2018-00952
`U.S. Patent No. 9,253,239
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`
`II. The Motion To Amend Is Supported
`Petitioner surprisingly contends at pages 3-5 of its Opposition that Patent
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`Owner somehow did not comply with its obligation under 37 C.F.R. § 42.121(b) by
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`providing citations only to the provisional application. However, quite to the
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`contrary, it is well established law that when a provisional application is
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`incorporated by reference it becomes part of the patent specification itself. See, for
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`example, Advanced Display Sys., Inc. v. Kent State Univ., 212 F.3d1272, 1282 (Fed
`
`Cir. 2000) (provisional applications incorporated by reference are “effectively part
`
`of the” specification as though it was “explicitly contained therein.”). See, also,
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`MPEP § 2163.07(b)2. Thus, to the extent the ’648 provisional provides additional
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`information above that in the issued ’239 patent, the two disclosures are treated as
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`cumulative. Merely because the specification of the patent is rewritten from the
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`earlier provisional does not mean that the claims are not fully supported by one or
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`both documents, especially given the incorporation by reference.
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`Further, the Declaration of Dr. Peggy Agouris In Support of Bradium
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`Technologies LLC’s Patent Owner Contingent Motion To Amend Pursuant To 37
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`C.F.R. § 42.121, EX2055, pp. 20-33, clearly supplies the required statement of
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`2 Further, 37 C.F.R. § 121(b)(2) expressly sanctions reference to an earlier filed
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`disclosure that need not be the specification of the issued patent.
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`U.S. Patent No. 9,253,239
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`support for the claim amendment in the priority application, U.S. Provisional Patent
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`Application No. 60/258,468, filed December 27, 2000, EX1019, pp. 52-67.
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`Accordingly, Patent Owner is compliant with 37 C.F.R. § 42.121(b), and
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`Petitioner’s position to the contrary on this point appearing to be frivolous. The
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`amended claims are supported in both the ’648 Provisional Patent Application
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`(EX1019) and the ’239 Patent (EX1001).
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`Further, based on the remarks in the Opposition, Petitioner misunderstands
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`the disclosed technology. When creating the quad tree structure of reduced
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`resolution images, one begins with a full resolution image and subsamples
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`/interpolates to obtain lower resolution images. These are then communicated in
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`lower resolution prioritized over higher resolution, so that the user device can
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`begin rendering the image before the high-resolution image is downloaded.
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`EX1019 p. 4, lines 8-14, and EX1001, p. 9, lines 1-3 make this clear.
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`Petitioner admits that the original formulation of claim 1 is supported,
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`stating “the specification and Bradium’s citations to the provisional application
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`only teach displaying a discrete portion using the data parcel that formed it as
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`recited in original claim 20. EX1027, ¶¶52-54; EX1013, Part 3, 59:7-9; Paper 39,
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`13; EX1019, 6:25-7:1 (only disclosing “rendering performed asynchronously as
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`data parcels are received”).” Thus, as properly interpreted the parallel language is
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`supported in all cases.
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`U.S. Patent No. 9,253,239
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`The predetermined color or bit depth is supported in EX1001, 6:8-13.
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`The “factor of two” is supported in EX1001, 11:45-56, where a quad-tree
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`data structure which divides an area into quadrants (and therefore each side in
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`half), and thus providing a factor of two difference in resolution, given the same
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`parcel size. Id., 6:3-41.
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`Moreover, the provisional patent application EX1019, 8:19-21 teaches away
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`from “determining priority of the additional request such that the second update
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`data parcel has a greater priority and requested, received, and displayed before the
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`additional data parcel.” The disclosure teaches that lower resolution parcels are
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`requested, received, and rendered before higher resolution parcels, and thus have
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`higher priority. EX1001, 4:1-3; 6:54-57; 8:37-56; 10:1-3; 10:56-64. According to
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`claim 20, the first request has higher priority than the second request, which has
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`higher priority than the additional request, and each has successively higher
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`resolution. (“the second update data parcel has a greater resolution than the first
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`update data parcel”; “the additional update data parcel has a greater resolution than
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`the second update data parcel”). The invention, prioritizes downloads of lower
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`resolution before higher resolution, but that does not mean that the higher
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`resolution parcels never are received before lower resolution parcels, and thus are
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`subject to prioritization, and not strict ordering. See, EX1001 11:1-16.
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`III. NEW CLAIM 21 IS A PROPER SUBSTITUTE CLAIM
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`Reply to Opposition to Motion to Amend, IPR2018-00952
`U.S. Patent No. 9,253,239
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`Petitioner challenged claims 1-25 of the patent. Claim 21 is indeed a proper
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`substitute claim with respect to the challenged claims. For example, it is strictly
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`narrower than claim 20, and responds to grounds for alleged invalidity. 35 U.S.C.
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`§ 316(d); 37 C.F.R, § 121(a)(2)(i). It is respectfully submitted that, given the patent
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`challenged had 25 claims, the review of 2 claims per the Motion to Amend is a
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`reasonable number. The need for the additional claim is clearly enunciated in Patent
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`Owner’s Contingent Motion to Amend. 37.C.F.R. § 121(a)(3). Further, each of
`
`claims 20 and 21 are traceable to an original claim, albeit the same original claim
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`20. Note that claim 21 is dependent from claim 20, and therefore is by definition
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`traceable to original claim 20. See 35 U.S.C. § 112, 4th paragraph.
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`While there is a rebuttable presumption that a single substitute claim is
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`sufficient, that presumption is both rebuttable and not based on any factual analysis
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`by the USPTO, and therefore is entitled to little deference. In this case, Patent Owner
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`has previously indicated the basis for presenting two proposed amended claims
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`based on a single remaining claim, and Petitioner has not presented convincing
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`arguments why the arbitrary presumption must be maintained.
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`A. Amended Claim 20 and New Claim 21 Are Not Broadened
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`Petitioner contends in its Opposition at pages 1-3 that the proposed claims 20
`
`and 21 are broader from the original claim 20. But this position is based on the
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`improper claim construction and indefiniteness argument addressed by Patent
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`Owner in Section I above. Once the proper Nautilus analysis is applied, and the
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`proper claim construction used, amended claim 20 merely adds additional features
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`to original claim 20 and is therefore more narrow. Likewise for new claim 21.
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`Further, Patent Owner points out that no broadening challenge under the claim
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`construction/indefinite analysis provided by Patent Owner in Section I above is
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`offered. Accordingly, the Board should find claims 20 and 21 complaint with 37
`
`C.F.R. § 42.121(a)(2).
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`IV. The Proposed Claims Are Non-Obvious
`As discussed in the Motion to Dismiss, the combination of Reddy (EX1004),
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`Hornbacker (EX1003), and Rosasco (EX1018) do not render the proposed amended
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`claims obvious. Further, U.S. Patent No. 6,496,189 to Yaron et al. (“Yaron”)
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`EX2028 does not remedy the deficiencies of the prior combination of Reddy,
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`Hornbacker, and Rosasco, because Yaron, either alone or in combination with the
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`other references, fails to teach or suggest any prioritization which involves both
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`image parcels involving different resolutions with respect to different viewpoints as
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`required by the claims. Patent Owner’s Expert agrees. EX2059 ¶¶ 61-74.
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`In particular, proposed amended claim 20 includes prioritization of requests
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`for image parcels of different resolution involving two distinct viewpoints. Thus,
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`the prioritization must consider both different resolution and two viewpoints.
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`Petitioner admits “a POSITA would have understood, or at least it would have been
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`U.S. Patent No. 9,253,239
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`rendered obvious to a POSITA, that when a viewpoint is at a particular point on the
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`map, the browser would first request and download lower resolution for particular
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`areas, then request higher resolution tiles for portions of the image that can usefully
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`display the higher resolution data. EX1027, ¶70.” However, this admission compels
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`a conclusion that Petitioner accepts that the references teach against consideration
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`of competing priorities for downloading and displaying image parcels with respect
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`to a different viewpoint. Petitioner further contends: “When the user-controlled
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`viewpoint is moving, the portions of the image utilizing higher resolution are
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`changing as the viewpoint moves. In contrast, when the viewpoint is constant, the
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`portion of the image utilizing the higher resolution image is also constant.”
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`Patent Owner does not admit that it “would be obvious to [download a further
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`yet-higher resolution tile within a portion of a mid-resolution tile, in a portion of a
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`low resolution tile] address user satisfaction issues so that the user is able to view a
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`lower resolution image until the higher resolution images are available instead of
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`just having a blank portion of the image during the waiting time. Id.; see also id.,
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`33:2-6. Mr. Wilson noted that “[t]here is in Reddy significant discussion of user
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`interface issues which might entail downloading that fourth yellow tile” and “several
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`spots in Reddy that it might be interpreted to require downloading that tile, mostly
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`related to efficiency.” Id., 37:11-19, 37:22-38:5. For example, Reddy describes that
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`“[u]sers must be able to navigate the VRML [(Virtual Reality Modeling Language)]
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`U.S. Patent No. 9,253,239
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`structures easily and efficiently using a standard VRML browser or a customized
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`browser that further increases browsing efficiency.” EX1004, ¶7.
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`A key issue is the prioritization of downloading: should all lowest resolution
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`tiles be downloaded before any highest resolution tiles? Should all mid-resolution
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`tiles be downloaded before any highest resolution tiles? If either of these is true,
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`then the downloading is not merely prioritized, but rather strictly ordered. But,
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`claims 20-21 require consideration of different viewpoints. If Reddy is interpreted
`
`to teach progressive resolution enhancement of a single viewpoint as Petitioner
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`contends, it cannot also teach hybrid prioritization based on both level of resolution
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`and different viewpoint. Therefore, Reddy does not teach or suggest prioritization
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`of two different viewpoints as required by the claims
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`Additionally, Reddy does not teach a prioritization algorithm or how such
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`downloading would be organized. Mr. Wilson hypothesizes that Terravision II (“TV
`
`II”) is optimized for user satisfaction, but there is no evidence on the record
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`whatsoever that TVII was actually tested with users, so that optimization remains an
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`unperformed task, and Mr. Wilson uses hindsight reconstruction from the claims at
`
`issue here, to manufacture a desire to perfect human factors at the same time that
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`they were trying to achieve a potentially desirable function in the first instance.
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`This presupposition of the novel inventive subject matter is clearly obtained
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`in hindsight from the applicant's inventive disclosure. See, Graham v. John Deere
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`Co., 383 U.S. 1, 36, 86 S. Ct. 684, 16 L. Ed. 2d 545 (1966) (warning against a
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`“temptation to read into the prior art the teachings of the invention in issue.”). The
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`hypothetical “user satisfaction” issues presented by Mr. Wilson are not themselves
`
`elements of the prior art, and are not properly considered in this proceeding.
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`Hornbacker, on the other hand, teaches that a user requests an image view,
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`EX1003, 5:16-21, and after the image is displayed, the user may click on an area of
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`the image to change the resolution of the image. Id., 5:21-24. However, this does
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`not reflect different viewpoints, but rather different potions of the same viewpoint.
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`In any case, according to this embodiment, any prioritization is replaced with an
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`express user command, and therefore the elements of claim 20 are not met.
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`With respect to claim 21, the prioritization issue is not extended to the
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`additional request. While claim 21 does not relate the priority of the additional
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`request with respect to the first request or the third request, the prioritization with
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`respect to the second request links these processes.
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`V. Conclusion
`For the foregoing reasons, in the event that the claim is deemed unpatentable,
`
`that Patent Owner’s Contingent Motion to Amend be granted.
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`
`/s/ Michael E. Shanahan
`Michael E. Shanahan (Reg. No.
`43,914) Bradium Technologies LLC
`75 Montebello Rd.
`Suffern, NY 10901
`Tel: (845) 368-4000
`mshanahan@generalpatent.com
`
`Counsel for Patent Owner
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`
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`
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`Dated: August 5, 2019
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`U.S. Patent No. 9,253,239
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`37 C.F.R. §42.24 CERTIFICATION
`The undersigned hereby certifies that this submission, excluding the
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`tables of contents, certificate of word count, exhibit list, and certificate of
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`service is within the 12 page limit per 37 C.F.R. § 42.24 and contains 2,798
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`words, as determined using the standard word counting feature of the Microsoft
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`Word 2016 program.
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`Dated: August 5, 2019
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`
`
`/s/ Michael E. Shanahan
`Michael E. Shanahan
`(Reg. No. 43,914)
`Bradium Technologies LLC
`75 Montebello Rd.
`Suffern, NY 10901
`Tel: (845) 368-4000
`mshanahan@generalpatent.com
`
`Counsel for Patent Owner
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`Reply to Opposition to Motion to Amend, IPR2018-00952
`U.S. Patent No. 9,253,239
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §42.6(e), the undersigned certifies that on August 5,
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`
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`2019, the foregoing Bradium Technology’s Patent Owner Reply To Opposition To
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`Motion To Amend Pursuant To 37 C.F.R. § 42.121 was served via electronic mail
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`upon the following counsel of record for the Petitioner:
`
`David L. Cavanaugh, Reg. No. 36,476
`Wilmer Cutler Pickering Hale and Dorr
`LLP 1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: David.Cavanaugh@wilmerhale.com
`
`Daniel V. Williams, Reg. No. 45,221
`Wilmer Cutler Pickering Hale and Dorr
`LLP 1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: Daniel.Williams@wilmerhale.com
`
`Jonathan E. Robe, Reg. No. 76,033
`Wilmer Cutler Pickering Hale and Dorr
`LLP 1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: Jonathan.Robe@wilmerhale.com
`
`Jonathan Stroud (Reg. 72,518)
`Unified Patents Inc.
`1875 Connecticut Avenue, N.W., Floor 10
`Washington, DC 20009
`Tel: (202) 805-8931
`jonathan@unifiedpatents.com
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`U.S. Patent No. 9,253,239
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`
`Roshan Suresh Mansinghani (Reg. 62,429)
`Unified Patents Inc.
`13355 Noel Road, Suite 1100
`Dallas, TX 75240
`Tel: (214) 945-0200
`roshan@unifiedpatents.com
`
`Dated: August 5, 2019
`
`
`
`/s/ Michael E. Shanahan
`Michael E. Shanahan (Reg. No.
`43,914) Bradium Technologies LLC
`75 Montebello Rd.
`Suffern, NY 10901
`Tel: (845) 368-4000
`mshanahan@generalpatent.com
`
`Counsel for Patent Owner
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