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