The ‘766 Patent discloses a football helmet.
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`Claim 1
`
`A football helmet,
`Subject to Riddell’s
`comprising:
`objections and
`
`reservations, denied.
`The reference does not
`disclose a football
`helmet, but only an
`ornamental design for a
`general “helmet for
`sports.” See ’766 Patent
`at Face.
`
`(‘766 Patent, FIGS. 1, 2, and 4)
`
`The ‘766 Patent discloses a plastic shell configured to receive a head of a wearer of the
`helmet, the shell having a front region, a crown region, and a rear region.
`
`
`
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`disclose a plastic shell,
`but only an ornamental
`design of unspecified
`material.
`
`a plastic shell
`configured to
`receive a head of a
`wearer of the
`helmet, the shell
`having: a front
`region, a crown
`region, a rear
`region,
`
`134219505.1
`
`1688
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`
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`Claim 1
`
`A football helmet,
`Subject to Riddell’s
`comprising:
`objections and
`
`reservations, denied.
`The reference does not
`disclose a football
`helmet, but only an
`ornamental design for a
`general “helmet for
`sports.” See ’766 Patent
`at Face.
`
`(‘766 Patent, FIGS. 1, 2, and 4)
`
`The ‘766 Patent discloses a plastic shell configured to receive a head of a wearer of the
`helmet, the shell having a front region, a crown region, and a rear region.
`
`
`
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`disclose a plastic shell,
`but only an ornamental
`design of unspecified
`material.
`
`a plastic shell
`configured to
`receive a head of a
`wearer of the
`helmet, the shell
`having: a front
`region, a crown
`region, a rear
`region,
`
`134219505.1
`
`1688
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`
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`
`Front Region
`
`Rear Region
`
`Crown Region
`
`(‘766 Patent, FIGS. 1, 2, and 4)
`
`The ‘766 Patent discloses two side regions wherein each side region has an ear flap with
`an ear opening.
`
`
`
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`disclose ear flaps with
`ear openings.
`
`With respect to the
`references shown in
`
`two side regions
`wherein each side
`region has an ear
`flap with an ear
`opening,
`
`134219505.1
`
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`
`
`
`Side Region
`
`Ear Opening
`
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`Exhibit AB1, Schutt has
`failed to specifically
`identify each of the
`claim elements as
`required by LPR
`2.3(b)(3). Accordingly,
`subject to Riddell’s
`objections and
`reservations, denied that
`any of the other cited
`references discloses the
`claim elements.
`
`Further, Schutt has
`failed to establish why a
`person of ordinary skill
`in the art would have
`been motivated to
`combine the reference
`with any of the
`references shown in
`Exhibit AB1. See LPR
`2.3(b)(2).
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied. As
`the reference does not
`
`(‘766 Patent, FIG. 4)
`
`Alternatively, in combination with one or more of the references shown in Exhibit AB1
`under 35 U.S.C. § 103.
`
`
`The ‘766 Patent discloses a lower edge surface extending generally from one of the ear
`flaps and along the rear region to the other of the ear flaps.
`
`
`a lower edge
`surface extending
`generally from one
`of the ear flaps and
`along the rear
`region to the other
`of the ear flaps,
`
`134219505.1
`
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`
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`disclose ear flaps, it
`cannot and does not
`disclose a lower edge
`surface extending
`generally from one ear
`flap and along a rear
`region to another ear
`flap.
`
`an inner shell wall
`surface, an outer
`shell wall surface,
`
`Lower Edge Surface
`
`
`
`
`(‘766 Patent, FIGS. 3 and 4)
`
`The ‘766 Patent discloses an inner shell wall surface and an outer shell wall surface.
`
`
`Outer Shell
`Wall Surface
`
`Inner Shell
`Wall Surface
`
`Subject to Riddell’s
`objections and
`reservations, admitted.
`
`
`(‘766 Patent, FIG. 2)
`
`
`
`134219505.1
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`
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`
`The ‘766 Patent discloses an offset band extending around the rear region and above the
`lower edge surface, the offset band including an offset band wall having an inner band
`surface offset from the inner shell wall surface, and an outer band surface offset from
`the outer shell wall surface.
`
`
`an offset band
`extending around
`the rear region and
`above the lower
`edge surface, the
`offset band
`including an offset
`band wall having an
`inner band surface
`offset from the
`inner shell wall
`surface, and an
`outer band surface
`offset from the
`outer shell wall
`surface, and
`
`
`134219505.1
`
`Offset Band
`
`
`
`
`(‘766 Patent, FIGS. 3 and 4)
`
`Alternatively, in combination with one or more of the references shown in Exhibit AB6
`under 35 U.S.C. § 103.
`
`
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`disclose an offset band
`including an offset band
`wall having an inner
`band surface offset from
`the inner shell wall
`surface.
`
`With respect to the
`references shown in
`Exhibit AB6, Schutt has
`failed to specifically
`identify each of the
`claim elements as
`required by LPR
`2.3(b)(3). Accordingly,
`subject to Riddell’s
`objections and
`reservations, denied that
`any of the other cited
`references discloses the
`claim elements.
`
`
`1692
`
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`
`
`
`The ‘766 Patent discloses a pair of angled transition walls extending between the offset
`band wall and the rear region.
`
`
`a pair of angled
`transition walls,
`extending between
`the offset band wall
`and the rear region;
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`Further, Schutt has
`failed to establish why a
`person of ordinary skill
`in the art would have
`been motivated to
`combine the reference
`with any of the
`references shown in
`Exhibit AB6. See LPR
`2.3(b)(2).
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied. As
`the reference does not
`disclose an “offset band
`wall” having an inner
`band surface offset from
`the inner shell wall
`surface, as recited in
`claim 1, it cannot and
`does not disclose a pair
`of angled transition
`walls, extending
`between the offset band
`wall and the rear region.
`
`With respect to the
`
`
`(‘766 Patent, FIGS. 3 and 4)
`
`Alternatively, in combination with one or more of the references shown in Exhibit AB6
`under 35 U.S.C. § 103.
`
`
`Angled
`Transition
`Walls
`
`
`
`134219505.1
`
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`
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`references shown in
`Exhibit AB6, Schutt has
`failed to specifically
`identify each of the
`claim elements as
`required by LPR
`2.3(b)(3). Accordingly,
`subject to Riddell’s
`objections and
`reservations, denied that
`any of the other cited
`references discloses the
`claim elements.
`
`Further, Schutt has
`failed to establish why a
`person of ordinary skill
`in the art would have
`been motivated to
`combine the reference
`with any of the
`references shown in
`Exhibit AB6. See LPR
`2.3(b)(2).
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`
`The ‘766 Patent discloses a raised central band integrally formed as part of the shell and
`extending across the crown region to the rear region, the raised central band having a
`width defined by a pair of opposed sidewalls.
`
`a raised central
`band integrally
`formed as part of
`the shell and
`extending across the
`crown region to the
`rear region, the
`raised central band
`having a width
`
`134219505.1
`
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`
`
`
`Raised Central Band
`
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`defined by a pair of
`Schutt has failed to
`opposed sidewalls,
`specifically identify
`
`where it believes the
`reference discloses a
`raised central band that
`is integrally formed as
`part of the shell and
`extends across a crown
`region to a rear region.
`See LPR
`2.3(b)(3).Regardless, the
`reference does not
`disclose these
`limitations.
`
`With respect to the
`references shown in
`Exhibit AB2, Schutt has
`failed to specifically
`identify each of the
`claim elements as
`required by LPR
`2.3(b)(3). Accordingly,
`subject to Riddell’s
`objections and
`reservations, denied that
`any of the other cited
`references discloses the
`claim elements.
`
`Further, Schutt has
`failed to establish why a
`person of ordinary skill
`
`(‘766 Patent, FIGS. 1, 2, and 7)
`
`Alternatively, in combination with one or more of the references shown in Exhibit AB2
`under 35 U.S.C. § 103.
`
`
`134219505.1
`
`1695
`
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`
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`in the art would have
`been motivated to
`combine the reference
`with any of the
`references shown in
`Exhibit AB2. See LPR
`2.3(b)(2).
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`Schutt has failed to
`specifically identify
`where it believes the
`reference discloses a
`first plurality of vent
`openings residing
`outside of a raised
`central band and aligned
`along a first side of a
`raised central band, nor
`where it discloses a
`second plurality of vent
`openings residing
`outside of a raised
`central band and aligned
`along a second side of a
`raised central band. See
`
`
`(‘766 Patent, FIGS. 1, 2, and 7)
`
`Alternatively, in combination with one or more of the references shown in Exhibit AB3
`under 35 U.S.C. § 103.
`
`
`a first plurality of
`vent openings
`residing outside of
`the raised central
`band and aligned
`along a first side of
`the raised central
`band, and a second
`plurality of vent
`openings residing
`outside of the raised
`central band and
`aligned along a
`second side of the
`raised central band;
`
`134219505.1
`
`The ‘766 Patent discloses a first plurality of vent openings residing outside of the raised
`central band and aligned along a first side of the raised central band, and a second
`plurality of vent openings residing outside of the raised central band and aligned along a
`second side of the raised central band.
`
`
`Vent Openings
`
`
`
`1696
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`
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`LPR 2.3(b)(3).
`
`Regardless, to the extent
`that the reference
`discloses openings at all
`that are outside of the
`centrally-located feature
`on top of the shell, it
`does not disclose that
`such openings are vent
`openings, nor that they
`are aligned along a first
`or second side of that
`feature.
`
`With respect to the
`references shown in
`Exhibit AB3, Schutt has
`failed to specifically
`identify each of the
`claim elements as
`required by LPR
`2.3(b)(3). Accordingly,
`subject to Riddell’s
`objections and
`reservations, denied that
`any of the other cited
`references discloses the
`claim elements.
`
`Further, Schutt has
`failed to establish why a
`person of ordinary skill
`
`134219505.1
`
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`
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`
`
`
`The ‘766 Patent discloses a face guard secured to the shell by a face guard connector.
`
`
`a face guard secured
`to the shell by a
`face guard
`connector; and
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`in the art would have
`been motivated to
`combine the reference
`with any of the
`references shown in
`Exhibit AB3. See LPR
`2.3(b)(2).
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`disclose a face guard or
`a face guard connector
`of any kind.
`
`With respect to the
`references shown in
`Exhibit AB5, Schutt has
`failed to specifically
`identify each of the
`claim elements as
`required by LPR
`2.3(b)(3). Accordingly,
`subject to Riddell’s
`objections and
`reservations, denied that
`any of the other cited
`
`
`(‘766 Patent, FIG. 2)
`
`Alternatively, in combination with one or more of the references shown in Exhibit AB5
`under 35 U.S.C. § 103.
`
`
`
`
`134219505.1
`
`1698
`
`Kranos IP Exhibit 2005, Page 11 of 77
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`
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`references discloses the
`claim elements.
`
`Further, Schutt has
`failed to establish why a
`person of ordinary skill
`in the art would have
`been motivated to
`combine the reference
`with any of the
`references shown in
`Exhibit AB5. See LPR
`2.3(b)(2).
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`disclose a chin strap
`assembly of any kind,
`much less one that
`releasably secures the
`helmet to the wearer.
`
`With respect to the
`references shown in
`Exhibit AB4, Schutt has
`failed to specifically
`
`(‘766 Patent, FIG. 1)
`
`Alternatively, in combination with one or more of the references shown in Exhibit AB4
`under 35 U.S.C. § 103.
`
`
`
`a chin strap
`assembly that
`releasably secures
`the helmet to the
`wearer.
`
`The ‘766 Patent discloses a chin strap assembly that releasably secures the helmet to the
`wearer.
`
`
`134219505.1
`
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`
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`identify each of the
`
`claim elements as
`required by LPR
`2.3(b)(3). Accordingly,
`subject to Riddell’s
`objections and
`reservations, denied that
`any of the other cited
`references discloses the
`claim elements.
`
`Further, Schutt has
`failed to establish why a
`person of ordinary skill
`in the art would have
`been motivated to
`combine the reference
`with any of the
`references shown in
`Exhibit AB4. See LPR
`2.3(b)(2).
`
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`
`The ‘766 Patent discloses an offset band that extends between the ear openings in the ear
`flaps.
`
`(See Claim 1 above.)
`
`
`Claim 2
`The football helmet
`of claim 1,
`wherein the offset
`band extends
`between the ear
`openings in the ear
`flaps.
`
`134219505.1
`
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`
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`
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`disclose a football
`helmet, much less the
`football helmet of claim
`1. See Response to
`claim 1, above.
`
`Further, the reference
`does not disclose an
`“offset band” as recited
`in claim 1 of the ’818
`Patent (see Response to
`claim 1, above), nor
`does it disclose ear
`openings in ear flaps,
`and thus it cannot and
`does not disclose the
`additional limitations of
`an offset band as set
`forth in claim 2.
`
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`disclose a football
`helmet, much less the
`
`The ‘766 Patent discloses an offset band that has a curvilinear configuration as the offset
`band extends around the rear region and above the lower edge surface.
`
`(See Claim 1 above.)
`
`
`Claim 3
`The football helmet
`of claim 1,
`wherein the offset
`band has a
`curvilinear
`configuration as the
`offset band extends
`around the rear
`region and above
`the lower edge
`surface.
`
`134219505.1
`
`1701
`
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`
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`football helmet of claim
`1. See Response to
`Claim 1, above.
`
`Further, as the reference
`does not disclose an
`“offset band” as recited
`in claim 1, it cannot and
`does not disclose the
`additional limitations of
`the offset band as set
`forth in claim 3.
`
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`disclose a football
`helmet, much less the
`football helmet of claim
`1. See Response to
`Claim 1, above.
`
`Further, as the reference
`does not disclose an
`“offset band wall” or
`
`The ‘766 Patent discloses that one of the angled transition walls extends between the rear
`region and an upper band edge of the offset band wall and the other of the angled
`transition walls extends between the rear region and a lower band edge of the offset band
`wall.
`
`(See Claim 1 above.)
`
`
`Claim 5
`The football helmet
`of claim 1,
`wherein one of the
`angled transition
`walls extends
`between the rear
`region and an upper
`band edge of the
`offset band wall and
`wherein the other of
`the angled transition
`walls extends
`between the rear
`region and a lower
`band edge of the
`offset band wall.
`
`134219505.1
`
`1702
`
`Kranos IP Exhibit 2005, Page 15 of 77
`Riddell, Inc. v. Kranos IP II Corp., IPR2018-01164
`
`
`
`The ‘766 Patent discloses an offset band that includes end segments that curve
`downwardly toward the lower edge surface.
`
`(See Claim 1 above.)
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`“angled transition walls”
`as recited in claim 1 (see
`Response to claim 1,
`above), it cannot and
`does not disclose the
`additional limitations of
`the angled transition
`walls as set forth in
`claim 5.
`
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`disclose a football
`helmet, much less the
`football helmet of claim
`1. See Response to
`Claim 1, above.
`
`Further, as the reference
`does not disclose an
`“offset band” as recited
`in claim 1, it cannot and
`does not disclose the
`additional limitations of
`
`Claim 6
`The football helmet
`of claim 1,
`wherein the offset
`band includes end
`segments, and
`wherein the end
`segments curve
`downwardly toward
`the lower edge
`surface.
`
`134219505.1
`
`1703
`
`Kranos IP Exhibit 2005, Page 16 of 77
`Riddell, Inc. v. Kranos IP II Corp., IPR2018-01164
`
`
`
`Claim 8
`The football helmet
`of claim 1,
`wherein the offset
`band is integrally
`formed as part of
`the shell.
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`the offset band as set
`forth in claim 6.
`
`Regardless, the
`reference does not
`disclose an offset band
`that includes end
`segments that curve
`downwardly toward a
`lower edge surface.
`
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`disclose a football
`helmet, much less the
`football helmet of claim
`1. See Response to
`Claim 1, above.
`
`Further, Schutt has
`failed to specifically
`identify where it
`believes the reference
`discloses an offset band
`
`The ‘766 Patent discloses an offset band that is integrally formed as part of the shell.
`
`(See Claim 1 above.)
`
`
`134219505.1
`
`1704
`
`Kranos IP Exhibit 2005, Page 17 of 77
`Riddell, Inc. v. Kranos IP II Corp., IPR2018-01164
`
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`that is integrally formed
`as part of the shell. See
`LPR 2.3(b)(3).
`
`Regardless, as the
`reference does not
`disclose an “offset
`band” as recited in claim
`1, it cannot and does not
`disclose the additional
`limitations of the offset
`band as set forth in
`claim 8.
`
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`disclose a football
`helmet, much less the
`football helmet of claim
`1. See Response to
`Claim 1, above.
`
`Further, the reference
`does not disclose a
`
`The ‘766 Patent discloses a crown shock absorbing pad disposed in the crown region
`adjacent the inner shell wall surface.
`
`(See Claim 14 below.)
`
`Claim 9
`The football helmet
`of claim 1,
`further comprising a
`crown shock
`absorbing pad
`disposed in the
`crown region
`adjacent the inner
`shell wall surface.
`
`134219505.1
`
`1705
`
`Kranos IP Exhibit 2005, Page 18 of 77
`Riddell, Inc. v. Kranos IP II Corp., IPR2018-01164
`
`
`
`Claim 10
`The football helmet
`of claim 9,
`wherein the crown
`shock absorbing
`pad includes a
`positioning
`member, and
`wherein the
`positioning member
`extends through an
`opening in the
`raised central band.
`
`The ‘766 Patent discloses a crown shock absorbing pad that includes a positioning
`member that extends through an opening in the raised central band.
`
`(See Claim 22 below.)
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`crown shock absorbing
`pad of any kind.
`
`See also Response to
`Claim 14, below.
`
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`disclose a football
`helmet, much less the
`football helmet of claim
`9. See Response to
`Claim 1 and Claim 9,
`above.
`
`Further, as the reference
`does not disclose a
`“crown shock absorbing
`pad” of any kind, it
`cannot and does not
`disclose the additional
`limitations of that pad as
`set forth in claim 10.
`
`
`134219505.1
`
`1706
`
`Kranos IP Exhibit 2005, Page 19 of 77
`Riddell, Inc. v. Kranos IP II Corp., IPR2018-01164
`
`
`
`Claim 11
`The football helmet
`of claim 9,
`wherein the crown
`shock absorbing
`pad is inflatable and
`includes an inflation
`valve, and wherein
`the inflation valve is
`aligned with an
`opening in the
`raised central band.
`
`The ‘766 Patent discloses a crown shock absorbing pad that is inflatable and includes an
`inflation valve, and wherein the inflation valve is aligned with an opening in the raised
`central band.
`
`(See Claim 14 below.)
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`See also Response to
`Claim 22, below.
`
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`disclose a football
`helmet, much less the
`football helmet of claim
`9. See Response to
`Claim 1 and Claim 9,
`above.
`
`Further, as the reference
`does not disclose a
`“crown shock absorbing
`pad” of any kind, it
`cannot and does not
`disclose the additional
`limitations of that pad as
`set forth in claim 11.
`
`See also Response to
`Claim 14, below.
`
`
`Claim 12
`
`134219505.1
`
`1707
`
`Kranos IP Exhibit 2005, Page 20 of 77
`Riddell, Inc. v. Kranos IP II Corp., IPR2018-01164
`
`
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`The ‘766 Patent discloses a crown shock absorbing pad that is inflatable and includes a
`The football helmet
`Schutt has failed to
`positioning member and an inflation valve, wherein the positioning member extends
`of claim 9,
`specifically identify
`through a first opening in the raised central band and wherein the inflation valve is
`wherein the crown
`each of the claim
`aligned with a second opening in the raised central band.
`shock absorbing
`elements as required by
`pad is inflatable and
`
`LPR 2.3(b)(3).
`(See Claims 14 and 22 below.)
`includes a
`
`positioning member
`Subject to Riddell’s
`and an inflation
`objections and
`valve, and wherein
`reservations, denied.
`the positioning
`The reference does not
`member extends
`disclose a football
`through a first
`helmet, much less the
`opening in the
`football helmet of claim
`9. See Response to
`raised central band
`and wherein the
`Claim 1, above.
`inflation valve is
`
`aligned with a
`Further, as the reference
`second opening in
`does not disclose a
`the raised central
`“crown shock absorbing
`band.
`pad” of any kind, it
`cannot and does not
`disclose the additional
`limitations of that pad as
`set forth in claim 12.
`
`See also Response to
`Claim 14 and Claim 22,
`below.
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`
`The ‘766 Patent discloses a football helmet.
`
`(See Claim 1 above.)
`
`Claim 14
`A football helmet,
`comprising:
`
`134219505.1
`
`1708
`
`Kranos IP Exhibit 2005, Page 21 of 77
`Riddell, Inc. v. Kranos IP II Corp., IPR2018-01164
`
`
`
`The ‘766 Patent discloses a plastic shell configured to receive a head of a wearer of the
`helmet, the shell having a front region, a crown region, and a rear region.
`
`(See Claim 1 above.)
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`The reference does not
`disclose a football
`helmet.
`
`See Response to Claim
`1, above.
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`disclose a plastic shell.
`
`See Response to Claim
`1, above.
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied.
`The reference does not
`disclose ear flaps with
`ear openings.
`
`The ‘766 Patent discloses two side regions wherein each side region has an ear flap with
`an ear opening.
`
`(See Claim 1 above.)
`
`a plastic shell
`configured to
`receive a head of a
`wearer of the
`helmet, the shell
`having: a front
`region, a crown
`region, a rear
`region,
`
`two side regions
`wherein each side
`region has an ear
`flap with an ear
`opening,
`
`134219505.1
`
`1709
`
`Kranos IP Exhibit 2005, Page 22 of 77
`Riddell, Inc. v. Kranos IP II Corp., IPR2018-01164
`
`
`
`The ‘766 Patent discloses a lower edge surface extending generally from one of the ear
`flaps and along the rear region to the other of the ear flaps.
`
`(See Claim 1 above.)
`
`a lower edge
`surface extending
`generally from one
`of the ear flaps and
`along the rear
`region to the other
`of the ear flaps,
`
`Final Response to Schutt’s Claim Chart Regarding Invalidity of U.S. Patent No. 8,938,818 (“the ‘818 Patent”)
`In Light of U.S. Patent No. D412,766 to Tang, Filed February 20, 1998, Issued August 10, 1999 (“the ‘766 Patent”)
`‘818 Patent Claim Asserted Prior Art Reference
`Response by Riddell
`
`See Response to claim 1,
`above.
`Schutt has failed to
`specifically identify
`each of the claim
`elements as required by
`LPR 2.3(b)(3).
`
`Subject to Riddell’s
`objections and
`reservations, denied. As
`the reference does not
`disclose ear flaps, it
`cannot and does not
`disclose a lower edge
`surface extending
`generally from one ear
`flap and along a rear
`region to another ear
`flap.
`
`See Response to claim 1,
`above.
`Subject to Riddell’s
`objections and
`reservations, admitted.
`Schutt has failed to
`specifically identify
`where it believes the
`reference discloses an
`offset band extending
`
`The ‘766 Patent discloses and inner shell wall surface and an outer shell wall surface.
`
`(See Claim 1 above).
`The ‘766 Patent discloses an offset
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