UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Apple Inc.,
`Petitioner
`
`v.
`
`Qualcomm Inc.,
`Patent Owner
`
`Inter Partes Review No. IPR2018-01279
`U.S. Patent 7,844,037
`
`PATENT OWNER’S REPLY TO PETITIONER’S OPPOSITION TO
`MOTION TO AMEND UNDER 37 C.F.R. § 42.121
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Apple Inc.,
`Petitioner
`
`v.
`
`Qualcomm Inc.,
`Patent Owner
`
`Inter Partes Review No. IPR2018-01279
`U.S. Patent 7,844,037
`
`PATENT OWNER’S REPLY TO PETITIONER’S OPPOSITION TO
`MOTION TO AMEND UNDER 37 C.F.R. § 42.121
`
`
`
`Inter Partes Review No. IPR2018-01279
`
`TABLE OF CONTENTS
`
`I.
`II.
`
`III.
`
`IV.
`
`INTRODUCTION ........................................................................................... 1
`THE SUBSTITUTE CLAIMS NARROW THE SCOPE OF THE
`ORIGINAL CLAIMS OF THE ’037 PATENT .............................................. 1
`Substitute independent claim 26 narrows the scope of claim 1 ............ 1
`1.
`“presenting . . . reply options” and “enabling the user . .
`. to manually compose all of the content of the message” ...... 2
`“automatically addressing the message” ....................................... 6
`2.
`PETITIONER’S RESPONSIVENESS ARGUMENTS LACK MERIT ........ 6
`Substitute claim 26 is responsive to the instituted grounds .................. 6
`Substitute dependent claims 27, 30, 40, and 41 are responsive ............ 7
`THE SUBSTITUTE CLAIMS ARE PATENTABLE OVER THE ART
`OF RECORD ................................................................................................... 8
`Substitute claims 26–33, and 37–42 are patentable over Makela
`and Moran in view of Pirskanen ........................................................... 8
`1.
`The Prior Art of Record Does Not Disclose all the Recited
`Features of Substitute Claim 26 .................................................... 8
`
`- i -
`
`
`
`Inter Partes Review No. IPR2018-01279
`
`TABLE OF AUTHORITIES
`
`Cases
`Apple Inc., et al. v. Valencell, Inc.,
`IPR2017-00321, Paper 44 (PTAB June 5, 2018) ................................................. 9
`Lectrosonics, Inc. v. Zaxcom, Inc.,
`IPR2018-01129, Paper 15 (PTAB Feb. 25, 2019) ................................................ 9
`
`Page(s)
`
`- ii -
`
`
`
`Inter Partes Review No. IPR2018-01279
`
`EXHIBIT LIST
`
`Patent Owner’s Exhibits
`
`2001
`
`2002
`
`2003
`
`2004
`
`2005
`
`2006
`
`2007
`
`2008
`
`2009
`
`2010
`
`2011
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`2012
`
`2013
`
`2014
`
`2015
`
`2016
`
`2017
`
`2018
`
`Disclaimer in Patent Under 37 CFR 1.321(a)
`
`U.S. Patent No. 6,219,413 to Burg
`
`Declaration of Puneet Kohli
`
`Declaration of Dr. Kevin Jeffay
`
`CV of Dr. Kevin Jeffay
`
`Transcript of Dr. Narayan Mandayam’s Deposition
`
`U.S. Patent No. 8,737,578
`
`Prosecution History for ’578 Patent
`
`Apple’s Invalidity Contentions
`
`Exhibit E to Apple’s Invalidity Contentions
`
`U.S. Pub. No. 2004/0127263 to Vegh
`
`U.S. Patent No. 6,484,027 to Mauney
`
`U.S. Patent No. 6,253,075 to Beghtol
`
`U.S. Pub. No. 2002/0132608 to Shinohara
`
`U.S. Pub. No. 2004/0185885 to Kock
`
`U.S. Pub. No. 2002/0084549 to Yang
`
`EP 1263201 A2 to Hoersten
`
`Sascha Segan, “Coming Attractions-Nokia’s Latest Camera Phone,”
`PCMag at 22
`
`2019
`
`Nokia 6682 User Guide (May 4, 2005) (“Nokia 6682 User Guide”)
`
`- iii -
`
`
`
`Inter Partes Review No. IPR2018-01279
`
`2020
`
`Sascha Segan, “Nokia 6682,” PCMag (June 27, 2005)
`
`2022
`
`“IEEE 100: The Authoritative Dictionary of IEEE Standards Terms”
`(7th ed. 2000)
`
`2023
`
`Merriam-Webster’s Collegiate Dictionary (10th ed. 1997)
`
`2024
`
`2025
`
`Newton’s Telecom Dictionary, 16th Updated, Expanded and Much
`Improved Edition
`
`Oral Deposition of Jeremy R. Cooperstock, Ph.D. dated October 22,
`2019, Apple Inc. vs. Qualcomm Incorporated
`
`- iv -
`
`
`
`I.
`
`INTRODUCTION
`Petitioner mischaracterizes Patent Owner’s Motion to Amend and makes
`
`arguments that are inconsistent with and, at times, directly contrary to the record.
`
`As set forth herein and in the Motion to Amend, Patent Owner’s substitute claims
`
`are responsive to and patentable over the grounds set forth in the Petition. The
`
`substitute claims provide clarification without enlarging the scope of the claims and
`
`are also patentable over the art of record. Furthermore, the substitute claims are
`
`patentable over Petitioner’s newly proposed ground.
`
`II.
`
`THE SUBSTITUTE CLAIMS NARROW THE SCOPE OF THE
`ORIGINAL CLAIMS OF THE ’037 PATENT
`Substitute independent claim 26 narrows the scope of claim 1
`Substitute claim 26 includes the amended features of “presenting a user of the
`
`first computing device a graphic user interface that at least has the following reply
`
`options . . . insertion of pre-formulated content for the message and manual
`
`composition of all the content of the message” and “enabling the user of the first
`
`computing device to manually compose all of the content of the message.” Petitioner
`
`contends that substitute claim 26 enlarges the scope of original claim 1 because it
`
`“entirely removes ‘prompting’ limitation from claim 1, and it omits the language
`
`regarding the first computing device . . . . composing . . . [the] message.” Opp. at 3
`
`(emphasis added). Petitioner further contends that “claim 26 also enlarges the scope
`
`of original claim 1 to include scenarios in which the automatic addressing of the
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`Case IPR2018-01279
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`message does not occur ‘responsive to receiving the incoming call and the user
`
`entering the user input.’” Opp. at 5 (emphasis added). However, Petitioner’s
`
`arguments fail for the following reasons.
`
`1.
`
`“presenting . . . reply options” and “enabling the user . . . to
`manually compose all of the content of the message”
`Petitioner’s suggestion that the substitute claim “entirely removes the
`
`prompting limitation” is a red herring. Opp. at 3. In fact, substitute claim 26 recites
`
`“presenting reply options”—which is the only prompting disclosed in the
`
`specification. See Patent Owner Response at 16-17. Patent Owner, therefore,
`
`proposed in its Preliminary Patent Owner Response that the “prompting” term be
`
`construed to mean “presenting reply options [to a user].” Preliminary Patent Owner
`
`Response at 19. Based on the record at the time of the Institution Decision, however,
`
`the Board was “not persuaded that the term ‘prompting’ was so limited.” Institution
`
`Decision at 11 (emphasis added).
`
`In light of the entire record before the Board at this time, the Board should
`
`construe the “prompting” term to mean “presenting reply options [to a user]”—
`
`which necessarily entails “displaying a symbol or message to a user of the first
`
`computing device indicative of an option. If, however, the Board is still “not
`
`persuaded that the term ‘prompting’ [is] so limited,” then under the Board’s
`
`rationale, “presenting reply options,” which is an amended feature of the substitute
`
`claim, is narrower than the “prompting” of claim 1. Institution Decision at 11
`
`2
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`Case IPR2018-01279
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`(emphasis added). Indeed, Petitioner itself asserts that “Qualcomm proposes
`
`narrowly construing “prompting a user of the first computing device” to require
`
`“displaying a symbol or message to a user of the first computing device indicative
`
`of an option”—which is equivalent to the amended feature of “presenting reply
`
`options.”” Petitioner’s Reply at 2 (emphasis added).
`
`Substitute claim 26 not only limits the prompting, as recited in claim 1—under
`
`the Board’s rationale—to presenting reply options, it also narrows the scope of
`
`prompting to (i) presenting reply options in a graphic user interface; (ii) two specific
`
`reply options; and (iii) two specific types of message content. First, by reciting
`
`“presenting a user of the first computing device a graphic user-interface that has at
`
`least the following reply options,” the substitute claim effectively adds the limitation
`
`of original claim 2, which recites, in part, “generating a graphic user-interface that
`
`prompts the user.” ’037 Patent at 10:17. Second, by reciting “the following reply
`
`options: (i) answering the incoming call, and (ii) message responding to the
`
`incoming call by sending a message to a user of the second computing device,”
`
`substitute claim 26 narrows (under the Board’s rationale) the scope of prompting, as
`
`recited in claim 1, to two specific reply options—namely, answering the call and
`
`message responding to the call. Third, to the extent the Board does not agree with
`
`Patent Owner’s proposed construction for “composing . . . a message,” as recited in
`
`claim 1, and finds that the recited composing is not limited to manual composition
`
`3
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`Case IPR2018-01279
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`of the message, substitute claim 26 further limits the scope of claim 1 to two specific
`
`types of message content—namely, inserting pre-fabricated content and manual
`
`composition of the content after receiving the incoming call. Specifically, claim 26
`
`recites in part, “wherein message responding option allows insertion of pre-
`
`formulated content for the message and manual composition of all of the content of
`
`the message.” By reciting these phrases, substitute claim 26 effectively adds
`
`limitations to claim 1 from claims 15 and 16—which recite in part, “provide content
`
`manually for the message” and “insertion of pre-formulated content,” respectively.
`
`Fourth, by reciting “enabling the user of the first computing device to manually
`
`compose . . . content of the message,” substitute claim 26 effectively adds the entire
`
`limitation of original claim 15, which recites, “enabling the user of the first
`
`computing device to provide content manually for the message,” to claim 1.
`
`Significantly, Petitioner does not—and cannot contend—that a POSITA
`
`would understand “provide content manually for the message,” as recited in claim
`
`15, as not equivalent to “manual composition of the content of the message,” as
`
`recited in part in claim 26. Instead, Petitioner merely contends that claim 1 “requires
`
`composition of the message by the first computing device.” Opp. at 3. Even if
`
`Petitioner’s assertions were correct that “composing” in claim 1 is done by the
`
`computing device —which is not the case—Petitioner fails to understand that claim
`
`1 does not recite the step of the computing device actually composing the message,
`
`4
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`Case IPR2018-01279
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`but instead recites that the computing device prompts the user to enter user input that
`
`instructs the computing device to handle the call by composing. Thus, the action
`
`being taken in the relevant limitation of claim 1 is “prompting,” and the focus when
`
`comparing claims 1 and 26 should be on how the computing device prompts the
`
`user, not what entity composes the message.
`
`While claim 1 recites “prompting a user of the first computing device to enter
`
`user input that instructs the first computing device to handle the incoming call by
`
`composing . . . a message,” substitute claim 26 recites “presenting a user of the first
`
`computing device a graphic user-interface that at least has the following reply
`
`options: . . . (ii) message responding to the incoming call by sending a message to a
`
`user of the second computing device, wherein the message responding option allows
`
`insertion of preformulated content for the message and manual composition of all of
`
`the content of the message.” Thus, claim 1, under Petitioner’s position, more
`
`broadly recites that a computing device must prompt a user to enter input that
`
`instructs the computing device to compose the message to the incoming call, while
`
`claim 26 more specifically recites the exact prompts that allow a user to instruct the
`
`computing device to message respond to the incoming call and further explains the
`
`types of user input that can be used to instruct how to message respond (i.e., either
`
`by using preformulated content or by using content manually provided by the user
`
`at the time of the call). Thus, claim 26 is clearly narrower than claim 1.
`
`5
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`Case IPR2018-01279
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`“automatically addressing the message”
`2.
`First, as an initial matter, substitute claim 26 recites automatically addressing
`
`the message “while not answering the call.” This limitation suggests that the
`
`predicate act of receiving the call is required before automatically addressing the
`
`message. As such, the scope of “while not answering the call” is not larger than
`
`“responsive to receiving the incoming call.”
`
`Second, “automatically addressing the message” requires addressing the same
`
`message that is composed in response to the user “selection of the message
`
`responding option,” which, by definition, means being responsive to the user
`
`entering user input (the selection of the message responding option). Accordingly,
`
`substitute claim 26 requires automatic addressing be both “responsive to receiving
`
`the incoming call and the user entering the user input,” as in claim 1. As such,
`
`substitute claim 26 does not impermissibly enlarge the scope of the claims.
`
`Finally, dependent claims 27–42 further narrow claim 26, and as such, do not
`
`enlarge the scope of the original claims of the ’037 patent.
`
`III. PETITIONER’S RESPONSIVENESS ARGUMENTS LACK MERIT
`Substitute claim 26 is responsive to the instituted grounds
`As described above, substitute claim 26 is responsive at least because it
`
`narrows claim 1 in response to the Petitioner’s arguments that the scope of claim 1
`
`is disclosed in the prior art of record, assuming that reaching this Motion, the Board
`
`has accepted Petitioner’s broad constructions of claim 1. As discussed above,
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`6
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`Case IPR2018-01279
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`Petitioner’s argument that substitute claim 26 removes the “prompting,” and as such,
`
`does not narrow the “prompting” limitation, is belied by the narrower “presenting”
`
`limitation put in its place. See Opp. at 8.
`
`More specifically, including “in response to an incoming call . . . presenting a
`
`user of the first computing device a graphic user-interface that at least has the
`
`following reply options . . .” in the substitute claim 26 is responsive to a ground of
`
`unpatentability, as evidenced by the argument in Section IV that the prior art
`
`references, alone or in combination, do not disclose or suggest this feature.
`
`Moreover, including “while not answering the incoming call, enabling the user of
`
`the first computing device to manually compose all of the content of the message”
`
`in substitute claim 26 is responsive to a ground of unpatentability, as evidenced by
`
`the argument in Section IV that the prior art references do not disclose or suggest
`
`this feature. Indeed, it includes a limitation similar to that of original claim 15, which
`
`was not even challenged in the Petition.
`
`Substitute dependent claims 27, 30, 40, and 41 are responsive
`Petitioner contends that a substitute claim is not responsive “if it does not
`
`include or narrow each feature of the challenged claim being replaced.” Opp. at 15
`
`(emphasis omitted) (citing Apple Inc., et al. v. Valencell, Inc., IPR2017-00321, Paper
`
`44 at 53 (PTAB June 5, 2018) (non-precedential)). However, the Board has issued
`
`more recent precedential authority in an Order regarding Information and Guidance
`
`7
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`Case IPR2018-01279
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`on Motions to Amend, holding a substitute claim responsive “if it narrows the scope
`
`of at least one claim of the patent, for example [but not necessarily] the challenged
`
`claim it replaces, in a way that is responsive to a ground of unpatentability.”
`
`Lectrosonics, Inc. v. Zaxcom, Inc., IPR2018-01129, Paper 15, 6-7 (PTAB Feb. 25,
`
`2019) (precedential) (emphasis added). Because claims 27, 30, 40, and 41 further
`
`narrow claim 26 to distinguish the claims from the prior art in the Petition, they meet
`
`this responsiveness requirement.
`
`IV. THE SUBSTITUTE CLAIMS ARE PATENTABLE OVER THE ART
`OF RECORD
`Substitute claims 26–33, and 37–42 are patentable over Makela
`and Moran in view of Pirskanen
`1.
`The Prior Art of Record Does Not Disclose all the Recited
`Features of Substitute Claim 26
`Petitioner contends that a POSITA would have combined the device of
`
`Makela and Moran with the reply options for incoming calls of Pirskanen. Opp. at
`
`12. However, as discussed below, Pirskanen does not remedy the failure of Makela
`
`and Moran to disclose all the recited features of substitute claim 26, such as
`
`“presenting a user of the first computing device a graphic user-interface that at least
`
`has the following reply options” and “while not answering the incoming call,
`
`enabling the user of the first computing device to manually compose all of the
`
`content of a message.”
`
`8
`
`
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`Case IPR2018-01279
`
`(i) “presenting a user of the first computing device a
`graphic user-interface that at least has the following
`reply options . . .”
`First, Makela does not disclose presenting a user with a GUI that presents
`
`reply options in response to receiving an incoming call. See EX-2004 (“Jeffay
`
`Declaration”) at ¶ 93. While Makela discloses “a selection made by the user,”
`
`allowing the user to “answer the call normally or give a certain key command that
`
`means sending a short message,” it fails to disclose the presentation of any GUI in
`
`response to receiving an incoming call that presents options for sending a message.
`
`See Jeffay Declaration at ¶ 92-93; APPLE-1004 at 3:27-38, 5:35-36. Moreover,
`
`Petitioner does not contend that Moran discloses presenting the user with a graphic
`
`user-interface as recited. See Jeffay Declaration at ¶ 94; see also EX-2006 at 89:20-
`
`90:1.
`
`Second, Makela is directed exclusively to inserting pre-formulated, stored,
`
`content for the message. See Jeffay Declaration at ¶ 96; see also EX-2004 at ¶ 96.
`
`Indeed, Petitioner’s own expert repeatedly admitted that Makela only discloses the
`
`ability for the user receiving an incoming call to respond to the call by selecting a
`
`precomposed message that was created and stored in the device at some point prior
`
`to the incoming call.
`
`Q: [I]s there any disclosure in Makela that the message sent by the user
`in response to an incoming call is anything other than a message
`
`9
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`
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`Case IPR2018-01279
`
`previously stored by the user before the incoming call? Yes or no,
`please.
`THE WITNESS: The specification describes messages that have been
`composed ahead—previously by the user with the ability to choose
`from them.
`
`EX-2006 at 112:18-113:4; see also id. at 128:8-130:9; id. at 133:11-20.
`
`Accordingly, Makela does not have any disclosure related to message responding,
`
`“wherein the message responding option allows . . . manual composition of all the
`
`content of the message”—let alone a GUI option allowing selection of a manual
`
`composition option. See, e.g., Jeffay Declaration at ¶¶ 91-107. The claims of
`
`Makela, therefore, cannot possibly cover subject matter (i.e., related to composing
`
`that is outside the scope of the invention described in the specification. See EON
`
`Corp. IP Holdings LLC v. Silver Spring Networks, Inc., 815 F.3d 1314 (Fed. Cir.
`
`2016) (holding that the meaning of a claim term must be tethered to the invention
`
`described in the specification). Moreover, Petitioner does not contend that Moran
`
`discloses presenting the user with a graphic user-interface as recited. See Jeffay
`
`Declaration at ¶ 94; see also EX-2006 at 89:20-90:1.
`
`Third, Pirskanen does not even disclose or suggest responding to an incoming
`
`call with a message response, so it cannot remedy the failure of Makela and Moran to
`
`disclose “in response to receiving an incoming call . . . presenting a user of the first
`
`computing device a graphic user-interface that at least has the following reply options .
`
`10
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`Case IPR2018-01279
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`. . (ii) message responding to the incoming call by sending a message to a user of the
`
`second computing device” as recited in substitute claim 26. See, e.g., Jeffay Declaration
`
`at ¶¶ 96, 107. Even if Pirskanen is only being used to disclose a pop-up window that
`
`can be displayed in response to an incoming call, which does not fill in the missing
`
`disclosure of Makela and Moran, it fails there as well. While Petitioner points to the
`
`“pop-up” menus in FIGS. 10 and 14 to try to fill in the missing limitations, Petitioner’s
`
`expert admits there is no disclosure in Pirskanen that the menus of FIGS. 10 and 14 are
`
`displayed in response to an incoming call. See EX-2025 (“Cooperstock Transcript”) at
`
`84:8 - 87:3. Paragraph [0079] is the only section of Pirskanen that discloses an
`
`incoming call notification, but it does not disclose presenting the user of the first
`
`computing device with a GUI with any of the claimed reply options. Moreover, FIGS.
`
`10 and 14 do not disclose displaying a graphic user-interface in response to an incoming
`
`call. See Cooperstock Transcript at 85:15 - 87:3. Accordingly, none of Makela, Moran,
`
`or Pirskanen disclose “presenting a user of the first computing device a graphic user-
`
`interface” that has the reply options recited in claim 26.
`
`(ii) “while not answering the incoming call, enabling the
`user of the first computing device to manually compose
`all of the content of the message”
`No prior art reference of record discloses “while not answering the incoming
`
`call, enabling the user of the first computing device to manually compose all of the
`
`content of the message.” As discussed in the preceding section, Makela is directed
`
`11
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`Case IPR2018-01279
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`exclusively to inserting pre-formulated, stored content for the message, see Jeffay
`
`Declaration at ¶ 96; APPLE-1004 at 3:15-19; EX-2006 at 112:18-113:4; EX-2006
`
`at 112:18-113:4; see also id. at 128:8-130:9; id. at 133:11-20, and teaches away from
`
`manually composing all of the content of the message in response to an incoming
`
`call. See Jeffay Declaration at ¶ 106; EX-2004 at ¶ 106. The claims of Makela,
`
`including claims 27-28, therefore, cannot possibly cover subject matter (i.e., related
`
`to composing) that is outside the scope of the invention described in the
`
`specification. See EON Corp. IP Holdings LLC v. Silver Spring Networks, Inc., 815
`
`F.3d 1314 (Fed. Cir. 2016) (holding that the meaning of a claim term must be
`
`tethered to the invention described in the specification). Moran does not even
`
`disclose an incoming call, let alone enabling a user of the first computing device to
`
`manually compose a message while not answering an incoming call. See Jeffay
`
`Declaration at ¶ 107; EX-2004 at ¶ 107. Pirskanen does not disclose composing a
`
`message in response to an incoming call, as is required in substitute claim 26.
`
`Indeed, Petitioner’s own expert appears to admit so. See Cooperstock Transcript at
`
`84:8 - 87:3. Accordingly, Pirskanen fails to remedy the missing disclosure of
`
`Makela and Moran with regards to the feature “while not answering the incoming
`
`call, enabling the user of the first computing device to manually compose all of the
`
`content of the message.”
`
`12
`
`
`
`Date: October 30, 2019
`
`/Brian Oaks/
`
`Case IPR2018-01279
`
`Brian W. Oaks, Reg. No. 44,981
`Baker Botts L.L.P.
`98 San Jacinto Blvd., Suite 1500
`Austin, Texas 78701
`Telephone: (512) 322-5470
`Facsimile: (512) 322-3621
`
`Eliot Williams, Reg. No. 50,822
`Baker Botts L.L.P.
`1001 Page Mill Road,
`Building One, Suite 200
`Palo Alto, California 94304-1007
`
`Chad Walters, Reg. No. 48,022
`Charles Yeh, Reg. No. 63,440
`Baker Botts L.L.P.
`2001 Ross Avenue, Suite 900
`
`Jessica W. Lin, Reg. No. 69,920
`Joseph Akalski, Reg. No. 76,783
`Baker Botts L.L.P.
`30 Rockefeller Plaza
`
`Puneet Kohli, Pro Hac Vice
`Baker Botts L.L.P.
`98 San Jacinto Blvd., Suite 1500
`Austin, Texas 78701
`
`Counsel for Patent Owner
`
`13
`
`
`
`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on October 30,
`
`2019, a complete and entire copy of this PATENT OWNER’S REPLY TO
`
`PETITIONER’S OPPOSITION TO MOTION TO AMEND UNDER 37 C.F.R.
`
`§ 42.121 was served via electronic mail to Petitioner at:
`
`W. Karl Renner, IPR39521-0050IP1@fr.com,
`Thomas A. Rozylowicz, PTABInbound@fr.com,
`Sara C. Fish, sfish@fr.com,
`axf-ptab@fr.com,
`rozylowicz@fr.com,
`riffe@fr.com,
`tkodish@fr.com,
`dsmith@fr.com
`(referencing No. 39521-0050IP1).
`
`/Brian Oaks/
`Brian W. Oaks, Reg. No. 44,981
`Baker Botts L.L.P.
`98 San Jacinto Blvd., Suite 1500
`Austin, Texas 78701
`Telephone: (512) 322-5470
`Facsimile: (512) 322-3621
`
`Lead Counsel for Patent Owner
`
`
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