UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS AMERICA, INC.
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`Petitioner
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`v.
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`UNILOC LUXEMBOURG, S.A.1
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`Patent Owner
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`IPR2018-01664
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`PATENT 8,872,646
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`PATENT OWNER REPLY TO PETITIONER’S OPPOSITION
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`TO PATENT OWNER’S MOTION TO AMEND
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`1 The owner of this patent is Uniloc 2017 LLC.
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS AMERICA, INC.
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`Petitioner
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`v.
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`UNILOC LUXEMBOURG, S.A.1
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`Patent Owner
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`IPR2018-01664
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`PATENT 8,872,646
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`PATENT OWNER REPLY TO PETITIONER’S OPPOSITION
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`TO PATENT OWNER’S MOTION TO AMEND
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`1 The owner of this patent is Uniloc 2017 LLC.
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`IPR2018-01664
`Uniloc’s Reply (Paper 13)
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`Table of Contents
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`I.
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`II.
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`INTRODUCTION .................................................................................... 1
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`PETITIONER FAILED TO PROVE CLAIM 23 IS
`UNSUPPORTED ...................................................................................... 1
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`III.
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`PETITIONER FAILED TO PROVE UNPATENTABILITY ................. 4
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`A.
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`Claim Construction ......................................................................... 4
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`1.
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`Petitioner’s obviousness challenge relies on an
`incorrect construction for “motion data” .............................. 5
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`B. No obviousness for limitations directed to the “glitches”
`term ................................................................................................. 6
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`1. McMahan’s “error” is distinguishable from
`“glitches” .............................................................................. 6
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`2. McMahan does not remove “glitches” as claimed ............... 8
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`3.
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`Petitioner’s alternative reliance on Hyatt is
`unavailing ............................................................................. 8
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`C. No obviousness for limitations reciting the “dominant
`axis” term ...................................................................................... 11
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`CONCLUSION ....................................................................................... 13
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`IV.
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`ii
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`IPR2018-01664
`Uniloc’s Reply (Paper 13)
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`I.
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`INTRODUCTION
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`Uniloc 2017 LLC (“Uniloc” or “Patent Owner”) hereby replies to Petitioner’s
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`Opposition (“Opposition” or “Opp.”, filed as Paper 11) to Uniloc’s Motion to
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`Amend U.S. Patent No. 8,872,646 (“the ’646 patent”), which seeks to replace
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`challenged claim 22 with proposed substitute claim 23.
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`Petitioner does not dispute that substitute claim 23 does not enlarge claim
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`scope and does respond to a ground of unpatentability in the trial. The only dispute
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`Petitioner raises against entering the amendment is that the phrase “within an
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`operational range” allegedly lacks written description support. Opp. 1‒5. Petitioner
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`fails to meet its burden of proof on this issue. Accordingly, the Motion should be
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`granted as satisfying all requirements for entry of the amendment. Petitioner also
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`fails to meet its burden to prove obviousness of substitute claim 23.
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`II.
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`PETITIONER FAILED TO PROVE CLAIM 23 IS UNSUPPORTED
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`Petitioner failed to prove that substitute claim 23 is unsupported by the
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`specification of the application as originally filed. The Federal Circuit has instructed
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`that a petitioner challenging the patentability of a proposed amended claim bears the
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`burden of proof “for questions of indefiniteness, as with other questions of
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`unpatentability.” Bosch Auto. Serv. Sols., LLC v. Matal, 878 F.3d 1027, 1040 (Fed.
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`Cir. 2017), as amended on reh’g in part (Mar. 15, 2018).
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`The only claim language Petitioner identified as allegedly lacking sufficient
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`written description support is the phrase “within an operational range.” Opp. 1‒5.
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`This phrase must be understood at least within the fuller context of “the one or more
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`glitches each indicating a respective detected motion that is both within an
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`1
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`IPR2018-01664
`Uniloc’s Reply (Paper 13)
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`operational range of the motion sensor and outside an acceptable range,” as recited
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`in claim 23. Thus, it is the respective detected motion that is within an operational
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`range of the motion sensor, yet outside an acceptable range. Petitioner glosses over
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`this informative context, and corresponding disclosure in the specification as
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`originally filed, in alleging there is “no written description support.” Opp. 1.
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`To be clear, the disputed issue here is not whether the specification as
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`originally filed requires, in all disclosed examples, that a glitch must be defined as
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`encompassing a detected motion that is within the operational range of the motion
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`sensor. Rather, the only issue raised by Petitioner’s challenge is whether there is
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`sufficient written description support for “within an operational range.” Opp. 1‒5.
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`Even one disclosed embodiment may provide sufficient written description support;
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`and Uniloc had identified several that Petitioner failed to even acknowledge.
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`Notably absent from Petitioner’s challenge, for example, is any direct rebuttal
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`to the embodiment summarized in Uniloc’s Motion as follows:
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`For example, the original application discloses “glitch correcting logic
`235 further may be used to discard non-human motions” that are
`nevertheless accurately detectable by the sensor. EX1002, pp. 12-13, ¶
`21. This example is further explained in the context of “a device [that]
`is not being used but is in a moving vehicle.” Id. While the vehicle’s
`motion is measurable by the sensor, it is considered a glitch that “can
`be discarded as not fitting the signature of human motion.” Id.
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`Mot. (Paper 10) 5; see also id., 12‒13 (“To be clear, the data influenced by the
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`vehicle’s motion is not inherently deemed an impossible error of the sensor. Rather,
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`the data is presumably accurately measured yet not within a predetermined range
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`indicative of human motion.”) (citations omitted).
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`2
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`IPR2018-01664
`Uniloc’s Reply (Paper 13)
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`Petitioner mischaracterized the embodiment summarized in the block
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`quotation above as merely addressing “data outside a pre-determined range of
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`acceptable data.” Opp. 3 (quoting Ex. 1002, pp. 12-13, ¶21). Petitioner’s selective
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`quotation addresses a different embodiment introduced with its own respective
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`phrase “[i]n one embodiment.” See Ex. 1002, pp. 12-13, ¶21. The same paragraph
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`expressly introduces another embodiment directed to detecting and discarding
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`glitches as representative of “non-human motions.” Id. One disclosed example of
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`non-human motion is “a vehicle’s motion.” Id. Petitioner has the burden of proof,
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`yet its Opposition fails to address this distinct embodiment directed to discarding as
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`glitches certain motion (e.g., a “vehicle’s motion”) that is accurately detected, yet
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`within a range deemed to be non-human. Mot. 5; see also id., 12‒13.
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`Petitioner also failed to address additional example support for the challenged
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`claim language, which Uniloc had summarized in its Motion as follows:
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`The original application provides another example in the context of
`removing a measured reading of “64 feet per second squared (equivalent
`to 2 g)”. Id., pp. 19‒20, ¶ 52. In this example, a “glitch” is identified not
`because the motion data is outside the operational range of the sensor,
`but rather because of the specific context of immediately “going from
`idle (e.g., no motion) to moving at [such] an acceleration.” Id.
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`Mot. 5‒6. It remains undisputed that, in this example, the measurement of “64 feet
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`per second squared” is a detected motion within the operational range of the motion
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`sensor. Petitioner also did not dispute that a glitch is identified in this example not
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`because of the measured reading itself being outside an operational range, but rather
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`because of the change between readings within the operational range—i.e., “going
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`from idle (e.g., no motion) to moving at [such] an acceleration.” Id. (citing Ex. 1002,
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`3
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`IPR2018-01664
`Uniloc’s Reply (Paper 13)
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`pp. 19‒20, ¶52) The change between readings would be irrelevant if “64 feet per
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`second squared” was a reading outside the operational range of the sensor.
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`Neither the Petition nor its attached declaration provide any rebuttal to the
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`above reasoning. At most, Petitioner offered, without further explanation, the partial
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`quotation that the above embodiment describes “datum that indicates a motion
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`outside an acceptable range.” Opp. 3 (partially quoting Ex. 1002, pp. 14‒15, ¶52).
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`That this embodiment offers the measured reading of “64 feet per second squared”
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`as “a datum that indicates a motion” only further supports the understanding that the
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`indicated motion is within the operational range of the motion sensor. Id. Neither
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`Petitioner nor its declarant offer any reasoning to conclude otherwise.2
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`III. PETITIONER FAILED TO PROVE UNPATENTABILITY
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`A. Claim Construction
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`Petitioner does not dispute that entry of the amendment resolves the claim
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`construction dispute injected by the Petition over the “glitches” term. Mot. 9‒10.
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`Petitioner also does not dispute that its prior “claim construction arguments for the
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`‘logic to’ limitations are irrelevant because no party asserts 35 U.S.C. § 112, ¶ 6
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`should apply.” Id. 11. In short, Petitioner newly alleges that “motion data” is now
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`the only disputed term requiring construction. Opp. 6‒7. Petitioner’s construction
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`for “motion data” should be rejected; and Petitioner’s obviousness theory is tainted
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`2 Petitioner fails to explain why it interpreted the phrase “within an operational range
`[of the motion sensor]” to be a negative limitation. See Opp. 4. The affirmative
`recitation “within an operational range [of the motion sensor]” does not invoke the
`authority Petitioner cited. Id. (citing Santarus, Inc. v. Par Pharm., Inc., 694 F.3d
`1344, 1350-51 (Fed. Cir. 2012)).
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`4
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`IPR2018-01664
`Uniloc’s Reply (Paper 13)
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`by reliance on an incorrect claim construction. See Mentor Graphics Corp., v.
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`Synopsys, Inc., IPR2014-00287, Paper 31 at 11 (June 11, 2015), aff'd sub nom.
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`Synopsys, Inc. v. Mentor Graphics Corp., 669 Fed. Appx. 569 (Fed. Cir. 2016).
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`1.
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`Petitioner’s obviousness challenge relies on an incorrect
`construction for “motion data”
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`Petitioner incorrectly asserts, without explanation, that Uniloc’s Motion
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`“implicitly” injected a claim construction dispute over the “motion data” term,
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`ostensibly by advancing an example distinction over McMahan. Opp. 6.
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`Specifically, Petitioner pointed to Uniloc’s observation that McMahan “replaces
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`errors with contrived data, which is not a removal of one or more glitches, much
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`less one that results in the alleged ‘motion data containing less data.’” Mot. 14; see
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`also Opp. 6 (partially quoting the same).
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`Petitioner evidently failed to recognize that this example distinction over
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`McMahan expressly focuses on the “glitches” term, as explicitly defined by
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`amendment. Petitioner also overlooks that the quantitative comparator “less data”
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`does not include a “motion” qualifier. In advancing its incorrect claim construction
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`for “motion data,” Petitioner also fails to defend or even explain its apparent position
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`that a collection of generated motion data containing a certain amount of data would
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`somehow quantitatively contain “less data” as a result of replacing one value with
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`another. Nor does Petitioner explain how such a strained interpretation is compelled
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`by the construction it seeks for the “motion data” term.
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`Even if Petitioner’s manufactured dispute turned on whether Petitioner’s
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`construction for the “motion data” term is correct, and Petitioner fails to explain
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`5
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`IPR2018-01664
`Uniloc’s Reply (Paper 13)
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`why this is so, resolution is simple. Petitioner seeks to construe “motion data” to
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`mean virtually any “data generated by the motion sensor.” Opp. 7. Petitioner
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`essentially seeks to rewrite “a motion sensor to detect motion along three axes and
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`generate motion data” to recite, instead, a motion sensor to detect motion along three
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`axes and generate any data. The claim language proscribes such a construction.
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`Petitioner’s construction fails to recognize that the qualifier “motion” in the
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`couplet “motion data” should be given meaningful effect. Pause Technology, LLC
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`v. TiVo, Inc., 419 F.3d 1326, 1334 (Fed. Cir. 2005) (citing Merck & Co. v. Teva
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`Pharms. USA, Inc., 395 F.3d 1364, 1372 (Fed. Cir. 2005) (“A claim construction
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`that gives meaning to all the terms of the claim is preferred over one that does not.”).
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`This canon is especially applicable here, given the context in which “motion
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`data” is recited. Petitioner does not dispute that claim 23 derives antecedent basis
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`for “the motion data” from the phrase “a motion sensor to detect motion along three
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`axes and generate motion data.” Opp. 7 (citing Mot. 10). This definitive context
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`proscribes interpreting “motion data” as referring to any data generated by the
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`motion sensor. Rather, the “motion” qualifier confirms “motion data” refers to a
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`specific type of data—i.e., data that represents the motion detected along three axes.
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`Thus, at a minimum, Petitioner’s construction should be rejected as failing to give
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`meaningful effect to the “motion” qualifier in “motion data.”
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`B. No obviousness for limitations directed to the “glitches” term
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`1. McMahan’s “error” is distinguishable from “glitches”
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`Petitioner’s primary theory for the limitations directed to the “glitches” term
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`relies on “the McMahan prior art combination in the petition.” Opp. 9. Uniloc
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`6
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`IPR2018-01664
`Uniloc’s Reply (Paper 13)
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`explained why the mapping of McMahan’s “error” applied in the Petition fails to
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`satisfy multiple limitations directed to the “glitches” term. Mot. 11‒14.
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`One of the patentable distinctions is laid bare, for example, in the following
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`definitive description of McMahan’s error quoted in the Petition: “[w]hen the output
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`of sensor 102 is not within the expected range of its normal operation, it is presumed
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`that the output is an error. This means that the output of the sensor is not an accurate
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`reflection of the stimulus that the sensor is designed to monitor.” Pet. 31 (quoting
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`McMahan (Ex. 1005), 4:26‒30) (emphasis added). This definitive description of the
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`“error” in McMahan, which Petitioner relied upon in presenting its mapping, is
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`plainly distinguishable from the requirement that “the one or more glitches each
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`indicating a respective detected motion that is both within an operational range of
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`the motion sensor and outside a predetermined range of acceptable motion data.”
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`Petitioner’s Opposition points to only two passages in McMahan in defense
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`of its mapping of McMahan’s “error” onto the “glitches” term. Neither are availing.
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`Petitioner first emphasizes the statement that “sensor 102 . . . is subject to a definable
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`range for output signals such that an anomalous event may be detected based on the
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`output of the sensor.” Opp. 8 (quoting McMahan, 3:37‒40). This statement is
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`helpful only to Uniloc in that it confirms that McMahan’s “error” is an output of
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`sensor 102 that is not within the “expected” or “definable” operational range.
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`Uniloc’s Motion pointed to the example in McMahan (which Petitioner ignores)
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`where the operational range was “from 17.5 to 21 in a 0.5 ms interval,” such that a
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`value over 21, for example, would be deemed an “error.” Mot. 12.
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`Petitioner’s reliance on claim language recited in McMahan is likewise
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`7
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`IPR2018-01664
`Uniloc’s Reply (Paper 13)
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`unavailing. Opp. 8‒9. None of the quoted claim language purports to redefine
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`McMahan’s “error.” On the contrary, as explained above, McMahan’s recitation that
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`“an output of the sensor . . . is outside the normal operating range” is plainly
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`distinguishable from the definition of the “glitches” term recited in claim 23. Id.
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`2. McMahan does not remove “glitches” as claimed
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`At least because Petitioner fails to prove McMahan’s “error” maps onto the
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`claimed “glitches” term, the alleged removal of an “error” cannot possibly satisfy
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`limitations directed to glitch removal. Mot. 13‒14. Additional deficiencies arise, for
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`example, from the requirement that “the motion data containing less data as a result
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`of the removal of the one or more glitches from the motion data.” Id. Petitioner has
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`not and cannot meet its burden of proof concerning these additional deficiencies by
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`relying on an incorrect claim construction for “motion data.” See §III.A.1, supra.
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`3.
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`Petitioner’s alternative reliance on Hyatt is unavailing
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`Petitioner’s alternative reliance on Hyatt fails, at a minimum, to establish
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`obviousness of a “glitch corrector” that removes “one or more glitches from the
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`motion data,” which results in the “motion data containing less data.” A plain reading
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`of this claim language readily reveals that any determined “one or more glitches”
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`must be included as part (but not all) of a collection of generated “motion data” and
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`that the “motion data” must further include non-glitch data. This is because, as a
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`result of removing the glitch(es) from the motion data, the motion data is recited as
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`still “containing . . . data,” albeit “less data” than before the claimed removal.
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`In mapping Hyatt onto “the motion data containing less data as a result of the
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`removal of the one or more glitches from the motion data,” Petitioner relies
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`8
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`IPR2018-01664
`Uniloc’s Reply (Paper 13)
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`exclusively on quotations directed to the signal processing circuit 62 performing
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`processing on one signal at a time and in a manner which results in blocking the
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`signal in its entirety from being input to the control circuit 42. Opp. (Paper 11)
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`14‒15 (citing Hyatt (Ex. 1017), ¶¶58‒59) (emphasis added); see also id., 9‒10.
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`Petitioner then argues, without explanation, that “removal of a signal . . . from the
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`control circuit 42” maps onto the requirement “the motion data containing less data
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`as a result of the removal,” as recited in substitute claim 23. Id.
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`Petitioner’s mapping of Hyatt is deficient on its face. A signal that is never
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`provided to control circuit 42 (because it is blocked/removed by signal processing
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`circuit 62) cannot subsequently be removed from control circuit 42, much less
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`removed from a collection of “motion data” that includes non-glitch data.
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`Accordingly, at a minimum, Petitioner fails to prove that its mapping of Hyatt
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`renders obvious “the motion data containing less data as a result of the removal of
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`the one or more glitches from the motion data,” as recited in substitute claim 23.
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`Scrutiny of the embodiment Petitioner and its declarant rely upon only
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`underscores the patentable distinction. Petitioner and its declarant both first quote
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`the statement in Hyatt that “[t]he motion signal processing circuit 62 may block from
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`the control circuit 42 signals representing brief or casual movement of the mobile
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`phone 10.” See, e.g., Ex. 1018 ¶92 (quoting Hyatt (Ex. 1017), ¶58) (emphasis
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`original); Opp. 14 (quoting and emphasizing the same); see also Opp. 9 (“Hyatt
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`discloses ‘a motion signal processing circuit’ that ‘filter[s] the output of the motion
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`sensor 60 or...condition[s] the output using known techniques such that the
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`indication of motion or an appropriate signal to represent motion to the control
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`9
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`IPR2018-01664
`Uniloc’s Reply (Paper 13)
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`circuit 42 only is provided in instances where the user decidedly moves the mobile
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`phone 10 in a prescribed manner.”) (quoting Ex. 1017 ¶58) (emphasis added). Hyatt
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`offers additional context by further explaining (in the same paragraph) that “the
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`motion signal processing circuit 62 . . . processes and conditions the signal prior to
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`[the signal] being input to the control circuit 42.” Hyatt (Ex. 1017), ¶58 (emphasis
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`added). The embodiment Petitioner identified, therefore, discloses blocking an entire
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`signal in a manner that prevents it from being provided to control circuit 42.
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`Petitioner and its declarant next quote Hyatt’s description of the low pass filter
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`64 of signal processing unit 62. Opp. (Paper 11) 14‒15 (citing Hyatt (Ex. 1017),
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`¶¶58‒59). Consistent with the first quotation, the description of the low pass filter
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`identifies the word “removes” as a synonym to the word “blocking” and in the
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`context of preventing a signal from reaching the control circuit 42. Hyatt (Ex. 1017),
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`¶59 (“The low pass filter 64 removes or blocks signals . . . .”). Petitioner concedes
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`Hyatt discloses that any signal that is blocked/removed by low pass filter 64 (of
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`signal processing unit 62) is not provided on line 72 to the control circuit 42. Id.;
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`see also Ex. 1018 ¶40 (“To ‘block from the control circuit’ [42] signals not
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`indicative of ‘intended motion,’ ‘motion signal processing circuits 62a, 62b, 62c . .
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`. includes a low pass filter 64 and either a threshold detector 66, amplitude detector
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`68, or frequency detector 70,’ as shown in Figure 3-5 of Hyatt.”) (emphasis added).
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`Thus, the specific embodiment Petitioner and its declarant rely upon, by their
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`selective quotations from paragraphs 58 and 59 of Hyatt, is directed to processing
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`performed by the signal processing unit 62 that prevents a signal in its entirety from
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`being provided as input to the control circuit 42. A signal that is never provided to
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`10
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`IPR2018-01664
`Uniloc’s Reply (Paper 13)
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`control circuit 42 (because it is blocked/removed by signal processing circuit 62)
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`cannot subsequently be removed from control circuit 42, much less removed from a
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`collection of generated “motion data” that includes non-glitch data, such that “the
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`motion data contain[s] less data as a result of the removal of the one or more glitches
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`from the motion data,” as recited in substitute claim 23.
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`C. No obviousness for limitations reciting the “dominant axis” term
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`Petitioner does not dispute that the combination of Pasolini and Goldman fails
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`to disclose certain original limitations reciting the “dominant axis” term (e.g., the
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`original “power logic” limitations). Mot. 14‒17; Opp. 17‒18. In a failed attempt to
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`cure these deficiencies, Petitioner newly presents redundant theories based on
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`Marvit and Fabio (in the alternative), without justifying the redundancy and without
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`informing the Board that both references appear on the face of the ’646 patent.
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`Uniloc should not be expected to address Petitioner’s unjustifiably redundant
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`arguments, especially given that (1) Petitioner raises them as a do-over in addressing
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`unamended claim language, though its Response should have been limited to new
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`issues arising from the amendment; (2) the USPTO has already found the broader
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`original language patentable over Pasolini,3 Marvit, and Fabio; and (3) the rules limit
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`this Reply to only twelve pages. In any event, the redundant challenges are deficient.
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`Petitioner newly proposes modifying Pasolini to incorporate Marvit’s
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`“dominant axis of motion.” Opp. 18 (citations omitted). At least Because Marvit’s
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`“dominant axis of motion” is defined as the axis experiencing a greater amount of
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`3 The application that issued as Pasolini was published as U.S. Pub. No.
`US2004/0172167A1, which also appears on the face of the ’646 patent.
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`11
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`IPR2018-01664
`Uniloc’s Reply (Paper 13)
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`movement, as opposed to which axis has a largest effect of gravity among three axes,
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`incorporating this distinguishable feature into Pasolini would not render obvious
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`even the unamended language reciting the “dominant axis” term. Moreover,
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`Petitioner alleges that Pasolini would still detect movement along the vertical axis,
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`even if modified by Marvit. Opp. 19. Yet Petitioner leaves undisputed Uniloc’s
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`reasoning as to why “merely detecting a change along the vertical axis does not
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`disclose what the [original] claim language expressly requires.” Mot. 14‒17.
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`Evidently recognizing the weakness of its new reliance on Marvit, Petitioner
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`secondarily offers Fabio (presumably the weaker of the two) in raising a redundant
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`argument which also purports to address the unamended “power logic” limitations.
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`Opp. 23. However, neither Fabio nor Pasolini disclose “a power logic to move the
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`device from the inactive state to an active state upon detection of a change in the
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`dominant axis which is the axis experiencing the largest effect of gravity,” as recited
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`in the unamended claim language. The unamended “upon” condition recites an
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`explicit interrelationship which is itself meaningfully limiting yet not disclosed in
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`any cited reference. Thus, even if the Board is inclined to consider the merits of
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`Petitioner’s multiple do-over attempts, each attempt fails to establish obviousness of
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`at least the unamended claim language Petitioner purported to address.
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`12
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`IPR2018-01664
`Uniloc’s Reply (Paper 13)
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`IV. CONCLUSION
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`For the reasons set forth above, and in the Motion, Uniloc respectfully
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`requests that the Board grant Uniloc’s Motion to Amend and issue substitute claim
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`23.
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`Date: October 11, 2019
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`Respectfully submitted,
`By: /Brett A. Mangrum/
`Brett A. Mangrum; Reg. No. 64,783
`Attorney for Patent Owner
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`13
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`IPR2018-01664
`Uniloc’s Reply (Paper 13)
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.6(e), the undersigned certifies that service of the
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`foregoing was made on Petitioner via Patent Review Processing System (PRPS)
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`and/or email as detailed below:
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`Naveen Modi
`Joseph E. Palys
`Phillip W. Citroën
`Michael A. Wolfe
`PH-Samsung-Uniloc-IPR@paulhastings.com
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`Date: October 11, 2019
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`Respectfully submitted,
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`By: /s/ Brett A. Mangrum
`Brett A. Mangrum; Reg. No. 64,783
`Attorney for Patent Owner
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`i
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