`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`Panasonic Avionics Corp.,
`Petitioner
`
`vs.
`
`Linksmart Wireless Technology, LLC,
`Patent Owner
`
`———————
`
`IPR2019-00043
`
`U.S. Patent No. RE46,459
`
`_______________
`
`
`PETITIONER’S REQUEST FOR REHEARING
`
`OF THE DECISION DENYING INSTITUTION
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`
`
`

`

`IPR2019-00043 – RE46,459
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`
` Petitioner’s Request for Rehearing
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`
`TABLE OF CONTENTS
`PETITIONER’S EXHIBIT LIST ........................................................................ ii
`I.
`Introduction and Relief Requested .................................................................... 1
`II. Legal Standard ................................................................................................... 1
`III. ARGUMENT ..................................................................................................... 2
`A.
`“Redirection” feature of the “redirection server” ...................................... 2
`1. The Decision overlooked Malkin’s disclosure of redirecting
`a user’s request to a different network location. .............................. 2
`2. The Decision overlooked Malkin’s second technique for
`redirecting a packet .......................................................................... 5
`3. The Decision misapprehended Petitioner’s mapping of the
`prior art to the claimed “redirection server.” ................................... 6
`4. The Decision misapprehended the lack of any limitation
`relating to whether packets enter a network. ................................... 7
`“User’s rule set correlated to a temporarily assigned network
`address” ..................................................................................................... 8
`1. The Decision misapprehended Abraham’s user rule set,
`which includes global rules that are modified while
`correlated to the user’s temporarily assigned network
`address. ............................................................................................. 8
`2. The Decision overlooked Petitioner’s design choice
`argument. ........................................................................................11
`C. The Decision misconstrued “redirection server” by overlooking
`the ’459 patent’s multiple examples of “redirection.” ............................12
`IV. Conclusion .......................................................................................................14
`
`
`
`B.
`
`
`
` i
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`IPR2019-00043 – RE46,459
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` Petitioner’s Request for Rehearing
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`
`PETITIONER’S EXHIBIT LIST
`Unchanged from October 9, 2018
`
`Ex. 1001
`
`Ex. 1002
`
`Ex. 1003
`
`Ex. 1004
`
`Ex. 1005
`
`Ex. 1006
`
`Ex. 1007
`
`Ex. 1008
`
`Ex. 1009
`
`Ex. 1010
`
`Ex. 1011
`
`Ex. 1012
`
`Ex. 1013
`
`Ex. 1014
`
`Ex. 1015
`
`U.S. Patent No. RE46,459 to Ikudome et al. (“the ’459 Patent”)
`
`Prosecution File History of U.S. Patent No. RE46,459
`
`Declaration of Dr. Bill Lin under 37 C.F.R. § 1.68
`
`Curriculum Vitae of Dr. Bill Lin
`
`U.S. Patent No. 5,983,270 to Abraham et al. (“Abraham”)
`
`U.S. Patent No. 6,247,054 to Malkin (“Malkin”)
`
`European Patent No. EP0762707A2 to Telia (“Telia”)
`
`File History of U.S. Patent No. 6,779,118
`
`Prosecution File History of Ex Parte Reexam control no. 90/009,301
`
`Prosecution File History of Ex Parte Reexam control no. 90/011,485
`
`Prosecution File History of Ex Parte Reexam control no. 90/012,149
`
`Prosecution File History of Ex Parte Reexam control no. 90/012,342
`
`Prosecution File History of Ex Parte Reexam control no. 90/012,378
`
`Prosecution File History of Inter Partes Reexam control no.
`95/002,035
`
`Comer, D., INTERNETWORKING WITH TCP/IP (Prentice Hall, 3rd ed.
`1995) (selected pages)
`
`Ex. 1016
`
`U.S. Patent No. 5,944,824 to He (“He”)
`
`Ex. 1017
`
`James E. Gaskin, CORPORATE POLITICS AND THE INTERNET (Prentice
`Hall 1997) (selected pages)
`
`Ex. 1018
`
`Declaration of Dr. Ingrid Hsieh-Yee
`
`
`
`ii
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`IPR2019-00043 – RE46,459
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` Petitioner’s Request for Rehearing
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`
`INTRODUCTION AND RELIEF REQUESTED
`Petitioner respectfully requests that the Decision on Institution (Paper 7) be
`
`I.
`
`withdrawn and a new decision be issued to institute the requested inter partes
`
`review. The Decision provided two rationales for declining to institute the
`
`requested inter partes review:
`
`1.
`
`that Malkin allegedly failed to teach “redirection” as performed by the
`
`claimed “redirection server,” (Decision at 17-18) and
`
`2.
`
`that Abraham’s global rules are allegedly not “correlated to a
`
`temporarily assigned network address” (Decision at 19-20).
`
`For each of these rationales, the Decision overlooked or misapprehended
`
`multiple aspects of the evidence discussed in the Petition. Any one of the points
`
`raised below is sufficient to vacate each non-institution rationale. Additionally, the
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`Decision adopted an erroneous preliminary construction of “redirection server” by
`
`overlooking or misapprehending portions of the ’459 patent’s specification
`
`highlighted by both Petitioner and Patent Owner.
`
`II. LEGAL STANDARD
`A request for rehearing “must specifically identify all matters the party
`
`believes the Board misapprehended or overlooked, and the place where each
`
`matter was previously addressed in a motion, an opposition, or a reply.” 37 C.F.R.
`
`§ 42.71(d). Upon a request for rehearing, the decision on institution is reviewed for
`
`
`
`1
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`

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`IPR2019-00043 – RE46,459
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` Petitioner’s Request for Rehearing
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`an abuse of discretion. 37 C.F.R. § 42.71(c). An abuse of discretion occurs when a
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`“decision was based on an erroneous conclusion of law or clearly erroneous factual
`
`findings, or . . . a clear error of judgment.” PPG Indus. Inc. v. Celanese Polymer
`
`Specialties Co. Inc., 840 F.2d 1565, 1567 (Fed. Cir. 1988).
`
`III. ARGUMENT
`“Redirection” feature of the “redirection server”
`A.
`The Decision overlooked Malkin’s disclosure of
`1.
`redirecting a user’s request to a different network location.
`The Decision states that “When the NAS detects a user attempting
`
`unauthorized access, Malkin routes the user’s request to redirection server 14
`
`within ISP 16, as shown in Figure 1…. Malkin either allows network access for
`
`authorized user requests or blocks network access for unauthorized user requests,
`
`but it does not redirect a request to another location on the network.” Decision at
`
`17.
`
`These statements misapprehend Malkin’s disclosure and overlook how
`
`“rout[ing] the user’s request” to server 14 meets the Board’s construction of
`
`“redirection.”
`
`First, the Decision’s statement that “Malkin routes the user’s request”
`
`overlooks that within Malkin’s disclosure, it is the Network Access Server (NAS)
`
`that handles the routing of the user’s request. The Petition relied on and cited to
`
`the NAS as teaching the “redirection” feature of the claimed “redirection server.”
`
`
`
`2
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`IPR2019-00043 – RE46,459
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` Petitioner’s Request for Rehearing
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`See Petition at 22, n.3 & 32-33; see also infra, § III.A.3.
`
`Second, Malkin does not merely teach that the NAS “routes” a user’s
`
`request. The Petition highlighted Malkin’s teaching that “NAS 12 may redirect
`
`the subscriber’s request (in the form of a packet)” to a server different from that
`
`specified in the request. Ex. 1006, 2:25-26 (emphasis added, cited in Petition at
`
`32); see also Ex. 1006, Abstract (“NAS… redirects the second [packet]”)
`
`(emphasis added, cited and quoted in Petition at 32). Malkin explains that the
`
`user’s request is for a “requested Internet service,” but the NAS will redirect the
`
`request so that it is delivered to server 14 instead of its intended destination.1 Ex.
`
`1006, 2:12-15 (cited in Petition at 21) & 2:22-27 (cited in Petition at 32); see also
`
`Ex. 1006, 4:15-16 (describing in contrast how, for permitted Internet services, the
`
`“NAS will forward the packets to their respective destinations”).
`
`To the extent that Malkin’s NAS performs some type of “routing” in this
`
`
`1 The Decision characterized Malkin’s redirection as being a form of blocking
`
`(Decision at 17), but that characterization overlooked the fact that redirection
`
`naturally acts as a form of blocking, as redirection prevents a user’s packets from
`
`reaching their originally requested destination. See, e.g., Ex. 1001, 6:64-7:2
`
`(describing how packets directed to the xyz.com domain will be redirected, and
`
`thus, the packets are blocked from reaching the xyz.com domain).
`
`
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`3
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`IPR2019-00043 – RE46,459
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` Petitioner’s Request for Rehearing
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`process, it performs misrouting of packets because the packets are not delivered to
`
`their intended destination; instead, they are redirected and diverted to server 14.
`
`Ex. 1006, Abstract, 1:20-23, & 2:22-27 (cited in Petition at 32). Malkin teaches
`
`modifying and redirecting the user’s packet by encapsulating the original packet in
`
`a new packet that specifies server 14 as its destination. Ex. 1006, 1:38-55 & Fig. 1
`
`(discussed in Petition at 20-22), 4:20-37 (discussed in Petition at 71-72 & 78-79);
`
`see also infra, Section III.A.2.
`
`Thus, in stating that “Malkin routes a user’s request to… server 14,” the
`
`Decision overlooked that Malkin’s NAS redirects a user’s request to server 14,
`
`which is not the network location identified in the user’s request. Thus, Malkin’s
`
`“rout[ing]” of the user’s request to a different, unrequested network location is in
`
`fact a teaching of what the Decision called the “essential function of the redirection
`
`server of the ’459 patent… to redirect users to Internet locations that are different
`
`from those in the user’s request.” Decision at 12. By misnaming Malkin’s packet
`
`redirection function as simply “rout[ing],” the Decision overlooked how that
`
`“rout[ing]” function corresponds exactly with the Decision’s understanding of the
`
`claimed redirection server. Because Malkin teaches modifying a user’s request to
`
`redirect the request to an alternate, unrequested destination, the Decision should
`
`have found that the prior art renders obvious the claimed “redirection server.”
`
`Petitioner respectfully requests correction of the Decision’s error through the
`
`
`
`4
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`IPR2019-00043 – RE46,459
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` Petitioner’s Request for Rehearing
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`issuance of a new decision instituting inter partes review.
`
`The Decision overlooked Malkin’s second technique for
`2.
`redirecting a packet
`The Decision states that “In Malkin, NAS 14 blocks unauthorized network
`
`access by encapsulating the request into a different message, without modifying
`
`the requested destination, and sending the encapsulated message to redirection
`
`server 16.” Decision at 17. The Decision then contrasts this with “the redirection
`
`server in the ’459 patent[, which] modifies a request to access a destination on the
`
`network by changing the requested destination.” Decision at 18.
`
`As discussed above in Section III.A.1, the Decision overlooks the fact that
`
`Malkin’s encapsulation technique results in a modified packet that has a different
`
`destination than the original packet. Additionally, the Decision entirely overlooks
`
`Malkin’s other technique for redirecting a packet: “the NAS will typically remove
`
`the data message (i.e., the request) from the Subscriber’s packet and place it in a
`
`new packet to be sent to” server 14. Ex. 1006, 3:12-14 (cited in Petition at 71).
`
`The Petition argued that this technique results in “replacing the packet’s original
`
`destination address with the address of server 14.” Petition at 78. Thus, Malkin’s
`
`address-replacement approach to redirection “modifies a request to access a
`
`destination on the network by changing the requested destination” (Decision at 18),
`
`and Malkin indisputably teaches the same “redirection” concept disclosed in the
`
`
`
`5
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`IPR2019-00043 – RE46,459
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` Petitioner’s Request for Rehearing
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`’459 patent. For the additional reason that the Decision overlooked the Petition’s
`
`presentation of this alternative approach to redirection in Malkin, Petitioner
`
`respectfully requests issuance of a new Decision instituting the requested inter
`
`partes review.
`
`The Decision misapprehended Petitioner’s mapping of the
`3.
`prior art to the claimed “redirection server.”
`The Decision states in part that “despite its name, Malkin’s redirection
`
`server does not actually redirect the user’s request…. Instead of redirecting the
`
`user to another site on the network, redirection server 14 sends the user a message
`
`that appears to be generated from the user’s requested destination on the network.”
`
`Decision at 17. Because of this, the Board was not persuaded that Malkin’s
`
`“redirection server ‘redirects’ a request as that term is used in the ’459 patent.”
`
`Decision at 17.
`
`These statements misapprehended of Petitioner’s analysis and mapping of
`
`the prior art to the claimed “redirection server.” Petitioner expressly
`
`acknowledged the potentially confusing name of Malkin’s redirection server 14
`
`and stated that server 14 has “different functionality… than the ’459 Patent
`
`requires of the claimed ‘redirection server.’” Petition at 22, n.3.
`
`The Petition stated that “Malkin’s Network Access Server performs packet
`
`redirection like the claimed ‘redirection server.’” Petition at 22, n.3. Thus, the
`
`
`
`6
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`IPR2019-00043 – RE46,459
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` Petitioner’s Request for Rehearing
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`Petition relied on the Network Access Server (NAS) —not server 14—as teaching
`
`the “redirection” technique of the ’459 patent.
`
`Because the Decision misapprehended Petitioner’s claim analysis—and
`
`specifically the reliance on Malkin’s NAS, not server 14, as teaching the
`
`“redirection” technique—Petitioner respectfully requests withdrawal of the
`
`Decision and consideration of the Petition’s arguments.
`
`The Decision misapprehended the lack of any limitation
`4.
`relating to whether packets enter a network.
`The Decision states that Malkin fails to disclose “redirection” because “the
`
`user’s packets never enter the network.” Decision at 17.
`
`This statement misapprehended the term “redirection server” by importing
`
`limitations that are not in the Board’s adopted construction and not supported by
`
`the ’459 patent specification. The Board construed “redirection server” to require
`
`redirection “to a network location that is different from the network location in the
`
`user’s request.” Decision at 12 (emphasis added). Because it refers only to a
`
`network location (and not a network in its entirety), the construction does not
`
`require a user’s packet to enter any particular network, either before or as a result
`
`of redirection. Accordingly, whether Malkin’s user’s packet does or does not enter
`
`a network is not relevant to whether Malkin teaches the “redirection” feature of the
`
`claimed “redirection server.”
`
`
`
`7
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`IPR2019-00043 – RE46,459
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` Petitioner’s Request for Rehearing
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`
`By focusing on the irrelevant issue of whether a user’s packets enter a
`
`network, the Decision overlooked the Petition’s showing that Abraham’s network
`
`server 50 (modified to use Malkin’s redirection technique) is a server that redirects
`
`packets to a different server than that specified in the user’s packets. Petition at 30-
`
`32. In the combination, a user requests a particular Internet service, and instead of
`
`obtaining access to the requested Internet site, the user is redirected to another
`
`destination, such as Malkin’s server 14. Petition at 30-33. This meets the express
`
`terms of the Board’s construction, because server 14 is a “network location [the
`
`location of server 14] that is different from the network location in the user’s
`
`request [the location of the requested Internet service].” See Decision at 12
`
`(construing “redirection server”). Accordingly, Petitioner respectfully requests
`
`that the Decision be withdrawn and a new decision issue to institute the requested
`
`inter partes review.
`
`“User’s rule set correlated to a temporarily assigned network
`B.
`address”
`The Decision misapprehended Abraham’s user rule set,
`1.
`which includes global rules that are modified while correlated to
`the user’s temporarily assigned network address.
`The Decision states that “the periodic updating of the global rules, even
`
`while the user is not connected, demonstrates that at least a portion of the user rule
`
`set is not correlated to the temporarily assigned network address.” Decision at 19.
`
`
`
`8
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`IPR2019-00043 – RE46,459
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` Petitioner’s Request for Rehearing
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`
`This statement misapprehended the claim language, which neither requires
`
`or excludes the updating of a rule set that is not correlated to a temporarily
`
`assigned network address. To the contrary, claim 91 (as an example) requires
`
`“modify[ing] at least a portion of the rule set while the rule set is correlated to the
`
`temporarily assigned network address.” Ex. 1001, 16:42-45 (discussed in Petition
`
`at 40-44). Thus, it is simply irrelevant that Abraham describes updating global
`
`rules even when a user is not logged in.
`
`The Decision further misapprehended the claim language by implicitly
`
`requiring the claimed “user’s rule set” to contain only user-specific rules.
`
`Specifically, the Decision found that global rules, which apply to all users and are
`
`programmed into Abraham’s server even when a user is not connected, are not
`
`“correlated to the temporarily assigned network address”:
`
`Given that Petitioner cites applying the global rules and the user
`rules as applying the user rule set, we are persuaded by Patent
`Owner’s argument that the periodic updating of the global
`rules, even while the user is not connected, demonstrates that
`at least a portion of the user rule set is not correlated to the
`temporarily assigned network address, as required by all the
`challenged claims.
`
`Decision at 19 (emphasis added).
`
`By improperly focusing on what happens when a user is not connected, the
`
`
`
`9
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`

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`IPR2019-00043 – RE46,459
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` Petitioner’s Request for Rehearing
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`Decision overlooks Abraham’s disclosure of the network server’s functionality
`
`when a user is connected and has a temporarily assigned network address.
`
`Abraham states that the network server’s rules include “corporate rules, global
`
`network protocol rules, user rules and time rules, for each user of a computer
`
`connected to the LAN.” Ex. 1005, 3:66-4:2 (quoted in Petition at 34). When a
`
`packet is received from a user, the packet is checked against the global network
`
`protocol rules. Ex. 1005, 44:30-45 (cited in Petition at 34). The global network
`
`protocol rules include timer rules. Ex. 1005, 4:6-9 (cited in Petition at 34). The
`
`global network protocol rules are included in the rules that are applied “as a user
`
`logs into and out of the LAN.” Ex. 1005, 8:23-25 (quoted in Petition at 37).
`
`Because the global network protocol rules are applied to the user’s packets while
`
`the user is logged into the LAN, the global network protocol rules are “correlated”
`
`to the user’s IP address (“temporarily assigned network address”). See Petition at
`
`37 (“The IP address is correlated to Abraham’s user’s rule set in the filter engine
`
`78 because the user’s packets are filtered by the combination of rules stored in
`
`the filter engine 78 while the user is mapped to the IP address.”); see also
`
`Petition at 34 (the rules programmed into the filter engine 78 include global
`
`network protocol rules). Notably, Patent Owner did not dispute that Abraham’s
`
`global rules are applied to a user’s temporarily-assigned IP address. See, e.g., Paper
`
`6 at 22-23 (discussing only Abraham’s behavior when a user does not have a
`
`
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`10
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`IPR2019-00043 – RE46,459
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` Petitioner’s Request for Rehearing
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`temporarily assigned address).
`
`In summary, the Decision overlooked and failed to address Petitioner’s
`
`argument that the entirety of the user’s rule set—including the global network
`
`protocol rules and user rules—is “correlated” with the user’s IP address because
`
`all the rules are applied to the user’s packets while the user is logged into the LAN.
`
`Petition at 37. Accordingly, Petitioner respectfully requests withdrawal of the
`
`Decision and issuance of a new decision instituting inter partes review.
`
`The Decision overlooked Petitioner’s design choice
`2.
`argument.
`With respect to the “global protocol rules” issue, the Decision overlooked
`
`and failed to address Petitioner’s argument, offered in the alternative, that
`
`“[a]dding user-specific, timer-based rules is merely a matter of design choice.”
`
`Petition at 35-36. The Petition further offered the unrebutted testimony of Dr. Lin
`
`that timer rules defined on a per-user basis were a “known option” providing the
`
`“the same per-user filtering as occurs with the global application of the rule.”
`
`Petition at 36 (citing Ex. 1003, ¶ 103).
`
`The Decision acknowledged that Petitioner made this argument (Decision at
`
`19), but the Decision overlooked the argument by not providing any analysis or
`
`response. Notably, Dr. Lin’s testimony is unrebutted, and factual issues are to be
`
`viewed at institution in the light most favorable to Petitioner. See 37 C.F.R.
`
`
`
`11
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` Petitioner’s Request for Rehearing
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`§ 42.108(c). In fact, the Patent Owner Response did not even offer any attorney
`
`argument against Petitioner’s design choice argument. See generally Paper 6
`
`(never mentioning “design choice,” or even the word “choice”).
`
`Accordingly, Petitioner respectfully requests withdrawal of the Decision and
`
`issuance of a new decision instituting inter partes review.
`
`C. The Decision misconstrued “redirection server” by overlooking the
`’459 patent’s multiple examples of “redirection.”
`The Decision refers to the “’459 patent’s description of conventional
`
`redirection” in the background section, which involves “redirection of the user,”
`
`and states that “the ’459 patent does not describe any other type of redirection.”
`
`Decision at 12 (emphasis added, quoting Ex. 1001, 1:63-2:3).
`
`These statements overlooked the ’459 patent’s discussion of redirection
`
`examples outside the background section. For example, the ’459 patent describes
`
`redirection server 208 as being programmed to perform “redirection of data
`
`packets based on the rule sets.” Ex. 1001, 5:5-12 (emphasis added, cited in
`
`Petition at 15); see also Ex. 1001, 3:29-34 & 6:50-52 (“redirect the user’s packets
`
`according to the rule set”); Ex. 1001, 7:52-55 (“a packet containing HTTP data…
`
`is redirected by the redirection server 208 to www.widgetsell.com”).
`
`Patent Owner highlighted other, similar statements to argue that the claimed
`
`redirection server “changes the request for one website to a request for a different
`
`
`
`12
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` Petitioner’s Request for Rehearing
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`website.” Paper 6 at 15 (citing Ex. 1001, 6:53-7:5 & 7:38-55); see also Paper 6 at
`
`4 (“the redirection server may modify the user’s request for an Internet location
`
`to redirect it to a different Internet location”) (emphasis added); Paper 6 at 14 (“the
`
`’459 patent uniformly describes ‘redirection’ as modifying a user’s request”).
`
`Patent Owner argued that such changes to a user’s request were the only form of
`
`“redirection” disclosed or described in the ’459 patent. Paper 6 at 15 (“The ’459
`
`patent does not disclose or describe any other form of ‘redirection.’”).
`
`The Decision overlooked these descriptions of redirecting a user’s packet or
`
`request by modifying the packet or request, and therefore misapprehended the ’459
`
`patent’s conception of “redirection.” By construing the claimed redirection server
`
`to require “redirecting a user,” the Board’s construction of “redirection server”
`
`improperly excluded the many embodiments involving the redirection of a packet
`
`or a request. An “interpretation which excludes a disclosed embodiment from the
`
`scope of the claim is rarely, if ever, correct.” Broadcom Corp. v. Emulex Corp.,
`
`732 F.3d 1325, 1333 (Fed. Cir. 2013) (internal quotations omitted).
`
`Petitioner respectfully requests correction of the Decision’s erroneous claim
`
`construction through the withdrawal of the Decision and issuance of a new
`
`decision construing “redirection server” in light of the specification’s disclosure of
`
`redirecting (via modification) a user’s packet or request.
`
`
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`13
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`IPR2019-00043 – RE46,459
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` Petitioner’s Request for Rehearing
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`IV. CONCLUSION
`For the reasons set forth above and in the Petition, Petitioner respectfully
`
`requests a new Decision instituting an inter partes review trial on all requested
`
`claims.
`
`
`
`
`Dated: June 12, 2019
`HAYNES AND BOONE, LLP
`2323 Victory Avenue, Suite 700
`Dallas, Texas 75219
`
`
`Customer No. 27683
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`
`
`/David L. McCombs/
`David L. McCombs
`Lead Counsel for Petitioner
`Registration No. 32,271
`
`
`
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`14
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`IPR2019-00043 – RE46,459
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` Petitioner’s Request for Rehearing
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`CERTIFICATE OF SERVICE
`
`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e), that
`service was made on the Patent Owner as detailed below.
`
`
`Date of service June 12, 2019
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`Manner of service Email: rmirzaie@raklaw.com; jchung@raklaw.com
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`Documents served PETITIONER’S REQUEST FOR REHEARING, 37 C.F.R.
`§ 42.71(d)
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`Reza Mirzaie
`C. Jay Chung
`Russ August & Kabat
`12424 Wilshire Blvd., 12th Fl.
`Los Angeles, CA 90025
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`Persons served
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`/David L. McCombs/
`David L. McCombs
`Registration No. 32,271
`Lead Counsel for Petitioner
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`15
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