UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`CANON, INC.
`Petitioner,
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`v.
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`CELLSPIN SOFT, INC.
`Patent Owner.
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`CASE: IPR2019-001271
`Patent No. 9,258,698
`
`PATENT OWNER CELLSPIN’S OBJECTIONS TO PETITIONER’S
`DEMONSTRATIVE EXHIBITS
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`1 GoPro, Inc., Garmin International, Inc. and Garmin USA, Inc. were joined as
`parties to this proceeding. Paper 27.
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CANON, INC.
`Petitioner,
`
`v.
`
`CELLSPIN SOFT, INC.
`Patent Owner.
`
`CASE: IPR2019-001271
`Patent No. 9,258,698
`
`PATENT OWNER CELLSPIN’S OBJECTIONS TO PETITIONER’S
`DEMONSTRATIVE EXHIBITS
`
`
`1 GoPro, Inc., Garmin International, Inc. and Garmin USA, Inc. were joined as
`parties to this proceeding. Paper 27.
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`I.
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`Introduction.
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`IPR2019-00127
`U.S. Pat. No. 9,258,698
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`Petitioner Canon’s proposed demonstrative slides, like Canon’s Reply and its
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`Exhibits, are rife with improper new theories, directions, approaches, arguments and
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`evidence which are not proper rebuttal and which Canon could, and should, have
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`presented in its prima facie case in its Petition (collectively the “Improper New
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`Matters”). Such Improper New Matters violate 37 C.F.R. §42.23(b), the
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`Administrative Procedure Act (“APA”) and due process. See Genzyme v. Biomarin
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`Pharm., 825 F.3d 1360, 1365-66 (Fed. Cir. 2016); Intelligent Bio-Sys. v. Illumina
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`Cambridge, 821 F.3d 1359, 1369-70 (Fed. Cir. 2016); In re NuVasive, 841 F.3d 966,
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`973 (Fed. Cir. 2016); Belden v. Berk-Tek, 805 F.3d 1064, 1078, 1081 (Fed. Cir.
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`2015); Apple v. e-Watch, IPR2015-00412 (Paper 50, p. 44) (PTAB May 6, 2016);
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`See Consolidated Guide, pp. 73 & 80-81. See also 5 U.S.C. §§ 554(b)-(c), 556(d),
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`557(c); Abbott Labs. v. Cordis, 710 F.3d 1318, 1328 (Fed. Cir. 2013). See also
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`Cellspin’s January 3, 2020 Motion to Strike (“MTS”) and Cellspin’s January 10,
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`2020 Response to Canon’s Motion to Strike (Paper 40). Canon’s original theory in
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`its Petition for “paired wireless connection” limitation being met was that Hiroishi’s
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`Bluetooth (“BT”) wireless connection was paired because it allows two-way
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`communication. Paper 1 (Pet.), p. 23.The PTAB should strike, or alternatively,
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`exclude, Canon’s improper demonstratives, which were submitted as a whole, in
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`their entirety. See CBS Interactive v. Helferich Patent Licensing, IPR2013-00033,
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`
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`1
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`IPR2019-00127
`U.S. Pat. No. 9,258,698
`Paper 118 (Oct. 23, 2013). Alternatively, the PTAB should strike, or alternatively,
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`exclude, the individual slides specifically noted below. It should be noted that all
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`matters sought to be excluded as demonstratives herein are not specifically included
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`in Cellspin’s MTS, and thus it would be improper to defer ruling on these objections
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`until the MTS is ruled upon, unless the MTS will be ruled upon prior to the upcoming
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`oral hearing.
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`II. Objections and Argument.
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`A. Objections to Slides 14-17
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`Cellspin objects to Petitioners slides 14-17 because the this purported “State
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`of the Art” constitutes Improper New Matters, namely the evidence in each is from
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`the BT Basic Imaging Profile (“BIP”), Ex. 2023. This purported “State of the Art”
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`was not relied upon or cited in Canon’s Petition, nor was it even cited in Canon’s
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`Reply for being indicative of the state of the art. See, e.g., CBS Interactive, IPR2013-
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`00033, Paper 118 at 4 (Oct. 23, 2013) (burden on party presenting the slide to be
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`able to point to a sentence or paragraph in a paper of record for support). Rather,
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`these slide titles for “State of the Art” are a subterfuge for Canon to provide evidence
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`supporting its Improper New theory/argument/position/ assertion that “paired
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`wireless connections” are allegedly obvious, which was improperly asserted for the
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`first time in Canon’s Reply. See MTS, §III.A. Canon’s original theory in its Petition
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`for “paired wireless connection” limitation being met was that Hiroishi’s Bluetooth
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`2
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`IPR2019-00127
`U.S. Pat. No. 9,258,698
`(“BT”) wireless connection was paired because it allows two-way communication.
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`Paper 1 (Pet.), p. 23. Here Canon relied upon the original Madisetti Dec. Ex. 1003,¶¶
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`97-100. Canon had no obviousness theory with regard to paired connections. Paper
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`1, p. 23; Ex. 1003, ¶¶ 97-100. See MTS, §III.A.
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`Canon’s Reply, in reliance upon the improper Madisetti Reply Dec. at Ex.
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`1043, improperly relies in multiple places upon a new theory of obviousness to pair,
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`including that a POSITA would have been motivated to pair the Hiroishi and/or
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`Hollstrom wireless connections for various reasons, including encouragement,
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`design choice, expectedness, routineness and/or due to predictable results. E.g.,
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`Reply (Paper 36), p. 2, pp. 9-10; Ex. 1043 ¶¶ 9-13. See MTS, §III.A
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`Canon’s new obviousness theory further relies upon Improper New Matters
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`from the BIP. Reply, pp. 11-13; Ex. 1043 ¶ 12. See MTS, §III.A. Slides 14-17 all
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`feature the BIP. They each note that Canon referenced the BIP at p. 11 of its Reply
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`Brief, which is part of Canon’s Improper New Matters concerning alleged
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`obviousness of “paired wireless connection.”
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`Here and throughout its demonstrative slides, Canon’s, being aware of
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`Cellspin’s pending Motion to Strike, has used minimalistic titles, or here, downright
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`misleading titles, for its slides seeks to mask its purpose for offering the evidence
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`contained therein, but the only purpose for Canon possibly offering them is
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`necessarily to advance the foregoing Improper New Matters.
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`3
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`B. Objections to Slides 63-69
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`IPR2019-00127
`U.S. Pat. No. 9,258,698
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`Cellspin objects to Slides 63-69 including because the purported evidence
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`therein for “Establishing a paired wireless connection … cryptographically
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`authenticating” constitutes Improper New Matters. These slides do not provide any
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`purported evidence for an asserted prior art device establishing a paired wireless
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`connection” or for an asserted device cryptographically authenticating. Rather, the
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`title references to “Establishing a paired wireless connection … cryptographically
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`authenticating” are a subterfuge for Canon to instead provide evidence supporting
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`its Improper New theory/argument/position/ assertion that “paired wireless
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`connections” are allegedly obvious, which was improperly asserted for the first time
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`in Canon’s Reply. See MTS, §III.A.
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`Cellspin further objects to Slide 63 because the cited text from the Madisetti
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`Deposition at Ex. 1042 is an improper attempt by Canon and Dr. Madisetti to assert
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`Improper New Matters, namely their new obviousness theory for “paired wireless
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`connection” slipped in during Dr. Madisetti’s deposition, when Dr. Madisetti was
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`supposed to be testifying about the opinions in his Declaration at Ex. 1003, not new
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`opinions that he had formed after his Declaration and after Canon’s Petition. See
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`Cellspin’s MTS, §III.A. Dr. Madisetti’s testimony about obviousness was obviously
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`pre-planned to be improperly interjected by Dr. Madisetti at the first opportunity, as
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`it was not even responsive to the question posed, which was “That's an example of
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`4
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`IPR2019-00127
`U.S. Pat. No. 9,258,698
`optional pairing in Bluetooth 2.1, correct?” Ex. 2040, 13:2-3. This evidence and
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`indeed such an opinion/theory of obviousness from Dr. Madisetti were not relied
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`upon in Canon’s Petition. Despite the ambiguity of the titles to Canon’s slides, it is
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`clear from Canon’s Reply that this Improper New evidence from Ex. Ex. 1042 at
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`13:12-19 is being used to support its Improper New Obviousness Theory. See
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`Canon’s Reply, p. 9.
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`Cellspin further objects to Petitioners Slides 64 and 69 because the cited text
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`from the Madisetti Reply Declaration at Ex. 1043 is an improper attempt by Canon
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`and Dr. Madisetti to assert Improper New Matters, namely their new obviousness
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`theory for “paired wireless connection” by including it in Canon’s Reply and Ex.
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`1043. See Cellspin’s MTS, §III.A. This evidence and indeed such an opinion/theory
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`of obviousness from Dr. Madisetti were not relied upon in Canon’s Petition. Despite
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`the ambiguity of the titles to Canon’s slides, it is clear from Canon’s Reply that this
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`Improper New evidence from Ex. 1043 is being used to support its Improper New
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`Obviousness Theory. See Canon’s Reply, pp. 9-10.
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`Cellspin further objects to Petitioners Slides 65-67 because the cited text from
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`the Foley Deposition at Ex. 1040 is an improper attempt by Canon to assert Improper
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`New Matters, namely its new obviousness theory for “paired wireless connection”
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`by slipping it in during Dr. Foley’s deposition, when Canon was supposed to be
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`asking Dr. Foley about his opinions in Ex. 2009, not posing questions to get sound
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`5
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`IPR2019-00127
`U.S. Pat. No. 9,258,698
`bites for a new obviousness theory that Canon had formulated post-Petition. Despite
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`the ambiguity of the titles to Canon’s slides, it is clear from Canon’s Reply that this
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`Improper New evidence from Ex. 1040 is being used to support its Improper New
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`Obviousness Theory. See Canon’s Reply, p. 9.
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`Cellspin further objects to Slide 68 because Ex. 2023, which was not cited in
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`Canon’s Petition, is Improper New evidence offered in Canon’s Reply, and not in
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`Canon’s Petition, support the foregoing Improper New obviousness Reply
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`theory/argument/position/assertion. This is a citation to the BIP, which is discussed
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`at Slides 14-17 above. Despite the ambiguity of the titles to Canon’s slides, it is clear
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`from Canon’s Reply that this Improper New evidence from Ex. 2023 is being used
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`to support its Improper New Obviousness Theory. See Canon’s Reply, p. 11.
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`Including as noted in Section A above and in MTS, §III.A, Canon’s new
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`obviousness theory, and the evidence offered by Canon in support thereof, is an
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`Improper New Matter that went beyond the proper scope of Canon’s Reply and
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`proper Reply evidence. The evidence cited within Slides 63-69 is clearly being
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`offered in support of this Improper New obviousness theory, as is evident from the
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`references in each slide to portion of Canon’s Reply in which it advances the theory.
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`C. Objections to Slides 70-72 and 75-80
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`Cellspin objects to Petitioners Slides 70-72 and 75-80 including because the
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`purported evidence therein for “Establishing a paired wireless connection …
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`6
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`IPR2019-00127
`U.S. Pat. No. 9,258,698
`cryptographically authenticating” constitutes Improper New Matters relative to
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`Canon’s Improper New Reply theory concerning cryptographic authenticating being
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`obvious based upon matters and language set forth in the Bluetooth standard or other
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`new Reply exhibits relied upon by Canon, for new reasons first articulated in
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`Canon’s Reply, including cryptographic authentication being a feature of Bluetooth
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`association models, encouragement, design choice, expectedness, routineness,
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`safeness and/or predictable results. See Cellspin’s MTS, §III.C. As noted in
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`Cellspin’s MTS, §III.C, Canon’s original theory in its Petition was that
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`“cryptographically authenticating” was obvious because: (1) “Cryptographic
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`authentication between wireless devices like a digital camera and cellular phone was
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`routine at the time of the invention. Id.; Ex. 1017,3 91-92; Ex. 1019, [0055]; Ex.
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`1020, [0019];” (2) “cryptographic authentication was part of the Bluetooth standard;
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`and (3) “motivation for using cryptographic authentication: to ensure that …
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`information is protected from outsiders … Ex. 1003 ¶¶ 99-100, 44-47.” Pet., pp. 24-
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`25. Belatedly realizing this was untenable, Canon, relying upon Dr. Madisetti,
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`shifted its obviousness theory and the bases for said theory in its Reply. See, e.g.,
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`Reply, pp. 6-7; Ex. 1043, §6-7, 10. The purported evidence in Petitioners Slides 70-
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`72 and 75-81 was not relied upon or cited in Canon’s Petition. Including as noted in
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`Cellspin’s MTS, §III.C, this new obviousness theory, and the evidence offered by
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`Canon in support thereof, is an Improper New Matter that went beyond the proper
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`7
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`IPR2019-00127
`U.S. Pat. No. 9,258,698
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`scope of Canon’s Reply and proper Reply evidence.
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`Cellspin further objects to Slides 70-72 because the cited/highlighted text
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`from “Ex. 1017 at 6,” “Ex. 1019 at [0055],” and “Ex. 1020 at [0019]” was not cited
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`or relied upon in Canon’s Petition or in Canon’s Reply, and because it is being cited
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`for
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`the
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`foregoing
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`Improper New
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`theory/argument/position/assertion
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`for
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`cryptographic authentication being obvious, which goes far beyond Canon’s Petition
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`theory and basis for such obviousness. Canon’s Petition merely cited exhibits 1017,
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`1019 and 1020 for the general proposition that “Cryptographic authentication
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`between wireless devices like a digital camera and cellular phone was routine at the
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`time of the invention.” Petition, p. 24. None of the highlighted text at Slides 70-71
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`was mentioned directly or indirectly in Canon’s Petition. Further, Exhibits 1017,
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`1019 and 1020 is not cited at all in Canon’s Reply. For this reason alone these
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`demonstratives should be stricken or excluded. See Dell, 884 F.3d at 1369; PTAB
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`Guide, p. 84. The highlighted text in slide 70-72 from “Ex. 1017 at 6, Ex. 1019 at
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`[0055] and Ex. 1020 at [0019] has no bearing to Canon’s Petition theory that
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`“Cryptographic authentication between wireless devices like a digital camera and
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`cellular phone was routine at the time of the invention”; rather, it is now being cited
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`in for the first time in Canon’s Demonstratives to assert Improper New Matters.
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`Cellspin further objects to Slides 75, 77-78 and 80 because the cited text from
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`the Foley Deposition at Ex. 1040 is an improper attempt by Canon to assert Improper
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`
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`8
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`IPR2019-00127
`U.S. Pat. No. 9,258,698
`New Matters, namely its new theories and bases for cryptographic authentication
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`being obvious, which goes far beyond Canon’s Petition theory and basis for such
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`obviousness, by slipping it in during Dr. Foley’s deposition, when Canon was
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`supposed to be asking Dr. Foley about his opinions in Ex. 2009, not posing questions
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`to get sound bites for new obviousness theories that Canon had formulated post-
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`Petition. See Cellspin’s MTS, §III.C. This evidence and indeed Canon’s new Reply
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`theories for obviousness for “cryptographically authenticating” were not relied upon
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`in Canon’s Petition. Despite the ambiguity of the titles to Canon’s slides, it is clear
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`from Canon’s Reply that this Improper New evidence from Ex. 1040 is being used
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`to support its Improper New Obviousness Theory. See Canon’s Reply, pp. 15-16.
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`Including as noted in Cellspin’s MTS, this new obviousness theory and basis for
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`obviousness, and the evidence offered by Canon in support thereof, is an Improper
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`New Matter that went beyond the proper scope of Canon’s Reply and proper Reply
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`evidence.
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`Cellspin further objects to Slide 75 because the cited text from “Ex. 1039 at
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`18” was not relied upon in Canon’s Petition, and because it is being cited for the
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`foregoing Improper New theory/argument/position/assertion for cryptographic
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`authentication being obvious, which goes far beyond Canon’s Petition theory and
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`basis for such obviousness. Canon’s Slide 75 correctly notes that the only time that
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`Ex. 1039 at 18 has been cited was in Canon’s Reply and when Dr. Madisetti slipped
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`9
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`IPR2019-00127
`U.S. Pat. No. 9,258,698
`it in during his deposition with a non-responsive answer. Canon’s Petition did not
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`rely at all on Security Mode 4 from the Bluetooth Specification; rather, Security
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`Mode 4 and its details were cited in Canon’s Reply for the foregoing Improper New
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`theory/argument/ position/assertion. Despite the ambiguity of the titles to Canon’s
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`slides, it is clear from Canon’s Reply that this Improper New evidence from Ex.
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`1039 is being used to support its Improper New Obviousness Theory. See Canon’s
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`Reply, p. 15.
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`Cellspin further objects to Slide 79 because the cited text from “Ex. 1036 at
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`9” was not relied upon in Canon’s Petition, and because it is being cited for the
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`foregoing Improper New theory/argument/position/ assertion for cryptographic
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`authentication being obvious, which goes far beyond Canon’s Petition theory and
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`basis for such obviousness. Despite the ambiguity of the titles to Canon’s slides, it
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`is clear from Canon’s Reply that this Improper New evidence from Ex. 1036 is being
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`used to support its Improper New obviousness theory. See Canon’s Reply, p. 16.
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`Including as noted above and in MTS, §III.C, Canon’s new obviousness
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`theories and bases for cryptographically authenticating being obvious, and the
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`evidence offered by Canon in support thereof, are Improper New Matters that went
`
`beyond the proper scope of Canon’s Reply and proper Reply evidence. The evidence
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`cited within Slides 70-72 and 75-80 is clearly being offered in support of these
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`Improper New obviousness theories and bases, as is evident from the references in
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`
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`10
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`IPR2019-00127
`U.S. Pat. No. 9,258,698
`each slide to portion of Canon’s Reply in which it advances same.
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`D. Objections to Slides 81-83
`
`Cellspin objects to Petitioners Slides 81-83 including because the purported
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`evidence therein for “Establishing a paired wireless connection … cryptographically
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`authenticating” constitutes Improper New Matters relative to Canon’s Improper
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`New Reply theory concerning cryptographic authentication being a “mandatory”
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`feature, including under Security Mode 3 of the Bluetooth Standard. See MTS,
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`§III.E. As noted in Section C above, Canon’s original theory in its Petition was that
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`“cryptographically authenticating” was obvious because: (1) “Cryptographic
`
`authentication between wireless devices like a digital camera and cellular phone was
`
`routine at the time of the invention. Id.; Ex. 1017,3 91-92; Ex. 1019, [0055]; Ex.
`
`1020, [0019];” (2) “cryptographic authentication was part of the Bluetooth standard;
`
`and (3) “motivation for using cryptographic authentication: to ensure that …
`
`information is protected from outsiders … Ex. 1003 ¶¶ 99-100, 44-47.” Pet., pp. 24-
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`25. The purported evidence in Slides 81-83 for “Establishing a paired wireless
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`connection … cryptographically authenticating,” which is really only pertinent to
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`cryptographically authenticating, namely Ex. 1039 at 16, Ex. 1042 at 31:1-32:9 and
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`Ex. 1040 at 25:6-12, was not relied upon or cited in Canon’s Petition, nor did
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`Canon’s Petition assert that cryptographic authentication was mandatory. Despite
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`the ambiguity of the titles to Canon’s slides, it is clear from Canon’s Reply that this
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`11
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`IPR2019-00127
`U.S. Pat. No. 9,258,698
`Improper New evidence cited in these slides is being used to support this Improper
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`New Obviousness Theory. See Canon’s Reply, p. 17.
`
`Cellspin further objects to Slide 82 because the cited text from the Madisetti
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`Deposition at Ex. 1042 is an improper attempt by Canon and Dr. Madisetti to assert
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`Improper New Matters, namely an Improper New theory that “cryptographic
`
`authentication” is allegedly “mandated,” by slipping it in during Dr. Madisetti’s
`
`deposition in a non-response to a question, when Dr. Madisetti was supposed to be
`
`testifying about the opinions in his Declaration at Ex. 1003, not new opinions that
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`he had formed after his Declaration and after Canon’s Petition. See MTS, §III.E.
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`This evidence and indeed such an opinion/theory serving the basis for obviousness
`
`from Dr. Madisetti were not expressed in Dr. Madisetti’s Petition Declaration, Ex.
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`1003, nor were they stated or relied upon in Canon’s Petition.
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`Including as noted above and in MTS, §III.E, Canon’s new obviousness
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`theories and bases for cryptographically authenticating being mandatory, and the
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`evidence offered by Canon in support thereof, are Improper New Matters that went
`
`beyond the proper scope of Canon’s Reply and proper Reply evidence. The evidence
`
`cited within Slides 80-82 is clearly being offered in support of these Improper New
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`obviousness theories and bases, as is evident from the references in each slide to
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`portion of Canon’s Reply in which it advances same.
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`12
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`E. Objections to Slide 3
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`IPR2019-00127
`U.S. Pat. No. 9,258,698
`
`Cellspin objects to Petitioner’s Slide 83 including because it attempts to
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`arguments or introduce evidence, namely from testimony at Ex. 1040 at 25:6-12, not
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`previously presented in the record. See Dell v. Acceleron, 884 F.3d 1364, 1369 (Fed.
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`Cir. 2018); PTAB Consolidated Trial Practice Guide (“Guide”), p. 84. Canon’s Slide
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`83 alleges this testimony was cited at p. 17 of Canon’s Reply; however, it was no
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`cited anywhere in Canon’s Reply (or in Canon’s Petition either). To the extent this
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`newly asserted evidence is attempting to advance a new obviousness theory for
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`pairing or new theory or basis for cryptographically authenticating being obvious,
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`see objections to foregoing slides. To the extent this newly asserted evidence is
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`attempting to advance new arguments, which appears to be the case, that is clearly
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`improper, including under the above-noted authorities.
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`III. Conclusion.
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`
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`For the foregoing reasons and also the reasons noted in Cellspin’s Motion to
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`Strike, the PTAB should strike, or alternatively, exclude, Canon’s improper
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`demonstratives, which were submitted as a whole, in their entirety. Alternatively,
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`the PTAB should strike, or alternatively, exclude, individual slides 14-17, 63-69
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`70-72, 75-80, and 81-83.
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`13
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`Dated: January 21, 2020
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`IPR2019-00127
`U.S. Pat. No. 9,258,698
`Respectfully submitted,
`
`
`
`/s/ John J. Edmonds
`John J. Edmonds, Reg. No. 56,184
`EDMONDS & SCHLATHER, PLLC
`355 South Grand Avenue,
`Suite 2450 Los Angeles, CA
`90071
`Telephone: 213-973-7846
`Facsimile: 213-835-6996
`Email: pto-edmonds@ip-lit.com
`
`Stephen F. Schlather, Reg. No. 45,081
`EDMONDS & SCHLATHER, PLLC
`2501 Saltus Street
`Houston, TX 77003
`P: 713-234-0044
`F: 713-224-6651
`E: sschlather@ip-lit.com
`
`Counsel for Patent Owner, Cellspin Soft,
`Inc.
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`14
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`IPR2019-00127
`U.S. Pat. No. 9,258,698
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`CERTIFICATE OF SERVICE
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`I hereby certify that these Objections are being served on January 21, 2020
`by electronic mail and ECF to the following:
`
`
`jarednewton@quinnemaneul.com
`Jennifer.Bailey@eriseip.com
`Adam.Seitz@eriseip.com
`PTAB@eriseip.com
`karinehk@rimonlaw.com
`
`
`
`January 21, 2020
`
`/s/ John J. Edmonds
`John J. Edmonds
`
`
`
`15
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`
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