Case No. IPR2019-00500
`Patent No. 9,737,154
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`AMERICAN NATIONAL MANUFACTURING INC.,
`Petitioner,
`
`v.
`
`SLEEP NUMBER CORPORATION
`f/k/a SELECT COMFORT CORPORATION,
`Patent Owner.
`
`____________
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`Case No. IPR2019-00500
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`Patent No. 9,737,154
`____________
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`
`
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`PETITIONER’S SURREPLY TO PATENT OWNER’S
`MOTION TO AMEND (PAPER 42)
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`WA 14551779.2
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`Patent No. 9,737,154
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`AMERICAN NATIONAL MANUFACTURING INC.,
`Petitioner,
`
`v.
`
`SLEEP NUMBER CORPORATION
`f/k/a SELECT COMFORT CORPORATION,
`Patent Owner.
`
`____________
`
`Case No. IPR2019-00500
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`Patent No. 9,737,154
`____________
`
`
`
`
`PETITIONER’S SURREPLY TO PATENT OWNER’S
`MOTION TO AMEND (PAPER 42)
`
`
`
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`WA 14551779.2
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`Case No. IPR2019-00500
`Patent No. 9,737,154
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`TABLE OF CONTENTS
`INTRODUCTION ......................................................................................... 1
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`I.
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`II. ARGUMENT ................................................................................................. 2
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`A. The Proposed Amendments Fail To Meet The Statutory And Regulatory
`Requirements ..................................................................................................... 2
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`1. PO has not demonstrated support for the Proposed Amendments ........... 2
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`2. The Substitute Claims are not enabled and/or lack written description
`because the specification contains an ERROR in a critical equation as now PO
`admits ............................................................................................................ 4
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`3. The Substitute Claims are arguably broader in light of proposed
`dependent claims ............................................................................................ 6
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`4. The Substitute Claims are indefinite ....................................................... 7
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`5. PO’s compliance with the duty of candor remains deficient ................... 8
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`B. The Proposed Claims Remain Improper and/or Obvious as this Board
`correctly determined .......................................................................................... 9
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`1. Motivation to combine satisfies the flexible KSR standard ..................... 9
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`2. Remaining Substitute Claims are also obvious ......................................11
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`3. Petitioner does NOT admit the references are not analogous .................12
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`III.
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`CONCLUSION .........................................................................................12
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`TABLE OF AUTHORITIES
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` Page(s)
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`Federal Cases
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`B.E. Tech., L.L.C. v. Google, Inc.,
`No. 2015-1827, 2016 WL 6803057 (Fed. Cir. Nov. 17, 2016)
`(unpublished) ................................................................................................. 3, 4
`
`Constant v. Advanced Micro-Devices, Inc.,
`848 F.2d 1560 (Fed. Cir. 1988) ........................................................................ 10
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`Nautilus, Inc. v. Biosig Inst., Inc.,
`572 U.S. 898 (2014) ........................................................................................... 7
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`Ormco Corp. v. Align Tech., Inc.,
`498 F.3d 1307 (Fed. Cir. 2007) .......................................................................... 5
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`Petitioner American National Manufacturing, Inc. (“ANM” or “Petitioner”)
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`files this Surreply in support of its Opposition (Paper 68) to Patent Owner Sleep
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`Number Corp.’s (f/k/a Select Comfort Corp.) (“PO” or “Sleep Number”) Motion to
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`Amend (Paper 42) (the “MTA”) and in response to PO’s Reply (Paper 81) (the
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`“Reply”). The appendix to the MTA provides a redline of proposed “Substitute
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`Claim(s)” (or the “Proposed Amendment(s)”).
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`I.
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`INTRODUCTION
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`This Board correctly found all the Substitute Claims to be unpatentable over
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`prior art. See Prel. Guidance (Paper 77 at 6–11). The Board’s guidance recognized
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`that the Proposed Amendments add nothing more than non-distinguishing, generic
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`limitations within the ambit of prior art and do nothing to add to patentability.
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`The Reply does nothing to rebut the Board’s careful analysis, much less
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`Petitioner’s analysis. Instead providing cogent analysis, the MTA’s rebuttal
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`arguments are not tied to claim language (or even a specific construction),
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`misrepresent Petitioner’s positions and expert testimony to complexify and make
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`strawman arguments, or are otherwise specious.
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`Moreover, PO for the first time admits that the specification contains an error
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`in a critical equation. This renders the claims inoperative and un-enabled, among
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`other things.
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`Accordingly, the Board should deny the MTA.
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`II. ARGUMENT1
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`A. The Proposed Amendments Fail To Meet The Statutory And
`Regulatory Requirements
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`1.
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`PO has not demonstrated support for the Proposed
`Amendments
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`PO’s rebuttal is a meager one sentence asserting that Dr. Messner now has
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`provide detailed support. Reply at 1–2. However, Dr. Messner himself admitted
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`that his declaration merely parrots back claim language under the heading “My
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`analysis.” E.g., Ex. 1062 at 78:1–10. He also admitted that he merely provides a
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`bare list of citations (without analysis) under the heading “Support in Ex. . . .”. E.g.,
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`Ex. 1062 at 86:6–15. He also admitted that the vast majority of those citations are
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`1 In § II.B of the Reply, PO argues that Petitioner improperly incorporates by
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`references because the Opposition cites to more robust discussion provided in Dr.
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`Phinney’s declaration. As an initial matter, PO’s argument seems disingenuous
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`given that PO itself effectively by citation incorporates by reference 28 pages of
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`declaration testimony. See Reply at 1–2 (“written description . . . is now further
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`bolstered by Dr. Messner’s detailed mapping of the substitute claims to the original
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`disclosure. (Exhibit 2079 ¶¶ 11-20.)”). In stark contrast to the PO (see § II.A.1 infra
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`discuss PO’s practice of merely providing string citations), the Opposition provides
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`plain-English discussion in a level of detail demanded by this Board’s imposed page
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`limits. That discussion is supported by citation to evidence providing a more detail
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`discussion. Petitioner’s plain-English briefing is proper unlike PO’s string-citation
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`briefing.
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`to paragraphs that merely parrot back claim language, e.g., from the “Abstract” or
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`“Summary,” or merely describe the Background. E.g., Ex. 1062 at 80:4–81:5 and
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`84:10–86:5. Where Dr. Messner citations to figures or the detailed description for
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`support, he intentionally omitted identification of specific reference numerals that
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`would identify which claim elements correspond to which elements in the figures
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`and detailed description. E.g., Ex. 1062 at 86:6–91:21.
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`This makes it impossible for Petitioner (and this Board) discern PO’s theory
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`of support for various Proposed Amendments. PO’s prejudicial practice has been
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`held deficient, and the Federal Circuit has upheld such holding of deficiency. See
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`B.E. Tech., L.L.C. v. Google, Inc., No. 2015-1827, 2016 WL 6803057, at *7 (Fed.
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`Cir. Nov. 17, 2016) (unpublished) (agreeing with Board that a patent owner did not
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`meet its burden to show written description support for proposed substitute
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`limitations in motion to amend where the patent owner provided only a string
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`citation without explaining how the cited material supported each of the proposed
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`substitute limitations).
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`Although the Preliminary Guidance accepted mere string citations at that
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`stage, the Guidance did not address the cases cited by Petitioner rejecting the practice
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`of providing only string citations. Oppo., § II.A.2. Petitioner respectfully submits
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`that the reasoning of these opinions is sound and should be followed.
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`It is PO’s burden to show support, and it has not done so here. See B.E. Tech.,
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`No. 2015-1827, 2016 WL 6803057 at *7 (burden is on patentee).
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`2.
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`The Substitute Claims are not enabled and/or lack written
`description because the specification contains an ERROR
`in a critical equation as now PO admits
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`As discussed in § II.A.3 of the Opposition, the specification of the ’154 Patent
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`at the crucial point of detailing the equation for calculating an AFE and modifying
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`the PAF contains an ERROR. See also Ex. 2079, ¶ 20 (Patent Owner’s expert
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`expressly acknowledges this error stating “this is a typographical error”).
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`Implementing any embodiment disclosed in the detailed description would results in
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`same PAF or accumulation of small amounts of error over time. See Ex. 1046, § X,
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`¶¶ 434–36. This is a latent error that would not be evident to a person having
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`ordinary skill in the art (“POSA”) and render embodiments inoperative, as Dr.
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`Phinney explained on cross-examination by PO’s counsel:
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`Q.
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`Is it operable as written?
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`A. Yes [and no]. And that’s kind of a problem, because
`what I’m trying to explain is it gives kind of a reasonable
`number that, as I explained, can differ a little bit from a
`number that was used previously, so it can give sort of the
`illusion of things being okay yet drift over time. So it’s
`like a hidden problem that — you know, an enablement
`you frequently are trying to pierce the veil of haze or fog
`around something to arrive at the actual implementation.
`This provides an implementation that’s incorrect.
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`Ex. 2080 at 162:4–18 (emphasis added). Further concealing this problem is that the
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`maximum number attempts and time-out checks (see ’747 Patent, FIG. 7, elements
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`151 and 173) would prevent indefinite operation, resulting on achieving actual
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`pressure close to desired pressure. See Ex. 1062 114:11–115:7 (Dr. Messner
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`agreeing with the same).
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`Thus, this error results in undue (or indefinite amount of) experimentation and
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`inoperability. See Ormco Corp. v. Align Tech., Inc., 498 F.3d 1307, 1319 and 1326
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`(Fed. Cir. 2007) (failure to be able to implement “an embodiment of the patent
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`invention [] is strong evidence that the patent specification lacks enablement”).
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`Petitioner’s own expert agreed that the disclosure is inoperable. Ex. 1062 at 113:8–
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`14.
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`This is not a “minor typographical error” as PO asserts (Reply at 11–12). PO
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`fails to explanation of how a POSA would even realize this error given its latent
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`nature. Indeed, PO’s prosecution attorneys and inventors—all who reviewed the
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`specification in detail multiple times when filing the priority PCT application, parent
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`’747 Patent, this ’154 Patent, and a child continuation application—presumably
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`never recognized this error and certainly never took corrective action. The proper
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`procedure to correct a defect in a patent is reissue. See 35 U.S.C. § 251. PO cannot
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`use the IPR process to circumvent the reissue process.
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`Thus, all the Proposed Claims are invalid.2
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`3.
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`The Substitute Claims are arguably broader in light of
`proposed dependent claims
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`Petitioner’s in its Opposition (§ II.A.4) provided a detail discussion of how
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`dependent Substitute Claims 24–26 may imply that independent claims are broader
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`based on principles of claim differentiation. The legal test is “a claim is broader in
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`scope than the original claims if it contains within its scope any conceivable product
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`or process which would not have infringed the original patent.” MPEP § 1412.03.
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`“A claim is broadened if it is broader in any one respect even though it may be
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`narrower in other respects.” Id.
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`Here, PO has not put forth any construction for what it means to modify the
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`PAF “based on” the AFE as recited in independent claims. Petitioner asserts that
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`that phrase is not broad enough to cover the AFE being a binary flag. Under the
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`original independent claims, for instance, an AFE being a binary flag would not
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`infringe, but such would conceivably infringe independent Substitute Claims when
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`interpreted by a court in view of dependent Substitute Claim 25. PO’s Reply does
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`2 Wands factor 3 (presence or absence of working examples) is particularly relevant
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`as there are no true working examples here (only example that would appear to
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`work). See id. at 1326. The remaining Wands factors are generally inapplicable as
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`there is a latent error here that a POSA would not recognize required
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`experimentation.
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`not analyze this issue. Although the Preliminary Guidance determined that scope
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`was not enlarged, it does not appear to discuss broadening based on claim
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`differentiation. Petitioner respectfully submits that Petitioner’s inherent position
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`that the Proposed Claims are broad to encompass these proposed dependent claims
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`are an impermissible attempt to broaden to the scope.3
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`4.
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`The Substitute Claims are indefinite
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`Petitioner’s arguments of indefiniteness are not about over breadth as PO
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`asserts. Instead, Petitioner’s arguments relate to interpretation of the independent
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`claims with respect to the AFE and whether those claims provide sufficient notice
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`to the public that they cover the new dependent Substitute Claims 24–26. The ’154
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`Patent fails to provide clear notice of such.4 See, e.g., Nautilus, Inc. v. Biosig Inst.,
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`Inc., 572 U.S. 898, 910 (2014) (“a patent must be precise enough to afford clear
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`notice of what is claimed, thereby apprising the public of what is still open to them.”
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`(quotations, alterations, and citations omitted; emphasis added)). PO fails to apply
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`the correct legal standard.
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`3 This further evidences lack of support and enablement for the full breadth of claim
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`scope.
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`4 Given PO’s practice of obfuscation with respect to written description support
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`discussed supra, it is unclear how these dependent claims as a whole have written
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`description support. At best, it appears is mixing a matching portions of the
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`specification to find piecemeal support.
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`5.
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`PO’s compliance with the duty of candor remains deficient
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`As a preliminary matter, PO’s expert Dr. Messner testified under oath that he
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`was aware of the defect in the specification related to the AFE equations since at
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`least PO’s first filing in this proceeding around April 2019. Ex. 1062 at 109:20–
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`111:13. Yet, PO has neither taken corrective action to date (e.g., filing for a
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`certificate of correction or reissue), nor candidly informed this Board of this critical
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`error. See Ex. 1062 at 109:11–111:13. This is inconsistent with the duty of candor.
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`PO asserts that it is “unaware” of material prior art and submits 9 pages listing
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`references. Reply at 12 and Ex. 2082. Nowhere in those 9 pages does PO disclose a
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`single physical product—even though PO was the market leader in consumer air
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`mattress systems at the relevant times and for long before. Certainly, its own prior
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`art products (and related product manuals and marketing materials) are material to
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`the Proposed Amendments. For instance, certain Proposed Amendments related to
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`“plurality of air bladders” (e.g., [23.P] et seq.), and PO was certainly selling air
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`mattress systems with two air bladders prior to 2007. See, e.g., Ex. 1004, FIG. 2
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`(Sleep Number’s own patent, filed in 1997, depicting a two bladder air mattress).
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`PO cannot in good faith assert adding “a plurality of bladders” and other
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`conventional elements (e.g., “network”) makes a patentable difference. Tellingly,
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`PO did not even consult its own expert regarding its duty of candor. See Ex. 1062
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`at 140:12–17 (PO expert testifying he did no analysis in support of the “Duty of
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`Candor” section).
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`B.
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`The Proposed Claims Remain Improper and/or Obvious as
`this Board correctly determined
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`As discussed in detail in the Opposition and the Preliminary Guidance, the
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`Substitute Claims are unpatentable as obvious. PO’s Reply does nothing to change
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`that careful analysis. Petitioner below addresses each of PO rebuttal arguments.
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`Each of the below subsection corresponds to the same subsection of § II. C of the
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`Reply.
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`1. Motivation to combine satisfies the flexible KSR standard
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`This Board has repeatedly found a motivation to combine here. See, e.g., Prel.
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`Guidance at 7 and Inst. Dec. at 28–31. Particularly, all the references are from an
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`analogous field—pneumatic systems. Among other things, basic-engineering
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`motivations of making things faster, more efficient, and more accurate would
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`provide a rationale for a POSA to combine to solve a known problem. See Ex. 1062,
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`82:13–84:8 (Dr. Messner waffling but not refuting such basic-engineering
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`motivations). Further, the invention here uses conventional hardware and known
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`software concepts that are within the grasp of a POSA that can be predictably
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`combine. See Ex. 1062 at 102:5–105:8 (Dr. Messner waffling but could not identify
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`a single change to conventional hardware needed to implement the invention of the
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`’154 Patent, ergo all change merely required writing software); see also Ex. 1062 at
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`42:7–13 (Dr. Messner testified that drawing simple electrical-equivalent diagrams
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`(e.g., as shown in the ’154 Patent, FIG. 3) were in the ambit of an engineering student
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`circa 1990’s); The flexible KSR standard is easily satisfied here.
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`PO arguments are specious. First, PO’s lead argument is that Ebel is less
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`accurate. However, nothing in the Substitute Claims limits the claims to any
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`particular degree of accuracy, nor has PO proposed any construction that would
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`require a degree of accuracy. Thus, this argument is not legal relevant here. See,
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`e.g., Constant v. Advanced Micro-Devices, Inc., 848 F.2d 1560, 1571-72 (Fed. Cir.
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`1988) (rejecting arguments based on reading into claims limitations that are not
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`present in the claims).
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`Second, PO argues that Ebel does not teach a multiplicative offset in
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`accordance with the claimed language. Ebel indisputably teaches a multiplicative
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`PAF—“a2.” Ex. 1007, ¶ [0031]. Although Ebel teaches modifying sensed pressure
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`based on a2 and deflating until that quantity equals desired pressure, it is the simple
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`algebraic equivalent to use a2 to modify desired pressure and compare that quantity
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`to dynamic pressure, as shown:
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`Ebel
`[sensed press.] * a2 ≈ [desired press.]
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`<=>
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`Algebraic Equiv.
`[sensed press.] ≈ [desired press.] / a2
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` Trivial algebra does not create patentable subject matter.
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`PO also argues that Dr. Phinney’s derivative diagram (Rv/R+Rv) is not taught
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`by prior art. Dr. Phinney has never asserted that that diagram was expressly taught
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`by the prior art, but has consistently asserted that it was derived from FIG. 2 of Ebel
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`to show how a POSA would simplify the teachings of Ebel if certain unnecessary
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`components were omitted (e.g., the low pass filter). PO also makes various
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`arguments related to Pillsbury, but PO’s argument distort Portioner’s theory. PO’s
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`arguments are specious as they needlessly complexify, misinterpret Petitioner’s
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`position, and are strawman in nature.
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`Third, PO argues improper hindsight because a single piece of art does not
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`expressly suggest modifying a multiplicative PAF. PO effectively concedes that
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`Pillsbury expressly teaches modifying an additive PAF. It would be obvious to
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`modify Pillsbury with the multiplicative PAF (a2) of Ebel, which would then be
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`modified in accordance with the teachings of Pillsbury. A POSA would be
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`motivated to make that modification because the POSA (looking at FIGS. 3a–5 of
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`Ebel) would see that Ebel’s equations provide a better “fit.” The POSA would see
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`that that better fit would provide increase accuracy, reduce iterations, and thus
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`increase speed and efficiency. Such basic-engineering motivations are available to
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`supply a rationale for combining under the flexible KSR standard.
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`2.
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`Remaining Substitute Claims are also obvious
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`Further, the Substitute Claims are generally a generic combination of various
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`conventional components (e.g., adding a “network” or time-out function). A POSA
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`would be motivated to add various useful components for analogous reasons as more
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`tools are added to the Swiss Army knife or restaurants add more items to buffets.
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`Such provides a motivation to combine Finkelstein (for a count function), Luff (for
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`a time-out function), and Collins (for network). Such is sufficient given the generic
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`nature of the relevant limitations in the Substitute claims.
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`3.
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`Petitioner does NOT admit the references are not
`analogous
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`This Board has already rejected PO’s argument that the field of endeavor is
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`limited to air mattress, but instead concluded that the relevant filed is pneumatic
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`systems. See Inst. Dec. at 27–28. PO does not present any new evidence that would
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`change that careful analysis. Instead, new evidence shows that even PO’s experts
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`believe that the relevant field is broader than air mattresses per se. See, e.g., Ex.
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`1062 at 10:17–11:13 (Dr. Messner describing that, although he has no per se
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`engineering experience with air beds, he is nonetheless qualified as an expert
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`because he has “extensive experience in controls, extensive background in
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`mechanical engineering, in design, in automatic control systems, all of which are
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`relevant to this case.” (emphasis added)); Ex. 1038 at 69:2–71:5 (similarly, Dr.
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`Edwards suggesting, e.g., tire pressure monitoring systems and handwashing
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`systems, within the relevant field).
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`III. CONCLUSION
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`For the foregoing reasons, the MTA should be denied.
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`Date: April 2, 2020
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`Respectfully Submitted,
`SPENCER FANE LLP
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`By /s/Kyle L. Elliott .
`Kyle L. Elliott, Reg. No. 39,485
`Kevin S. Tuttle, Reg. No. 52,307
`Brian T. Bear (pro hac vice)
`Mark A. Thornhill (pending pro hac vice)
`Spencer Fane LLP
`1000 Walnut Street, Suite 1400
`Kansas City, Missouri 64106-2140
`Telephone: (816) 474-8100
`
`Jaspal S. Hare, Reg. No. 66,988
`jhare@spencerfane.com
`Spencer Fane LLP
`5700 Granite Pkwy, Suite 650
`Plano, TX 75024
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`Counsel for Petitioner American National
`Manufacturing, Inc.
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies that a copy
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`of the foregoing PETITIONER’S SURREPLY TO PATENT OWNER’S MOTION
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`TO AMEND (PAPER 42) is served in its entirety on April 2, 2020, by electronic
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`mail, as authorized by Patent Owner’s Updated Mandatory Notices, directed to the
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`attorneys of record for Patent Owner at the following correspondence address of
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`record:
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`Steven A. Moore
`stevemoore@zhonglun.com
`ZHONG LUN
`4322 Wilshire Boulevard, Suite 200
`Los Angeles, CA 90010
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` Kecia J. Reynolds
`kecia.reynolds@pillsburylaw.com
`PILLSBURY WINTHORP SHAW
`PITTMAN LLP
`1200 Seventeenth Street, NW
`Washington, DC 20036
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`Luke Toft
`ltoft@foxrothschild.com
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`
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`Andrew Hansen (pro hac vice)
`ahansen@foxrothschild.com
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`Archana Nath (pro hac vice)
`anath@foxrothschild.com
`
`Elizabeth A. Patton (pro hac vice)
`epatton@foxrothschild.com
`
`FOX ROTHSCHILD LLP
`222 South Ninth Street, Suite 2000
`Minneapolis, MN 55402
`
`
`Date: April 2, 2020
`
`
`
`
` /s/Kyle L. Elliott .
`Kyle L. Elliott (Reg. No. 39,485)
`.
`Attorney for Petitioner
`American National Manufacturing, Inc.
`
`- 14 -
`
`WA 14551779.2
`
`
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