CASE IPR2019-01279
`Patent No. 8,510,407
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`LENOVO HOLDING COMPANY, INC.,
`LENOVO (UNITED STATES) INC., and
`MOTOROLA MOBILITY LLC,
`Petitioners,
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`v.
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`DODOTS LICENSING SOLUTIONS LLC,
`Patent Owner.
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`CASE IPR2019-01279
`Patent No. 8,510,407
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`PATENT OWNER DODOTS LICENSING SOLUTIONS, LLC’S
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`SUR-REPLY
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
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`LENOVO HOLDING COMPANY, INC.,
`LENOVO (UNITED STATES) INC., and
`MOTOROLA MOBILITY LLC,
`Petitioners,
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`v.
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`DODOTS LICENSING SOLUTIONS LLC,
`Patent Owner.
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`
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`CASE IPR2019-01279
`Patent No. 8,510,407
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`PATENT OWNER DODOTS LICENSING SOLUTIONS, LLC’S
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`SUR-REPLY
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`TABLE OF CONTENTS
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`I.
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`Introduction……………………………………………………………….1
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`II. Claim Construction……………………………………………………….2
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`III. The Combination of Hoff & Berg ……………………………………….7
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`IV. The Combination of Razavi & Anderson …………………………….....8
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`V.
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`The Dependent Claims …………………………………………………9
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`VI. The Objective Indicia (i.e., Secondary Considerations) ………………..9
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`VII. The Petition’s Reliance on “Secret” Prior Art Is Appropriately
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`Challenged By Patent Owner……………………………………………12
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`VIII. Conclusion………………………………………………………………..13
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`TABLE OF AUTHORITIES
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`CASES
`Graham v. John Deere Co.,
`383 U.S. 1 (1966)………………………………………..……...……...…10, 11
`In re Cyclobenzaprine,
`676 F.3d 1063 (Fed. Cir. 2012)……………………………………………….10
`In re Geisler,
`116 F.3d 1465 (Fed. Cir. 1997)………………………………………………..5
`Intercontinental Great Brands LLC v. Kellogg N. Am. Co.,
`869 F.3d 1336 (Fed. Cir. 2017)……………………...………………...………10
`KSR International Co. v. Teleflex Inc.,
`550 U.S. 398 (2007)………………………………………………………………10-11
`Phillips v. AWH Corp.,
`415 F.3d 1303 (Fed. Cir. 2005) ……………………...…..……………………..7
`Ruckus Wireless, Inc. v. Innovative Wireless Solutions,
` 824 F.3d 999 (Fed. Cir. 2016)……………….………………………………….6
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`Stratoflex, Inc. v. Aeroquip Corp.,
`713 F.2d 1530 (Fed Cir. 1983)………………………………………………..11
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`EXHIBIT LIST
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`Exhibit No.
`2006
`2007
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`Description
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`Intentionally left blank
`Supplemental Declaration of Dr. Earl Sacerdoti
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`I.
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`Introduction
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`Petitioners have failed to meet their burden of proof to show that the challenged
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`claims should be cancelled. Petitioners’ belated attempt to support a broad definition
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`that “template” can refer to “executable code” is incorrect and tellingly is not
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`accompanied by any expert declaration. Contrary to Petitioners’ contentions, Patent
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`Owner has used the term “template” consistently in each of the contexts in which
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`Petitioners suggest otherwise, and Patent Owner’s construction would not exclude any
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`disclosed embodiments. When the template limitation is properly construed, none of
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`Petitioners’ proffered combinations invalidate any of the challenged claims because the
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`applications they disclose are not templates.
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`Petitioners also wrongly state that the “template” limitation is the only one Patent
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`Owner contests. Reply at 1. Patent Owner’s arguments also related to the “networked
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`information monitor” (“NIM”) limitation, and those arguments have gone unrebutted.
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`As Patent Owner explained, NIMs are frames, and NIMs are distinct from the NIM
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`templates that are used to define them. Patent Owner Response at 1-2, 7, 12-13. Patent
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`Owner also has made arguments relating to dependent claims 8 and 20. Id. at 14-15.
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`Objective indicia (i.e., “secondary considerations”) further support the
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`conclusion that the challenged claims are non-obvious, and Petitioners’ attack on the
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`evidence submitted by Patent Owner would raise too high of a bar for this type of
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`evidence and likewise improperly shifts the burden to Patent Owner. Importantly,
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`Petitioners have not submitted any evidence of their own relating to secondary
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`considerations even though the burden of proof remains theirs. For example, Petitioners
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`have not submitted any evidence of contemporaneous and independent invention. The
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`fact that the Examiner already considered Petitioners’ main references and did not find
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`the claims obvious is yet another indicator that a contrary ruling now would be
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`impermissible hindsight.
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`Petitioners likewise have failed to meet their burden of showing that one of skill
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`in the art would have been motivated to combine the Razavi and Banthia references.
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`As for dependent Claims 8 and 20, Petitioners have failed to submit any evidence
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`to rebut the evidence submitted by Patent Owner, providing instead merely the
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`conclusory statement by Petitioners’ counsel that Petitioners met their burden. Reply at
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`15-16. But attorney argument (even if it had been fleshed out, which it wasn’t) cannot
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`take the place of evidence.
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`Because Petitioners have not met their various burdens, Patent Owner
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`respectfully submits that each of the challenged claims should be confirmed.
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`II. Claim Construction
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`The heart of the dispute between the parties with respect to claim construction
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`relates to the term “template” as used in the phrase “networked information monitor
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`NIM template” (a.k.a., “NIM template”). Petitioners concede that the “NIM” should be
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`interpreted as “a fully configurable frame with one or more controls” through which
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`content is presented to the user. Reply at 2. Thus, the dispute boils down to how the
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`“template” limitation should be interpreted as it relates to the NIM. Even if the template
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`limitation is not deemed to have an express definition in the specification, an
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`interpretation of this limitation is needed in order to resolve Petitioners’ validity
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`challenges.
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`In its Petition, Petitioners did not put forth a proposed construction of the
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`“template” limitation, and only now in its sur-reply do the Petitioners attempt to defend
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`a construction of this term that would be broad enough to include a “template” that itself
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`is executable code. Petitioners’ arguments all miss the mark.
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`Petitioners first argue that Patent Owner’s proposed construction is not supported
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`by the specification. Reply at 2-3. Petitioners are incorrect. The specification clearly
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`distinguished the patented approach from the prior art approach of downloading
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`applications, and every reference to the NIM template is consistent that it is a data
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`structure not compiled code.
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`Tellingly, Petitioners have not submitted an expert declaration to support their
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`new contentions about the specification, and thus have not submitted evidence as to
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`how the specification would be understood by a person of skill in the art in this regard.
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`This may explain why they have misunderstood Figure 13, which as Dr. Sacerdoti
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`explains does in fact show a data structure. Supp. Sacerdoti Decl. (Ex. 2007), ¶ 2.
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`One of the many clear statements in the specification on this issue is the
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`following, cited by the Reply at page 4: “NIMs are extremely flexible, because the
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`definition of the NIM is content, rather than compiled code.” Petitioners try to suggest
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`that this sentence only applies to one particular embodiment (Reply at 4), but one of
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`skill in the art would read this sentence as speaking broadly about NIMs and their
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`definitions, not just one particular embodiment. Supp. Sacerdoti Decl. (Ex. 2007), ¶ 3.
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`Moreover, the “one embodiment” language that Petitioners cite specifies the use of
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`XML, and in that sense distinguishes that one embodiment from embodiments using
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`other languages for data structures, rather than distinguishing that one embodiment from
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`(non-existent) embodiments in which the template is compiled code. Id. And
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`Petitioners misread the language of the specification relating to “Blob[s],” as that
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`reference was to an XML Blob. Id. at 4.
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`Petitioners’ second argument is that Patent Owner’s construction would exclude
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`disclosed embodiments. Reply at 5-7. In this regard, Petitioners contend that the
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`“second executable module” described in the specification is an embodiment of a “NIM
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`template.” Reply at 5. Petitioners are incorrect, as the “second executable module” is
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`part of the client parser application, not an embodiment of a NIM template. Supp.
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`Sacerdoti Decl., ¶¶ 5-11. The specification makes clear that rather than being a NIM
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`template, the “second executable module” uses information from the NIM template. Id.
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`Petitioners further contend that the “NIM definition modules” are further embodiments
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`that supposedly are executable code. Reply at 5-7. Petitioners are incorrect because
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`one of skill in the art would understand that the term “modules” is not limited to
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`executable code as Petitioners wrongly imply. Supp. Sacerdoti Decl., ¶¶ 12-14.
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`Even if (contrary to fact) there were other methods disclosed in the patent for
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`creating a NIM, those methods are not claimed. What is claimed is to use a template,
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`not executable code.
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`Petitioners’ third argument is that Patent Owner makes clear in related patents
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`that a NIM template may be “executed.” Reply at 7-8. Patent Owner’s expert
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`explained in his opening declaration why that is not inconsistent with Patent Owner’s
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`construction.
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`Importantly, Petitioners have not submitted any expert declaration to support
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`their attorneys’ incorrect understanding of how one of skill in the art would interpret the
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`claims. In re Geisler, 116 F.3d 1465, 1470-71 (Fed. Cir. 1997) (argument by counsel
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`cannot take the place of evidence).
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`Petitioners’ contention that the Patent Owner took an inconsistent position during
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`prosecution of a related patent is wholly inaccurate, as the issue there had nothing to do
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`with the current distinction being made by the parties here. And yet again Petitioners
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`have not submitted any expert testimony to support up their contention.
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`Petitioners’ fourth argument is that Patent Owner’s construction of NIM template
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`allegedly is inconsistent with Patent Owner’s allegations in the related district court
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`litigation. Reply at 8-9. Petitioners’ argument is based on a misunderstanding of Patent
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`Owner’s allegations and a misunderstanding of how the accused apps work. Patent
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`Owner’s allegations are consistent with its proffered construction, as the accused apps
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`involve the downloading of templates that are data structures. Supp. Sacerdoti Decl., ¶
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`15. In this respect an “app” is not the same thing as an “applet” or “application.” Id.
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`And yet again the Petitioners have not submitted any evidentiary support for their
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`position.
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`In sum, the specification is consistent in explaining that the NIM template is a
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`data structure, not compiled code, and the “template” limitation should be construed in
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`accordance with the disclosed embodiments. See Ruckus Wireless, Inc. v. Innovative
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`Wireless Solutions, 824 F.3d 999, 1003-04 (Fed. Cir. 2016) (affirming construction of
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`“communication path” as not including wireless communications because the
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`embodiments disclosed in the specification were limited to wired communications).
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`As Dr. Sacerdoti explained, the use of “template” in the ‘407 Patent is also
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`consistent with how the term “template” is understood generally in the field of computer
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`science. Sacerdoti Decl. (Ex. 2004), ¶¶ 29-36. And because the NIM templates
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`contain “definitions,” Patent Owner’s proposed construction is also consistent with how
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`the term “definition” is understood, and it would not make sense to use the term
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`“definition” in connection with compiled code. Id., ¶¶ 43-44. Petitioners have not
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`submitted any evidence to rebut this testimony.
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`Although Patent Owner believes its proposed construction is clearly correct, to
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`the extent Petitioners have created any doubt that doubt should be resolved in a manner
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`that preserves the validity of the claims. Phillips v. AWH Corp., 415 F.3d 1303, 1327
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`(Fed. Cir. 2005) (en banc).
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`III. The Combination of Hoff & Berg
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`Petitioners do not deny that if the “NIM template” limitations require data
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`structures, then the art they rely upon is unavailing. Reply at 9 (arguing only that Patent
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`Owner’s argument “relies on a flawed construction of NIM template”).
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`Patent Owner’s Response explained that the numerous advantages of the
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`patented invention would not be applicable if the NIM template were executable code.
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`Patent Owner’s Response at 9. Not surprisingly, Petitioners have not put forth any
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`argument or evidence to rebut this important point, and this weighs heavily against
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`Petitioners’ position.
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`Petitioners arguments as to Hoff and Berg also fail because Petitioners also have
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`not shown that Hoff and Berg disclose the required NIM that is separate from the
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`alleged NIM template. Petitioners wrongly point to a “channel application” as the NIM
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`even though the parties agree that the NIM is a “frame” (not an application) and even
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`though the NIM must be created on the client device rather than downloaded.1
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`In sum, because the combination of Hoff and Berg discloses neither the
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`required “template” nor the required “NIM,” these two references do not render
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`the challenged claims obvious.
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`IV. The Combination of Razavi & Anderson
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`As with the combination of Hoff and Berg, Petitioners do not deny that if the
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`“NIM template” limitations require data structures, then the combination of Razavi and
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`Anderson is unavailing. Reply at 13 (arguing only that Patent Owner’s argument “relies
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`on an improperly narrow construction of NIM template”). Because neither Razavi nor
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`Banthia disclose the required “template,” the combination of these two references does
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`not render the challenged claims obvious.
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`Moreover, as for motivation to combine, Patent Owner’s Response and
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`accompanying declaration of Dr. Sacerdoti explained why one of skill in the art would
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`not have combined Razavi and Anderson. Petitioners have failed to submit a rebuttal
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`1 The significance of Petitioners’ failed attempt to belatedly submit evidence of
`Berg’s status as prior art should not be ignored by the Board even though Patent
`Owner did not address the issue in its Patent Owner’s Response and thereby
`waived the issue. Petitioner must meet its burden of proof on this issue even
`though Patent Owner remains silent as to why Petitioners haven’t met their burden.
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`declaration from their expert and instead rely solely on attorney argument.
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`V.
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`The Dependent Claims
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`Because the independent claims are valid, so too are the dependent claims.
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`Patent Owner also has submitted separate evidence and argument in support of
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`dependent Claims 8 and 20. Petitioners have failed to submit any evidence in rebuttal,
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`providing instead merely the conclusory statement by Petitioners’ counsel that
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`Petitioners met their burden with their Petition. Reply at 15-16. But attorney argument
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`(even if it had been fleshed out, which it wasn’t) cannot take the place of evidence.
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`VI. The Objective Indicia (i.e., Secondary Considerations)
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`In its Petition, Petitioners failed to present any argument whatsoever relating to
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`objective indicia, and their expert similarly failed to make any argument whatsoever
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`relating to the objective indicia. Notably, one of the objective indicia militating in favor
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`of obviousness would be evidence of contemporaneous invention, but there is no such
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`evidence and Dr. Madisetti did not identify any such evidence despite his purported
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`expertise in the field. As such, the absence of such evidence is an objective indicia
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`supporting non-obviousness.
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`Petitioners’ Reply arguments as to the objective indicia would lead the PTAB to
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`commit reversible error, by focusing too narrowly on just one of these indicia
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`(commercial success) and by wrongly shifting the burden of proof as to all the indicia to
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`Patent Owner. See, e.g., Reply at 16 (“To demonstrate nonobviousness based on
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`‘commercial success,’ Patent Owner must ‘show….’”); id. at 20 (“Patent Owner’s
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`evidence of secondary considerations therefore should be afforded little if any weight.”).
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`Objective indicia are one of the four Graham factors that must be considered in
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`determining whether the challenged claims are obvious. Graham v. John Deere Co.,
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`383 U.S. 1, 17 (1966). Despite this mandate from the Supreme Court, Petitioners treat
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`this factor as if it were optional. Regardless of whether objective indicia must be
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`considered in determining whether there is a prima facia case as to obviousness (e.g., at
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`the institution stage of an IPR), the objective indicia must be considered prior to making
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`the ultimate determination as to obviousness. Intercontinental Great Brands LLC v.
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`Kellogg N. Am. Co., 869 F.3d 1336, 1346 (Fed. Cir. 2017). Despite Petitioners’
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`contrary suggestion, the burden never shifts to the Patent Owner to prove non-
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`obviousness. In re Cyclobenzaprine, 676 F.3d 1063, 1079-80 (Fed. Cir. 2012).
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`The Supreme Court in Graham emphasized the importance of the objective
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`indicia in the analysis, explaining that objective indicia help guard against hindsight and
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`“the temptation to read into the prior art the teachings of the invention in issue.”
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`Graham at 36. The Supreme Court reiterated the importance of the objective indicia in
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`KSR, cautioning factfinders to consider “the distortion caused by hindsight bias” and
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`“be cautious of arguments reliant upon ex post reasoning.” KSR International Co. v.
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`Teleflex Inc., 550 U.S. 398, 421 (2007). And the Federal Circuit has explained that the
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`objective indicia “may often be the most probative and cogent evidence in the record.”
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`Stratoflex, Inc. v. Aeroquip Corp., 713 F.2d 1530, 1538 (Fed Cir. 1983).
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`The Supreme Court in Graham did not provide an exhaustive list of what such
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`indicia could be. Rather, the Supreme Court left this list open ended: “Such secondary
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`considerations as commercial success, long felt but unsolved needs, failure of others,
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`etc., might be utilized to give light to the circumstances surrounding the origin of the
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`subject matter sought to be patented.” Graham at 17-18 (emphasis added). The
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`Supreme Court made clear too that some objective indicia may cut both ways – some
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`favoring a finding of obviousness and some favoring a finding of nonobviousness –
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`rather than being relegated to the role of rebutting a prima facie case of obviousness. Id.
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`at 18 (“As indicia of obviousness or nonobviousness, these inquiries may have
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`relevancy.”).
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`As mentioned above and in Patent Owner’s Response, the lack of
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`contemporaneous and independent invention is an objective indicia undermining
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`Petitioners’ obviousness contention. Patent Owner’s Response at 16 (“Nor do
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`Petitioners submit evidence of contemporaneous and independent invention by others,
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`even though they have the burden of proof.”). If Petitioners had any such evidence they
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`had ample opportunity to present it in their Petition and Reply. Petitioners cannot avoid
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`the impact of this objective indicia by burying their heads in the sand and staying silent.
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`Petitioners are also wrong with their attorney criticism of Patent Owner’s
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`unrebutted evidence of commercial success. The Ramde declaration explained the
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`commercial success of the technology described in the ‘407 Patent, as well as why the
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`success should be attributed to the patented invention rather than other factors. Ramde
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`Decl., ¶¶ 3-5 (Ex. 2003). Although Petitioners state that Mr. Ramde’s testimony should
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`be given “little weight” (Reply at 17), giving the testimony any weight further tips the
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`objective indicia in favor of a finding of non-obviousness given that Petitioners have not
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`submitted any counter evidence and given that the burden rests with Petitioners.
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`Moreover, Mr. Ramde’s deposition testimony is entirely consistent with his declaration
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`testimony.
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`VII. The Petition’s Reliance on “Secret” Prior Art Is Appropriately Challenged
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`By Patent Owner
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`As explained in the Patent Owner’s Response, many of the references relied
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`upon by Petitioners were published only after the critical date for the ‘407 Patent (April
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`26, 1999).
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`It is appropriate for a litigant to advocate that prior rulings be overturned. Patent
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`Owner believes that a patent that was not available to one of ordinary skill in the art as
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`of the critical date could not have rendered the invention obvious as of that date to one
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`of ordinary skill in the art, and that the same “public accessibility” standard applicable to
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`printed publications should apply to patents and patent applications. Even if the PTAB
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`is compelled to follow existing precedent that considers “secret art” in the obviousness
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`analysis, Patent Owner must advance the argument here to preserve it for appeal (e.g.,
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`as an alternative ground of affirmance in any appeal that Petitioners may file once the
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`validity of the claims is confirmed).
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`VIII. Conclusion
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`Because Petitioners’ Reply fails to rebut Patent Owner’s arguments, and because
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`Petitioners have failed to carry their burden of proof, Patent Owner respectfully requests
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`that the challenged claims be confirmed.
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`Respectfully submitted,
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`By: /s/ Lewis E. Hudnell, III
`Lewis E. Hudnell, III
`Reg. No. 51,185
`(Special Counsel to Progress LLP)
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`Hudnell Law Group P.C.
`800 W. El Camino Real
`Suite 180
`Mountain View, CA 94040
`T: 650-564-7720
`F: 347-772-3034
`lewis@hudnelllaw.com
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`Lead Counsel for Patent Owner
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`Perry Goldberg (pro hac vice)
`Progress LLP
`11620 Wilshire Blvd., Suite 900
`Los Angeles, CA 90025
`T: 310-697-7201
`goldberg@progressllp.com
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`Back up Counsel for Patent Owner
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`CERTIFICATE OF SERVICE
`I certify that the foregoing PATENT OWNER DODOTS LICENSING
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`SOLUTIONS, LLC’S PATENT OWNER’S SUR-REPLY was served on
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`September 19, 2020 on the Petitioner by filing this document through the Patent
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`Trial and Appeal Board End-to-End System as well as e-mailing a copy to
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`jalemanni@kilpatricktownsend.com, smoore@kilpatricktownsend.com,
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`taludlam@kilpatricktownsend.com, and MMeyer@kilpatricktownsend.com.
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`By: /s/ Lewis E. Hudnell, III
`Lewis E. Hudnell, III
`Reg. No. 51,185
`(Special Counsel to Progress LLP)
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`Hudnell Law Group P.C.
`800 W. El Camino Real
`Suite 180
`Mountain View, CA 94040
`T; 650-564-7720
`F: 347-772-3034
`lewis@hudnelllaw.com
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`CERTIFICATE OF COMPLIANCE WITH TYPE-VOLUME
`LIMITATION, TYPEFACE REQUIREMENTS, AND TYPE STYLE
`REQUIREMENTS
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`1.
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` This Patent Owner Response complies with the type-volume
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`limitation of words applicable to replies, comprising fewer than 5,000 words,
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`excluding the parts exempted by 37 C.F.R. § 42.24.
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`2.
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`This Patent Owner Response complies with the general format
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`requirements of 37 C.F.R. § 42.6(a) and has been prepared using Microsoft® Word
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`for Mac Version 16.32 in 14 point Times New Roman.
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`By: /s/ Lewis E. Hudnell, III
`Lewis E. Hudnell, III
`Reg. No. 51,185
`(Special Counsel to Progress LLP)
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`Hudnell Law Group P.C.
`800 W. El Camino Real
`Suite 180
`Mountain View, CA 94040
`T; 650-564-7720
`F: 347-772-3034
`lewis@hudnelllaw.com
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`16
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