`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`ROKU, INC.,
`Petitioner,
`v.
`UNIVERSAL ELECTRONICS, INC.,
`Patent Owner.
`
`___________________
`
`Case IPR2019-01615
`U.S. Patent No. 9,716,853 B2
`___________________
`
`
`PETITIONER ROKU, INC.'S REQUEST FOR REHEARING
`
`
`
`
`
`
`
`
`
`Mail Stop "PATENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`Case IPR2019-01615
`U.S. Patent No. 9,716,853
`TABLE OF CONTENTS
`
`Standard for Rehearing ........................................................................................................1
`I.
`II. Background .........................................................................................................................1
`III.
`The Board Erred in Implicitly Narrowing the Scope of Independent Claim 1 in Two
`Ways. .........................................................................................................................................4
`A.
`The Board erred in implicitly and narrowly construing independent claim 1 to require
`consultation of the claimed listing to determine which communication method to use. ............5
`1.
`Claim 1 does not require consulting the created listing to determine which
`communication method to use. ............................................................................................5
`2.
`Even under the Board’s implicitly narrow construction, Chardon discloses consulting
`the listing to determine which communication method to use. ........................................... 10
`B.
`The Board erred in implicitly and narrowly construing the term “communication
`method.” ............................................................................................................................... 13
`
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`INTRODUCTION
`The Board erred by implicitly construing too narrowly key limitations of
`
`independent claim 1 that neither party advocated for. First, claim 1 does not require
`
`consulting the created listing to determine which communication method to use.
`
`Second, the term “communication method” is not limited to a command
`
`transmission medium, but instead also includes the command protocols to be used.
`
`Under a correct claim interpretation, Chardon renders the claims obvious. And,
`
`even under the Board’s narrow claim interpretation, it overlooked portions of
`
`Chardon that meet the claim limitations and render the claims obvious.
`
`ARGUMENT
`
`I.
`
`Standard for Rehearing
`“A party dissatisfied with a decision may file a single request for rehearing
`
`without prior authorization from the Board.” 37 C.F.R. § 42.71(d). “The burden of
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`showing a decision should be modified lies with the party challenging the decision.
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`The request must specifically identify all matters the party believes the Board
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`misapprehended or overlooked, and the place where each matter was previously
`
`addressed in a motion, an opposition, or a reply.” Id.
`
`II.
`
`Background
`Claim 1 of the challenged ’853 patent is a system claim directed to a
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`universal control engine (“UCE”) responsible for controlling devices in, for
`
`example, a home theater system. The UCE’s memory has executable instructions
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`U.S. Patent No. 9,716,853
`that cause it to detect a target appliance. It then uses the target appliance’s identity
`
`to “create a listing comprised of at least a first [and second] communication
`
`method.” The two “communications methods” are different and are, broadly, “for
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`use in controlling” a first and second “functional operation of the intended target
`
`appliance.” Exemplary functional operations may be, for example, a “power on”
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`command or a “volume up” command.
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`The executable instructions on the UCE respond to a received request from a
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`“controlling device,” like a hand-held remote control, “by causing a one of the first
`
`and second communication methods [in the listing] that has been associated with
`
`the requested one of the first and second functional operations to be used to
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`transmit to the intended target appliance a command.” The claim does not specify
`
`how the UCE chooses which communication method to use—it simply “causes”
`
`one of them “to be used to transmit” a command to the target appliance.
`
`Chardon is the primary reference in this IPR. Like the ’853 patent, it
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`describes a universal control engine for controlling appliances in a home theater
`
`environment. Chardon’s UCE (its “multi-media gateway”) uses a target
`
`appliance’s Extended Display Identification Data (“EDID”) to generate a linked
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`database of command codes for potential use by that target appliance. The database
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`includes Consumer Electronic Control (“CEC”) command codes – i.e., a set of
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`CEC-specific command codes that are used where the controlling device
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`determines that the CEC protocol is appropriate and that the commands will thus
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`be sent over a wired HDMI bus. Pet. at 20-21. The database also has a set of infra
`
`red (“IR”) command codes – i.e., a set of IR-specific command codes that are used
`
`where the controlling device determines that IR protocols are appropriate and that
`
`the commands will thus be sent wirelessly using infra red communications. Id.
`
`This description of Chardon comports with the Board’s own description in its Final
`
`Written Decision. See e.g., FWD at 21 (“Chardon describes that its remote
`
`database 135 stores sets of command codes, that these may include both ‘a set of
`
`CEC command codes’ and ‘a set of IR command codes,’ and that these may be
`
`linked to a device ID.”); see also FWD at 12-13.
`
`Chardon’s controlling device also includes the physical hardware for
`
`sending both IR and CEC communications. It has an IR transceiver for sending IR
`
`command codes. Pet. at 20, citing EX1005, ¶40; Pet. at 57. And it has a CEC bus
`
`or communication port over which CEC command codes may be communicated to
`
`HDMI appliances. Id. Again, this description of Chardon comports with the
`
`Board’s own description in its Final Written decision. FWD at 12 (“[Chardon’s]
`
`remote control also may include an IR transceiver, an RF transceiver, and a bus
`
`that includes a CEC bus or communication port over which CEC command codes
`
`may be communicated to HDMI appliances.”).
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`III.
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`Case IPR2019-01615
`U.S. Patent No. 9,716,853
`The Board Erred in Implicitly Narrowing the Scope of Independent
`Claim 1 in Two Ways.
`The Board, in making its final determination, focused on the claimed listing
`
`of “communication methods.” It “evaluate[d] whether command codes in
`
`Chardon’s database teach or suggest the listing of communication methods of
`
`claim 1.” FWD at 21. The Board answered that in the negative. In doing so it
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`appears to have made two implicit claim construction errors.
`
`First, the Board appears to have implicitly and wrongly imposed a
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`requirement in claim 1 that the selection of which “communication method” to use
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`somehow depends on the content of the created “listing” of communication
`
`methods. While not excluding that possibility, claim 1 is broader and has no such
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`requirement. And even if the selected communication method in claim 1 must
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`depend on the content of the claimed listing, Chardon discloses this feature.
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`Second, the Board appears to have implicitly and wrongly construed the term
`
`“communication method” to be limited to the “method of transmission” or the
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`“transmission medium” through which the selected command is sent. The parties,
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`however, agree that the “communication method” also refers to, at least, the
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`communication protocol to be employed, and Chardon thus discloses a database
`
`with at least two different communication methods. We explain each error below.
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`A. The Board erred in implicitly and narrowly construing
`independent claim 1 to require consultation of the claimed listing
`to determine which communication method to use.
`The Board rejected Petitioner’s argument, in part, because it believed that
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`claim 1’s selection of a preferred “communication method” is somehow dependent
`
`on the contents of the created listing of communication methods. For example, the
`
`Board found that “Petitioner’s argument that the method of transmission is
`
`dependent on the contents of the database is not supported by its citations to
`
`Chardon.” FWD at 21; accord at 22 (“Chardon does not describe deciding whether
`
`to send an IR code based on consulting an EDID-linked database of command
`
`codes.”); accord at 22 (“Petitioner does not cite Chardon to support how a
`
`communication method is selected ‘depending on the contents of the database for a
`
`given appliance’ (Reply 11)….”). To the extent that the Board held the claims
`
`patentable because Chardon’s system allegedly does not consult its EDID-linked
`
`command code databases to determine which communication method should be
`
`used, the Board made two dispositive errors.
`
`1. Claim 1 does not require consulting the created listing to determine
`which communication method to use.
`Nowhere does claim 1 require that the selection of which communication
`
`method to use somehow “depend on the contents” of the claimed listing of
`
`communication methods. Nor does it require the claimed listing to be consulted to
`
`determine which communication method to use. All claim 1 requires is that the
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`listing be “for use in controlling each of at least a first [and second] functional
`
`operation of the intended target appliance.” EX1001, 14:59-64. And there can be
`
`little dispute that Chardon’s EDID-linked database, which includes sets of CEC
`
`and IR command codes, is “for use in controlling [a plurality of] functional
`
`operation[s] of the intended target appliance,” as claimed. See e.g., Pet at 58-59,
`
`citing EX1007, ¶207 (describing Chardon’s EDID-linked database as “a set of
`
`command codes configured for controlling the HDMI display”).
`
`The rest of the claim also does not require the selection of a particular
`
`communication method to depend on the contents of the claimed listing. All claim
`
`1 requires in that regard is that the executable instructions “respond to a received
`
`request from a controlling device” to instantiate one of the plurality of functional
`
`operations “by causing a one of the first and second communication methods in the
`
`listing of communications methods … to be used to transmit to the intended target
`
`appliance a command.” The claim simply does not specify any particular means of
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`causation, let alone a specific requirement that the selection of which
`
`communication method to use depends on the contents of the created listing.
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`Put differently, nothing in the claim precludes, for a particular target
`
`appliance, having instructions that cause a pre-prioritized communication method
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`to be used based on the type of intended target appliance, and only then consults
`
`the created listing to obtain a command code that is appropriately formatted for the
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`selected protocol and that is associated with requested functional operation. By
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`using the broader language of simply “causing a one” of the two communication
`
`methods to be used, without more, leaves open many possibilities.
`
`Dependent claims 2 and 6 confirm this understanding. In dependent claim 2,
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`for example, the UCE responds to the request not by consulting the claimed listing,
`
`but rather by “causing a highest prioritized one of the first and second
`
`communication methods in the listing of communication methods … to be used to
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`transmit … a command.” And, as set forth in dependent claim 6, the UCE
`
`determines the highest prioritized communication method by using “at least one
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`characteristic associated with each of the plurality of communication methods in
`
`the listing.” Importantly, dependent claims 2 and 6 modify the “responding to a
`
`received request … by causing” step, and not the “respond to a detected presence
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`of an intended target appliance … by creat[ing] a listing” step. So the dependent
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`claims also do not imply that the choice of communication method has been
`
`embedded in the created listing—only that the executable instructions broadly
`
`“cause” the selection of one of them in response to a received request.
`
`The Board overlooked that ’853 patent specification is similarly broad in
`
`scope. It explains that “[i]n order to select the optimum command method for each
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`function of each configured appliance any suitable method may be utilized….”
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`EX1001, 9:60-631; see also Pet. at 8. One example sets “a system-wide
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`prioritization of command media and methods by desirability (e.g. apply IP, CEC,
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`IR in descending order).” EX1001, 9:62-64, 14:10-24; see also Pet. at 8. In other
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`embodiments the ’853 creates “appliance-specific command maps by brand and/or
`
`model” or “function-specific preference and/or priority maps (e.g., all volume
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`function commands via IR where available)” or “any combination thereof.”
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`EX1001, 9:64-67; Pet. at 8.
`
`The main point here is that the ’853 patent specification describes a variety
`
`of ways to determine which communication method to use, and claim 1 does not
`
`exclude any of them – it simply responds to a functional operation request by
`
`“causing” one of the communication methods in the listing “to be used to transmit
`
`… a command.” Having selected the communication method (i.e., having caused it
`
`to be used), the created listing is used to obtain, for the intended target appliance,
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`the appropriately formatted command associated with the selected function.
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`Chardon’s Figure 5, which both the Petition (e.g., Pet. at 57-58, 62-63) and
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`Board (FWD at 21-22) relied upon as an exemplary embodiment, falls well within
`
`the broad scope of claim 1. There, Chardon’s intended target appliance is “an
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`HDMI appliance” having “an HDMI cable.” EX1005, FIG. 5, step 500, ¶¶58-59
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`(describing FIG. 5). For such an appliance, Chardon prioritized communication
`
`
`1 All emphasis added except where otherwise indicated.
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`method is CEC, so its instructions are configured to select a CEC command code
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`from the EDID-linked set of CEC command codes for that appliance that
`
`corresponds to the requested function. Id. In that embodiment, Chardon’s
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`executable instructions are thus configured to “respond to a received request from
`
`a controlling device … by causing [the CEC command code] that has been
`
`associated with the requested … functional operation[] to be used to transmit to
`
`the intended appliance a command…,” just as claim 1 recites. Chardon’s
`
`instructions thus caused transmission of a CEC command code (from the preferred
`
`set of CEC command codes in the EDID-linked database) via an HDMI cable
`
`because that is the prioritized communication method for the selected target
`
`appliance—namely, an HDMI appliance having an HDMI cable. In fact, the ’853
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`patent contemplates such a prioritization scheme. See EX1001, 9:60-67; 14:6-24.
`
`*
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`*
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`*
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`Claim 1 of the ’853 patent, by its own plain language, does not require the
`
`choice of a preferred communication method to be dependent on the contents of
`
`the created listing of communication methods. To the extent that the Board
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`implicitly read that limitation into the claim, and then denied the Petition because
`
`Chardon allegedly does not disclose that limitation, it erred.
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`2. Even under the Board’s implicitly narrow construction, Chardon
`discloses consulting the listing to determine which communication
`method to use.
`Even if the selection of the communication method to be used is dependent
`
`on the contents of the created listing (which it is not), the Board still erred in
`
`determining that Chardon does not meet this limitation in at least two ways: (a) the
`
`Board misconstrued ¶60 of Chardon; and (b) the Board ignored all other cited
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`teachings of Chardon that firmly establish the reliance on a continually updated
`
`database for determining which communication method to use.
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`a. The Board misinterpreted Chardon’s ¶60, FWD at 22 (referring multiple
`
`times to EX1005 ¶60). As explained in the Petition, Chardon’s EDID-linked
`
`databases may be developed, refined, and stored on a remote server. Pet. at 49-50,
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`citing EX1005, ¶¶55-56 (explaining one embodiment where the database of
`
`command codes is built at a remote database). Paragraph 60, in turn, explains how,
`
`in one embodiment, Chardon’s UCE uses that remote database: Chardon’s UCE
`
`“may determine from the remote server that a given HDMI appliance is not
`
`configured to receive CEC command codes, and will by default send IR command
`
`codes to the given HDMI appliance instead of sending CEC command codes.”
`
`EX1005, ¶60; see Reply at 11. Chardon thus unambiguously determines from
`
`(consults) the remote database that CEC is not an option, and then defaults to IR.
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`The Board mischaracterized this disclosure as either determining that CEC
`
`will not work for a given HDMI appliance or “always send[ing] an IR command
`
`code first, followed by a CEC code if no response is detected.” FWD at 22. But
`
`that is not at all what Chardon’s ¶60 says—it uses an IR command code by default
`
`only after “determin[ing] from the remote server that a given HDMI appliance is
`
`not configured to receive CEC command codes.” EX1005, ¶60. Put differently,
`
`Chardon consults the command code database (i.e. the EDID-linked command
`
`code database) on the remote server for a given appliance to determine which
`
`communication method (protocol) to use—CEC or IR. See also, Pet. at 50, citing
`
`EX1005, ¶33 (“The remote database may store the sets of command codes and the
`
`links under control of the remote server…[including] IR command codes and/or
`
`CEC command codes”).
`
`Chardon’s ¶51 confirms use of a remote server for this purpose. See, Pet. at
`
`52, citing EX1005, ¶51 (explaining how “linking an EDID to a make or a model
`
`number of the HDMI display initiates the remote server to link the EDID to a set of
`
`IR command codes for the HDMI display stored in remote database 135, and/or to
`
`link the EDID to a set of CEC command codes for the HDMI display stored in
`
`remote database 135”); Pet. at 37-38, also citing ¶51. Chardon thus expressly
`
`discusses at least one embodiment where it consults its created listing on the
`
`remote server to determine which communication medium or protocol to use.
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`b. Other portions of Chardon confirm that Chardon’s UCE (the remote
`
`control engine on its multimedia gateway) interfaces with Chardon’s EDID-linked
`
`command code database to determine which communication method to use. For
`
`example, the Board overlooked that Chardon describes “continuously update[ing]
`
`the listing based on new received or observed information.” Pet. at 22-23, citing
`
`EX1005, ¶¶44, 46, 57, EX1003, ¶137. It does so to “facilitate communication
`
`between a remote control device and an intended appliance” by acting “as ‘a bridge
`
`device’” for relaying commands between a controlling device and an intended
`
`target appliance. Pet. at 23, citing EX1005, ¶43; see also Pet. at 61-63, citing
`
`EX1005, ¶43. It is thus Chardon’s UCE that, on an operation-by-operation basis, is
`
`responsible for selecting which communication method to use first, and to select an
`
`alternate communication method if the first one doesn’t work. See e.g., Pet. at 50,
`
`citing EX1005, ¶20 (describing how Chardon, determines CEC command code
`
`failures and takes action taken in view thereof to determine alternative command
`
`codes using Chardon’s EDID-linked database). Chardon’s continually updated
`
`EDID- and Vendor ID linked databases are integral to that selection.
`
`In sum, even under the Board’s implicitly narrow construction, both the ’853
`
`patent and Chardon describe strikingly similar methods where the executable
`
`instructions cause a communication method like CEC to be attempted first, and if
`
`no confirmation is received that the communication was successful, then trying a
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`secondary communication method like IR. Pet. at 57, 63 (comparing EX1001, FIG.
`
`13 with Chardon’s FIG. 5 embodiment).
`
`B.
`
`The Board erred in implicitly and narrowly construing the term
`“communication method.”
`The Board also appears to have erred in implicitly construing the term
`
`“communication method” to be limited to a “method of transmission” or a
`
`“command transmission medium.” For example, the Board alleged that
`
`“Petitioner’s argument that the method of transmission is dependent on the
`
`contents of the database is not supported by its citations to Chardon.” FWD at 21-
`
`22 (citing Reply at 11). The Board’s discussion in the last paragraph on p. 22 of the
`
`FWD also implies that it understood the term “communication method” to refer to
`
`different “command transmission mediums.” FWD at 22. (rejecting notion that a
`
`“stored command code”—even the acknowledged CEC command codes and IR
`
`command codes in the EDID-linked database—could identify a particular
`
`“communication method”).
`
`If the Board implicitly construed the term “communication method” to be
`
`limited to a “method of transmission” or a “command transmission medium,” it
`
`erred. No party has ever advocated for that overly narrow construction. Patent
`
`Owner itself makes it abundantly clear in its Patent Owner Response that the
`
`“communication method” refers to a “medium or protocol.” POR at 22 (“Thus, a
`
`POSITA would have understood that a “communication method” is a medium or
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`protocol for transmitting or receiving information.”); cf. Sur-Reply at 9 (defining
`
`“communication method” as “a medium or protocol for transmitting or receiving
`
`information”). Petitioner’s Reply also explains that the claimed “communication
`
`method” is broader than simply a transmission medium. See Reply at 13-14.
`
`So there is no dispute between the parties that the claim term
`
`“communication method” could be at least “a medium or protocol for transmitting
`
`or receiving information.” The ’853 patent similarly distinguishes between a
`
`“command transmission medium (e.g., IR, CEC over HDMI, IP over WiFi, etc.)
`
`and a corresponding command value and control protocol to be used in
`
`transmitting that command to an intended target appliance, e.g., TV 106, in a
`
`format recognizable by that appliance to thereby control one or more functional
`
`operations of that appliance.” EX1001, 6:24-32.
`
`The term “communication method” is thus not limited solely to a “method of
`
`transmission” or a “command transmission medium.” It is broader and it
`
`encompasses, at least, the control protocols used to transmit a command—e.g., IR
`
`protocols and CEC protocols. There is no dispute whatsoever that Chardon’s
`
`EDID-linked set of command codes includes both a set of IR command codes and
`
`a set of CEC command codes. See FWD at 12-13 (describing Chardon). There can
`
`also be no dispute that a CEC command code at least indicates that the CEC
`
`protocol and its associated hardware are used, and that an IR command code at
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`least indicates that IR protocols and its associated IR hardware are used. Pet. at 2,
`
`24, EX1003, ¶¶35-43 (detailing structure of IR codes), ¶¶77-88 (detailing structure
`
`of CEC codes). To suggest otherwise defies common sense because it would defeat
`
`the necessity to ever create two separate sets of command codes in the first place.
`
`The Board thus erred when it concluded that “Petitioner has not shown that
`
`one of ordinary skill in the art would have understood Chardon’s EDID-linked sets
`
`of command codes specific to certain communication methods would teach or
`
`suggest a listing comprised of at least two different communication methods.”
`
`FWD at 22-23. This circular conclusion simply begs the question as to the scope of
`
`the term “communication method.” To the parties, however, the answer is clear:
`
`An EDID-linked database that includes, for an identified target appliance, a set of
`
`CEC command codes and an alternate and separate set of IR command codes,
`
`unambiguously discloses two different “communication methods” if, as the parties
`
`agree, the term “communication method” is properly construed to encompass
`
`different protocols (e.g., CEC and IR) to be used for transmitting information.
`
`PETITION FOR RELIEF
`For the foregoing reasons, and under 37 C.F.R. § 42.71(d), Roku, Inc.
`
`hereby respectfully requests rehearing of the Board’s determination in its Final
`
`Written Decision (Paper 33). Roku, Inc. respectfully requests that the Board grant
`
`this motion for rehearing and find the challenged claims to be unpatentable.
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`Respectfully submitted,
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`/Jon E. Wright/
`
`Jon E. Wright, Reg. No. 50,720
`Attorney for Petitioner Roku, Inc.
`
`
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`
`
`
`Date: May 13, 2021
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
`
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`CERTIFICATE OF SERVICE (37 C.F.R. § 42.6(e))
`The undersigned hereby certifies that on May 13, 2021, a true and correct
`
`copy of the foregoing PETITIONER ROKU, INC.’S REQUEST FOR
`
`REHEARING was served electronically via e-mail in its entirety on the following
`
`counsel for Patent Owner:
`
`Benjamin S. Pleune (Lead Counsel)
`Ryan W. Koppelman (Back-up Counsel)
`Thomas W. Davison (Back-up Counsel)
`James H. Abe (Back-up Counsel)
`Caleb J. Bean (Back-up Counsel)
`Derek S. Neilson (Back-up Counsel)
`Nicholas T. Tsui (Back-up Counsel)
`Gary Jarosik (Back-up Counsel)
`James J. Lukas, Jr. (Back-up Counsel)
`Benjamin P. Gilford (Back-up Counsel)
`
`ben.pleune@alston.com
`ryan.koppelman@alston.com
`tom.davison@alston.com
`james.abe@alston.com
`caleb.bean@alston.com
`derek.neilson@alston.com
`nick.tsui@alston.com
`jarosikg@gtlaw.com
`lukasj@gtlaw.com
`gilfordb@gtlaw.com
`
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C
`
`/Jon E. Wright/
`Jon E. Wright, Reg. No. 50,720
`Attorney for Petitioner Roku, Inc.
`
`
`
`
`
`
`
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`
`
`Date: May 13, 2021
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
`
`
`16745269
`
`
`
`
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