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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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`APPLE INC.,
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`Petitioner
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`v.
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`LBT IP I LLC,
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`Patent Owner
`___________
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`
`
`Case No. IPR2020-01189
`U.S. Patent No. 8,497,774
`____________
`
`
`PETITIONER APPLE INC.’S SUR-REPLY TO PATENT OWNER’S
`REPLY TO PETITIONER’S OPPOSITION TO MOTION TO AMEND
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`B.
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`C.
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`TABLE OF CONTENTS
`1
`INTRODUCTION
`I.
`II. CLAIM CONSTRUCTION ....................................................................... 1
`THE DISCLOSURES OF THE ’774 PATENT RELIED UPON BY PATENT
`A.
`OWNER DO NOT SUPPORT SUCH AN INTERPRETATION .......................... 1
`PATENT OWNER’S DISTINCTION BETWEEN “TIMING SCHEDULE”
`AND “REFRESH RATE” IS UNSUPPORTED BY THE ’774 PATENT .............. 3
`PATENT OWNER’S NEWLY PROPOSED CONSTRUCTION FOR
`“VALUE” IMPROPERLY IMPORT LIMITATIONS INTO THE CLAIMS............ 5
`III. THE PROPOSED REPLACEMENT CLAIMS ARE NOT
`PATENTABLE ........................................................................................... 7
`THE PROPOSED REPLACEMENT ARE UNPATENTABLE UNDER
`A.
`35 U.S.C. § 103 .................................................................................. 7
`1.
`Ground 1: Claims 20–34 Are Obvious over Sakamoto .............. 7
`2.
`Ground 4: Claims 20–34 Are Obvious over Sakamoto in
`View of Huang........................................................................ 10
`IV. CONCLUSION ......................................................................................... 12
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`TABLE OF AUTHORITIES
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`Statutes:
`35 U.S.C. § 103 .................................................................................. 1, 6, 12
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`Regulations:
`37 C.F.R. § 42.6 ........................................................................................................ 15
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`37 C.F.R. § 42.6(e) ................................................................................................... 15
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`I.
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`INTRODUCTION
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`Petitioner, Apple Inc., submits this Sur-Reply responsive to Patent Owner’s
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`Reply to Petitioner’s Opposition to Patent Owner’s Motion to Amend (Paper 30,
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`“Reply to Opposition”). As set out below and in Petitioner’s Opposition to Patent
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`Owner’s Motion to Amend (Paper 26, “Opposition”), Patent Owner’s Motion to
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`Amend (Paper 16, “MTA”) should be denied because the amended claims improperly
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`use claim construction to import limitations into the claims, lack written description
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`under Patent Owner’s proposed constructions, and are unpatentable under § 103.
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`II. CLAIM CONSTRUCTION
`Patent Owner maintains that the newly added claim limitation “timing
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`schedule” should be interpreted to mean “when to listen for location coordinates and
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`transmit those location coordinates” as opposed to simply how often to listen or
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`transmit updates. See, e.g., Reply to Opposition at 4. Patent Owner also proposes,
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`for the first time, that the claim term “value,” which is responsive to a user input
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`request, be limited to a “time value.” Id at 10. Such claim interpretations are not
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`supported by the disclosure of the ’774 Patent and should be rejected.
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`A. The Disclosures of the ’774 Patent Relied upon by Patent Owner Do
`Not Support Such an Interpretation
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`In support of its proposed interpretation, Patent Owner cites disclosure
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`specifying that the tracking device “‘checks internal time schedule to determine if it
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`should listen for (perform a location lookup of) location coordinates’ and ‘based on
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`1
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`the internal time schedule, portable location tracking device determines whether to
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`transmit [location coordinates 422] to target host 452.’” Reply to Opposition at 3
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`(quoting Ex. 2017, ’451 Application, at p. 18, ll. 9–11 and 16–18). However,
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`disclosures are consistent with the teaching elsewhere in the ’774 Patent that the
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`timing schedule is a refresh rate. For example, using the embodiment of FIG. 4, the
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`device determines whether to transmit the location coordinates based on the
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`specified update interval of 10 minutes, rather than based on any schedule indicating
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`“when” (i.e., a specific time) an update should occur.
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`
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`Ex. 1001, ’774 Patent, FIG. 4 (colored annotations added). As depicted, FIG. 4 itself
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`characterizes “timing schedule 446” as an “update interval,” and the “timing
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`schedule 446” is the same “timing schedule” that is “responsive to a user input
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`request.” See ’774 Patent, 15:13–15 (“user readjusts the initial timing schedule 446
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`for communication of signaling parameters in accordance with a local request by
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`remote user using an Internet accessible icon 432.”) Thus, the “time schedule” relied
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`upon by Patent Owner is an update interval rather than an absolute time “when to
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`listen for location coordinates.” Reply to Opposition at p. 4.
`2
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`Next, Patent Owner argues that because a “refresh rate” is included in the
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`updated set of network signaling protocols that is used to adjust the “internal time
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`schedule,” the internal time schedule must be something other than the refresh rate.
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`Reply to Opposition at 3–4. However, the same language cited by Patent Owner
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`explains this distinction: the received update rate (refresh rate) is used to update the
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`internal update rate (time schedule) by replacing the internally stored value with the
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`newly received update rate. As such, Patent Owner’s interpretation finds no support
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`in the ’774 Patent because the ’774 Patent simply uses “internal time schedule” to
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`describe the internally stored refresh rate specified by the update. ’774 Patent at
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`4:43–49 (describing updating the internal time schedule “in accordance with” the
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`user specified update rate). In sum, Patent Owner provides no example in the ’774
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`Patent of a timing schedule representing absolute times because the ’774 Patent
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`includes none.
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`B.
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`Patent Owner’s Distinction Between “Timing Schedule” and “Refresh
`Rate” is Unsupported by the ’774 Patent
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`Patent Owner argues that the Opposition “attempts to conflate the claim term
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`timing schedule” with “refresh rate.” Reply to Opposition at 5. Indeed, the
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`Opposition shows how the ’774 Patent uses the terms “refresh rate,” “update rate”
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`and “timing schedule” interchangeably. For example, reference numeral 446 is
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`variously described as “update rate 446 (e.g., refresh rate) of location coordinate
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`packets,” “timing schedule (e.g., refresh rate 446),” and “timing schedule 446.” ’774
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`Patent at 11:56–57; 12:59–60; 13:33. Indeed, in describing how the user adjusts the
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`tradeoff between update frequency and battery lifetime, the ’774 Patent refers to both
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`“timing schedule 446” and “update rate 446” within the same paragraph. Id. at
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`15:13–21. As such, the examples of an “update rate” and a “refresh rate” discussed
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`in the Opposition are also examples of the claimed “timing schedule,” and (what is
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`more) they are the only examples of the timings for updates given in the ’774 Patent.
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`Patent Owner attempts to explain away the express statements of the ’774
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`disclosures that a “refresh rate” is one example of a “timing schedule” by rewriting
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`the disclosure of the ’774 Patent:
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`Reply to Opposition at 4 (colored annotations added). However, contrary to Patent
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`Owner’s rewriting, “e.g.” does not mean “based on,” and Patent Owner offers no
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`evidence or even argument as to why “e.g.” should be read differently for “timing
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`schedule” than for the “local battery adjustment mechanism” in the immediately
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`4
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`previous line. In sum, to the extent the Patent Owner’s proposed construction for
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`“timing/time schedule” excludes a refresh rate, it is wholly unsupported by the ’774
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`Patent and should be rejected.
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`C.
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`Patent Owner’s Newly Proposed Construction
`Improperly Import Limitations into the Claims
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`for “Value”
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`Patent Owner proposes, in passing and for the first time, that the claim term
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`“value” in the limitations “the updated set of network communication signaling
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`protocols having a value that is responsive to a user input request” and “the local
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`battery power adjustment mechanism activates or deactivates at least one portion of
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`the transceiver circuitry or the processor circuitry in response to the value” be
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`interpreted so as to require a “time value.” Reply to Opposition at p. 10. Such a claim
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`interpretation would import a limitation from the Specification of the ’774 Patent
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`into the claims and is inconsistent with the sole described example in that
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`Specification. Patent Owner’s proposed constructions should be rejected, and
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`“value” should be accorded its plain and ordinary meaning.
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`First, the Specification describes this “value” with respect to reference
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`numeral 419 of FIG. 4, which depicts a cursor allowing the user to “adjust battery
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`performance” rather than any “time value”:
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`5
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`’774 Patent, FIG. 4 (colored annotations added); see also ’774 Patent 11:46–53
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`(“local battery power adjustment mechanism 416 … communicates a message to
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`active or deactivate a portion of transceiver circuitry 102 or processor circuitry 104
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`or location tracking circuitry 114 to conserve battery charge level 406 responsive to
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`value 419 (e.g., a user input screen control or mouse adjustable cursor value).”).
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`Similarly, the value of the “set of network communication signaling
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`protocols” itself is not “time value.” The ’774 Patent gives, as one example of a
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`value of a communication signaling protocol, “(X Y Z).” ’774 Patent, 11:42. These
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`same X, Y, and Z values are described, in the context of FIG. 5, as “request rate
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`420,” “location coordinates packet 422,” and “listen rate 425,” respectively. Id. at
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`13:1-12. Neither the collection of these values nor any of the individual component
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`values is a “time value” as Patent Owner appears to propose. For at least these
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`reasons, Patent Owner’s belated attempt to insert the requirement that a “value” be
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`a “time value” is unsupported and should be rejected.
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`6
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`III. THE PROPOSED REPLACEMENT CLAIMS ARE NOT
`PATENTABLE
`A. The Proposed Replacement Are Unpatentable Under 35 U.S.C. § 103
`1.
`Ground 1: Claims 20–34 Are Obvious over Sakamoto
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`a)
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`Sakamoto teaches “a communication signaling protocol having a
`value that is responsive to a user input request”
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`Patent Owner argues that Sakamoto fails to teach the claim limitation
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`requiring that “the updated set of network communication signaling protocols hav[e]
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`a value that is responsive to a user input request” because, as Patent Owner interprets
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`the Petition, a “preset threshold value” (set by a user) is used to meet this limitation
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`in the original mapping for claim 1, and this preset threshold value does not
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`“represent a timing schedule” as required by replacement claim 20. Reply to
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`Opposition at pp. 6-7. In making this argument, however, Patent Owner
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`mischaracterizes (or misunderstands) the original mapping in the Petition:
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`specifically, the Petition devotes § VI.C.6.d to explaining how Sakamoto teaches
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`that the terminal user A can select the positioning mode (and therefore the value of
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`the communication signaling protocol). Paper 1, Petition, at pp. 34-36; see also
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`Paper 9, Institution Decision at 21-23 (setting out this mapping finding it
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`persuasive). Furthermore, as set out in § IV.A.3 of the Opposition, Sakamoto’s
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`positioning mode represents a timing schedule for at least one of the request rate and
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`the listen rate. Opposition at pp. 13-15.
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`Sakamoto’s refresh rate is a “refresh rate”
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`b)
`Curiously, Patent Owner contends that Sakamoto’s “refresh rate” is not the
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`same as the “update rate 446/refresh rate 446/refresh rate” in the ’774 Patent. Reply
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`to Opposition at p. 7. However, the ’774 Patent describes one embodiment where
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`the refresh rate is described as “global positioning system (GPS) system refresh rate
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`446.” ’774 Patent, 13:40–43. In other words, the ’774 Patent contemplates that
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`“refresh rate 446” could be a GPS system refresh rate. This is, as pointed out in both
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`the Petition and the Opposition, the refresh rate for the listen rate in Sakamoto’s high
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`sensitivity positioning mode.
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`Petition at p. 34 (red box added). Thus, contrary to Patent Owner’s arguments,
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`Sakamoto teaches a positioning mode that adjusts the refresh rate to be that of the
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`GPS system refresh rate, which is specifically given as one example of a “refresh
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`rate 446” in the ’774 Patent.
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`8
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`Sakamoto teaches updating the refresh rate
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`c)
`Patent Owner next concedes that Sakamoto discloses changing between
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`positioning modes and, as a result of changing positioning modes, applies different
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`refresh rates. Reply to Opposition at 7. Patent Owner contends, however, that while
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`Sakamoto teaches a set of network communication signaling protocols associated
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`with a positioning mode (the listen rate and response rate), it “does not disclose an
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`updated set of network communication signaling protocols that has a user-input
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`request responsive value and represents a timing schedule.” Id. at p. 8. This again
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`misrepresents (or misunderstands) the mapping in the Petition. As explained in the
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`Petition, “switching the mode in this way [manually or automatically based on
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`battery level] is generating an updated set of network communication signaling
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`protocols as claimed.” Petition at p. 30. In other words, if the original set of protocols
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`represents the listen and response rate of high sensitivity positioning mode, then the
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`updated set of protocols represents the listen and response rate of normal sensitivity
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`positioning mode generated after the user instructs a switch from high to normal
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`sensitivity in response to a battery level warning. As described in the Petition, these
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`communication signaling protocols are generated “substantially in real time” in
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`response to the user input instructing the switch. Petition at pp. 29-30.
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`Similar to the original “set of network communication signaling protocols,”
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`the original “cycle timing” is that timing associated with high sensitivity positioning
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`mode and the adjusted cycle timing is that timing associated with normal sensitivity
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`positioning mode after an automatic switch from high sensitivity to normal
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`sensitivity in response based on the battery charge level.
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`2.
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`Ground 4: Claims 20–34 Are Obvious over Sakamoto in View of
`Huang
`a) Huang teaches dynamically updating refresh rates
`First, Patent Owner argues that “Ground 4 continues to rely on Sakamoto’s
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`disclosure that … each positioning mode has an associated refresh rate and changing
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`to a different positioning mode results in a different refresh rate.” Reply to
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`Opposition at p. 10. This is simply incorrect. The proposed combination of Sakamoto
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`and Huang replaces Sakamoto’s discrete positioning modes with a user-
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`configurable, continuous mapping function that dynamically and continuously
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`updates the GPS update frequency based on battery level:
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`is
`listen rate
`the proposed combination, Sakamoto’s GPS
`In
`dynamically adapted according to the mapping function disclosed by
`Huang. Rather than the user specifying the battery thresholds where the
`system switches to normal sensitivity positioning mode (as taught by
`Sakamoto), the user would specify the battery thresholds where update
`frequency begins to decrease (e.g., 75% in Huang’s FIG. 5) and where
`it reaches its minimum value (e.g., 25% in Huang’s FIG. 5).
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`Opposition at pp. 17-18; see also Ex. 1077, Andrews Supplemental Declaration, ¶ 9
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`(describing the advantages of continuous adaptation rather than the abrupt stepped
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`10
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`transitions associated with Sakamoto’s transitions between positing modes). As
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`such, Patent Owner’s arguments with respect to Sakamoto do not apply to the
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`combination of Sakamoto and Huang at least because Huang teaches dynamically
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`updating refresh rates without discrete positioning modes. For this reason, the
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`combination of Sakamoto and Huang renders the amended claims obvious.
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`b)
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`The proposed combination includes a set of communication
`signaling protocols having a value responsive to a user input
`request
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`Finally, based on their proposed construction for “value,” Patent Owner
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`argues that Huang does not teach “an updated set of communication signaling
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`protocols having a value that is responsive to a user input request.” Reply to
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`Opposition at p. 10. Patent Owner does not, however, address the mapping for the
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`claim limitation in the Opposition. In the proposed combination, “the user would
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`specify the battery thresholds where update frequency begins to decrease (e.g., 75%
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`in Huang’s FIG. 5) and where it reaches its minimum value (e.g., 25% in Huang’s
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`FIG. 5).” Opposition at p. 18. In other words, in the proposed combination, the user
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`provides inputs that control the shape of the curve that controls the update rate. For
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`example, Huang depicts one exemplary curve (set of communication signaling
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`protocols) in FIG. 5. As proposed, the user could provide inputs specifying that the
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`update frequency decreased more rapidly such that the minimum update frequency
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`is reached when the battery reaches 50% rather than 25% as depicted below.
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`Andrews Supplemental Declaration, ¶ 8 (annotating Huang FIG. 5); alternative
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`curve. As such, the proposed combination of Sakamoto and Huang teaches a set of
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`communication signaling protocols having a value responsive to a user input request.
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`IV. CONCLUSION
`For the reasons discussed herein, Apple submits that LBT’s proposed
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`substitute claims are unpatentable over at least 35 U.S.C. § 103.
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`Respectfully submitted,
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`ERISE IP, P.A.
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`BY: /s/ Jennifer C. Bailey
`Jennifer C. Bailey, Reg. No. 52,583
`Adam P. Seitz, Reg. No. 52,206
`7015 College Blvd., Suite 700
`Overland Park, KS 66211
`P: (913) 777-5600
`jennifer.bailey@eriseip.com
`adam.seitz@eriseip.com
`
`ATTORNEYS FOR PETITIONER
`APPLE INC.
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`12
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`APPENDIX OF EXHIBITS
`
`Exhibit 1001 U.S. Patent No. 8,497,774 to Scalisi et al. entitled “Apparatus and
`Method for Adjusting Refresh Rate of Location Coordinates of a
`Tracking Device,” filed on April 7, 2009 and issued on July 30,
`2013
`Exhibit 1002 File History of U.S. Patent No. 8,497,774
`Exhibit 1003 Declaration of Scott Andrews
`Exhibit 1004 Certified English Translation of Japanese Unexamined Patent
`Application Publication No. JP 2004-37116A to Sakamoto
`(“Sakamoto”); Certified English Translation of Figures of
`Japanese Unexamined Patent Application Publication No. JP
`2004-37116A to Sakamoto; Affidavit for Sakamoto Translation;
`Affidavit for Sakamoto Figures Translation
`Exhibit 1005
`Intentionally Left Blank
`Exhibit 1006
`Intentionally Left Blank
`Exhibit 1007
`Intentionally Left Blank
`Exhibit 1008
`Intentionally Left Blank
`Exhibit 1009
`Intentionally Left Blank
`Exhibit 1010 U.S. Patent No. 6,799,050 to Krasner, filed June 4, 2001 and
`published September 28, 2004 (“Krasner”)
`Exhibit 1011 U.S. Patent No. 5,845,142 to Hayasaka, filed August 29, 1997 and
`published December 1, 1998 (“Hayasaka”)
`Exhibit 1012
`Intentionally Left Blank
`Exhibit 1013 U.S. Patent No. 5,902,347 to Backman et al. (“Backman”)
`Exhibit 1014
`Intentionally Left Blank
`Exhibit 1015 U.S. Patent No. 6,308,134 to Croyle et al. (“Croyle”)
`Exhibit 1016 U.S. Patent No. 7,024,321 to Deninger et al. (“Deninger”)
`Exhibit 1017 U.S. Patent No. 7,196,661 to Harvey (“Harvey”)
`Exhibit 1018
`Intentionally Left Blank
`Exhibit 1019 U.S. Patent Application Publication No. 2006/0167647A1 to
`Krumm et al. (“Krumm”)
`Exhibit 1020 U.S. Patent No. 5,592,173 to Lau et al. (“Lau”)
`Exhibit 1021 U.S. Patent No. 7,430,675 to Lee (“Lee”)
`Exhibit 1022 U.S. Patent No. 8,467,804 to Lindquist (“Lindquist”)
`Exhibit 1023 U.S. Patent No. 7,760,137 to Martucci et al. (“Martucci”)
`Exhibit 1024 U.S. Patent No. 7,181,192 to Panasik et al. (“Panasik”)
`Exhibit 1025 U.S. Patent No. 7,126,536 to Rabinowitz et al. (“Rabinowitz”)
`Exhibit 1026 U.S. Patent No. 8,797,214 to Taylor et al. (“Taylor”)
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`Exhibit 1027 U.S. Patent No. 7,239,271 to Vyas et al. (“Vyas”)
`Exhibit 1028 U.S. Patent No. 6,850,844 to Walters et al. (“Walters”)
`Exhibit 1029 U.S. Patent No. 7,439,907 to Wang et al. (“Wang”)
`Exhibit 1030 U.S. Patent No. 5,491,486 to Welles, II et al. (“Welles”)
`Exhibit 1031
`Intentionally Left Blank
`Exhibit 1032 Vehicle Location and Navigation Systems, pp. 43-81 (“Zhao”)
`Exhibit 1033
`Intentionally Left Blank
`Exhibit 1034
`Intentionally Left Blank
`Exhibit 1035 Curriculum Vitae of Scott Andrews
`Exhibit 1036 LBT IP I LLC v. Apple Inc., 1:19-cv-01245, No. 1 (D. Del. July 1,
`2019) (“LBT Complaint”)
`Exhibit 1037
`Intentionally Left Blank
`Exhibit 1038
`Intentionally Left Blank
`Exhibit 1039 U.S. Patent Application Publication No. 2007/005243A1 to
`Horvitz et al. (“Horvitz”)
`Exhibit 1040 U.S. Patent Application Publication No. 2007/0005363A1 to
`Cucerzan et al. (“Cucerzan”)
`Exhibit 1041
`Intentionally Left Blank
`Exhibit 1042
`Intentionally Left Blank
`Exhibit 1043
`Intentionally Left Blank
`Exhibit 1044 U.S. Patent No. 6,657,587 to Mohan et al. (“Mohan”)
`Exhibit 1045-
`Intentionally Left Blank
`1066
`Exhibit 1067 District Court Complaint DDE-1-19-cv-01245-1
`Exhibit 1068 Scott Andrews Deposition Transcript
`Exhibit 1069 Email Regarding Motion to Amend
`Exhibit 1070 Email from Board Re Hearing
`Exhibit 1071 Attorneys for LBT IP I LLC v. Apple Inc. DDE-1-19-cv-01245
`Exhibit 1072 Annotated NOTICE OF SERVICE of Apples Production of Core
`Technical Documents
`Exhibit 1073 2020-05-01 DI-29 Agreed Protective Order Regarding
`Disclosure and Use of Discovery Materials
`Exhibit 1074 Transcripts of Proceedings - May 20, 2021 Hearing
`Exhibit 1075 Butzel Long Website
`Exhibit 1076 dictionary.com definition for “multitude”
`Exhibit 1077 Supplemental Declaration of Scott Andrews
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`14
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`CERTIFICATE OF SERVICE ON PATENT OWNER
`UNDER 37 C.F.R. § 42.6
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on November
`19, 2021 the foregoing Petitioner Apple Inc.’s Opposition to Patent Owner’s Motion
`to Amend was served via electronic filing with the Board and via Electronic Mail on
`the following practitioners of record for Patent Owner:
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`Mitchell S. Zajac (zajac@butzel.com)
`Shaun D. Gregory (gregorysd@butzel.com)
`Brian S. Seal (seal@butzel.com)
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`/s/ Jennifer C. Bailey
`Jennifer C. Bailey, Reg. No. 52,583
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`ATTORNEY FOR PETITIONER
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`15
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