UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`
`Petitioner
`
`v.
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`LBT IP I LLC,
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`Patent Owner
`____________
`
`Case IPR2020-01192
`U.S. Patent No. 8,421,618
`____________
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`
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`PATENT OWNER’S RESPONSE
`TO PETITION FOR INTER PARTES REVIEW
`OF U.S. PAT. NO. 8,421,618
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`IWASHINGTON\000150560\0001\585593.v1-5/31/21
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`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`
`Petitioner
`
`v.
`
`LBT IP I LLC,
`
`Patent Owner
`____________
`
`Case IPR2020-01192
`U.S. Patent No. 8,421,618
`____________
`
`
`
`PATENT OWNER’S RESPONSE
`TO PETITION FOR INTER PARTES REVIEW
`OF U.S. PAT. NO. 8,421,618
`
`
`
`
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`
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`IWASHINGTON\000150560\0001\585593.v1-5/31/21
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`Case IPR2020-01192
`U.S. Patent No. 8,421,618
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`TABLE OF CONTENTS
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`PATENT OWNER’S EXHIBIT LIST ..................................................................... II
`TABLE OF AUTHORITIES ...................................................................................III
`I.
`INTRODUCTION ............................................................................................ 1
`II. LEVEL OF ONE OF ORDINARY SKILL IN THE ART .............................. 2
`III. SAKAMOTO DOES NOT INVALIDATE CLAIMS 1-24. ............................ 2
`A. OVERVIEW OF SAKAMOTO ................................................................................. 2
`B. SAKAMOTO DOES NOT DISCLOSE SELECTIVELY ACTIVATING AND DEACTIVATING
`AT LEAST ONE PORTION OF THE TRANSCEIVER CIRCUITRY AND LOCATION TRACKING
`CIRCUITRY ... IN RESPONSE TO A SIGNAL LEVEL” AS REQUIRED BY CLAIMS 1-24. ..... 4
`IV. RESERVATION OF RIGHTS .......................................................................13
`V. CONCLUSION ..............................................................................................14
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`PATENT OWNER’S EXHIBIT LIST
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`2002
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`Exhibit Number Description
`2001
`Declaration of Brian S. Seal in support of Patent Owner’s
`Unopposed Motion For Pro Hac Vice Admission
`Revised Declaration of Brian S. Seal in support of Patent
`Owner’s Unopposed Motion For Pro Hac Vice Admission
`Transcript of deposition of Scott Andrews
`U.S. Pub. No. 2009/0174603 (Appl. No. 11/969,905)
`Sun, U.S. Patent Number 7,612,663
`Syrjarinne et al., U.S. Pub. No. 2005/0113124
`Suprun et al., U.S. Patent Number 7,292,223
`Croyle et al., U.S. Patent Number 5,862,511
`Lau et al., U.S. Patent Number 5,592,173
`Tsai, U.S. Pub. No. 2007/0057068
`Huang et al., U.S. Patent Number 7,826,968
`File history of U.S. Patent Number 8,421,619
`U.S. Pub. No. 2009/0189807 (Appl. No. 12/419,451)
`
`2003
`2004
`2005
`2006
`2007
`2008
`2009
`2010
`2011
`2012
`2013
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`TABLE OF AUTHORITIES
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`Cases
`Arthrex, Inc. v. Smith & Nephew, Inc.,
`941 F.3d 1320 (Fed. Cir. 2019), cert. granted, 141 S. Ct. 551 (2020) ................. 17
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`As required by 37 C.F.R. § 42.22(a)(2), the Petition must include “a full
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`statement of the reasons for the relief requested, including a detailed explanation of
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`the significance of the evidence including material facts.” The Petition and its
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`allegedly supporting evidence fail to satisfy that requirement and fail to establish by
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`a preponderance of the evidence that the challenged claims of U.S. Patent No.
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`8,412,618 (the “’618 Patent”) are unpatentable. As explained in further detail below,
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`the Petition and its supporting evidence fail to adequately demonstrate how the cited
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`references expressly or inherently disclose all elements required by the claims.
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`I.
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`INTRODUCTION
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`The ’618 Patent describes a device and method to monitor location
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`coordinates of an electronic tracking device. Ex. 1001, Abstract. The device
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`includes transceiver circuitry, accelerometer circuitry, a battery power monitor to
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`selectively activate and deactivate at least one portion of the transceiver circuitry
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`and location tracking circuitry, and processor circuitry. Id.
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`Independent claim 1 recites, in part:
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`accelerometer circuitry to measure displacements of the portable
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`electronic tracking device;
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`a battery power monitor configured to selectively activate and
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`deactivate at least one portion of the transceiver circuitry and location
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`tracking circuitry to conserve battery power in response to a signal level
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`of the at least one portion of the receive communication signal;
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`Id., Claim 1.
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`Independent claim 15 recites, in part:
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`measuring displacements of the portable electronic tracking device;
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`activating and deactivating at least one portion of the transceiver
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`circuitry and location tracking circuitry to conserve battery power in
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`response to a signal level of the at least one portion of the receive
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`communication signal;
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`Id., Claim 15.
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`Of note, displacements of the device are measured. In addition, independent
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`claims 1 and 15 recite a single “signal level” in response to which activation and
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`deactivation occurs.
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`
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`II. LEVEL OF ONE OF ORDINARY SKILL IN THE ART
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`For purposes of this response, Patent Owner adopts the Board’s definition of
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`the person of ordinary skill in the art (“POSITA”). Paper 9 at 8.
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`
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`III. SAKAMOTO DOES NOT INVALIDATE CLAIMS 1-24.
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`A. Overview of Sakamoto
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`Sakamoto is a Japanese patent application publication directed to the use of a
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`GPS positioning system that includes a portable terminal and remote server. Ex.
`2
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`1004 at ¶ 18. Sakamoto discloses three different states of operation based on the
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`strength of the satellite signal received by the terminal’s GPS receiver. Id. at ¶ 19.
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`One state is “normal sensitivity positioning mode,” which is used when the signal
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`level is strong (i.e., has a value equal to or higher than a predetermined threshold
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`value). Id. at ¶ 38. In normal sensitivity positioning mode, the GPS receiver obtains
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`a signal in response to a position request. Id. at ¶¶ 22-23. Once the GPS receiver
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`successfully obtains a position, it is turned off. Id. at ¶ 24.
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`Sakamoto’s second state is “high sensitivity position mode,” used when the
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`signal level is weak (i.e., has a value equal to or lower than a predetermined threshold
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`value). Id. at ¶ 38. In high sensitivity positioning mode, the GPS receiver is operated
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`constantly. Id. at ¶¶ 4–5, 19.
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`When the signal is so weak that Sakamoto is unable to perform positioning, it
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`stops position searching. Id. at ¶ 38. The Petitioner identifies this third state as “stop-
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`position mode” and notes that when Sakamoto enters this third mode, it deactivates
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`the GPS receiver. Pet. at 37 (“when position searching is stopped, a POSITA would
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`have understood that, at the least, sub-components of GPS receiver and GPS control
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`unit are deactivated”) (emphasis in original).
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`A user may select among normal sensitivity positioning mode, high sensitivity
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`positioning mode, and the power-off of terminal 1 via man-machine interface control
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`unit 14. Ex. 1004 at ¶¶ 26, 28.
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`B. Sakamoto does not disclose selectively activating and
`deactivating at least one portion of the transceiver circuitry and
`location tracking circuitry ... in response to a signal level” as
`required by claims 1-24.
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`Battery conservation is an essential component of the claims of the ’618
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`Patent. In prior art electronic navigation systems, attempts to monitor or track weak
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`signals resulted in unnecessary expenditure of battery power. Ex. 1001 at 3:2-7 (“Not
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`only is a GPS transceiver receiving a weak GPS signal, but also the GPS transceiver
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`is depleting battery power in failed attempts to acquire communications signals from
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`one or more location coordinates monitoring satellites, e.g., GPS satellites, or out-
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`of-range location coordinates reference towers.”). As described in the Summary of
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`the Invention, the inventors of the ’618 Patent solved that problem in part by
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`reducing power to certain circuitry when the signal strength falls below a specified
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`threshold and increasing power to that circuitry when the signal strength rose above
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`the threshold:
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`In this method, a transceiver communicates measured signal strength.
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`In response to measured signal strength level, a power management
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`circuitry (e.g., battery monitor) controls power levels associated with
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`the first tracking device to reduce or increase power consumption of a
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`transceiver and its associated circuitry.
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`Ex. 1001 at 3:40-45 (emphasis added).
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`All twenty-four claims of the ’618 Patent explicitly include the concept of
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`activating and deactivating circuitry in response to a signal level in order to conserve
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`battery power. Independent claim 1 (from which claims 2 through 14 depend) recites
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`“a battery power monitor configured to selectively activate and deactivate at least
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`one portion of the transceiver circuitry and location tracking circuitry to conserve
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`battery power in response to a signal level of the at least one portion of the receive
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`communication signal.” Ex. 1001 at 10:27-31. Independent claim 15 (from which
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`claims 16 through 24 depend) similarly recites “activating and deactivating at least
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`one portion of the transceiver circuitry and location tracking circuitry to conserve
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`battery power in response to a signal level of the at least one portion of the receive
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`communication signal.” Ex. 1001 at 11:41-12:2. Thus even when the transceiver
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`circuitry and location tracking circuitry have been deactivated, the inventions
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`claimed by the ’618 Patent must still be able to receive and measure the GPS signal
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`necessary to activate that circuitry.
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`The ’618 Patent accomplishes the claimed activation and deactivation by not
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`disabling the circuitry responsible for detecting, processing, and measuring the
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`signal power level, i.e., signal detecting circuitry 115 or signal processing circuitry
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`104. Ex. 1001 at 6:17-20 (“In one embodiment, a signal detecting circuitry 115
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`detects and measures signal power level. In another embodiment the signal
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`processing circuitry 104 processes and measures signal power level.”). Nor does the
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`patent teach disabling antenna 122, which is also responsible for detecting the signal
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`level. Ex. 1001 at 6:50-54 (“the accelerometer 130 activates upon one or more
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`designated antenna(s), e.g., antennas 122a, 122b, detecting a first signal level, e.g.,
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`a low signal level or threshold value, as specified by, for instance, a user or system
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`administrator”).
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`The process by which the ’618 Patent determines whether to reactivate the
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`claimed “at least one portion of the transceiver circuitry and location tracking
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`circuitry” is demonstrated in Figure 3, shown below:
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`Ex. 1001, Fig. 3.
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`There, in step 302 (“S302”), antenna 122a acquires a snapshot of the receive
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`communication signal. Ex. 1001 at 9:35-37. In step 304 (“S304”), signal processing
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`unit 104 first “processes the snapshot of receive communication signal,” then, in step
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`306 (“S306”), it “determines a power level of receive communication signal.” Ex.
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`1101 at 9:37-41. Finally, “[i]n one variation of step 312, upon determining receive
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`communication signal of sufficient strength, location tracking circuitry 114 are
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`activated ....” Ex. 1101 at 9:52-54. Thus, the inventions of the ’618 Patent are able
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`to detect and measure the signal power level even when it has reduced power to —
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`or even disabled entirely— “at least one portion of the transceiver circuitry and
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`location tracking circuitry,” i.e., location tracking circuitry 114.
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` In light of the claims and specification of the ’618 Patent, including the
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`Summary of the Invention, it is clear that the claimed “at least one portion of the
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`transceiver circuitry and location tracking circuitry” cannot both (1) include the only
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`ability to receive GPS signals and (2) be turned off completely when it is deactivated.
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`Yet the Petitioner includes both in its attempt to meet that limitation by relying
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`exclusively on Sakamoto’s disabling of circuitry that includes the functionality of
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`receiving GPS signals.
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`With regard to claim 1, for example, the Petitioner relies solely on Sakamoto’s
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`transitioning to and from stop-position mode to meet the limitation of “a battery
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`power monitor configured to selectively activate and deactivate at least one portion
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`of the transceiver circuitry and location tracking circuitry to conserve battery power
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`in response to a signal level of the at least one portion of the receive communication
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`signal.” Pet. at 35 (“Sakamoto’s transitioning between the stop-position searching
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`mode and either the normal/high modes results in selective activation and
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`deactivation of
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`the GPS
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`receiver’s signal acquisition and processing
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`functionalities”) (emphasis in original).
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`According to the Petitioner’s argument, the transceiver circuitry claimed by
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`the ’618 Patent “includes the signal acquisition section of the Sakamoto GPS
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`receiver 10” and the claimed location tracking circuitry “at least includes the signal
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`processing section of GPS receiver and GPS control unit for determining position.”
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`Pet. at 38. The Petitioner asserts that those components from Sakamoto are
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`“activated” from a powered-off state when they are powered on in response to a
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`position request:
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`To position search, Sakamoto teaches powering on the GPS receiver:
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`“the position request turns on the power of the GPS receiver 10 via the
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`GPS control unit 12 and the GPS receiver 10 starts the position
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`detection process.” Sakamoto, [0020]. Because the GPS receiver and
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`GPS control unit are powered on to perform position detection, and
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`because the position detection process includes both signal acquisition
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`and signal processing to determine position based on the signal, sub-
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`components of GPS receiver and GPS control unit related to signal
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`acquisition (transceiver circuitry) and signal processing for positioning
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`(location tracking circuitry) are activated, i.e., “at least one portion of
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`the transceiver circuitry and the location tracking circuitry” is activated.
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`Pet. at 38-39.
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`The Petitioner further asserts that the components from Sakamoto are
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`“deactivated” when Sakamoto enters stop-position mode:
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`when position searching is stopped, as taught by Sakamoto, a POSITA
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`would have understood or otherwise found it obvious that sub-
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`components of GPS receiver related to signal acquisition (transceiver
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`circuitry) and signal processing (location tracking circuitry) are
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`selectively deactivated, i.e., “at least one portion of the transceiver
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`circuitry and the location tracking circuitry” is deactivated.
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`Pet. at 39.
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`As acknowledged by Mr. Andrews in his deposition, GPS receiver 10 is the
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`only component in Sakamoto that receives GPS satellite signals. Ex. 2003 at 14:5-
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`16:2.1 If Sakamoto is “wait[ing] in a state in which the power of the GPS receiver
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`10 is cut off,” (Pet. at 37) or has deactivated the “sub-components of GPS receiver
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`related to signal acquisition (transceiver circuitry) and signal processing (location
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`tracking circuitry)” and GPS receiver 10 is the only component in Sakamoto that
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`receives the GPS satellite signal, Sakamoto cannot then activate GPS receiver 10 or
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`any component of GPS receiver 10 “in response to a signal level” as required by the
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`claims of the ’618 Patent. It cannot acquire or process the necessary signal for
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`activation until the GPS receiver (or at least the “sub-components of GPS receiver
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`related to signal acquisition (transceiver circuitry) and signal processing (location
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`1 Mr. Andrews states that another component of Sakamoto—communication control
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`unit 11—receives different information known as “ephemeris data” that GPS
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`systems use to locate the GPS satellite. Ex. 2003 at 14:24-16:2. See also Ex. 1003 at
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`¶36 (“a POSITA would have recognized that the ephemeris data including orbital
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`information of a plurality of satellites would have been used for locally determining
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`longitudinal, latitudinal, and elevational coordinates of the satellite”). The ephemeris
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`data, however, is not received from the satellite, but is provided through a network,
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`such as a cellular communication link. Ex. 2003 at 15:7-16. Thus it is not the
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`“receive communication signal” identified by Petitioner in Sakamoto. Pet. at 36
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`(identifying the “receive communication signal” as a “satellite signal level”).
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`tracking circuitry)”) have already been activated in response to some other trigger,
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`such as the position request referenced above. As described by Sakamoto, however,
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`the position request is not itself a “signal level,” but is an instruction that activates
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`the GPS receiver in order to obtain a signal level:
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`The position information communication terminal 1 waits in a state in
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`which the power of the GPS receiver 10 is cut off; in order to obtain
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`terminal user A’s own position, a position request is sent to the
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`positioning control unit 13 by pressing the button provided on the man-
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`machine interface control unit 14. The positioning control unit 13 that
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`has received the position request turns on the power of the GPS
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`receiver 10 via the GPS control unit 12 and the GPS receiver 10 starts
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`the position detection process.
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`Ex. 1004 at ¶ 20 (emphasis added).
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`The Petitioner’s expert, Mr. Andrews, conceded that Sakamoto does not teach
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`reactivating the GPS receiver 10 from the stop-position mode in response to a signal
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`level. During his deposition, when asked about Sakamoto moving from stop-position
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`mode to either normal sensitivity mode or high sensitivity mode, Mr. Andrews
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`participated in the following exchange:
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`Q.· · In that case, however, when Sakamoto turns on GPS receiver
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`10, it does not do so in response to a signal level, correct?
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`A.· · That’s correct.
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`Ex. 2003 at 20:1-4. See also id. at 23:10-11 (“Sakamoto doesn’t describe how he
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`determines that the signal level is above that threshold”).
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`Nor does Mr. Andrews’s declaration provide the necessary teaching. He
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`recognizes the logical problem presented by the Petitioner’s argument, but states
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`only that:
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`if the device was previously in the stop-position searching mode
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`(because the received GPS signal level was equal to or lower than a
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`predetermined threshold) and a subsequently received GPS signal level
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`is good (i.e., above a threshold value), then a POSITA would have
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`understood GPS control unit 12 instructs GPS receiver 10 to begin
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`position searching, resulting in increased power usage by the GPS
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`receiver.
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`Ex. 1003 at ¶ 138. While Mr. Andrews suggests that the resumption of position
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`searching by GPS receiver 10 (i.e., “activation”) occurs when “a subsequently
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`received GPS signal level is good,” he never explains how Sakamoto can receive a
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`GPS signal when the GPS receiver is not already activated.
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`Nor could Sakamoto’s activation of GPS receiver 10 in response to a position
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`request be an intermediate step toward some subsequent activation in response to a
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`signal. Sakamoto teaches that, once it acquires and measures a signal in response to
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`a position request, it can move out of stop-position mode into either normal
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`sensitivity mode or high sensitivity mode. Ex. 1004 at ¶ 36. In normal sensitivity
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`mode, once the signal has been acquired and the mode set, “the power of the GPS
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`receiver 10 is shut off.” Id. And in high sensitivity mode, “the power of the GPS
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`receiver 10 is continuously turned on.” Id. Thus, in response to the measured signal
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`level in that scenario, the component of GPS receiver 10 receiver responsible for the
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`receipt and processing of GPS satellite signals is either turned off (normal sensitivity
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`mode) or kept on (high sensitivity mode). In neither case is it activated in response
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`to the measured signal level.
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`As noted above, the claimed “at least one portion of the transceiver circuitry
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`and location tracking circuitry” cannot both (1) include the only ability to receive
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`GPS signals and (2) be turned off completely when it is deactivated. Supra, at 7.
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`Because the evidence relied upon by the Petitioner—Sakamoto’s GPS receiver 10—
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`does both, it cannot be the circuitry required by claims 1 through 24. Consequently,
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`the Petitioner has not identified any circuitry in the prior art that is both activating
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`and deactivated in response to a signal level as required by all claims of the ’618
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`Patent.
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`IV. RESERVATION OF RIGHTS
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`Patent Owner does not concede or waive any omitted arguments and this response
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`shall not be construed as an admission against interest in any manner. In particular,
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`Patent Owner expressly reserves the right to raise an argument under Arthrex, Inc.
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`v. Smith & Nephew, Inc., 941 F.3d 1320 (Fed. Cir. 2019), cert. granted, 141 S. Ct.
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`551 (2020).
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`V. CONCLUSION
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`For the reasons set forth above, the grounds contained in the Petition fall far
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`short of establishing, by a preponderance of the evidence, that any of claims 1
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`through 20 are unpatentable. The abovementioned gaps in the proffered evidence
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`and substantive content of the Petition and cited evidence prove fatal to the Petition.
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`The challenged claims should be upheld.
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`
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`Respectfully submitted,
`
`BUTZEL LONG, PC
`
`/Shaun D. Gregory/
`
`Shaun D. Gregory
`USPTO Reg. No. 68,498
`Counsel for Patent Owner
`
`
`Date: June 1, 2021
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`1909 K Street, N.W.
`Suite 500
`Washington, DC 20006
`(202) 454-2800
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`CERTIFICATE OF COMPLIANCE
`Pursuant to 37 C.F.R. § 42.24(d), I hereby certify that the foregoing PATENT
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`OWNER’S RESPONSE TO PETITION FOR INTER PARTES REVIEW OF U.S.
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`PAT. NO. 8,421,618 contains 2,813 words, excluding the parts of the petition
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`exempted by 37 C.F.R. § 42.24(b), as measured by the word-processing system used
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`to prepare this paper.
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`BUTZEL LONG, PC
`
`/Shaun D. Gregory/
`
`Shaun D. Gregory
`USPTO Reg. No. 68,498
`Counsel for Patent Owner
`
`
`Date: June 1, 2021
`
`1909 K Street, N.W.
`Suite 500
`Washington, DC 20006
`(202) 454-2800
`
`
`
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`CERTIFICATE OF SERVICE (37 C.F.R. § 42.6(e))
`
`The undersigned hereby certifies that PURSUANT TO 37 C.F.R. §42.8(a)(2)
`
`the foregoing PATENT OWNER’S RESPONSE TO PETITION FOR INTER
`
`PARTES REVIEW OF U.S. PAT. NO. 8,421,618 is being served electronically via
`
`e-mail on June 1, 2021, in its entirety on the following counsel of record for
`
`Adam P. Seitz (Back-Up Counsel)
`USPTO Reg. No. 52,206
`ERISE IP, P.A.
`7015 College Blvd., Suite 700
`Overland Park, KS 66211
`PTAB@eriseip.com
`Phone: (913) 777-5600
`Fax: (913) 777-5601
`
`BUTZEL LONG, PC
`
`/Shaun D. Gregory/
`
`Shaun D. Gregory
`USPTO Reg. No. 68,498
`Counsel for Patent Owner
`
`Petitioners:
`
`Jennifer C. Bailey (Lead Counsel)
`USPTO Reg. No. 52,583
`ERISE IP, P.A.
`7015 College Blvd., Suite 700
`Overland Park, KS 66211
`PTAB@eriseip.com
`Phone: (913) 777-5600
`Fax: (913) 777-5601
`
`
`
`
`
`
`
`
`Date: June 1, 2021
`
`1909 K Street, N.W.
`Suite 500
`Washington, DC 20006
`(202) 454-2800
`
`IWASHINGTON\000150560\0001\585593.v1-5/31/21
`
`
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