Trials@uspto.gov
`571-272-7822
`
`
`Paper 28
`Date: September 24, 2021
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
`v.
`LBT IP I LLC,
`Patent Owner.
`____________
`
`IPR2020-01192
`Patent 8,421,618 B2
`____________
`
`Before JOHN A. HUDALLA, SHEILA F. McSHANE, and
`JULIET MITCHELL DIRBA, Administrative Patent Judges.
`
`McSHANE, Administrative Patent Judge.
`
`
`PRELIMINARY GUIDANCE
`PATENT OWNER’S MOTION TO AMEND
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`Patent 8,421,618 B2
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`I. INTRODUCTION
`On March 4, 2021, we instituted trial as to claims 1–24 of U.S. Patent No.
`8,421,618 B2. Paper 9 (“Decision”). After institution, Patent Owner filed a
`Motion to Amend that proposes substitute claims 25–48 for original claims 1–24.
`Paper 16 (“Motion” or “Mot.”). Specifically, “[t]o the extent the Board finds any
`original claim unpatentable in this proceeding, Patent Owner respectfully requests
`that the Board grant this motion to amend with respect to each corresponding
`proposed substitute claim presented herein.” Mot. 2. Petitioner filed an
`Opposition to the Motion. Paper 26 (“Opposition” or “Opp.”).
`In the Motion, Patent Owner requested that we provide preliminary guidance
`concerning the Motion in accordance with the Board’s pilot program concerning
`motion to amend practice and procedures. Mot. 2; see also Notice Regarding a
`New Pilot Program Concerning Motion to Amend Practice and Procedures in Trial
`Proceedings under the America Invents Act before the Patent Trial and Appeal
`Board, 84 Fed. Reg. 9,497 (Mar. 15, 2019) (providing a patent owner with the
`option to receive preliminary guidance from the Board on its motion to amend)
`(“Notice”). We have considered Patent Owner’s Motion and Petitioner’s
`Opposition.
`In this Preliminary Guidance, we provide information indicating our initial,
`preliminary, non-binding views on whether Patent Owner has shown a reasonable
`likelihood that it has satisfied the statutory and regulatory requirements associated
`with filing a motion to amend in an inter partes review and whether Petitioner (or
`the record) establishes a reasonable likelihood that the substitute claims are
`unpatentable. See 35 U.S.C. § 316(d); 37 C.F.R. § 42.121; Lectrosonics, Inc. v
`Zaxcom, Inc., IPR2018-01129, Paper 15 (PTAB February 25, 2019) (precedential);
`see also Notice, 84 Fed. Reg. at 9,497 (“The preliminary guidance . . . provides
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`preliminary, non-binding guidance from the Board to the parties about the [motion
`to amend].”); Rules of Practice to Allocate the Burden of Persuasion on Motions to
`Amend in Trial Proceedings Before the Patent Trial and Appeal Board, 85 Fed.
`Reg. 82,923 (Dec. 21, 2020).
`For purposes of this Preliminary Guidance, we focus on the proposed
`substitute claims, and specifically on the amendments proposed in the Motion. See
`Notice, 84 Fed. Reg. at 9,497. We do not address the patentability of the
`originally challenged claims. Id. Moreover, in formulating our preliminary views
`on the Motion and Opposition, we have not considered the parties’ other
`substantive papers on the underlying merits of Petitioner’s challenges. We
`emphasize that the views expressed in this Preliminary Guidance are subject to
`change upon consideration of the complete record, including any revision to the
`Motion filed by Patent Owner. Thus, this Preliminary Guidance is not binding on
`the Board when rendering a final written decision. See id. at 9,500.
`II. PRELIMINARY GUIDANCE
`A. Statutory and Regulatory Requirements
`For the reasons discussed below, at this stage of the proceeding, and based
`on the current record, it appears that Patent Owner has shown a reasonable
`likelihood that it has satisfied the statutory and regulatory requirements associated
`with filing a motion to amend.
`1. Reasonable Number of Substitute Claims
`
`Does Patent Owner propose a reasonable number of substitute claims?
`(35 U.S.C. § 316(d)(1)(B))
`Yes. Patent Owner proposes no more than one substitute claim for each
`challenged claim. Mot. 4. Petitioner does not argue otherwise. See
`generally Opp. Thus, Patent Owner proposes a reasonable number of
`substitute claims.
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`2. Respond to Ground of Unpatentability
`Does the Motion respond to a ground of unpatentability involved in the
`trial? (37 C.F.R. § 42.121(a)(2)(i))
`Yes. Patent Owner responds to at least one ground of unpatentability from
`the Decision. Mot. 3. Petitioner does not argue otherwise. See generally
`Opp. Thus, the Motion responds to a ground of unpatentability.
`
`3. Scope of Amended Claims
`Does the amendment seek to enlarge the scope of the claims? (35 U.S.C.
`§ 316(d)(3); 37 C.F.R. § 42.121(a)(2)(ii))
`No. Proposed substitute claims 25–48 retain all the features of the
`corresponding original claims while only adding additional limitations.
`Mot. 2–3. Petitioner does not argue otherwise. See generally Opp. Thus,
`the amendment does not seek to enlarge the scope of the claims.
`
`4. New Matter
`Does the amendment seek to add new subject matter? (35 U.S.C.
`§ 316(d)(3); 37 C.F.R. § 42.121(a)(2)(ii))
`No. On this record, Patent Owner appears to have identified adequate
`written description support for proposed substitute claims 25–48. Mot. 4–
`18.
`The ’618 patent issued from Application Ser. No. 13/356,599 (“the ’599
`application), which is a division of Application Ser. No. 11/969,905 (“the
`’905 application). Ex. 1001, codes (21), (62); see also Mot. 4. To show
`support for the substitute claims, Patent Owner cites the published version
`of the ’905 application—U.S. Pub. No. 2009/0174603 A1 (“the ’603
`publication”)—rather than the ’905 application or the ’599 application.
`See Mot. 4 (citing Ex. 2004). Patent Owner, however, was required to cite
`to the ’905 application itself as well as the ’599 application. See
`Lectrosonics, IPR2018-01129, Paper 15 at 7 (requiring that a motion to
`amend set forth written description support in the originally filed
`disclosure of the subject patent and an earlier filed disclosure for which
`benefit of the filing date of that disclosure is sought). Here the ’603
`publication appears to be substantially identical to the ’599 and ’905
`applications, and Petitioner does not identify any differences. As a result,
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`and to provide further guidance to the parties, we address Patent Owner’s
`citations as if Patent Owner had cited to the ’905 and the ’599
`applications. In the event that Patent Owner files either a reply to
`Petitioner’s Opposition or a revised motion, Patent Owner should conform
`to Lectrosonics and include citations to the ’599 application as well as the
`’905 application.
`Petitioner contends Patent Owner has not shown that the ’905 application
`adequately supports “battery power monitor,” as recited in substitute claim
`25. Opp. 1. Specifically, Petitioner contends the term “battery power
`monitor” is not recited in the ’905 application, except for the abstract and
`claims. Id. Petitioner further contends paragraph 29 of the ’905
`application states that battery level monitor 116 merely detects a battery
`level, but it does not disclose battery level monitor 116 as performing any
`of the claimed functions (i.e., selectively activating/deactivating circuitry).
`Id. at 1–2 (citing Ex. 2004 ¶ 29). Petitioner additionally contends
`paragraphs 31, 32, and 36 merely describe certain elements being placed
`in “a sleep or standby mode or low power mode,” but do not disclose that
`a battery power monitor is configured to do anything with respect to
`modes. Id. at 2.
`At this stage of the proceeding, we disagree with Petitioner’s contention.
`Paragraph 29 states that “[b]attery level detection circuitry (e.g., battery
`level monitor 116) detects a battery level of battery 118.” Ex. 2004 ¶ 29.
`In addition, paragraph 14 of the ’905 application states that, “[i]n response
`to measured signal strength level, a power management circuitry (e.g.,
`battery monitor) controls power levels associated with [a] tracking device
`to reduce or increase power consumption of transceiver and its associated
`circuitry.” Id. ¶ 14 (emphasis added). In light of the aforementioned
`paragraphs, at this stage of the proceeding, we determine that the ’905
`application adequately supports “battery power monitor,” as recited in
`substitute claim 25.
`Thus, at this stage of the proceeding, on the record before us, Patent
`Owner has shown a reasonable likelihood that there is adequate written
`description support for proposed substitute claims 25–48.
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`B. Patentability
`For the reasons discussed below, at this stage of the proceeding, and based
`on the current record,1 it appears that Petitioner (or the record) has shown a
`reasonable likelihood that proposed substitute claims 25–48 are unpatentable.
`
`
`Does the record establish a reasonable likelihood that the proposed
`substitute claims are unpatentable?
`
`35 U.S.C. § 112, First Paragraph – Written Description
`No. On the current record, it appears that Petitioner has not established a
`reasonable likelihood that substitute claims 25–48 fail to comply with the
`written description requirement of 35 U.S.C. § 112, first paragraph.
`As described in Section II.A.4 of this Preliminary Guidance, Petitioner
`contends substitute claims 25–48 fail to comply with the written
`description requirement. Opp. 1–2. For the reasons previously described
`in Section II.A.4 of this Preliminary Guidance, it does not appear, on this
`record, that Petitioner has shown a reasonable likelihood that substitute
`claims 25–48 fail to comply with the written description requirement.
`
`35 U.S.C. § 103(a) – Obviousness
`Yes. On the current record, it appears that Petitioner has established a
`reasonable likelihood that substitute claims 25–48 are unpatentable under
`35 U.S.C. § 103(a).
`Both parties present constructions for “wherein the at least one portion of
`the transceiver circuitry and the location tracking circuitry is deactivated
`by placing the at least one portion of the transceiver circuitry and the
`location tracking circuitry in a low power mode in which the at least one
`portion of the transceiver circuitry and the location tracking circuitry
`consumes at least reduced power,” recited in substitute claim 25 and
`similarly recited in substitute claim 39. Mot. 19–20; Opp. 2–3. We
`
`
`1 We express no view on the patentability of original claims 1–24 in this
`Preliminary Guidance. Instead, we focus on limitations added to those claims in
`Patent Owner’s Motion to Amend.
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`determine that it is not necessary to provide an express interpretation of
`any claim terms at this juncture. See Nidec Motor Corp. v. Zhongshan
`Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017); Vivid
`Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999)
`(“[O]nly those terms need be construed that are in controversy, and only to
`the extent necessary to resolve the controversy.”).
`Petitioner contends that substitute claims 25–48 are unpatentable as
`obvious under 35 U.S.C. § 103(a) based on the following new grounds:
`• substitute claims 25, 27, 33–35, 38–40, 43–45, and 48 would have
`been obvious over the combination of Sakamoto, Levi, and Alberth
`(“Ground 6”);
`• substitute claims 25, 27, 33–35, 38–40, 43–45, and 48 would have
`been obvious over the combination of Sakamoto, Levi, and
`Gronemeyer (“Ground 7”);
`• substitute claims 28–30 would have been obvious over the
`combination of Sakamoto, Levi, Vaganov, and Alberth
`(“Ground 8”);
`• substitute claims 31, 36, 37, 41, 46, and 47 would have been
`obvious over the combination of Sakamoto, Levi, Cervinka, and
`Alberth (“Ground 9”);
`• substitute claim 26 would have been obvious over the combination
`of Sakamoto, Levi, Krasner, and Alberth (“Ground 10”);
`• substitute claims 32 and 42 would have been obvious over the
`combination of Sakamoto, Levi, Cervinka, Krasner, and Alberth
`(“Ground 11”);
`• substitute claims 28–30 would have been obvious over the
`combination of Sakamoto, Levi, Vaganov, and Gronemeyer
`(“Ground 12”);
`• substitute claims 31, 36, 37, 41, 46, and 47 would have been
`obvious over the combination of Sakamoto, Levi, Cervinka, and
`Gronemeyer (“Ground 13”);
`• substitute claim 26 would have been obvious over the combination
`of Sakamoto, Levi, Krasner, and Gronemeyer (“Ground 14”); and
`• substitute claims 32 and 42 would have been obvious over the
`combination of Sakamoto, Levi, Cervinka, Krasner, and
`Gronemeyer (“Ground 15”).
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`Opp. 5, 17, 21–23. Petitioner does not allege that any of substitute claims
`25–48 are unpatentable as obvious based on the instituted grounds from
`the Decision. See generally Opp.
`Patent Owner contends that no combination of the prior art of record or
`known to Patent Owner teaches or suggests substitute claims 25–48.
`Mot. 20–21. Specifically, Patent Owner contends Sakamoto teaches
`turning off a GPS receiver, in contrast to “consum[ing] at least reduced
`power,” as recited in substitute claim 25, and similarly recited in substitute
`claim 39. Id. at 21–23. Patent Owner further contends that none of the
`asserted secondary references (e.g., Levi, Vaganov, Cervinka, Krasner)
`compensate for the deficiencies of Sakamoto. Id. at 23–24.
`Ground 6: Proposed Substitute Claims 25, 27, 33–35, 38–40, 43–45, 48
`(Sakamoto, Levi, Alberth)
`Petitioner contends that the new reference, Alberth, is in the same field of
`endeavor and is pertinent to a problem to be solved by the claimed
`invention of the ’618 patent, and thus is analogous art, because both
`Alberth and the ’618 patent relate to and disclose a portable electronic
`tracking device employing a GPS receiver and reducing applied power to
`the GPS receiver by decreasing a frequency at which the GPS receiver
`activates and deactivates at least a portion of the GPS receiver. Opp. 3–4
`(citing Ex. 1076, 4:32–36, 4:50–52).
`Petitioner additionally contends Alberth teaches “wherein the at least one
`portion of the transceiver circuitry and the location tracking circuitry is
`deactivated by placing the at least one portion of the transceiver circuitry
`and the location tracking circuitry in a low power mode in which the at
`least one portion of the transceiver circuitry and the location tracking
`circuitry consumes at least reduced power,” as recited in substitute claims
`25 and 39. Opp. 12. Specifically, Petitioner contends Alberth teaches a
`mobile station comprising a GPS receiver operating at two activation rates:
`a higher-frequency activation rate used when a GPS satellite signal level is
`good such that GPS positioning can be performed; and a lower-frequency
`activation rate used to preserve the power of the GPS receiver when the
`signal level is poor and GPS positioning cannot be performed (i.e., low
`power mode). Id. at 8–9, 12–14 (citing Ex. 1076, 3:53–60, 3:67–4:7,
`4:25–41, 5:41–45). Petitioner further contends that Alberth teaches the
`second activation rate involves at least a portion of the GPS receiver being
`deactivated to conserve power, which means that at least another portion
`of the GPS receiver is using power. Opp. 14 (citing Ex. 1076, 4:50–52).
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`Mr. Andrews provides supporting testimony that under Alberth’s
`teachings, “all power to the GPS receiver is not shut off or eliminated.”
`Ex. 1080 ¶ 19.
`Petitioner further contends a person of ordinary skill in the art
`(“POSITA”) would have been motivated to modify Sakamoto’s system (as
`modified by Levi) to include Alberth’s low power mode to perform
`activation at the lower-frequency activation rate to conserve power.
`Opp. 15. Specifically, Petitioner contends Sakamoto teaches transitioning
`from a “normal positioning mode” where the GPS receiver is periodically
`turned on/off to a “stop-position searching mode” when GPS signals are
`poor, and Alberth teaches transitioning to a lower-frequency activation
`rate when position location signals are not suitable for processing. Id. at
`15–16 (citing Ex. 1004 ¶ 35–38; Ex. 1076, 4:31–35). As contended by
`Petitioner, modifying Sakamoto to use a second cycle in advance (i.e.,
`Alberth’s lower-frequency activation rate) in the stop-position searching
`mode instead of Sakamoto’s single “cycle set in advance” would have
`advantageously saved battery power, as taught by Alberth. Id. at 16–17
`(citing Ex. 1076, 4:31–36, 4:41–49, 6:30–33).
`On this record, Petitioner has sufficiently shown that Alberth teaches
`“wherein the at least one portion of the transceiver circuitry and the
`location tracking circuitry is deactivated by placing the at least one portion
`of the transceiver circuitry and the location tracking circuitry in a low
`power mode in which the at least one portion of the transceiver circuitry
`and the location tracking circuitry consumes at least reduced power,” as
`recited in substitute claims 25 and 39. Further, Petitioner’s reasons for
`modifying Sakamoto’s system (as modified by Levi) to include Alberth’s
`low power mode to perform activation at the lower-frequency activation
`rate to conserve power have a rational underpinning and are supported by
`the testimony of Mr. Andrews, which is unrebutted at this stage of the
`proceeding. Substitute claims 27, 33–35, 38, 40, 43–45, and 48 depend
`from one of substitute claims 25 and 39, and are substantially similar to
`original claims 3, 9–11, 14, 16, 19–21, and 24, which were addressed in
`the Decision. Thus, on the current record, Petitioner has established a
`reasonable likelihood that substitute claims 25, 27, 33–35, 38–40, 43–45,
`and 48 are unpatentable as obvious over Sakamoto, Levi, and Alberth.
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`Ground 7: Proposed Substitute Claims 25, 27, 33–35, 38–40, 43–45, 48
`(Sakamoto, Levi, Gronemeyer)
`Petitioner contends Gronemeyer, a newly asserted reference, qualifies as
`prior art to the ’618 patent. Opp. 4. As further contended by Petitioner,
`Gronemeyer is in the same field of endeavor and is pertinent to a problem
`to be solved by the claimed invention of the ’618 patent, and thus is
`analogous art, because both Gronemeyer and the ’618 patent disclose a
`portable electronic tracking device employing a GPS receiver and
`reducing applied power to the GPS receiver by shutting off selected
`components, but leaving components powered on, when the GPS is not
`actively acquiring satellite information. Id. (citing Ex. 1077, 5:14–19,
`6:41–48, 7:9–12, 7:34–45).
`Petitioner additionally contends Gronemeyer teaches “wherein the at least
`one portion of the transceiver circuitry and the location tracking circuitry
`is deactivated by placing the at least one portion of the transceiver
`circuitry and the location tracking circuitry in a low power mode in which
`the at least one portion of the transceiver circuitry and the location
`tracking circuitry consumes at least reduced power,” as recited in
`substitute claims 25 and 39. Opp. 17. Specifically, Petitioner contends
`Gronemeyer teaches conserving power in a GPS receiver unit by shutting
`down select components during periods when the GPS receiver unit is not
`actively acquiring satellite information used to calculate the location of the
`GPS receiver unit, where the conservation of power is identified as a
`“sleeping period” or “sleep mode,” and where the select components
`include an oscillator, a radio, a clocks generator, and GPS signal
`processors. Id. at 17–18 (citing Ex. 1077, 5:11–14, 6:41–45, 14:13–23).
`Gronemeyer further teaches that certain components remain on and
`consume power even during the “sleep mode,” such as a low power time
`keeping circuit, as contended by Petitioner. Opp. 18–19 (citing Ex. 1077,
`5:14–17, 6:45–48, 7:8–11, 12:9–13, 12:58–61). Mr. Andrews provides
`supporting testimony that under Gronemeyer’s teachings, that even during
`the sleep mode, “the low power components of low power time keeping
`circuit 200 remain on,” and “‘low power’ components that operate
`continuously consume at least some power continuously.” Ex. 1080
`¶¶ 35–36.
`Petitioner further contends a POSITA would have been motivated to
`modify Sakamoto (as otherwise modified by Levi) to include
`Gronemeyer’s select components that remain powered during a sleep
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`mode, such as Gronemeyer’s clock, oscillator, and low power time
`keeping circuit. Opp. 19. Specifically, Petitioner contends a POSITA
`would have been motivated to make such a modification to achieve the
`advantages expressly taught by Gronemeyer, including saving power and
`more quickly reacquiring GPS satellite signals. Id. at 19–20 (citing
`Ex. 1077, 3:25–28, 14:3–12, 14:45–48).
`On this record, Petitioner has sufficiently shown that Gronemeyer teaches
`“wherein the at least one portion of the transceiver circuitry and the
`location tracking circuitry is deactivated by placing the at least one portion
`of the transceiver circuitry and the location tracking circuitry in a low
`power mode in which the at least one portion of the transceiver circuitry
`and the location tracking circuitry consumes at least reduced power,” as
`recited in substitute claims 25 and 39. Further, Petitioner’s reasons for
`modifying Sakamoto’s system (as modified by Levi) to include
`Gronemeyer’s select components that remain powered during a sleep
`mode have a rational underpinning and are supported by the testimony of
`Mr. Andrews, which is unrebutted at this stage of the proceeding.
`Substitute claims 27, 33–35, 38, 40, 43–45, and 48 depend from one of
`substitute claims 25 and 39, and are substantially similar to original claims
`3, 9–11, 14, 16, 19–21, and 24, which were addressed in the Decision.
`Thus, on the current record, Petitioner has established a reasonable
`likelihood that substitute claims 25, 27, 33–35, 38–40, 43–45, and 48 are
`unpatentable as obvious over Sakamoto, Levi, and Gronemeyer.
`Grounds 8–11: Proposed Substitute Claims 26, 28–32, 36, 37, 41, 42, 46,
`47 (Sakamoto, Levi, Vaganov, Cervinka, Krasner, Alberth)
`Petitioner contends the Petition set forth Grounds 2–5 for various
`dependent claims of the ’618 patent, and substitute claims 26, 28–32, 36,
`37, 41, 42, 46, and 47 would have been obvious over similar grounds as
`set forth in the Petition, including the references to Alberth set forth in
`Ground 6. Opp. 20–22. For the reasons described regarding Ground 6, on
`the current record, Petitioner has established a reasonable likelihood that
`substitute claims 26, 28–32, 36, 37, 41, 42, 46, and 47 are unpatentable as
`obvious over Sakamoto, Levi, Alberth, in combination with Vaganov,
`Cervinka, and/or Krasner.
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`Grounds 12–15: Proposed Substitute Claims 26, 28–32, 36, 37, 41, 42, 46,
`47 (Sakamoto, Levi, Vaganov, Cervinka, Krasner, Gronemeyer)
`Petitioner contends the Petition set forth Grounds 2–5 for various
`dependent claims of the ’618 patent, and substitute claims 26, 28–32, 36,
`37, 41, 42, 46, and 47 would have been obvious over similar grounds as
`set forth in the Petition, including the references to Gronemeyer set forth
`in Ground 7. Opp. 20, 22–23. For the reasons described regarding
`Ground 7, on the current record, Petitioner has established a reasonable
`likelihood that substitute claims 26, 28–32, 36, 37, 41, 42, 46, and 47 are
`unpatentable as obvious over Sakamoto, Levi, Gronemeyer in combination
`with Vaganov, Cervinka, and/or Krasner.
`Thus, on the current record, it appears that Petitioner has established a
`reasonable likelihood that substitute claims 25–48 are unpatentable as
`obvious under 35 U.S.C. § 103(a). We acknowledge that Patent Owner
`has not yet had the opportunity to respond to Petitioner’s contentions that
`substitute claims 25–48 are unpatentable as obvious. Patent Owner will
`have the opportunity to do so in its reply to Petitioner’s Opposition (or in a
`revised motion) in this proceeding.
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`FOR PETITIONER:
`
`Jennifer Bailey
`Adam Seitz
`Robin Snader
`Jocelyn Ram
`Kelly Hughes
`ERISE IP, P.A.
`jennifer.bailey@eriseip.com
`adam.seitz@eriseip.com
`robin.snader@eriseip.com
`jocelyn.ram@eriseip.com
`kelly.hughes@eriseip.com
`
`FOR PATENT OWNER:
`
`Mitchell S. Zajac
`BUTZEL LONG, PC
`zajac@butzel.com
`
`
`
`
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