`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`ASSA ABLOY AB, ASSA ABLOY Inc.,
`ASSA ABLOY Residential Group, Inc., August Home, Inc., HID Global
`Corporation, and ASSA ABLOY Global Solutions, Inc.,
`Petitioners,
`
`v.
`
`CPC Patent Technologies PTY LTD.,
`Patent Owner.
`Case No. IPR2022-01006
`Patent No. 9,665,705
`______________________________________________________
`
`
`
`
`
`PETITIONERS’ REQUEST FOR DIRECTOR REVIEW
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`
`
`TABLE OF CONTENTS
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`Page
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`INTRODUCTION ............................................................................................................. 1
`LEGAL STANDARDS ..................................................................................................... 2
`SUMMARY OF ARGUMENT ......................................................................................... 2
`THE BOARD’S CONSTRUCTION OF “BIOMETRIC SIGNAL” IS
`ERRONEOUS AND LEADS TO NUMEROUS PROBLEMS. ....................................... 6
`A.
`The plain and ordinary meaning of “Biometric Signal” is the input and
`output of a biometric sensor. .................................................................................. 7
`The Board’s construction renders other limitations superfluous. ........................ 11
`B.
`The Board’s construction results in indefinite claims. ......................................... 12
`C.
`The Board failed to consider relevant evidence. .................................................. 13
`D.
`CONCLUSION ................................................................................................................ 15
`
`
`I.
`II.
`III.
`IV.
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`V.
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`-i-
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`IPR2022-01006
`U.S. Patent No. 9,665,705
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`I.
`
`INTRODUCTION
`Petitioners request Director review pursuant to 37 C.F.R. § 42.71(d)
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`regarding the finding in the Final Written Decision (“FWD”) that claims 1-17 of
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`U.S. 9,665,705 (“’705 Patent”) are not unpatentable. Petitioners’ request is
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`particularly worthy of Director review because the Board issued inconsistent claim
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`construction positions regarding the term “biometric signal” in two different
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`proceedings concerning the same patent and claims. Petitioners demonstrated that
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`the claims were unpatentable under both Petitioners’ and Patent Owner’s proposed
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`constructions for “biometric signal.” However, the Board adopted an erroneous
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`construction for “biometric signal” that was not proposed by either side and the
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`Board never raised its new claim construction until the FWD, after all briefing had
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`concluded.1 In the earlier IPR on this patent filed by a different petitioner,
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`IPR2022-00602, Patent Owner likewise requested Director review based on the
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`Board’s inconsistent findings regarding “biometric signal.” This is an exceedingly
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`rare situation in which both Patent Owner and Petitioners argue that a specific IPR
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`of the same patent should be reviewed based on the same Panel’s inconsistent
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`treatment of the same term.
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`Petitioners submit that the findings of unpatentability in IPR2022-00602
`
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`1 Petitioners reserve for appeal that the late construction, not proposed by either
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`side, violates the Administrative Procedures Act.
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`1
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`IPR2022-01006
`U.S. Patent No. 9,665,705
`were correct, and that if the same construction were applied here, the FWD’s sole
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`dispositive issue would be reversed and the claims deemed unpatentable.
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`II. LEGAL STANDARDS
`Under the USPTO’s interim procedures, Director review of a Board decision
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`may be warranted to determine if it includes, among other things, “(a) an abuse of
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`discretion, (b) important issues of law or policy, (c) erroneous findings of material
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`fact, or (d) erroneous conclusions of law. USPTO Website, Revised Interim
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`Director Review Process. Requests for Director Review must be filed within thirty
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`days of the entry of a final written decision. 37 C.F.R. 42.71(d).
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`III. SUMMARY OF ARGUMENT
`In the Petition, Petitioners sought review of Claims 1-17 of the ’705 Patent
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`based, in part, on Bianco in view of Mathiassen. Every claim of the ’705 Patent
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`recites a “biometric signal,” and the dispute regarding this term is identical for all
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`claims. The Board found all challenged claims were not unpatentable based on its
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`newly presented construction of “biometric signal.” FWD, 77-86. In the FWD, the
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`Board construed “biometric signal” to mean “a physical or behavioral biometric
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`attribute that provides secure access to a controlled item.” FWD, 68. For the first
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`time, using language neither side proposed, the Board added the limitation that the
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`“biometric signal” requires “provid[ing] secure access to a controlled item.” Id.
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`The ’705 Patent is directed to a system that uses the output of a “biometric
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`sensor”—or a “biometric signal”—for two purposes: (1) authenticating a user to
`2
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`IPR2022-01006
`U.S. Patent No. 9,665,705
`provide secure access to a controlled item, and (2) recognizing a series of entries
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`on the biometric sensor—each having a duration—and mapping this Morse-code
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`like series of “biometric signals” into an instruction.2 Claim 1 is representative and
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`recites the following relevant elements (emphasis added):
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`1. A system for providing secure access to a controlled item, the
`system comprising: …
`a biometric sensor configured to receive a biometric
`signal; …
`a receiver sub-system controller configured to:
`receive the transmitted secure access signal; and
`provide conditional access to the controlled item
`dependent upon said information;
`wherein the transmitter sub-system controller is further
`configured to:
`receive a series of entries of the biometric signal, said
`series being characterised according to at least one of the
`number of said entries and a duration of each said entry;
`map said series into an instruction; and
`populate the data base according to the instruction, …
`EX-1001, Cl. 1.
`
`In reaching its construction, the Board did not address the plain and ordinary
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`meaning of the term, nor did the Board address other claim limitations that already
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`2 The “Series/Duration Limitation” is used to refer to claim element D(1): “receive
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`a series of entries of the biometric signal, said series being characterised according
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`to at least one of the number of said entries and a duration of each said entry.”
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`3
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`U.S. Patent No. 9,665,705
`recite providing secure access to a controlled item, namely the “receiver sub-
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`system.” In addition, the Board did not address that the claims require mapping a
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`series of biometric signals (each having a duration) into an instruction—a function
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`completely unrelated to, and recited separately from, providing “secure access to
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`the controlled item.” Rather, the Board relied on one of the objectives of system as
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`a whole and limited the claim term to achieving that objective: “the purpose of the
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`biometric signal is to achieve this objective–‘secure access to a controlled item.’”
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`FWD, 60. Applying its construction, the Board further incorrectly held that “when
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`Mathiassen-067 switches to text input mode or cursor control mode, it exits access
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`control mode and is no longer functioning as a fingerprint sensor.” FWD, 85.
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`In a separate proceeding, however, the same Panel reached the opposite
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`conclusion when addressing the same patent and limitation. Apple Inc. v. CPC
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`Patent Technologies PTY, Ltd., IPR2020-00602, Final Written Decision (PTAB
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`Sept. 27, 2023) [Paper No. 31] (“Apple FWD”). Of relevance here is the Board’s
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`interpretation of the key phrase “a series of entries of the biometric signal,” where
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`the series is “characterised” by “at least one of the number of said entries and a
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`duration of each said entry.” Id., 29-30. The Board held “we construe the number
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`and duration clauses to require a number and duration of biometric signals because
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`the input for these biometric signals is a biometric sensor, as disclosed in the
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`Specification” Apple FWD, 31. Regarding fingerprint sensors, the Board further
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`4
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`U.S. Patent No. 9,665,705
`observed: “A fingerprint sensor’s ability to recognize a fingerprint is not
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`turned off when a succession of finger presses is applied to the fingerprint
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`sensor.” Apple FWD, 31. Thus, in the Apple FWD, the Board correctly opined
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`that fingerprint sensors generally act the same way—i.e., they output biometric
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`signals (fingerprint scans) that they detect on their surface for any finger press.
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`Contrary to its construction in the instant IPR, the Board nowhere added the
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`limitation in the Apple FWD that the “biometric signal” must provide secure
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`access to a controlled item.
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`The reasoning in the Apple FWD is correct and is plainly inconsistent with
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`the same Panel’s finding in the instant proceeding, where it held “that there is a
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`substantive distinction between the finger press command entry function and the
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`fingerprint user authentication function in Mathiassen-067. Both functions use the
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`same ‘touch sensitive switch 1, in the form of a fingerprint sensor with navigation
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`means.’” FWD, 84. Here, the Board inconsistently and erroneously held that a
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`fingerprint sensor’s function to recognize a fingerprint is somehow turned off in
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`Mathiassen-067, as compared to fingerprint sensors in general, which the Board
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`correctly found in the Apple FWD to always be turned on even if the output is used
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`for a different function. The Board’s inconsistent findings constitute legal and
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`material error, and should be reviewed.
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`Moreover, Petitioners identified explicit teachings of Mathiassen that
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`5
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`disclose the “biometric signal” limitation under any reasonable construction,
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`including Petitioners’ construction, Patent Owner’s construction(s) and the
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`construction from the earlier Apple FWD. However, the Board did not address any
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`of this evidence. For instance, Petitioners’ showed that Mathiassen explicitly
`
`teaches that “[t]he fingerprint sensors…scans the fingerprint, and in order to be
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`able to analyse [sic] the finger print, is able to detect the finger movement
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`across the sensor in one dimension…” Reply, 6, 14 (quoting EX-1004, 8:30-32).
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`In addition, PO’s expert agreed that fingerprint data is always read by Mathiassen’s
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`fingerprint sensor, including when being used to issue commands during the Morse
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`code-like mapping of finger presses/movements into commands. EX-1028, 115:10-
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`25. The Board’s failure to address this evidence is also a material error.
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`IV. THE BOARD’S CONSTRUCTION OF “BIOMETRIC SIGNAL” IS
`ERRONEOUS AND LEADS TO NUMEROUS PROBLEMS.
`The Board’s construction constitutes error because it imports a “secure
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`access” requirement to the “biometric signal” term—essentially adding a
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`functional requirement for a biometric signal rather than defining what a biometric
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`signal is. FWD, 68 (“‘Biometric signal’ means a physical or behavioral biometric
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`attribute that provides secure access to a controlled item.”) (emphasis added).
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`Neither side’s construction proposed or contemplated a secure access
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`requirement. Petitioners’ construction: “the input and output of the biometric
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`sensor” (Reply at 8); PO construction: “physical attribute of the user (i.e.,
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`U.S. Patent No. 9,665,705
`fingerprint, facial pattern, iris, retina, voice, etc.” (PO Resp. 9–10, 19). Instead, the
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`dispute was whether the attribute of the user is limited to a physical attribute
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`instead of a physical or behavioral attribute, and the Board correctly ruled that the
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`term is not limited to a physical attribute. Nowhere in the dispute, the Board’s
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`institution decision, or even the Apple FWD did a “biometric signal” require
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`“secure access.”
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`Indeed, authentication (providing secure access) is one of functions that is
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`performed using the “biometric signal” in the claims, and this function is recited in
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`the claim where intended (see infra). The other use of “biometric signal” in the
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`claims—receiving a “series of entries of [a] biometric signal” (each having a
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`duration) and mapping them into an instruction—has nothing to do with providing
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`secure access and has none of the recited language relating to providing access to a
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`controlled item. EX-1001, Cls. 1,10, 11 (“receive a series of entries of the
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`biometric signal [and a duration of each said entry]…map said series into an
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`instruction”). Nor is there any suggestion in the specification of providing secure
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`access to a controlled item when the system is recognizing the series of entries of
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`the biometric signal and mapping them into an instruction. See EX-1001, 11:1-14.
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`Therefore, it is respectfully submitted that the Board’s construction is wrong.
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`A. The plain and ordinary meaning of “Biometric Signal” is the
`input and output of a biometric sensor.
`The claims provide that the biometric signal is received by the biometric
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`7
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`U.S. Patent No. 9,665,705
`sensor (i.e., as an input). EX-1001, Cls. 1,10, 11 (“a biometric sensor configured to
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`receive a biometric signal.”). The claims further require that “a transmitter sub-
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`system controller [is] configured to match the biometric signal against members of
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`the database of biometric signatures…” Id. In other words, the claims recite that
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`the biometric signal is also the output of the biometric sensor. Thus, when read in
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`light of the specification, the “biometric signal” is simply the input and output of
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`the biometric sensor. How that biometric signal is used (e.g., for authentication or
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`providing instructions) is dictated by other claim limitations.
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`The Board’s construction improperly added a limitation that the biometric
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`signal must be used to “provide secure access to a controlled item,” and then used
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`this to reject the obviousness grounds. FWD 68. This construction improperly
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`imports a limitation and is inconsistent with the claim language itself.
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`The claims make clear that the biometric signal does not do anything on its
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`own—it is merely an input and output of a biometric sensor. The claim then uses
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`the output from the biometric sensor in two different ways.
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`First, the system can utilize the biometric signal for secure access. EX-
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`1001, Cls. 1, 10, 11: “a transmitter sub-system controller [is] configured to match
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`the biometric signal against members of the database of biometric signatures…”.
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`Second, the system receives a series of entries of the biometric signal in a
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`Morse-code like sequence (where each has a duration) and maps the series to an
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`8
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`IPR2022-01006
`U.S. Patent No. 9,665,705
`instruction (e.g., “Enroll an ordinary user). EX-1001, Cls. 1,10, 11 (“receive a
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`series of entries of the biometric signal [and a duration of each said entry]…map
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`said series into an instruction; and populate the data base according to the
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`instruction.”); See EX-1001, 11:1-8. The ’705 Patent specification explains that
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`“[t]he first administrator can provide control information to the code entry module
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`by providing a succession of finger presses to the biometric sensor 121… the
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`controller 107 accepts the presses as potential control information and checks
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`the input information against a stored set of legal control signals.”). Id., 10:56-67.
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`The Board’s construction reads out this essential function of the claims and
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`all embodiments of the specification, which neither describe nor suggest the
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`succession of presses being used for secure access.
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`Further, to hold that a biometric signal can only be used to “provide[] secure
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`access to a controlled item” is contrary to the specification, which states that
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`incoming biometric signal may not even be legible (and thus unable to provide
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`secure access). EX-1007, 13:48-51 (“step 906 determines whether the incoming
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`biometric signal is legible. If this is not the case, then the process 900 proceeds
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`according to a NO arrow to a step 907.”) Because an illegible “biometric signal”
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`could not provide secure access, this is an additional reason that the Board’s
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`construction (requiring a secure access limitation) is incorrect.
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`A simple way to recognize the error in the Board’s construction is to
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`9
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`IPR2022-01006
`U.S. Patent No. 9,665,705
`consider a biometric sensor (e.g., fingerprint sensor) that is connected in a simple
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`circuit that lacks any controlled item to which secure access may be provided. In
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`this scenario, a finger press on a fingerprint sensor would output its “biometric
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`signal” (fingerprint scan) as it normally would. However, because this “biometric
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`signal” is never compared against a database of fingerprints to authenticate a user
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`and provide secure access to a controlled item, the Board’s construction would
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`require that this normal output of the fingerprint sensor would not be a “biometric
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`signal.” This makes no sense. A fingerprint sensor is doing the same thing in all
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`instances—it is outputting the biometric signal (fingerprint scan) that it detects on
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`its surface. What is done downstream using that biometric signal is a separate
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`matter (in this hypothetical, nothing is done with it).
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`The Board correctly recognized this point in the Apple FWD, where it
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`stated: “[a] fingerprint sensor’s ability to recognize a fingerprint is not turned
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`off when a succession of finger presses is applied to the fingerprint sensor.” Apple
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`FWD, 31. A fingerprint sensor is a simple device that detects and outputs the scan
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`of finger presses on its surface. The output of the fingerprint sensor is the
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`“biometric signal,” plain and simple. It is incorrect—and legal error—to add a
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`limitation that the biometric signal must “provide secure access to a controlled
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`item.” Providing secure access to a controlled item is one of the claimed uses of
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`the “biometric signal,” but it is not required. And use of biometric signals for
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`10
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`authentication was admittedly old. See EX-1001, Background. The purported
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`point of novelty of the claims of the ’705 patent (reflected in the Series/Duration
`
`Limitation) is a second use of the “biometric signal”—receiving a series of
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`“biometric signals” (each having a duration) and mapping them into an instruction.
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`This second use of the “biometric signals” has nothing to do with providing secure
`
`access to a controlled item. The Board’s construction is therefore incorrect.
`
`The Board’s construction renders other limitations superfluous.
`B.
`The Board improperly added a “secure access” limitation into “biometric
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`signal,” and this limitation renders other claim limitations superfluous. When
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`claiming the first use of the biometric signal, the claims already recite structures
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`that provide “secure access”: Ex-1001, Cls. 1, 10, 11 (“a transmitter configured
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`to emit a secure access signal conveying said information dependent upon said
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`accessibility attribute.”); Id. Cls. 1, 11 (“a receiver sub-system controller
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`configured to…receive the transmitted secure access signal; and provide
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`conditional access to the controlled item dependent upon said information.” EX-
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`1001, Cls. 1, 11. By improperly adding the limitation “provides secure access to a
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`controlled item” into its construction for “biometric signal,” the Board stripped all
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`meaning from the “receiver sub-system,” which is already responsible for
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`providing secure access to the controlled item. See Mformation Techs., Inc. v.
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`Research in Motion Ltd., 764 F.3d 1392, 1399 (Fed. Cir. 2014) (favoring a
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`construction that does not render another limitation “superfluous”).
`11
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`U.S. Patent No. 9,665,705
`C. The Board’s construction results in indefinite claims.
`The Board’s newly created construction would also lead to nonsensical and
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`indefinite claims, which is evident in multiple places of the specification.
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`The ’705 Patent claims require “match[ing] the biometric signal
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`against members of the database of biometric signatures.” EX-1001,
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`Cl. 1. This is shown in Fig. 3 (right) and illustrates a problem with the
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`construction. See EX-1001, 8:6-19. Step 210 (yellow) determines if a
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`biometric signal was received and step 202 (green) compares the
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`“biometric signal” against the signature database to determine if the
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`user is authorized. The Board’s construction requires that “biometric
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`signals” must themselves already provide secure access (i.e., are authorized), and
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`therefore only signals that already match the signature database would proceed
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`through step 201 (yellow), eliminating the need for checking against the signature
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`database. This result is nonsensical and would render the claims indefinite.
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`Similarly, when the claimed system is used by any user for the first time
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`(i.e., prior to enrollment), their “biometric signal” would not
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`already exist in the database and the Board’s secure access
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`requirement would necessarily fail every time. Likewise,
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`consider col. 10:15-33 and Fig. 6 (right). Under the Board’s
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`construction, step 702 (blue), which determines if the
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`database is empty and needs to be populated with new data
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`U.S. Patent No. 9,665,705
`(green), would only be reached if a “biometric signal” has been received at step
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`701 (yellow). But the Board’s construction requires “biometric signals” to
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`themselves provide secure access, which is not possible with an empty database
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`because there is nothing to compare against to provide secure access. With an
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`empty database, no biometric signals could ever clear step 701 under the Board’s
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`construction. The Board’s construction leads to indefiniteness and is erroneous.
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`D. The Board failed to consider relevant evidence.
`In its Final Written Decision, the Board concluded that Mathiassen does not
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`teach receiving a series of biometric signals. FWD, 85 (“As disclosed in
`
`Mathiassen-067 and discussed above, when Mathiassen-067 switches to text input
`
`mode or cursor control mode, it exits access control mode and is no longer
`
`functioning as a fingerprint sensor.”) The Board relied on a statement from
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`Petitioner’s expert early in the proceeding that he didn’t recall whether Mathiassen
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`discloses that its fingerprint sensor reads the fingerprint in all cases. However,
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`after PO raised this argument, Petitioners showed that Mathiassen indeed explicitly
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`discloses this, and both sides’ experts acknowledged this fact.
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`Petitioners showed that Mathiassen expressly teaches that its fingerprint
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`sensor always acts as a fingerprint sensor—i.e., it analyzes and outputs fingerprint
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`data, even when being used to issue commands. Reply at 14 (quoting EX-1004,
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`8:25-38). Specifically, Mathiassen teaches use of a known fingerprint sensor and
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`analyzing that fingerprint data to register movements and command inputs:
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`The fingerprint sensors…scans the fingerprint, and in
`order to be able to analyse[s] the fingerprint, is able to
`detect the finger movement across the sensor’ for
`purposes of receiving commands and instructions.
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`EX-1004, 8:25-38. In fact, PO’s expert agreed that Mathiassen’s fingerprint sensor
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`captures fingerprint data when in the gesture/command mode. Ex-1028, 115:10-25
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`(“Q.…Is the fingerprint being scanned in connection with detecting finger
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`movement across the sensor in Mathiassen? A. Part of the fingerprint is being
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`imaged in connection with gestures…if it's a tap … just the part that sits over
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`the sensor.…whatever part of the fingerprint passes over the sensor in the course
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`of doing the gesture.”) In other words, the fingerprint sensor in Mathiassen is
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`always outputting fingerprint data upon finger presses—i.e., it is always outputting
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`a “biometric signal(s)” regardless of its mode. See Reply at 14-16, 17 and EX-
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`2029 at ¶¶23-27. The Board failed to address any of this evidence that contradicts
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`its rationale for finding claims 1-17 not unpatentable. FWD, 85.
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`The Board’s failure to consider this evidence is especially surprising because
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`it is inconsistent with the same Panel’s own reasoning regarding the same issue in
`
`the Apple FWD. In its FWD in this proceeding, the Board acknowledged that
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`Mathiassen’s fingerprint sensor reads fingerprint motion to act as a control input.
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`FWD, 77 (emphasis added) (“By reading the fingerprint and its motion, ‘single-
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`button sensor’ 1 (along with above components 2-5) combines biometric reading
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`for user authentication and cursor-type control for text input.”). Similarly, in
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`14
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`the Apple IPR, the Board also understood that a fingerprint sensor must analyze
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`fingerprint data to detect movements or issue commands. Apple v. CPC, IPR2022-
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`00602, Paper 31 (FWD), 52 (“Because Mathiassen, like the ’705 patent, uses a
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`biometric sensor as the input device, it will detect the biometric part of the
`
`input signal, while also sensing the number and duration of inputs.”)3
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`Yet, the Board inexplicably came to the opposite conclusion about the
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`Series/Duration Limitation for the Mathiassen-067 reference in this proceeding.
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`Petitioners submit that the Board’s rationale in the Apple FWD was correct, and if
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`that same rationale were consistently applied to the Matthiassen-067 reference in
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`the instant IPR, the Board would be compelled to find claims 1-17 unpatentable.
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`V. CONCLUSION
`Petitioners request Director review based on the Board’s erroneous
`
`construction of “biometric signal” and inconsistent application of that term.
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`Petitioners further request Director review based on the Board’s failure to consider
`
`evidence regarding the Mathiassen reference acknowledged by both sides’ experts.
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`Dated: December 22, 2023
`
`
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`3 The Mathiassen reference in the Apple FWD is different from the Mathiassen-
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`/ Dion M. Bregman /
`
`[Reg. No. 45,645]
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`067 reference in this proceeding. However, the Board’s rationale regarding
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`biometric sensors (generally) in the Apple FWD would apply equally to the
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`biometric sensors disclosed in the Mathiassen-067 reference in this proceeding.
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`15
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that a complete
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`and entire copy of PETITIONERS’ REQUEST FOR DIRECTOR REVIEW
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`was served on December 22, 2023, via email on Patent Owner’s counsel of record
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`in this proceeding:
`
`Andrew C. Ryan (ryan@cantorcolburn.com)
`
`Steven M. Coyle (scoyle@cantorcolburn.com)
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`Nicholas A. Geiger (ngeiger@cantorcolburn.com)
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`
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`
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`Dated: December 22, 2023
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`
`Respectfully Submitted,
`
` / Dion M. Bregman /
`Dion Bregman (Reg. No. 45,645)
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