`________________
`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. IPR2022-01045
`Patent No. 9,269,208 (Claims 1-9)
`______________________________________________________
`
`PETITIONERS’ REQUEST FOR DIRECTOR REVIEW
`
`
`
`TABLE OF CONTENTS
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`Page
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`I.
`II.
`III.
`IV.
`
`V.
`
`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. ......................................... 11
`C.
`The Board failed to consider relevant evidence. .................................................. 13
`D.
`CONCLUSION ................................................................................................................ 15
`
`-i-
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`
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`IPR2022-01045
`U.S. Patent No. 9,269,208
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`I.
`
`INTRODUCTION
`Petitioners request Director review under 37 C.F.R. § 42.71(d) regarding the
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`finding in the Final Written Decision (“FWD”) that claims 1-9 of U.S. 9,269,208
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`(“’208 Patent”) are not unpatentable. This request follows a request for Director
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`review in IPR2022-01006 on a related patent involving identical issues.
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`Petitioners’ request is particularly worthy of Director review because the
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`Board issued inconsistent claim construction positions regarding the term
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`“biometric signal” in different proceedings concerning the same patents and
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`limitations. Petitioners demonstrated that the claims were unpatentable under both
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`Petitioners’ and Patent Owner’s proposed constructions for “biometric signal”:
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`Petitioners
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`Patent Owner Board’s New Construction
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`plain and ordinary
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`physical
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`a physical or behavioral biometric
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`meaning—i.e., the input and
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`attribute of the
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`attribute that provides secure
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`output of a biometric sensor
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`user
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`access to a controlled item
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`However, as shown above, the Board adopted a new and erroneous
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`construction that was not proposed by either side. The Board never raised its new
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`claim construction until the FWD, after all briefing had concluded.1
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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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`IPR2022-01045
`U.S. Patent No. 9,269,208
`Petitioners submit that the findings of unpatentability in IPR2022-0601 were
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`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. This is
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`consistent with the Board’s denial of Patent Owner’s request for rehearing in
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`IPR2022-0602.
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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 1-9 of the ’208 Patent
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`based, in part, on Bianco in view of Mathiassen. Every claim of the ’208 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, 61-93. 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, 70. For the first
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`time, using language neither side proposed, the Board added the limitation that the
`2
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`IPR2022-01045
`U.S. Patent No. 9,269,208
`“biometric signal” requires “provid[ing] secure access to a controlled item.” Id.
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`The ’208 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
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`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:
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`1. A system for providing secure access to a controlled item, the
`system comprising: …
`a biometric sensor for receiving a biometric signal; …
`a receiver sub-system comprising:
`means for receiving the transmitted secure access
`signal; and
`means for providing conditional access to the
`controlled item dependent upon said information;
`wherein the transmitter sub-system controller is further
`configured to:
`means for receiving 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;
`means for mapping said series into an instruction; and
`means for populating the data base according to the
`instruction, …
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`2 “Series/Duration Limitation” refers to claim element D(1): “means for receiving a
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`series of entries of the biometric signal, said series being characterised according to
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`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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`IPR2022-01045
`U.S. Patent No. 9,269,208
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`EX-1001, Cl. 1 (emphasis added).
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`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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`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, 62-63. Applying its construction, the Board further incorrectly held: “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, 91.
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`In a separate proceeding, however, the same Panel reached the opposite
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`conclusion when addressing the same limitation. Apple Inc. v. CPC Patent
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`Technologies PTY, Ltd., IPR2022-00601, Final Written Decision (PTAB Sept. 27,
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`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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`4
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`IPR2022-01045
`U.S. Patent No. 9,269,208
`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, 37. Regarding fingerprint sensors, the Board further
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`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.” Id. Thus, the Board correctly opined that fingerprint sensors generally act
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`the same way—i.e., they output biometric signals (fingerprint scans) that they
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`detect on their surface for any finger press. Contrary to its construction in the
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`instant IPR, the Board nowhere added the limitation in the Apple FWD that the
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`“biometric signal” must provide secure 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, 89. 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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`5
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`U.S. Patent No. 9,269,208
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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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`disclose the “biometric signal” limitation under Petitioners’ construction, Patent
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`Owner’s construction(s) and the construction from the earlier Apple FWD.
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`However, the Board did not address any of this evidence. For instance, Petitioners
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`showed that Mathiassen explicitly teaches that “[t]he fingerprint sensors…scans
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`the fingerprint, and in order to be able to analyse [sic] the finger print, is able
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`to detect the finger movement across the sensor…” Reply, 6, 14 (quoting EX-
`
`1004, 8:30-32). In addition, PO’s expert agreed that fingerprint data is always read
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`by Mathiassen’s fingerprint sensor, including when being used to issue commands
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`during the Morse code-like mapping of finger presses/movements into commands.
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`EX-1028, 115:10-25. The Board’s failure to address this evidence is also a
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`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, 70 (“‘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 contemplated a secure access requirement.
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`6
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`U.S. Patent No. 9,269,208
`Petitioners’ construction: “the input and output of the biometric sensor” (Reply at
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`8); PO construction: “physical attribute of the user (i.e., fingerprint, facial pattern,
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`iris, retina, voice, etc.” (PO Resp. 9–10, 15). Nowhere in either Parties’
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`construction, the Board’s institution decision, or even the Apple FWD did any
`
`party suggest that a “biometric signal” requires “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
`
`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, 9, 10 (“means for receiving a series of entries of
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`the biometric signal [and a duration of each said entry]… means for mapping said
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`series into an instruction”). Nor is there any suggestion in the specification of
`
`providing secure access to a controlled item when the system is recognizing the
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`series of entries of the biometric signal and mapping them into an instruction. See
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`EX-1001, 10:57-11:2. Therefore, 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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`sensor (i.e., as an input). EX-1001, Cls. 1, 9, 10 (“a biometric sensor for receiving
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`7
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`U.S. Patent No. 9,269,208
`a biometric signal.”). The claims further require “[means for] matching the
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`biometric signal against members of [the] database of biometric signatures…” Id.
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`In other words, the claims recite that the biometric signal is also the output of the
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`biometric sensor. Thus, when read in light of the specification, the “biometric
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`signal” is simply the input and output of the biometric sensor. How that
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`biometric signal is used (e.g., for authentication or providing instructions) is
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`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
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`used this to reject the obviousness grounds. FWD, 70. This construction
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`improperly 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
`
`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, 9, 10: “[means for] matching 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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`instruction (e.g., “Enroll an ordinary user”). EX-1001, Cls. 1, 9, 10 (“[means for]
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`8
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`IPR2022-01045
`U.S. Patent No. 9,269,208
`receiving a series of entries of the biometric signal [and a duration of each said
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`entry]… mapping said series into an instruction; and…populating the data base
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`according to the instruction.”); see EX-1001, 11:57-63. The specification explains:
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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., 10:45-56.
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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-1001, 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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`consider a biometric sensor (e.g., fingerprint sensor) that is connected in a simple
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`9
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`IPR2022-01045
`U.S. Patent No. 9,269,208
`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
`
`off when a succession of finger presses is applied to the fingerprint sensor.” Apple
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`FWD, 37. 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
`
`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
`
`authentication was admittedly old. See EX-1001, Background. The purported
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`10
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`U.S. Patent No. 9,269,208
`point of novelty of the claims of the ’208 patent (reflected in the Series/Duration
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`Limitation) is a second use of the “biometric signal”—receiving a series of
`
`“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.
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`The Board’s construction renders other limitations superfluous.
`B.
`The Board improperly added a “secure access” limitation into “biometric
`
`signal,” rendering other claim limitations superfluous. For the first use of the
`
`biometric signal, the claims already recite structures provide “secure access”: Ex-
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`1001, Cls. 1, 9 (“means for emitting a secure access signal conveying [said]
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`information dependent upon said accessibility attribute.”); Cls. 1, 10 (“a receiver
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`sub-system comprising[:] means for receiving the transmitted secure access
`
`signal; and means for providing conditional access to the controlled item
`
`dependent upon said information.” By improperly adding the limitation “provides
`
`secure access to a controlled item” into its construction for “biometric signal,” the
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`Board stripped all meaning from the “receiver sub-system,” which is already
`
`responsible for providing secure access to the controlled item. See Mformation
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`Techs., Inc. v. Research in Motion Ltd., 764 F.3d 1392, 1399 (Fed. Cir. 2014)
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`(favoring a construction that does not render another limitation “superfluous”).
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`The Board’s construction results in indefinite claims.
`C.
`The Board’s newly created construction would also lead to nonsensical and
`11
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`IPR2022-01045
`U.S. Patent No. 9,269,208
`indefinite claims, which is evident in multiple places of the specification.
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`The ’208 Patent claims require “means for matching the
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`biometric signal against members of the database of biometric
`
`signatures.” EX-1001, Cl. 1. This is shown in Fig. 3 (right) and
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`illustrates a problem with the construction. See EX-1001, 7:65-8:10.
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`Step 210 (yellow) determines if a biometric signal was received and
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`step 202 (green) compares the “biometric signal” against the signature
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`database to determine if the user is authorized. The Board’s
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`construction requires that “biometric signals” must themselves already provide
`
`secure access (i.e., are authorized), and therefore only signals that already match
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`the signature database would proceed through step 201 (yellow), eliminating the
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`need for checking against the signature database. This result is nonsensical and
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`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 already exist in the
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`database and the Board’s secure access requirement would
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`necessarily fail every time. Likewise, consider col. 10:5-23
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`and Fig. 6 (right). Under the Board’s construction, step 702
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`(blue), which determines if the database is empty and needs to
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`be populated with new data (green), would only be reached if
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`12
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`U.S. Patent No. 9,269,208
`a “biometric signal” has been received at step 701 (yellow). But the Board’s
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`construction requires “biometric signals” to themselves provide secure access,
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`which is not possible with an empty database because there is nothing to compare
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`against to provide secure access. With an empty database, no biometric signals
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`could ever clear step 701 under the Board’s construction. The Board’s
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`construction leads to indefiniteness and is erroneous.
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`The Board failed to consider relevant evidence.
`D.
`In its Final Written Decision, the Board concluded that Mathiassen does not
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`teach receiving a series of biometric signals. FWD, 91 (“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:
`13
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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
`
`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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`1029 at ¶¶23-30. The Board failed to address any of this evidence that contradicts
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`its rationale for finding claims 1-9 not unpatentable. FWD, 91, 93.
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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
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`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, 80 (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 FWD, 58
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`(“Because Mathiassen, like the ’208 patent, uses a biometric sensor as the
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`input device, it will detect the biometric part of the input signal, while also
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`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- 9 unpatentable.
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`V.
`
`CONCLUSION
`Petitioners request Director review based on the Board’s erroneous
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`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
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`evidence regarding the Mathiassen reference acknowledged by both sides’ experts.
`
`Dated: January 18, 2024
`
`/ Dion M. Bregman /
`
`Reg. No. 45,645
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`3 The Mathiassen reference in the Apple FWD is different from the Mathiassen-
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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 on January 18,
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`2024, a complete and entire copy of PETITIONERS’ REQUEST FOR
`
`DIRECTOR REVIEW was submitted in the Patent Trial and Appeal Case
`
`Tracking System (P-TACTS), and sent by electronic mail to the following:
`
`Director
`Email: Director_PTABDecision_Review@uspto.gov
`
`Counsel for Patent Owner:
`
`Andrew C. Ryan
`Steven M. Coyle
`Nicholas A. Geiger
`Email: ryan@cantorcolburn.com
`Email: scoyle@cantorcolburn.com
`Email: (ngeiger@cantorcolburn.com)
`
`Dated: January 18, 2024
`
`Respectfully Submitted,
`
` / Dion M. Bregman /
`Dion Bregman (Reg. No. 45,645)
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`16
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