Case 2:16-cv-00741-RWS Document 103 Filed 12/05/16 Page 1 of 14 PageID #: 1185
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`Civil Action No. 2:16-cv-741 (JRG)
`LEAD CASE
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`JURY TRIAL DEMANDED
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`UNILOC USA, INC. and
`UNILOC LUXEMBOURG, S.A.,
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`Plaintiffs,
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`v.
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`ADP, LLC,
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`Defendant.
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`PLAINTIFFS’ SURREPLY IN OPPOSITION TO
`DEFENDANT’S MOTION TO DISMISS
`FOR FAILURE TO STATE A CLAIM
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`2A84988
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`Case 2:16-cv-00741-RWS Document 103 Filed 12/05/16 Page 2 of 14 PageID #: 1186
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`TABLE OF CONTENTS
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`I.
`
`II.
`
`INTRODUCTION............................................................................................................. 1
`
`ARGUMENT ..................................................................................................................... 1
`
`A.
`B.
`
`C.
`
`D.
`
`E.
`
`The Asserted Patents Provide Unconventional Technological Solutions ............... 1
`ADP’s Claim Construction Argument should be Rejected..................................... 6
`
`District Court Cases ................................................................................................ 8
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`Unasserted Claims ................................................................................................ 10
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`’293 Patent Pleading ............................................................................................. 10
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`III
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`CONCLUSION ............................................................................................................... 10
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`i
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`

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`Case 2:16-cv-00741-RWS Document 103 Filed 12/05/16 Page 3 of 14 PageID #: 1187
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`TABLE OF AUTHORITIES
`
`Cases 
`800 Adept, Inc. v. Murex Sec., Ltd.,
`539 F.3d 1354 (Fed. Cir. 2008) ................................................................................................ 10
`
` A
`
` Pty Ltd. v. eBay, Inc.,
` No. 1:15-cv-155-RP, Dkt. No. 34 (W.D. Tex. Oct. 8, 2015) ................................................... 10
`
`Amdocs (Isr.) Ltd. v. Opennet Telecom, Inc.,
` 2016 U.S. App. LEXIS 19593 (Fed. Cir. Nov. 1, 2016) .................................................... 1, 2, 8
`
`BASCOM Global Internet Servs. v. AT&T Mobility LLC,
`827 F.3d 1341 (Fed. Cir. 2016) .............................................................................................. 2, 8
`
`
`Blitzsafe Texas, LLC, v. Volkswagen Group of Am., Inc.,
`Case No. 2:15-cv-1278-JRG-RSP (E.D. Tex. Aug. 19, 2016) ................................................ 10
`
`
`Core Wireless Lic. S.à.r.l. v. LG Elecs., Inc.,
`2016 U.S. Dist. LEXIS 35663 (E.D. Tex. Mar. 20, 2016) ............................................... 8, 9, 10
`
`
`DDR Holdings, LLC v. Hotels.com, L.P.,
`773 F.3d 1245 (Fed. Cir. 2014) .................................................................................... 2, 8, 9, 10
`
`
`Enfish LLC v. Microsoft Corp.,
`822 F.3d 1327 (Fed. Cir. 2016) .............................................................................................. 1, 8
`
`
`FoxGroup, Inc. v. Cree, Inc.,
` 700 F.3d 1300 (Fed. Cir. 2012) ................................................................................................ 10
`
`Genband US LLC v. Metaswitch Networks Ltd.,
`2016 U.S. Dist. LEXIS 134659 (E.D. Tex. Sept. 29, 2016) ...................................................... 9
`
`
`JDS Techs., Inc. v. Exacq Techs.,
`2016 U.S. Dist. LEXIS 73622 (E.D. Mich., June 7, 2016) ................................................. 9, 10
`
`
`McRo, Inc. v. Bandai Namco Games AM. Inc.,
`837 F3d 1299 (Fed. Cir. 2016) ................................................................................................... 8
`
`
`Novo Nordisk A/S v. Caraco Pharm. Labs., Ltd.,
` 719 F.3d 1346 (Fed. Cir. 2013) .................................................................................................. 1
`
`Perdiemco, LLC v. Industrack LLC,
`2016 U.S. Dist. LEXIS 135667 (E.D. Tex., July 7, 2016) ......................................................... 8
`
`
`Skinner v. Spitzer,
` 562 U.S. 521 (2011) ................................................................................................................. 10
`
`ii
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`

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`Case 2:16-cv-00741-RWS Document 103 Filed 12/05/16 Page 4 of 14 PageID #: 1188
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`I.
`
`INTRODUCTION
`In its opening motion and again in its reply, ADP improperly characterizes the nature of
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`the Asserted Patents as covering “time-honored methods of organizing human activity,
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`‘implemented with generic technical components in a conventional way.” Reply at 1. This
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`argument must be rejected because it constitutes an improper over-generalization of the scope of
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`the Asserted Patents. See, e.g., Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1336 (Fed. Cir.
`
`2016). Moreover, Uniloc has identified specific limitations of the Asserted Claims that
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`contribute to unique solutions that improve the functionality of the technology while also
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`identifying how the art at the time was so lacking. See Opp.(Dkt. No. 64) at 2-6.
`
`ADP also improperly attempts to shift the burden of proof to Uniloc at this stage of the
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`litigation. Reply at 1 (“Uniloc must show that its computer-limited claims provide a ‘technology-
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`based solution’ that overcomes problems in a technical art.”). Contrary to ADP’s argument, the
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`burden of proving invalidity rests with ADP and never shifts to Uniloc. See, e.g., Novo Nordisk
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`A/S v. Caraco Pharm. Labs., Ltd., 719 F.3d 1346, 1352 (Fed. Cir. 2013). In any event, Uniloc
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`has shown the problems overcome by the claimed inventions. See Opp. at 2-6, 9-25.
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`II.
`
`ARGUMENT
`A.
`The Asserted Patents Provide Unconventional Technological Solutions
`ADP goes to great lengths to distinguish the Federal Circuit precedent cited by Uniloc
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`using an overly-simplistic analogy to a librarian or shopkeeper in 1916. Reply at 2-5. An even
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`more recent Federal Circuit case further supports Uniloc’s position. In Amdocs (Isr.) Ltd. v.
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`Opennet Telecom, Inc., 2016 U.S. App. LEXIS 19593 (Fed. Cir. Nov. 1, 2016), the Court
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`considered, inter alia, the following claim:
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`A computer program product embodied on a computer readable storage
`1.
`medium for processing network accounting information comprising:
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`computer code for receiving from a first source a first network accounting record;
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`1
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`

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`Case 2:16-cv-00741-RWS Document 103 Filed 12/05/16 Page 5 of 14 PageID #: 1189
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`computer code for correlating the first network accounting record with accounting
`information available from a second source; and
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`computer code for using the accounting information with which the first network
`accounting record is correlated to enhance the first network accounting record.
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`Id. at **24-25. The Court reversed the district court’s determination that this claim was directed
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`to an abstract idea under Step 1 and lacking “inventive concept” under Step 2 of Alice. Id. at
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`**25-33. The Court found this claim to be patent eligible, relying on the holdings from Bascom
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`and DDR Holdings cited prominently in Uniloc’s opposition brief.
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`
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`The claims of the Asserted Patents are similar in their language and scope as the above
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`claim found eligible in Amdocs. For example, claim 1 of the ’578 Patent recites as follows:
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`1. A method for management of configurable application programs on a network
`comprising the steps of:
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`[a] installing an application program having a plurality of configurable preferences
`and a plurality of authorized users on a server coupled to the network;
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`[b] distributing an application launcher program associated with the application
`program
`to
`a
`client
`coupled
`to
`the
`network;
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`[c] obtaining a user set of the plurality of configurable preferences associated with
`one of the plurality of authorized users executing the application launcher program;
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`[d] obtaining an administrator set of the plurality of configurable preferences from an
`administrator; and
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`[e] executing the application program using the obtained user set and the obtained
`administrator set of the plurality of configurable preferences responsive to a request
`from the one of the plurality of authorized users.
`
`
`See Opp. at 9-10. As in Amdocs, this and the other challenged claims are patent eligible.
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`
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`The Court in Amdocs also noted specifically that the patent provided a “critical
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`advancement over the prior art.” Id. at *27. Specifically, the patent identified the problem in the
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`prior art as being that “all the network data information flows to one location, making it very
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`difficult to keep up with the massive record flows from the network devices and requiring huge
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`2
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`

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`Case 2:16-cv-00741-RWS Document 103 Filed 12/05/16 Page 6 of 14 PageID #: 1190
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`databases.” Id. at *28 (internal citations omitted). The court reasoned that “this claim entails an
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`unconventional
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`technological solution (enhancing data
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`in a distributed fashion)
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`to a
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`technological problem (massive record flows which previously required massive databases). The
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`solution requires arguably generic components, including network devices and “gatherers” which
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`“gather” information. However, the claim’s enhancing limitation necessarily requires that these
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`generic components operate in an unconventional manner to achieve an improvement in
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`computer functionality. Id. at *28. The same is true here.
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`
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`ADP also argues that the technological elements of Uniloc’s method claims are not
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`“specific to computers” and, therefore, lend no patentable weight. Reply at 4. ADP’s argument
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`should be rejected. For example, Figure 1 of each Asserted Patent clearly discloses a computer
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`network. See, e.g., ’578 Patent Fig. 1. Moreover, the specifications describe Figure 1 as follows:
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`
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`See ’578 Patent at 6:13-15. Moreover, for example, the ’293 Patent recites the limitation:
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`preparing a file packet associated with the application program and including a
`segment configured to initiate registration operations for the application program at
`the target on-demand server;
`
`The
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`language of
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`this
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`’293
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`limitation
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`inherently
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`requires performance on
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`a
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`computer. Importantly, the inherent computer-based language of the limitation is consistent with
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`the disclosure of the ’293 Patent specification, which teaches that this limitation includes
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`programmed instructions for processing specific data (“a segment configured to initiate
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`registration operations” includes “an import data file and a call to an import program executing
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`on a target station.” ’293 Patent at 5:45-48; “a variable field into which the target station inserts
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`its identification during registration operations.” Id. at 5:53-56; “[a] profile manage import call is
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`3
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`included in the distributed file packet along with an import text file containing the data required
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`to properly install and register the application program on the on-demand server.” Id. at 4:18-
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`22.). Processing of data in accordance with programmed instructions can only be performed on a
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`computer and, thus, is fundamentally not an abstract concept performable by a librarian.
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`Therefore, when properly construed, the above limitation contributes to the inventive concept
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`that provides an unconventional technological solution (enhancing installation and registration of
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`application programs on computers of the network) to a technological problem (limited
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`capabilities associated with centralized management of software distribution) to thereby improve
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`the underlying
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`technological functionality of computers
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`in a heterogeneous network
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`environment.
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`In addition, the ’578 Patent recites the following limitations:
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`distributing an application launcher program associated with the application program
`to a client coupled to the network; and
`executing the application program using the obtained user set and the obtained
`administrator set of the plurality of configurable preferences responsive to a request
`from the one of the plurality of authorized users;
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`The language of these ’578 limitations also inherently requires performance on a computer.
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`The’578 Patent specification teaches that these limitations include program code executable on
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`a computer (“the application launcher may … only contain code required to obtain the
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`application program’s executable code and the appropriate code to obtain preferences.” ’578
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`Patent at 8:35-42; “The application launcher program is then fully distributed to the client when
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`execution of the application program is requested by the user.” Id. at 8:42-44; “Alternatively, the
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`application launcher may contain all the executable code before execution is requested.” Id. at
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`8:46-48.) Execution of application launcher program code can only be performed on a computer.
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`Such code is inherently electronic and cannot be performed by a librarian. When properly
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`4
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`construed, the ’578 Patent limitations cooperate to recite the inventive concept that provides an
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`unconventional technological solution (enabling sharing of a storage device between computers
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`or use of separate but synchronized databases of preferences values at the computers; Id. at
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`10:37-46) to a technological problem (roaming users within a heterogeneous computer network)
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`to further improve the underlying functionality of computers in the network.
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`The ’466 Patent recites the limitation of “providing an instance of the selected one of the
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`plurality of application programs to the client for execution responsive to the selection.” The
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`language of this ’466 limitation requires performance on a computer. The inherent computer-
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`based language of the limitation is consistent with the disclosure of the ’466 Patent specification,
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`which teaches that this limitation includes program code executable on a computer (“the
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`application program code itself may be included in the application launcher at the time the user
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`desktop interface is populated allowing an instance of the application program to be executed.”
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`’466 Patent at 16:5-9). Execution of application program code can only be performed on a
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`computer and not by a librarian. Again, when properly construed, the ’466 limitation contributes
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`to the inventive concept that provides an unconventional technological solution (allowing
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`execution of an instance of the application program with less communication traffic between the
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`network and computer; Id. at 16:10-12) to a technological problem (providing seamless
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`integration of application access across heterogeneous networks) to improve the underlying
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`functionality of computers in the network.
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`Lastly, the ’766 Patent recites the limitation:
`
`maintaining license management policy information for a plurality of application
`programs at a license management server, the license management policy
`information including at least one of a user identity based policy, an administrator
`policy override definition or a user policy override definition;
`
`5
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`

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`Case 2:16-cv-00741-RWS Document 103 Filed 12/05/16 Page 9 of 14 PageID #: 1193
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`The language of this ’766 limitation is also inherently requires performance on a
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`computer. Indeed, the ’766 Patent specification teaches that this limitation includes program
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`calls executable on a computer (“the application launcher is configured to read a set of license
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`policies, for example, by using the preference Application Program Interface (API) for the user
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`that is requesting initiation of an instance of the application.” ’766 Patent at 12:67 to 13:1-4;
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`“The application launcher may then initiate appropriate calls to register the kind of license
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`specified by the policy with the server system 22 for centralized storage and management.” Id. at
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`13:4-7.) Execution of program calls can only be performed on a computer and not by a librarian.
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`Therefore, when properly construed, the ’766 limitation contributes to the inventive concept that
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`provides an unconventional technological solution (flexibility to software designers writing
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`applications and to administrators to change policies not otherwise readily modified without
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`rewriting the applications (Id. at 13:50-54)) to a technological problem (management of licenses
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`based on roaming users accessing applications from different client stations) to thereby improve
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`the underlying functionality of computers in the network.
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`B.
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`ADP’s Claim Construction Argument should be Rejected
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`ADP next argues that, even under the constructions offered by Uniloc, “the patents still
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`address problems known outside the computer arts, using solutions known outside the computer
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`arts, to achieve benefits known outside the computer arts.” Reply at 5. ADP is incorrect. As
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`indicated above, the Asserted Patents are expressly directed to solving problems that existed
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`within computer networks in 1998.
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`ADP repeats the arguments in its opening brief that the Asserted Patents merely mimic
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`routine tasks that humans, such as librarians and vendors, can perform. Reply at 5-7. Uniloc
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`already rebutted those arguments on pages 9-19 of its opposition brief. For example, at the time
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`6
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`

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`Case 2:16-cv-00741-RWS Document 103 Filed 12/05/16 Page 10 of 14 PageID #: 1194
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`the inventions were conceived and reduced to practice, the notion of user mobility in a
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`heterogeneous environment was a new issue confronted by many technology companies. ’766
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`Patent at 3:5-11. Previously, users were free to exploit the use of software licenses by, e.g.,
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`making copies of application programs for their friends. Software developers lacked little
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`control over copying their proprietary software. Id. at 3:27-33. The management of licenses and
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`distributing applications in a heterogeneous network where users moved from station to station
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`became a pressing issue. Id. at 1:53-56.
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`Also, the Asserted Patents solve a problem that existed in the industry in 1998 in
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`accommodating user mobility in a heterogeneous network environment. Claim 1 of the ’766
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`patent uses the term “license management policy information” which can be construed as setting
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`“policies, such as the limit of the number of users, whether crossing the limit of users is allowed
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`or not and how users are counted.” Opp. at 19. This construction addresses the issue of mobility
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`of users in a heterogeneous network environment. The patent specifically addresses the problem
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`of managing license use to insure compliance with limitations established by software developers
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`in heterogeneous, distributed network environments. ’766 Patent at 15:63-15:17. Particularly,
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`the recitation of “license management policy information” contemplates providing an “instance
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`of the selected one of the plurality of application programs to the client for execution” as the
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`specification clarifies that an “application being managed may retrieve its license use policy
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`based on the user that is requesting initiation of an instance of the application.” See ’766 Patent
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`at 12:53-56. This comports with Uniloc’s proposed construction of the ’466 Patent of the term
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`“providing an instance of the selected one of the plurality of application programs.” Opp. at 14.
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`Read together, these proposed constructions avoid preempting all ways of distributing and
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`managing applications and licenses in a client-server environment.
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`7
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`

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`Case 2:16-cv-00741-RWS Document 103 Filed 12/05/16 Page 11 of 14 PageID #: 1195
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`C.
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`District Court Cases
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`
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`ADP argues that the district court cases cited by Uniloc are distinguishable. Reply at 8-9.
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`Uniloc disagrees. Irrespective of the district courts cases cited, however, the claims are patent
`
`eligible under the Federal Circuit cases cited herein and in Uniloc’s opposition brief, namely
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`Enfish, BASCOM, McRo and now Amdocs. Thus, ADP’s argument regarding the district court
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`cases is moot. Nonetheless, Uniloc will respond to ADP’s argument for the sake of
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`completeness.
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`
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`ADP argues that Perdiemco is inapposite because the Asserted Patents “bring
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`conventional efficiencies to computers.” Reply at 8. ADP is incorrect. As in DDR, the claims
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`are “rooted in computer technology in order to overcome a problem specifically arising in the
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`realm of computer networks.” DDR Holdings, 773 F.3d at 1256. As in DDR, the claims are
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`patent eligible. As in Perdiemco, each challenged claim of the Asserted Patents “defines a set of
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`rules for organizing and improving the behavior of a [] computer system.” ].” 2016 U.S. Dist.
`
`LEXIS 135667, at *18. As in Perdiemco, the claims are patentable.
`
`
`
`ADP argues that, unlike in Core Wireless, it has shown that the elements of Uniloc’s
`
`claims are “no different from brick-and-mortar examples.” Reply at 9. ADP is incorrect. In
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`Core Wireless, the Court stated that “concepts of ‘application,’ ‘summary window,’ and
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`‘unlaunched state’ are specific to devices like computers and cell phones.” Core Wireless, 2016
`
`U.S. Dist. LEXIS 35663, at *11. The asserted claims recite similar computer-centric terms. For
`
`example, claim 1 of the ’578 Patent recites the following: “management of configurable
`
`application programs on a network”; “authorized users on a server coupled to a network”;
`
`“application launcher program,” and “executing the application launcher program.”
`
`8
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`

`

`Case 2:16-cv-00741-RWS Document 103 Filed 12/05/16 Page 12 of 14 PageID #: 1196
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`As demonstrated herein, a reasonable person could not legitimately argue that these elements are
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`not specific to devices like computers. Thus, ADP’s brick-and-mortar argument should be
`
`rejected. As in Core Wireless, the asserted claims herein are patent eligible.
`
`
`
`ADP argues that Genband v. Metaswitch is inapposite “because there the claimed
`
`operations were ‘meaningless outside the context of a computer network,’ while Uniloc’s
`
`methods are just as advantageous when applied outside computer environments.” Reply at 9. As
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`set forth in the preceding paragraphs, the elements of the asserted claims are directed specifically
`
`to computer networks. Thus, ADP’s attempt to distinguish Genband should be rejected.
`
`Moreover, as in Genband, the asserted Uniloc claims “attempt to ‘overcome a problem
`
`specifically arising in computer networks.’”1 Genband, 2016 U.S. Dist. LEXIS 134659, at *107
`
`(quoting DDR Holdings, 773 F.3d at 1257)). As in Genband, the asserted claims are patent
`
`eligible.
`
`
`
`In JDS Techs., the Court upheld the challenged claims, inter alia, because they are
`
`directed to a “particular concrete application” that solved a problem with computers. See JDS
`
`Techs., 2016 U.S. Dist. LEXIS 73622, at **18-19. ADP argues that JDS Techs. is inapposite
`
`because “Uniloc’s patents treat application programs like products and file packets like catalog
`
`cards, and thus cover ‘“fundamental practice[s]” previously practiced’ by librarians and
`
`vendors.” Reply at 9 (quoting JDS Techs., 2016 U.S. Dist. LEXIS 73622, at *19). Once again,
`
`ADP improperly ignores the language of the claims which, as set forth above and in JDS Techs.,
`
`is “rooted in computer technology in order to overcome a problem that specifically arose” with
`
`computer networks.” JDS Techs., 2016 U.S. Dist. LEXIS 73622, at **19-20. Such subject
`
`                                                            
`1 See Uniloc’s opposition brief (Dkt. No. 64), at 2-6, 9-19.
`
`9
`
`

`

`Case 2:16-cv-00741-RWS Document 103 Filed 12/05/16 Page 13 of 14 PageID #: 1197
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`matter is patent eligible under Federal Circuit law, DDR Holdings, 773 F.3d at 1256, as applied
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`by this Court. See, e.g., Core Wireless, 2016 U.S. Dist. LEXIS 35663, at **11-12.
`
`
`
`
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`D.
`
`Unasserted Claims
`
`With respect to the unasserted claims, Uniloc agrees that the (unappealed) A Pty decision
`
`supports ADP’s argument. Uniloc believes, however, that A Pty is inconsistent with 800 Adept,
`
`Inc. v. Murex Sec. Ltd., 539 F.3d 1354, 1366-67 (Fed. Cir. 2008) and FoxGroup, Inc. v. Cree,
`
`Inc., 700 F.3d 1300, 1308 (Fed. Cir. 2012) which require that claims must be specified before
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`they can be rendered invalid.
`
`
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`
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`E.
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`’293 Patent Pleading
`
`Finally, ADP argues that the Complaint fails to identify which specific backend server is
`
`accused of infringement. As set forth in Uniloc’s opposition brief, paragraph 38 of the
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`Complaint, however, identifies “backend server architecture,” a “network server” and an “on-
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`demand server.” See Dkt. No. 1 at ¶ 38.2 This is sufficient for pleading purposes. Blitzsafe
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`Texas, LLC, v. Volkswagen Group of Am., Inc., Case No. 2:15-cv-1278-JRG-RSP, Dkt. No. 27 at
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`8 (E.D. Tex. Aug. 19, 2016); Skinner v. Spitzer, 562 U.S. 521, 530 (2011).
`
`III. CONCLUSION
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`For the reasons stated herein and in Uniloc’s opposition brief, the Motion should be
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`denied.
`
`
`Dated: December 5, 2016
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`Respectfully submitted,
`
`
`
`/s/ Kevin Gannon
`Paul J. Hayes
`Kevin Gannon
`Daniel J. McGonagle
`
`
`
`                                                            
`2 ADP acknowledges that Uniloc’s Infringement Contentions identify the “Nginx” and “Apache”
`servers. Reply at 10.
`
`
`10
`
`

`

`Case 2:16-cv-00741-RWS Document 103 Filed 12/05/16 Page 14 of 14 PageID #: 1198
`
`CESARI AND MCKENNA, LLP
`88 Black Falcon Ave., Suite 271
`Boston, MA 02110
`Telephone: (617) 951-2500
`Facsimile: (617) 951-3927
`Email: pjh@c-m.com
`Email: kgannon@c-m.com
`Email: djm@c-m.com
`
`Craig Tadlock
`State Bar No. 00791766
`John J. Harvey, Jr.
`State Bar No. 09179770
`TADLOCK LAW FIRM PLLC
`2701 Dallas Parkway, Suite 360
`Plano, TX 75093
`Tel: (903) 730-6789
`Email: craig@tadlocklawfirm.com
`Email: john@tadlocklawfirm.com
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`ATTORNEYS FOR THE PLAINTIFFS
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that all counsel of record who are deemed to have
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`consented to electronic service are being served with a copy of this document via the Court’s
`CM/ECF system per Local Rule CV-5(a)(3) on December 5, 2016.
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`/s/ Kevin Gannon
`Kevin Gannon
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`11
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