`Trials@uspto.gov
`Entered: November 17, 2016
`
`571-272-7822
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`RPX CORPORATION,
`Petitioner,
`
`v.
`
`SOCKEYE LICENSING TX, LLC,
`Patent Owner.
`_______________
`
`Case IPR2016-01054
`Patent 8,879,987 B1
`_______________
`
`
`
`Before BRYAN F. MOORE, ROBERT J. WEINSCHENK, and
`JOHN A. HUDALLA, Administrative Patent Judges.
`
`WEINSCHENK, Administrative Patent Judge.
`
`DECISION
`Institution of Inter Partes Review
`37 C.F.R. § 42.108
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`
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`INTRODUCTION
`I.
`RPX Corporation (“Petitioner”) filed a Petition (Paper 2, “Pet.”)
`requesting an inter partes review of claims 6–9 of U.S. Patent No. 8,879,987
`B1 (Ex. 1201, “the ’987 patent”). Sockeye Licensing TX, LLC (“Patent
`Owner”) did not file a preliminary response to the Petition. An inter partes
`review may not be instituted “unless . . . there is a reasonable likelihood that
`the petitioner would prevail with respect to at least 1 of the claims
`challenged in the petition.” 35 U.S.C. § 314(a).
`For the reasons set forth below, Petitioner demonstrates a reasonable
`likelihood of prevailing in showing the unpatentability of claims 6–9 of the
`’987 patent. Accordingly, we institute an inter partes review as to claims 6–
`9 of the ’987 patent on the grounds specified below.
`Related Proceedings
`A.
`The parties indicate that the ’987 patent is the subject of several cases
`in the United States District Court for the Northern District of Illinois.
`Pet. 1–2; Paper 5, 2–3. The parties also indicate that the following petitions
`for inter partes review are related to this case:
`Case No.
`Involved U.S. Patent No.
`IPR2016-00985
`U.S. Patent No. 8,879,987
`IPR2016-00989
`U.S. Patent No. 8,135,342
`IPR2016-01052
`U.S. Patent No. 8,135,342
`IPR2016-01053
`U.S. Patent No. 8,879,987
`Pet. 1; Paper 5, 2.
`The ’987 Patent
`B.
`The ’987 patent relates to establishing a connection between a
`wireless device and a peripheral device. Ex. 1201, col. 1, ll. 25–30. The
`’987 patent explains that, although previous products allowed a wireless
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`device to project images onto a wall or nearby surface, those products did
`not allow a wireless device to transmit browser-based content to a full-size
`digital display device, such as a computer monitor. Id. at col. 2, ll. 1–9. To
`address this deficiency, the ’987 patent describes connecting a wireless
`device to one or more peripheral devices, such as a desktop monitor or
`printer, using one or more wireline or wireless connections. Id. at col. 6,
`ll. 55–63. The wireless device uses a cell phone network and Transmission
`Control Protocol/Internet Protocol (“TCP/IP”) network to access one or
`more browser-based applications. Id. at col. 6, ll. 63–67. The data received
`by the wireless device from the browser-based applications is communicated
`through a peripheral communications interface to the one or more peripheral
`devices. Id. at col. 7, ll. 9–18.
`Illustrative Claim
`C.
`Claims 6 and 7 are independent and are reproduced below.
`6. A method for facilitating user connectivity,
`comprising:
`downloading, by a user on a wireless device in a
`communications network from a server in said communications
`network, user information to said wireless device;
`receiving said user information in a manner that uniquely
`associates the user information with one or more peripheral
`devices and uniquely associates each peripheral device with one
`or more users;
`transmitting, under control of each user accessing said
`wireless device, the downloaded user information from said
`wireless device to a peripheral device,
`wherein said peripheral device, controlled by said user
`from said wireless device, is connected to a separate system,
`wherein said peripheral device includes a display screen
`and at least one input peripheral device, thereby enabling
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`interactive and real time communications between peripheral
`devices and the server, and
`wherein two users interconnect to said peripheral device,
`said two users controlling said user information.
`Ex. 1201, col. 15, l. 50–col. 16, l. 2.
`7. A wireless device for facilitating user connectivity
`comprising:
`for each user accessing a wireless device, a means for
`connecting a user of said wireless device to user information
`stored for the respective wireless device on a server in a
`communications network;
`means for downloading said user information to said
`wireless device;
`means for relaying the downloaded user information, at
`the control of said user, to a peripheral device;
`means for operating said peripheral device from said
`wireless device; and
`wherein said peripheral device comprises a hub, whereby
`a plurality of components connected to said peripheral device
`are accessible therethrough,
`wherein each user accesses a respective peripheral
`device, said respective peripheral devices being selected from
`the group consisting of: a desktop monitor keyboard and
`mouse, a laptop computer, a laptop computer terminal device, a
`tablet computer, a tablet computer terminal device, a high-
`definition monitor and speaker system, and combinations
`thereof,
`wherein respective peripheral devices are used to access
`and operate software available on the wireless device or over
`the Internet.
`Id. at col. 16, ll. 3–28.
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`Exhibit No.
`Ex. 1202
`
`Ex. 1203
`
`Evidence of Record
`D.
`Petitioner relies on the following references and declarations (Pet. 3,
`11–12, 34–35, 44–45):
`Reference or Declaration
`Tee et al., U.S. Patent Application Pub. No. 2006/0203758
`A1 (published Sept. 14, 2006) (“Tee”)
`Acharya et al., U.S. Patent Application Pub. No.
`2005/0036509 A1 (published Feb. 17, 2005) (“Acharya”)
`Soin et al., U.S. Patent Application Pub. No. 2005/0091359
`A1 (published Apr. 28, 2005) (“Soin”)
`Wang et al., U.S. Patent Application Pub. No.
`2006/0077310 A1 (published Apr. 13, 2006) (“Wang”)
`Benco et al., U.S. Patent Application Pub. No.
`2005/0135393 A1 (published June 23, 2005) (“Benco”)
`Declaration of Peter Rysavy (“Rysavy Declaration”)
`Second Declaration of Peter Rysavy (“Second Rysavy
`Declaration”)
`Asserted Grounds of Unpatentability
`E.
`Petitioner asserts that the challenged claims are unpatentable on the
`following grounds (Pet. 3):
`Claim(s)
`Basis
`6–9
`35 U.S.C. § 103(a)
`6
`35 U.S.C. § 103(a)
`7–9
`35 U.S.C. § 103(a)
`II. ANALYSIS
`A. Claim Construction
`The claims of an unexpired patent are interpreted using the broadest
`reasonable interpretation in light of the specification of the patent in which
`they appear. 37 C.F.R. § 42.100(b); Cuozzo Speed Techs., LLC v. Lee, 136
`S. Ct. 2131, 2144–46 (2016). Petitioner proposes construing several claim
`terms in the ’987 patent. Pet. 4–11. On this record and for purposes of this
`
`Reference(s)
`Soin and Wang
`Tee and Acharya
`Tee, Acharya, and Benco
`
`Ex. 1204
`
`Ex. 1205
`
`Ex. 1206
`
`Ex. 1208
`Ex. 1210
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`decision, we determine that only the means-plus-function limitations
`addressed below require express construction. See Vivid Techs., Inc. v. Am.
`Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999) (“[O]nly those terms
`need be construed that are in controversy, and only to the extent necessary to
`resolve the controversy.”). Construing a means-plus-function limitation
`involves two steps: 1) identifying the claimed function; and 2) identifying in
`the specification the corresponding structure for the claimed function. Med.
`Instrumentation & Diagnostics Corp. v. Elekta AB, 344 F.3d 1205, 1210
`(Fed. Cir. 2003). With respect to the second step, “structure disclosed in the
`specification is ‘corresponding’ structure only if the specification or
`prosecution history clearly links or associates that structure to the function
`recited in the claim.” Golight, Inc. v. Wal-Mart Stores, Inc., 355 F.3d 1327,
`1334 (Fed. Cir. 2004) (citations and quotation marks omitted).
`means for connecting a user of said wireless device to
`1.
`user information stored for the respective wireless device
`on a server in a communications network
`Petitioner argues that this term is a means-plus-function limitation to
`be construed in accordance with 35 U.S.C. § 112, ¶ 6. Pet. 8. Petitioner
`argues that the corresponding structure disclosed in the ’987 patent is a
`digital baseband and TCP/IP services. Id. (citing Ex. 1201, col. 7, ll. 1–9,
`Figs. 1, 3A–3D). On this record, we agree with Petitioner. Thus, for
`purposes of this decision, we determine that the recited function is
`“connecting a user of said wireless device to user information stored for the
`respective wireless device on a server in a communications network,” and
`the corresponding structure is “a digital baseband and TCP/IP services, and
`equivalent structures.”
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`2.
`
`means for downloading said user information to said
`wireless device
`Petitioner argues that this term is a means-plus-function limitation to
`be construed in accordance with 35 U.S.C. § 112, ¶ 6. Pet. 9. Petitioner
`argues that the corresponding structure disclosed in the ’987 patent is a
`digital baseband, TCP/IP services, and a desktop browser. Id. (citing
`Ex. 1201, col. 7, ll. 9–18, Figs. 1, 3A–3D). On this record, we agree with
`Petitioner. Thus, for purposes of this decision, we determine that the recited
`function is “downloading said user information to said wireless device,” and
`the corresponding structure is “a digital baseband, TCP/IP services, and
`desktop browser, and equivalent structures.”
`means for relaying the downloaded user information, at
`3.
`the control of said user, to a peripheral device
`Petitioner argues that this term is a means-plus-function limitation to
`be construed in accordance with 35 U.S.C. § 112, ¶ 6. Pet. 9. Petitioner
`argues that the corresponding structure disclosed in the ’987 patent is a
`desktop browser, TCP/IP services, peripheral communications hardware and
`software configured to implement at least one of the Universal Serial Bus
`(“USB”), Institute of Electrical and Electronics Engineers (“IEEE”) 1394, or
`IEEE 802.11 protocols, and a device driver for the peripheral
`communications hardware. Id. at 9–10 (citing Ex. 1201, col. 3, ll. 54–57,
`col. 7, ll. 9–18, col. 8, l. 60–col. 9, l. 12, col. 9, ll. 59–67, col. 10, ll. 34–37,
`Figs. 1, 3A–3D). On this record, we agree with Petitioner. Thus, for
`purposes of this decision, we determine that the recited function is “relaying
`the downloaded user information, at the control of said user, to a peripheral
`device,” and the corresponding structure is “a desktop browser, TCP/IP
`services, peripheral communications hardware and software configured to
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`implement at least one of the USB, IEEE 1394, or IEEE 802.11 protocols,
`and a device driver for the peripheral communications hardware, and
`equivalent structures.”
`means for operating said peripheral device from said
`4.
`wireless device
`Petitioner argues that this term is a means-plus-function limitation to
`be construed in accordance with 35 U.S.C. § 112, ¶ 6. Pet. 10. Petitioner
`argues that the corresponding structure disclosed in the ’987 patent is: 1) a
`keypad, a keyboard, or a mouse connected to a wireless device; or 2) TCP/IP
`services, peripheral communications hardware and software configured to
`implement at least one of the USB, IEEE 1394, or IEEE 802.11 protocols,
`and a device driver for the peripheral communications hardware. Id. at 10–
`11 (citing Ex. 1201, col. 3, ll. 54–57, col. 6, ll. 31–33, col. 7, ll. 9–18, col. 8,
`l. 60–col. 9, l. 12, col. 9, ll. 59–67, col. 10, ll. 34–37, col. 11, ll. 59–60, col.
`13, ll. 58–62, Figs. 1, 3A–3D). On this record, we agree with Petitioner.
`Thus, for purposes of this decision, we determine that the recited function is
`“operating said peripheral device from said wireless device,” and the
`corresponding structure is: “1) a keypad, a keyboard, or a mouse connected
`to a wireless device, and equivalent structures; or 2) TCP/IP services,
`peripheral communications hardware and software configured to implement
`at least one of the USB, IEEE 1394, or IEEE 802.11 protocols, and a device
`driver for the peripheral communications hardware, and equivalent
`structures.”
`B.
`
`Asserted Grounds of Unpatentability
`Obviousness of Claims 6–9 Over Soin and Wang
`1.
`Petitioner argues that claims 6–9 would have been obvious over Soin
`and Wang. Pet. 3. We have reviewed Petitioner’s assertions and supporting
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`evidence. For the reasons discussed below, we determine that Petitioner
`demonstrates a reasonable likelihood of prevailing in showing that claims 6–
`9 would have been obvious over Soin and Wang.
`
`Claim 7 recites “for each user accessing a wireless device, a means for
`connecting a user of said wireless device to user information stored for the
`respective wireless device on a server in a communications network.” Ex.
`1201, col. 16, ll. 5–8. As discussed above, for purposes of this decision, we
`determine that the corresponding structure for this means-plus-function
`limitation is a digital baseband and TCP/IP services, and equivalent
`structures. See supra Section II.A.1. Petitioner identifies evidence
`indicating that Soin teaches a modem (i.e., a digital baseband) and TCP/IP
`connections for connecting a user of a wireless computing device to
`information stored on a server in a communications network. Pet. 22–24
`(citing Ex. 1204 ¶¶ 39, 42, 44–45, 56; Ex. 1210 ¶¶ 61–64). On this record,
`Petitioner has shown sufficiently that the combination of Soin and Wang
`teaches the above limitation of claim 7.
`Claim 7 recites “means for downloading said user information to said
`wireless device.” Ex. 1201, col. 16, ll. 9–10. As discussed above, for
`purposes of this decision, we determine that the corresponding structure for
`this means-plus-function limitation is a digital baseband, TCP/IP services,
`and a desktop browser, and equivalent structures. See supra Section II.A.2.
`Petitioner identifies evidence indicating that Soin teaches a modem (i.e., a
`digital baseband), TCP/IP connections, and a web browser for downloading
`user information to the wireless computing device. Pet. 22–24 (citing
`Ex. 1204 ¶¶ 39, 42, 44–45, 56; Ex. 1210 ¶¶ 61–64); Pet. 24–25 (citing
`Ex. 1204 ¶¶ 44, 68–69; Ex. 1210 ¶¶ 65–66). On this record, Petitioner has
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`shown sufficiently that the combination of Soin and Wang teaches the above
`limitation of claim 7.
`Claim 7 recites “means for relaying the downloaded user information,
`at the control of said user, to a peripheral device.” Ex. 1201, col. 16, ll. 11–
`12. As discussed above, for purposes of this decision, we determine that the
`corresponding structure for this means-plus-function limitation is a desktop
`browser, TCP/IP services, peripheral communications hardware and
`software configured to implement at least one of the USB, IEEE 1394, or
`IEEE 802.11 protocols, and a device driver for the peripheral
`communications hardware, and equivalent structures. See supra
`Section II.A.3. As discussed above, Petitioner identifies evidence indicating
`that Soin teaches that a modem (i.e., a digital baseband), TCP/IP
`connections, and a web browser for downloading user information to the
`wireless computing device. Pet. 22–24 (citing Ex. 1204 ¶¶ 39, 42, 44–45,
`56; Ex. 1210 ¶¶ 61–64); Pet. 24–25 (citing Ex. 1204 ¶¶ 44, 68–69; Ex. 1210
`¶¶ 65–66). Petitioner also identifies evidence indicating that Soin teaches
`hardware and software, including a device driver, that implements the IEEE
`802.11 protocol for transmitting the downloaded information to a peripheral
`device, such as a projector. Pet. 25–26 (citing Ex. 1204 ¶¶ 24, 99; Ex. 1210
`¶¶ 69–70). On this record, Petitioner has shown sufficiently that the
`combination of Soin and Wang teaches the above limitation of claim 7.
`Claim 7 recites “means for operating said peripheral device from said
`wireless device.” Ex. 1201, col. 16, ll. 13–14. As discussed above, for
`purposes of this decision, we determine that the corresponding structure for
`this means-plus-function limitation is: 1) a keypad, a keyboard, or a mouse
`connected to a wireless device, and equivalent structures; or 2) TCP/IP
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`services, peripheral communications hardware and software configured to
`implement at least one of the USB, IEEE 1394, or IEEE 802.11 protocols,
`and a device driver for the peripheral communications hardware, and
`equivalent structures. See supra Section II.A.4. Petitioner identifies
`evidence indicating that Soin teaches a keyboard and a point device for
`operating the peripheral device from the wireless computing device.
`Pet. 26–27 (citing Ex. 1204 ¶ 54, 65, 102–104, 158; Ex. 1210 ¶¶ 71–73). On
`this record, Petitioner has shown sufficiently that the combination of Soin
`and Wang teaches the above limitation of claim 7.
`Claim 7 recites “wherein said peripheral device comprises a hub,
`whereby a plurality of components connected to said peripheral device are
`accessible therethrough.” Ex. 1201, col. 16, ll. 16–18. Petitioner identifies
`evidence indicating that Wang teaches a hub device, through which a
`plurality of components of the peripheral device can be accessed. Pet. 27–
`28 (citing Ex. 1205 ¶¶ 32, 34, 42, 44). Petitioner also identifies evidence
`indicating that it would have been obvious to use the hub device in Wang
`with the wireless computing device in Soin in order to provide the user with
`additional flexibility. Pet. 12–13 (citing Ex. 1205 ¶ 51; Ex. 1208 ¶¶ 120–
`122); Pet. 28–29 (citing Ex. 1208 ¶¶ 188–189). On this record, Petitioner
`has shown sufficiently that the combination of Soin and Wang teaches the
`above limitation of claim 7.
`Claim 7 recites “wherein each user accesses a respective peripheral
`device, said respective peripheral devices being selected from the group
`consisting of: a desktop monitor keyboard and mouse, a laptop computer, a
`laptop computer terminal device, a tablet computer, a tablet computer
`terminal device, a high-definition monitor and speaker system, and
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`combinations thereof.” Ex. 1201, col. 16, ll. 19–25. Petitioner identifies
`evidence indicating that the peripheral device in Soin can be a laptop, a
`projector, or a high definition television. Pet. 29–30 (citing Ex. 1204 ¶¶ 26,
`28, 58, 104). On this record, Petitioner has shown sufficiently that the
`combination of Soin and Wang teaches the above limitation of claim 7.
`Claim 7 recites “wherein respective peripheral devices are used to
`access and operate software available on the wireless device or over the
`Internet.” Ex. 1201, col. 16, ll. 26–28. Petitioner identifies evidence
`indicating that, in Soin, the peripheral device can operate software available
`on the wireless computing device. Pet. 30–31 (citing Ex. 1204 ¶¶ 44, 54,
`68–69; Ex. 1208 ¶¶ 152–155; Ex. 1210 ¶ 78). On this record, Petitioner has
`shown sufficiently that the combination of Soin and Wang teaches the above
`limitation of claim 7.
`
`In sum, on this record, Petitioner has shown sufficiently that the
`combination of Soin and Wang teaches the limitations in claim 7. Petitioner
`also identifies evidence indicating that the combination of Soin and Wang
`teaches the limitations in claims 6, 8, and 9. See Pet. 13–21, 31–34.
`Therefore, on this record, Petitioner has shown sufficiently that the
`combination of Soin and Wang teaches the limitations in claims 6, 8, and 9.
`For the foregoing reasons, we determine that Petitioner demonstrates a
`reasonable likelihood of prevailing in showing that claims 6–9 would have
`been obvious over Soin and Wang.
`Obviousness of Claim 6 Over Tee and Acharya
`2.
`Petitioner argues that claim 6 would have been obvious over Tee and
`Acharya. Pet. 3. We have reviewed Petitioner’s assertions and supporting
`evidence. For the reasons discussed below, we determine that Petitioner
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`demonstrates a reasonable likelihood of prevailing in showing that claim 6
`would have been obvious over Tee and Acharya.
`
`Claim 6 recites “downloading, by a user on a wireless device in a
`communications network from a server in said communications network,
`user information to said wireless device.” Ex. 1201, col. 15, ll. 51–53.
`Petitioner identifies evidence indicating that Tee teaches that a user of a
`mobile terminal can download video data from a server over an IP network.
`Pet. 37 (citing Ex. 1202 ¶¶ 15, 18, 19, 22; Ex. 1208 ¶¶ 58–59). On this
`record, Petitioner has shown sufficiently that the combination of Tee and
`Acharya teaches the above limitation of claim 6.
`Claim 6 recites “receiving said user information in a manner that
`uniquely associates the user information with one or more peripheral devices
`and uniquely associates each peripheral device with one or more users.”
`Ex. 1201, col. 15, ll. 54–57. Petitioner identifies evidence indicating that
`Acharya teaches that a user of a wireless device can select one or more
`peripheral devices, and Tee teaches that a mobile terminal can transmit
`information to selected peripheral devices. Pet. 37–39 (citing Ex. 1202 ¶ 98;
`Ex. 1203 ¶ 54; Ex. 1208 ¶¶ 199–201; Ex. 1210 ¶¶ 36–38). Petitioner also
`identifies evidence indicating that it would have been obvious to use the
`selection mechanism in Acharya with the mobile terminal in Tee in order to
`allow users “to more easily choose from among many available external
`display devices.” Pet. 38 (citing Ex. 1208 ¶¶ 217–219). On this record,
`Petitioner has shown sufficiently that the combination of Tee and Acharya
`teaches the above limitation of claim 6.
`Claim 6 recites “transmitting, under control of each user accessing
`said wireless device, the downloaded user information from said wireless
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`device to a peripheral device.” Ex. 1201, col. 15, ll. 58–60. Petitioner
`identifies evidence indicating that, in Tee, the user of the mobile terminal
`can transmit downloaded information to a peripheral device, such as a
`computer or a projector. Pet. 39–40 (citing Ex. 1202 ¶¶ 16, 23). On this
`record, Petitioner has shown sufficiently that the combination of Tee and
`Acharya teaches the above limitation of claim 6.
`Claim 6 recites “wherein said peripheral device, controlled by said
`user from said wireless device, is connected to a separate system.” Ex.
`1201, col. 15, ll. 61–63. Petitioner identifies evidence indicating that, in
`Tee, the peripheral device may be the dashboard display of a car, which is
`connected to a separate automotive system. Pet. 40 (citing Ex. 1202 ¶ 15;
`Ex. 1208 ¶¶ 64–66). On this record, Petitioner has shown sufficiently that
`the combination of Tee and Acharya teaches the above limitation of claim 6.
`Claim 6 recites “wherein said peripheral device includes a display
`screen and at least one input peripheral device, thereby enabling interactive
`and real time communications between peripheral devices and the server.”
`Ex. 1201, col. 15, ll. 64–67. Petitioner identifies evidence indicating that, in
`Tee, the peripheral device includes an external display and keyboard.
`Pet. 41 (citing Ex. 1202 ¶¶ 15, 24; Ex. 1208 ¶¶ 67–68). Petitioner also
`identifies evidence indicating that Tee teaches an interface that enables
`communications between the server, the mobile terminal, and the external
`display and keyboard. Pet. 41–42 (citing Ex. 1202 ¶¶ 18, 24; Ex. 1208
`¶ 69). On this record, Petitioner has shown sufficiently that the combination
`of Tee and Acharya teaches the above limitation of claim 6.
`
`Claim 6 recites “wherein two users interconnect to said peripheral
`device, said two users controlling said user information.” Ex. 1201, col. 16,
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`ll. 1–2. Petitioner identifies evidence indicating that, in Acharya, one user
`can transfer control of the peripheral device to a second user. Pet. 42–43
`(citing Ex. 1203 ¶¶ 56, 94–95). Petitioner identifies evidence indicating that
`Acharya also teaches that two users can modify a presentation on the
`peripheral device simultaneously, such as by making edits or annotations to
`another user’s presentation. Pet. 42–43 (citing Ex. 1203 ¶¶ 94–95).
`Petitioner additionally identifies evidence indicating that it would have been
`obvious to use the multi-user feature in Acharya with the mobile terminal in
`Tee in order “to handle common user scenarios,” such as “a conference
`room meeting with many users taking the podium in sequence.” Ex. 1208
`¶ 90. On this record, Petitioner has shown sufficiently that the combination
`of Tee and Acharya teaches the above limitation of claim 6.
`In sum, on this record, Petitioner has shown sufficiently that the
`combination of Tee and Acharya teaches the limitations in claim 6. For the
`foregoing reasons, we determine that Petitioner demonstrates a reasonable
`likelihood of prevailing in showing that claim 6 would have been obvious
`over Tee and Acharya.
`Obviousness of Claims 7–9 Over Tee, Acharya, and
`3.
`Benco
`Petitioner argues that claims 7–9 would have been obvious over Tee,
`Acharya, and Benco. Pet. 3. We have reviewed Petitioner’s assertions and
`supporting evidence. For the reasons discussed below, we determine that
`Petitioner demonstrates a reasonable likelihood of prevailing in showing that
`claims 7–9 would have been obvious over Tee, Acharya, and Benco.
`Claim 7 recites “for each user accessing a wireless device, a means for
`connecting a user of said wireless device to user information stored for the
`respective wireless device on a server in a communications network.”
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`Ex. 1201, col. 16, ll. 5–8. As discussed above, for purposes of this decision,
`we determine that the corresponding structure for this means-plus-function
`limitation is a digital baseband and TCP/IP services, and equivalent
`structures. See supra Section II.A.1. Petitioner identifies evidence
`indicating that Tee teaches a transceiver (i.e., a digital baseband) and IP
`network for connecting a mobile terminal to information stored on a server.
`Pet. 46–49 (citing Ex. 1202 ¶¶ 4, 18, 20, 22, 25, 27; Ex. 1210 ¶¶ 41–43). On
`this record, Petitioner has shown sufficiently that the combination of Tee,
`Acharya, and Benco teaches the above limitation of claim 7.
`Claim 7 recites “means for downloading said user information to said
`wireless device.” Ex. 1201, col. 16, ll. 9–10. As discussed above, for
`purposes of this decision, we determine that the corresponding structure for
`this means-plus-function limitation is a digital baseband, TCP/IP services,
`and a desktop browser, and equivalent structures. See supra Section II.A.2.
`Petitioner identifies evidence indicating that Tee teaches a transceiver (i.e., a
`digital baseband), IP network, and a web browser for downloading user
`information to the mobile terminal. Pet. 46–49 (citing Ex. 1202 ¶¶ 4, 18, 20,
`22, 25, 27; Ex. 1210 ¶¶ 41–43); Pet. 49–50 (citing Ex. 1202 ¶¶ 4, 18;
`Ex. 1210 ¶¶ 44–45). On this record, Petitioner has shown sufficiently that
`the combination of Tee, Acharya, and Benco teaches the above limitation of
`claim 7.
`Claim 7 recites “means for relaying the downloaded user information,
`at the control of said user, to a peripheral device.” Ex. 1201, col. 16, ll. 11–
`12. As discussed above, for purposes of this decision, we determine that the
`corresponding structure for this means-plus-function limitation is a desktop
`browser, TCP/IP services, peripheral communications hardware and
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`software configured to implement at least one of the USB, IEEE 1394, or
`IEEE 802.11 protocols, and a device driver for the peripheral
`communications hardware, and equivalent structures. See supra Section
`II.A.3. As discussed above, Petitioner identifies evidence indicating that
`Tee teaches that a transceiver (i.e., a digital baseband), IP network, and a
`web browser for downloading user information to the mobile terminal. Pet.
`46–49 (citing Ex. 1202 ¶¶ 4, 18, 20, 22, 25, 27; Ex. 1210 ¶¶ 41–43); Pet. 49–
`50 (citing Ex. 1202 ¶¶ 4, 18; Ex. 1210 ¶¶ 44–45). Petitioner also identifies
`evidence indicating that Tee teaches hardware and software that implements
`the IEEE 802.11 protocol for transmitting the downloaded information to a
`peripheral device. Pet. 50–52 (citing Ex. 1202 ¶¶ 21–22, 27; Ex. 1210
`¶¶ 46–49). Petitioner additionally identifies evidence indicating that a
`person of ordinary skill in the art would have known that the hardware and
`software that implements the IEEE 802.11 protocol in Tee can include the
`IEEE 802.11 driver in Acharya. Pet. 51 (citing Ex. 1203 ¶ 105; Ex. 1210
`¶¶ 48–49). On this record, Petitioner has shown sufficiently that the
`combination of Tee, Acharya, and Benco teaches the above limitation of
`claim 7.
`Claim 7 recites “means for operating said peripheral device from said
`wireless device.” Ex. 1201, col. 16, ll. 13–14. As discussed above, for
`purposes of this decision, we determine that the corresponding structure for
`this means-plus-function limitation is: 1) a keypad, a keyboard, or a mouse
`connected to a wireless device, and equivalent structures; or 2) TCP/IP
`services, peripheral communications hardware and software configured to
`implement at least one of the USB, IEEE 1394, or IEEE 802.11 protocols,
`and a device driver for the peripheral communications hardware, and
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`equivalent structures. See supra Section II.A.4. Petitioner identifies
`evidence indicating that Tee teaches a keypad for operating the peripheral
`device from the mobile terminal. Pet. 52 (citing Ex. 1202 ¶¶ 25–26). On
`this record, Petitioner has shown sufficiently that the combination of Tee,
`Acharya, and Benco teaches the above limitation of claim 7.
`Claim 7 recites “wherein said peripheral device comprises a hub,
`whereby a plurality of components connected to said peripheral device are
`accessible therethrough.” Ex. 1201, col. 16, ll. 16–18. Petitioner identifies
`evidence indicating that Benco teaches a peripheral hub that connects a
`wireless device to a plurality of peripheral devices, such as a monitor, a
`printer, a keyboard, and a mouse. Pet. 52–53 (citing Ex. 1206 ¶¶ 19–20).
`Petitioner also identifies evidence indicating that it would have been obvious
`to use the peripheral hub in Benco with the mobile terminal in Tee in order
`to allow “users to connect to a wider variety of peripheral devices.” Pet. 46
`(citing Ex. 1208 ¶¶ 55–56, 71, 73–74). On this record, Petitioner has shown
`sufficiently that the combination of Tee, Acharya, and Benco teaches the
`above limitation of claim 7.
`Claim 7 recites “wherein each user accesses a respective peripheral
`device, said respective peripheral devices being selected from the group
`consisting of: a desktop monitor keyboard and mouse, a laptop computer, a
`laptop computer terminal device, a tablet computer, a tablet computer
`terminal device, a high-definition monitor and speaker system, and
`combinations thereof.” Ex. 1201, col. 16, ll. 19–25. Petitioner identifies
`evidence indicating that the peripheral device in Tee can be a television, a
`computer monitor, a keyboard, a laptop, or a personal computer. Pet. 53–54
`(citing Ex. 1202 ¶¶ 15, 21). On this record, Petitioner has shown sufficiently
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`that the combination of Tee, Acharya, and Benco teaches the above
`limitation of claim 7.
`Claim 7 recites “wherein respective peripheral devices are used to
`access and operate software available on the wireless device or over the
`Internet.” Ex. 1201, col. 16, ll. 26–28. Petitioner identifies evidence
`indicating that Tee teaches that the peripheral devices can operate software
`available on the mobile terminal. Pet. 54–55 (citing Ex. 1202 ¶¶ 18, 22, 24;
`Ex. 1210 ¶¶ 53–55). On this record, Petitioner has shown sufficiently that
`the combination of Tee, Acharya, and Benco teaches the above limitation of
`claim 7.
`
`In sum, on this record, Petitioner has shown sufficiently that the
`combination of Tee, Acharya, and