`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`
`GLOBAL TEL*LINK CORPORATION
`Petitioner
`
`v.
`
`SECURUS TECHNOLOGIES, INC.
`Patent Owner
`
`_____________________
`
`Case: IPR2016-01220
`Patent: 9,007,420
`_____________________
`
`
`
`
`PETITIONER’S OPPOSITION TO
`PATENT OWNER’S MOTION
`TO EXCLUDE
`
`
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`TABLE OF CONTENTS
`
`Case IPR2016-01220
`Patent 9,007,420
`
`Introduction ...................................................................................................... 1
`
`Exhibit 1021 is relevant in compliance with Fed. R. Evid. 401. ..................... 2
`
`
`
`I.
`
`II.
`
`III. Exhibit 1021’s probative value is not substantially outweighed by
`undue prejudice, confusion, or as a waste of time as specified in Fed.
`R. Evid. 403. .................................................................................................... 6
`
`IV. Exhibit 1021 is authentic, having contents and distinctive
`characteristics that authenticate it under Rule 901(b)(4)................................. 6
`
`V.
`
`Exhibit 1021 is not hearsay under Fed. R. Evid. 801 and 802. ....................... 9
`
`VI. Exhibit 2010 is procedurally improper at this time and should be
`expunged. .......................................................................................................11
`
`VII. Conclusion .....................................................................................................13
`
`
`
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`- i -
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`
`
`I.
`
`Introduction
`
`
`
`Case IPR2016-01220
`Patent 9,007,420
`
`In its Patent Owner Response, Securus argued that “term ‘actual face’
`
`should be construed as referring to the user’s physical face and not a facsimile of a
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`face such as a photograph.” (POR, 11.) Based on this construction, Securus argued
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`that the ’420 patent recites distinguishing a “face” from an “actual face” to prevent
`
`“circumvention attempts … known as ‘spoofing.’” (Id., 30.) In contrast, GTL’s
`
`expert Dr. Beigi had stated that, in the context of the ’420 patent the word “actual”
`
`in the phrase “actual face” distinguishes between “[a] face and something of its
`
`like.” (Ex. 2006, 120:23.) In support of its proposed construction of “actual face,”
`
`Securus cited to a dictionary definition of the word “actual,” arguing it to be
`
`probative of the term’s plain meaning, and to testimony from its expert Dr.
`
`Kakadiaris, who opined on what one of skill in the art would have thought the
`
`phrase “actual face” meant. (POR, 11-17.)
`
`During cross-examination, Dr. Kakadiaris identified on his CV a citation to a
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`document that relates to face recognition. (Ex. 1022, 27:5-6.) The document
`
`described an “actual geometry of the face” (Ex. 1021, 260), yet Dr. Kakadiaris
`
`admitted at deposition that the document did not relate to anti-spoofing. (Ex. 1022,
`
`20:1-5) GTL submitted a copy of the document with its Reply as Exhibit 1021 on
`
`June 22, 2017. Securus did not request a sur-reply or seek permission to submit
`
`additional evidence.
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`- 1 -
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`Case IPR2016-01220
`Patent 9,007,420
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`On July 15, 2017, Securus submitted a Motion to Exclude GTL’s Exhibit
`
`1021 (Paper 23), which referenced a supplemental declaration from Dr. Kakadiaris
`
`(Exhibit 2010). Securus argued that Exhibit 1021 should be excluded for failing to
`
`comply with Fed. R. Evid. 401, 403, 901 and 802. As set forth below, each of
`
`Securus’s contentions fails, and Dr. Kakadiaris’s supplemental declaration (Ex.
`
`2010) should not be considered and should be expunged as unauthorized and
`
`untimely.1
`
`II. Exhibit 1021 is relevant in compliance with Fed. R. Evid. 401.
`Fed. R. Evid. 401 states: “Evidence is relevant if: (a) it has any tendency to
`
`make a fact more or less probable than it would be without the evidence; and (b)
`
`the fact is of consequence in determining the action.” Fed. R. Evid. 401. Securus
`
`argues that Exhibit 1021, which Securus acknowledges uses the word “actual” in
`
`connection to face recognition, is irrelevant. (Paper 23, 2, 5.) In particular, Securus
`
`argues that the word “actual” is irrelevant to the question of how a person skilled in
`
`the art would understand the term “actual face” in the ’420 patent. (Id., 2-7.)
`
`Securus’s arguments fail because Exhibit 1021 is illustrative of how a skilled
`
`artisan would understand the word “actual” in the art of face recognition. Dr.
`
`Kakadiaris’s self-serving allegations in his supplemental declaration that Exhibit
`
`1 As set forth in an email to the Board dated July 17, 2017, GTL is also
`
`seeking leave to make a motion to expunge Exhibit 2010.
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`- 2 -
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`Case IPR2016-01220
`Patent 9,007,420
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`1021 is in a materially different context from the ’420 patent should not be
`
`credited. But even if accepted as true, that would only go to the document’s weight
`
`and not its admissibility.
`
`In its Motion, Securus acknowledges that Dr. Kakadiaris has admitted that a
`
`document citing Exhibit 1021 “related to the broad topic of facial recognition.”
`
`(Paper 23, 5.) Dr. Beigi opines that a skilled artisan is merely someone with “a BS
`
`degree in computer science or equivalent field, as well as at least 2 to 3 years of
`
`academic or industry experience in software development, or comparable industry
`
`experience.” (Ex. 1006, ¶ 23.) And Dr. Kakadiaris admits that a skilled artisan
`
`would have “knowledge of available facial detection and facial recognition
`
`technologies in the market.” (Ex. 2004, ¶ 66.) Exhibit 1021 is relevant because it
`
`shows the vernacular used by those skilled artisans in connection with face
`
`recognition technology, in particular demonstrating usage of the word “actual.”
`
`Securus and Dr. Kakadiaris acknowledge that Exhibit 1021 does not use the word
`
`“actual” to refer to “a real, physical face, as opposed to a photograph or other
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`facsimile of a person’s face.” (Paper 23, 4.) Instead, Securus states that Exhibit
`
`1021 uses the word “actual” merely to “refer to the existence of geometric
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`information about face.” (Id., 4.) Thus, by Securus’s own admission the authors of
`
`Exhibit 1021 use the word “actual” in a manner consistent with how Dr. Beigi
`
`asserts the term should be read in the ’420 patent and inconsistent with how Dr.
`
`- 3 -
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`Case IPR2016-01220
`Patent 9,007,420
`
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`Kakadiaris asserts that the term should be read in the ’420 patent. Hence, Exhibit
`
`1021 makes Dr. Beigi’s opinion of how a skilled artisan would have read the ’420
`
`patent more probable and makes Dr. Kakadiaris’s opinion less probable. Therefore,
`
`Exhibit 1021 is relevant to the meaning of “actual.”
`
`Even aside from the substantive issue of claim construction, Exhibit 1021 is
`
`also relevant for impeachment of Dr. Kakadiaris. Dr. Kakadiaris was one of the
`
`authors of Exhibit 1021. In Exhibit 1021, he used the word “actual” in the admitted
`
`context of face recognition in a manner that is inconsistent with how he is now
`
`reading the word when interpreting the ’420 patent in his declaration. That
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`inconsistency is relevant as to Dr. Kakadiaris’s credibility.
`
`In its Motion, Securus strains to differentiate between the phrase used in
`
`Exhibit 1021—“actual geometry of the face”—and the phrase used in the ’420
`
`patent—“actual face.” (Paper 23, 4.) The ’420 patent describes and claims
`
`“verify[ing] that an actual face was present in the image.” (Ex. 1001, 11:10-11 (“to
`
`verify that an actual face was present in the image”); see also 11:49-50, FIG. 4,
`
`Abstract, 1:45-48, 1:54-59, 8:66-9:2.) A face, physical or otherwise, cannot be
`
`“present” in the image in the same way that a face can be present in a mask. What
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`the ’420 patent is saying when it describes “verify[ing] that an actual face was
`
`present in the image” is verifying whether the image includes the likeness, or
`
`geometry, of the face. (See Ex. 2006, ¶¶ 87-96.) There is no genuine difference
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`- 4 -
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`
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`between usage of “actual” in the ’420 patent and in Exhibit 1021.
`
`Case IPR2016-01220
`Patent 9,007,420
`
`Indeed, Securus itself cited a lay dictionary definition of “actual” in support
`
`of its proposed construction. (Ex. 2005.) If “actual” in the phrase “actual face” as
`
`used in the ’420 patent was so divorced from its ordinary meaning in other
`
`contexts, Securus’s definition would have no relevance.
`
`Securus also cites an unpublished, nonprecedential decision from the Federal
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`Circuit: In re NuVasive, --- F. Appx. ---, 2017 WL 2365257. (Paper 23, 6.) That
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`case did not deal with admissibility of evidence. Instead, that case dealt with
`
`whether the Board correctly relied on a statement of an expert made at deposition
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`in determining its claim construction. Id. The Federal Circuit found that the Board
`
`was unreasonable in adopting the expert’s statement that “lateral would be
`
`anything that’s basically lateral to an anterior puncture” given that the expert had
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`prefaced his statement as to the meaning of “lateral” by stating that that meaning is
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`specific to a particular context different from the patent at issue. Id. Here, in
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`contrast to NuVasive, GTL is not asking the Board to rely on and adopt any
`
`statements from Dr. Kakadiaris for the meaning of “actual face.” GTL’s
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`construction is supported by its own expert Dr. Beigi. Instead, with Exhibit 1021,
`
`GTL only illustrates the way the word “actual” is used in face recognition and has
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`been used by Dr. Kakadiaris himself in a paper relating to face recognition, which
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`provides further corroborating support for Dr. Beigi’s position. Indeed, neither
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`- 5 -
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`Case IPR2016-01220
`Patent 9,007,420
`
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`Securus nor Dr. Kakadiaris has provided a single paper where the word “actual” is
`
`used to impart the meaning of “actual face” that Securus advances.
`
`For these reasons, Exhibit 1021 is relevant in compliance with Fed. R. Evid.
`
`401.
`
`III. Exhibit 1021’s probative value is not substantially outweighed by undue
`prejudice, confusion, or as a waste of time as specified in Fed. R. Evid.
`403.
`
`In a one-paragraph argument, Securus claims that “[e]ven if the Board
`
`determines that Exhibit 1021… has some minimal relevance…, it should still
`
`exclude Exhibit 1021 under Federal Rule of Evidence 403 because any probative
`
`value of Exhibit 1021 is substantially outweighed by the danger of unfair
`
`prejudice, confusing the issues, undue delay, and wasting time.” (Paper 23, 5-6.)
`
`As to unfair prejudice and confusion, the Board, as an expert tribunal, is fully
`
`capable of weighing Exhibit 1021 appropriately. As to undue delay and wasting
`
`time, Securus has provided no evidence or explanation that admission of Exhibit
`
`1021 will materially affect the timeframe of this proceeding or of the oral
`
`argument, nor could they. Therefore, Exhibit 1021 should not be excluded under
`
`Fed. R. Evid. 403.
`
`IV. Exhibit 1021 is authentic, having contents and distinctive characteristics
`that authenticate it under Rule 901(b)(4).
`
`Fed. R. Evid. 901 requires that a “proponent . . . produce evidence sufficient
`
`to support a finding that [an] item is what the proponent claims it is.” Fed. R. Evid.
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`- 6 -
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`Case IPR2016-01220
`Patent 9,007,420
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`901(a). GTL does not use the challenged exhibit as prior art or for the truth of its
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`contents. (See Paper 23, 2 (Securus conceded that GTL did not offer them as
`
`printed publications).) Instead, GTL only uses Exhibit 1021 to illustrate the way in
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`which those in the art understood the word “actual” in the context of face
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`recognition. Thus, all Exhibit 1021 purports to be under Fed. R. Evid. 901 is a
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`document written by or for those of skill in the art. To comply with Fed. R. Evid.
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`901, all that is needed is evidence sufficient to support a finding that it is just that.
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`Securus cites to no PTAB case, and the undersigned are aware of none, where
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`documents used for this purpose were excluded under Fed. R. Evid. 901.
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`To authenticate evidence, extrinsic evidence is not always necessary. See
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`Fed. R. Evid. 902. For example, Securus provides no extrinsic evidence supporting
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`the authenticity of its Exhibits 2001, 2005, and 2009. A party may authenticate
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`evidence using “the appearance, contents, substance, internal patterns, or other
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`distinctive characteristics of the item, taken together with all the circumstances.”
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`Fed. R. Evid. 901(b)(4). The distinctive characteristics can include labels
`
`indicating the item’s source, which are themselves self-authenticating. See Fed. R.
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`Evid. 902(7). In particular, Fed. R. Evid. 902(7) states that no extrinsic evidence is
`
`required to authenticate “[a]n inscription, sign, tag, or label purporting to have
`
`been affixed in the course of business and indicating origin, ownership, or control.”
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`Id. The Board applied these rules, for example, in EMC Corp. v. PersonalWeb
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`- 7 -
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`Case IPR2016-01220
`Patent 9,007,420
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`Technologies, LLC, finding that labels identifying Usenet, LexisNexis, and a free
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`software database called Simtel authenticated documents from those respective
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`databases. IPR2013-00084, Paper 64, 50-51; see also Alexander v. CareSource,
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`576 F.3d 551, 561 (6th Cir. 2009) (finding document printed on company
`
`letterhead to be self-authenticating under Fed. R. Evid. 902(7) because letterhead
`
`indicated company’s ownership and control).
`
`Here, Securus incorrectly claims: “Petitioner has not attempted to produce
`
`any evidence showing that Exhibit 1021 is what Petitioner claims.” (Paper 23, 7.)
`
`With this statement, Securus completely ignores the document’s intrinsic
`
`characteristics. Exhibit 1021 has contents and other intrinsic characteristics
`
`showing that it is what it purports to be: a document written by or for those of skill
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`in the art. In particular, the document’s intrinsic characteristics show that it is a
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`book chapter referenced in Dr. Kakadiaris’s CV and co-authored by Dr.
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`Kakadiaris. The citation from Dr. Kakdiaris’s CV is excerpted below:
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`
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`(Ex. 2004, 92.)
`
`This citation identifies the chapter as being part of a volume entitled
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`Multibiometrics for Human Identification edited by B. Bhanu and V. Govindaraju
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`and published by Cambridge University Press. The chapter
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`is entitled
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`“Bidirectional relighting for 3D-aided 2D face recognition” and is on pages 258-
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`- 8 -
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`274.
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`Case IPR2016-01220
`Patent 9,007,420
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`Intrinsic characteristics of Exhibit 1021 match these attributes of the citation
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`and Dr. Kakadiaris’s CV. The cover and copyright pages identify the document as
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`being from a volume entitled Multibiometrics for Human Identification and edited
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`by B. Bhanu and V. Govindaraju. (Ex. 1021.) Exhibit 1021 excerpts a chapter
`
`entitled “Bidirectional relighting for 3D-aided 2D face recognition.” The copyright
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`page also shows that it was published by Cambridge University Press. (Ex. 1021.)
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`Both the table of contents and numbering at the bottom of the pages are consistent
`
`with the excerpted chapter being from pages 258-274 of the volume. All of these
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`markings represent “appearance, contents, substance, internal patterns, or other
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`distinctive characteristics of [Exhibit 1021].” Fed. R. Evid. 901(b)(4). They
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`represent more than “sufficient [evidence] to support a finding that [Exhibit 1021]
`
`is what the proponent claims it is.” Fed. R. Evid. 901(a). Hence, Exhibit 1021 is
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`authentic in compliance with Fed. R. Evid. 901.
`
`V. Exhibit 1021 is not hearsay under Fed. R. Evid. 801 and 802.
`Hearsay is an out of court statement offered “to prove the truth of the matter
`
`asserted in the statement.” Fed. R. Evid. 801(c)(2). Securus argues that Exhibit
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`1021 is hearsay and therefore should be excluded. (Paper 23, 8.) In particular,
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`Securus alleges: “because Petitioner seeks to offer Exhibit 1021 for the truth of the
`
`matter asserted — to show that it ‘describes an actual geometry of the face’ — it is
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`- 9 -
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`Case IPR2016-01220
`Patent 9,007,420
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`inadmissible hearsay.” (Id.) Securus’s argument represents a misunderstanding of
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`what it means to offer something “for the truth of the matter asserted.”
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`GTL is not offering Exhibit 1021 for the truth of what Exhibit 1021 says.
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`The complete cited passage from Exhibit 1021 is:
`
`We employ the Annotated Face Model (AFM) proposed
`by Kakadiaris et al. (2007) to generate geometry images
`(regularly sampled 2D images that have three channels)
`encoding geometric information (x, y, and z components
`of a vertex in R3). In this paper the number of channels in
`the geometry
`image
`is seven (three channels for
`representing the actual geometry of the face, three for
`representing the texture information, and one for the
`visibility map).
`
`(Exhibit 1021, 260.) GTL is not offering Exhibit 1021 to show that the
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`authors in truth “employ[ed] the Annotated Face Model (AFM) proposed by
`
`Kakadiaris et al. (2007)” or that, in the system the authors created, “the number of
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`channels in the geometry image is seven.” (Id.) Regardless of whether the paper
`
`accurately describes the work done by the authors is irrelevant to claim
`
`construction. What is relevant to claim construction, however, is the vernacular
`
`that the authors employed, because that reflects how a person of skill the art would
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`understand those terms. In particular, GTL is offering Exhibit 1021 because it
`
`“describes an actual geometry of the face” (Paper 23, 8), which shows usage of the
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`- 10 -
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`Case IPR2016-01220
`Patent 9,007,420
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`word “actual” in a manner consistent with Dr. Beigi’s interpretation and
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`inconsistent with Dr. Kakadiaris’s. Securus is incorrect in arguing that Exhibit
`
`1021 is used for the truth of the matter asserted in Exhibit 1021.
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`Moreover, even outside of the substantive issue of claim construction,
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`Exhibit 1021 is relevant for the purpose of impeachment because in Exhibit 1021
`
`Dr. Kakadiaris makes a statement that is inconsistent with his declaration. The
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`Notes for Fed. R. Evid. 801 are instructive on this point: “Rule 801 defines what is
`
`and what is not hearsay for the purpose of admitting a prior statement as
`
`substantive evidence. A prior statement of a witness at a trial or hearing which is
`
`inconsistent with his testimony is, of course, always admissible for the purpose of
`
`impeaching the witness’ credibility.” Notes of Committee on the Judiciary, Senate
`
`Report No. 93–1277.
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`For these reasons, Exhibit 1021 is not hearsay under Fed. R. Evid. 801 and
`
`802.
`
`VI. Exhibit 2010 is procedurally improper and should be expunged.
`As mentioned above, Securus submitted a declaration from Dr. Kakadiaris
`
`with its Motion to Exclude as Exhibit 2010. This is totally improper. As explained
`
`in the Office Trial Practice Guide, by the time the Motion to Exclude was filed,
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`discovery was closed. 77 Fed. Reg. 48757, 48758 (Aug. 14, 2012) (“Once the time
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`for taking discovery in the trial has ended, the parties will be authorized to file
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`- 11 -
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`Case IPR2016-01220
`Patent 9,007,420
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`motions to exclude evidence believed to be inadmissible.”). Securus did not seek
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`authorization to file a late declaration as the rules require that they must. See e.g.
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`Google Inc. v. Ji-Soo Lee, IPR2016-00022, Paper 30 (April 21, 2017); Enovate
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`Medical, LLC v. Intermetro Industries Corp., IPR2015-00300, Paper 54 (May 11,
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`2016). Finally, GTL has a right to cross examine Dr. Kakadiaris on his direct
`
`testimony, including the testimony provided in Exhibit 2010. 37 C.F.R. §
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`42.51(b)(1)(ii); 5 U.S.C. § 556(d) (APA). Because discovery is closed, the deadline
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`for Motions for Observations have passed, and oral argument is less than three
`
`weeks away, taking cross-examination on Dr. Kakadiaris’s deposition testimony is
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`impossible without unfairly prejudicing GTL. (Paper 16, 1.)
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`Dr. Kakadiaris’s supplemental declaration is NOT in support of its
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`contentions for Fed. R. Evid. 401. Rather, Dr. Kakadiaris’s self-serving
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`supplemental declaration, even if credible (which it is not), goes only to weight,
`
`not to admissibility. Securus’s contention that it needs Exhibit 2010 to support its
`
`Motion to Exclude is appears simply to be a pretext in an attempt to get late
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`evidence into the record.
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`For these reasons, the supplemental declaration of Dr. Kakadiaris (Ex. 2010)
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`should not be considered and should be expunged.
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`- 12 -
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`VII. Conclusion
`In sum, Securus’s Motion to Exclude GTL’s Exhibit 1021 lacks merit and
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`Case IPR2016-01220
`Patent 9,007,420
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`should be denied, and Exhibit 2010 accompanying Securus’s Motion to Exclude
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`should not be considered and should be expunged.
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`Date: July 21, 2017
`
`1100 New York Avenue, N.W.
`Washington, D.C.20005-3934
`(202) 371-2600
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`Respectfully Submitted,
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C
`
`/Joseph E. Mutschelknaus/
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`Michael D. Specht, Reg. No. 54,463
`Joseph E. Mutschelknaus, Reg. No. 63,285
`Attorneys for Petitioner
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`CERTIFICATE OF SERVICE
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`Case IPR2016-01220
`Patent 9,007,420
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`The undersigned certifies that a true and correct copy of the foregoing
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`PETITIONER’S OPPOPSITION TO PATENT OWNER’S MOTION TO
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`EXCLUDE was served electronically via e-mail on July 21, 2017, on the
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`following Counsel for Patent Owner:
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`Justin B. Kimble (Lead Counsel)
`Jeffrey R. Bragalone (Back-up Counsel)
`Daniel F. Olejko (Back-up Counsel)
`Terry A. Saad (Back-up Counsel)
`Nicholas c. Kliewer (Back-up Counsel)
`BRAGALONE CONROY PC
`jkimble-IPR@bcpc-law.com
`jbragalone@bcpc-law.com
`dolejko@bcpc-law.com
`tsaad@bcpc-law.com
`nkliewer@bcpc-law.com
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`Date: July 21, 2017
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`1100 New York Avenue, N.W.
`Washington, D.C.20005-3934
`(202) 371-2600
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`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C
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`/Joseph E. Mutschelknaus/
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`Michael D. Specht, Reg. No. 54,463
`Joseph E. Mutschelknaus, Reg. No. 63,285
`Attorneys for Petitioner
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`5502288_1.docx
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