Filed on behalf of:
`Google LLC
`
`Paper No. 11
`Date: March 22, 2018
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`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________
`
`
`
`GOOGLE LLC1,
`
`Petitioner,
`
`v.
`
`ALEX IS THE BEST, LLC,
`
`Patent Owner.
`
`_________________
`
`IPR2017-02058
`U.S. Patent 8,581,991
`_________________
`
`
`PETITIONER’S REQUEST FOR REHEARING
`Under 37 C.F.R. § 42.71(c) and (d)
`
`Before DANIEL N. FISHMAN, MINN CHUNG, and JESSICA C. KAISER,
`Administrative Patent Judges
`
`
`
`
`1 As indicated in the Petitioner’s updated mandatory notices, Petitioner Google Inc.
`is now Google LLC.
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`

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`U.S. Patent No. 8,581,991
`Request for Rehearing
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`I.
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`INTRODUCTION
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`
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`IPR2017-02058
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`On September 7, 2017, Petitioner Google LLC (“Google”) filed a Petition
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`requesting an inter partes review of claims 1-3, 10-14 and 21 of U.S. Patent No.
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`8,581,991 B1 (Ex. 1001, “the ‘991 patent”) on the following grounds:
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`Ground Claims Challenged Basis
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`References
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`1–3, 10–14, and 21 35 U.S.C. §103(a) Inoue and Nair2
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`1–3, 10–14, and 21 35 U.S.C. §103(a) Yamazaki and Nicholas
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`1–3, 10–14, and 21 35 U.S.C. §103(a) Yamazaki and Nair
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`10 and 11
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`35 U.S.C. §103(a) Yamazaki, Nicholas and Nair
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`1–3, 12-14, and 21 35 U.S.C. §103(a) Kusaka and Nicholas
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`10 and 11
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`35 U.S.C. §103(a) Kusaka, Nicholas and Nair
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`1
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`2
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`3
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`4
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`5
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`6
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`
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`Patent Owner Alex is the Best, LLC (“AITB”) filed a Preliminary Response
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`(Paper 7, “Prelim. Resp.”).
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`On March 9, 2018, the Board denied Google’s request to institute an inter
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`partes review of the challenged claims. The Board instituted trial as to certain
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`other challenged claims of the ‘991 patent, however, in a different Petition (the
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`
`2 For convenience, we refer to each reference by the first named inventor. “Inoue”
`refers to U.S. Patent Application Pub. No. 2004/0109066 Al (published June 10,
`2004) (Ex. 1005); “Nair” refers to U.S. Patent Application Pub. No. 2004/0127208
`Al (published July 1, 2004) (Ex. 1006); “Yamazaki” refers to U.S. Patent
`Application Pub. No. 2004/0105008 Al (published June 3, 2004) (Ex. 1007);
`“Nicholas” refers to U.S. Patent Application Pub. No. 2004/0133668 Al (published
`July 8, 2004) (Ex. 1008); and “Kusaka” refers to U.S. Patent Application Pub. No.
`2004/0109063 Al (published June 10, 2004) (Ex. 1009).
`1
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`U.S. Patent No. 8,581,991
`Request for Rehearing
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`IPR2017-02058
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`“Other ‘991 Petition”). See IPR2007-02059, Paper 8. As discussed below, the prior
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`art in the Other ‘991 Petition that was instituted overlaps with the prior art in the
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`instant ‘991 Petition. Google now respectfully requests that the Board partially
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`reconsider its decision not to institute inter partes review of the remaining
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`challenged claims of the ‘991 patent presented in the instant ‘991 Petition.
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`Specifically, Google requests that the Board reconsider Google’s challenges
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`under Grounds 1, 5, and 6. It appears that the Board may have overlooked certain
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`teachings in the Inoue prior art reference regarding the claimed “WSARC” and in
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`the Kusaka prior art reference concerning the WSARC and the claimed “account
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`associated with an Internet direct device.” The Board also may have overlooked
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`pertinent discussions by Dr. Madisetti regarding these references in the background
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`for his detailed analysis. Indeed, although the Patent Owner made several
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`arguments opposing institution of this IPR, it did not argue that either Inoue or
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`Kusaka failed to disclose a WSARC or that Kusaka failed to disclose an “account
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`associated with an Internet direct device.” See Paper 7, pp. 1-4 (outlining seven
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`arguments opposing institution).
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`This request is timely under 37 C.F.R. 42.71(d)(2) because it was filed
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`within 30 days of the Board’s decision not to institute review on the challenged
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`claims. The arguments presented in this motion were also made in the Petition,
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`2
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`U.S. Patent No. 8,581,991
`Request for Rehearing
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`IPR2017-02058
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`although we highlight certain matters in hopes of addressing what we perceive as
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`the Board’s concerns regarding the Inoue and Kusaka references.
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`II.
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`PRECISE RELIEF REQUESTED
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`
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`The Board should institute inter partes review of all challenged claims under
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`Grounds 1, 5, and 6.
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`For Ground 1, Google respectfully suggests that the Board may have
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`overlooked pertinent details in Inoue’s description of an image server that includes
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`an image display accessed via the Internet (e.g., the web). See, e.g., Ex. 1005, Figs.
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`3 & 13; Abstract, ¶¶ 18, 56, 59-60, 79-80, 80-82. The evidence from Inoue cited in
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`the Petition is responsive to the concerns raised by the Board regarding whether
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`Inoue’s “file server 100” is web-related and/or a website. See Paper 10, pp. 17-19.
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`Inoue’s teachings, as cited in Google’s Petition, disclose the claimed WSARC.
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`Petition (Paper 1), pp. 11-27. An inter partes review should be instituted for claims
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`1–3, 10–14, and 21 under Ground 1.
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`As for Grounds 5 and 6, Google respectfully suggests that Kusaka in fact
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`describes both an WSARC and the claimed account associated with the Internet
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`direct device. See, e.g., Ex. 1009, Abstract, ¶¶ 3, 219–221, 234, 236. Kusaka’s
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`web-based image server has all of the attributes and performs all of the functions
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`described in the specification of the ‘991 patent and required by independent
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`claims 1 and 13, as the examiner of a parent application for the ‘991 patent found.
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`3
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`U.S. Patent No. 8,581,991
`Request for Rehearing
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`IPR2017-02058
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`See id.; see also Petition, pp. 58-59 & Ex. 1003, p. 192. Google also respectfully
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`suggests that Kusaka’s disclosure of user identification information associated with
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`an WSARC account that is also associated with Kusaka’s digital camera is a
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`disclosure of an account at the WSARC “associated with” the camera, and is
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`responsive to the concerns described at pages 27-31 of the Decision. Google cited
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`to this relevant disclosure in Kusaka in its Petition, and Dr. Madisetti provided
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`further information regarding Kusaka in his declaration. Petition, pp. 54-67; Ex.
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`1010, ¶¶ 135-141, 497-522. An inter partes review should be instituted for claims
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`1–3, 12–14, and 21 under Ground 5 and as to claims 10 and 11 under Ground 6.
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`III. LEGAL STANDARDS
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`
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`“A party dissatisfied with a decision may file a request for rehearing,
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`without prior authorization from the Board.” 37 C.F.R. §42.71(d). “The request
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`must specifically identify all matters the party believes the Board misapprehended
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`or overlooked, and the place where each matter was previously addressed in a
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`motion, an opposition, or a reply.” Id. The Board reviews a decision for an abuse
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`of discretion. 37 C.F.R. §42.71(c).
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`The Board has granted requests for rehearing and instituted grounds that
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`were not previously instituted after determining that it did not consider a disclosure
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`in the prior art and/or evidence that was previously cited by the Petitioner. See,
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`e.g., Asustek Computer, Inc., et al. v. Avago Technologies General IP (Singapore)
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`4
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`U.S. Patent No. 8,581,991
`Request for Rehearing
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`IPR2017-02058
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`PTE. Ltd., IPR2016-00647, Paper 23 at pp. 3-5 (P.T.A.B. Mar. 8, 2017) (instituting
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`a previously uninstituted ground because the Board had overlooked a figure cited
`
`in the Petition); Boston Scientific Corp. v. UAB research Foundation, IPR2015-
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`00918, Paper 14 at p. 4 (P.T.A.B. Mar. 7, 2016) (instituting a previously
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`uninstituted ground upon determining that the patent-at-issue is not entitled to an
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`earlier priority date because the prior application did not disclose a pulse with such
`
`an energy value).
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`IV. ARGUMENT
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`A. Inoue Discloses A WSARC
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`The Board found that the Petition had not established that Inoue’s “file
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`
`
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`server 100” describes the “website archive and review center” (WSARC) required
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`by the challenged independent claims 1 and 13. Paper 10, pp. 17-20. It appears that
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`the Board’s primary concern regarding Inoue was the following:
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`In view of our discussion above, we determine that the term “website
`archive and review [center] (WSARC)” is a sufficiently significant
`limitation in the context of the ’991 patent to require Petitioner
`address the limitation in sufficient detail in the Petition in order to
`demonstrate a reasonable likelihood of prevailing with respect to the
`challenged claims in this case. However, as discussed above, neither
`Petitioner nor Dr. Madisetti explains sufficiently why Inoue’s file
`server teaches or suggests the “website archive and review [center]
`(WSARC)” recited in claims 1 and 13.
`
`Nor do we discern any express teaching of a “website archive and
`review center (WSARC)” in the portion of Inoue cited by Petitioner.
`Indeed, Petitioner does not identify, nor do we discern, any
`description of a “website” or web-related function in connection
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`
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`5
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`U.S. Patent No. 8,581,991
`Request for Rehearing
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`IPR2017-02058
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`with Inoue’s file server in the portion of Inoue relied upon by
`Petitioner.
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`Paper 10, p. 19 (emphasis added, citations omitted).
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`
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`Although the Decision referenced several of Inoue’s citations as called out in
`
`the Petition, it appears that the broader context of Inoue’s disclosure regarding the
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`file server may have been overlooked. Google respectfully directs the Board to
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`Figs. 3 and 13 of Inoue and their associated description, both of which were
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`discussed in the Petition. Petition, pp. 12-13, 16-18. Fig. 3 depicts Inoue’s digital
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`camera 10 communicating over the Internet 126 to file server 100, and a separate
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`user terminal 124 also communicating over the Internet to view images stored on
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`the file server 100. Ex. 1005, Fig. 3 & ¶ 60. Fig. 13 is a graphical depiction of a
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`display 112 accessible via the Internet to organize or retrieve images archived on
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`file server 100. Id. Fig. 13 & ¶¶ 82-83. Both Figures are re-presented below:
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`U.S. Patent No. 8,581,991
`Request for Rehearing
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`IPR2017-02058
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`These figures and their associated text describe a file server 100 that
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`archives images transmitted from a digital camera for later retrieval and review by
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`both the camera and other devices via the Internet (e.g., other digital cameras,
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`computers, etc.). Id., ¶¶ 60, 62, 82-84. Fig. 13 depicts the graphical user interface
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`used by these various devices. Id., ¶¶ 82-83; see also Petition, pp. 12-13; Ex. 1010,
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`“Madisetti Decl.”, ¶ 91. Inoue further explains that these images can be stored in
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`an account associated with the digital camera. Ex. 1005, ¶ 82 (“The area 134 [of
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`the display] shows the identification information of the digital camera 10 or the ID
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`of the user.”). Therefore, Inoue’s file server 100 performs all the functions of the
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`WSARC recited in the challenged claims. Ex. 1001, col. 8, ln. 16 - col. 9, ln. 42.
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`Google believes that these teachings in Inoue also satisfy the Board’s
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`concern that Inoue may not describe a “‘website’ or web-related function in
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`connection with Inoue’s file server.” Paper 10, p. 19. Inoue’s “file server 100” is
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`accessible to multiple remote terminals (e.g., user terminal 124) over the Internet
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`using Fig. 13’s graphical user interface. See Petition, pp. 12-21; e.g., id., p. 16
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`(“The communication control unit 72 exercises control necessary to communicate
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`with the file server….” [Ex.1005], ¶¶0056, 0060”); see also id., pp. 14, 16-18
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`(focusing on Inoue’s Internet camera but evidencing server function). Respectfully,
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`
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`7
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`U.S. Patent No. 8,581,991
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`IPR2017-02058
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`these sections describe the “web-related function” performed by Inoue’s file server
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`to transmit, receive, and display captured images over the Internet.3
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`Setting up file server 100’s user interface as a website is also disclosed by
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`Fig. 13’s user interface, which depicts a web page. In fact, as Dr. Madisetti
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`explained in the background for his opinions, a website is a common means of
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`sharing images among a variety of devices connected to the Internet. Ex. 1010, ¶¶
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`67, 70, 72-73, 82.
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`Thus, Google respectfully submits that Inoue describes the claimed WSARC
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`and that review of the evidence of record reveals a reasonable likelihood of success
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`as to the challenged claims. The WSARC appears to have been the stated basis for
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`declining to institute Ground 1, and a parallel inter partes review for other claims
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`of the ‘991 patent which omit the WSARC was instituted based on the same
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`combination of the Inoue and Nair references. See IPR2017-2059, Paper 8, pp. 19-
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`
`3 The Board may have believed that Inoue’s Fig. 13 depicted only the display on
`Inoue’s camera, not a display that could be accessed by various Internet-enabled
`devices. If that assumption was made, Google respectfully suggests that it was a
`misapprehension of Inoue’s teachings. “[D]isplay 112” is not part of Inoue’s
`description of its Internet-enabled camera (compare Fig. 1). Rather, Inoue is
`referencing any display capable of displaying images retrieved from Inoue’s file
`server over an Internet connection. This is indicated not only by the passages cited
`in the Petition [e.g., Ex. 1005, ¶¶ 60, 82-83], but also in the description of the
`“display 112” in paragraph 62. There, Inoue explains that “when the user uses the
`file management system 120 of FIG. 3, the shot images can thus be checked on the
`display 112 of FIG. 2 efficiently, not necessarily on the LCD 22 of digital camera
`10, a display of relatively small size.” Ex. 1005, ¶ 62 (emphasis added).
`8
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`U.S. Patent No. 8,581,991
`Request for Rehearing
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`IPR2017-02058
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`32 (instituting review of claims 22, 23, 25, 27-29, 32, 33 and 35-38 based on the
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`combination of Inoue and Nair). Google respectfully requests that the Board
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`reconsider its decision on Ground 1 and institute this inter partes review based on
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`Ground 1 as to challenged claims 1–3, 10–14, and 21 of the ‘991 patent.
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`B. Kusaka Discloses A WSARC And An Account On The WSARC
`Associated With An Internet Direct Device
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`The Board also did not institute review based upon Google’s proposed
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`
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`combinations of Kusaka and Nicholas in Ground 5 and Kusaka, Nicholas, and Nair
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`in Ground 6 based upon its findings that the Petition had failed to establish that
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`Kusaka disclosed (1) the claimed WSARC and (2) the claimed “account associated
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`with the Internet direct device” in the two challenged independent claims (claims 1
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`and 13). Paper 10, pp. 29-32. Google respectfully suggests that relevant disclosures
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`in Kusaka regarding both claim elements may have been overlooked.
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`1. Kusaka’s Disclosure Of A WSARC
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`In footnote 7 of the Decision, the Board indicated that the Petition had not
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`
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`sufficiently demonstrated that Kusaka disclosed a WSARC. Paper 10, p. 29, n.7.
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`Google respectfully submits that the Board appears to have overlooked certain
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`portions of Kusaka cited in its Petition as well as Dr. Madisetti’s unrebutted
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`discussion of how a skilled artisan would have understood Kusaka’s “gateway
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`server” and “image server” to operate.
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`9
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`U.S. Patent No. 8,581,991
`Request for Rehearing
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`IPR2017-02058
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`As Google noted in its Petition, the examiner of a parent application for the
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`‘991 patent expressly found that Kusaka discloses a WSARC. See Petition, p. 58
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`(citing Ex. 1003, p. 192). The examiner relied upon paragraph 220 of Kusaka,
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`which is also cited in the Petition (e.g., at p. 59). Paragraph 220 describes a
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`“gateway server 160” and “image servers 181-184” on the Internet, which operate
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`according to Internet protocols to maintain an “album” of images. Ex. 1009, ¶ 220;
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`Fig. 1. As Dr. Madisetti noted in the background for all of his opinions, Kusaka’s
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`“gateway server 160 manages image albums created on a per-user basis on
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`multiple image servers on the Internet … and stores the image data received from
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`the electronic camera 100 in an image album corresponding to the user
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`identification information on the selected image server.” Ex. 1010, ¶ 96 (quoting
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`Ex. 1009, Abstract).
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`Google respectfully submits that both the examiner and Dr. Madisetti
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`properly determined that a skilled artisan would have understood that Kusaka’s
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`description of how its “gateway server” and “image server” operated on the
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`Internet taught a web-based archive for the storage and retrieval of images, i.e., a
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`WSARC. Ex. 1003, p. 192; Ex. 1010, ¶¶ 503-504. As noted above, a website was
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`(and is) a common means of sharing images among a variety of devices connected
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`to the Internet. Ex. 1010, ¶¶ 67, 70, 72-73, 82. Indeed, in a passage not explicitly
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`cited in the Petition, “gateway server 160” is interchangeably named a “web
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`10
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`U.S. Patent No. 8,581,991
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`IPR2017-02058
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`server 160,” confirming that images stored on the image server can also be
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`accessed via the gateway server and the World Wide Web. Ex. 1009, ¶ 317
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`(emphasis added). And Patent Owner did not dispute Dr. Madisetti’s and the
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`examiner’s views that Kusaka’s IP-based image server, accessed via a gateway
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`server on the Internet, was a WSARC.
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`Moreover, and again not disputed by Patent Owner, Dr. Madisetti noted that
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`a skilled artisan would understand that “[a] WSARC is nothing more than a remote
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`server with databases to store or manage images that is accessible via the ‘Internet’
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`or a ‘communication network’ through well-known wired, wireless, cellular, or
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`other communication means.” Ex. 1010, ¶ 46. Kusaka (and Inoue as well)
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`indisputably discloses such a server. Google respectfully asks that Board find that
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`it has met the initial burden to demonstrate that Kusaka discloses a WSARC.
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`2. Kusaka Also Discloses An “Account Associated With An
`Internet Direct Device”
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`
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`The Board also disagreed with Google’s view that Kusaka disclosed the
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`additional element of an “account” on the WSARC that is “associated with an
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`Internet direct device.” Paper 10, pp. 29-31. For example, the Board stated the
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`following:
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`Furthermore, we do not discern any teaching of an account associated
`with the Internet direct device on a WSARC in the portion of Kusaka
`cited by Petitioner. As discussed above in Section III.F.1 (Overview
`of Kusaka), although Kusaka describes that the camera identification
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`11
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`U.S. Patent No. 8,581,991
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`IPR2017-02058
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`information is transmitted by electronic camera 100 to gateway server
`160, the paragraphs of Kusaka cited by Petitioner do not describe the
`gateway server sending the camera identification information to the
`image server. See Ex. 1009 ¶¶ 3, 219–221. Instead, the gateway server
`sends the image file, the user identification information, and the image
`identification information to the selected image server. Id. ¶ 220. The
`image identification information is not created by the electronic
`camera because Kusaka discloses that the electronic camera does not
`send the image identification information to the gateway server. Id. ¶
`219. Instead, according to Kusaka, the gateway server adds the image
`identification information to the image file. Id. ¶ 220. As also
`discussed above, when the image server of Kusaka receives the image
`file, the user identification information, and the image identification
`information, the image server associates and stores the image file and
`the image identification information in an album corresponding to the
`received user identification information. Id. That is, the album
`existing on the image server is associated with the user identification
`information, not any camera identification information. Indeed,
`since there is no disclosure in the cited paragraphs of Kusaka of
`transmitting any camera identification information to the image
`server, there is no explicit disclosure of anything associated with
`camera identification information existing on the image server in
`the paragraphs of Kusaka cited by Petitioner. Thus, we discern no
`teaching of an account associated with the electronic camera existing
`on Kusaka’s image server in the paragraphs of Kusaka relied upon by
`Petitioner.
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`Paper 10, pp. 30-31 (emphasis added and removed).
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`
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`The Board is correct that Kusaka describes storing images in albums
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`(accounts) based upon an identification of a particular user of Kusaka’s system.
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`Google respectfully suggests that the Board appears to have overlooked, however,
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`that these user identifications are also associated with Kusaka’s digital cameras. In
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`particular, the digital camera sends both “camera identification information” and
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`U.S. Patent No. 8,581,991
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`IPR2017-02058
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`“user identification information” to the gateway server. Ex. 1009, ¶¶ 219, 220
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`(cited in Petition at, e.g., pp. 58-59). Although only the user identification
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`information is passed by the gateway server to the image server, the user
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`identification is still “associated with” the camera that it originated from. Id.
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`Indeed, in other portions of Kusaka that are cited in the Petition, Kusaka describes
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`how a particular camera can retrieve image information from an album on the
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`image server—i.e., the camera continues to be associated with the images
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`contained in the album on the image server. Id., ¶ 236.
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`In this regard, Google respectfully notes that the claim requirement is not
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`that images be transmitted to a WSARC with “camera identification information.”
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`Independent claims 1 and 13 require only that the images be transmitted to “an
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`account associated with the Internet direct device.” Google respectfully submits
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`that an account identified by a “user identification” that originates from the digital
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`camera and which can be used by the digital camera to retrieve images from that
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`same account, as in Kusaka, describes an account that is “associated with” the
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`digital camera. See, e.g., Petition, pp. 58-59 (citing, inter alia, Kusaka, ¶¶ 220, 221,
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`236). Thus, Google respectfully submits that Kusaka teaches a WSARC with “an
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`account associated with the Internet direct device.”
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`*
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`*
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`*
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`*
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`*
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`13
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`U.S. Patent No. 8,581,991
`Request for Rehearing
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`IPR2017-02058
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`The Board’s findings that Kusaka did not disclose a WSARC or “an account
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`associated with the Internet direct device” were its only stated grounds to refuse to
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`institute Grounds 5 and 6 of the Petition. For the reasons stated above, Google
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`respectfully requests that the Board reconsider these findings and institute inter
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`partes review based on Grounds 5 and 6 as to all challenged claims 1–3, 10–14,
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`and 21 of the ‘991 patent.
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`V. CONCLUSION
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`Google appreciates the Board’s diligent and careful analysis of the prior art
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`references that are before it. Google hopes that the foregoing discussion is helpful
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`to the Board in highlighting the teachings of the asserted grounds. Google
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`respectfully requests that the Board reconsider its findings regarding Inoue and
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`Kusaka, and that it institute Grounds 1, 5, and 6 of the Petition in IPR2017-02058.
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`Respectfully submitted,
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`
`
`
`
`/ Joshua P. Larsen /
`Joshua P. Larsen
`Reg. No. 62,761
`Counsel for Petitioner, Google LLC
`
`BARNES & THORNBURG LLP
`11 South Meridian Street
`Indianapolis, Indiana 46204
`(317) 231-1313
`joshua.larsen@btlaw.com
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`U.S. Patent No. 8,581,991
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`IPR2017-02058
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on this 22nd
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`day of March 2018, I caused a true and correct copy of the foregoing REQUEST
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`FOR REHEARING, and all accompanying exhibits, to be served on Patent
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`Owner via electronic mail at the following addresses of record:
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`aim@imiplaw.com
`docket@imiplaw.com
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`/ Steven D. Shipe /
`Steven D. Shipe
`Reg. No. 71,944
`Counsel for Petitioner, Google LLC
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`BARNES & THORNBURG, LLP
`1717 Pennsylvania Ave, NW
`Suite 500
`Washington, D.C. 20006
`(202) 408-6924
`steven.shipe@btlaw.com
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`15
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