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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`CLEARFIELD, INC.
`Petitioner
`
`v.
`
`COMMSCOPE TECHNOLOGIES LLC
`Patent Owner
`
`___________________
`
`Case No. IPR2017-02122
`Patent No. 8,705,929
`___________________
`
`PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 8,705,929
`
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`
`TABLE OF CONTENTS
`
`IV.
`
`Page(s)
`
`Table of Authorities .................................................................................................. ii
`Table of Exhibits ...................................................................................................... iii
`Mandatory Notices ................................................................................................... iv
`INTRODUCTION .......................................................................................... 1
`I.
`
`II.
`PRELIMINARY STATEMENT .................................................................... 1
`
` REQUIREMENTS FOR PETITION FOR INTER PARTES REVIEW ......... 3
`III.
`A. Grounds for Standing (37 C.F.R. § 42.104 (a)) ................................... 3
`Identification of Claims Being Challenged (37 C.F.R. § 42.104
`B.
`(b)) ........................................................................................................ 3
`Fee for Inter Partes Review (37 C.F.R. § 42.15(a)) ............................ 4
`C.
`Proof of Service (37 C.F.R. § 42.105) ................................................. 4
`D.
` SUMMARY OF THE ’929 PATENT ............................................................ 4
`A. Overview of the ’929 Patent ................................................................. 4
`B.
`’929 Patent Family ............................................................................... 7
`V.
`PERSON HAVING ORDINARY SKILL IN THE ART .............................. 8
`
`VI.
` CLAIM CONSTRUCTION ........................................................................... 8
` UNPATENTABILITY OF THE CHALLENGED CLAIMS ........................ 9 VII.
`
`A. Ground 1: Walters Anticipates Claims 1-3, 8, 12, and 17 of the
`’929 Patent ............................................................................................ 9
`B. Ground 2: The Combination of Walters and Fuller Renders
`Obvious Claims 5-7, 10, 11, 13, 15, 16, 19, and 20 of the ’929
`Patent .................................................................................................. 30
`C. Ground 3: Fuller and Balde Render Obvious Claims 1-3, 5-8,
`10-13, 15-17, 19, and 20 of the ’929 Patent ....................................... 36
` CONCLUSION ............................................................................................. 59
`VIII.
`
`
`i
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`TABLE OF AUTHORITIES
`
`Page(s)
`
`
`CASES
`
`KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398 (2007) .......................................... 33, 35
`
`
`
`STATUTES
`
`35 U.S.C. § 102 .................................................................................................passim
`
`35 U.S.C. § 103 .......................................................................................... 3, 4, 37, 43
`
`
`
`OTHER AUTHORITIES
`
`37 C.F.R. § 42.100(b) ............................................................................................ 1, 9
`
`Final Rule, 77 Fed. Reg. 48680 (Aug. 14, 2012) ....................................................... 9
`
`
`
`
`
`ii
`
`

`

`
`Exhibit Description
`Exhibit No.
`Ex. 1001 U.S. Patent No. 8,705,929 (“ the ’929 Patent”)
`Ex. 1002
`Prosecution History of the ’929 Patent (“the Prosecution History”)
`Ex. 1003 Declaration of Dr. Michael Lebby
`Ex. 1004 U.S. Patent No. 6,220,413 (“Walters”)
`Ex. 1005 U.S. Patent No. 6,933,441 (“Fuller”)
`Ex. 1006 U.S. Patent No. 4,201,278 (“Balde”)
`Prosecution History of U.S. App. No. 12/182,705, filed on Jul. 30,
`Ex. 1007
`2008.
`PCT Pub. No. WO2009048680 (A1), corresponding to PCT App.
`No. PCT/US2008/072218, filed on August 5, 2008.
`EP Pub. No. EP2618195 A2, corresponding to EP App. No.
`13163032.9.
`File Wrapper of EP App. No. 13163032.9, downloaded from
`Ex. 1010
`European Patent Office on August 10, 2017.
`Ex. 1011 U.S. Patent No. 4,657,140 of Zagar et al.
`Ex. 1012 USConec MTP® Brand Connectors Data Sheet (© 2014)
`Katsuki Suematsu et al., “Super Low-Loss, Super High-Density
`Multi-Fiber Optical Connectors,” Furukawa Review (n. 23), 2003
`(“Suematsu”)
`Ex. 1014 U.S. Patent No. 6,885,799 of Lee
`
`Ex. 1008
`
`Ex. 1009
`
`Ex. 1013
`
`
`
`
`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`
`LIST OF EXHIBITS
`
`iii
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`
`MANDATORY NOTICES
`
`Clearfield, Inc. (“Petitioner”) hereby submits these Mandatory Notices
`
`pursuant to 37 C.F.R. § 42.8.
`
`A. Real Party in Interest (37 C.F.R. § 42.8(b)(1))
`
`The real party in interest of this petition is Clearfield, Inc., located at 7050
`
`Winnetka Avenue North, Suite 100, Brooklyn Park, Minnesota 55428.
`
`B. Related Matters (37 C.F.R. § 42.8(b)(2))
`
`U.S. Patent No. 8,705,929 (“the ’929 Patent”), which is the subject of the
`
`present Petition, was asserted by CommScope Technologies LLC (“CommScope”)
`
`against Petitioner in a complaint filed on January 31, 2017 in the U.S. District
`
`Court for the District of Minnesota, captioned CommScope Technologies LLC v.
`
`Clearfield, Inc., Case No. 0:12-cv-00307-PJS-BRT.
`
`C.
`
`Lead and Backup Counsel (37 C.F.R. 42.8(b)(3))
`
`Petitioner hereby identifies lead counsel as William D. Belanger (Reg. No.
`
`40,509), and Andrew W. Schultz (Reg. No. 66,869) as backup counsel, both of
`
`which can be reached at Pepper Hamilton LLP, 125 High Street, 19th Floor, High
`
`Street Tower, Boston, Massachusetts 02110, via telephone at 617.204.5100, and
`
`via fax at 617.204.5150. A Power of Attorney is filed concurrently herewith.
`
`iv
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`Service Information (37 C.F.R. 42.8(b)(4))
`
`D.
`
`Petitioner consents to electronic service by email at the following address:
`
`BN_IPR-Clearfield@pepperlaw.com. Please direct all physical correspondence to
`
`the address for counsel provided above.
`
`v
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`
`
`I.
`
`INTRODUCTION
`Pursuant to 35 U.S.C. §§ 311-319 and 37 C.F.R. §§ 42.100 et seq., Petitioner
`
`hereby respectfully requests inter partes review of claims 1-3, 5-8, 10-13, 15-17,
`
`19, and 20 (“the challenged claims”) of the ’929 Patent (Ex. 1001). For the
`
`reasons set forth below, the challenged claims should be found unpatentable.
`
`
`II.
`
`PRELIMINARY STATEMENT
`
`The ’929 Patent generally relates to a fiber optic enclosure assembly
`
`enclosing a spool of fiber optic cable. Ex. 1001 at Abstract. Fiber optic cables
`
`provide an advantage over traditional cables utilizing electrically-conductive wires
`
`because fiber optic cables are generally lighter and are capable of transporting
`
`more information than traditional cables of the same size. Ex. 1003 at ¶28.
`
`However, because optical fibers are made from glass or plastic, fiber optic cables
`
`must be handled with care. As such, fiber optic cables have traditionally been
`
`stored and transported on reels, with the reels having a central hub exhibiting a
`
`radius greater than the minimum bend radius of the fiber to avoid damaging the
`
`fibers wrapped therearound. Because twisting or excessive bending of the fibers
`
`can cause damage as the cables are removed over the edges of these reels, it is has
`
`also long been common to unwind the cables by rotating the reels about a central
`
`axis. Id. at ¶29.
`
`1
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`Unlike traditional cables, which can be cut to proper length and connected to
`
`other cables and equipment relatively easily by a technician in the field, special
`
`tools and techniques are required to cut glass or plastic optical fibers in a manner
`
`that does not damage the fibers’ ability to propagate a light signal. For example,
`
`the cleaved end of an optical fiber must be in a condition to allow light to travel
`
`through without distortion. Moreover, optical fibers require precise alignment with
`
`the end of an abutting fiber or an optical detector at a receiving device to allow the
`
`light signal to propagate therethrough undisturbed. Id. at ¶30. As such, it has long
`
`been common for fiber optic cables to be terminated with a connector, which can
`
`provide dependable optical alignment and coupling between two optical fibers that
`
`are received within an adapter. In fact, it is preferable to connectorize fibers in a
`
`controlled manufacturing facility rather than in the field where the likelihood of
`
`contamination is greatly increased. Id. at ¶31.
`
`As each of these elements were well-recognized in the relevant field, it is not
`
`readily apparent what was considered inventive about the challenged claims, which
`
`are broadly directed to providing an enclosure within which a fiber optic cable
`
`spool can rotate so as to unwind cable from the spool, while at least one fiber optic
`
`adapter is mounted on the spool such that the adapter rotates as cable is paid out
`
`from the spool. See Ex. 1001 at Abstract. In fact, as discussed in detail below, the
`
`references upon which this petition is based teach every element of at least claims
`
`2
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`1-3, 5-8, 10-13, 15-17, 19, and 20, thus anticipating or rendering obvious each of
`
`them. Accordingly, Petitioner respectfully requests that the Board institute trial
`
`and cancel each of the challenged claims.
`
` REQUIREMENTS FOR PETITION FOR INTER PARTES REVIEW III.
`
`
`A. Grounds for Standing (37 C.F.R. § 42.104(a))
`Petitioner certifies that the ’929 Patent is available for inter partes review
`
`and that Petitioner is not barred or estopped from requesting inter partes review of
`
`the challenged claims of the ’929 Patent on the grounds identified herein.
`
`B.
`Identification of Claims Being Challenged (37 C.F.R. § 42.104(b))
`Petitioner requests inter partes review of claims 1-3, 5-8, 10-13, 15-17, 19,
`
`and 20 on the following grounds, and requests that each of the challenged claims
`
`be found unpatentable based on the detailed description that follows in Section VII,
`
`which indicates where each element can be found in the relied upon prior art, and
`
`the relevance of that prior art. Additional evidence for each ground of
`
`unpatentability is set forth in the Declaration of Dr. Michael Lebby, which is
`
`submitted herewith as Exhibit 1003.
`
`Ground 1: Claims 1-3, 8, 12, and 17 are anticipated pursuant to 35
`U.S.C. § 102 by U.S. Patent No. 6,220,413 to Walters et al. (Ex. 1004,
`“Walters”);
`
`Ground 2: Claims 5-7, 10, 11, 13, 15, 16, 19, and 20 are obvious
`pursuant to 35 U.S.C. § 103 over Walters in view of U.S. Patent No.
`6,933,441 to Fuller et al. (Ex. 1005, “Fuller”); and
`
`3
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`Ground 3: Claims 1-3, 5-8, 10-13, 15-17, 19, and 20 are obvious
`pursuant to 35 U.S.C. § 103 over Fuller in view of U.S. Patent No.
`4,201,278 to Balde (Ex. 1006, “Balde”).
`
`Fee for Inter Partes Review (37 C.F.R. § 42.15(a))
`
`C.
`The required fees are submitted herewith. The Office is authorized to charge
`
`any additional fees due at any time during this proceeding to Deposit Account No.
`
`50-0436.
`
`Proof of Service (37 C.F.R. § 42.105)
`
`D.
`Proof of service of this Petition on the Patent Owner at the correspondence
`
`address of record for the ’929 Patent is attached.
`
`IV.
`
` SUMMARY OF THE ’929 PATENT
`A. Overview of the ’929 Patent
`The ’929 Patent, entitled “Fiber Optic Enclosure with Internal Cable Spool,”
`
`was filed on June 21, 2013, and issued on April 22, 2014. The ’929 Patent claims
`
`priority through a series of continuation applications to U.S. Provisional App. No.
`
`61/029,248, filed on February 15, 2008, and to U.S. Provisional App. No.
`
`60/954,214, filed on August 6, 2007. Accordingly, the earliest effective filing date
`
`of the ’929 Patent is no earlier than August 6, 2007.
`
`The ’929 Patent generally relates to a fiber optic enclosure assembly
`
`enclosing a spool of fiber optic cable. Ex. 1001 at Abstract. As shown in FIGS. 2
`
`and 3 (reproduced below), the fiber optic enclosure (21) includes a housing (23)
`
`4
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`having a base (27), sidewalls (29, 31), and a cover (25) that define an interior
`
`region (33). See Ex. 1001 at 2:60-67. A cable spool (37), disposed in the interior
`
`region (33), includes a spooling portion around which subscriber cable (22) can be
`
`coiled. See Ex. 1001 at 3:6-9; Ex. 1003 at ¶33..
`
`
`
`The axial end (41) of the cable spool (37) includes a termination module
`
`(45) having an adapter plate (47) that is adapted to receive a plurality of adapters
`
`(401). See Ex. 1001 at 3:11-18, 3:30-32. As shown in FIG. 3, the axial end (41)
`
`also defines a slack storage area (59) having a cable management spool (61)
`
`
`
`disposed therein. See Ex. 1001 at 3:60-63; Ex. 1003 at ¶34.
`
`As noted above, subscriber cable (22), which includes multiple optical
`
`fibers, is coiled around the cable spool (37). Ex. 1001 at 32-34. “The subscriber
`
`cable 22 includes a first end having connectorized ends, which are inserted through
`
`the cable passage 63 and connectedly engaged with the first ends 413 of the
`
`adapters 401. A second end of the subscriber cable 22 is configured for
`
`5
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`connectivity with the fiber distribution hub 17.” Ex. 1001 at 4:39-44; Ex. 1003 at
`
`¶35.
`
`As shown in FIG. 5 (reproduced below), the enclosure (21) also includes a
`
`bearing mount (71) that is sized to fit within a central hole of the spooling portion
`
`(39) that allows the cable spool (37) to rotate about the axis of the bearing mount
`
`(71). Ex. 1001 at 4:11-14, 4:26-31. With the cable spool (37) mounted to the
`
`bearing mount (71) and the first end of the subscriber cable (22) connected with
`
`the front sides (413) of the adapters (401), the subscriber cable (22) can be paid out
`
`through the fiber ports (79) in the housing (23) by rotating the cable spool (37)
`
`with respect to the housing (23), with the termination module (45) rotating in
`
`unison with the cable spool (37) such that the second end of the subscriber cable
`
`(22) can be paid out without the first end being pulled out of the termination
`
`module (45). See Ex. 1001 at 5:21-38; Ex. 1003 at ¶36.
`
`
`
`6
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`“Once the desired length of subscriber cable 22 has been paid out, the
`
`rotation of the cable spool 37 is ceased. At this point, the position of the cable
`
`spool 37 can be fixed such that it does not rotate relative to the housing 23. In one
`
`embodiment, a pin is inserted through an opening in the axial end 41 of the cable
`
`spool 37 and through a corresponding opening in the base 27 of the housing 23 to
`
`fix the position of the cable spool 37 with respect to the housing 23.” Ex. 1001 at
`
`5:39-46.
`
`’929 Patent Family
`
`B.
`As noted above, the ’929 Patent claims priority to a series of applications,
`
`the earliest non-provisional of which is U.S. App. No. 12/182,705, filed on July 30,
`
`2008 (now U.S. Patent No. 7,756,379, “the ’705 Application”)1, which itself claims
`
`priority to U.S. Provisional App. No. 61/029,248, filed on February 15, 2008, and
`
`to U.S. Provisional App. No. 60/954,214, filed on August 6, 2007. See Ex. 1001 at
`
`1. On August 5, 2008, PCT App. No. PCT/US2008/072218 (“the ’218 PCT
`
`Application”), which is submitted herewith as Exhibit 1008, was filed claiming
`
`priority to the ’705 Application and the above-referenced provisional applications.
`
`See Ex. 1008 at 1. The ’705 Application and the ’218 PCT Application are
`
`
`1 The ’705 Application, as originally filed on Jul. 30, 2008 and downloaded from
`
`the USPTO’s PAIR system, is submitted herewith as Exhibit 1007.
`
`7
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`substantively identical. Compare generally, Ex. 1007 at 289/332-318/332 and Ex.
`
`1008.
`
`On May 11, 2009, the ’218 PCT Application entered the European phase as
`
`EP App. No. 08837186.9, which also spawned a series of European divisional
`
`applications including EP App. No. 13163032.9.2
`
`V.
`
`
`
`PERSON HAVING ORDINARY SKILL IN THE ART
`
`A person having ordinary skill in the art (“POSA”) with respect to the
`
`technology described in the ’929 Patent would be a person with at least a Bachelor
`
`of Science degree in physics (with optics), electrical engineering, or a closely
`
`related field, along with three to five years of experience in fiber optic equipment
`
`and networks. An individual with an advanced degree in a relevant field (e.g., a
`
`master’s degree in physics) would require less experience in fiber optic equipment
`
`and networks. Ex. 1003 at ¶25.
`
`VI.
`
` CLAIM CONSTRUCTION
`The terms in the claims of an unexpired patent subject to inter partes review
`
`receives the “broadest reasonable construction in light of the specification of the
`
`2 EP Pub. No. EP2618195 A2, corresponding to EP App. No. 13163032.9, is
`
`submitted herewith as Exhibit 1009. The file wrapper of EP App. No. 13163032.9,
`
`as downloaded from the website of the European Patent Office, is submitted
`
`herewith as Exhibit 1010.
`
`8
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`patent in which it appears.” 37 C.F.R. § 42.100(b). Any ambiguity regarding the
`
`“broadest reasonable construction” of a claim term is resolved in favor of the
`
`broader construction absent amendment by the patent owner. Final Rule, 77 Fed.
`
`Reg. 48680, 48699 (Aug. 14, 2012). For purposes of this Petition only, Petitioner
`
`submits that the terms and phrases in the challenged claims are accorded their
`
`broadest reasonable interpretation and consistent with the specification of the ’929
`
`Patent. Petitioner’s positions herein are without prejudice to any other claim
`
`construction Petitioner may advance in this or another administrative proceeding
`
`before the Patent Trial and Appeal Board or other agency, or before the district
`
`court.
`
` UNPATENTABILITY OF THE CHALLENGED CLAIMS
`VII.
`As discussed in detail below, Petitioner requests that claims 1-3, 5-8, 10-13,
`
`15-17, 19, and 20 be found unpatentable as follows.
`
`A. Ground 1: Walters Anticipates Claims 1-3, 8, 12, and 17 of the
`’929 Patent
`U.S. Patent No. 6,220,413 to Walters et al. issued on April 24, 2001, and is
`
`prior art to the ’929 Patent under 35 U.S.C. § 102(b). See Ex. 1004. As explained
`
`below, claims 1-3, 8, 12, and 17 of the ’929 Patent are unpatentable as being
`
`anticipated by Walters.
`
`9
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`
`1. Overview of Walters
`Entitled “Retractable Cable Reel,” Walters is directed to a cable storage
`
`apparatus from which the fiber optic cable can be extended and retracted in order
`
`to connect devices in a local area network, for example. See Ex. 1004 at Abstract,
`
`1:4-25; Ex. 1003 at ¶38. As shown in FIGS. 1 and 2 (reproduced below), Walters
`
`provides a reel (11) for storing fiber optic cable rotatably mounted within a
`
`housing (27). Ex. 1004 at 2:23-25 (“Frame 27 is rectangular, having a baseplate 29
`
`(FIG. 2) and four sidewalls 31.”). The reel (11) comprises a pair of flanges (15,
`
`17) extending radially outward from a central hub (13), disposed on the axis of
`
`rotation of the reel (11). Id. at 2:6-8. “An axle or spindle (not shown) extends
`
`between hub 13 and bottom 30 of frame 27 to enable rotation of reel 11.” Id. at
`
`2:41-47. As shown in FIG. 2, fiber optic cable (23) is coiled around a perimeter
`
`wall (19) between the flanges (15, 17) such that a technician can unwind the cable
`
`(23) by pulling one end of the cable (23) through an access port (35) in one of the
`
`sidewalls (31) as the reel (11) rotates. See Ex. 1004 at 2:14-16, 2:28-33, 4:46-51;
`
`Ex. 1003 at ¶38.
`
`10
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`
`As shown in FIGS. 5 and 6 (reproduced below), Walters provides two
`
`docking stations with which a connector panel (53) can be alternatively engaged: a
`
`frame docking station (43) on one of the frame’s sidewalls (31) and a reel docking
`
`station (47) that can be mounted to the hub (13) such that the connector panel
`
`rotates with the reel (11). See Ex. 1004 at 2:48-53, 2:59-65; Ex. 1003 at ¶39.
`
`
`
`
`
`11
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`As shown, the connector panel (53) comprises a flat plate having a plurality
`
`of fiber optic connector sleeves (55) mounted to it and two quick release fasteners
`
`(57) that can releasably engage holes (45) in the frame docking station (43), as
`
`shown in FIG. 5, or holes (51) of the reel docking station (47), as shown in FIG. 6.
`
`Ex. 1004 at 2:59-65; Ex. 1003 at ¶40. “[A] locking member 65 serves to prevent
`
`inadvertent rotation of reel 11 while connector panel 53 (FIG. 6) is located on
`
`frame docking station 43.” Ex. 1004 at 3:25-27.
`
`As shown above, each connector sleeve (55) has two receptacles on an outer
`
`side of the connector panel (53) and two receptacles on an inner side of the
`
`connector panel (53). See Ex. 1004 at 2:66-3:15; Ex. 1003 at ¶41. Each receptacle
`
`on the outer side is adapted to receive a male plug connector on the end of a fiber
`
`optic line (59) from a cable (not shown) that leads to nearby equipment (e.g., a
`
`server or telecom equipment in a telecom closet). See Ex. 1004 at 2:66-3:4. On
`
`the inner side, each receptacle of the connector sleeves (55) is adapted to receive
`
`male plug connectors on the ends of fibers (61) from the fiber optic cable (23) that
`
`is wrapped around the reel (11). See Ex. 1004 at 3:6-8; Ex. 1003 at ¶41.
`
`As explained in the following sections, Walters discloses each and every
`
`element of claims 1-3, 8, 12, and 17 of the ’929 Patent, arranged as in the claims.
`
`12
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`
`Independent Claim 1
`
`2.
`As explained in the claim chart below and in the following discussion,
`
`Walters discloses each and every element of claim 1, arranged as in the claim. See
`
`Ex. 1003 at ¶¶51-61.
`
`Claim 1
`1. A fiber optic
`enclosure assembly
`comprising:
`
`[1.1] a housing
`having an interior;
`
`Exemplary Disclosure of Walters
`To the extent the preamble is limiting, Walters discloses an
`enclosure assembly for a fiber optic cable. Ex. 1003 at ¶51.
`For example, Walters discloses “a cable storage device.”
`See, e.g., Ex. 1004 at Abstract, FIGS. 1 and 2.
`Walters discloses a housing as required by this claim
`element. See Ex. 1003 at ¶52.
`Walters discloses a housing that defines an interior (i.e.,
`housing (27), outlined in red in FIG. 1 below). Id. For
`example, Walters provides that a “reel 11 is rotatably
`mounted in a housing or frame 27. Frame 27 is rectangular,
`having a baseplate 29 (FIG. 2) and four sidewalls 31.” Ex.
`1004 at 2:23-25 (emphasis added). Walters also provides a
`“cover 33 [] [that] locates over the top of frame 27 parallel to
`baseplate 29. One of the sidewalls 31 has an access port 35
`for passage of the fiber optic cable 23 (FIG. 2).” Ex. 1004 at
`2:28-33; see also Ex. 1003 at ¶52.
`
`13
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`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`
`
`
`[1.2] a cable
`storage spool
`positioned within
`the interior of the
`housing, wherein
`the cable storage
`spool rotates about
`an axis relative to
`the housing to
`allow the first
`portion of the fiber
`optic cable to be
`paid out from the
`interior of the
`housing;
`
`
`
`Walters discloses a cable storage spool as required by this
`claim element. See Ex. 1003 at ¶¶53-55.
`Walters discloses a cable storage spool (i.e., reel (11)
`outlined in blue in FIG. 1 below) that is positioned within the
`housing (27). Id. at ¶53. The reel (11) of Walters rotates
`about an axis relative to the housing (27) to allow a first
`portion of the cable (23) to be paid out from the interior of
`the housing (27) through the access port (35). Id.
`For example, Walters provides that “reel 11 is rotatably
`mounted in a housing or frame 27.” Ex. 1004 at 2:23-25
`(emphasis added). “A polygonal rod 41 extends from the
`axis of hub 13 for rotation with reel 11. Rod 41 has flat sides
`for receiving a conventional socket of a socket wrench that is
`used to rotate reel 11 relative to frame 27. An axle or
`spindle (not shown) extends between hub 13 and bottom 30
`of frame 27 to enable rotation of reel 11.” Ex. 1004 at 2:41-
`47; Ex. 1003 at ¶54.
`
`14
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`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`
`
`Walters also discloses that “[o]ne of the sidewalls 31 has an
`access port 35 or passage of the fiber optic cable 23 (FIG. 2).
`A storage area 36 may be located adjacent access port 35 for
`storing a lead end or pulling eye of cable 23.” Ex. 1004 at
`2:28-33; Ex. 1003 at ¶55. When the connector panel (53) is
`placed in the position as shown in FIG. 5, “reel 11 may be
`rotated to extend or retract cable 23.” Ex. 1004 at 3:19-22;
`Ex. 1003 at ¶54. “The technician will then take the remote
`or pulling eye end of the cable from storage compartment 36
`(FIG. 1) and begin pulling the cable 23 to the remote site.”
`Ex. 1004 at 4:46-48.
`Walters discloses a fiber optic cable as required by this claim
`element. See Ex. 1003 at ¶¶56-57.
`Walters discloses that a fiber optic cable (23) having a first
`end and a second end is wound around the reel (11). Id. at
`¶56.
`For example, as shown in FIG. 2 (annotated below), Walters
`discloses that the fiber optic cable (23) is wrapped around a
`perimeter wall (19) of the reel (11). See, e.g., Ex. 1004 at
`
`15
`
`[1.3] a fiber optic
`cable wound
`around the cable
`storage spool, the
`fiber optic cable
`having a first end
`and a second end;
`and
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`2:6-8, 2:20-22, FIG. 2; Ex. 1003 at ¶56. “A cylindrical
`perimeter wall 19 encircles hub 13 at the inner diameter of
`flange 15. . . A cable 23 [], such as fiber optic cable, wraps
`around perimeter wall 19 between flanges 15, 17.” Ex. 1004
`at 2:14-22.
`“In operation, cable 23 (FIG. 2) will be wrapped around
`perimeter wall 19, preferably at the factory. The direction of
`wrapping is counterclockwise when viewed as shown in FIG.
`1.” Ex. 1004 at 4:32-35.
`
`cable (23)
`
`With reference to claim 1, the claimed first end of the cable
`(23) terminates in male plug connectors within the housing
`(27). Ex. 1003 at ¶57. Walters also discloses that “[t]he
`proximal end of cable 23 will be fanned out, with individual
`fibers 61 being secured to connector panel 53 as shown in
`FIG. 5. Connector panel 53 will be mounted to reel docking
`station 47.” Ex. 1004 at 4:35-38.
`The claimed second end of the cable (23) (i.e., the lead end
`or pulling end of the cable (23)) extends from the reel (11)
`and can be stored in the storage area (36) adjacent the access
`port (35). Id. at 2:31-34; Ex. 1003 at ¶57.
`Walters discloses fiber optic adapters as required by this
`claim element. See Ex. 1003 at ¶¶58-61.
`Walters discloses a fiber optic adapter (i.e., a connector
`sleeve (55)) mounted on the reel (11). Ex. 1003 at ¶58. The
`
`16
`
`[1.4] a fiber optic
`adapter mounted on
`the cable storage
`spool, the fiber
`optic adapter
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`connector sleeve (55) receives a male plug connector of the
`optical fibers (61) at the first end of the fiber optic cable
`(23). Id. at ¶60.
`For example, as shown in FIG. 5 (annotated below), Walters
`discloses that each connector sleeve (55) has two receptacles
`on an outer side of the connector panel (53) and two
`receptacles on an inner side of the connector panel (53). See
`Ex. 1004 at 2:66-3:15; Ex. 1003 at ¶60. On the inner side,
`each receptacle of the connector sleeves (55) is adapted to
`receive male plug connectors on the ends of fibers (61) from
`the fiber optic cable (23) that is wrapped around the reel
`(11). See Ex. 1004 at 3:6-8; Ex. 1003 at ¶60.
`
`receiving the first
`end of the fiber
`optic cable, the
`fiber optic adapter
`being carried with
`the cable storage
`spool as the cable
`storage spool is
`rotated about the
`axis to allow the
`second end of the
`fiber optic cable to
`be paid out from
`the interior of the
`housing, the fiber
`optic adapter being
`configured to
`couple the first end
`of the fiber optic
`cable to a
`connectorized end
`of a subscriber
`optical fiber while
`the adapter is
`mounted on the
`cable storage spool.
`
`
`
`Walters discloses that the fiber optic adapter (i.e., a
`connector sleeve (55)) is carried with the reel (11) as the reel
`(11) is rotated about the axis to allow the second end of the
`fiber optic cable (23) to be paid out from the interior of the
`housing (27). Ex. 1003 at ¶58.
`For example, as shown in FIG. 5 (annotated below), Walters
`discloses that the fiber optic connector sleeves (55) are
`mounted to the connector panel (53). Ex. 1004 at 2:59-61
`
`17
`
`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`(“Connector panel 53 comprises a flat plate having a
`plurality of fiber optic connector sleeves or terminals 55
`mounted to it.”); Ex. 1003 at ¶59. The connector panel (53)
`is adapted to fit on reel docking station 47, which is
`“mounted to the hub 13 for rotation with reel 11.” Ex. 1004
`at 2:52-61. Walters also discloses that “[w]ith the connector
`panel 53 mounted to the reel docking station 47, locking
`member 65 will be in the unlocked position, with its finger
`69 (FIG. 2) out of engagement with one of the apertures 73. .
`. The technician will then take the remote or pulling eye end
`of the cable from storage compartment 36 (FIG. 1) and begin
`pulling the cable 23 to the remote site.” Ex. 1004 at 4:40-48;
`Ex. 1003 at ¶58.
`
`Walters further discloses that the connector sleeve (55) is
`configured to couple the individual fibers (61) of the first
`end of the fiber optic cable (23) to a connectorized end of a
`subscriber optical fiber (i.e., fiber optic line (59)) while the
`connector sleeve 55 is mounted on the reel (11), as shown
`above in annotated FIG. 5. Ex. 1003 at ¶58.
`For example, Walters provides that each receptacle on the
`
`18
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`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`outer side is adapted to receive a male plug connector on the
`end of a fiber optic line (59) from a cable (not shown) that
`leads to nearby equipment (e.g., a server or telecom
`equipment in a telecom closet). See Ex. 1004 at 2:66-3:4;
`Ex. 1003 at ¶60. On the inner side, each receptacle of the
`connector sleeves (55) is adapted to receive male plug
`connectors on the ends of fibers (61) from the fiber optic
`cable (23) that is wrapped around the reel (11). See Ex. 1004
`at 3:6-8; Ex. 1003 at ¶60. The connector sleeves (55) are
`thus configured to receive and couple the lines (59) and
`fibers (61) when the connector panel (53) to which the
`connector sleeves (55) are attached is mounted to the reel
`docking station (47). Ex. 1003 at ¶60.
`
`
`As discussed above with reference to element [1.4], the connector sleeves
`
`(55) are configured to receive the lines (59) when the connector panel (53) to
`
`which the connector sleeves (55) are attached is mounted on the reel docking
`
`station (47). Ex. 1003 at ¶¶58-60. In particular, a POSA would appreciate that the
`
`configuration of the connector sleeves (55) does not change when the connector
`
`sleeves (55) are mounted on the reel docking station (47). See Ex. 1003 at ¶61.
`
`That is, regardless of the positioning of the connector panel (53), “[e]ach
`
`receptacle on an outer side of each connector sleeve 55 is adapted to receive a male
`
`plug connector on the end of a fiber optic line 59” and each receptacle on “an inner
`
`side [] receive[s] male plug connectors on the ends of fibers 61 from optical cable
`
`23.” Ex. 1004 at 2:67-3:8; Ex. 1003 at ¶61.
`
`Though Walters discloses that “when rotation is desired, connector panel 53
`
`must be moved to the position shown in FIG. 5 on reel docking station 47” and that
`
`19
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`

`

`Petition for IPR2017-02122
`U.S. Patent No. 8,705,929
`the external lines (59) “must first be removed from connector sleeves 55