UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SNAP, INC.,
`Petitioner
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`v.
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`BLACKBERRY LIMITED,
`Patent Owner
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`Case No. IPR2019-00715
`Patent No. 8,326,327
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`PATENT OWNER’S SUR-REPLY TO
`PETITIONER’S REPLY TO PRELIMINARY GUIDANCE
`(PURSUANT TO 84 FED. REG. 9502)
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SNAP, INC.,
`Petitioner
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`v.
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`BLACKBERRY LIMITED,
`Patent Owner
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`Case No. IPR2019-00715
`Patent No. 8,326,327
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`PATENT OWNER’S SUR-REPLY TO
`PETITIONER’S REPLY TO PRELIMINARY GUIDANCE
`(PURSUANT TO 84 FED. REG. 9502)
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`I.
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`II.
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`TABLE OF CONTENTS
`CLAIM 21 IS NON-OBVIOUS UNDER 35 U.S.C. §103 ............................. 1
`A.
`Petitioner’s Rationales For The Proposed New Obviousness
`Combinations Are Insufficient And Contrary To Substantial
`Evidence ................................................................................................ 1
`1.
`Petitioner failed to articulate and support (with evidence) a
`specific rationale for applying Eyal’s or Jaffe’s video features
`to the base system of Lemmela or Winkler ................................. 1
`The Reply failed to cure the defects in the Petitioner’s original
`three rationales that lacked specificity and ignored evidence .... 4
`The Opposition Failed To Specify All Grounds With The Requisite
`“Particularity” And Thereby Prejudiced Patent Owner ........................ 6
`Petitioner Overlooked Why The Cited References Are Lacking
`Multiple Elements Of Claim 21 ............................................................ 7
`1.
`Original Claim Limitations ......................................................... 7
`2.
`New Claim Requirement – Element 21[f] .................................. 8
`3.
`New Claim Requirement – Element 21[i] .................................. 9
`CLAIM 21 SATISFIES THE WRITTEN DESCRIPTION REQUIREMENT
`UNDER 35 U.S.C. §112, ¶1 .......................................................................... 10
`III. CLAIM 21 IS DIRECTED TO PATENT-ELIGIBLE SUBJECT MATTER
`UNDER 35 U.S.C. §101 ................................................................................ 11
`IV. CONCLUSION .............................................................................................. 12
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`Case No.: IPR2019-00715
`Attorney Docket No.: 21828-0041IP1
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`2.
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`B.
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`C.
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`i
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`Case No.: IPR2019-00715
`Attorney Docket No.: 21828-0041IP1
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`I.
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`CLAIM 21 IS NON-OBVIOUS UNDER 35 U.S.C. §103
`A.
`Petitioner’s Rationales For The Proposed New Obviousness
`Combinations Are Insufficient And Contrary To Substantial Evidence
`1.
`Petitioner failed to articulate and support (with
`evidence) a specific rationale for applying Eyal’s or Jaffe’s video features to
`the base system of Lemmela or Winkler
`The Preliminary Guidance (“PG”) properly explained that “Petitioner does not
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`explain why a person of ordinary skill in the art would have been prompted to either
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`perform a substitution or make the asserted combination,” and substantial evidence
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`supports this assessment. PG, 10-12; EX2003, ¶¶143, 147; EX1022, 27:11-16;
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`EX1024, 153:20-154:1. The Reply to the Preliminary Guidance (“PG-Reply”)
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`overlooks this evidence—resorting to vague entreaties to KSR. PG-Reply, 2-6.
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`Under KSR, it was Petitioner’s burden to provide persuasive evidence/articulated
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`reasoning that a POSITA back in 2010, starting from Lemmela (or Winkler) and
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`without hindsight, would have been prompted to make the specific changes proposed
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`in Petitioner’s Opposition. Unigene Labs., Inc. v. Apotex, Inc., 655 F.3d 1352, 1360-
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`61 (Fed. Cir. 2011) (“selected and combined”). That burden certainly was not met.
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`The Opposition’s “reasons to combine” for all grounds lean on Petitioner’s
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`false assumption that Jaffe’s statements for “broad social and practical importance”
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`of “viewing and interacting” were somehow tethered to video posts. Opp., 16, 18.
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`They are not. The Preliminary Guidance correctly noted that these statements in
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`Jaffe pertain to the popularization of “digital photography” at the time, not “video
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`1
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`posts.” PG, 11 (citing EX1013, 1:14-21). Contrary the PG-Reply (p. 7), the
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`evidence shows Jaffe’s teaching in this regard is not equally applicable to images
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`and video posts—and certainly not before August 2010. EX1022, 27:11-16;
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`EX1024, 153:20-154:1. Jaffe’s system discussed later in the “Detailed Description”
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`section can process several types of media objects including photographs and video
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`(col. 3:63-4:4), but it does not follow from this that Jaffe’s specific statements in
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`“Background” regarding “digital photographs” (col. 1:14-21) must be imputed to all
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`other species of media objects. Petitioner had a burden to provide persuasive
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`evidence of this allegation, but it failed to do so. Indeed, the Preliminary Guidance
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`adroitly noted the evidence from Dr. McDaniel (PG, 10-11), which appears to be
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`consistent with Dr. Bhattacharjee’s admission that the network infrastructure
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`required to support large scale video posting was not available in August 2010
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`(EX1020, ¶¶94, 220). Arctic Cat Inc. v. Bombardier Recreational Prods. Inc., 876
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`F.3d 1350, 1363 (Fed. Cir. 2017) (“Evidence suggesting reasons to combine cannot
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`be viewed in a vacuum apart from evidence suggesting reasons not to combine.”).
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`The PG-Reply (pp. 7-9) improperly raised for the first time “specific reasons”
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`that were fatally absent from its Opposition paper. Such prejudicially late theories
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`should be disregarded. Henny Penny Corp. v. Frymaster LLC, 938 F.3d 1324, 1330-
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`1331 (Fed. Cir. 2019). Moreover, they are unsupported. For instance, the Reply
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`contends that a POSITA would have been prompted to further modify Lemmela’s
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`and Winkler’s base systems in light of Eyal or Jaffe merely because some describe
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`“similar problems in the prior art” and allegedly “provide methods for organizing
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`the presentation of content.” Reply, 8. But the mere circumstance that references
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`have these “alleged similarities” is not enough to “constitute an articulated reasoning
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`with rational underpinning.” William Wesley Carnes, Sr., Inc. v. Seaboard Int’l Inc.,
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`IPR2019-00133, Paper 10, 17-18 (PTAB May 8, 2019). Here, Petitioner overlooks
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`critical differences among the references by characterizing their solutions at an
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`absurdly high level of generality. Indeed, Eyal’s solution for sharing geocoded video
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`content is far different from Winkler’s system for generating map elements that
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`prompt user conversations or Lemmela’s system for generating salient-word clouds.
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`EX2003, ¶¶143, 147. Jaffe’s goal for summarizing media collections is likewise
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`markedly different from Winkler’s or Lemmela’s desired results. Id.
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`Finally, Petitioner’s reliance on Uber Techs., Inc. v. X One Inc. is misplaced.
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`Reply, 4. In Uber, the prior art highlighted a finite set of only two alternatives and
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`a design need that would have prompted the substitution of one for the other. Uber,
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`2020WL 2123399 at *9-10. In contrast, the record here does not even define a
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`specific problem, let alone a finite set of only two solutions. The addition of video
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`posting was also not a mere “choice” (PG-Reply, 9) or “change/add for the input” of
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`Lemmela and Winkler (PG-Reply, 5), especially where substantial evidence in the
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`record confirms the proposed “video” modifications were inconsistent with device
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`capabilities/infrastructure before August 2010 and inconsistent with original
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`solutions/principle purposes of Lemmela and Winkler’s base systems. EX2003,
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`¶¶143, 147; EX1022, 27:11-16; EX1024, 153:20-154:1; EX1020, ¶¶94, 220.
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`2.
`The Reply failed to cure the defects in the Petitioner’s
`original three rationales that lacked specificity and ignored evidence
`Petitioner contends that its generic allegations for (1) “known methods to
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`yield predictable results,” (2) a “simple substitution,” and (3) “known techniques to
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`improve similar systems” were sufficient, yet evidence in the record demonstrated
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`the opposite. PG-Reply, 3-4 (citing Opp. 14-18); PG, 10-11 (“conclusory
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`statements” and “does not appear to be factually supported”). The PG-Reply sought
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`to cure these noted defects with erroneous and belatedly new attorney argument.
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`For example, consider the Lemmela-Crowley-Eyal combination. Petitioner
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`now contends that the resulting system would have “operated as usual” according to
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`Lemmela except that the system “would have grouped posts, including video posts,
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`by location and associated word tag.” PG-Reply, 4. But this operation assumes that
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`Eyal’s video posts are associated with “word tags,” when, in reality, they are not.
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`Eyal tags its videos with GPS/location coordinates indicating where the video was
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`recorded, but does not separately disclose tagging the videos with descriptive text
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`like that of Lemmela’s “salient word” system. EX1014, 2:29-31, 5:16-21, 7:20-22;
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`EX2003, ¶147. Despite Petitioner’s unsupported assumptions, the addition of
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`descriptive-text metadata for Eyal’s videos and processing of such videos for salient
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`word themes was never contemplated nor predictable in the cited references
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`themselves. EX2003, ¶147 (“antithetical to Lemmela’s desired solution”). The
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`Lemmela-Crowley-Jaffe combination is also flawed. Petitioner pointed to Jaffe’s
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`map interface of Figures 2A-B as allegedly teaching selectable graphical items that
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`would “provide a pop-up display of [] underlying video posts.” Opp., 13-14. Then,
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`in the alleged “reasons to combine,” Petitioner switches to Jaffe’s distinct Figure 4
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`embodiment, which represents a “tag map 400 display[ing] tags 430… associated
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`with specific locations on a map.” Opp., 15 (citing EX1013, FIG. 4 (“twinpeaks”)).
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`But Jaffe never actually describes selecting such textual tags on the “tag map 400”
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`to thereby display the full media content. Petitioner assumed too much, and failed
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`to establish that applying Jaffe’s teaching to Lemmela-Crowley involved “known
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`methods” or “predictable results” to achieve the specific solution of claim 21.
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`Finally, regarding the new Winkler combinations, Petitioner ignored critical
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`evidence. Dr. McDaniel testified that Winkler “does not include anything akin to
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`video postings,” and because “Winkler’s object is merely to drive users toward two-
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`way messaging sessions regardless of their present locations,” “Winkler is not
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`concerned with enabling users to easily locate and assess nearby ‘action spots’
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`corresponding to locations where other users posted videos[].” EX2003, ¶¶142-143.
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`Neither the Opposition nor the PG-Reply mentioned this straightforward testimony
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`even though it was acutely relevant to Petitioner’s newly proposed modifications to
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`Winkler and, at a minimum, highlighted reasons why Petitioner’s proposed video
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`postings in Winkler would not have been “predictable” before August 2010. The
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`law required Petitioner to address such evidence. Arctic Cat, 876 F.3d at 1363
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`(“evidence suggesting reasons not to combine”). It did not.
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`B.
`The Opposition Failed To Specify All Grounds With The
`Requisite “Particularity” And Thereby Prejudiced Patent Owner
`Even beyond Petitioner’s flawed rationales for the newly proposed
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`combinations, Petitioner ignores that the Opposition failed to identify the grounds
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`with sufficient “particularity.” Adaptics Ltd. v. Perfect Co., IPR2018-01596, Paper
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`20, 18-23 (PTAB “Informative” March 6, 2019) (“suffers from a lack of
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`particularity”). Here, the analysis in both the Opposition and Reply repeatedly fail
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`to delineate between mappings and combinability arguments that pertain to Eyal
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`“or” Jaffe, Lemmela “or” Winkler, or other unstated combinations. E.g., Opp., 10
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`(“Eyal or Jaffe’s video features are combined with the Lemmela-Crowley or
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`Winkler-Altman systems”), 7. The element-by-element analysis in the Opposition is
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`not always consistent with these “or” alternatives—sometimes suggesting it must be
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`Eyal “and” Jaffe. For example, the Opposition’s analysis of the “action spots and
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`activity level” (p. 11) cites only Jaffe (not Eyal) for its contention that videos “could”
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`have been associated with words—seemingly excluding the combinations that rely
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`on Eyal rather than Jaffe. Opp. 11, see also 14-15 (citing exclusively Jaffe (not Eyal)
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`for the specific contention that “grouping/displaying video posts” was known). Such
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`failures to identify all grounds “with particularity” prejudices Patent Owner at this
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`stage and unfairly forces the Board to speculate regarding at least these elements.
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`C.
`Petitioner Overlooked Why The Cited References Are
`Lacking Multiple Elements Of Claim 21
`Petitioner’s Reply to the Preliminary Guidance alleged that “there can be no
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`reasonable dispute that the prior art references include each and every limitation” of
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`substitute claim 21. Reply, 1. This is false. Not only is there meaningful evidence
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`in the record contrary to the Reply’s allegation, but Petitioner also overlooks
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`multiple shortcomings of the newly cited Jaffe and Eyal references.
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`1. Original Claim Limitations
`The language of substitute claim 21 results from rewriting dependent claim 2
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`in independent form through explicit incorporation of the language of claim 1, and
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`also reciting new limitations that narrow the scope. PG, 8-9. As described in the
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`Motion to Amend (“MTA”), the original limitations in claim 21 also recite several
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`features that are nowhere taught by the Lemmela-Crowley or Winkler-Altman
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`combinations. For example, the Lemmela-Crowley combinations fail to teach
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`Element 21[e] (“determine at least one action spot within a predetermined distance
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`from the current location of the mobile device”) and Element 21[g] (“provide an
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`indication of activity level”). MTA, 13-16. Likewise, the Winkler-Altman
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`combinations fail to teach Element 21[e] (“determine at least one action spot …”).
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`Id., 17-19. Petitioner never relies upon Eyal nor Jaffe to cure these deficiencies.
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`2.
`New Claim Requirement – Element 21[f]
`Claim element 21[f] recites a new requirement—that two items be signified
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`on the interactive map of the graphical user interface: (1) “the at least one action
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`spot” and (2) “the current location of the mobile device.” The action spot must be
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`signified “as a selectable graphical item,” and the current location of the mobile
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`device must be signified “as an icon.” Id. The Opposition and PG-Reply overlooked
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`why none of the proposed prior art combinations would have achieved this feature.
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`For the Lemmela grounds, the Opposition relied on Lemmela’s disclosure of
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`“icons representing the locations of grouped posts, which ‘typical[ly] correspond to
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`the current location of the poster” as teaching the claimed signifier for “the current
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`location of the mobile device.” Opp., 9. But under Petitioner’s mapping of
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`Lemmela, the “location of the poster” corresponds to the location of the “other”
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`(second) mobile device that has allegedly “engaged in documenting action”—not
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`the location of the (first) mobile device whose location must also be signified on the
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`interactive map. Pet., 45-47; EX1005, [0033], [0002]. Notably, none of Lemmela’s
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`maps (Figures 1-3 or 5) depicts the current location of the first user’s mobile device
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`“as an icon” while also signifying the alleged action spot as a “selectable graphic
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`item” on the same interactive map. Petitioner’s citations for Element 21[f] (Opp.,
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`9.), when scrutinized, show that the Lemmela combinations fall short.
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`For the Winkler grounds, the Opposition points to Winkler’s generation of a
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`map element icon “based on [] identifying a location of a user’s mobile device” for
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`the claimed signifier of the “current location of the mobile device.” Opp., 9. Yet,
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`this mapping is deficient since it is the same mapping that Petitioner offers for the
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`signifier of the “action spot” itself. Specifically, Petitioner’s Reply relied on a
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`“scenario” where a “hidden map element X” is created at the current location of a
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`first device, and upon occurrence of a certain event, map element X allegedly
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`becomes the claimed “action spot.” Reply (Paper 22), 17. The inconsistent citations
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`highlight why Winkler fails to provide the distinct signifiers recited in Element 21[f].
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`3.
`New Claim Requirement – Element 21[i]
`Element 21[i] recites that the mobile device “provide[s] a pop-up display of
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`said posted video on the graphical user interface of the touch sensitive display.” The
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`Opposition contends that this feature is taught by Jaffe, and specifically alleges that
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`Jaffe discloses icons representative of video posts that “‘may be selected by a user’
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`to provide a pop-up display of the underlying video posts, such as the pop-up
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`depicted in Figure 2B.” Opp., 13. But in fact, Petitioner’s allegation is unsupported.
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`Jaffe’s Figure 2B instead depicts a pop-up of a still image—not a video post. Ex-
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`1013, 6:6-13, FIG. 2B. Jaffe’s description is generic in reference to the thumbnail,
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`which is referred to as a “media object 220a.” Id. By contrast, Jaffe is specific in
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`its description of what is presented in response to user input scrolling over media
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`object 220a: namely, a “larger image 230” of that thumbnail. Id. Thus, regardless
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`of the underlying type of media object represented by thumbnail 220a (e.g., still
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`image or video), the result of scrolling over Jaffe’s thumbnail is a presentation of “a
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`larger image 230” of that thumbnail—not the full rendering of an underlying video.
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`Petitioner’s reliance Jaffe assumed too much for Element 21[i].
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`II. CLAIM 21 SATISFIES THE WRITTEN DESCRIPTION
`REQUIREMENT UNDER 35 U.S.C. §112, ¶1
`The Preliminary Guidance correctly assessed why the subject matter of claim
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`21 was supported by the original ’676 application, and substantial evidence in the
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`record buttresses the Board’s explanation. PG, 5-8; EX2003, ¶¶125-139. The Reply
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`disagrees, and argues that the ’676 application does not disclose “a pop-up display
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`of said posted video” (Element 21[i]). Reply, 11-12. Dr. McDaniel provided ample
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`testimony of the original written description Element 21[i] and what a POSITA
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`would have recognized from such teaching. EX2003, ¶¶131-134 and 137-139;
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`MTA, 5-6. The evidence demonstrated why the cited paragraphs of the ’676
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`application discuss, for example, that an “action spot” can be determined “within a
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`predetermined distance from the current location of the mobile device,” and the
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`action spot can correspond to a location where at least one other mobile device
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`posted “video,” including “within a specific period of time.” EX2003, ¶138
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`(referring back to “¶¶131-134” and EX2007, [0022], [0032], and [0036]
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`(“predetermined period of time”)). This substantial evidence also demonstrated why
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`a POSITA would have recognized the original disclosure for each aspect of the
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`“posted video” that is provided in the claimed “pop-up display.” Id.; see also In re
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`Wright, 866 F.2d 422, 424-25 (Fed. Cir. 1989) (“specification as a whole must be
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`considered” and the element “need not be described in haec verba”); In re Alton, 76
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`F.3d 1168, 1175-76 (Fed. Cir. 1996) (citing expert testimony as to why a POSITA
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`“would have understood the inventor to have been in possession”).
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`Finally, Petitioner’s citation to the non-precedential Taylor decision is
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`misplaced and overlooks the authority in Wright and Alton. PG-Reply, 12. Taylor
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`upheld a §112 rejection where the claim attempted to combine aspects of two
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`alternative versions—a “real time version” and a “simulation mode” intended to
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`achieve vastly distinct results. 2020 WL 1651682, *7. Here, the claimed aspects of
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`the “posted video” in the pop-up display are not drawn from such mutually exclusive
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`alternatives in the ’327 patent, and instead substantial evidence confirms the
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`underlying facts noted in the Preliminary Guidance. EX2003, ¶¶133 and 138.
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`III. CLAIM 21 IS DIRECTED TO PATENT-ELIGIBLE SUBJECT
`MATTER UNDER 35 U.S.C. §101
`The Preliminary Guidance correctly assessed that claim 21 is directed to
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`eligible subject matter under §101, and substantial evidence in the record supports
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`the Board’s explanation. PG, 12-14; EX2003, ¶¶122-124 and 157-161. Petitioner’s
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`dispute with the Preliminary Guidance, however, is fatally flawed for two reasons.
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`First, the Reply (p. 10) improperly lumped five detailed elements (21[d]-[h],
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`which span more than 150 words) into one genericized “abstract idea” used for
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`describing broader claim 1 in a now-appealed district court decision. EX2005; PG,
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`9, 13-14. Not only does such a hollow analysis overlook numerous tangible
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`requirements of claim 21, it never squarely addresses the Core Wireless precedent.
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`MTA, 20. Further, it ignores the cited evidence showing why these limitations tether
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`the action spot/activity level features to the specific solutions on the small-screen
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`interface while also limiting the claim scope towards the specific application based
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`on posted video. MTA, 19-20 (citing EX2003, ¶¶150-161 and Revised Guidance).
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`Second, Petitioner’s contention (p. 10-11) that claim 21 does not integrate any
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`abstract idea into a “practical application” is inconsistent with the Office’s Revised
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`Guidance. Contrary to Petitioner’s insufficient allegation that the “new” elements
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`alone “were known,” the Revised Guidance is clear that whether [a] limitation is
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`well-known” is “not a consideration at Step 2A.” Revised Guidance, 15, 12
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`(“considers the claim as a whole”). Here, substantial evidence actually addressing
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`the claim as a whole explains that “[s]ubstitute claim 21 represents a very clear
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`technological improvement in the way computing devices—namely, mobile devices
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`with limited screen space—operate to assist users in identifying and locating nearby
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`happenings and events.” EX2003, ¶¶150 and 158-61; MTA, 19-21. Petitioner has
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`not refuted the specific technological improvements identified by Dr. McDaniel.
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`IV. CONCLUSION
`The Board’s final determination should find substitute claim 21 patentable.
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`Case No.: IPR2019-00715
`Attorney Docket No.: 21828-0041IP1
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`Dated: 29 May 2020
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`Fish & Richardson P.C.
`(Trial No. IPR2019-00715)
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`Respectfully submitted,
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`/Nicholas W. Stephens/
`Nicholas Stephens, Reg. No. 74,320
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`Attorney for Patent Owner
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`Case No.: IPR2019-00715
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR §42.6(e), the undersigned certifies that on May 29,
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`2020, a complete and entire copy of this Patent Owner’s Sur-Reply to Petitioner’s
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`Reply to Preliminary Guidance on Patent Owner’s Motion to Amend were
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`provided via email to the Petitioner by serving the email correspondence address of
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`record as follows:
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`Yar R. Chaikovsky
`David Okano
`Paul Hastings LLP
`1117 S. California Avenue
`Palo Alto, CA 94304
`Email: Snap-Blackberry-PH-IPR@paulhastings.com
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`Chad Peterman
`Paul Hastings LLP
`200 Park Avenue
`New York, NY 10166
`Email: Snap-Blackberry-PH-IPR@paulhastings.com
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`/Jessica K. Detko/
`Jessica Detko
`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`(612) 337-2516
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