UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.
`Petitioner
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`v.
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`UNILOC 2017 LLC
`Patent Owner.
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`Case IPR2019-00753
`Patent 7,587,207
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`PETITIONER’S REQUEST FOR REHEARING
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`PURSUANT TO 37 C.F.R. § 42.7
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.
`Petitioner
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`v.
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`UNILOC 2017 LLC
`Patent Owner.
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`____________
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`
`Case IPR2019-00753
`Patent 7,587,207
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`PETITIONER’S REQUEST FOR REHEARING
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`PURSUANT TO 37 C.F.R. § 42.7
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`Proceeding No.: IPR2019-00753
`Attorney Docket: 39521-0058IP1
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`TABLE OF CONTENTS
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`I.
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`INTRODUCTION ......................................................................................... 1
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`II. ARGUMENT .................................................................................................. 3
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`A.
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`The Majority’s Decision Misapprehends and/or Overlooks the
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`Bluetooth Capabilities of a Receiverless Beacon .............................. 3
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`B.
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`The Dissent’s Assessment of the Combination is Reasonable and
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`Should be Evaluated During a Trial ................................................ 12
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`III. CONCLUSION ............................................................................................ 15
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`Proceeding No.: IPR2019-00753
`Attorney Docket: 39521-0058IP1
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`I.
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`INTRODUCTION
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`Apple Inc. (“Petitioner”) respectfully requests rehearing of the September
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`16, 2019 Decision (“Decision”) denying institution of Inter Partes Review of
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`claims 1-3, 5-6, and 9–11 (the “Challenged Claims”) of U.S. Patent No. 7,587,207
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`(the “’207 Patent”) under 37 CFR § 42.71(d). In the Decision, Judges Smith and
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`Medley (“the Majority”) held that the Petition had not established a reasonable
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`likelihood that the Petitioner would prevail with respect to at least one of the
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`Challenged Claims. Paper 7, p 1. Judge Horvath issued a dissent (“the Dissent”).
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`Paper 7, p 1. As explained below, the Majority’s decision misapprehends and/or
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`overlooks critical technical teachings of the prior art and arguments advanced in
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`the Petition.
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`For example, the Majority’s decision misapprehends and/or overlooks
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`critical features of Bluetooth technology and the Bluetooth capabilities of a
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`receiverless beacon. Specifically, the Majority explained:
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`We also agree with Patent Owner that the Petition does
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`not explain why a transmitter that uses existing
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`Bluetooth technology and cannot receive an inquiry
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`response message (a) would send inquiry messages, and
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`(b) would add an additional data field to the inquiry
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`message, rather than use an existing alternative that
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`1
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`Proceeding No.: IPR2019-00753
`Attorney Docket: 39521-0058IP1
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`does not require modifying the standard Bluetooth
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`inquiry message. Paper 7, p 11.1
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`The problem with this statement, as explained by Dr. Knutson, is that it
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`assumes the existence of a Bluetooth alternative that does not exist. See Ex. 1003,
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`¶¶[51]-[52] (citing Ex. 1007, pp 108-10). Indeed, although Patent Owner argues
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`existence in Bluetooth of “any of a number of other alternatives,” Patent Owner
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`fails to demonstrate this with evidence – not even uncorroborated expert testimony,
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`and Patent Owner fails to even allege what alternative might be used. Paper 6, p
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`13. The only evidence on record (Dr. Knutson’s testimony and the teachings of
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`BT Core) confirms that “[t]he only way the beacon can provide information to
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`another device using Bluetooth is through a pre-connection inquiry message.” Ex.
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`1003, ¶¶[51]-[52], [79] (citing Ex. 1007, pp 108-10). With the full weight of
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`uncontroverted evidence supporting the Petition’s obviousness analysis, trial
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`should be instituted to allow proper vetting and full consideration of Patent
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`Owner’s unsupported argument that other alternatives exist. That type of vetting is
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`precisely the reason trials are instituted and decisions at institution are preliminary.
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`Accordingly, and for the reasons explained in more detail below, the
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`Majority’s decision misapprehends and/or overlooks critical features of Bluetooth.
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`
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` 1
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` All emphasis added, unless otherwise noted.
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`2
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`Thus, Petitioner respectfully requests reconsideration of the decision and
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`Proceeding No.: IPR2019-00753
`Attorney Docket: 39521-0058IP1
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`institution of Inter Partes Review.
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`II. ARGUMENT
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`A. The Majority’s Decision Misapprehends and/or Overlooks the
`Bluetooth Capabilities of a Receiverless Beacon
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`Several facts are undisputed:
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` McCall discloses a receiverless beacon that “transmits its identifying
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`signal continuously, or at intervals” (Ex. 1005, 4:10-16, 4:26-32; Paper 2,
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`p 10; Ex. 1003, ¶[42]);
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` McCall discloses multiple assets passively listening for the transmitted
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`signal (Id.);
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` McCall discloses using Bluetooth technology (Ex. 1005, 2:47-52 and 5:9-
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`23; Paper 2, p 10); and
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` McCall discloses the Bluetooth inquiry protocol, which involves
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`transmission of a broadcasted inquiry message received by any nearby
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`device (Id.; Ex. 1007, pp 108-10).
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`With this background, the dispute centers on whether McCall’s receiverless
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`beacon (1) transmits using Bluetooth’s inquiry protocol or (2) transmits using
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`another, alternative Bluetooth protocol. The Majority’s decision presupposes the
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`latter, but misapprehends and/or overlooks critical Bluetooth technology that
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`3
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`renders the latter impossible – alternative Bluetooth protocols are unavailable to
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`McCall’s receiverless beacon because, as explained in detail below, the
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`receiverless beacon cannot complete a Bluetooth connection with another device.
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`The Petition and Dr. Knutson explain that “the inquiry message is an initial
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`message used in the Bluetooth protocol to establish a connection between two
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`devices” and information received in an inquiry response “is needed to establish a
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`Bluetooth connection with another device.” Paper 2, pp 15, 29-30; Ex. 1003,
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`¶¶[51]-[52], [79]. Because McCall’s receiverless beacon cannot receive this
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`information, “McCall’s beacon cannot establish a Bluetooth connection with
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`another device” and, thus, cannot avail itself to alternative Bluetooth protocols
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`available upon connection. Id. Rather, as the Petition explained, because
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`McCall’s receiverless beacon is left without the information “needed to establish a
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`Bluetooth connection with another device,” Bluetooth’s pre-connection inquiry
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`protocol is the only Bluetooth protocol available for McCall’s receiverless beacon
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`to transmit Bluetooth messages to other devices. Id. Given these fundamental
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`properties of Bluetooth, which have not been disputed by competing expert
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`testimony or other evidence, Dr. Knutson concluded that a POSITA would have
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`found it obvious that McCall’s receiverless beacon transmits information using
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`Bluetooth’s inquiry protocol. Ex. 1003, ¶¶[48]-[52].
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`Dr. Knutson’s analysis is supported by a POSITA’s knowledge of Bluetooth
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`4
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`and portions of the BT Core specification cited in Dr. Knutson’s declaration. See
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`Ex. 1003, ¶¶[51]-[56] (citing Ex. 1007, pp 108-10). As explained in BT Core,
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`“[i]n the Bluetooth system, an inquiry procedure is defined which is used in
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`applications where the destination’s device address is unknown to the source.”
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`Ex 1007, p 108. Specifically, “[d]uring an inquiry substate, the discovering unit
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`collects the Bluetooth device addresses and clocks of all units that respond to the
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`inquiry message” and then uses the received Bluetooth device addresses and clocks
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`to “make a connection to any one of them by means of the previously described
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`page procedure.” Id. Because McCall’s receiverless beacon cannot receive the
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`necessary Bluetooth device addresses and clocks, McCall’s receiverless beacon
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`cannot use Bluetooth’s page procedure and cannot make a connection. Ex. 1003,
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`¶¶[51]-[52] (citing Ex. 1007, pp 108-10).
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`But, McCall’s receiverless beacon is not useless in Bluetooth – it can
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`transmit to other Bluetooth devices using Bluetooth’s inquiry protocol. Ex. 1003,
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`¶¶[48]-[51]; Ex. 1007, pp 108-10). As McCall describes, the receiverless beacon
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`“transmits its identifying signal continuously” (Ex. 1005, 4:10-16), just as a
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`Bluetooth device “continuously transmits the inquiry message … at different hop
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`frequencies” (Ex 1007, p 108). Nearby Bluetooth devices receive these
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`transmissions because Bluetooth devices “regularly enter[] the inquiry scan
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`substate” and look for inquiry messages transmitted at the different hop
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`5
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`frequencies defined by Bluetooth. Ex 1007, pp 108-09. Thus, as Dr. Knutson
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`explained with citation and support from the BT Core specification, Bluetooth’s
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`inquiry protocol provides McCall’s receiverless beacon with a mechanism to
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`transmit Bluetooth messages to other devices, even though McCall’s receiverless
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`beacon lacks the receiver needed to establish a connection and communicate using
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`other Bluetooth protocols and other Bluetooth messages. Ex. 1003, ¶¶[48]-[56]
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`(citing Ex. 1007, pp 108-10).
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`The fact that McCall’s receiverless beacon cannot receive an inquiry
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`response does not negate the relevance of Bluetooth’s inquiry protocol – “inquiry
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`response is optional” and “a unit is not forced to respond to an inquiry message.”
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`Ex. 1007, p 108. This portion of the Bluetooth specification clearly indicates that
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`the inquiry protocol is not used only when an inquiry response is needed,
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`confirming that McCall’s receiverless beacon is not restricted from using the
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`inquiry protocol simply because it has no receiver to receive inquiry responses.
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`Ex. 1007, pp 108-10.
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`The Majority decision misapprehends and/or overlooks these fundamental
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`principles of Bluetooth technology and the Bluetooth capabilities of McCall’s
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`receiverless beacon. The Majority contends that:
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`The combination teaches, at best, transmitting a beacon
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`identifier using a Bluetooth transmitter as taught by
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`6
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`McCall, where the beacon identifier includes the room
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`number of the beacon as taught by Hancock, in a
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`message other than an inquiry message. Paper 7, pp 9-
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`10.
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`What other message? As explained above, McCall’s receiverless beacon
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`cannot transmit other Bluetooth messages because it cannot establish a connection
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`with another Bluetooth device. Ex. 1003, ¶¶[51]-[52] (citing Ex. 1007, pp 108-10).
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`McCall’s receiverless beacon, however, can transmit inquiry messages because, as
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`discussed above, Bluetooth devices regularly scan for inquiry messages transmitted
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`over the different hop frequencies defined by Bluetooth’s inquiry protocol. Id.
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`Indeed, Bluetooth’s inquiry messages are precisely the types of messages that
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`McCall discloses as being continuously transmitted to any nearby devices. See Ex.
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`1005, 3:56-4:16 (“asset 122 transmits a signal inviting any beacons 102-112 within
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`range to respond;” “the beacon 102-112 transmits its identifying signal
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`continuously” and “asset[s] 120, 122 passively listen[] for beacons 102-112 that
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`are transmitting”); 5:19-23 (“This standard specifies an 'inquire' protocol whereby
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`a device transmits a specific sequence of data packets, and any 'listening' device
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`responds with its identifier”).
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`Neither Patent Owner nor the Majority identify another message in
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`Bluetooth that can be continuously transmitted to any nearby devices by a
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`7
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`Attorney Docket: 39521-0058IP1
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`receiverless beacon. In fact, Patent Owner’s contention that “any of a number of
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`other alternatives” exist, is without any evidentiary support in this record. Paper 6,
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`p 13; Paper 7, p 11. If Patent Owner is correct, that will be borne out through trial.
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`But, when the entire weight of the evidence suggests otherwise, trial is needed to
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`fully evaluate Patent Owner’s unsupported contention.
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`Additionally, in contending that McCall fails to disclose use of an inquiry
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`message in its receiverless beacon embodiment, the Majority places emphasis on
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`McCall’s reference to “the signal.” Paper 7, p 6. However, a full review of
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`McCall’s disclosure indicates that “the signal” referenced in this context refers to
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`the “identifying signal” or “unique identifier” transmitted by McCall’s beacons.
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`See Ex. 1005, 3:56-4:16 (“Beacons 102 and 104 respond with their unique
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`identifiers that are associated only with those beacons 102, 104;” “In an alternative
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`embodiment, the beacon 102-112 transmits its identifying signal continuously, or
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`at intervals”). McCall’s disclosure, thus, confirms that “the signal” includes
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`beacon ID data. A POSITA would not have interpreted reference to “the signal” to
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`mean that the identical message is used regardless of whether a beacon responds
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`with a signal or continuously initiates transmission of a signal. Indeed, as is
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`customary, Bluetooth defines different message formats for reply messages and
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`initiated messages. Ex. 1007, pp 110-112.
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`Further, the Majority places emphasis on McCall’s disclosure of “using
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`8
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`existing Bluetooth technology” and contends that McCall does not “implicate[]
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`modifying the structure of the standard inquiry message to accommodate location
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`information of the beacon.” Paper 7, p 8. Although McCall discloses using
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`Bluetooth, McCall also discloses using a receiverless beacon to transmit beacon
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`identification information. These points are undisputed. However, these two
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`points, when combined as in McCall, would inspire a POSITA to modify the
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`structure of an inquiry message because a receiverless beacon cannot otherwise
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`transmit beacon identification information using existing Bluetooth technology.
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`Ex. 1003, ¶¶[51]-[52]. In fact, this modification is the only way McCall’s
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`receiverless beacon transmission can be implemented using McCall’s preferred
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`implementation method—the Bluetooth protocol. Ex. 1005, 5:5-8, 2:48-52. As
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`explained above, McCall’s receiverless beacon cannot establish a connection to
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`nearby Bluetooth devices and can only transmit information to nearby Bluetooth
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`devices using Bluetooth’s inquiry protocol. Paper 2, pp 14-15. Yet, as recognized
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`in the Petition and by the Majority, a standard Bluetooth inquiry message does not
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`include a data field available to transmit beacon identification information. Paper
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`2, pp 15-17; Paper 7, p 8. For precisely this reason, and as explained by Dr.
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`Knutson, McCall’s disclosure would have motivated a POSITA to modify the
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`standard Bluetooth inquiry message to implement McCall’s receiverless beacon in
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`a Bluetooth environment. Ex. 1003, ¶¶[51]-[56].
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`Indeed, the modification of the inquiry message structure is directly
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`suggested by McCall’s reliance on the Bluetooth protocol to send beacon ID
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`information and McCall’s disclosure of a receiverless beacon. Paper 2, pp 14, 15.
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`Without modifying the Bluetooth inquiry message structure, McCall’s receiverless
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`beacon could not transmit the beacon ID information using any Bluetooth protocol.
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`Paper 2, pp 14, 15, 29, 30; Ex. 1003, ¶¶[79]-[81]. Petitioner’s arguments are
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`therefore based on “what the combined teachings of the references would have
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`suggested to those of ordinary skill in the art” and not hindsight or speculation. In
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`re Keller, 642 F.2d 413, 425 (Fed. Cir. 1981).
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`As to inquiry message modification, Dr. Knutson explains that “the payload
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`field is the most likely field to be used to carry data such as the beacon ID
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`information. This is at least because the header field includes very specific link
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`control information and is not used to transmit general data, whereas the payload
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`field can accommodate various types of data. Ex. 1007, pp 51, 62.” Ex. 1003,
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`¶[55]. “[T]he modified inquiry packet (reproduced below) would likely include a
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`payload field attached to the end of the access code fields of a typical inquiry
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`message to accommodate the beacon ID information,” as shown in the figures
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`below. Ex. 1003, ¶[56].
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`Attorney Docket: 39521-0058IP1
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`Dr. Knutson further explains that:
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`
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`a POSITA like myself could readily appreciate the
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`placement of the payload at the end of a Bluetooth inquiry
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`message as an obvious and predictable design choice since
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`such a structure is similar to the standard Bluetooth
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`protocol packet format (note that the payload field in a
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`standard Bluetooth packet is also placed at the end of a
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`data packet). For example, the inquiry message packet
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`structure would resemble the structure of an inquiry
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`response message, which includes a payload field
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`appended to the header and access code fields, as shown
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`in the standard Bluetooth packet format. Ex. 1007, pp. 56,
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`110, 112. Ex. 1003, ¶[57].
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`For these reasons, the Petition explained both how and why the prior art
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`(McCall, BT Core, and Larsson) suggested modification of Bluetooth inquiry
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`messages to implement McCall’s receiverless beacon in a Bluetooth environment.
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`Paper 2, pp 13-17; Paper 7, p 19. Indeed, with a full understanding of Bluetooth
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`technology, these modifications are apparent and supported by the BT Core and
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`Larsson references cited in the Petition. Paper 2, pp 13-17, 20-24. Thus, for the
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`Attorney Docket: 39521-0058IP1
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`reasons discussed above, the Majority’s decision misapprehends and/or overlooks
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`critical features of Bluetooth and Petitioner respectfully requests reconsideration in
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`view of the explanation above.
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`B.
`The Dissent’s Assessment of the Combination is Reasonable and
`Should be Evaluated During a Trial
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`As recognized in the Dissent, although the combination advanced in the
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`Petition relies on four references, the combination is straightforward and relies on
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`secondary references to explain how a POSITA would have implemented details of
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`McCall’s receiverless beacon. Paper 7, pp 15-22. Specifically, as explained in the
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`Petition, Petitioner asserted that the Challenged Claims were obvious over McCall
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`(Ex. 1005), BT Core (Ex. 1007), Larsson (Ex. 1014), and Hancock (Ex. 1006).
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`Paper 2, pp 2, 26-37; Paper 7, 16. To recap, McCall disclosed “a method to track
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`the location of objects using beacons of a wireless communication network that are
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`physically dispersed in a building, as shown in FIG. 1. Ex. 1005, 1:1-5, Abstract.”
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`Paper 2, p 9. McCall’s beacons transmit, to assets, beacon identification numbers
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`(IDs) that identify the transmitting beacon and enable determination of asset
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`location. Ex. 1005, 3:58-65, 4:10-16, 4:26-32; Paper 2, p 10. “Communications in
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`McCall’s wireless communication network are implemented using the Bluetooth
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`protocol. Ex. 1005, Abstract, 2:47-52, 5:5-15.” Paper 2, p 9; Paper 7, p 16.
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`McCall does not provide the specific implementation details of the
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`Bluetooth protocol used for communications between a beacon and an asset. Paper
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`2, pp 11, 13; Paper 7, p 17. The Dissent recognized that the Petition then
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`reasonably, without relying on hindsight and speculation and just as a skilled
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`artisan would, turns to BT Core, a document published by Bluetooth, “to
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`understand how McCall’s invention … could be implemented in a Bluetooth
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`environment.” Paper 2, pp 11, 13, 14; Paper 7, p 17.
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`BT Core discloses that an inquiry message can be used in Bluetooth
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`protocols when a transmitting device does not know the addresses of other nearby
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`devices—the identical scenario to McCall’s receiverless beacon transmitting
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`signals. Ex. 1007, pp 108-10; Paper 2, pp 11, 12. The Dissent correctly explained
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`that, “because McCall’s receiverless beacon cannot receive an inquiry response
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`message, the only way McCall’s receiverless beacon can transmit its beacon ID to
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`the receiver is via the inquiry message” disclosed by BT Core. Paper 7, p 19;
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`Paper 2, pp 14-16. “Moreover, because BT Core teaches the standard inquiry
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`message consists of a preamble and sync word without a header or payload, the
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`only way McCall’s receiverless beacon can transmit its beacon ID to the unknown
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`receiver is to modify the standard Bluetooth inquiry message.” Id.
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`Hancock was relied upon in the Petition to substitute McCall’s beacon IDs
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`with Hancock’s location information. Paper 2, pp 24-27.
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`Larsson corroborates the use of a length indicator or piggyback indicator “as
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`an indication of an additional data field being added to a message.” Paper 2, pp
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`18-20; Paper 7, pp 20-21. As explained in the Petition and acknowledged by the
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`Dissent, in the combination of McCall, BT Core, Hancock, and Larsson, “[t]he
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`piggyback indicator would alert the receiver ‘to the presence of an additional data
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`field’ when added to the access code of the modified inquiry message, thereby
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`preventing the receiver from sending ‘unnecessary inquiry response messages.’”
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`Paper 2, p 23; Paper 7, p 21.
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`For these reasons, McCall, BT Core, Larsson, and Hancock render obvious
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`all features of claims 1-3, 5-6, and 9–11 of the ’207 Patent. The four-reference
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`combination should not detract from the soundness of the combination and
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`Petitioner’s reasoning. Paper 2, pp 8, 9; Paper 7, p 21. “The criterion [for
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`obviousness] is not the number of references, but what they would have meant to a
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`person of ordinary skill in the field of the invention.” Id. (quoting In re Gorman,
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`933 F.2d 982, 986 (Fed. Cir. 1991)).
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`14
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`Proceeding No.: IPR2019-00753
`Attorney Docket: 39521-0058IP1
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`III. CONCLUSION
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`For the foregoing reasons and those previously presented in the Petition,
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`Petitioner requests that the Board institute an inter partes review of claims 1-3, 5-
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`6, and 9–11 of the ’207 Patent.
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`
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`Dated: October 16, 2019
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`
`Dated: October 16, 2019
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`
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`Respectfully submitted,
`
`___
`
` /Jeremy J. Monaldo/
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`
` /W. Karl Renner/
`W. Karl Renner, Reg. No. 41,265
`Jeremy J. Monaldo, Reg. No. 58,680
`Roberto J. Devoto, Reg. No. 55,108
`Fish & Richardson P.C.
`3200 RBC Plaza, 60 South Sixth Street
`Minneapolis, MN 55402
`T: 202-783-5070
`F: 877-769-7945
`
`Attorneys for Petitioner
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`Proceeding No.: IPR2019-00753
`Attorney Docket: 39521-0058IP1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR §§ 42.6(e)(4) et seq. and 42.205(b), the undersigned
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`certifies that on October 16, 2019, a complete and entire copy of this Petitioner’s
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`Request for Rehearing was provided via electronic service, to the Patent Owner by
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`serving the correspondence address of record as follows:
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`
`
`Ryan Loveless
`Brett Mangrum
`James Etheridge
`Jeffrey Huang
`Etheridge Law Group
`2600 E. Southlake Blvd., Ste. 120-324
`Southlake, TX 76092
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`Email: ryan@etheridgelaw.com
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` brett@etheridgelaw.com
`jim@etheridgelaw.com
` jeff@etheridgelaw.com
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`/Diana Bradley/
`Diana Bradley
`Fish & Richardson P.C.
`3200 RBC Plaza, 60 South Sixth Street
`Minneapolis, MN 55402
`(858) 678-5667
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