UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`——————
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`ALARM.COM INC.
`Petitioner
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`v.
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`VIVINT, INC.
`Patent Owner
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`——————
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`Case IPR2016-00116
`Patent 6,147,601
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`——————
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`PETITIONER’S RESPONSE TO PATENT OWNER’S MOTION FOR
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`OBSERVATION ON CROSS EXAMINATION OF REPLY WITNESS
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`ARTHUR ZATARAIN
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`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`US Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`
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`——————
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`ALARM.COM INC.
`Petitioner
`
`v.
`
`VIVINT, INC.
`Patent Owner
`
`——————
`
`Case IPR2016-00116
`Patent 6,147,601
`
`——————
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`PETITIONER’S RESPONSE TO PATENT OWNER’S MOTION FOR
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`OBSERVATION ON CROSS EXAMINATION OF REPLY WITNESS
`
`ARTHUR ZATARAIN
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`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`US Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
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`Case IPR2016-00116 of
`U.S. Patent No. 6,147,601
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`Patent Owner Vivint submits 22 observations, none of which undermine
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`Petitioner Alarm.com’s record evidence or further develop any existing issue in
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`this case. Thus, as set forth below, all of the observations should be disregarded.
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`Response to Observation 1: Vivint cites testimony suggesting that Mr.
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`Zatarain did not “select[] the arguments” in his Reply Declaration and that attorney
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`“wordsmithing” of Mr. Zatarain’s declaration is “relevant to the credibility of Mr.
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`Zatarain’s opinions”. Pat. Owner’s Mot. at 1 (“Motion”) (citing Ex. 2018, 7:2-25).
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`This observation should be disregarded for at least two reasons. First, Mr. Zatarain
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`testified unequivocally that his Declaration was “my content, my reply”, that the
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`attorneys identified topics addressed by Mr. Denning (Vivint’s expert), and that the
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`attorneys assisted him in formatting citations and other similar clerical work. See
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`id. at 7:17-22, 8:1-8. Second, Vivint’s claim about Alarm.com’s attorneys
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`“select[ing] the arguments” is also without merit, as the attorneys merely generated
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`a list of the “arguments” or “topics” raised by Patent Owner in its Response. See
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`Ex. 2018, 7:13-15. There is no reason to doubt the sincerity of Mr. Zatarain’s
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`opinions, and Vivint does not identify any specific opinion it claims is not credible
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`for this reason.
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`Response to Observation 2: Vivint cites Mr. Zatarain’s agreement that “a
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`system that only obtains data from storage and does not write to storage” comports
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`with the definitions of “access” cited in his Reply Declaration and therefore that
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`the user interface in Shetty could not be used to modify user profiles. Motion at 1-
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`2. That conclusion is without merit. Mr. Zatarain’s testimony does not contradict
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`his opinions because he opines that a person of ordinary skill in the art (“POSA”)
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`would understand the word “access” to include both read-only and read-write
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`systems. See Ex. 1130, ¶ 56; see also Ex. 2018, 13:23-14:4 (“access” applies to
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`both reading and/or writing); 16:4-9 (same); 17:4-10 (same); 18:5-14 (same). In
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`addition, the plain language definitions of access encompass both reading and
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`writing data, and other disclosures in Shetty make clear to a POSA that users of the
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`system can use the interface to configure the profiles (Ex. 1130, ¶¶ 44-50, 61-72).
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`Response to Observation 3: Vivint cites testimony of Mr. Zatarain stating
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`that he paraphrased, rather than quoted, Mr. Denning with regard to Mr. Denning’s
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`testimony that the word “access” includes both reading and writing data.
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`Regardless of whether Mr. Denning used the words “as well as”, Mr. Denning
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`testified that he agreed that both “retrieval” of data (reading) and “update” of data
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`(writing) are “access operations”. Ex. 1118, 39:13-19. Thus, there is no
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`substantive difference in meaning, and Mr. Denning’s testimony supports Mr.
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`Zatarain’s contentions concerning a POSA’s understanding of the word “access”.
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`See Ex. 1130, ¶¶ 51-55.
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`Response to Observation 4: Vivint cites Mr. Zatarain’s statement that the
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`Shetty reference discloses three logical databases as somehow “undermin[ing]” his
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`supposed argument that “allowing [a] user to input [sic] into the [Shetty] fleet and
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`machine database” means that “Shetty [also] discloses a user inputting data into the
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`user profile database”. Motion at 2-3 (citing Ex. 1130, ¶ 49). But Mr. Zatarain
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`never contended that the fleet and machine database and the user profile database
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`are the “same database”; instead he opined that adding data to the user profile
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`database is consistent with Shetty’s express disclosures about the fleet and machine
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`database. Specifically, Mr. Zatarain explained that Shetty teaches a customizable
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`system to solve “the problem of having too much data to analyze” with the solution
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`being a “system [that] allows for the users to decide what events they want to be
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`notified about and . . . how the system should contact them”. Ex. 1130, ¶ 47. In
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`that context, Mr. Zatarain explained that a system would be useless if new fleet and
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`machine data could be added to the system, but users could not be notified of
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`events concerning the newly-added machines. Id., ¶¶ 49; 70 (“a PHOSITA would
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`understand that the user profile database would also need to be modified when
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`changes are made to the fleet and machine data, so that notifications could be
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`received based on any new machines . . .”). The observation should be ignored.
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`Response to Observation 5: Vivint cites testimony from Mr. Zatarain
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`agreeing that the word “also” in the sentence “the user interface also allows the
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`user to input information relating to the fleet or machine data” informs a POSA
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`that user interface 110 would allow access to fleet and machine database 104,
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`rather than also reflecting on Shetty’s use of the word “access” in the preceding
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`sentence of the specification. Vivint misstates Mr. Zatarain’s testimony because it
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`is incomplete. In fact, Mr. Zatarain testified at page 32, lines 5 through 25 of
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`Exhibit 2018 that, “I think it’s using the words as they would be commonly known.
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`Access, input, reading, is all about working with the database, as is commonly
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`known.” Review of Mr. Zatarain’s complete testimony demonstrates that he did
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`not contradict his opinion, as reflected in paragraphs 69 and 70 of his Reply
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`Declaration.
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`Response to Observation 6: Vivint cites testimony that purportedly
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`“undermines” Mr. Zatarain’s argument “that databases are read-write unless
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`otherwise indicated”. Motion at 4 (citing Ex. 1130, ¶ 53). First, Mr. Zatarain did
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`not opine that “databases are read-write unless otherwise indicated”. Id. Rather,
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`he opined that, given the plain meaning of the word “access” and Shetty’s
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`unqualified use of that word, he would have expected Shetty to have made clear if
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`the user’s “access” was meant to be “read-only”. Second, Mr. Zatarain cited many
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`dictionary definitions of the word “access” to support his opinion that the plain
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`meaning of “access” includes read-write capabilities. Id.; see also Ex. 1130, ¶ 58
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`(addressing “special case” of online phone directory). The cited testimony does
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`not contradict Mr. Zatarain’s declaration; the observation should be disregarded.
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`Response to Observation 7: Vivint cites Mr. Zatarain’s testimony that there
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`are “two time periods” and argues that Mr. Zatarain “admitted he was reading
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`Shetty from a different context”. Motion at 4-5 (citing Ex. 2018, 42:4-10).
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`Vivint’s legal conclusion is incorrect. As a logical matter, the ’601 Patent’s use of
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`the word “access” cannot inform—and is irrelevant to—the meaning that Shetty
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`gave to the word “access”, because Shetty was written prior to the ’601 Patent.
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`Graham v. John Deere Co. of Kansas City, 383 U.S. 1, 36 (1966) (warning against
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`“the temptation to read into the prior art the teachings of the invention in issue”).
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`Response to Observation 8: Contrary to Vivint’s contention, whether rlogin
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`is enabled by default has no bearing on whether rlogin allows remote execution of
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`computer programs. Indeed, Vivint’s own evidence describes rlogin as enabling a
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`user to “use rlogin to log in on a remote host” and “then work on that system just
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`as [he] would on [his] home system”. Ex. 1130, ¶ 91(citing Ex. 2016, 13-12). In
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`addition, as to Mr. Zatarain’s personal usage of rlogin, Vivint misstates his
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`testimony. Mr. Zatarain in fact testified that he had used rlogin on some UNIX
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`systems, but could not recall whether that UNIX system utilized the HP-UX
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`operating system. Ex. 2018, 47:6-11.
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`Response to Observation 9: Regardless of whether rlogin is enabled by
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`default, as Vivint’s exhibit makes clear, a user can “use rlogin to log in on a remote
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`host” and “then work on that system just as [he] would on [his] home system”. Ex.
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`2016, 13-12. Additionally, whether or not enabled by default, “rlogin” does not
`5
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`Case IPR2016-00116 of
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`require any “programming”, as configuration—contrary to Vivint’s suggestion—is
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`not programming. Ex. 1130, ¶¶ 125-28. Finally, Mr. Zatarain only cited rlogin to
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`rebut Mr. Denning’s claim that remote shell access was limited to non-interactive
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`programs. Ex. 2018, 44:14-45:16; 47:12-20; Ex. 1130, ¶¶ 90-93.
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`Response to Observation 10: The cited testimony is taken out of context.
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`Whether rlogin and remote shell enable remote access is itself irrelevant, as Mr.
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`Zatarain cited rlogin only in response to Mr. Denning. Ex. 2018, 44:14-45:16;
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`47:12-20. As Mr. Zatarain noted, Shetty has a “clear” teaching of remote access.
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`Ex. 1130, ¶ 76; see also ¶¶ 78-84. Additionally, as Mr. Zatarain testified, “remote
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`logins were common among UNIX and HP-UX systems for many years prior to
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`the asserted patents”. Ex. 1130, ¶ 92. As such, the cited testimony is not relevant
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`to Mr. Zatarain’s assertions in paragraphs 92-93 of his Reply Declaration. In
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`addition, the disclosure of HP-UX in Shetty is consistent with Shetty’s teaching of
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`remote user workstations communicating with a central data manager, because
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`such capabilities were standard in the HP-UX operating system. Ex. 1107, ¶ 82.
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`Response to Observation 11: Vivint cites Mr. Zatarain’s testimony that “a
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`computer is going to have certain accessible and non-accessible things for a
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`particular user” and that rlogin will give a user the same access he would have had
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`locally. Motion at 6-7. Vivint states that this testimony “contradicts” Alarm.com’s
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`argument that Shetty teaches “remotely accessing [the] user profile database”. Id.,
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`Case IPR2016-00116 of
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`7. Vivint is incorrect. Regardless of whether rlogin allows a user to “access
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`everything”, Shetty states that the user can “access the data stored on the third
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`work station”, including the user profile database—a point that Mr. Zatarain
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`explained in detail in his Reply Declaration at paragraphs 78 to 84.
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`Response to Observation 12: Vivint contends that Mr. Zatarain admitted to
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`“new arguments in the Reply Declaration” that are not discussed in his Opening
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`Declaration. However, Vivint fails to cite any new argument in the Reply
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`Declaration (Ex. 1130) that is not discussed in the Opening Declaration (Ex. 1107).
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`For example, Vivint’s reference to paragraph 95 of the Reply Declaration is not
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`new because that paragraph expressly cross-references paragraphs 82 to 85 of the
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`Opening Declaration. Further, Vivint admits that Mr. Zatarain, in his Opening
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`Declaration, identified Shetty’s disclosure of users receiving notifications at
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`remote locations as a motivation to extend Shetty’s teachings to allow those users
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`to remotely configure user profiles as well. Motion at 7.
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`Response to Observation 13: Vivint states that Mr. Zatarain’s Reply
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`Declaration included supposedly “new Reply Declaration arguments that allege
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`commonality of remote configuration”. Vivint’s own argument contradicts its
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`claim. Vivint discusses the presence of remote configuration in commercial alarm
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`systems of the time—a point that Vivint acknowledges Mr. Zatarain identified and
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`discussed in his Opening Declaration at paragraph 84. Not only did Mr. Zatarain
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`Case IPR2016-00116 of
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`cite specific examples of such systems in paragraph 46 of the same declaration, but
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`Vivint also specifically responded to Alarm.com’s evidence at pages 26-28 of its
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`Response (Paper 20), demonstrating that Vivint understood Alarm.com’s
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`contentions and evidence and responded to them substantively.
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`Response to Observation 14: Vivint reiterates its argument that the need for
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`remote access by remote users was unknown prior to the ’601 Patent as support for
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`its incorrect claim that Mr. Zatarain used hindsight reasoning regarding his ease-
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`of-use opinions. This observation should be disregarded. For one thing, Vivint
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`already made this argument in its Response (Paper 20, 30-32), and Observation 14
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`is cumulative. In addition, Mr. Zatarain’s reply testimony demonstrates that the
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`need for remote access was known in preexisting alarm systems and thus not
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`hindsight. As Mr. Zatarain explained, some alarm systems of the time enabled
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`remote access while others did not. Ex. 2018, 132:13-133:3. He further explained
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`that it was a known problem that users would be required to travel to a central
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`location to configure the system for those alarm systems that did not enable remote
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`access. Id. Rather than “hindsight reasoning”, as Vivint contends, Mr. Zatarain’s
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`testimony relates to his experience with actual systems from the relevant time.
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`Finally, Mr. Zatarain disclosed several examples of such systems, with citations to
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`the record. See Ex. 1107, ¶¶ 45, 46; see also Ex. 2018, 135:2-14.
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`8
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`Case IPR2016-00116 of
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`Response to Observation 15: Vivint observes that the system described in
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`French provided for remote notification of users, but only local, and not remote
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`configuration. But neither Alarm.com nor Mr. Zatarain ever claimed that all pre-
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`existing alarm notification systems supported remote access. French was filed in
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`1990—years prior to the 1999 invention date at issue—and later prior art alarm
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`systems, such as Scadaware (manual dated 1994), Shetty (filed 1996), and Levac
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`(filed 1997), supported remote configuration, thus demonstrating that the industry
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`had (i) recognized the problem illustrated by French and (ii) arrived at the solution
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`well prior to the ’601 Patent’s filing date in 1999. See Ex. 1107, ¶¶ 46, 82, 110-11.
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`Thus, this observation adds nothing new and should be disregarded as cumulative,
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`including since Vivint raised this very issue in its Response (Paper 20, 26-28).
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`Response to Observation 16: Vivint misinterprets Mr. Zatarain’s reply
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`testimony to argue that Shetty and Verbatim are the only prior art systems he cited
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`as expressly teaching remote configuration. Mr. Zatarain did not agree with the
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`questioner’s assertion on page 75, lines 17-21 of Exhibit 2018 that he had cited
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`only Shetty and Verbatim for this proposition. In fact, in response to the question,
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`Mr. Zatarain expressly referred to the prior art system he developed, Scadaware.
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`Id., 76:21-23. Mr. Zatarain’s Opening Declaration cited both Scadaware (Ex.
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`1107, ¶ 46) and Levac (id., ¶¶ 110-11) as prior art systems that taught remote
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`configuration, as his testimony confirmed. Ex. 2018, 133:19-136:19.
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`Response to Observation 17: Vivint appears to contend that because Levac
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`and Scadaware are not part of the instituted grounds for the independent claims of
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`the ’601 Patent, they should be disregarded. For one thing, Levac and Scadaware
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`are cited as documentary support for Mr. Zatarain’s statement that, “By 1998 it
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`was common for remote notification systems (such as alarm auto-dialers) to
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`include remote configuration of callout phone numbers, alarm triggers, and other
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`system parameters.” Ex. 1107, ¶ 84; see also id., ¶¶ 46, 111. Parties may submit,
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`and the Board may consider, additional documentary evidence to establish the
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`knowledge of a POSA, even if such evidence is not part of the instituted grounds.
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`Genzyme Therapeutic Prods. Ltd. v. Biomarin Pharm. Inc., 825 F.3d 1360, 1369
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`(Fed. Cir. 2016) (“[T]he Board may consider a prior art reference to show the state
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`of the art at the time of the invention, regardless of whether that reference was
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`cited in the Board’s institution decision.”). In addition, Levac is prior art for the
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`instituted grounds for dependent claims 7, 19, 20, 28, 39 and 41.
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`Response to Observation 18: The cited testimony misconstrues
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`Alarm.com’s argument and is not relevant to Mr. Zatarain’s opinions on the
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`construction of the term “message profile”. Vivint and Mr. Denning argued that
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`the ’601 Patent, at column 4, lines 39-47, “explicitly define[d]” the term “message
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`profile.” Ex. 1130, ¶ 27 (internal citations omitted). Mr. Zatarain opined in his
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`Reply Declaration that, if that excerpt were a definition of message profile as
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`Vivint and Mr. Denning proposed, then all of the functionality stated in that
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`teaching—rather than some of the functionality—must be included in the
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`“definition” of message profile. Mr. Zatarain has consistently opined that this
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`excerpt does not reflect a definition of “message profile” (Ex. 1130, ¶¶ 28-29), and
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`Alarm.com has argued that “account” and “access via the internet” are not part of
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`the message profile (Reply, Paper 26, 2).
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`Response to Observation 19: Vivint cites Mr. Zatarain’s testimony as
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`purportedly relevant to whether Shetty teaches a “message profile” under Vivint’s
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`proposed construction of that term. Motion at 11-12. However, the testimony to
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`which Vivint refers—that Shetty “indicate[s] that a profile is tied to a specific
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`user”, (Ex. 2018, 94:11-13)—is entirely consistent with Mr. Zatarain’s opinion that
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`Shetty teaches a message profile even under Vivint’s construction:
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`“[E]ach profile identifies an individual who is to receive the
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`outgoing message, and how they are to be contacted. Ex. 1103
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`2:53-61 (defining multiple profiles for ‘user one’ and ‘user two’).
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`Because Shetty teaches multiple profiles for individual users, it
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`teaches a data record that specifies one or more devices associated
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`with one or more individuals to which an outgoing message can
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`be routed in response to an incoming exception message, even
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`under Patent Owner’s construction.” Ex. 1130, ¶ 43.
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`Thus, this observation adds nothing that Mr. Zatarain has not already stated in his
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`declaration, and should be disregarded as cumulative.
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`Response to Observation 20: The testimony cited by Vivint misconstrues
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`Mr. Zatarain’s testimony and is irrelevant. Motion at 12. An “equipment
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`identification code” is a “separate number” from a “communication device
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`identification code”. Ex. 2018, 111:4-112: 19. While an equipment identification
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`code could be an ESN, as Mr. Zatarain made clear, a “PHOSITA would not expect
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`the ‘communication device identification code’ of a user’s device that receives
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`outgoing messages to include an ESN without explicit disclosure in the Patent”.
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`Ex. 1130, ¶ 150; see also id., ¶¶148-49.
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`Response to Observation 21: The cited testimony regarding the Verbatim
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`reference (Ex. 1120) is not relevant to whether new arguments have been made.
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`By Vivint’s own admission, it “challenged” an argument that Mr. Zatarain made—
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`that “remote configuration was common in the art”—and Mr. Zatarain identified
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`the Verbatim reference (Ex. 1120) in response to that “challenge[]” of his
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`argument. For that reason, Exhibit 1120 is proper rebuttal evidence, and Mr.
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`Zatarain’s use of Exhibit 1120 is not relevant to whether Alarm.com and Mr.
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`Zatarain raised “new arguments and new evidence” in the Reply and Reply
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`Declaration, respectively. See Ex. 2018, 74:18-75:16 (detailing argument in Mr.
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`Zatarain’s Opening Declaration).
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`Response to Observation 22: Vivint claims that Mr. Zatarain did not
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`“specifically suggest any particular market pressures” to motivate a modification
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`of Shetty. Motion at 13. But the testimony cited by Vivint is incomplete, and the
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`observation should therefore be disregarded. Specifically, Vivint asks Mr. Zatarain
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`to locate “market pressures” in his Reply Declaration. Although the testimony that
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`Vivint cites, which references paragraphs 101 through 104 of Mr. Zatarain’s Reply
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`Declaration, does not identify a particular market pressure (Ex. 2018, 50:23-
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`51:10), Mr. Zatarain cites to paragraph 95 of his Reply Declaration in the
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`testimony that immediately follows, which does. The uncited testimony (Ex. 2018,
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`51:18-52:17) discusses motivations to modify Shetty, which Mr. Zatarain explains
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`constitute “market pressure or design emphasis” that would motivate a POSA.
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`Furthermore, paragraph 95 cites paragraphs 82 to 85 of Mr. Zatarain’s Opening
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`Declaration, in which he discusses the availability of remote configuration of
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`notification parameters in other alarm systems as a motivation to include that
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`feature in Shetty. Mr. Zatarain thus identified specific reasons to extend Shetty in
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`his Opening Declaration, and then cited to those reasons in his Reply Declaration,
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`as he explained in response to Vivint’s questioning at his deposition.
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`*
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`For the reasons cited above, Alarm.com respectfully submits the Board
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`should disregard all of Vivint’s observations.
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`Dated: January 10, 2017
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`Respectfully submitted,
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`By: /s/ Brian K. Shelton
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`Brian K. Shelton
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`Registration No. 50,245
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`Counsel for Petitioner
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a copy of the attached PETITIONER'S
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`RESPONSE TO PATENT OWNER'S MOTION FOR OBSERVATION ON
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`CROSS EXAMINATION OF REPLY was sent via electronic mail on January 10,
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`2017 to the following:
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`Robert G. Sterne (rsterne-PTAB@skgf.com)
`Jason D. Eisenberg (jasone-PTAB@skgf.com)
`PTAB@skgf.com
`STERNE, KESSLER, GOLDSTEIN & FOX
`1100 New York Avenue, N.W.
`Washington, DC 20005
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`Counsel of Record for the Patent Owner in this proceeding
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`Respectfully submitted,
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`By: /s/ Brian K. Shelton
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`Brian K. Shelton
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`Registration No. 50,245
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`Counsel for Petitioner
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`Dated: January 10, 2017
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