UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`
`ALARM.COM INC.,
`Petitioner
`v.
`
`VIVINT, INC.
`Patent Owner
`
`____________
`
`Case IPR2016-00116
`Patent 6,147,601
`___________________
`
`
`PATENT OWNER’S MOTION FOR OBSERVATION
`ON CROSS EXAMINATION OF REPLY WITNESS
`ARTHUR ZATARAIN
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`
`ALARM.COM INC.,
`Petitioner
`v.
`
`VIVINT, INC.
`Patent Owner
`
`____________
`
`Case IPR2016-00116
`Patent 6,147,601
`___________________
`
`
`PATENT OWNER’S MOTION FOR OBSERVATION
`ON CROSS EXAMINATION OF REPLY WITNESS
`ARTHUR ZATARAIN
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`
`
`
`
`Case IPR2016-00116
`U.S. Patent No. 6,147,601
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`EXHIBIT LIST
`
`Description
`January 27, 2016 Conference Call Transcript
`Excerpts from Microsoft Computer Dictionary, 3rd ed. (1997)
`Request for Certificate of Correction and Filing Receipt1
`Declaration of Scott A. Denning
`CV of Scott A. Denning
`Deposition transcript of Arthur M. Zatarain, taken July 11,
`2016
`Exhibit No. 1 for Deposition of Arthur M. Zatarain, taken July
`11, 2016
`Excerpts from Webster’s New World Dictionary of Computer
`Terms, 6th ed. (1997)
`Excerpts from Elmasri et al., Fundamentals of Database
`Systems, 3rd ed. (2000)
`Excerpts from Hewlett Packard, Using HP-UX, 1st ed. (1992)
`Excerpts from Leininger, HP-UX Developer’s Tool Kit (1995)
`Deposition transcript of Arthur M. Zatarain for his Reply
`Declaration, taken December 13, 2016
`
`
`
`
`Exhibit No.
`2001
`2002
`2003
`2010
`2011
`2012
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`2013
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`2014
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`2015
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`2016
`2017
`2018
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`U.S. Patent No. 6,147,601
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`Patent Owner respectfully requests the Board consider its Observations of
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`Petitioner’s declarant Dr. Zatarain’s Reply Declaration (Ex. 1130 or RD) and
`
`deposition transcript (Ex. 2018 or DT).
`
`I. Background
`Observation 1: Expert did not write final arguments in the Reply Declaration.
`
`When asked about his process for preparing the Reply Declaration, Mr.
`
`Zatarain replied that “the attorneys selected the arguments that they wanted to
`
`make.” (Ex. 2018, 7:2-15.) After claiming to have prepared some of the
`
`declaration, Mr. Zatarain admitted that “the attorneys would wordsmith that to put
`
`it into the precise language that they require,” stating that “I think some of it is
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`their own preference.” (Ex. 2018, 7:16-25.) This is relevant to the credibility of
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`Mr. Zatarain’s opinions.
`
`II. Shetty’s disclosure of accessing user profiles does not teach
`configuration of the profiles
`Observation 2: Mr. Zatarain agrees that access can mean a system that only
`obtains data.
`
`Mr. Zatarain admitted that “a system that only obtains data from storage and
`
`does not write to storage access[es] data within the meaning of the definition” in
`
`the IEEE dictionary (Ex. 1126) that he provided in his Reply Declaration. (Ex.
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`2018, 13:18-25, 42:16-43:5.) He also made similar admissions with respect to the
`
`other dictionary definitions he cited in paragraph 56 of his Reply Declaration. (Ex.
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`2018, 16:4-9, 17:4-10, 18:5-14.) This is relevant because it shows that Shetty’s
`
`disclosure of accessing user profiles does not teach configuring the profiles, as
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`recited in claims 1 and 22.
`
`Observation 3: Mr. Zatarain acknowledged that only Alarm.com’s counsel
`and not Mr. Denning said that both reading “as well [a]s” writing are
`required to access.
`
`When asked about how he characterized the deposition testimony from
`
`Vivint’s expert Mr. Denning (Ex. 1130, ¶55), Mr. Zatarain admitted that Mr.
`
`Denning did not “repeat” the words “as well [a]s” used by Mr. Denning’s
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`questioner – Alarm.com’s counsel. (Ex. 2018, 20:11-19.) Mr. Zatarain further
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`admitted that Mr. Denning “is saying that [access] could only be one [of reading or
`
`writing] but he doesn't say that it's excluded.” (Ex. 2018, 21:3-15.) Mr. Zatarain
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`also admitted that Mr. Denning is “characterizing access as including the options to
`
`read or write, not exclusively; that they both could be done under the definition of
`
`access.” (Ex. 2018, 21:15-19.) This statement is relevant because it clarifies, if not
`
`contradicts, Mr. Zatarain’s claim in his Reply Declaration that Mr. Denning had
`
`testified that access involves reading “as well is” (sic) writing. (Ex. 1130, ¶ 55.)
`
`Observation 4: Mr. Zatarain acknowledged that the fleet and machine
`database and user profile database are separate databases.
`
`When asked whether Figure 1 shows that “the fleet machine data, the user
`
`profile data and event data are stored in the same database,” Mr. Zatarain admitted,
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`“It shows them as separate, logical databases, whether in the same physical
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`database is doesn’t really say. From a logical standpoint it is disclosing them as
`
`three separate entities.” (Ex. 2018, 28:6-16.) This is relevant because it undermines
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`Mr. Zatarain’s claim that somehow by allowing user to input into the fleet and
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`machine database, Shetty discloses a user inputting data into the user profile
`
`database. (See Ex. 1130, ¶ 49.)
`
`Observation 5: Mr. Zatarain admits that the purpose of the word “also” in a
`critical sentence in Shetty for Alarm.com’s case is to make up for a
`shortcoming in Shetty’s FIG. 1.
`
`When asked whether the sentence in Shetty that “the user interface also
`
`allows the user to input information relating to the fleet or machine data” is there
`
`so that a POSA looking at Figure 1 would know that interface 110 can also be used
`
`to enter information into database 104, Mr. Zatarain admitted, “[T]hat sentence
`
`serves that purpose.” (Ex. 2018, 29:3-30:25.) This is relevant because it shows
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`another meaning for the word “also” other than describing the write capabilities of
`
`the user interface with respect to the user profile database, as argued in Mr.
`
`Zatarain’s Reply Declaration and Petitioner’s Reply. (See Ex. 1130, ¶ 69;
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`Petitioner’s Reply, p. 6.)
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`Observation 6: Mr. Zatarain could not point to any evidence that supports his
`opinion that a “read-only” database is required to be explicitly labeled.
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`Mr. Zatarain was asked, “Do you provide any evidence that it is always
`
`stated in a document if it is going to be a read-only database?” (Ex. 2018, 37:21-
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`23.) He admitted “the evidence would be all the [dictionary] definitions we gave of
`
`‘access’ that include read or write as commonly available.” (Ex. 2018, 37:25-38:4.)
`
`Mr. Zatarain also admitted that accessing a read-only database would satisfy the
`
`proffered definitions of “access.”1 He further admitted there can be read-only
`
`access to a telephone directory. (Ex. 2018, 38:17-39:15.) And he admitted he
`
`provided no express statement that explicitly describes to a telephone directory
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`database as read-only. This is relevant because it undermines the testimony in Mr.
`
`Zatarain’s Reply Declaration stating that databases are read-write unless otherwise
`
`indicated. (Ex. 1130, ¶ 53.)
`
`Observation 7: Mr. Zatarain acknowledged that he was reading words in
`Shetty based on a POSA at the time of Shetty and not at the time of the ’601
`patent.
`
`In paragraph 74 of his Reply Declaration, Mr. Zatarain stated that “’601
`
`Patent’s treatment of the term ‘access’ is not relevant at all to how that term was
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`earlier used by Shetty.” During deposition, Mr. Zatarain stated: “There is two time
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`periods [Shetty and the ’601 patent], two separate patents and two different
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`1 See Observation 1.
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`interpretations of the word ‘access.’” (Ex. 2018, 41:13-16.) This is relevant
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`because the time of the invention is the only relevant time period, and Mr. Zatarain
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`admitted he was reading Shetty from a different context. (Ex. 2018, 42:4-10.)
`
`III. Shetty’s disclosure of HP-UX does not teach that Shetty’s user profile
`access can be done remotely.
`
`Observation 8: Mr. Zatarain admitted he lacked any knowledge of whether
`the rlogin command is enabled by default and could not recall ever setting up
`rlogin.
`
`When asked whether rlogin is “enabled by default for an HP-UX computer,”
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`Mr. Zatarain admitted “I would have to research.” (Ex. 2018, 45:17-20.) And when
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`asked whether he had “ever configured an HP-UX computer to use rlogin,” he said
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`“I don't recall. It was a long time ago.” (Ex. 2018, 46:19-22.) This is relevant
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`because it undermines Mr. Zatarain’s testimony in his Reply Declaration that “A
`
`PHOSITA would understand that remote login (as done with the rlogin command)
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`allows a user to run programs on one computer while interacting with the program
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`from another computer.” (Ex. 1130, ¶ 91.)
`
`Observation 9: Mr. Zatarain backtracked from his discussion of default
`enablement of rlogin discussed in his Reply Declaration.
`
`When asked whether rlogin is “enabled by default for an HP-UX computer,”
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`Mr. Zatarain admitted “I would have to research.” (Ex. 2018, 45:17-20, 46:19-22.)
`
`This is relevant because Mr. Zatarain answered differently than his Reply
`
`Declaration, which explicitly states that configurations are required to enable
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`rlogin. (Ex. 1130, ¶ 126.) This is also relevant because the Petitioner’s Reply,
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`while quoting Mr. Zatarain’s Reply Declaration, only highlighted “no
`
`programming whatsoever would be needed,” but did not discuss the portions of the
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`Reply Declaration that state that configurations are needed to enable rlogin.
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`(Petitioner’s Reply, p. 13.)
`
`Observation 10: Mr. Zatarain admitted that rlogin is not taught in Shetty and
`that setting it up in Shetty would require system administration beyond the
`scope of the Shetty.
`
`Mr. Zatarain admitted that HP-UX’s rlogin and remote shell commands are
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`“[ir]relevant to the claims or overall description in Shetty.” (Ex. 2018, 46:5-10.)
`
`He also stated that rlogin would require “computer administration that is beyond
`
`the scope of the patents.” (Ex. 2018, 48:17-49:8.) This is relevant because it
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`undermines Mr. Zatarain’s assertion that Shetty’s disclosure of HP-UX somehow
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`discloses that Shetty allows access to its user profile database that is remote. (Ex.
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`1130, ¶¶ 92-93.)
`
`Observation 11: Mr. Zatarain admitted that rlogin does not make access of
`some data into access of all data.
`When asked whether rlogin allows a user to “access everything on that
`
`computer,” Mr. Zatarain answered that “a computer is going to have certain
`
`accessible and non-accessible things for a particular user,” and with rlogin “you
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`would have access to whatever you would have access to.” (Ex. 2018, 47:21-
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`48:16.) Mr. Zatarain admitted that remote access of some data does not mean
`
`remote access of all data. (Id.) This is relevant because Mr. Zatarain contradicts
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`Petitioner’s Reply that argued Shetty’s user “access the data stored on the third
`
`work station” teaches remotely accessing user profile database (Petitioner’s Reply,
`
`pp. 8-9), because Shetty makes no disclosure that the accessed “data” in its
`
`Column 4 is the user profile database accessed through user interface 110 in its
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`Column 2.
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`IV. No motivation exists for modifying Shetty to allow remote configuration
`to the user profile database
`
`Observation 12: Mr. Zatarain admitted that his Original Declaration provides
`no evidence or discussion of the new arguments in the Reply Declaration
`directed to a problem Shetty is trying to resolve, or a design need or market
`pressure to modify Shetty.
`
`When asked whether his Original Declaration “talk[s] about design need or
`
`market pressure for changing Shetty,” Mr. Zatarain responded that “I don't
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`specifically suggest any particular market pressures.” (Ex. 2018, 50:23-51:10.) On
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`redirect Mr. Zatarain stated that paragraph 83 of his Original Declaration is
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`“describing the problem of remote user notification.” (Ex. 2018, 131:20-21.)
`
`Admitting he is relying on remote notification and not remote configuration is
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`relevant because it illuminates Mr. Zatarain’s claim that “a PHOSITA would have
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`been motivated to extend Shetty’s teaching of ‘access’ to remote configuration of
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`the user profile database.” (Ex. 1130, ¶ 95.)
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`Observation 13: Mr. Zatarain’s Original Declaration does not provide
`evidence to support the new Reply Declaration arguments that allege
`commonality of remote configuration in the art.
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`On redirect Mr. Zatarain stated that paragraph “84 [of his Original
`
`Declaration] describes that it was common for remote notifiers such as an auto-
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`dialer to include remote configuration of things like callout numbers, alarm
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`triggers and other parameters.” (Ex. 2018, 131:22-132:5.) Mr. Zatarain admitted
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`this without citation to Shetty or other prior art reference in paragraph 84 of his
`
`Original Declaration. (Id., 143:9-15.) This is relevant because Mr. Zatarain
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`admitted he provided no evidence that commonality alone shows why a person
`
`skilled in the art would modify Shetty. (Ex. 1130, ¶ 99.)
`
`Observation 14: Mr. Zatarain’s testimony regarding ease-of-use shows his
`hindsight reasoning.
`
`On redirect Mr. Zatarain stated that “the problem is if you can’t alter that
`
`system remotely would mean you have to go to a central location. So that would be
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`the problem he would be aware of, that some systems didn’t have that feature and
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`it would be a problem.” (Ex. 2018, 132:21-133:3.) This is relevant because the
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`only teaching of an ease-of-use problem in the record is in the ’601 patent itself
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`where it describes its solution to allow remote configuration of the message profile.
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`(Ex. 1101, 2:3-5, 2:25-27.)
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`Observation 15: Mr. Zatarain now admits that systems, such as the one
`described in French, provide remote notification with a message profile that
`can only be locally configured.
`
`Mr. Zatarain was asked, hypothetically, whether “a system [could] provide
`
`remote notification with a message profile that can only be locally configured.”
`
`(Ex. 2018, 53:17-19.) In response, Mr. Zatarain admitted “It is not just
`
`hypothetical. There is a reference, we had used French, which had local
`
`configuration of the equivalent of the user profile in the French patent, for
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`example, which used fax notifications. It was an example of one that has local
`
`configuration.” (Id., 53:24-54:6.) This is relevant because the existence of systems,
`
`other than Shetty, that had remote notification, but not remote message profile
`
`configuration as claimed, undermines Mr. Zatarain’s statement in his Original and
`
`Reply Declarations that Shetty’s teaching alone was being used to show remote
`
`notification would somehow suggest remote configuration of user profiles. (Ex.
`
`1107, ¶ 83; Ex. 1130, ¶ 99.)
`
`Observation 16: The only evidence that allegedly describes remote
`configuration of a message profile is new and not part of the instituted
`grounds.
`
`Mr. Zatarain admitted that the only reference outside of Shetty that Mr.
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`Zatarain alleged explicitly teaches remote configuration of a message profile was a
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`new document, Verbatim, which was not provided until Mr. Zatarain’s Reply
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`Declaration. (Ex. 2018, 74:17-77:3.) This is relevant because it undermines Mr.
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`Zatarain’s claim that remote configuration was common in the art at the time. (Ex.
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`1130, ¶ 99.)
`
`Observation 17: Mr. Zatarain admitted Levac, which is not part of the
`instituted ground for the independent claims, was being relied upon for
`remote configuration of a message profile.
`
`On redirect Mr. Zatarain admitted that “Levac [is] an example of one of the
`
`systems that existed at the time that provided for remote configuration of
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`something like message profile the systems that existed at the time that provided
`
`for remote configuration of something like message profile” and that the
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`Scadaware system provided for remote configuration of a message profile. (Ex.
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`2018, 135:2-11.) This is relevant because Levac and Scadaware were only applied
`
`in the Petition for independent claims for uninstituted grounds2 in this inter partes
`
`review and a previous one. (Paper 14, p. 46; Patent Owner’s Response, p. 27.)
`
`V. Shetty’s user profile is not a message profile as claimed.
`Observation 18: Mr. Zatarain admits that the claimed message profile need
`not include elements beyond those proposed by Patent Owner.
`
`Petitioner traversed Patent Owner's proposed construction of message profile
`
`and Patent Owner’s reliance on the ’601 patent arguing: “[t]hat passage [from the
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`2 In re Nuvasive, Inc. 841 F.3d 966, 972-73 (Fed. Cir. 2016) (holding the
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`Board cannot rely on grounds of unpatentability that are not instituted.)
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`’601 Patent] identifies several implementation details of the preferred embodiment
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`that are not limitations of the independent claims: a user account; accessing a
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`server via the internet; specifying types of communication devices and the
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`specification of multiple individuals,” and that “[t]o make such details part of the
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`term construction improperly imports the specification into the claims.”
`
`(Petitioner’s Reply, p. 2.) This is relevant because Mr. Zatarain admitted that the
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`disclosed “account” and “access via the Internet” do not relate to the message
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`profile itself, but rather “to the mechanism by which [the contractor] is going to
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`access the message profile to configure [the message profile]” (Ex. 2018, 91:16-
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`24.) This is also relevant because Mr. Zatarain's testimony contradicts Petitioner’s
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`argument because the testimony demonstrates that the disclosed account and
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`Internet access in the above excerpt are not disclosed as being part of the message
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`profile, and thus are not required to properly construe “message profile.”
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`Observation 19: Mr. Zatarain admitted that Shetty’s profile is for a specific
`user.
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`Mr. Zatarain admitted that Shetty “indicate[s] that a profile is tied to a
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`specific user” (Ex. 2018, 94:11-13.) Mr. Zatarain admitted that “[e]ach user would
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`have multiple profiles but they would be for that user.” (Id., 95:2-3.) This is
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`relevant to Petitioner’s Reply arguing Shetty teaches Vivint’s construction of the
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`message profile (Petitioner’s Reply, p. 3), because it shows that Shetty does not
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`teach the correct construction of message profile set forth in the POR, which is
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`“data record including instructions specifying which communication device
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`associated with which individuals an outgoing message can be routed in response
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`to an incoming exception message.”
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`VI. Shetty does not disclose a communication device identification code.
`Observation 20: Mr. Zatarain admitted that an electronic serial number could
`at least be an identification code for the equipment.
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`When asked what his understanding of an equipment identification code is,
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`Mr. Zatarain admitted the code may be an ESN. (Ex. 2018., 112:4-17.) This is
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`relevant because it undermines Mr. Zatarain’s assertion that an ESN cannot be a
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`communication device identification code as claimed, given the fact that the 601
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`patent describes both as in “identification code.” (Ex. 1130, ¶ 151.)
`
`VII. Mr. Zatarain added new arguments and new evidence in his Reply
`Declaration beyond the scope allowed under 37 C.F.R. § 42.23(b)
`Observation 21: Mr. Zatarain admitted that he added the Verbatim reference.
`
`Mr. Zatarain admitted that he added the Verbatim reference (Ex. 1120) in his
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`Reply Declaration because his point (remote configuration being common in the
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`art) was “challenged.” (Ex. 2018, 75:23-76:20, 80:23-81:4.) This is relevant to
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`whether new arguments and new evidence raised in Petitioner’s Reply and the
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`Reply Declaration are within the scope of 37 C.F.R. § 42.23(b).
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`Observation 22: Mr. Zatarain admitted that he did not provide a “finite
`number of solutions” rationale in his Original Declaration.
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`As discussed in Observation 12, Mr. Zatarain admitted that he did not
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`“specifically suggest any particular market pressures.” (Ex. 2018, 50:23-51:10.)
`
`Mr. Zatarain’s Reply Declaration states “I understand that when there is a design
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`need or market pressure to solve a problem and there are a finite number of
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`identified, predictable solutions, a person of ordinary skill has good reason to
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`pursue the known options within his or her technical grasp.” (Ex. 1130, ¶ 102.)
`
`This is relevant to Petitioner’s Reply and Mr. Zatarain’s Reply Declaration arguing
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`a finite number of solutions rationale, because Mr. Zatarain’s Original Declaration
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`(and to that extent, the petition) provides no analysis regarding this new rationale.
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`(Petitioner’s Reply, 10-11; Reply Declaration, ¶ 103.)
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`Respectfully submitted,
`
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`
`
`
` /Jason D. Eisenberg/
`
`Jason D. Eisenberg, Reg. No. 43,447
`Attorney for Patent Owner
`
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`
`Date: December 20, 2016
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that the foregoing PATENT OWNER'S
`
`MOTION FOR OBSERVATION ON CROSS EXAMINATION OF REPLY
`
`WITNESS ARTHUR ZATARAIN and Exhibit 2018, was served electronically
`
`via e-mail on December 20, 2016, in its entirety on the following:
`
`William H. Mandir (wmandir@sughrue.com)
`Roger G. Brooks (rgbrooks@cravath.com)
`Teena-Ann V. Sankoorikal (tsankoorikal@cravath.com)
`Marc J. Khadpe (mkhadpe@cravath.com)
`Brian K. Shelton (bshelton@sughrue.com)
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`
`
`
` /Jason D. Eisenberg/
`
`Jason D. Eisenberg, Reg. No. 43,447
`Attorney for Patent Owner
`
`
`
`
`
`
`
`
`Date: December 20, 2016
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
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