Paper No. ___
`Filed: July 5, 2016
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________
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`
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`SECURUS TECHNOLOGIES, INC.
`Petitioner
`
`v.
`
`GLOBAL TEL*LINK CORPORATION
`Patent Owner
`_________________________
`
`Case IPR2016-00267
`Patent No. 7,256,816
`_________________________
`
`
`PETITIONER’S REQUEST FOR REHEARING
`
`
`
`
`
`
`
`
`Filed: July 5, 2016
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________
`
`
`
`SECURUS TECHNOLOGIES, INC.
`Petitioner
`
`v.
`
`GLOBAL TEL*LINK CORPORATION
`Patent Owner
`_________________________
`
`Case IPR2016-00267
`Patent No. 7,256,816
`_________________________
`
`
`PETITIONER’S REQUEST FOR REHEARING
`
`
`
`
`
`
`
`
`
`
`
`TABLE OF CONTENTS
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`I.
`
`
`
`
`Rehearing Is Needed to Correct a Fundamental Misreading of the
`Evidence and Petition ...................................................................................... 1
`Legal Standard ................................................................................................. 3
`II.
`III. Argument ......................................................................................................... 3
`A.
`The Petition and Supporting Evidence Relied Solely on
`Bulriss’s Public Mode ........................................................................... 3
`The Board’s Focus on Bulriss’s Privacy Mode Ignores the
`Petition’s Public-Mode Analysis ........................................................... 5
`The Petition Demonstrated that Bulriss’s Public Mode
`Discloses the Claimed Monitoring Features ......................................... 6
` GTL’s Irrelevant Privacy-Mode Analysis Should Not Have
`Influenced the Board’s Public-Mode Analysis ..................................... 9
`Scheduling of Public-Mode Communications Ensures the
`Timeliness of Bulriss’s Privacy-Mode Communications ................... 11
`IV. Conclusion ..................................................................................................... 14
`
`B.
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`
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`C.
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`D.
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`E.
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`TABLE OF AUTHORITIES
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` Page(s)
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`Federal Cases
`Bates v. Coe,
`98 U.S. 31 (1878) ................................................................................................ 11
`
`Daicel Corp. v. Celanese Int’l Corp.,
`IPR2015-00173, Paper 15 (P.T.A.B. June 26, 2015) ........................................... 3
`
`KSR Int’l Co. v. Teleflex, Inc.,
`550 U.S. 398 (2007) ............................................................................................ 14
`
`In re Nomiya,
`509 F.2d 566 (CCPA 1975) ................................................................................ 14
`
`Optivus Tech., Inc. v. Ion Beam Applications S.A.,
`469 F.3d 978 (Fed. Cir. 2006) ............................................................................ 13
`
`Regulations
`
`37 C.F.R. § 42.71(c) ................................................................................................... 3
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`37 C.F.R. § 42.71(d) .................................................................................................. 3
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`I.
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`Rehearing Is Needed to Correct a Fundamental Misreading of the
`Evidence and Petition
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`Rehearing is rarely granted, but it is needed here to correct a fundamental
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`misunderstanding of the prior art and Petitioner Securus’ arguments, which
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`resulted in a decision not to institute that is not supported by the evidence. The
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`primary reference, Bulriss, discloses two modes of operation—public and privacy.
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`The public-mode disclosure—exclusively relied on by Securus—teaches the
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`claimed communications monitoring, but the Board mistakenly relied on the
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`privacy-mode description of non-monitored attorney-client communications as the
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`basis for denying institution. By overlooking Securus’ reliance on the public mode
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`and how that mode functions, the Board reached a conclusion that is contrary to the
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`evidence. For example, the Board noted in several places that Bulriss’s
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`communications could be protected by the attorney-client privilege and assumed
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`that its communications occur only when other devices are locked out from
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`monitoring. (See, e.g., Paper 8 (“Decision”) at 8, 10-11.) These statements are only
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`true of Bulriss’s privacy mode and do not apply to the public mode described in the
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`reference and presented throughout the Petition.
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`The Board’s remaining reasons for denying institution stem from its
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`mistaken reliance on the privacy mode to the exclusion of the public mode on
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`which the Petition relies. For example, the Board found that Bulriss would not
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`have been combined with Hesse’s scheduling mechanism because private
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`communications need to occur on an ad hoc basis and having to schedule them
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`would be counter to Bulriss’s purpose of providing communications without delay.
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`(Decision at 12.) These concerns, however, overlook that Bulriss provides its
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`timely private communications because it has already established a public-mode
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`communication channel at the beginning of the hearing or trial. Because the
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`courtroom and inmate are already connected in public mode, the judge can quickly
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`and easily enable Bulriss’s privacy mode so the attorney and inmate can
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`communicate privately at a moment’s notice. Without the preexisting public-mode
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`communication channel, ad hoc private communications would take longer to set
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`up during trial, requiring the inmate to move to a location with conferencing
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`equipment and a private connection. Scheduling a public-mode communication
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`channel—the channel relied on throughout the Petition—is not only consistent
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`with Bulriss’s goals, it is presupposed to occur in certain Bulriss embodiments.
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`The Board’s mistaken reliance on the privacy-mode issues in Bulriss was
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`invited by GTL’s preliminary response, which failed to address the public mode
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`disclosures that formed the basis of the Petition. Because the Board followed
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`GTL’s lead and overlooked or misapprehended the public-mode arguments and
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`evidence when denying institution, Securus respectfully requests rehearing and
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`institution of review on all claims, as set forth in the Petition.
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`II. Legal Standard
`“A party dissatisfied with a decision may file a request for rehearing without
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`prior authorization from the Board.” 37 C.F.R. §42.71(d). “The request must
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`specifically identify all matters the party believes the Board misapprehended or
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`overlooked, and the place where each matter was previously addressed in a motion,
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`an opposition, or a reply.” Id. The Board reviews a decision for an abuse of
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`discretion. 37 C.F.R. §42.71(c). “An abuse of discretion may arise if a decision is
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`based on an erroneous interpretation of law, if a factual finding is not supported by
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`substantial evidence, or if an unreasonable judgment is made in weighing relevant
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`factors.” Daicel Corp. v. Celanese Int’l Corp., IPR2015-00173, Paper 15 at 2
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`(P.T.A.B. June 26, 2015) (citing Federal Circuit cases).
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`III. Argument
` The Petition and Supporting Evidence Relied Solely on
`A.
`Bulriss’s Public Mode
`Securus focused its unpatentability analysis on Bulriss’s public mode, in
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`which a judge and jury can monitor conversations between an inmate and attorney
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`via a judge control panel and courtroom displays. (Petition at 32.) Securus stated
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`that “[j]udge control panel 44 acts as a ‘monitoring station’ or a ‘third
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`terminal’ … .” (Id.) And “[i]n addition to judge’s control panel 44, Bulriss’s
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`display devices 96 also constitute a ‘monitoring station’ or a ‘third terminal’
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`because the judge may send the communications data to display devices 96 for
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`display in the courtroom, where it can be monitored by the judge and jury.” (Id.)
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`Securus then quoted from Bulriss’s public-mode explanation that “the judge
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`may select, from a menu, the preferred display format for the display devices 96 …
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`the judge may select a format where the prosecuting attorney, the defense,
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`attorney, the inmate, and the judge are simultaneously depicted on the display
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`devices 96. In this manner … the conduct of each of the parties [may] be displayed
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`to the jury … .” (Petition at 32-33, citing Ex. 1005 at 17:4-12.) Securus further
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`explained that “[i]n Bulriss’s system the judge’s control panel 44 and display
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`devices 96—the monitoring stations or third terminals—are located in [the]
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`courtroom.” (Petition at 36-37, citing Ex. 1005 at 17:4-12; Fig. 2A; Ex. 1002 at ¶
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`[0126].) These passages demonstrate that Securus relied on Bulriss’s public mode,
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`where communications between an attorney and inmate are displayed for a judge
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`and jury to monitor.
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`Other examples of Securus’ reliance on Bulriss’s public mode include:
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` Petition at 15, citing Ex. 1005 at 17:5-12, Ex. 1002 at ¶ [049];
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` Petition at 23, citing Ex. 1005 at 17:4-12, Ex. 1002 at ¶ [091];
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` Petition at 30-31, citing Ex. 1005 at Fig. 2A, 12:64-13:14, and 17:4-12;
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`Ex. 1002 at ¶ [0109];
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` Petition at 36-37, citing Ex. 1005 at 17:4-12; Fig. 2A; Ex. 1002 at
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`¶ [0126]; and
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` Petition at 42, citing Ex. 1005 at 17:13-18.
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`The public mode disclosures in Bulriss, as analyzed in the Petition,
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`demonstrate unpatentability of the claims. The Board, however, based its decision
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`on unrelated concerns that apply solely to Bulriss’s privacy mode, which was not
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`relied on by Securus.
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`
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`B.
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`The Board’s Focus on Bulriss’s Privacy Mode Ignores the
`Petition’s Public-Mode Analysis
`Much of the Decision focuses on issues related to Bulriss’s privacy mode,
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`which are not relevant to the public-mode analysis in the Petition. For example, the
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`Board agreed with GTL’s argument “that the communication in Bulriss referred to
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`is attorney-client privileged communication, and although it may be initiated by
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`the judge, it is not monitored and is private.” (Decision at 10.) The Board also
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`stated that “[i]f the ‘visit’ claimed is the specific communication between the
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`attorney and the inmate only, it will not be monitored without vitiating the
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`attorney-client privilege. In other words, if utilized in ‘privacy’ mode, as discussed
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`above, all other devices would be ‘locked out,’ and the attorney-client sidebar
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`stations would not be monitored.” (Id.) The Decision also separately quoted and
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`emphasized the lockout features of Bulriss’s privacy mode. (Id. at 8.)
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`There is no dispute that Bulriss discloses a privacy mode that may implicate
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`some of the privilege and other concerns noted by the Board, but because Securus
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`relied on the public mode instead, these issues are not relevant here. To the extent
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`the Board relied on privacy-mode concerns to deny institution, the Board
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`misapprehended that those concerns were not relevant to the public-mode analysis
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`presented in the Petition.
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`C.
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` The Petition Demonstrated that Bulriss’s Public Mode
`Discloses the Claimed Monitoring Features
`The Board’s analysis of Bulriss’s public mode was tainted by its mistaken
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`inference from the privacy mode that all attorney-inmate conversations are
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`privileged. In its public-mode discussion, the Board stated that “Bulriss is clear
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`that based on the type of communications, those communications may not be
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`monitored.” (Decision at 11.) But not every communication between an attorney
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`and a client is privileged, and Bulriss’s public mode is used to allow those non-
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`privileged communications to be displayed to a judge and jury for monitoring. And
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`if the attorney-client sidebar stations could only be used for privileged
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`communications, why would they have a public mode at all? The notion that those
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`stations are only used for unmonitorable privileged communications is illogical in
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`light of Bulriss’s repeated teaching that those stations have a public mode.
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`The Board also stated that “if the communication is used in ‘public mode,’
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`then it is not clear that this would be the communication between the inmate and
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`attorney that Petitioner relies upon.” (Decision at 10.) But as discussed above, the
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`Petition relied exclusively and repeatedly on Bulriss’s public-mode description of
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`the attorney and inmate communication being broadcast to monitors in the
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`courtroom. (See, e.g., Petition at 32-33, citing Ex. 1005 at 17:4-12.)
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`The Board’s comment also implies that the attorney-client communication
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`differs between the public and privacy modes, but in both modes an attorney
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`communicates with an inmate using the attorney-client sidebar station that “may
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`operate in a privacy or in a public mode.” (Ex. 1005 at 16:24-26.) Bulriss also
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`describes communications in both modes using the same hardware configuration,
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`Figure 2A, which is discussed throughout the Petition.1 (See, e.g., Petition at 14,
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`22, 24, 25, 26, 30, 33, 35, and 38.)
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`The primary differences between Bulriss’s two communication modes are:
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`(1) in privacy mode the attorney and inmate communicate using telephone-like
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`handsets as opposed to the public mode’s microphones; and (2) in privacy mode,
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`other monitoring devices may be locked out by disabling them or routing
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`communication signals away from them. (See, e.g., Ex. 1005 at 16:24-31; 18:2-8.)
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`1 This is like the ’816 patent, where the same hardware captures private,
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`attorney-client privileged communications and non-privileged communications.
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`(See Ex. 1001 at 15:10-14, “However, in other embodiments, the video visit may
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`have been between an inmate and his attorney. In such embodiments, the warden
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`may not be authorized to view the recording of the video visit because of attorney-
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`client privilege issues.”)
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`Neither of these differences, however, changes that the attorney and client
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`communicate through the attorney-client sidebar station in both modes. Securus
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`discussed communications through the attorney-client sidebar station as being “the
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`communications between the inmate and attorney that Petitioner relies upon.” (See
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`Petition at 15, 16, 22-25, 30-33, and 36.) The Board’s comment to the contrary
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`evidences its misapprehension.
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`The Board continued
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`that,
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`if Securus relies on Bulriss’s “general
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`communication between the inmate and the judge or one of the attorneys, it does
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`not include the specific use of the attorney-client sidebar station relied upon by
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`Petitioner. Such general communication would necessarily have more than those
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`two participants, and although it could include exchanges between the inmate and
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`his or her attorney, it is not the communication relied upon by Petitioner.”
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`(Decision at 10-11.) The Board similarly stated that “the specific communication
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`between the inmate and his or her attorney would not be the same as the
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`simultaneous depiction of all parties on the display devices.” (Id. at 11-12.)
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`But the judge and jury are not necessarily parties to the conversation
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`occurring through the attorney-client sidebar station. In fact, outside of voir dire,
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`juries are almost never allowed to communicate with parties or their counsel
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`during a trial. Instead they are limited to passing notes to the judge, who may ask
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`the parties the questions if appropriate. The jury’s function is to monitor the trial’s
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`communications and use them as the judge permits when deciding a case. Bulriss
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`even refers to the jury displays as “monitors.” (Ex. 1005 at 14:7-12.)
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`Securus explained this monitoring function throughout its Petition. (See
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`Section III.A, supra; see also Petition at 32, “the judge may send the
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`communications data to display devices 96 for display in the courtroom, where it
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`can be monitored by the judge and jury.”) To the extent the Board declined to
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`institute based on the judge or jury being parties to the communication and
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`therefore not monitoring the communication, as claimed, the Board overlooked or
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`misapprehended that the reference also discloses the judge and jury in monitoring
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`roles.
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`The Board also stated that this type of monitored exchange “is not the
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`communication relied upon by Petitioner,” and that “although it is possible that a
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`‘video visit’ may encompass more than communications between the inmate and
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`attorney … Petitioner has not relied on more in its Petition.” (Decision at 11.) For
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`the reasons above, these statements misapprehend that the Petition repeatedly relies
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`on
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`this very
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`type of monitored communication, where more
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`than
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`the
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`communicating parties may view it.
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`D.
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` GTL’s Irrelevant Privacy-Mode Analysis Should Not Have
`Influenced the Board’s Public-Mode Analysis
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`GTL’s preliminary response may have created some of the confusion over
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`this issue because, instead of addressing the public mode discussed throughout the
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`Petition, GTL exclusively addressed Bulriss’s privacy mode. (See Paper No. 6.) In
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`summarizing its argument, for example, the preliminary response states that any
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`monitoring “would cause infringement upon a communication protected by the
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`attorney-client privilege,” and that Bulriss “is aimed squarely at maintaining such
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`communications ‘in confidence’ so as not to lose ‘its protected status under … the
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`attorney-client privilege.” (Id. at 2.) But these arguments having nothing to do with
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`the Petition’s public-mode analysis.
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`In the one place where GTL briefly mentions monitoring by a judge or jury,
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`it turns the discussion to Bulriss’s privacy mode, contending that Bulriss does not
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`disclose the claimed monitoring because the judge can enable a mode where the
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`other devices are locked out (i.e., the judge can enable Bulriss’s privacy mode).
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`(Id. at 14-15.) But again, this argument focuses only on Bulriss’s privacy mode and
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`does not address its public mode. GTL then quotes Bulriss’s statements about its
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`attorney-client sidebar station being located out of earshot of the others in the
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`courtroom. (Id. at 16.) GTL never mentions, however, Bulriss’s disclosure that
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`“the courtroom attorney-client sidebar station 48 also may be located at the defense
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`attorney’s table,” (Ex. 1005 at 17:49-50), which would be well within earshot of
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`the judge and jury.
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`The preliminary response also appears to rely heavily on Bulriss’s choice of
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`terminology, repeatedly
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`italicizing “attorney-client sidebar”
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`throughout
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`its
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`response. (See id. at 12-22.) While the term “sidebar” might imply a private
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`communication in other contexts, Bulriss uses this term to describe stations having
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`both public and privacy modes as explained above in Section III.C. And as the
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`Supreme Court explained long ago, a patentability analysis turns on the way a prior
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`art system operates, not on the names used to describe it. Bates v. Coe, 98 U.S. 31,
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`42 (1878) (“In determining about similarities and differences, courts of justice are
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`not governed merely by the names of things; but they look at the machines and
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`their devices in the light of what they do, or what office or function they perform,
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`and how they perform it.”).
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`It is not clear to what extent GTL’s privacy-mode arguments affected the
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`Board’s decision, but to the extent the Board allowed them to influence their
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`public-mode analysis, Securus respectfully requests that the Board reconsider its
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`analysis in light of the overlooked and misapprehended facts identified throughout
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`this request that were raised in the Petition.
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`E.
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`Scheduling of Public-Mode Communications Ensures the
`Timeliness of Bulriss’s Privacy-Mode Communications
`In the context of Bulriss’s public mode discussed throughout the Petition, if
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`an inmate is scheduled to view an entire hearing or trial, scheduling the connection
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`is a logical step one of ordinary skill in the art would have taken. As explained in
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`the Petition and supported by Securus’ expert, “[s]witching device 22 establishes
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`its first and second data connections in association with a scheduled court
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`proceeding, so Bulriss arguably discloses the ‘at a scheduled time’ feature of the
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`claims. (Ex. 1002 at ¶ [097].)”
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`This fact is confirmed throughout Bulriss, which presupposes that a public-
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`mode connection already exists between the courthouse and the inmate at the time
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`the privacy mode is enabled. For example, Bulriss states that “when the judge
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`selects the attorney-client sidebar mode of operation [i.e., privacy mode], the
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`system 10, 38 uses the established communications link between the courtroom 16
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`and the jail 14 for the communications link between the attorney’s station 48 and
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`the inmate’s station 62, 172.” (Ex. 1005 at 18:59-63, emphasis added.) It then
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`explains
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`that, when enabling privacy mode, “a separate communications
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`connection between the attorney and the inmate is not established.” (Id. at 18:64-
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`66.) No separate privacy-mode connection is required because one has already
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`been established in public mode.
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`The Board adopted GTL’s argument that establishing connections at a
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`scheduled time would impede or delay a court proceeding. (Decision at 12.) But
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`this argument misapprehends that Bulriss’s system achieves its timely privacy-
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`mode communications because it already has a connection between the courthouse
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`and the inmate at the time a privacy-mode communication is started. Indeed, not
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`having a pre-established connection would delay the proceedings because the
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`inmate would need to be moved to a suitable prison location with an interface
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`device and then the courthouse would need to establish a connection. There is no
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`telling how long this might take, but it would certainly take longer than having the
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`judge select a menu option to enable privacy-mode on an already-established
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`public-mode connection. Scheduling a public-mode communication, such as the
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`one discussed throughout the Petition, is not contrary to Bulriss’s goals, as the
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`Board found, but instead enables Bulriss’s goal of providing timely privacy-mode
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`communications.
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`As noted in the Petition, while Bulriss arguably teaches scheduling public-
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`mode communications to coincide with scheduled trials (Petition at 26-27), it also
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`would have been obvious for one of ordinary skill in the art to look to Hesse’s
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`more explicit and detailed disclosure of how to implement a scheduling mechanism
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`(Petition at 27-28). Bulriss itself provides a motivation for scheduling public-mode
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`communications, and it specifically identifies Hesse’s disclosure as an exemplary
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`“prior art video conferencing system designed for courtroom use.” (Petition at 19-
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`21, citing Ex. 1005 at 3:55-58.) Consequently, one of the first disclosures one of
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`ordinary skill in the art would have looked to after reading Bulriss was Hesse, and
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`it would have been obvious to implement Hesse’s scheduling features, as explained
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`in the Petition. (Petition at 19-21; see also Optivus Tech., Inc. v. Ion Beam
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`Applications S.A., 469 F.3d 978, 990-91 (Fed. Cir. 2006) (finding a motivation to
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`combine where a first reference cited a second reference, and the second
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`reference’s disclosure was complementary to and extended the teachings of the
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`first).)
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`Finally, the Board took issue with Securus’ motivation-to-combine analysis
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`because it discussed the challenged ’816 patent. (Decision at 8-9.) But the
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`Petition’s discussion of the ’816 patent simply confirmed that Bulriss and Hesse
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`were seeking to achieve the same goals as stated in the ’816 patent. The motivation
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`to combine exists independent of the ’816 patent and it did not come from the ’816
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`patent itself. But even if Bulriss and Hesse had been seeking to achieve different
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`goals from those of the ’816 patent, one of ordinary skill in the art still would have
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`combined their disclosures because Bulriss cites Hesse and Hesse discloses in
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`more detail the specific mechanisms for scheduling connections like Bulriss’s, as
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`discussed in the Petition. (Petition at 19-21.) The motivation to combine is
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`therefore explicit in the references, averting any concerns the Board has regarding
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`the lack of a known problem in the art. (See Decision at 9, citing In re Nomiya, 509
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`F.2d 566, 573 (CCPA 1975), and KSR Int’l Co. v. Teleflex, Inc., 550 U.S. 398, 420
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`(2007).)
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`IV. Conclusion
`Because the Board misapprehended or overlooked critical facts that formed
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`the basis for its denial of institution, Securus respectfully requests rehearing and
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`institution of review on all claims, as set forth in the Petition.
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`Date: July 5, 2016
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`Respectfully submitted,
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`/Jason Stach/
`Erika Arner
`Reg. No. 57,540
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, L.L.P.
`Two Freedom Square
`11955 Freedom Drive
`Reston, VA 20190-5675
`Telephone: 571-203-2700
`Fax: 202-408-4400
`E-mail: erika.arner@finnegan.com
`
`Jason Stach
`Reg. No. 54,464
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, L.L.P.
`271 17th Street, NW
`Suite 1400
`Atlanta, GA 30363
`Telephone: 404-653-6428
`Fax: 404-653-6444
`E-mail: jason.stach@finnegan.com
`
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`- 15 -
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`Case IPR2016-00267
`Patent No. 7,256,816
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing
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`PETITIONER’S REQUEST FOR REHEARING was served on July 5, 2016,
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`via email directed to counsel of record for the Patent Owner at the following:
`
`Michael D. Specht
`Mspecht-PTAB@skgf.com
`
`Michael B. Ray
`Mray-PTAB@skgf.com
`
`Lauren C. Schleh
`Lschleh-PTAB@skgf.com
`
`Brian Lee
`Blee-PTAB@skgf.com
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3932
`
`/Ashley F. Cheung/
` Ashley F. Cheung
`Case Manager
`
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, L.L.P.
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`- 16 -
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`Case IPR2016-00267
`Patent No. 7,256,816
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