April 27, 2017
`
`Petitioner’s Demonstrative Exhibit
`
`Trial No. IPR2016-00475
`U.S. Patent No. 9,036,343
`L&P Property Mgmt. Co.
`L&P v. NPI
`IPR2016-00475
`
`Exhibit 1051
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`Trial No. IPR2016-00475
`U.S. Patent No. 9,036,343
`L&P Property Mgmt. Co.
`L&P v. NPI
`IPR2016-00475
`
`Exhibit 1051
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`The Challenged Claims
`
`Claims 1 to 20 of the ’343 patent
`
`Slide 2
`
`Source: ’343 patent (Ex. 1001) at 51:21–54:65.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Slide 3
`
`Grounds Of Unpatentability – §103
`Ground 1
` Nguyen
` Revolution
` Pandock
` Yamamoto
`Ground 2
` Nguyen
` Revolution
` Pandock
` Yamamoto
` Nakajima
`
`Source: Institution Dec. (Paper 8) at 26.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Slide 4
`
`What Is In Dispute
`
`The Parties Dispute Only Four Issues Relating To Two Claim Terms
` “Molded”
`– Whether “molded” means the claims are product-by-process claims
`– Whether Nguyen and Nakajima disclose molded docking stations
` “Resilient retraction mechanism”
`– Whether Yamamoto is analogous art
`– Whether Yamamoto discloses a resilient retraction mechanism
`
`The Parties Do Not Dispute
` What is taught by Revolution and Pandock
` That the additional limitations in the dependent claims do not give rise
`to patentability
`
`Sources: Pet. (Paper 1); Resp. (Paper 12); Pet. Reply (Paper 17).
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Slide 5
`
`“Molded” — Product-By-Process Claims
`Board Was Correct — “[C]laims containing ‘molded’ limitations are
`product-by-process claims,” which means that these limitations must
`be disregarded for purposes of obviousness. (Institution Dec. at 9, 15;
`see also Pet. Reply at 2–6.)
`
`Patent and Carnevali Declaration — Many molding processes are
`known in the art for forming parts. (Ex. 1001 at 43:54–56, 43:48-53,
`44:1–33, 45:14–61,46:8–62, 47:5–55; Ex. 2014 at ¶¶ 21–28.)
`
`’343 Patent — Nowhere do the claims use “molded” to describe any
`structural feature. (Pet. Reply at 5.)
`
`Case law — All of the cases relied upon by Patent Owner use terms
`to describe structure as opposed to a process by which the structural
`element was formed. (Pet. Reply at 5–6.)
`
`Sources: Pet.; Institution Dec.; Pet. Reply; Ex. 1001; Ex. 2014.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Slide 6
`
`“Molded” — Well-Known in Docking Stations
`Nguyen Discloses A Molded Docking Station. (Pet. at 12, 31, 35–36,
`47; Pet. Reply at 7–8; Ex. 1014 at ¶¶ 35–37.)
` Lewandowski Declaration identifies specific structures that one of skill in
`the art would recognize as molded. (Ex. 1014 at ¶¶ 36–37.)
` Carnevali Declaration admits as much. (Ex. 2014 at ¶ 24.)
`
`Nakajima Discloses A Molded Docking Station. (Pet. at 58–59; Pet.
`Reply at 8–10; Ex. 1014 at ¶ 92; Ex. 1009 at 25:1–10.)
`
`Molded Docking Stations Were The State Of The Art. (Ex. 1014 at ¶¶
`93–96, 111[1.P]; Ex. 1010 at 5:3–15; Ex. 1011 at 2:36–38; Ex. 1012
`at ¶ [0022]; Ex. 1013 at ¶ [0022].)
`
`The Patent Office twice rejected Patent Owner’s argument about
`molded. (Pet. Reply at 3; Ex. 1002 at 130; Ex. 1039 at 7.)
`
`Sources: Pet.; Pet. Reply; Exs. 1002, 1009–14, 1039; Ex. 2014.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Slide 7
`
`Nguyen Discloses A Molded Docking Station
`
`In addition, a part to be manufactured by
`molding will typically be designed with additional
`built-in structural support, such as ribbing or
`bosses that would otherwise be too difficult or
`expensive to incorporate by other manufacturing
`methods.
`
`Carnevali Testimony (Ex. 2014 at ¶ 24)
`
`The manner in which the different portions of upper
`and lower housing sections 18a, 18b are shaped
`and formed teaches one of ordinary skill in the art
`that Nguyen’s housing 18 is molded or die cast. For
`example, the external and internal ribs and internal
`bosses are integrally formed as one piece with the
`walls of upper and lower housing sections 18a and
`18b. . .. Figure 7, . . . shows that front restraining rib
`30 is integrally formed as one-piece with the bottom
`wall of upper housing section 18a.
`
`Lewandowski Testimony (Ex. 1014 at ¶ 36, see id. at ¶¶ 37–38)
`
`Sources: Ex. 1014; Ex. 2014; Pet. 12–13, 30, 35–36; Pet. Reply at 7–8.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Slide 8
`
`Nakajima Discloses A Molded Docking Station
`
`Nakajima (Ex. 1009 at 25:1–10)
`
`Sources: Ex. 1009; Pet. at 58–59; Pet. Reply at 8–10; Ex. 1014 at ¶¶ 92.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Slide 9
`
`State of the Art — Molded Docking Stations
`
`Wolff (Ex. 1010 at 5:3–15)
`
`Howell (Ex. 1011 at 2:36–38)
`
`Brophy (Ex. 1012 at ¶ [0022])
`
`McCormack (Ex. 1013 at ¶ [0022])
`
`Sources: Pet. at 58; Pet. Reply at 2, n.1; Ex. 1014 at ¶¶ 93–96, 111[1.P]; Exs. 1010–1013.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`“Resilient Retraction Mechanism”
`
`Slide 10
`
`Yamamoto Is Analogous Art Whatever Prong Of The Standard
`Applies. (Pet. at 18; Pet. Reply at 15–17; Ex. 1014 at ¶¶ 62–67.)
`
`Yamamoto Discloses The Recited Resilient Retraction Mechanism
`Whatever Claim Construction The Board Adopts. (Pet. Reply at 18–
`20.)
`
`Sources: Pet.; Pet. Reply; Ex. 1014.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Slide 11
`
`Analogous Art—Same Field of Endeavor
`’343 Patent
`Carnevali Testimony
`
`Ex. 1001 at 1:19–23, 53:41–44.
`
`Yamamoto
`
`Ex. 1006 at 1:9–14, 12:6–12.
`
`Sources: Ex. 1001; Ex. 1006; Ex. 1049.
`
`Ex. 1049 at 6:22–7:1.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Slide 12
`
`Analogous Art—Reasonably Pertinent
`’343 Patent
`Yamamoto
`
`Ex. 1001 at 14:30–38.
`
`Ex. 1006 at 1:38–65.
`
`Sources: Pet. at 18; Pet. Reply at 7–8; Ex. 1014 at ¶¶62–67.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Slide 13
`
`“Resilient Retraction Mechanism”
`
`Patent Owner Reads Extraneous Limitations Into The Claims
` “automatic”
` “linear”
`Patent Owner Conflates Claim Elements
` Unrebutted evidence establishes that Yamamoto in combination with
`Nguyen discloses “resilient retraction mechanism coupled to the linear
`expansion connector drive mechanism for urging the expansion
`connector to the disengaged position.”
`– The Yamamoto mechanism is just as automatic as mechanism with latch
`disclosed in Patent. (Pet. Reply at 18–20; see also Pet. at 38.)
`– Unrebutted Lewandowski Declaration explains in detail how and why one of
`skill in the art would combine the retraction spring in Yamamoto to perform
`the same function in Nguyen, that is, to retract the expansion connector to
`the disengaged position with the linear expansion connector drive
`mechanism. (Ex. 1014 at ¶¶ 68–81, 102–109.)
` Obviousness must be based on the prior art as a whole. (Pet. at 8, 18,
`20.)
`Sources: Pet.; Pet. Reply; Ex. 1014.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Slide 14
`
`Yamamoto Resilient Retraction Mechanism
`
`Sources: Pet. at 20–23; Pet. Reply at 18–20; Ex. 1006 at 9:16–16, 11:1–12:6; Ex. 2014 at ¶¶ 70–81.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Slide 15
`
`Yamamoto Resilient Retraction Mechanism
`
`Ex. 1001—Fig. 25 Annotated
`
`Ex. 1006 at 9:6–12.
`
`Ex. 1001—Fig. 28 Annotated
`Sources: Pet. at 21–22; Pet. Reply at 18–20; Ex. 1001; Ex. 1006.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Slide 16
`
`No Evidence of Secondary Considerations
`
`Patent Owner withdrew its purported evidence of copying. (See Ex.
`2014 (revised).)
`
`Patent Owner’s argument and purported evidence regarding “passing
`off” is irrelevant to patentability.
`
`Sources: Pet. Reply at 22–23.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Slide 17
`
`Conclusion
`
`Claims 1–20 of the ’343 Patent are unpatentable.
`
`Claims 1–20 of the ’343 Patent should be canceled.
`
`Sources: Pet.; Pet. Reply.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Slide 18
`
`Appendix
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Independent Claim 1
`
`Slide 19
`
`Source: ’343 patent (Ex. 1001) at 51:21–52:17.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Independent Claim 9
`
`Slide 20
`
`Source: ’343 patent (Ex. 1001) at 52:66–53:40.
`
`
`
`Petitioner’s Demonstrative Exhibit
`
`April 27, 2017
`
`Independent Claim 10
`
`Slide 21
`
`Source: ’343 patent (Ex. 1001) at 53:41–54:19.
`
`
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