`571-272-7822
`
`
`Paper No. 30
`Entered: June 26, 2018
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`LIVEPERSON, INC.,
`Petitioner,
`
`v.
`
`24/7 CUSTOMER, INC.,
`Patent Owner.
`____________
`
`
`
`
`
`Case IPR2017-00609
`Patent 6,970,553 B1
`____________
`
`
`Before CHRISTOPHER L. CRUMBLEY, ROBERT J. WEINSCHENK,
`and JASON W. MELVIN, Administrative Patent Judges.
`
`MELVIN, Administrative Patent Judge.
`
`
`
`
`FINAL WRITTEN DECISION
`35 U.S.C. § 318(a) and 37 C.F.R. § 42.73
`
`
`
`
`
`IPR2017-00609
`Patent 6,970,553 B1
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`
`LivePerson, Inc. (“Petitioner”) filed a Petition (Paper 1, “Pet.”)
`
`requesting inter partes review of claims 1–3 and 33–35 of U.S. Patent No.
`
`6,970,553 B1 (Ex. 1001, “the ’553 patent”). Patent Owner 24/7 Customer,
`
`Inc. (“Patent Owner”) filed a Preliminary Response. Paper 9 (“PO Prelim.
`
`Resp.”). We instituted review of only claims 1 and 33. Paper 12
`
`(“Institution Decision” or “Inst.”). Our scheduling order cautioned Patent
`
`Owner that “any arguments for patentability not raised in the response will
`
`be deemed waived.” Paper 13, 6. Patent Owner did not file a Response to
`
`the Petition; we therefore advised the parties to inform the Board “if there is
`
`any reason the Board should not proceed to issue final written decisions
`
`without additional briefing or an oral argument.” Paper 22, 2.
`
`On May 3, 2018, we expanded the scope of this proceeding to include
`
`review of all challenged claims and all grounds presented in the Petition.
`
`Paper 25; see United States Patent and Trademark Office, Guidance on the
`
`impact of SAS on AIA trial proceedings, PATENT TRIAL AND APPEAL BOARD
`
`TRIALS (April 26, 2018), https://go.usa.gov/xQ93y. Although presented
`
`with the opportunity to do so, the parties did not request further briefing or a
`
`hearing on the challenges added to this proceeding. Paper 26.
`
`I. BACKGROUND
`
`A. RELATED PROCEEDINGS
`
`The parties assert the ’553 patent and patents related to it are involved
`
`in 24/7 Customer, Inc. v. LivePerson, Inc., 3:15-CV-05585-JST (N.D. Cal.)
`
`and 24/7 Customer, Inc. v. LivePerson, Inc., 3:15-CV-02897-JST (N.D.
`
`Cal.). See Pet. 2; Paper 8, 2. The following petitions for inter partes review
`
`are related to this case:
`
`
`
`2
`
`
`
`IPR2017-00609
`Patent 6,970,553 B1
`
`
`Case No.
`
`Involved Patent
`
`IPR2017-00610 U.S. Patent No. 9,077,084
`
`IPR2017-00612 U.S. Patent No. 7,751,552
`
`IPR2017-00613 U.S. Patent No. 7,027,586
`
`IPR2017-00614 U.S. Patent No. 6,975,719
`
`IPR2017-00615 U.S. Patent No. 7,245,715
`
`IPR2017-00616 U.S. Patent No. 6,798,876
`
`
`
`B. THE ’553 PATENT
`
`The ’553 patent is directed to a phone system with an integrated chat
`
`client service. Ex. 1001, Abstract. The Specification describes a need for a
`
`“mechanism by which a called party can keep his/her side of the
`
`conversation private from others who may be present in the room.” Id. at
`
`1:63–65. When a calling party places a call, the call processing system
`
`queries the network to determine whether the called party has an accessible
`
`chat client on their computer. Id. at 3:63–4:8. If they do, the system
`
`prompts the calling party, notifying them that the called party has an
`
`accessible chat client, and confirming that the calling party would like to
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`send a chat invitation to the called party. Id. at 4:18–22. If the called party
`
`chooses to accept the invitation to chat, a chat session between the two
`
`parties may be arranged. Id. at 4:26–36.
`
`
`
`Petitioner challenges claims 1–3 and 33–35. Independent claim 1 is
`
`C. CHALLENGED CLAIMS
`
`reproduced below.
`
`1. A method for converting a voice call attempt to an alternate
`medium for a real-time communication session, comprising:
`
`
`
`3
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`IPR2017-00609
`Patent 6,970,553 B1
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`
`receiving a telephone call request;
`
`checking for accessibility of a called party chat client associated
`with a called party; and
`
`prompting a calling party to choose whether or not to
`electronically chat with the called party in an electronic chat
`session when the called party chat client is accessible,
`wherein the electronic chat session is enabled between a
`calling party chat client and the called party chat client that
`are logged into respective electronic chat servers.
`
`Ex. 1001, 11:36–48.
`
`Claim 2 depends from claim 1 and adds “sending an invitation to the
`
`called party, inviting initiation of a chat session with the calling party when
`
`the calling party chooses to chat.” Id. at 11:49–52.
`
`Claim 3 depends from claim 2 and adds “connecting a voice call when
`
`the calling party chooses not to chat.” Id. at 11:53–55.
`
`Claims 33–35 parallel claims 1–3, except that they recite a computer-
`
`readable medium that has a program that performs the claimed method steps
`
`recited in claims 1–3. See id. at 14:1–22.
`
`D. REVIEWED GROUNDS OF UNPATENTABILITY
`
`Petitioner asserts the following grounds of unpatentability. Pet. 4.
`
`Reference(s)
`
`Basis
`
`Claims
`
`Truetken1
`
`§ 102(e)2 1–3 and 33–35
`
`
`1 U.S. Patent No. 6,493,324 B1, Dec. 10, 2002 (Ex. 1002, “Truetken”).
`2 Although Petitioner characterizes this ground as one based on obviousness,
`in substance, Petitioner asserts Truetken anticipates the challenged claims.
`See Pet. 16 (asserting that Truetken “discloses, and at a minimum renders
`obvious, the alleged invention claimed by each of the Challenged
`Claims”); id. at 17–28 (not identifying any potential differences between
`claimed subject matter and Truetken). We therefore treat Petitioner’s
`challenge as one based on anticipation, not obviousness.
`
`
`
`4
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`IPR2017-00609
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`
`Reference(s)
`
`Basis
`
`Claims
`
`Truetken and Hansen3 § 103(a) 1–3 and 33–35
`
`E. LEGAL PRINCIPLES
`
`1. Burden of proof
`
`In an inter partes review, the petitioner bears the burden of proving
`
`unpatentability of the challenged claims, and the burden of persuasion never
`
`shifts to the patent owner. Dynamic Drinkware, LLC v. Nat’l Graphics, Inc.,
`
`800 F.3d 1375, 1378 (Fed. Cir. 2015). To prevail, Petitioner must support
`
`its challenge by a preponderance of the evidence. 35 U.S.C. § 316(e);
`
`37 C.F.R. § 42.1(d). Accordingly, all of our findings and conclusions are
`
`based on a preponderance of the evidence.
`
`2. Anticipation
`
`A patent claim is unpatentable under 35 U.S.C. § 102 if “the four
`
`corners of a single, prior art document describe every element of the claimed
`
`invention, either expressly or inherently, such that a person of ordinary skill
`
`in the art could practice the invention without undue experimentation.”
`
`Advanced Display Sys., Inc. v. Kent State Univ., 212 F.3d 1272, 1282 (Fed.
`
`Cir. 2000). “A single prior art reference may anticipate without disclosing a
`
`feature of the claimed invention if such feature is necessarily present, or
`
`inherent, in that reference.” Allergan, Inc. v. Apotex Inc., 754 F.3d 952, 958
`
`(Fed. Cir. 2014) (citing Schering Corp. v. Geneva Pharm., 339 F.3d 1373,
`
`1377 (Fed. Cir. 2003)). We analyze the ground based on anticipation in
`
`accordance with the above-stated principles.
`
`
`3 U.S. Patent No. 5,940,475, Aug. 17, 1999 (Ex. 1003, “Hansen”).
`
`
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`5
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`3. Obviousness
`
`An invention is not patentable “if the differences between the subject
`
`matter sought to be patented and the prior art are such that the subject matter
`
`as a whole would have been obvious at the time the invention was made to a
`
`person having ordinary skill in the art to which said subject matter pertains.”
`
`35 U.S.C. § 103(a). The question of obviousness is resolved on the basis of
`
`underlying factual determinations including: (1) the scope and content of
`
`the prior art; (2) any differences between the claimed subject matter and the
`
`prior art; (3) the level of ordinary skill in the art; and, (4) where in evidence,
`
`so-called secondary considerations, including commercial success, long-felt
`
`but unsolved needs, and failure of others. Graham v. John Deere Co.,
`
`383 U.S. 1, 1718 (1966).
`
`When evaluating a combination of teachings, we must also “determine
`
`whether there was an apparent reason to combine the known elements in the
`
`fashion claimed by the patent at issue.” KSR Int’l Co. v. Teleflex Inc.,
`
`550 U.S. 398, 418 (2007) (citing In re Kahn, 441 F.3d 977, 988 (Fed. Cir.
`
`2006)). Whether a combination of elements produced a predictable result
`
`weighs in the ultimate determination of obviousness. Id. at 416–17. We
`
`analyze the grounds based on obviousness in accordance with the above-
`
`stated principles.
`
`II. ANALYSIS
`
`A. CLAIM CONSTRUCTION
`
`Neither party proposes any claim constructions, and we conclude no
`
`express claim constructions are necessary for our unpatentability
`
`determinations. See Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d
`
`
`
`6
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`Patent 6,970,553 B1
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`795, 803 (Fed. Cir. 1999) (“[O]nly those terms need be construed that are in
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`controversy, and only to the extent necessary to resolve the controversy.”).
`
`B. ANTICIPATION BASED ON TRUETKEN
`
`As explained below, Petitioner has made an adequate showing of
`
`anticipation regarding claims 1 and 33, but has not done so regarding claims
`
`2, 3, 34, or 35.
`
`1. Truetken (Ex. 1002)
`
`Truetken was filed on March 29, 1999, before the earliest priority date
`
`of the ʼ553 patent, and is prior art under 35 U.S.C. § 102(e). Pet. 5.
`
`Truetken teaches an Internet Protocol (“IP”) telephony client that initiates
`
`and manages multimedia sessions. Ex. 1002, Abstract. When a calling
`
`party initiates a call, the system prompts the calling party to select from a list
`
`of available helper applications or media types, including “IP phone,
`
`browser, e-mail, chat, personal directory, video streaming applications, and
`
`the like.” Id. at 4:2–4, 15–33. Once selected, a Session Initiation Protocol
`
`or “SIP” invite is sent to the called party, prompting the called party to
`
`accept, decline, or negotiate for other options. Id. at 4:41–47. In particular,
`
`if the called party wishes to negotiate for a different time or
`media for the call, the called party clicks on an other options
`button, which causes the called party client to open another
`options dialog box . . . . The options dialog box gives the called
`party the opportunity to suggest alternative media or an
`alternative time for the call. The called party client populates
`the options dialog box with the names of the other helper
`applications that the called party has available.
`
`Id. at 4:59–67 (reference numerals omitted). Once the calling and called
`
`parties have agreed on a communications medium, the appropriate helper
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`
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`7
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`application launches on the parties’ respective systems. See id. at 5:9–19,
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`58–60, Fig. 6.
`
`Petitioner asserts Truetken anticipates claims 1–3 and 33–35. Pet. 18–
`
`30. As explained below, Petitioner has shown by a preponderance of
`
`evidence that claims 1 and 33 are unpatentable. Petitioner has not shown,
`
`however, that claims 2, 3, 34, or 35 are unpatentable over Truetken.
`
`2. Claims 1 and 33
`
`As summarized above, independent claims 1 and 33 recite parallel
`
`limitations, with claim 1 reciting a method and claim 33 reciting a
`
`“computer-readable medium having a program for” performing a method
`
`with steps nearly identical to those of claim 1. We, therefore, address the
`
`two claims together.
`
`We find that that Truetken teaches a method and a computer-readable
`
`medium for “converting a voice call attempt to an alternate medium for a
`
`real-time communication session.” See Pet. 18–19 (citing Ex. 1002,
`
`Abstract, 1:34–39, 1:51–55, 2:53–55, 4:15–33, 4:41–65, Fig. 3; Ex. 1005
`
`¶¶ 60–64).
`
`We find that Truetken teaches “receiving a telephone call request.”
`
`See Pet. 20 (citing Ex. 1002, 1:51–55, 4:2–4, 4:34–39; Ex. 1005 ¶¶ 67–68),
`
`24 (citing Ex. 1002, 1:51–55, 4:34–39).
`
`We find that Truetken teaches “checking for accessibility of a called
`
`party chat client associated with a called party.” See Pet. 20–21 (citing
`
`Ex. 1002, 1:64–66, 4:59–67; Ex. 1005 ¶¶ 65–66), 24 (citing Ex. 1002, 1:64–
`
`66, 4:65–67). As Petitioner explains, in Truetken, when a called party
`
`wishes to negotiate for a different media for an incoming call, they can click
`
`on an “other options” button, which causes the called party client to
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`“populate[] [an] options dialog box 85 with the names of the other helper
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`applications that the called party has available.” Ex. 1002, 4:59–67; see Pet.
`
`20–21. In addition, Truetken discloses that helper applications types include
`
`chat applications. Ex. 1002, 4:2–4. We view the claimed “checking for
`
`accessibility” of a chat client as including Truetken’s determination of
`
`“available” applications, including chat clients. See Ex. 1002, 4:2–4, 4:65–
`
`67. Thus, based on the record, we agree with Petitioner and find that
`
`Truetken teaches “checking for accessibility of a called party chat client
`
`associated with a called party,” as claims 1 and 33 require.
`
`We find that Truetken teaches “prompting a calling party to choose
`
`whether or not to electronically chat with the called party in an electronic
`
`chat session when the called party chat client is accessible,” as claims 1 and
`
`33 require. See Pet. 21–22 (citing Ex. 1002, 5:13–20, Fig. 6; Ex. 1005
`
`¶¶ 70–73). In Truetken, the calling party’s chat-option prompt is premised
`
`on the called party first proposing chat as an alternative medium. See Ex.
`
`1002, 5:9–17 (describing that “[a]fter the called party has selected an
`
`alternative option for the call, the called party clicks on an OK button 91,
`
`which causes the called party client to send a response with the selected
`
`option back to the calling party client”). As explained above, however, the
`
`called party’s chat proposal is itself premised on the system populating a list
`
`of alternative media applications that the called party has available. Thus, in
`
`Truetken, two conditions must be met before the calling party is prompted to
`
`choose whether to chat: (1) the called party electronic chat client must be
`
`accessible, and (2) the called party must propose the alternative chat media.
`
`Although the claim limitation at issue only recites the first of those two
`
`conditions, nothing in the limitation’s plain language precludes the second
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`9
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`condition as well. Thus, based on the record, we agree with Petitioner and
`
`find that Truetken teaches “prompting a calling party to choose whether or
`
`not to electronically chat with the called party in an electronic chat session
`
`when the called party chat client is accessible,” as claims 1 and 33 require.
`
`We find that Truetken discloses “the electronic chat session is enabled
`
`between a calling party chat client and the called party chat client that are
`
`logged into respective electronic chat servers.” See Pet. 21 (citing Ex. 1002,
`
`5:13–20, Fig. 6; Ex. 1005 ¶¶ 70–73), 24–25 (citing Ex. 1002, 3:15–19, 3:31–
`
`34, 4:15–28, 4:34–39, 4:47–52, 5:13–21).
`
`Having considered the record, we find that Petitioner has
`
`demonstrated by a preponderance of the evidence that Truetken, in a single
`
`embodiment, discloses the limitations of claims 1 and 33. Accordingly, we
`
`find claims 1 and 33 are unpatentable as anticipated by Truetken.
`
`3. Claims 2, 3, 34, and 35
`
`Dependent claims 2 and 34 (and, by dependency, claims 3 and 35)
`
`require “sending an invitation to the called party, inviting initiation of a chat
`
`session with the calling party when the calling party chooses to chat.”
`
`Petitioner maps this additional invitation to Truetken’s initial “invitation to
`
`the called party that identifies the calling party and the requested media
`
`type—e.g., chat.” Pet. 22–23 (citing Ex. 1002, 3:15–19, 4:15–28, 4:34–39).
`
`We conclude that Truetken’s initial chat invitation is insufficient. See
`
`PO Prelim. Resp. 23–25. For the limitations recited in claims 1 and 33,
`
`Petitioner relies on an embodiment in Truetken where the system converts a
`
`calling party’s initial voice call invitation to a chat session. See Pet. 18–20.
`
`For the additional-invitation limitation recited in claims 2 and 34, however,
`
`Petitioner relies on a distinct embodiment—i.e., a calling party’s initial chat
`
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`invitation. See Pet. 22–23. The two separate embodiments are mutually
`
`exclusive because one has the calling party initially select a voice call,
`
`whereas the other has the calling party initially select a chat. Thus, Truetken
`
`does not disclose all elements of claims 2 and 34 “arranged as in the
`
`claim[s].” Net MoneyIN, Inc. v. VeriSign, Inc., 545 F.3d 1359, 1369 (Fed.
`
`Cir. 2008). In addition, Petitioner does not acknowledge these distinct
`
`embodiments or offer any explanation as to why one skilled in the art would
`
`combine these distinct steps in the same system, as claims 2 and 34 require.4
`
`See Pet. 37. Thus, we find Petitioner has not demonstrated by a
`
`preponderance of the evidence that claims 2, 3, 34, or 35 are unpatentable
`
`over Truetken.
`
`C. OBVIOUSNESS OVER TRUETKEN AND HANSEN
`
`Petitioner asserts claims 1–3 and 33–35 would have been obvious
`
`over Truetken and Hansen at the time of the invention. Pet. 29–43. As
`
`explained below, Petitioner has made an adequate showing regarding claims
`
`1 and 33, but has not done so regarding claims 2, 3, 34, or 35.
`
`1. Hansen (Ex. 1003)
`
`Hansen issued more than one year before the earliest priority date of
`
`the ʼ553 patent on August 17, 1999 and is, therefore, prior art under
`
`35 U.S.C. § 102(b). Pet. 5. Hansen addresses enhancing communication
`
`
`4 As addressed above, Petitioner did not propose any combination of the
`embodiments of Truetken, or any other modification of Truetken, and for
`this reason we have considered the ground of unpatentability to be based
`on anticipation alone. Even if we were to consider Petitioner’s ground of
`unpatentability over Truetken as an obviousness ground, however, we
`would have found it insufficient for failing to acknowledge the distinct
`embodiments of Truetken or articulate a reason to combine them.
`
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`systems and processes used by the deaf, hearing-impaired, and/or speech-
`
`impaired community. Ex. 1003, 2:59–62. According to Hansen, “[d]eaf,
`
`hearing impaired, and/or speech impaired individuals primarily
`
`communicate with others via a Telecommunication Device for the Deaf
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`(‘TDD’), which is primarily a teletypewriter (‘TTY’).” Id. at 2:6–9. Hansen
`
`teaches a system that “integrate[s] TDD and TTY calls into mainstream
`
`telephone system and computer communication functions.” Id. at 3:52–54.
`
`Relevant to this case, Hansen teaches that when a calling party initiates a
`
`TDD call, the system checks if the called party is listed in a database of
`
`individuals who have a networked computer with real-time chat
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`functionality. See id. at 14:40–59. If so, the system can establish a
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`connection that enables real-time chat between them. Id. at 15:6–24.
`
`2. Claims 1 and 33
`
`Petitioner’s obviousness challenge based on Truetken and Hansen
`
`largely parallels its anticipation challenge over Truetken alone, except that,
`
`for the obviousness ground, the Petition relies on Hansen to show the
`
`limitation “checking for accessibility of a called party chat client associated
`
`with a called party.” See Pet. 34–36, 39; Ex. 1005 ¶ 100. We conclude that
`
`Petitioner has made an adequate showing that Hansen teaches that limitation.
`
`As Petitioner’s expert, Dr. Wicker, explains, Hansen discloses
`
`“checking a database to see if the called party has chat (teletypewriter, or
`
`‘TTY’) capability.” Ex. 1005 ¶ 100 (citing Ex. 1003, Abstract, 14:40–49);
`
`see Pet. 34–35. We agree with Petitioner this disclosure teaches “checking
`
`for accessibility of a called party chat client associated with a called party.”
`
`In addition, Petitioner made a sufficient showing that one skilled in
`
`the art had reason to combine the known elements in the manner Petitioner
`
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`12
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`suggests. See KSR, 550 U.S. at 418. The Petition explains, with relevant
`
`support from Dr. Wicker, that it would have been obvious for one skilled in
`
`the art to combine Hansen’s chat accessibility check with Truetken’s system
`
`“because a text server check would allow the options dialog box of Truetken
`
`to be automatically populated with communications medium options within
`
`the system capabilities of both parties,” and thus, “a SIP invitation is never
`
`sent requesting an unavailable communications medium.” Pet. 35–36 (citing
`
`Ex. 1005 ¶ 101).
`
`In all other regards, we adopt our analysis of Petitioner’s anticipation
`
`challenge based on Truetken. Based on the analysis above and our findings
`
`from the anticipation challenge, Petitioner’s showing satisfies the legal
`
`thresholds for obviousness. We, therefore, conclude Petitioner has
`
`demonstrated by a preponderance of the evidence that the subject matter of
`
`claims 1 and 33 would have been obvious over Truetken and Hansen
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`3. Claims 2, 3, 34, and 35
`
`Petitioner’s obviousness challenge based on Truetken and Hansen has
`
`the same deficiency as its ground based on Truetken alone. That is,
`
`Petitioner relies on distinct embodiments from Truetken, yet does not
`
`suggest combining those embodiments or explain why one skilled in the art
`
`would have done so. See Pet. 37. Thus, for the reasons explained above, we
`
`conclude Petitioner has not demonstrated by a preponderance of the
`
`evidence that the subject matter of claims 2, 3, 34, or 35 is unpatentable over
`
`Truetken and Hansen. See supra at 10.
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`III. CONCLUSION
`
`For the foregoing reasons, we determine that Petitioner has
`
`demonstrated by a preponderance of the evidence that:
`
`a) Claims 1 and 33 are unpatentable under 35 U.S.C. § 102(e) as
`
`anticipated by Truetken; and
`
`b) Claims 1 and 33 are unpatentable under 35 U.S.C. § 103(a) as
`
`obvious over Truetken and Hansen.
`
`We further determine that Petitioner has not demonstrated by a
`
`preponderance of the evidence that:
`
`a) Any of claims 2, 3, 34, or 35 is unpatentable under 35 U.S.C.
`
`§ 102(d) as anticipated by Truetken; or
`
`b) Any of claims 2, 3, 34, or 35 is unpatentable under 35 U.S.C.
`
`§ 103(a) as obvious over Truetken and Hansen.
`
`Because this is a Final Written Decision, parties to the proceeding
`
`seeking judicial review of the Decision must comply with the notice and
`
`service requirements of 37 C.F.R. § 90.2.
`
`Accordingly, it is:
`
`IV. ORDER
`
`ORDERED that claims 1 and 33 of the ’553 patent are unpatentable;
`
`and
`
`FURTHER ORDERED that claims 2, 3, 34, and 35 of the ’553 patent
`
`have not been proven unpatentable.
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`PETITIONER:
`
`Robert Kang
`Kristen Reichenbach
`Eugene Goryunov
`KIRKLAND & ELLIS LLP
`robert.Kang@kirkland.com
`kristen.reichenbach@kirkland.com
`eugene.goryunov@kirkland.com
`
`
`PATENT OWNER:
`
`Mark E. Miller
`Brian Cook
`O’MELVENY & MYERS LLP
`markmiller@omm.com
`bcook@omm.com
`
`
`
`
`15
`
`