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`
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
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`
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`
`
`
`
`PETITION FOR INTER PARTES REVIEW OF
`
`UNITED STATES PATENT 8,379,801
`
`UNDER 35 U.S.C. §§ 311-319 & 37 C.F.R. §§ 42.100-42.123
`
`
`
`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 1 of 68
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`

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`TABLE OF CONTENTS
`
`I. EXHIBIT LIST ............................................................................................... IV
`
`II. MANDATORY NOTICES .............................................................................. V
`A. REAL PARTY-IN-INTEREST............................................................................... V
`
`B. RELATED MATTERS ......................................................................................... V
`
`C. LEAD AND BACK-UP COUNSEL ........................................................................ V
`
`D. SERVICE INFORMATION ................................................................................... VI
`
`
`III. GROUNDS FOR STANDING ......................................................................... 1
`
`IV. THE ‘801 PATENT ........................................................................................... 1
`
`V. PRECISE RELIEF REQUESTED .................................................................. 2
`A. CLAIM CONSTRUCTION ..................................................................................... 2
`
`B. GROUND 1: CLAIMS 1-4, 7- 9, 13, 14, 17, AND 18 ARE ANTICIPATED UNDER 35
`U.S.C. § 102(B) BY THE BRIDGE VIDEO PUBLICATION ............................................ 2
`
`1. Material Facts Relevant to Ground 1 .......................................................... 3
`
`2. Basis for Invalidity Under Ground 1 ........................................................... 3
`
`
`C. GROUND 2: CLAIMS 1, 2, 7, AND 9 ARE ANTICIPATED UNDER 35 U.S.C. §
`102(B) BY U.S. PATENT 6,567,503 (“ENGELKE 1”) ............................................... 11
`
`D. GROUND 3: CLAIMS 1, 2, 9-13, 25, 26, 28, AND 29 ARE ANTICIPATED UNDER
`35 U.S.C. § 102(B) BY U.S. PATENT 5,809,112 (“RYAN”) ..................................... 13
`
`E. GROUND 4: CLAIMS 1, 3-6, AND 8-29 ARE OBVIOUS UNDER 35 U.S.C. §
`103(A) OVER U.S. PATENT 7,881,441 (“ENGELKE 2”) AND IN VIEW OF U.S.
`PATENT 7,428,702 (“CERVANTES”) ....................................................................... 19
`
`
`
`
`ii
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`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 2 of 68
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`F. GROUND 5: CLAIMS 3-6 AND 8 ARE OBVIOUS UNDER 35 U.S.C. § 103(A)
`OVER U.S. PATENT 5,809,112 (“RYAN”) IN VIEW OF U.S. PATENT 7,428,702
`(“CERVANTES”) ..................................................................................................... 46
`
`G. GROUND 6: CLAIMS 5, 6, 10-12, 15, 16, 25, 26, 28, AND 29 ARE OBVIOUS
`UNDER 35 U.S.C. § 103(A) OVER THE BRIDGE VIDEO PUBLICATION IN VIEW OF
`U.S. PATENT 7,428,702 (“CERVANTES”) ............................................................... 50
`
`H. GROUND 7: CLAIMS 19-23 ARE OBVIOUS UNDER 35 U.S.C. § 103(A) OVER
`THE BRIDGE VIDEO PUBLICATION IN VIEW OF U.S. PATENT 6,567,503 (“ENGELKE
`1”) ....................................................................................................................... 58
`
`
`VI. SUMMARY ..................................................................................................... 60
`
`
`
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`iii
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`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 3 of 68
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`

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`I.
`
`
`EXHIBIT LIST
`
`The following Exhibit List is provided in accordance with 37 C.F.R. §
`
`42.63(e):
`
`EXHIBIT LIST
`
`Number
`
`Brief Description
`
`1001
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`
`
`
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`U.S. Patent 8,379,801
`
`Notice of Allowance
`
`Transcription and screen shots of a video tutorial
`published online regarding Bridge 2.0 software
`(“Bridge Video Publication”)
`
`“About us” page from Advantage Software website
`
`E-Tips Newsletter, No. 71 (Nov. 2007)
`
`U.S. Patent 6,567,503 (“Engelke 1”)
`
`U.S. Patent 5,809,112 (“Ryan”)
`
`U.S. Patent 7,881,441 (“Engelke 2”)
`
`U.S. Patent 7,428,702 (“Cervantes”)
`
`CapTel® Summer 2007 Newsletter
`
`Declaration of Xavier Santistevan supporting exhibits
`
`Declaration of Christopher Butler authenticating
`archived website of Bridge Video Publication
`
`“Prior Art in the Field of Business Method Patents -
`When is an Electronic Document a Printed Publication
`for Prior Art Purposes,” Coggins, Wynn W., The
`United States Patent and Trademark Office, Fall 2002
`
`
`iv
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`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 4 of 68
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`

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`II. MANDATORY NOTICES
`
`As required under 37 C.F.R. § 42.8, the following mandatory notices are
`
`filed with the Patent Trial and Appeal Board (“Board”).
`
`A. Real Party-In-Interest
`The real parties-in-interest, pursuant to 37 C.F.R. § 42.8(b)(1), include
`
`
`
`Ultratec, Inc. (“Petitioner”), having a place of business at 450 Science Drive,
`
`Madison, Wisconsin 53711, and CapTel, Inc., having a place of business at 450
`
`Science Drive, Madison, Wisconsin 53711.
`
`B. Related Matters
`United States application number 13/768,918 filed on February 15, 2013,
`
`
`
`which claims the benefit of United States patent 8,379,801, may be affected by a
`
`decision in this proceeding.
`
`C. Lead and Back-Up Counsel
`Lead and back-up counsel for the instant proceeding are:
`
`
`
`Lead Counsel
`Michael Jaskolski
`Reg. No. 37,551
`Attorney for Petitioner
`michael.jaskolski@quarles.com
`QUARLES & BRADY LLP
`411 East Wisconsin Avenue
`Suite 2350
`Milwaukee, Wisconsin 53202
`Tel: (414) 277-5711
`Fax: (414) 978-8711
`
`
`
`
`Back-Up Counsel
`Nicholas Seay
`Reg. No. 27,386
`Attorney for Petitioner
`nicholas.seay@quarles.com
`QUARLES & BRADY LLP
`33 East Main Street
`Suite 900
`Madison, Wisconsin 53703
`Tel: (608) 283-2484
`Fax: (608) 294-4967
`
`
`
`v
`
`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 5 of 68
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`Service Information
`
`D.
`Service information is as follows, with the postal mailing address being
`
`
`
`identical to the hand-delivery address:
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`
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`
`
`
`
`
`
`
`
`
`QUARLES & BRADY LLP
`c/o Michael Jaskolski
`411 East Wisconsin Avenue
`Suite 2350
`Milwaukee, Wisconsin 53202
`Tel: (414) 277-5711
`Fax: (414) 978-8711
`
`
`
`vi
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`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 6 of 68
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`III. GROUNDS FOR STANDING
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`Petitioner certifies that United States patent 8,379,801 (“‘801 Patent”) is
`
`available for inter partes review having been filed on November 24, 2009, and that
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`Petitioner is not barred or estopped from requesting this inter partes review
`
`challenging all claims of the ‘801 Patent on the Grounds identified in this Petition.
`
`IV. THE ‘801 PATENT
`
`The ‘801 Patent is directed to “providing error correction in a text caption,”
`
`and describes replacing a block of transcribed text with another block of text on a
`
`display. (Ex. 1001 at Abstract, 6:14-40). The ‘801 Patent claims to differ from
`
`“conventional” correction methods like “backspacing an error in a text caption and
`
`displaying corrected text or providing a corrected portion (e.g., a word or sentence)
`
`at the end of a previously provided text caption.” (Ex. 1001 at 1:49-53).
`
`
`
`During prosecution, the examiner found that the prior art did not disclose
`
`making “an inline correction during the conversation, such that the corrected block
`
`of text appears within the text caption in a proper location as produced in the voice
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`signal, wherein replacing at least one block of text with a corrected block of text
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`and displaying the corrected block of text within the text caption occur at least
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`substantially simultaneously.” (Ex. 1002 at 6). Petitioner respectfully believes the
`
`Examiner’s finding was incorrect and that, as shown herein, the prior art (including
`
`some art that was of record and some that was not) does disclose displaying
`
`1
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`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 7 of 68
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`corrected text blocks as inline corrections during a real time conversation.
`
`V.
`
`
`PRECISE RELIEF REQUESTED
`
`Petitioner specifically requests that Claims 1-29 of the ‘801 Patent be found
`
`invalid under 35 U.S.C. §§ 102 and 103 for the reasons set forth in Grounds 1-7.
`
`A. Claim Construction
`Claims 1-29 of the ‘801 Patent are given their “broadest reasonable
`
`
`
`construction in light of the specification.” See 37 C.F.R. § 42.100(b). For clarity,
`
`the term “block of text” (and the plural “blocks of text”) as used in the ‘801 Patent
`
`has the following construction to one skilled in the art:
`
`Term
`
`Construction
`
`Support
`
`block(s) of text
`
`at least one word,
`sentence, or line of text
`
`‘801 Patent (Ex. 1001) at 5:13-
`16; 5:60-63; 6:14-16; 6:29-37;
`FIG. 3; and FIG. 4
`
`One of ordinary skill is considered to be a person that is, among other attributes,
`
`familiar with the electronic generation, correction, and display of transcribed or
`
`captioned text that is transmitted to and displayed on an electronic device. (See,
`
`e.g., Ex. 1001 at 3:11-19 and 5:5-11).
`
`B. Ground 1: Claims 1-4, 7- 9, 13, 14, 17, and 18 are Anticipated
`Under 35 U.S.C. § 102(b) by The Bridge Video Publication
`
`
`
`References herein to the “Bridge Video Publication” will cite to Exhibit
`
`1003 for ease of reference, though Petitioner relies upon the underlying video
`
`publication itself as prior art.
`
`2
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`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 8 of 68
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`
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`a.
`
`1. Material Facts Relevant to Ground 1
`The Bridge Video Publication was publically accessible online as early as
`
`January 2, 2008, i.e., more than one year before the effective filing date of the ‘801
`
`Patent. (Ex. 1011 at ¶¶ 4-8; Ex. 1012).
`
`b.
`
`One skilled in the art could have located the Bridge Video Publication by
`
`exercising reasonable diligence because it was publicly available on a website
`
`directed to transcription/captioning. (Ex, 1011 at ¶¶ 4-8; Ex. 1012).
`
`c.
`
`Attached to this Petition as Exhibit 1003 is an accurate set of screen shots
`
`and typed transcription of the Bridge Video Publication. (Ex. 1011 at ¶ 6).
`
`Basis for Invalidity Under Ground 1
`
`2.
`In view of the Material Facts above, the Bridge Video Publication is a prior
`
`
`
`art “printed publication” under § 102(b) to the ‘801 Patent. See Voter Verified,
`
`Inc. v. Premier Election Solutions, Inc., 698 F.3d 1374, 1381 (Fed. Cir. 2012) (an
`
`article was a “printed publication” because one skilled in the art of electronic
`
`voting would have been aware of a prominent electronic voting technology website
`
`containing the article); Ex Parte Mettke, No. 2008-0610, 2008 WL 4448201
`
`(B.P.A.I. Sept. 30, 2008) (stating that a video tape was a prior art printed
`
`publication); MPEP § 2128; Ex. 1013 at 3 (discussing the use of the “Wayback
`
`Machine” to establish prior art). The Bridge Video Publication discloses to one of
`
`ordinary skill in the art each and every element arranged as required by Claims 1-4,
`
`3
`
`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 9 of 68
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`
`
`7-9, 13, 14, 17, and 18 of the ‘801 Patent:
`
`Claim of the ‘801 Patent
`
`Specific Reference to Prior Art
`
`1.
`A method of
`providing error correction
`in a text caption, the
`method comprising:
`
`displaying a text
`
`caption on at least one
`electronic device, the text
`caption including one or
`more blocks of text
`representing a text
`transcription of a voice
`signal;
`
`replacing a first
`
`block of text of the text
`caption with another
`block of text during a
`real-time conversation
`from which the voice
`signal is generated; and
`
`The Bridge Video Publication discloses a method of
`providing error correction of a real-time transcription.
`(Ex. 1003 at 1-9). The Bridge Video Publication
`discloses the “Bridge/Law Bridge Auto-Refresh
`protocol” that facilitates real-time display of a
`reporter’s screen with the screen of one or more
`client computers. (Ex. 1003 at 3-8). The Bridge
`Video Publication states that “whenever corrections
`or changes or Real Time editing was performed on
`the reporter’s screen, the client’s screens were
`automatically refreshed.” (Ex. 1003 at 4-8).
`
`The Bridge Video Publication discloses displaying a
`text caption on a court reporter/transcriptionist’s
`computer screen (i.e., the top window entitled
`“Automatic Realtime Document Refresh”) and on a
`client’s computer screen (i.e., the bottom window
`entitled “Bridge”), the text caption including one or
`more blocks of text (e.g., “Welcome to the Bridge
`pro...” displayed on the client’s screen) that can
`represent a text transcription of a voice signal heard
`by the transcriptionist (see, e.g., the example question
`and answer illustrated). (Ex. 1003 at 6-8).
`
`The Bridge Video Publication discloses replacing a
`first block of text (e.g., “Welcome to the Bridge
`pro...” shown on the client’s screen in Ex. 1003 at 4-
`7) with another block of text (e.g., the all-caps text
`block “WELCOME TO THE BRIDGE PROGRAM”
`shown on the reporter’s screen in Ex. 1003 at 7)
`during a real-time conversation from which the voice
`signal is generated. (See, e.g., Ex. 1003 at 3-7).
`
`displaying another
`
`block of text within the
`text caption on the at least
`
`The Bridge Video Publication discloses displaying
`the another block of text (i.e., the all-caps text block
`“WELCOME TO THE BRIDGE PROGRAM”) on
`
`4
`
`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 10 of 68
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`

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`
`
`one electronic device at a
`location of the first block
`of text within the text
`caption.
`
`2.
`The method of
`claim 1, further
`comprising identifying
`one or more errors within
`the first block of text of
`the text caption with
`respect to what was said
`in the voice signal prior to
`generating the another
`block of text.
`
`3.
`The method of
`claim 1, further
`comprising generating the
`another block of text with
`a first device and
`
`both the reporter’s screen (see Ex. 1003 at 7-8) and
`on the client’s screen (see Ex. 1003 at 8) at a location
`of the block of text within the transcription (i.e., the
`replacement, all-caps block of text on the client’s
`screen is located where the original block of text was
`located).
`
`The Bridge Video Publication discloses that a
`reporter/transcriptionist views the transcribed blocks
`of text on the reporter’s screen to identify a
`transcription error prior to generating the another
`block of text. (Ex. 1003 at 3-8 (“1998, Bridge/Law
`Bridge Auto-Refresh to take the rough out of Rough
`Draft”)).
`
`The Bridge Video Publication discloses generating
`the another block of text (i.e., “WELCOME TO THE
`BRIDGE PROGRAM”) with a first device (i.e., the
`reporter’s computer). (Ex. 1003 at 4-7).
`
`transmitting the
`
`another block of text to
`the at least one electronic
`device.
`
`The Bridge Video Publication discloses transmitting
`(via the “Bridge Auto-Refresh protocol”) the another
`block of text to the at least one electronic device (i.e.,
`the client’s screen). (Ex. 1003 at 8).
`
`4.
`The method of
`claim 3, wherein
`generating another block
`of text comprises:
`identifying one or more
`errors within the first
`block of text of the text
`caption; and
`
`The Bridge Video Publication discloses that a
`reporter/transcriptionist views the transcribed blocks
`of text on the reporter’s screen to identify a
`transcription error within the blocks of text. (Ex.
`1003 at 3-8 (“1998, Bridge/Law Bridge Auto-Refresh
`to take the rough out of Rough Draft”)).
`
`generating the
`
`another block of text
`including the first block
`
`The Bridge Video Publication discloses generating
`the another block of text (i.e., “WELCOME TO THE
`BRIDGE PROGRAM”) that completely replaces the
`
`5
`
`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 11 of 68
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`

`

`
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`of text of the text caption
`having each of the one or
`more errors replaced with
`corrected text within the
`text caption.
`
`7.
`The method of
`claim 1, wherein the first
`block of text of the text
`caption includes one or
`more errors, and
`
`wherein the another
`
`block of text includes
`corrected words.
`
`8.
`The method of
`claim 1, further
`comprising generating the
`text caption on a first
`device and
`
`transmitting the
`
`text caption to the at least
`one electronic device.
`
`9.
`A communication
`system, comprising:
`
`first block of text (i.e., “Welcome to the Bridge
`pro...”) and the identified errors therein. (Ex. 1003 at
`8).
`
`The Bridge Video Publication discloses the first
`block of text (i.e., “Welcome to the Bridge pro...”) of
`the transcription including errors (e.g., upper/lower
`case errors). (Ex. 1003 at 8).
`
`The Bridge Video Publication discloses the another
`block of text (i.e., “WELCOME TO THE BRIDGE
`PROGRAM”) includes corrected words (e.g.,
`capitalization). (Ex. 1003 at 8).
`
`The Bridge Video Publication discloses the
`reporter/transcriptionist generating the text
`transcription on the reporter’s computer (i.e., a first
`device). (Ex. 1003 at 4-7).
`
`The Bridge Video Publication discloses transmitting
`(via the “Bridge Auto-Refresh protocol”) the text
`transcription to the at least one electronic device (i.e.,
`the client’s screen). (Ex. 1003 at 8).
`
`The Bridge Video Publication discloses a
`communication system that provides real-time
`communication of a transcription between a
`reporter’s computer screen and the computer screen
`of one or more clients. (Ex. 1003 at 1-9).
`
`a communication
`
`device including a
`processor; a computer-
`readable medium coupled
`to the processor; a display
`coupled to the processor;
`and at least one
`
`The Bridge Video Publication discloses a reporter’s
`computer (i.e., a communication device) and a
`client’s computer screen (i.e., the bottom window
`entitled “Bridge”) that inherently includes a
`processor, a computer-readable medium coupled to
`the processor, a display coupled to the processor, and
`at least one application program (e.g., a program
`
`6
`
`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 12 of 68
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`

`

`
`
`application program
`stored in the computer-
`readable medium,
`
`wherein the at least
`
`one application program,
`when executed by the
`processor, is configured
`to: display a text caption
`including one or more
`blocks of text on the
`display, the text caption
`indicating a text
`transcription of a voice
`signal received by the
`communication device;
`and
`
`display another
`
`block of text within the
`text caption on the display
`at a location that
`corresponds to an actual
`location as produced by
`the voice signal.
`
`implementing the Bridge Auto-Refresh protocol)
`stored in the computer-readable medium.
`Specifically, these particular elements are necessarily
`present in the reporter’s computer and/or the client’s
`computer described in the Bridge Video Publication,
`and it would be so recognized by persons of ordinary
`skill because, at a minimum, the basic components of
`a computer (and the familiar “windows” illustrated in
`the Bridge Video Publication) unambiguously
`disclose that the Bridge Video Publication
`incorporates a computer as a component of the
`communication system.
`
`The Bridge Video Publication states that “whenever
`corrections or changes or real-time editing was
`performed on the reporter’s screen, the client’s
`screens were automatically refreshed.” (Ex. 1003 at
`4-8). The Bridge Program discloses that a text
`caption including one or more blocks of text (e.g.,
`“Welcome to the Bridge pro...” displayed on the
`client’s screen) is displayed on a reporter’s computer
`screen (i.e., the top window entitled “Automatic
`Realtime Document Refresh”) and on a client’s
`computer screen (i.e., the bottom window entitled
`“Bridge”), the text caption that can represent a text
`transcription of a voice signal heard by the
`transcriptionist, input to the reporter’s computer, and
`received by the client’s computer (see, e.g., the
`example question and answer illustrated). (Ex. 1003
`at 6-8).
`
`The Bridge Video Publication discloses displaying
`the another block of text (i.e., the all-caps text block
`“WELCOME TO THE BRIDGE PROGRAM”) on
`both the reporter’s screen (see Ex. 1003 at 7-8) and
`on the client’s screen (see Ex. 1003 at 8) at an actual
`location of the block of text within the transcription
`(e.g., the replacement, all-caps block of text on the
`client’s screen is located where the original block of
`text was actually located).
`
`7
`
`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 13 of 68
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`

`

`
`
`13. The communication
`system of claim 9,
`wherein the at least one
`application program is
`further configured to
`replace at least one block
`of text of the text caption
`with the another block of
`text and display the text
`caption on the display of
`the communication device
`substantially
`simultaneously.
`
`14. A computer-
`readable media storage
`medium storing
`instructions that when
`executed by a processor
`cause the processor to
`perform a method for
`providing error correction
`in a text caption, the
`method comprising:
`
`displaying a text
`
`caption representing a text
`transcription of a voice
`signal transmitted
`between a first device and
`a second device, the text
`caption including at least
`one block of text; and
`
`The Bridge Video Publication discloses replacing a
`block of text (e.g., “Welcome to the Bridge pro...”
`shown on the client’s screen in Ex. 1003 at 4-7 with
`another block of text (e.g., the all-caps text block
`“WELCOME TO THE BRIDGE PROGRAM”
`shown on the client’s screen in Ex. 1003 at 8)
`displayed on the client’s screen substantially
`simultaneously as the another block of text is
`generated by the reporter. (See, e.g., Ex. 1003 at 3-
`8).
`
`The Bridge Video Publication discloses a reporter’s
`computer (i.e., a communication device) and a
`client’s computer (i.e., the bottom window entitled
`“Bridge” representing the client’s screen) that
`inherently include a computer-readable medium
`having stored thereon the Bridge 2.0 software.
`
`The Bridge Video Publication discloses displaying a
`text caption on a court reporter/transcriptionist’s
`computer screen (i.e., the top window entitled
`“Automatic Realtime Document Refresh”) and on a
`client’s computer screen (i.e., the bottom window
`entitled “Bridge”), the text caption including one or
`more blocks of text (e.g., “Welcome to the Bridge
`pro...” displayed on the client’s screen) that represent
`a text transcription of a voice signal heard by the
`transcriptionist (see, e.g., the example question and
`answer illustrated). (Ex. 1003 at 6-8). The text
`caption is transmitted from the court reporter’s device
`(i.e., the “first device”) to the client’s device (i.e., the
`“second device”).
`
`8
`
`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 14 of 68
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`

`

`
`
`displaying another
`
`block of text within the
`text caption on at least
`one of the first device and
`the second device by
`replacing the at least one
`block of text by the
`another block of text at a
`location of the at least one
`block of text within the
`text caption.
`
`17. A method,
`comprising:
`
`generating a text
`
`caption as a text
`transcription of a voice
`signal;
`
`transmitting the
`
`text caption to a
`communication device;
`
`The Bridge Video Publication discloses displaying
`the another block of text (i.e., the all-caps text block
`“WELCOME TO THE BRIDGE PROGRAM”) on
`both the reporter’s screen (see Ex. 1003 at 7-8) and
`on the client’s screen (see Ex. 1003 at 8). The
`another block of text replaces an original block of
`text (i.e., the non-capitalized text block “Welcome to
`the Bridge program”) at the location where the
`original block of text appeared within the
`transcription (i.e., the replacement, all-caps block of
`text on the client’s screen is located where the
`original block of text was located). (Compare Ex.
`1003 at 7 to Ex. 1003 at 8).
`
`The Bridge Video Publication discloses a method of
`providing error correction of a real-time transcription.
`(Ex. 1003 at 1-9).
`
`The Bridge Video Publication discloses that a court
`reporter listening to a verbal conversation (which one
`skilled in the art would understand could be audibly
`or via microphone) transcribes the conversation to
`generate a text caption. (See, e.g., Ex. 1003 at 4).
`
`The Bridge Video Publication discloses that the court
`reporter’s device transmits the text caption to a client
`device (i.e., a communication device) in real time.
`On page 4 of the Bridge Video Publication, a text
`caption is displayed on a court
`reporter/transcriptionist’s computer screen (i.e., the
`top window entitled “Automatic Realtime Document
`Refresh”) and is transmitted in real time to a client’s
`computer screen (i.e., the bottom window entitled
`“Bridge”). (See, e.g., Ex. 1003 at 4). According to
`the Bridge Video Publication, this transmission may
`be accomplished via the “Bridge Auto-Refresh
`protocol,” over “typical real-time cables, or networks,
`or wirelessly.” (Ex. 1003 at 15).
`
`
`
`identifying an error The Bridge Video Publication discloses displaying a
`
`9
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`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 15 of 68
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`

`
`
`
`
`in a block of text within
`the text caption; and
`
`transmitting a
`
`corrected block of text to
`the communication device
`as an inline correction for
`the text caption to replace
`the block of text within
`the text caption with the
`corrected block of text at
`a proper location as
`produced in the voice
`signal during
`communication between
`at least two parties.
`
`18. The method of
`claim 17, wherein the
`error is a disagreement
`between the text caption
`and what was stated in the
`voice signal.
`
`text caption on a court reporter/transcriptionist’s
`computer screen (i.e., the top window entitled
`“Automatic Realtime Document Refresh”), which the
`court reporter can review in real time while making
`transcriptions. This allows the court reporter to
`identify errors and make “corrections” to the
`transcription. (Ex. 1003 at 3-8).
`
`The Bridge Video Publication discloses the
`“Bridge/Law Bridge Auto-Refresh protocol” that
`allows real-time display of a reporter’s screen on a
`client’s screen. (Ex. 1003 at 3-8). The Bridge Video
`Publication states that “whenever corrections or
`changes or Real Time editing was performed on the
`reporter’s screen, the client’s screens were
`automatically refreshed.” (Ex. 1003 at 4-8).
`As an example, the Bridge Video Publication
`discloses the court reporter correcting the non-
`capitalized text block “Welcome to the Bridge
`program” to be in all-caps, and transmitting the
`corrected block of text via the Auto-Refresh protocol
`to the client’s device, such that the all-caps text block
`“WELCOME TO THE BRIDGE PROGRAM”
`appears on both the reporter’s screen (see Ex. 1003 at
`7-8) and on the client’s screen (see Ex. 1003 at 8) in
`the place of the original, non-capitalized text block.
`(Compare Ex. 1003 at 7 to Ex. 1003 at 8).
`
`The Bridge Video Publication discloses that the court
`reporter can make “corrections” and “changes” to the
`transcription in real time, and refers to the court
`reporter’s edits as “tak[ing] the rough out of rough
`draft.” (Ex. 1003 at 3-8). Inherently the
`“corrections” (versus any other “change” or “edit”) a
`transcriptionist makes to a transcription he or she is
`generating are due to a disagreement between the
`transcription and the words used in the monitored
`conversation. (Ex. 1003 at 3-8).
`
`10
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`Ultratec Exhibit 1012
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`C. Ground 2: Claims 1, 2, 7, and 9 are Anticipated Under 35 U.S.C.
`§ 102(b) by U.S. Patent 6,567,503 (“Engelke 1”)
`
`Engelke 1 (Ex. 1006) is prior art to the ‘801 patent under § 102(b) and
`
`discloses to one skilled in the art each and every element arranged as required by
`
`Claims 1, 2, 7, and 9 of the ‘801 Patent:
`
`Claim of the ‘801 Patent
`
`Specific Reference to Prior Art
`
`1.
`A method of
`providing error correction
`in a text caption, the
`method comprising:
`
`displaying a text
`
`caption on at least one
`electronic device, the text
`caption including one or
`more blocks of text
`representing a text
`transcription of a voice
`signal;
`
`Engelke 1 discloses an editing system for real-time
`remote transcription in which words can be
`identified and corrected. (Ex. 1006 at Abstract).
`
`Engelke 1 discloses that the voice signal 16 of a
`hearing user 12 is provided to a relay computer and
`converted to a text caption that is presented on a
`display 48 (see, e.g., Ex. 1006 at FIGS. 1 and 3) to a
`call assistant 40 as a text transcription (see, e.g., Ex.
`1006 at 3:38-46; 5:39-56).
`
`replacing a first
`
`block of text of the text
`caption with another block
`of text during a real-time
`conversation from which
`the voice signal is
`generated; and
`
`Engelke 1 discloses that when the call assistant 40 at
`the relay identifies an error in the text caption on
`display 48 (see, e.g., Ex. 1006 at FIG. 3), the call
`assistant 40 selects the text error (e.g., via touch)
`and replaces the text error by revoicing corrected
`text or typing corrected text. (See, e.g., Ex. 1006 at
`6:13-34).
`
`displaying another
`
`block of text within the
`text caption on the at least
`one electronic device at a
`location of the first block
`of text within the text
`caption.
`
`Engelke 1 discloses that when the text within the
`text caption is replaced by the call assistant 40, the
`corrected text is displayed on the call assistant’s
`interface in the location of the text that was
`replaced. (Ex. 1006 at 6:26-34).
`
`11
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`Ultratec Exhibit 1012
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`

`

`
`
`2.
`The method of claim
`1, further comprising
`identifying one or more
`errors within the first block
`of text of the text caption
`with respect to what was
`said in the voice signal
`prior to generating the
`another block of text.
`
`7.
`The method of claim
`1, wherein the first block
`of text of the text caption
`includes one or more
`errors, and
`
`wherein the another
`
`block of text includes
`corrected words.
`
`9.
`A communication
`system, comprising:
`
`a communication
`
`device including a
`processor; a computer-
`readable medium coupled
`to the processor; a display
`coupled to the processor;
`and at least one application
`program stored in the
`computer-readable
`
`Engelke 1 discloses that a voice signal 16 from a
`hearing user 12 is played to a call assistant 40 via a
`headset 38 and the call assistant 40 revoices the
`voice signal 16 to a speech recognition program 70
`to generate the text caption. (Ex. 1006 at FIG. 1 and
`3:34-46). The call assistant 40 first identifies an
`error in the text caption on display 48 (see, e.g., Ex.
`1006 at FIG. 3), the call assistant selects the text
`error (e.g., via touch), and then replaces the text
`error by revoicing corrected text or typing corrected
`text. (See, e.g., Ex. 1006 at 6:13-34). The corrected
`text is a correction to the text caption and therefore
`is a correction with respect to what was said in the
`voice signal prior to generating the correction text.
`
`Engelke 1 discloses that a word in the text
`transcription may include an error. (Ex. 1001 at
`6:13-34).
`
`Engelke 1 discloses that the error in the text can be
`replaced by touching the text on a touch screen and
`revoicing or typing a corrected word to replace the
`text including the error. (Ex. 1001 at 6:13-34).
`
`Engelke 1 discloses a system to enable
`communication between a hearing user 12 and a
`hearing impaired user 14. (See, e.g., Ex. 1006 at
`2:66-3:13).
`
`Engelke 1 discloses a relay 10 including a computer
`18 having a processor 44, 56 joined on a bus 58 with
`memory 60, and a display 48 coupled to the
`processor 44, 56. (Ex. 1006 at 3:40-45; 4:1-4; FIGS.
`1 and 4). The processor 56 runs programs 70, 78
`stored in memory 60. (Ex. 1006 at 4:12-41).
`
`12
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`Ultratec Exhibit 1012
`Ultratec v Sorenson IP Holdings Page 18 of 68
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`

`
`
`
`
`
`
`medium,
`
`wherein the at least
`
`one application program,
`when executed by the
`processor, is configured to:
`display a text caption
`including one or more
`blocks of text on the
`display, the text caption
`indicating a text
`transcription of a voice
`signal received by the
`communication device;
`and
`
`display another
`
`block of text within the
`text caption on the display
`at a location that
`corresponds to an actual
`location as produced by the
`voice signal.
`
`Engelke 1 discloses that the executed program 70,
`78 of the computer 18 receives the voice of the
`hearing user 12 and converts the voice signal 16 to a
`text caption that is presented on the display 48 to a
`call assistan