UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`LUXSHARE PRECISION INDUSTRY CO., LTD.,
`Petitioner,
`
`V.
`
`BING XU PRECISION CO., LTD.,
`Patent Owner.
`_____________
`
`Case IPR2017-01404 (Patent 8,512,071 B2)
`Case IPR2017-01492 (Patent 8,758,044 B2)
`Case IPR2017-01657 (Patent 8,740,631 B2)
`_____________
`
`
`
`Record of Oral Hearing
`Held: October 9, 2018
`_____________
`
`
`
`
`Before DEBRA K. STEPHENS (via videoconference), BRYAN F. MOORE,
`and STACEY G. WHITE (via videoconference), Administrative Patent
`Judges.
`
`
`
`
`

`

`Case IPR2017-01404 (Patent 8,512,071 B2)
`Case IPR2017-01492 (Patent 8,758,044 B2)
`Case IPR2017-01657 (Patent 8,740,631 B2)
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`
`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
`CHRISTOPHER KAO, ESQUIRE
`ROBERT C.F. PÉREZ, ESQUIRE
`BROCK S. WEBER, ESQUIRE
`Pillsbury, Winthrop, Shaw, Pittman LLP
`1650 Tysons Boulevard, 14th Floor
`McLean, VA 22102
`
`
`
`ON BEHALF OF THE PATENT OWNER:
`
`
`TAMMY J. DUNN
`CALIFF T. COOPER (admitted pro hac vice)
`Osha Liang LLP
`909 Fannin Street, Suite 3500
`Houston, TX 77010
`
`
`
`
`
`The above matter came on for hearing on Tuesday, October 9, 2018,
`commencing at 1:01 p.m., at the U.S. Patent and Trademark Office, Madison
`Building East, 600 Dulany Street, Alexandria, Virginia 22314.
`
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`Case IPR2017-01404 (Patent 8,512,071 B2)
`Case IPR2017-01492 (Patent 8,758,044 B2)
`Case IPR2017-01657 (Patent 8,740,631 B2)
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`
`P R O C E E D I N G S
`- - - - -
` THE COURT: This is the hearing for IPRs 2017-1404, 1492, and
`1657. We have -- I'm Judge Moore. We have remotely Judges White and
`Stephens. With that, we'll take appearances starting with Petitioner.
` MR. KAO: Chris Kao with Pillsbury on behalf of Petitioner
`Luxshare. With me is the lead counsel on the case, Mr. Rob Perez. And my
`colleague, Brock Weber, all from the same firm.
` THE COURT: Thank you.
` MR. COOPER: Good afternoon, Judge. My name is Califf Cooper.
`I am back-up counsel for Patent Owner, Bing Xu. With me is my colleague,
`Tammy Dunn, who is lead counsel. And good to meet you.
` THE COURT: Thank you. All right. Because we have judges that
`are remote, I always remind the parties that they can't see everything in the
`courtroom as we see it. They can't necessarily see the board, so when you're
`referring to exhibits for the record and for the judges, you need to identify
`what slide you're on. And if you're referring to evidence that's not on
`exhibit, you have to get the remote judges the time to bring up that evidence
`and get it in front of them. So just be aware of those things.
` We also have an issue of timing.
`When we wrote the hearing order, we put one hour per case, but looking at
`this case, that timing would be, I think, excessive for the amount of material
`we have to cover here. So I would suggest that an hour and a half per side
`would probably suffice. I think the 1404 and 1492 cases are -- overlap
`pretty much, and then the 1657 may have some other issue. So unless one of
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`the parties feels like that's not going to be enough time, I think we're going
`to work with that.
` Okay. So with that, Petitioner has the burden, so Petitioner will go
`first, and if you could let me know how much time you want to reserve,
`given our new time frame, how much time do you want to reserve for
`rebuttal?
` MR. KAO: Sure. So if I have an hour and a half, I'll reserve a half an
`hour for rebuttal.
` THE COURT: Okay. And any time you're --
` MR. KAO: We're in the queue, Your Honor. Hopefully I won't need
`to use all of that time.
` THE COURT: Fine.
` MR. KAO: Certainly.
` (Speaking out of hearing.)
` MR. KAO: Thank you. So I will address first the petitions for the
`’071 patent and the ’044 patent together. As Your Honor noted, I think the
`issues with respect to those patents are overlapping, as the claims are at least
`in all material respects identical, so we can address those two together. And
`then I will turn to the petition on the ’631 patent.
` So first at slide four we just simply have a list of all of the grounds
`that have now been instituted after the SAS decision. And so that's just by
`way of reference on slide four.
` With respect to the ’071 and ’044 patents, I intend to address five
`main arguments or the five arguments that the Patent Owner makes with
`respect to the claims of these two patents. But I'll address those in turn. I
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`don't believe there's a dispute as to any of the other grounds that have been
`set forth. Particularly after the SAS decision, the Patent Owner did not
`address any of the other grounds that had been instituted. So I think these
`are the five main disputes between the parties. So I'll limit my discussion
`today to those. Happy to answer questions from the judges if you have
`questions on any other grounds. But my intention is just to discuss these.
` So turning now to slide seven, both the ’071 and the ’044 patents
`concern electrical connectors that are compliant with the SATA standard, and
`SATA connectors were known and conventional at the time of the invention
`of the two patents here. So these patents don't purport to have invented
`SATA connectors. They purported to -- are directed to purported
`improvements to SATA connectors.
` Turning to slide eight, this just is simply an illustration of figure 3
`from the two patents with the key components of the connector identified in
`different colors. So the housing is component 10, the PCB is number 40 in
`green. The FFC is number 50 in brown, and then the power terminals and
`the data terminals, respectively, are noted in red as 20 and 30.
` Now, I should note that under the SATA standard, they are actually --
`the standard requires that there be seven data terminals, which are reflected
`in the diagram in figure 3. The standard also requires that there be 15 power
`terminals. They're not all depicted in the figure. I think for space reasons
`they're not all shown. But there should be 15 power terminals. And if you --
`actually look at the housing number 10, they -- I think they don't accurately
`reflect the ten inputs on the housing side where you would insert the 15
`power terminals.
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` So turning to claim 1 of the ’071 and the ’041, the only dispute
`between the parties is with respect to the element that is not highlighted in
`this slide ten, which is the FFC, the Flexible Flat Cable. There's no dispute
`as to any of the other limitations being present in lieu of the prior art. And
`with respect to the Flexible Flat Cable, it's merely a difference in claim
`construction that is disputed between parties. In the institution decision, the
`Board correctly in our view noted that the Flexible Flat Cable is not limited
`to a laminated ribbon cable, as asserted by the Patent Owner. And this is
`supported by the intrinsic evidence here. The patent specification when
`referring to the FFC simply calls it a Flexible Flat Cable. There's no other
`limitations built into that term. It's -- there are many references in the patent
`specifications of the flex -- to the FFC as the Flexible Flat Cable.
` One example is at column one, line 44 of the ’071 patent. The Patent
`Owner now appears to be asserting that Flexible Flat Cable should be even
`more narrowly limited than they asserted before in response to the original
`petition. The Patent Owner asserts that the Flexible Flat
`Cable must have one flat connectors, which of course appears nowhere in
`the specification. Second, the Patent Owner asserts that the Flexible Flat
`Cable must be laminated. Again, the word laminated appears nowhere in the
`specification and is not required. And third, which appears to be a new
`argument, the Patent Owner is now claiming that there can only be one
`insulating layer in order to be a Flexible Flat Cable. And again, that
`limitation is found nowhere in the intrinsic evidence. The intrinsic evidence
`supports only that FFC must be read to be a Flexible Flat Cable, which are
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`ordinary words that any of us and any person of ordinary skill in the art
`would understand.
` THE COURT: So isn't -- is it your position that Flexible Flat Cable is
`not a term that's used in the industry? It's a term that's used in the industry,
`right, it's just that at least at the time of the invention, given the what we had
`in front of us, there was no agreed upon way to define Flexible Flat Cable.
`Is that right?
` MR. KAO: Correct. So because there's no support in the intrinsic
`evidence, the Patent Owner is relying on extrinsic evidence and what the
`industry may -- how the industry uses the term Flexible Flat Cable. I think
`the
`evidence in the record shows that the industry uses the term broadly. So
`there are certainly references, so there are exhibits in the record, which use
`the term Flexible Flat Cable to describe the type of cable that the Patent
`Owner is talking about. A laminated ribbon connector with flat conductors.
`That is a type of flexible flat conductor that's discussed in the industry
`literature. The industry literature, however, also uses the term Flexible Flat
`Cable to discuss cables with round connectors that are not necessarily
`laminated. They're just enclosed in a -- an insulating layer made of silicone
`or some other flexible material that is flat. In other words, it is wider, the
`width is greater than the height. Which is all that you need to be considered
`flat. And there are many pictures of this in the exhibits, some of which we
`have in the slide. So I think the industry definition would be broad, it would
`encompass both the Patent Owner's view of what an FFC is and what we --
`the Petitioner consider to be an FFC. And the expert testimony, at least of
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`Dr. Lall, the Petitioner's expert, supports this. And the exhibits, which we
`have put in the record.
` In slide 12 there's some examples of these.
` THE COURT: Excuse me, do you -- can you point to the specific
`evidence you have that isn't just something that was recently pulled off of a
`website? Do you have anything from the time of the invention to support
`the
`interpretation?
` MR. KAO: I think the best evidence of that is that some of the
`website materials actually date back to the time of the invention. But what
`Dr. Lall did after hearing the testimony of the Patent Owner's expert is that
`the FFC was very narrowly defined, he went and actually cited to and has
`put in the record a number of patents that predate the ’071 and the ’044
`patent, some of which predate them by 30 years. And those are Exhibits
`1031 to 1035 in the 1404 petition. The same exhibits exist with respect to
`the petition for the
`’044 patent, they just have different numbers. But if you look at the ’071
`petition, they're Exhibits 1031 through 1035. And they are shown -- some of
`which are shown on slides 16 and 17 of the demonstratives.
`These are all figures from patents whose titles all say Flexible Flat
`Cable, and you can see that the figures show round connectors, for example.
`They're not laminated. These are all -- these were all discussed as being Flat
`Flexible Cables. And that is consistent of course with the website evidence
`that is depicted in slide 12. These are all referring to Flat Flexible
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`Cables as cables with round connectors and insulating layers that were
`not laminated, that just surround the conductors.
` So I think the evidence in the record at least as to the proper claim
`construction, obviously the intrinsic record supports it most strongly that the
`term FFC cannot be as limited and as narrow as the Patent Owner suggests,
`but also the extrinsic evidence, both the exhibits in the record and the
`testimony of the Petitioner's expert, Dr. Lall.
` And I should note that the Patent Owner's expert goes to great lengths
`to try to argue that a traditional SATA cable, which he had illustrated in his
`expert declaration is not a Flat Flexible Cable. But it's simply not credible.
`So he did what he could to avoid saying the word flat at his deposition when
`describing this. So instead he called this a planer cable. But the definition
`of the word planer is simply flat. So he's doing his best to avoid calling a
`cable a SATA cable that looks like this on slide 13 a flat cable, but of course
`it is. And the Patent Owner is just trying to get around this by claiming,
`well, the Flexible Flat Cable that we claim in the ’071 and ’044 patents has
`reck -- I mean, has flat conductors and this has round, but none of this
`appears in the intrinsic evidence, and that's required here.
` So given the proper construction of the term Flexible Flat Cable, I
`think there should be no dispute that Wu, the reference relied on here,
`anticipates the ’071 or the ’044 patents. Because Wu discloses a Flexible
`Flat Cable, and that's illustrated on slide 18, which is figure 1of the Wu
`patent. And the cable is number 3 in this diagram, which is colored in
`yellow. That is the cable. It is plainly flat. And I think both experts, both
`the Patent Owner's expert and the Petitioner's expert agree that it would be
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`flexible because the insulating layer is used for these types of cables.
`There's always a silicone type of coating which naturally bends and is
`flexible, and there's no dispute about that in the record.
` And even if Wu doesn't anticipate, even if this number 3 is not a
`Flexible Flat Cable, which I submit that it is, it would certainly be obvious to
`use an FFC of the type that the Patent Owner contends is a proper
`FFC in place of the cable used in Wu. Dr. Pecht, who is the Patent Owner's
`expert, testified at his deposition that the type of FFC that the Patent Owner
`relies on, a laminated ribbon cable, were well known decades before the
`’071 and the ’044 patents, and they were used in these types of applications.
`So if Wu doesn't disclose an FFC, which I believe it does, it would still have
`been obvious to use another type of FFC, the type that the Patent Owner is
`relying on. They serve the same purpose, so they could just easily be
`exchanged for the other. So with that, I'll move to claim 2, unless there are
`any further questions as to claim 1.
` Okay. So with respect to claim 2, the primary issue that's disputed
`between the parties is whether the prior art cited in the petition discloses that
`the pitch between two adjacent first contacts is less than a pitch between any
`two adjacent first soldering the holes. And that's the case in claim 2 in both
`the ’071 and the ’044. Now, there are two primary grounds that I'm going to
`discuss here with respect to claim 2. The first is that claim 2 is obvious
`based on Wu alone. And secondly, that Wu is obvious based on a -- that the
`’071 and the ’044 patents are obvious in light of Wu and the AAIH.
` So let me first start with Wu on its own. So Wu actually shows the
`difference in pitch between the contacts on the PCB and the soldering holes.
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` THE COURT: Now, what evidence in Wu do we have? I know that
`or it's my understanding anyway from cases from the Federal Circuit that
`drawings can't be taken to be to scale unless there's some evidence that they
`are to scale. So you're relying on kind of what we see here, but what
`evidence from the Spec do we have that the drafter was being exacting when
`he drew the holes 204 or the holes 220? I think you mentioned in your
`opening that there were certain connections that should be 15 which were
`actually ten and so, if I'm going to rely on this picture, what do I have from
`the Spec that tells me that it's to scale?
` MR. KAO: Sure. And I think the most important thing is that Wu,
`like the ’071 and the ’044 patents, disclosed SATA connectors. So because
`of that, they have to have the features that I discussed earlier. Which is -- if
`you look at what's labeled 220 which is highlighted in green, there have to
`be contacts to accommodate all of the data pins and all of the power pins that
`are required for a SATA connector. So that means that there have to be --
`even though it's not necessarily, drafted to scale or depicted to scale, there
`have to be at least 22 contact pads where the contacts are addition closed in
`220. And similarly, and the accurate number is shown here, it's just very
`small.
` For the soldering holes 204, there are actually 22 of those. Seven for
`the data terminals and 15 for the power terminals. And so even if this is not
`necessarily drawn to scale and the scale is not disclosed in the specification,
`the drawing at least shows you that the height of the PCB is much smaller
`than the width of the PCB. And indeed, that's the whole point of the Wu
`invention, which is to try to make this connector have a smaller form factor.
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`And the pitch between the soldering holes 204, are also defined by the SATA
`specification. So that cannot change. The distance between the soldering
`holes, the pitch, is set forth in the SATA standard at pages -- it's Exhibit 1009
`is the SATA standard, and the pitch is defined on pages 74 and 76. So since
`the pitch there is immoveable, if you're going to reduce the form factor --
`of the connector, the only way you could do that is by reducing the form
`factor of the cable and the corresponding contacts on the PCB. And that's
`what the patent discusses and that's what's shown in the picture.
`Otherwise, the height would be the same as the width if you were going to
`use the same pitch. So the fact that this shows the height being much, much
`smaller than the width I think is enough to establish that it's showing a
`different pitch between the contacts 220 and the soldering holes 204.
` And then the second point I would make as to why Wu renders the
`’071 and the ’044 obvious, so there's no dispute amongst the experts that if
`you were to use an FFC along the lines that the Patent Owner discusses, the
`laminated ribbon cable, which, you know, in our view would be obvious to
`use as well, even the Patent Owner's own expert says that that type of cable
`necessarily has a finer pitch than the pitch required by the SATA standard for
`the terminals. And he testified to that at his deposition, which is shown at
`slide 21. On the right, the Patent Owner's expert said, I asked him even in
`2011, this was the time of the patent, is it the case as you defined FFCs the
`pitch between the conductors of the FFC are finer than the SATA standard
`pitch, and he agreed. So if you were to use the FFC that was known to have
`existed at the time in 2011, the pitch would necessarily be finer, which is
`also
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`consistent with Wu. As I said, that's indeed the whole point of these
`inventions is to reduce the size of the cable. You don't want to have a cable
`that's that wide. You want to have it narrower and since you cannot change
`holes 204, the best way to do it is to change the cable number 3 and the
`contacts 220.
` So, the second ground is combining Wu with the AAIH, the Area
`Array Interconnection Handbook. And this handbook also illustrates that
`this type of what's called a fan-out connection where you're going from a
`finer pitch to a
`wider pitch is well known in the art. When you're making electrical
`connections between any types of contact in order to save space, in order to
`make the form factor smaller, this was illustrated, repeatedly that this is one
`way you can do that. And so on slide 23, we show a diagram from the AAIH
`showing that fan-out connections were well known. The primary argument
`that the Patent Owner makes with respect to the AAIH is that you wouldn't --
`a person of ordinary skill in the art would not look at this handbook when
`considering the design of a SATA connector, because the handbook relates
`to electrical connections on a PCB. But there really is no difference.
`Electrical connections that are -- that we're discussing here in the context of
`the ’071 and the ’044 are also electrical connections on a PCB. The
`difference is you're connecting a cable to various terminals as opposed to,
`for instance, a chip on a PCB. But the electrical connections that are on the
`PCB are exactly the same. And in fact, the experts -- both experts in this
`case, Dr. Pecht
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`for the Patent Owner and Dr. Lall for the Petitioner, together wrote a chapter
`of a book on electrical connections that discusses both electrical connections
`on a PCB in the chip context and in the connector context. And they said
`that you would look at art in both of these realms when thinking about
`connections.
`Because from an electrical connection standpoint, they're exactly the
`same. You would follow the same approach. And so I think in our view, a
`person of ordinary skill in the art would look at the AAIH. That is what Dr.
`Lall has testified to, Petitioner's expert. And the fact that now he coauthored
`a chapter with the Patent Owner's expert that similarly interchanges
`technology in the chip space and the cable connection space reflects that. So
`I don't think it's well founded to say that a person of ordinary skill in the art
`would ignore this type of teaching.
` In addition, and this is not art that we're relying on for any grounds,
`but just to rebut the Patent Owner's -- Dr. Pecht's testimony in his deposition
`that this type of fan-out design was not known in the art and was in fact
`novel in the ’071 and ’044 patents, we have put in the record Exhibits 1023
`and 1024. 1023 is the Babow reference, which reflects this type of fan-out
`design on a PCB. And similarly, Exhibit 1027, which is the Bartholomew
`reference, similarly discloses those. And again, this is strictly in the record
`to rebut Dr. Pecht's testimony that this wasn't known in the art, which is
`contradicted by both the AAIH which we put in, but that also Exhibits 1023
`and 1027.
` I'll now turn to claim 3. Claim 3 of the ’071 and ’044 patents, the
`dispute there is whether Wu discloses a bending portion of the FFC. And
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`Case IPR2017-01404 (Patent 8,512,071 B2)
`Case IPR2017-01492 (Patent 8,758,044 B2)
`Case IPR2017-01657 (Patent 8,740,631 B2)
`
`with respect to the bending portion, both experts agree that the cable in Wu
`is flexible so that it -- again, it's -- the insulating layer is made out of silicone
`material, which will bend. And so, therefore, Wu, in our view, anticipates
`the claim 3 limitation that it has a flexible cable that will bend as it's exiting
`the housing of the connector. But in any case, even if that isn't anticipated,
`even if that is not shown directly, it would be an obvious modification to Wu
`to bend the cable using an additional piece of housing to hold it in as a way
`simply to make sure that the cable is more secure. It's just another way of
`making it more secure so that it won't disconnect accidentally during use.
` So with respect to claim 3, I think the Patent Owner's main arguments
`are that Wu teaches away from this modification, which on institution the
`Board correctly found that it did not. The invention in Wu does disclose
`having, the point of it, was to have a smaller form factor, which I mentioned.
`But that has to do with using a smaller cable, as we discussed. If you bend
`the cable and put it at a different angle, that doesn't change the form factor at
`all. It's just a way to hold the cable in place differently. I should also note
`that neither of the ’071 or the ’044 require any specific degree of bending. It
`just says a first bending portion. So we've illustrated it in the petition and on
`slide 29 as a 90 degree angle, but it doesn't have to be that. It could even be
`a small, five degree bend to (inaudible) better hold in place the cable. But as
`I said, I don't believe that any of that changes the form factor of the
`connector,
`and Wu doesn't teach away from having that type of bend.
` The Patent Owner also argues that it would be impossible to do this,
`but there's no evidence in the record as to why this would be impossible.
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`Case IPR2017-01404 (Patent 8,512,071 B2)
`Case IPR2017-01492 (Patent 8,758,044 B2)
`Case IPR2017-01657 (Patent 8,740,631 B2)
`
`Again, it's a very simple modification rather than have the cable exit the
`housing straight, it would just exit it at some angle.
` So moving on to claim 4. So claim 4 of the ’071 patent and the ’044
`patent require a latch, and that is the limitation that's in dispute, whether
`there is a latch disclosed in the combination of Wu and Tang. And in
`particular, I don't believe there's any dispute between the parties that Tang
`does in fact disclose a latch. Those are shown here in figure 1 on slide 32,
`circled in red. Those are the two latches that are disclosed in Tang. The
`Patent Owner's argument is that because those latches are manufactured
`separately and then inserted into the housing, they do not disclose what is in
`claim 4 of the
`’071 and the ’044 patents. However, there's nothing in the claim language
`that would limit the latch in the housing to be a latch that is manufactured as
`part of the housing as part of a molding process. It simply says that the
`insulated
`housing has at least one latch. And although I don't have it on a slide, if you
`look at figure 2 of the Tang patent, it shows the latch inserted into the
`housing. An exhibit number just for reference. So it's Exhibit 1005, figure
`2. And although I don't have it on a slide, I'll try to hold it up. Figure 2 of
`Exhibit 1005 shows the latch, those two pieces that are circled in red,
`inserted into a --
`as part of the housing. So that plainly discloses the latch that is discussed in
`the ’071 and the ’044 patents.
` So turning to claim 8, claim 8 also, we argue, is obvious in view of
`Wu and the AAIH, which is the same handbook we discussed earlier. Claim
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`Case IPR2017-01404 (Patent 8,512,071 B2)
`Case IPR2017-01492 (Patent 8,758,044 B2)
`Case IPR2017-01657 (Patent 8,740,631 B2)
`
`8 recites a bending tail. That is, the difference between claim 8 and claim 1
`is that there is a bending tail soldered to soldering portions. So rather than
`having a soldering portion that's inserted into a soldering hole, which is what
`claim 1 claims, claim 8 recites a bending tail of the conductor that is
`soldered to essentially a pad. And the AAIH shows this.
` It's hard to see on the screen, but this is slide 35. Exhibit 1004, which
`is the AAIH handbook at page 61, the figure depicts this again using a chip,
`but the concept is exactly the same. Whether it's a chip or a part of a cable,
`it shows that if you were going to solder a conductor on to the PCB, on to a
`pad on the PCB, you can bend it and have what they call there is a gull wing
`type lead.
`So you would bend the conduct to solder it down. So that bending tail
`is disclosed in the AAIH. The Patent Owner makes a similar argument as to
`why a person of ordinary skill in the art would not look to the AAHI
`handbook. I've addressed that earlier, so I won't go through that again. But
`we believe, and Dr. Lall, Petitioner's expert, believes this would be
`something you would look at, and this type of bending tail was well known
`in the art. It
`was something that practitioners in the art knew how to do and would apply
`here, if you were not going to use soldering holes, if you were just going to
`solder directly on to the PCB.
` So that covers the arguments with respect to the ’071 and the ’044
`that I believe are in dispute. So I'll now move on to the ’631 patent, which is
`the 1657 petition. So there are two arguments I think in dispute between the
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`Case IPR2017-01404 (Patent 8,512,071 B2)
`Case IPR2017-01492 (Patent 8,758,044 B2)
`Case IPR2017-01657 (Patent 8,740,631 B2)
`
`parties as to the ’631 patent. First, as to claim one, the Patent Owner argues
`that neither Wu nor Su disclose an FFC, Flat Flexible Cable, and that
`argument is the same as the discussion that we had with respect to claim 1 of
`the ’071 and the ’044 in terms of the claim construction of the term Flat
`Flexible Cable. So for the same reasons that we believe Wu discloses a Flat
`Flexible Cable with respect to the other two patents, we believe it discloses
`that here. And in addition -- so Wu is on the left on slide 44, which is the
`same Flat Flexible Cable that we referred to earlier. Su
`also discloses a Flat Flexible Cable at figure 9, which is on the right of slide
`44. And similarly, these do have round conductors, not the type of flat
`conductors that the Patent
`Owner claims is necessary. But again, there's nothing in the specification of
`the ’631 patent that would require flat conductors or laminated insulation
`versus the type of Flexible Flat Cable that is disclosed in Su with round
`conductors. But where the conductors
`are arranged and laminated together and insulated together in a way that they
`are flat. Obviously the height of
`this cable is much lower than the width, and that's the point of a flat cable.
` So the second issue with respect to claim 13 is whether Wu and Su
`disclose the use of adhesives at the point where you are soldering, to further
`ensure that the conductor is connected to in that case the soldering hole.
` THE COURT: So I think Patent Owner's point on this issue is that for
`Su and Wu, you're implementing adhesives to connect plastic