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`Before MITCHELL G. WEATHERLY, CHRISTOPHER M. KAISER, and
`ROBERT L. KINDER, Administrative Patent Judges.
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`DONGHEE AMERICA, INC. and DONGHEE ALABAMA, LLC,
`Petitioners,
`
`v.
`
`PLASTIC OMNIUM ADVANCED INNOVATION AND RESEARCH,
`Patent Owner.
`____________
`
`Case IPR2017-01633 (Patent 6,866,812 B2)
`Case IPR2017-01647 (Patent 6,814,921 B1)
`____________
`
`Record of Oral Hearing
`Held on October 22, 2018
`____________
`
`
`
`
`
`Case IPR2017-01633 (Patent 6,866,812 B2)
`Case IPR2017-01647 (Patent 6,814,921 B1)
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`
`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
`BAS DE BLANK, ESQUIRE
`NICHOLAS H. LAM, ESQUIRE
`ALYSSA CARIDIS, ESQUIRE
`Orrick Herrington & Sutcliffe
`1000 Marsh Road
`Menlo Park, California 94025
`
`
`
`ON BEHALF OF THE PATENT OWNER:
`
`
`ROBERT C. MATTSON, ESQUIRE
`CHRISTOPHER RICCIUTI, ESQUIRE
`VINCENT K. SHIER, ESQUIRE
`Oblon, McClelland, Maier & Neustadt, LLP
`1940 Duke Street
`Alexandria, Virginia 22314
`
`
`
`
`The above-entitled matter came on for hearing on October 22, 2018,
`commencing at 1:00 p.m., at the U.S. Patent and Trademark Office, Madison
`Building, 600 Dulany Street, Alexandria, Virginia, 22314.
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`Case IPR2017-01633 (Patent 6,866,812 B2)
`Case IPR2017-01647 (Patent 6,814,921 B1)
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`P R O C E E D I N G S
`- - - - -
` JUDGE WEATHERLY: Welcome back.
` MR. de BLANK: Thank you.
` JUDGE WEATHERLY: It's been a little while, but not
`too long.
` This is a hearing for two cases today;
`IPR2017-01633 relating to U.S. Patent 6,866,812, and
`IPR2017-1647 dealing with Patent No. 6,814,921.
` My name is Judge Weatherly. I have Judge Kinder
` here to my left, and Judge Kaiser is joining us remotely.
` Because Judge Kaiser is appearing remotely, when
` you're delivering your argument, please make sure that you
` reference the slide numbers, if any, that you're using. It
` will make it easier for him to follow along. It also makes
` the transcript easier for us to use after the fact.
` I like to have -- even though it's not been that
` long since we've all been together, I'd like to have
` everyone introduce themselves before we start. Also, each
` side is going to get 60 minutes today.
` I understand we're going to have petitioner giving
` its entire case for both cases, followed by patent owner,
` then we'll go back to petitioner, and patent owner will have
` the last word on a surrebuttal.
` I think our preferences are to keep surrebuttals as
` short as possible.
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` So anyway, back to the introductions. Please, we'll
` have everyone introduce themselves -- reintroduce
` themselves, starting with petitioner and anyone you brought
` with you.
` MR. de BLANK: Thank you, Your Honor. My name is
`Bas de Blank with Orrick Herrington & Sutcliffe. With me are
`Nicholas Lam and Alyssa Caridis from Orrick. And also
`representatives from real party interests Kautex Textron,
`Fletcher Thompson and James Wensetter (sounds like).
` JUDGE WEATHERLY: Okay.
` MR. MATTSON: Good afternoon, Your Honor. Robert
`Mattson with The Oblon Firm for patent owner, Plastic Omnium.
`With me is Chris Ricciuti and Vincent Shier. Mr. Ricciuti
`will be presenting today for Plastic Omnium.
` JUDGE WEATHERLY: Okay. Excellent.
` So petitioner, since you're going first, how much
`time would you like to reserve for rebuttal?
` MR. de BLANK: 15 minutes, Your Honor.
` JUDGE WEATHERLY: 15 minutes. Okay.
` Whenever you're ready to come to the podium.
` MR. de BLANK: Your Honor, if you want, we have
`physical copies of the demonstratives that we can give you,
`as well --
` JUDGE WEATHERLY: Sure.
` MR. de BLANK: -- if it's easier.
` (Pause in the proceedings)
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` MR. de BLANK: Thank you, Your Honors. Good
`afternoon. As I said, my name is Bas de Blank. I'm here on
`behalf of petitioners.
` I'm going to begin with the '812 patent, followed by
` the '921 patents. I'll focus on what I understand to be the
` key disputes and issues between the parties, but of course,
` I would like to address whatever questions Your Honors may
` have, so please direct me in any way you'd like.
` Starting with the '812 patent and turning to
` Slide 3.
` There are four grounds for obviousness of the
` challenged claims; Claims 32, 48 through 41, 44 and 45, and
` then parallel Claims 16, 24 through 27, 30 and 31.
` The first ground is a combination of the Kasugai
` reference and Kagitani, and that's a reference -- the
` combination I'll focus on for the most part.
` The second ground adds an additional reference,
` Hata, to address the limitations added by Independent
` Claim 16, but that's really not in dispute, either the
` combination, the motivation to add Hata, or that the
` combination with Hata would address -- would be every
` element of the claims charged in grounds two. The
` dispute -- provided, of course, that there's a motivation to
` combine Kasugai and Kagitani, as petitioners have described.
` I will then touch on the other grounds, time
` permitting.
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` But the -- to start just with the construction for
` this case, the hollow body term has been construed by the
` Board in its decision, and the parties don't dispute it,
` that the hollow body is any article whose surface has at
` least one empty or concave part.
` There are two disputed claim terms -- parison and
` preassembled structure -- but neither of these disputes
` really have much bearing on the outcome of this case.
` The patent owner agrees, on page 14 of its response,
` that the construction of "parison" doesn't have any bearing,
` at least because the applied prior art depicts a parison.
` So it's a -- it's not really a dispute I think the Board
` needs to struggle with.
` And for "preassembled structure", that's a term that
` appears only in dependent claim -- Dependent Claims 40 and
` 41, I believe, and I don't believe that there's a dispute
` that the Kasugai reference describes the preassembled
` structure under either party's construction, though we
` explain in our papers why the construction -- if
` construction is necessary, it should simply be a premade
` structure.
` So turning then to Ground 1 regarding the invalidity
` of Claims 32 and the claims that depend from it.
` The Kasugai and Kagitani references are presented
` straightforward in a clear obviousness challenge.
` Kasugai describes blow-molding fuel tanks, and it
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` describes essentially every element of Claim 32, with the
` exception of how the two sheets -- or how the parison is
` formed into two sheets, which is described in Kagitani.
` Essentially, Kasugai has an embodiment in -- shown
` in Figure 7 and described in the patent that teaches using
` two sheets. It's silent as to the method of how those two
` sheets would be formed, but a person of ordinary skill in
` the art would know about the Kagitani and would see its
` teachings on how to form two sheets for use in a
` blow-molding process.
` JUDGE WEATHERLY: I apologize for interrupting.
` MR. de BLANK: No, please.
` JUDGE WEATHERLY: The way you're pronouncing the
`second reference is confusing people.
` MR. de BLANK: I apologize, Your Honor. I will --
`let me try again.
` JUDGE WEATHERLY: And it's distracting, and so I
`wanted to get it out there and clarified so that it could
`stop being distractive.
` MR. de BLANK: No. I apologize, Your Honor. It's
`my fault. Kagitani.
` JUDGE WEATHERLY: Kagitani? Is that how you
`pronounce it?
` MR. de BLANK: Okay.
` JUDGE WEATHERLY: Okay.
` MR. de BLANK: Kagitani.
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` JUDGE WEATHERLY: I wish we could just call it
`reference 2, but --
` MR. de BLANK: I wish (inaudible). That's what's
`throwing me off. I apologize.
` JUDGE WEATHERLY: I was actually wondering whether I
`was missing something. So I apologize for the interruption.
` MR. de BLANK: No, no. No, I apologize, Your Honor.
` So basically, the Kasugai reference, the first
`reference --
` JUDGE WEATHERLY: Yeah.
` MR. de BLANK: -- reference 1, teaches everything
`except the technique of how to form the -- form two sheets.
`It describes using two sheets and illustrates that
`embodiment, but doesn't say how you do it.
` The second reference, Kagitani, provides a technique
`to actually form two sheets from a parison for use in a
`blow-molding process consistent with Kasugai.
` So the combination of those two references together
`teach every element of Claim 32. And most of this I think is
`undisputed, but we'll just walk through it because it's
`clear --
` JUDGE WEATHERLY: And which slide are you on?
` MR. de BLANK: I'm sorry. I'm on Slide 15 now, Your
`Honor.
` JUDGE WEATHERLY: 15.
` MR. de BLANK: The preamble, if it's a limitation at
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`all, talks about a process of manufacturing a fuel tank, and
`Kasugai describes a method of manufacturing a fuel tank.
` Turning to Slide 16. The first element is extruding
`a parison. And as I mentioned before, the patent owner's
`response on page 14, they agree the prior art depicts a
`parison. And that's shown in Kasugai on Slide 16 in
`Figures 2 and Figure 7, and described in the corresponding
`text Column 4, lines 59 through 61 and Column 5, 42 through
`45.
` JUDGE KAISER: Is the -- is the twin sheet
`embodiment there that's shown in Figure 7, is there still a
`parison there? Is each sheet a parison? Or is the
`combination of the two sheets the parison? What's a parison
`there?
` MR. de BLANK: Yes, Your Honor. So a parison would
`be -- again, we go back to the construction that the parties
`have advanced. Our -- the petitioner's construction is
`simply the product obtained by passing through a die. The
`material that comes out of the die, a composition of at least
`one thermoplastic melt homogenized in an extruder whose head
`is terminated by a die.
` So if you look at Slide 16 and look at Figure 7, and
`what is coming out of the -- the top highlighted in yellow,
`numbers 38 shown on Figure 7, is described as -- as two
`sheets that compose parison 28.
` So a parison is extruded in Kasugai under either
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`embodiment, and it is -- then forms into two sheets in the
`embodiment shown in Figure 7.
` So the next element is cutting through said parison
` so as to form two portions separated by cut on Slide 17.
` And this is the element that Kasugai does not
` disclose, but is taught by Kagitani. And that's described
` in Slide 17 and shown on paragraph 7 of reference 2 where it
` describes providing severing blades at two locations -- so
` there's two places -- that allow parison 35 to be made into
` two sheets.
` JUDGE WEATHERLY: How explicit is Kagitani about
`parison 35 being a cylindrical body?
` MR. de BLANK: Well, it's -- it describes, as shown
`in paragraph 4, again on Slide 17, that the head of that
`parison is coming out of an accumulator head. It doesn't --
`I'm not sure that it expressly says that it's cylindrical,
`but I think that, when you're extruding it --
` JUDGE WEATHERLY: The parison is shown as having a
`diameter,
`though.
` MR. de BLANK: Yeah.
` JUDGE WEATHERLY: Okay.
` MR. de BLANK: And it's -- and it can be separated,
`it can be cut with the blades and formed into the two sheets,
`the two sheets that are being described in the -- as useful
`in the Kasugai first embodiment shown in Figure 7.
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` JUDGE WEATHERLY: Figure 2, Kagitani, looks like it
`expressly -- explicitly shows a cylindrical parison, also.
` MR. de BLANK: Yes, Your Honor. That's on
`Slide 18 --
` JUDGE WEATHERLY: I see. Okay.
` MR. de BLANK: -- Exhibit 1004.
` So the next element -- so Kagitani describes an
` embodiment where you would use two blades, and that's not
` specifically illustrated, but it's shown in a demonstrative
` created by Dr. Kazmer shown on Slide 19, Kazmer Figure 1,
` what that would look like.
` And while it's not a test for obviousness that you
` can really assemble the components together in a physical
` structure, in this case, one actually could. And that's --
` it's shown in Kazmer's Demonstrative Figure 2 on Slide 20
` how the Kagitani process would create two sheets, and that
` would be use in the Kasugai process shown in Figure 7 and
` described in the text to have the two sheets used in the
` construction of the fuel tank disclosed in Kasugai.
` And a person of ordinary skill in the art would be
` motivated to make this combination, to do this because of
` the express teachings in the Kasugai reference where it
` discloses and describes and even illustrates an embodiment
` using two sheets, and the fact that Kagitani talks about how
` those two sheets are made for a blow-molded process.
` And there are, as we go through it and is set forth
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` in Dr. Kazmer's declaration, additional benefits and reasons
` for using Kagitani's process in particular.
` JUDGE KAISER: I think you're probably right, that
`Kasugai and Kagitani together teach making two sheets, and
`putting them into a mold, and then doing something with them.
`I think patent owner has argued that the "something" is maybe
`what's lacking here. That Kagitani is -- or Kasugai is not
`very good at describing how you go from whatever it is you
`put in the mold to a fuel tank, other than it involves
`closing a mold around it in some way.
` And I wonder if you could address that a little bit,
`because I think that -- that's maybe the -- the biggest
`hurdle you've got here.
` MR. de BLANK: Thank you, Your Honor.
` So if I could turn to Slide 22. The something that
`is claimed as being required by Claim 32 is molding set two
`portions so as to form said fuel tank.
` And Kasugai does describe how that molding process
`works, and it describes it in Column 4, lines 62 through 66,
`where it talks about how air is blown into the parison, and
`the outside wall 2 is formed by blow-molding.
` And that's shown in -- it's shown in Figure 7, which
`corresponds to Figure 1 -- it's just a two-sheet
`embodiment -- and shows both the process and shows the
`resulting structure and the illustrations of the patent.
` So Kasugai does describe what happens next to the
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`sheets. What happens next is that air is blown into them,
`against the mold, against the outside wall that's formed by
`that blow-molding process.
` And then the final element is just, again, part of
` Kagitani's disclosure. It describes specifically how the
` cuts are made, and it requires two cuts to form two separate
` sheets. And as we discussed -- it's shown on Slide 23, but
` as discussed, that's clearly disclosed in Kagitani.
` So I'm happy to walk through the dependent claims,
` Your Honor, if you wish, although I've just touched briefly
` on the Ground 2, the combination with Hata.
` And that basically -- the difference between
` Claim 16 and Claim 32 is Claim 16's a little bit broader.
` It addresses any hollow body, it's not limited to a fuel
` tank, but it requires a multilayered parison and be narrower
` in that fashion.
` The Hata reference describes a multilayer parison,
` and this is shown on Slide 33, where -- and it talks
` about -- it both describes it as having these inner layers
` and outer layers in Column 3, lines 21 through 26, but it
` also provides the motivation to combine, about how this
` multilayer parison is superior in gasoline barrier
` properties and impact resistance, which is obviously key for
` a fuel tank.
` And as I mentioned at the beginning, I don't believe
` that there's any dispute over whether there would be a
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` motivation to combine Hata with the other two references or
` whether Hata provides the additional limitations of
` Claim 16.
` So turning just briefly then to the third ground,
` the other combination. That starts on Slide 35. Ground 3
` is the combination of Hatakeyama in view of Kagitani.
` Kagitani stands for the same teaching we discussed before,
` the multiple blades to make multiple sheets. Hatakeyama is
` another reference that describes making one cut into the
` parison in order to insert objects or simple structures into
` it.
` It doesn't describe making two cuts like the
` Kagitani reference does, but as Dr. Kazmer explains in his
` declaration, and is set forth in the briefing, a person of
` ordinary skill in the art would understand that, if you wish
` to insert a larger object than would be allowable through
` simply one cut into the Hatakeyama parison, it would be
` obvious, in light of the teachings of Kagitani, to make two
` cuts and divide it into two sheets.
` JUDGE KAISER: Is there any evidence in the record
`that there are any things that people insert into fuel tanks
`that are larger than the, whatever it is, baffle plates and
`whatever the other thing was that's in Hatakeyama already?
` MR. de BLANK: I think, Your Honor, there's evidence
`in the record that Hatakeyama would be limited to the
`diameter of the parison coming out, because it's coming down,
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`you're making a cut and putting things in.
` Fuel tanks are, of course, blow-molded. They're
`larger than the diameter of the parison, and you could
`have -- I would have to look to see if there is a citation in
`the record, but it would be obvious, I think, to a person of
`ordinary skill that if you want to have an object that's
`going to be the size of the fuel tank, or that would fit
`inside the finished fuel tank, you couldn't do that through a
`single cut in Hatakeyama's parison because that's limited to
`the diameter. You would make two cuts, separate them as
`taught in Kagitani, and then proceed with Hatakeyama's
`blow-molding.
` So then, again, I'm happy to address any questions
` related to the dependent claims, if you wish. Otherwise,
` I'll turn to the --
` JUDGE KINDER: Patent owner did make some arguments
`on the dependent claims. If you'd have time, you might want
`to make those.
` MR. de BLANK: Okay. So let me break -- yes, yes,
`your Honor, I will.
` So then let me turn back, if I could, to Slide
`number 24, which addresses the first challenged dependent
`claim, Claim 38, and why it's obvious in light of Kasugai and
`Kagitani.
` Claim 32 simply -- sorry -- Claim 38 adds a step of
` holding apart the portions of the parison and a subsequent
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` step of bringing them together, and that's shown in Kasugai
` Figure 7, which shows the two sheets being separated apart,
` and then Figure 1 shows the mold closed where the sheets
` have been brought together to form the fuel tank.
` Turning to Claim -- sorry -- the description also --
` support on Slide 25, the reference to Kagitani.
` But turning to Claim 39, the next challenged claim
` on Slide 26. That talks about this step of inserting an
` object in said parison during the step of holding apart the
` two portions. And again, that's illustrated in Kasugai,
` Figure 7, which shows the inserted structure and the
` accessories being inserted between the two sheets prior to
` the mold closing while the sheets are being -- are being
` held apart.
` Claim 40 on Slide 27 just requires that the object
` is a preassembled structure. And while the parties dispute
` the proper construction of "preassembled structure", I don't
` believe that there's a dispute that, with respect to
` Kasugai, the structure shown in Figure 3 holding the holding
` plate and the components would be either party's definition
` of "preassembled structure".
` Claim 41 on Slide 28 talks about where the
` preassembled structure is configured to anchor to an
` internal wall of said fuel tank. And here, I believe the
` dispute is whether or not the -- it could anchor anywhere
` inside the fuel tank, any internal wall at any point, or
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` whether patent owners are correct, that that excludes the
` seam or joinder between the fuel tank walls.
` And I would make two responses to that. First,
` there's nothing in the patent that would exclude the seam or
` joinder from being part of the internal wall. When you look
` at the inside of the fuel tank, that's the internal wall.
` That's what's meant by the claim, and that's the broadest
` reasonable interpretation.
` But secondly, if you look at the -- what the patent
` owner described as the nipple area is kind of 11A, 12A, and
` 13A, those are certainly not at the seam, those are in
` the -- within the internal wall of the fuel tank, and they
` anchor the various components to those spots.
` JUDGE KINDER: So your position is that the seams
`themselves would be kind of integrated with the wall.
` MR. de BLANK: Yes, Your Honor. Once the -- once
`this is closed, anything -- anything on the inside would be
`the internal wall, to differentiate it from the external
`wall, which would be the outer side of the fuel tank.
` But there's nothing in the patent, there's nothing
`in the prosecution history, and there's no reason to say some
`parts but not all of the inside of the fuel tank are the
`internal wall.
` JUDGE KINDER: Is there anything you can describe
`that would teach us what "to anchor to an internal wall"
`means?
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` MR. de BLANK: The patent gives examples that I
`would say would be nonlimiting where different accessories
`could be anchored or attached to the wall. And the examples
`that the patent gives, I don't believe it happens that
`they're anchored on the seam. But those are not limiting
`examples, and there's nothing that teaches this is the only
`way to anchor them.
` JUDGE KINDER: Thank you.
` JUDGE KAISER: The seam in Kasugai's twin sheet
`embodiment, as opposed to its cylinder embodiment, that --
`this sort of crimped area that the edge of that internal
`plate fits into, it seems like it might be easier to make
`that airtight, or leak tight, or whatever word you want to
`use to describe sort of tightness using the cylinder than it
`is using two sheets that have to overlap at that specific
`location. And so I wonder if this all kind of goes back to
`the enablement question again. Does Kasugai really give you
`enough to figure out how to close a two-sheet parison at a
`location where you're trying to crimp an internal accessory
`onto a wall and sort of weld all these parts together?
` I mean, that -- I get that there's -- obviously,
`a person of ordinary skill in the art knows how to weld things
`together, but welding three pieces is different than welding
`two pieces, and it seems at least intuitive, that it would
`be a little more difficult. And I just wondered if there's
`anything in Kasugai, or anywhere else in the record for that
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`matter, that gets you there.
` MR. de BLANK: Yeah. I guess, Your Honor, I say I
`have two parts to that response. One is, I agree with you
`that a person of ordinary skill in the art would understand
`how to join things together. These are engineers with
`backgrounds in this technology, and they would know how to
`form the weld, even with the intervening layer in between.
` Kasugai does describe the Figure 7 as a part of its
`first embodiment, so it is shown as -- as that part -- part
`of the embodiment, and it shows the finished product in
`Figure 1 that would be made through that two-sheet
`embodiment.
` And the thing that I would add is that the '812
`patent also describes having things between the two sheets
`that are separating them. If you may remember from last
`time, we had a longer discussion about how you would position
`the accessories by holding the sheet that was going -- that,
`as the mold was closing, that there were these cones or tabs
`that could be fit into the outer mold. That's part of the
`'812's description, also.
` So the '812 has no further teaching than the Kasugai
`reference does about how one would take the -- if any extra
`steps were necessary, how one would do them.
` And I think the conclusion one can draw from that is
`the '812 patent inventors understood that it would be within
`the skill of a person of ordinary skill in the art to be able
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`to close two sheets, even if there is a positioning plate,
`like in the '812, or parts of the insert, as in the Kasugai
`reference. So it would be enabled for the same reason that
`the '812 is enabled.
` JUDGE WEATHERLY: I think what I'm hearing you
`saying is you don't have to describe very much for a skilled
`artisan to know how to do these things.
` MR. de BLANK: Yes, Your Honor. I mean, this is --
`certainly, what is described is sufficient for a skilled
`artisan to practice it.
` JUDGE WEATHERLY: Okay.
` JUDGE KAISER: So do we get to assume that the
`'812 patent is enabled? I mean, in district court, we would
`be interpreting claims and doing things to preserve the
`validity of the patent claims and then proceeding
`accordingly.
` But, I mean, we're here to determine the validity of
`the patent claims, at least in a sense, and so I'm not sure
`we get to make that same assumption here.
` I get the argument. I mean, it's a nice argument
`that, well, look, if the combination of Kasugai and Kagitani
`isn't enabled, then neither is the '812 patent. And, you
`know, you should feel free to make that argument in district
`court, if you need to, but do you get to make that argument
`here?
` MR. de BLANK: Your Honor, I don't believe the Board
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`could find the patent invalid for lack of enablement, for
`example, in an IPR proceeding. I agree with you there.
` I guess I would leave it to patent owner. If patent
`owner wants to come back and argue that the '812 patent is
`not enabled, and for that reason the combination of Kasugai
`and Kagitani would not be sufficient, patent owner is free to
`do so, but I think that if you ask them is this combination
`enabled --
` JUDGE WEATHERLY: I don't see a straight face while
`you're making that argument. I tip my hat to you that you
`just made it.
` MR. de BLANK: I practice in the mirror, Your Honor.
` JUDGE WEATHERLY: At least until I broke in.
` (Laughter)
` MR. de BLANK: But thank you. But essentially, yes,
`Your Honor. To address it, I think it's at the heart of the
`argument. The person of ordinary skill in the art looking at
`this art, looking at the '812 patent, would understand from
`the '812 patent you can form this weld between two sheets.
` Looking at Kasugai and Kagitani, you would
`understand from those patents you can form this weld between
`these two sheets.
` Now, you asked before could it be easier to do this
`from a single parison without a cut? Maybe it could be.
`Maybe there would be instances where that would be
`preferable or desired, but not if you're trying to insert
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`large accessories, not if you're doing these other things.
` And the fact that there might be some instances
`where it's easier doesn't mean it's not obvious to make the
`combination, as described in the prior art.
` Just running down the last of the independent
` claims. Claim 45 talks about molding comprising (inaudible)
` of bringing the two portions together, which is obviously
` what happens with the tank when the molds are closed. And
` welding the two portions so as to form a leak tight joint,
` and Kasugai expressly talks about how airtightness is
` achieved. That would certainly be -- once you're airtight,
` you're certainly not having leaks. That's Kasugai.
` Column 20, lines 20 through 22. And 2, lines 31 through 36.
` And I'm on Slide 30, Your Honor.
` Turning then to the '921 patent, unless there's any
` further questions on the '812.
` The '912 -- I'm sorry -- '921 patent adds a couple
` (inaudible) while Section 1 (inaudible) adds the idea of
` compression molding.
` And compression molding is not a term that's --
` either party has identified for construction, though it
` seems that a lot of patent owner's arguments hinge on its
` interpretation of that term.
` What the parties agree on, and is shown in Slide 64,
` the constructions for "shell" and "accessory". Those aren't
` disputed.
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`Case IPR2017-01633 (Patent 6,866,812 B2)
`Case IPR2017
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