UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`Shenzhen Zhiyi Technology Co. Ltd., d/b/a iLife,
`Petitioner
`
`v.
`
`iRobot Corp.,
`Patent Owner.
`
`
`
`Patent No. 6,809,490 to Jones et al.
`
`IPR Case No. IPR2017-02061
`
`
`
`REQUEST FOR REHEARING
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`Shenzhen Zhiyi Technology Co. Ltd., d/b/a iLife,
`Petitioner
`
`v.
`
`iRobot Corp.,
`Patent Owner.
`
`
`
`Patent No. 6,809,490 to Jones et al.
`
`IPR Case No. IPR2017-02061
`
`
`
`REQUEST FOR REHEARING
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Patent No. 6,809,490
`
`
`
`
`Request for Rehearing
`
`2.
`
`
`B.
`
`C.
`
`TABLE OF CONTENTS
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`TABLE OF EXHIBITS .......................................................................................... iii
`THE BOARD MISAPPREHENDED PETITIONER’S ARGUMENT
`I.
`WITH RESPECT TO LIMITATION 1(d) ..................................................... 1
`The Board misapprehended Petitioner’s argument regarding
`A.
`how limitation 1(d) is met by Ueno-642. ............................................. 2
`1.
`Petitioner showed that Ueno-642 discloses selecting
`
`border-following travel in response to inputs from
`obstacle sensors .......................................................................... 3
`Petitioner showed that Ueno-642 discloses selecting
`random travel in response to inputs from obstacle sensors ....... 4
`The Board also misapprehended Ueno-642’s disclosures
`regarding the use of obstacle sensors to “exit” a mode. ....................... 5
`The Board misapprehended the language in limitation 1(d) as
`excluding pre-planned sequences of modes, which would
`exclude the only embodiment of the ’490 patent that uses three
`modes. ................................................................................................... 7
`Even if limitation 1(d) is interpreted to exclude pre-planned
`sequences of modes, Ueno-642 discloses using sequences of
`modes that are not pre-planned. ......................................................... 10
`The Board also appears to misapprehend limitation 1(d) as
`requiring that all operational modes must be stopped based on
`sensor information. ............................................................................. 11
`Patent Owner’s Preliminary Response led the Board to misapprehend
`Petitioner’s argument .................................................................................... 13
`CERTIFICATE OF SERVICE ............................................................................... 17
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`
`
`D.
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`E.
`
`II.
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`ii
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`Patent No. 6,809,490
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`Request for Rehearing
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`TABLE OF EXHIBITS
`
`Exhibit
`1001
`
`Description
`U.S. Patent No. 6,809,490 (“’490 patent”)
`
`1002
`
`1003
`
`1004
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`1005
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`1006
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`1007
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`1008
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`1009
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`1010
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`File history of U.S. Patent No. 6,809,490
`
`Declaration of C. Douglass Locke, Ph.D., Regarding
`Invalidity of the Challenged Claims of U.S. Patent No.
`6,809,490 (“Locke”)
`
`Certified Translation of Japanese Unexamined Patent
`Application Publication H11-212642, published August 6,
`1999 (“Ueno-642”)
`
`U.S. Patent No. 6,493,612 to Bissett (“Bissett-612”)
`
`Japanese Unexamined Patent Application Publication H11-
`212642, published August 6, 1999 (non-translated)
`
`Affidavit certifying translation of Japanese Unexamined
`Patent Application Publication H11-212642
`
`Joint Claim Construction Chart, as submitted in Investigation
`No. 337-TA-1057, August 18, 2017
`
`U.K. Patent Application 9827758
`
`PCT Publication WO 00/38026
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`iii
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`
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`Patent No. 6,809,490
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`
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`Request for Rehearing
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`Shenzhen Zhiyi Technology Co. Ltd., d/b/a iLife (“Petitioner”) requests
`
`rehearing under § 42.71(d) of the institution decision issued March 12, 2018
`
`(“Decision”) in the above-identified matter. Specifically, the Board’s Decision
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`relative to Ground 1 (claims 1-3, 7, and 12) misapprehended Petitioner’s argument
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`with respect to limitation 1(d) of the ’490 patent and the corresponding disclosures
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`of the Ueno-642 reference (Ex. 1004).
`
`I.
`
`THE BOARD MISAPPREHENDED PETITIONER’S ARGUMENT
`WITH RESPECT TO LIMITATION 1(D)
`
`Under § 42.71(d), “A party dissatisfied with a decision may file a single
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`request for rehearing without prior authorization from the Board…. The request
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`must specifically identify all matters the party believes the Board misapprehended
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`or overlooked, and the place where each matter was previously addressed in a
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`motion, an opposition, or a reply.”
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`As explained below, the Board misapprehended Petitioner’s argument
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`regarding limitation 1(d), and this misapprehension was the basis for denying
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`institution of Ground 1. This misapprehension may have been due to misleading
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`arguments made by Patent Owner.
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`Limitation 1(d) requires:
`
`“said control system configured to operate the robot in a plurality
`of operational modes and to select from among the plurality of
`modes in real time in response to signals generated by the
`
`1
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`Patent No. 6,809,490
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`Request for Rehearing
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`obstacle detection sensor, said plurality of operational modes
`comprising: …”
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`Claims 2, 3, 7, and 12 all depend from claim 1. The Decision denying institution
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`with respect to claims 1-3, 7, and 12 was based on the alleged failure of Ueno-642
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`to disclose limitation 1(d). (Decision at 10.)
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`A.
`
`The Board misapprehended Petitioner’s argument regarding how
`limitation 1(d) is met by Ueno-642.
`
`The Decision states that the “critical language” at issue in limitation 1(d)
`
`requires:
`
`“that the control system ‘select[s] from among the plurality of
`modes … in response to signals generated by the obstacle
`detection sensor.’ This requires, in practical application, that the
`system can choose a mode in which to operate (‘select from
`among’), based on inputs from the obstacle sensor (‘in response
`to signals’).”
`
`(Decision at 6 (italic emphasis in the Decision, underline emphasis added).)
`
`According to the Board’s analysis of limitation 1(d), it requires that the system
`
`choose a mode in which to operate based on inputs from the obstacle sensor.
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`Ueno-642 discloses this requirement, as shown in the Petition. Petitioner’s
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`analysis of limitation 1(d) is set forth in the Petition at pages 18-22 of the Petition,
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`with specific citations related to this aspect of limitation 1(d) set forth in at least
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`pages 19-21.
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`2
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`Patent No. 6,809,490
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`Request for Rehearing
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`First, Petitioner cites Ex. 1004-Ueno at FIGS. 4, 5, 9, 10, 15, 18, and
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`paragraphs 0023 and 0027 as disclosing that the Ueno-642 robot had three
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`operational modes: spiral travel, border-following travel, and random travel.
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`(Petition at 19.) There appears to be no dispute that Ueno-642 discloses operating
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`in these three modes. (Decision at 7 (referencing Patent Owner’s preliminary
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`response argument relative to “the three modes in Ueno-642”).)
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`Second, Petitioner showed that the Ueno-642 robot had obstacle sensors,
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`including “both infrared sensors and tactile (contact) sensors.” (Petition at 17.)
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`Petitioner specifically pointed out that Ueno-642’s obstacle sensors included
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`infrared sensors 26 and “side-sensor 25L.” (Petition at 17; Ueno-642 at ¶ 0016.)
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`Third, Petitioner showed that the Ueno-642’s “CPU selects among these
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`three modes based on the inputs from the sensor system.” (Petition at 20.)
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`Petitioner then supported that statement as follows:
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`1.
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`Petitioner showed that Ueno-642 discloses selecting border-
`following travel in response to inputs from obstacle sensors
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`Petitioner block-quoted paragraph 0023 of Ueno-642, which states that
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`“[t]he border-following travel pattern . . . is started when the side sensor 25L
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`detects the boundary such as a wall etc.” (Petition at 20 (citing Ex. 1004-Ueno at
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`0023.) That statement shows that the Ueno-642 robot chooses to start operating in
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`border-following travel mode based on input from “side-sensor 25L,” which is an
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`obstacle sensor. Petitioner also cited to paragraphs 0024-25, which provide further
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`3
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`Patent No. 6,809,490
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`details regarding the border-following travel. In particular, paragraph 0024
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`Request for Rehearing
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`discloses:
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`“As described later, during random travel and spiral travel, if the
`side sensor 25L or 26 senses a boundary such as a wall, and
`generates an output, CPU 8 generates a border-following travel
`start instruction and the processing in Fig. 4 is started (Step
`S70).”
`
`(Ex. 1004-Ueno at 0024). This statement confirms that the Ueno robot chooses to
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`start border-following travel based on input from obstacle sensors. More
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`specifically, it shows that while the Ueno-642 robot is traveling in one mode (e.g.,
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`random travel or spiral travel), the robot’s CPU will start border-following travel
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`mode in response to outputs generated by either sensor 25L or 26 (which are
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`obstacle sensors).
`
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`2.
`
`Petitioner showed that Ueno-642 discloses selecting random
`travel in response to inputs from obstacle sensors
`
`To show this, Petitioner again referenced several paragraphs of Ueno-642 as
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`disclosing selection of the mode based on obstacle sensor inputs. (See, e.g.,
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`Petition at 20 (citing Ex. 1004-Ueno at FIG. 5; 0026; 0028-29; 0033.) In
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`particular, paragraph 0028 discloses that the Ueno-642 robot (while operating in
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`spiral travel mode) will respond to outputs from sensors 25L or 26 by entering a
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`random travel mode:
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`4
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`Patent No. 6,809,490
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`Request for Rehearing
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`“A spiral gets bigger and based on the output of sensors 26 and
`25L, when it is recognized that the robot 1 approached within the
`planned distance with respect to the wall surface B, the spiral
`travel is stopped and a random travel is started[.]”
`
`(Ex. 1004-Ueno at 0028 (emphasis added).) This statement shows Ueno-642
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`discloses a robot that will start random travel mode “based on the output of sensors
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`26 and 25L,” which are obstacle sensors.
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`Accordingly, the Decision misapprehended Ueno-642 and Petitioner’s
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`argument about limitation 1(d) when it concluded that Ueno-642 failed to disclose
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`a robot that, “in practical application, … can choose a mode in which to operate
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`(‘select from among’), based on inputs from the obstacle sensor (‘in response to
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`signals’).” (See Decision at 6.) In fact, as just explained, Ueno-642 expressly
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`discloses a robot whose CPU will choose to start operating in both border-
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`following travel mode and random travel mode based on inputs from obstacle
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`sensors 25L and 26.
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`B.
`
`The Board also misapprehended Ueno-642’s disclosures regarding
`the use of obstacle sensors to “exit” a mode.
`
`The Decision states that using obstacle sensors to determine when to exit
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`one mode is different from using those sensors to select the next mode:
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`“Petitioner directs us to a disclosure in Ueno-642 where [based
`on sensors] the spiral is determined to be complete and a stop
`instruction is given. … Notably, however, signals from the
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`5
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`Patent No. 6,809,490
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`Request for Rehearing
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`obstacle sensors in the spiral mode determine when to exit the
`spiral mode. Determining when to exit the present mode is not
`the same as selecting the next mode based on signals generated
`by the obstacle detection sensor.”
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`(Decision at 7 (internal citations omitted; italics in original.) While it is certainly
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`true that exiting a mode is not the same as selecting the next mode, this argument
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`misapprehends Petitioner’s argument and the Ueno-642 reference, because Ueno-
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`642 does disclose using obstacle sensors to select the next mode. The Decision
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`cites to the Petition at 20 and to paragraph 0040 and FIG. 10 in particular. But that
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`isolated view of Ueno-642 is not representative, because Ueno-642 does not only
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`say that spiral travel ceases based on obstacle sensors.
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`To the contrary, Ueno-642 states that the robot will stop its spiral (or
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`random) operation and start border-following travel based on its obstacle sensors:
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`“As described later, during random travel and spiral travel, if the
`side sensor 25L or 26 senses a boundary such as a wall, and
`generates an output, CPU 8 generates a border-following travel
`start instruction and the processing in Fig. 4 is started (Step
`S70).”
`
`(Ex. 1004-Ueno at 0024.)
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`Ueno-642 also shows that the robot will stop spiral operation and start
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`random travel based on its obstacle sensors:
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`6
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`Patent No. 6,809,490
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`Request for Rehearing
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`“A spiral gets bigger and based on the output of sensors 26 and
`25L, when it is recognized that the robot 1 approached within the
`planned distance with respect to the wall surface B, the spiral
`travel is stopped and a random travel is started[.]”
`
`(Ex. 1004-Ueno at 0028 (emphasis added).)
`
`Thus, the Board’s analysis of paragraph 0040 and its relationship to ceasing
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`spiral travel is incomplete, both in terms of what Ueno-642 discloses and the
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`argument presented in the Petition. Ueno-642 states expressly that both border-
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`following mode and random travel mode are started based on signals from obstacle
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`sensors.
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`C.
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`The Board misapprehended the language in limitation 1(d) as
`excluding pre-planned sequences of modes, which would exclude
`the only embodiment of the ’490 patent that uses three modes.
`
`The Board also appears to have interpreted limitation 1(d) to exclude the
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`possibility of having a pre-planned sequence of modes:
`
`“[T]he claims recite that the system ‘selects from among the
`plurality of modes’ (emphasis added), and we understand the
`plain meaning of this phrase to be that the control system has
`several options to choose from, and that choice is in response to,
`i.e., is based on, input from the sensor. In Ueno-642, there does
`not appear to be a choice made ‘from among the plurality of
`modes’ by the control system, but rather it must simply move to
`the pre-ordained next mode.”
`
`(Decision at 8 (emphasis added).)
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`7
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`Patent No. 6,809,490
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`Request for Rehearing
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`The Board appears to interpret limitation 1(d) as requiring that the control
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`system be configured “to select from among the plurality of modes only in
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`response to signals generated by the obstacle detection sensor.” But the word
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`“only” is not present in the claim. If a robot has a pre-planned sequence of modes
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`selected from among the plurality of modes, and it starts the modes in that
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`sequence in response to obstacle-sensor signals, then it is selecting from among the
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`modes in response to both the sensor signals and the pre-planned sequence. That is
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`how the robot of the ’490 patent behaves in the only described embodiment which
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`uses all three modes:
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`“[A] preferred embodiment of the present invention is detailed in
`FIG. 14, in which all three operational modes are used. In a
`preferred embodiment, the device 10 begins in spiral mode
`(movement line 45). If a reflective spiral pattern is used, the
`device continues in spiral mode until a predetermined or random
`number of reflective events has occurred. If a standard spiral is
`used (as shown in FIG. 14), the device should continue until any
`bump sensor event. In a preferred embodiment, the device
`immediately enters wall following mode after the triggering
`event. In a preferred embodiment, the device then switches
`between wall following mode (movement lines 51) and random
`bounce modes (movement lines 48) based on bump sensor events
`or the completion of the wall following algorithm.
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`8
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`Patent No. 6,809,490
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`(Ex. 1001 at 16:36-50.) In this embodiment, there is a preplanned sequence of
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`Request for Rehearing
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`
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`spiral / bounce / wall following / bounce / wall following etc. The initial spiral
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`mode is exited when it bumps a wall (or, after some number of ‘reflective’ bumps
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`have occurred). The wall-following mode is then selected based on encountering
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`the wall, i.e., based on obstacle sensors. Bounce is then selected “based on bump
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`sensor events or the completion of the wall following algorithm.”
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`The above embodiment would not satisfy claim 1 under the Board’s
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`apparent interpretation of the claims: after the initial spiral, the robot must move to
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`the wall-following mode, and after that, the robot must cycle back and forth
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`between bounce and wall-following. It does not make sense to read the claims to
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`exclude this embodiment, especially because doing so requires adding a word to
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`the claims that is not there: “select from among the plurality of modes only in
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`response to signals generated by the obstacle detection sensor.”
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`Furthermore, the above embodiment shows that Ueno-642 discloses exactly
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`the same thing as the ’490 patent: a robot that may be configured to use both
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`obstacle-sensor signals and a preset sequence of modes in selecting a next mode of
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`operation.
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`9
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`Patent No. 6,809,490
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`Request for Rehearing
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`D. Even if limitation 1(d) is interpreted to exclude pre-planned
`sequences of modes, Ueno-642 discloses using sequences of modes
`that are not pre-planned.
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`Additionally, while there is no question that Ueno-642 discloses using preset
`
`sequences of modes, Ueno-642 also discloses sequences of modes that are not pre-
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`planned. In particular, claim 9 of Ueno-642 recites:
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`[Claim 9] The method for controlling a self-propelled robot
`according to any of the claims 1 through 7 wherein the sequence
`of executing spiral travel, border-following travel and random
`travel is preset before traveling start.
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`(Ueno-642 at claim 9.) This dependent claim adds the requirement that the
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`sequence of executing modes be “preset,” which shows that the sequence of modes
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`need not be preset.
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`Ueno-642 confirms this when it explains that while the robot operates in a
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`spiral mode, it then—in response to inputs from sensor 25L or 26—transitions to
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`either border-following travel or random travel modes. That shows that a robot in
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`spiral mode responds to sensor inputs by choosing from one of at least two other
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`modes, specifically, border-following travel or random travel. (E.g., Ex. 1004-
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`Ueno at 0023-24; 0028.) Thus, even if limitation 1(d) were interpreted to exclude
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`pre-planned sequences of modes—which it should not be—Ueno-642 would
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`nonetheless satisfy the claim because it discloses using sequences of modes that
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`are not pre-planned.
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`10
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`Patent No. 6,809,490
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`Request for Rehearing
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`E. The Board also appears to misapprehend limitation 1(d) as
`requiring that all operational modes must be stopped based on
`sensor information.
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`Finally, the Board appears to misapprehend limitation 1(d) as requiring that
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`all three operational modes (and border-following in particular) be stopped based
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`on sensor information. In particular, the Decision states:
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`“Petitioner has not shown how Ueno-642 discloses exiting the
`border-following mode using obstacle detection because it
`appears the border-following mode only exits upon an expiration
`of a timer or a crossing of a distance threshold.”
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`(Decision at 9 (emphasis added).)
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`But even if it is true that the border-following mode only exits upon an
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`expiration of a timer or a crossing of a distance threshold, that would not suggest
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`that limitation 1(d) is not satisfied. Limitation 1(d) does not require that every
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`operational mode be started or stopped based on sensor information. What it
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`requires is that the control system “select from among the plurality of modes in
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`real time in response to signals generated by the obstacle detection sensor….” The
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`Petition shows how Ueno-642 discloses doing so, and in particular, how it
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`discloses a control system configured to select border-following travel or random
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`travel in real time in response to signals from sensors 25L and 26. (Petition at 20
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`(citing Ex. 1004-Ueno at 0023-24; 0028).) In other words, the control system is
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`11
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`Patent No. 6,809,490
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`configured to select one of at least two different modes from among the plurality of
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`Request for Rehearing
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`modes – which satisfies limitation 1(d).
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`This is confirmed by the fact that embodiments of the ’490 patent describe
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`exiting wall-following only when a distance threshold is crossed:
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`“FIG. 13B shows the movement of a preferred embodiment of
`robot 10, whereby the robot cycles between BOUNCE and
`WALL FOLLOWING behaviors. As the robot follows path 99,
`each time the robot 10 encounters a wall 100, the robot follows
`the wall for a distance equal to twice the robot’s diameter.”
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`(Ex. 1001 at 16:26-33.) In this embodiment, there is a preplanned sequence of
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`bounce / wall following / bounce / wall following etc. Bounce mode is exited and
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`wall-following started when the robot “encounters a wall,” i.e., based on obstacle
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`sensors. Wall-following is exited and bounce is started when the robot has
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`followed the wall “the wall for a distance equal to twice the robot’s diameter,” i.e.,
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`based on a distance threshold. This shows that the ’490 patent expressly
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`contemplates the use of distance thresholds to exit wall-following mode, and thus it
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`would be improper to interpret limitation 1(d) to exclude that possibility.1 The use
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`1 The Board appears to assume that wall-following up to a distance threshold does
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`not use inputs from obstacle sensors. In fact, wall-following uses obstacle sensors
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`to track the wall. Thus, travelling a preset distance along a wall should be
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`considered an operation that is “based-upon” inputs from obstacle sensors.
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`12
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`Patent No. 6,809,490
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`of distance thresholds to exit wall-following mode is yet another way that the
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`Request for Rehearing
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`disclosure of Ueno-642 matches up exactly with the disclosure and claims of the
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`’490 patent.
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`II.
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`PATENT OWNER’S PRELIMINARY RESPONSE LED THE BOARD
`TO MISAPPREHEND PETITIONER’S ARGUMENT
`
`As shown above, the Board misapprehended Petitioner’s argument and the
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`prior art with respect
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`to
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`limitation 1(d).
`
` It appears
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`that
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`the Board’s
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`misapprehension is due to Patent Owner’s misleading characterization of
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`Petitioner’s arguments in the preliminary patent owner response (“POPR”). In
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`particular, the POPR raised three arguments with respect to limitation 1(d): (1) that
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`the travel mode pointer does not change in response to sensor signals; (2) that
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`transitioning modes after traveling a planned time or distance is different than
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`responding to sensors; and (3) that Ueno-642 prioritizes operations, not operating
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`modes. (POPR at 26-29.) None of these arguments shows that Ueno-642 fails to
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`disclose limitation 1(d).2
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`2 After Patent Owner filed its POPR with the Board, Patent Owner has effectively
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`admitted that Ueno-642 discloses every limitation of claim 1 in the corresponding
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`ITC investigation identified in the Petition. (Petition at 1.) In the pre-hearing
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`briefing in that proceeding, Petitioner asserted that claim 1 is anticipated by Ueno-
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`642. Patent Owner did not dispute that Ueno anticipates all of the limitations of
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`13
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`Patent No. 6,809,490
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`Request for Rehearing
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`First, the POPR argues that Ueno-642 discloses mode selection based on a
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`travel mode pointer, not sensor signals. (POPR at 26-27.) But the POPR limits its
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`analysis to paragraphs 0035 and 0037 of Ueno-642 and ignores the fact that, as
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`described above, Ueno describes using outputs from sensors 25L and 26 to start at
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`least border-following travel mode and random travel mode. The POPR’s reliance
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`on two of many cited paragraphs mischaracterizes Petitioner’s arguments and
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`incorrectly suggests that using both a preset sequence of modes and sensor signals
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`would not satisfy the claims. The POPR also ignores the fact the 490 patent’s only
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`3-mode embodiment uses both a preset sequence of modes and sensor signals,
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`exactly like Ueno-642. (See supra § I.C.) The Board carried this deficient and
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`misleading analysis of the Petition and Ueno-642 into its Decision by appearing to
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`credit the arguments presented in the POPR at 26-27 and to Ueno-642 at
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`paragraphs 0035-0037. (Decision at 7-8.)
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`claim 1, including limitation 1(d). Patent Owner was required to present all of its
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`arguments in its pre-hearing brief, so by not disputing that Ueno-642 anticipates all
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`the limitations of claim 1, Patent Owner has effectively admitted anticipation.
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`Petitioner believes that this is because interpreting the claims as excluding a pre-
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`ordained sequence of modes is inconsistent with iRobot’s infringement theories: all
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`of the allegedly infringing iLife devices operate with a pre-ordained sequence of
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`modes (bounce/wall-follow/bounce/wall-follow/etc.).
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`14
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`Patent No. 6,809,490
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`Request for Rehearing
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`Second, the POPR argues that border-following travel is stopped after a
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`planned time or distance. (POPR at 27.) This ignores that Ueno-642 discloses
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`using sensors to determine when to start border-following travel and random travel
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`modes, as explained above. (See supra § I.D.) It also ignores that the ’490 patent
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`discloses doing exactly the same thing as Ueno (i.e., stopping one mode after a
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`distance threshold). (Id.) The Decision appears to have credited Patent Owner’s
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`argument even though it is misleading and incorrect as explained above in § I.D.
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`Third, the POPR refers to lower-level robot operations that are not
`
`operational modes. (POPR at 28-29.) But the POPR presents no rational basis for
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`determining that the presence additional disclosures in Ueno-642 that allegedly do
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`not relate operational modes is relevant to what Ueno-642 does say about selecting
`
`operational modes. That is particularly true when there are clear disclosures in the
`
`reference which show that border-following and random travel modes are selected
`
`and started in response to sensor outputs. (See supra § I.A.) Nonetheless, the
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`Decision appears to have adopted Patent Owner’s misleading argument.
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`For the foregoing reasons, Petitioner respectfully requests rehearing under
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`42.71, and requests an inter partes review trial with the respect to the Challenged
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`Claims of the ’490 patent.
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`
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`15
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`Patent No. 6,809,490
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`
`
`Date: March 26, 2018
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`
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`
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`Request for Rehearing
`
`
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`
`
`Respectfully submitted,
`GREENBERG TRAURIG, LLP
`
`By: /s/ Patrick J. McCarthy
`Patrick J. McCarthy
`Registration No. 62,762
`mccarthyp@gtlaw.com
`Greenberg Traurig LLP
`2101 L Street, N.W., Suite 1000
`Washington, D.C. 20037
`Phone: (202) 533-2386
`Fax: (202) 331-3101
`
`Counsel for Petitioner Shenzhen Zhiyi
`Technology Co. Ltd., d/b/a iLife,
`
`16
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`
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`Patent No. 6,809,490
`
`
`
`
`Request for Rehearing
`
`CERTIFICATE OF SERVICE
`I hereby certify that on this 26th day of March, 2018, a copy of this Request
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`for Rehearing has been served in its entirety via electronic mail by emailing Patent
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`Owner’s lead and backup counsel at:
`
`W. Karl Renner
`IPR44360-0004IP1@fr.com
`Jeremy J. Monaldo
`PTABInbound@fr.com
`Patrick J. Bisenius
`PTABInbound@fr.com
`Tonya S. Drake
`tdrake@irobot.com
`
`as provided for by Patent Owner’s Updated Mandatory Notices.
`
`
`
`
`
`Date: March 26, 2018
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`
`
`
`
`
`
`
`
`Respectfully submitted,
`GREENBERG TRAURIG, LLP
`
`
`By: /s/ Patrick J. McCarthy
`Patrick J. McCarthy
`Registration No. 62,762
`mccarthyp@gtlaw.com
`Greenberg Traurig LLP
`2101 L Street, N.W., Suite 1000
`Washington, D.C. 20037
`Phone: (202) 533-2386
`Fax: (202) 331-3101
`
`Counsel for Petitioner Shenzhen Zhiyi
`Technology Co. Ltd., d/b/a iLife,
`
`
`17
`
`
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