Paper No. 13
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`MICROSOFT CORPORATION
`Petitioner,
`
`v.
`
`IRON OAK TECHNOLOGIES, LLC,
`Patent Owner.
`
`Patent No. 5,699,275
`Issued: December 16, 1997
`Filed: April 12, 1995
`Inventors: Dale E. Beasley et al.
`
`Title: SYSTEM AND METHOD FOR REMOTE PATCHING OF OPERATING
`CODE LOCATED IN A MOBILE UNIT
`____________________
`Inter Partes Review No. IPR2019-00106
`________________________
`
`PETITIONER’S REPLY
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`MICROSOFT CORPORATION
`Petitioner,
`
`v.
`
`IRON OAK TECHNOLOGIES, LLC,
`Patent Owner.
`
`Patent No. 5,699,275
`Issued: December 16, 1997
`Filed: April 12, 1995
`Inventors: Dale E. Beasley et al.
`
`Title: SYSTEM AND METHOD FOR REMOTE PATCHING OF OPERATING
`CODE LOCATED IN A MOBILE UNIT
`____________________
`Inter Partes Review No. IPR2019-00106
`________________________
`
`PETITIONER’S REPLY
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`
`
`
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`
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`I.
`
`INTRODUCTION
`Claim 1 of the 275 Patent is directed to “[a] system for remote patching of
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`operating code located in a mobile unit.” EX1001, 13:32-33. The system includes
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`“a manager host operable to initiate transmission … of at least one discrete patch
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`message defining at least one patch.” Id., 13:34-37. The claimed system also
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`requires two mobile units, a first and a second, each of which is “operable to
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`create patched operating code by merging the at least one patch with current
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`operating code located in the [first/second] mobile.” Id., 13:38-49 (emphasis
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`added). Finally, the claimed system requires that the “manager host” be “operable
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`to address the at least one discrete patch message such that the at least one discrete
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`patch message is transmitted to the first mobile unit but not to the second mobile
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`unit.” Id., 13:50-53 (emphasis added in each).
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`Claim 1 therefore recites a system having certain components capable of
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`performing certain functionality. It is not a method claim. It requires no activity.
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`Nor does it require the claimed “operability” to be employed in all circumstances,
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`or in any particular circumstance. It merely requires a system whose parts can
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`perform the specified functionality in the claim.
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`The Petition (“Pet.”) demonstrated that Sugita discloses such a system. In
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`particular, Sugita discloses a system that includes multiple mobile units, each of
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`which is capable of receiving a patch message and in response creating patched
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`operating code. Pet., 35-42. The Petition further demonstrated that the system of
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`Sugita includes a base station capable of performing the functionality of the
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`claimed “manager host,” including addressing the patch message such that it “is
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`transmitted to the first mobile unit but not to the second mobile unit.” Pet., 30-35.
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`The Petition demonstrated that Sugita’s base station satisfies this last claim
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`requirement in two, alternative ways. See Pet., 44 (“Both ways of addressing
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`update information (i.e., group ID or individual ID) meet this claim element under
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`either construction.”); see also id., 43-46. First, Sugita discloses transmission of a
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`patch message addressed to one of several groups of mobile units (i.e., a “specific
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`group,” see EX1005, [0013]), rather than to all mobile units, using a Group ID as
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`an address. Pet., 44-45. Thus, in this mapping of the claim, the “first mobile unit”
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`is a unit within the “specific group” to which the patch message is transmitted and
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`the “second mobile unit” is a unit within some other group, i.e., a group to which
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`the patch message is not transmitted. See id.
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`Second, Sugita discloses that, after such a group transmission, the system
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`will re-transmit the patch message to units that did not acknowledge reception of
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`the group transmission, and these re-transmissions will address the patch message
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`using the respective “individual IDs” of those units. See, e.g., Pet., 45-47. In this
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`mapping of the claim, the “first mobile unit” is a unit to which the patch message is
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`(re-)transmitted using its “individual ID” and the “second mobile unit” is a mobile
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`2
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`unit to which that re-transmission is not sent because, for example, that unit
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`acknowledged successfully receiving the patch via the group transmission, was not
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`a target of the group transmission, or is an unsuccessful target of the group
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`transmission but is not the target of this particular individual transmission. See id.
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`In response, Patent Owner advances a convoluted argument1 based on an
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`overly narrow interpretation of the claim that is unsupported by and inconsistent
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`with the claim language. The basis of its argument is that the claim supposedly
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`requires the “second mobile unit” to have the capability “to create patched
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`operating code” from the patch message at the time the patch message is
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`transmitted and that it will necessarily employ that functionality in response to a
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`patch message.
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`That position is both confused and erroneous for several reasons. First, in
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`relevant part the claim only requires the “second mobile unit” to be “operable to
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`create patched operating code” by merging the patch with current operating code.
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`
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`1 Patent Owner appears to use another translation of Sugita from the related IPR
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`proceeding IPR2018-00152. That translation is not of record in this proceeding.
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`For the Board’s convenience, Petitioner addresses Patent Owner’s arguments in
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`view of the same cited paragraphs of Sugita’s translation that is of record in this
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`proceeding (EX1005).
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`3
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`It includes no requirement that the mobile unit use that functionality in any
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`particular circumstance or at any particular time. A mobile unit that is capable of
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`creating patched operating code in some circumstances still satisfies the claim,
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`“even if it does not meet the claim limitations in all modes of operation.”
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`ParkerVision, Inc. v. Qualcomm Inc., 903 F.3d 1354, 1361 (Fed. Cir. 2018).
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`Second, a mobile unit that has the ability “to create patched operating code”
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`in some circumstances, is still “operable to create patched operating code” even
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`during time periods or under circumstances it may not implement that
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`functionality. Thus, a mobile unit operable to create patched operating code only
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`on Mondays, is still a mobile unit “operable to create patched operating code”
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`during the rest of the week.
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`Finally, as demonstrated below, the disclosure of Sugita and the analysis
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`included in the Petition satisfy the claim even under Patent Owner’s erroneous
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`claim interpretation.
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`Accordingly, as demonstrated below and in the Petition, Sugita satisfies all
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`elements of claim 1. Petitioner therefore respectfully requests that the Board find
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`that claim to be unpatentable.
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`4
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`II. CLAIM 1 OF THE 275 PATENT IS UNPATENTABLE
`Patent Owner Improperly Attempts To Limit The Claim
`A.
`Patent Owner begins its analysis by reading a temporal limitation into its
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`claim language, without even attempting to justify doing so based on the intrinsic
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`record or the law of claim construction. Patent Owner argues, for example, that
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`the Board failed to recognize that claim 1 requires that at the
`time of transmission of the patch message by the manager host
`both mobile units must be operable to create patched operating
`code from current operating code, and that the host transmit the
`patch to one mobile unit and not the other even though both units
`are capable of updating current operating code.
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`PO Resp., 7 (emphasis added).
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`But nothing in claim 1 requires that the mobile unit must be able to create
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`patched operating code “at the time of transmission of the patch message.”
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`Claim 1 requires only that the first and second mobile units be “operable” to
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`“create patched operating code.” Thus, a mobile unit capable of carrying out that
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`functionality on Monday, but not on Tuesday, is still “operable to create patched
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`operating code” as claimed. Indeed, just because a mobile unit does not “create
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`patched operating code” in a particular situation, does not mean the ability to do so
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`does not exist in the mobile unit. “[A] prior art reference may anticipate or render
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`obvious an apparatus claim—depending on the claim language—if the reference
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`discloses an apparatus that is reasonably capable of operating so as to meet the
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`5
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`claim limitations, even if it does not meet the claim limitations in all modes of
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`operation.” ParkerVision, 903 F.3d at 1361 (emphasis added).
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`Any contrary conclusion, moreover, would be inconsistent with other
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`language of the claim. For example, claim 1 requires a “second mobile unit” that
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`is “operable to receive” the patch message and a “manager host” operable to not
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`transmit the patch message to the second mobile unit. EX1001, 13:44-45.
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`Obviously, a mobile unit that is not transmitted the patch message will never
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`receive that message, but it can still be “operable” to do so. The failure of
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`transmission has simply prevented reception from occurring in that situation.
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`Similarly, a mobile unit that has the ability to create patched operating code from
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`the patch message but is prevented from doing so in a particular situation—e.g.,
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`by other functionality determining there is no need to implement the patch—is still
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`operable to create patched operating code.
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`Moreover, nothing in claim 1 requires that the “second mobile unit” be
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`capable of creating patched operating code in response to the “patch message”
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`recited in the claim, or in response to any particular patch message at all. The
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`relevant portion of the claim instead recites only a second mobile unit “operable to
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`create patched operating code by merging the at least one patch with current
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`operating code.” EX1001, 13:46-47. How the creation of patched operating code
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`is triggered is simply unclaimed functionality.
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`6
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`B.
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`Patent Owner’s Response Rests On Its Erroneous
`Interpretation of the Claim
`Patent Owner’s erroneous interpretation of the claim underlies its entire
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`response. For example, Patent Owner argues that Sugita does not satisfy the
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`portion of the claim requiring that the patch message be “transmitted to the first
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`mobile unit but not the second mobile unit” because Sugita supposedly always
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`sends its patch message to all mobile units capable of performing an update. See
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`PO Resp., 7-9; see also id., 16. But in this analysis Patent Owner explicitly defines
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`mobile units capable of performing the update as those that are “not already
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`updated.” See, e.g., id., 8-9 (“Sugita never discloses an instance when a mobile
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`terminal that is capable of being updated (e.g, not already updated) is not sent
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`an update.”) (emphasis added). That confirms the error of its analysis in several
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`ways.
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`Nothing in claim 1 requires the mobile units to be “not already updated.”
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`The claim only requires the capability to create patched operating code. Patent
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`Owner’s argument, moreover, is just another attempt to read a temporal limitation
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`into the claims such that mobile units qualify as a claimed “second mobile unit”
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`before they are updated, but not after. But that stands the claim word “operable”
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`on its head. Mobile units that have already created patched operating code via the
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`system of Sugita are demonstrably “operable” to do so precisely because they have
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`already created patched operating code.
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`7
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`Patent Owner’s argument in this regard also fails for a second reason. As
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`demonstrated in the Petition, Sugita discloses the transmission of a patch message
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`to just one group of mobile units (i.e., a “specific group,” EX1005, [0013]) among
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`several such groups. Pet., 43-45; EX1003, ¶151. Sugita also discloses that each
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`mobile unit in the system has the same ability to create patched operating code
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`from the patch and its own current operating code. See, for example, the
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`description of Figure 6, which discloses the update activity flow for “each mobile
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`communications terminal,” EX1005, [0043] (emphasis added), and which includes
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`the creation of patched operating code as claimed, id., [0046]. See also Pet., 38-42.
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`Thus, in the situation where a patch message is sent to a “specific group,” the
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`mobile units in the groups to which the patch message are not transmitted are
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`operable to create patched operating code, but are also “not already updated.”
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`Sugita’s group transmission disclosure therefore satisfies the claim even under
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`Patent Owner’s erroneous claim interpretation.
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`Patent Owner also argues that “Sugita’s group units account for all mobile
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`terminals that could be updated with the transmitted patch,” PO Resp., 10, and that
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`“to understand his invention Sugita intentionally set the stage as transmitting an
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`update to each mobile terminal that could be updated with the transmitted
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`information, whether by individual ID or as part of a group unit,” id., 11-12
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`(emphasis in original). Patent Owner also provides its interpretation of various
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`8
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`passages from Sugita, id., 11-13, and concludes that “[i]t is more likely” that
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`Sugita’s group units “were an accounting or tracking expedient” and that “rather
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`than starting by transmitting an update to 1,000 individual terminal IDs, Sugita’s
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`process could start with, for example, 20 group units representing the 1,000
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`terminals,” id., 13. Apparently, Patent Owner’s point is that Sugita sends updates
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`to all mobile units in the system, and therefore Sugita does not satisfy the claim
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`language requiring that the “patch message is transmitted to the first mobile unit
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`but not to the second mobile unit.” EX1001, 13:52-53.
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`But Patent Owner’s unsupported spin on Sugita is incorrect because Sugita
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`explicitly says otherwise. In particular, Sugita discloses that, in a first “round of
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`transmission,” his update is transmitted to all units, “or the unit addresses
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`belonging to a specific group”:
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`Additionally, the base station side (sending side) transmits the update
`information (all or part of the software) to each mobile
`communications terminal, with transmission at first performed based
`on the group ID of the group unit (all units, or the unit addresses
`belonging to a specific group), then the number of terminals in the
`group unit that complete the update in one round of transmission is
`investigated, and if the remaining number of units has decreased, the
`individual ID is used to perform updates of each unit one at a time.
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`EX1005, [0013] (emphasis added). Thus, Sugita expressly discloses that in the
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`first round his group update transmission can be either sent to “all units” or sent to
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`9
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`“the unit addresses belonging to a specific group.” Patent Owner even agrees with
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`this reading of Sugita, later in its brief. See PO Resp., 14 (asserting that this
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`passage of Sugita “simply means that Sugita forwards the update information to all
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`mobile terminals by first forwarding to ‘all [mobile communication terminals] or
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`the [mobile communication terminals] addresses belonging to a specific group.’”)
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`(bolded emphasis added). Because Sugita expressly discloses that there can be
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`multiple groups in his system, see EX1003, ¶151; Ex.1005, [0015], [0026], [0049],
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`his disclosure that the transmission can be first sent to “the unit addresses
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`belonging to a specific group” means that other units, outside that “specific group,”
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`are not sent that first round transmission. Sugita therefore satisfies the claim
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`requirement that the “patch message is transmitted to the first mobile unit but not
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`to the second mobile unit.”
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`This is confirmed by the testimony of Dr. White, who explains that this is
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`how a Skilled Artisan would understand Sugita, citing the exact passage of Sugita
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`quoted above:
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`In that case, update information sent to the one or more mobile
`terminals using the group ID for the first group unit would not be
`meant for the one or more mobile terminals in the second group unit.
`See id., ¶13 (“Additionally, the base station side … transmits the
`update information … to each mobile communications terminal, with
`transmission at first performed based on the group ID of the group
`unit (all units, or the unit addresses belonging to a specific
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`10
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`group) ….”) (emphasis added). … If so, the base station will send
`update information addressed to the first group that includes a “first
`mobile unit,” but does not include the “second mobile unit.”
`Accordingly, a Skilled Artisan would recognize that update
`information transmitted to the first group ID is “transmitted to the first
`mobile unit but not the second mobile unit.”
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`EX1003, ¶151 (emphasis in original).
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`Patent Owner’s assertion that “Petitioner’s unsupported speculation of what
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`a person of skill would have understood on this point is not evidence of the
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`‘content’ of Sugita required under the validity analysis,” PO Resp., 13, is thus
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`incorrect. The analysis of the Petition is concrete, not speculative, as it focuses on
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`this key passage of Sugita, see Pet., 44-45, and is supported by the express
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`disclosure of the prior art and the analysis of a recognized expert in the field.
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`Patent Owner’s assertions, on the other hand, are merely unsupported
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`attorney argument, as Patent Owner has not provided an expert declaration to back
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`up its interpretation of the prior art or explain how a Skilled Artisan would
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`understand the disclosure of Sugita. “It is well settled that attorney argument,
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`unsupported by factual evidence, is entitled to little probative value.” Inguran,
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`LLC v. Premium Genetics (UK) LTD, PGR2015-00017, Paper No. 22 at 8 (Dec.
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`20, 2016) (citations omitted). Indeed, “‘[a]ttorney argument is not evidence’ and
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`cannot rebut other admitted evidence” such as other expert testimony. Elbit Sys. of
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`11
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`Am., LLC v. Thales Visionix, Inc., 881 F.3d 1354, 1359 (Fed. Cir. 2018) (quoting
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`Icon Health & Fitness, Inc. v. Strava, Inc., 849 F.3d 1034, 1043 (Fed. Cir. 2017)).
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`C.
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`Patent Owner Mischaracterizes The Petition’s Alternative
`Argument Based on Individual ID Addressing
`Finally, Patent Owner mischaracterizes the Petition’s alternative argument
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`based on the individual IDs of Sugita. In particular, Patent Owner contends that
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`“Petitioner argues that Sugita’s disclosure of ‘Create list of update target terminals’
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`in [Figure 1] necessarily discloses that some terminals are excluded from that list”
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`citing pages 45-47 of the Petition and pages 153-157 of Dr. Whites Declaration.
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`See PO Resp., 9. Patent Owner then spends two pages arguing that “nothing in
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`[Figure 1] or the associated text that explains how or which mobile communication
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`terminals are ‘targeted for updates.’” Id., 15-16. But the Petition never argued that
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`“Sugita’s disclosure of ‘Create list of update target terminals’ in [Figure 1]
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`necessarily discloses that some terminals are excluded from that list.” Id. 9
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`(citations omitted). Rather, the Petition pointed out that Sugita satisfies the final
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`element of the claim in two alternative ways—via (i) the disclosure relating to
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`group ID addressing and, alternatively, (ii) the disclosure relating to individual ID
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`addressing. Pet., 43-47.
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`In its analysis of the individual ID address mapping, the Petition pointed to
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`Sugita’s disclosure of re-transmitting the patch, using individual IDs, to those units
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`12
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`that did not acknowledge the group ID transmission, and therefore remained on the
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`update target list:
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`As explained above, Sugita’s base station initially addresses
`update information to multiple mobile terminals using a group ID.
`Ex.1005, ¶35; Ex.1003, ¶153. However, in those situations in which
`some mobile terminals remain on the update target list after using the
`group ID (e.g., because no acknowledgement was received from those
`terminals), the base station retransmits the update information to
`the non-updated mobile terminal by addressing its individual ID.
`Ex.1005, ¶¶28, 36, 39; Ex.1003, ¶154.
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`Pet., 45-46 (emphasis added).
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`Thus, under this alternative mapping, Sugita again satisfies the claim
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`language, as it discloses the base station of Sugita (“manager host”) operable to
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`transmit the patch message to a mobile unit using an individual ID for that mobile
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`unit (“transmitted to the first mobile unit”) and not send that transmission to any
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`other mobile units (“but not the second mobile unit”).
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`The only argument in Patent Owner’s response directed to this analysis is
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`that previously updated mobile units can no longer be considered a “second mobile
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`unit” as claimed because they are supposedly not capable of updating (i.e., because
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`they have already been updated). See PO Resp., 16. As demonstrated above,
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`however, the claim requires only “operability.” It does not speak to whether the
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`claimed functionality of creating patched operating code must be carried out in
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`13
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`response to the patch message, or to a particular transmission, so whether a mobile
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`unit will create patched operating code at a particular point in time (e.g., after it has
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`already been updated) is not relevant. Sugita discloses that “each” of his mobile
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`units include the ability to create patched operating code for use at least at some
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`points in time, Pet., 38-42, EX1005, [0043], [0046], Fig. 6, so Sugita satisfies the
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`claim.
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`Moreover, even under Patent Owner’s erroneous claim interpretation,
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`Sugita’s individual ID addressing technique satisfies the claim. For example, the
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`individual patch transmissions of Sugita are sent to individual mobile units. See,
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`e.g., Pet., 45-46, EX1003, ¶154; EX1005, [0028], [0036], [0039]. Thus, where
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`multiple mobile units fail to acknowledge the group transmission, the subsequent
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`individual transmissions from the Sugita base station will each be sent to one, but
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`not all, mobile units who have not yet performed an update. See Pet., 46-47,
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`EX1003, ¶¶156-157. Thus, each such individual transmission is sent to one mobile
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`unit that has not yet been updated (“transmitted to the first mobile unit”), but also
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`is not sent to at least one other mobile unit that has not yet been updated (“but not
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`14
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`the second mobile unit”). Sugita therefore additionally satisfies the claim in this
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`manner, even under Patent Owner’s legally erroneous interpretation.2
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`III. CONCLUSION
`Petitioner therefore respectfully requests that claim 1 be canceled as
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`unpatentable.
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`Dated: August 9, 2019
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`Respectfully Submitted,
`
`/Joseph Micallef/
`Joseph A. Micallef
`Reg. No. 39,772
`Sidley Austin LLP
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`
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`2 Patent Owner also attempts to incorporate by reference the arguments advanced
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`in its Preliminary Response. See PO Resp. 1. Incorporation by reference, of
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`course, is not permitted, see 37 C.F.R. § 42.6(a)(3), and any argument not
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`expressly presented in Patent Owner’s Response should be deemed waived, Sony
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`Mobile Communications v. SSH Communications Security Oyj, IPR2015-01869,
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`Paper No. 39 at 3 (Sept. 8, 2017) (“However, our rules do not allow Patent Owner
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`to incorporate arguments by reference from its Preliminary Response … and our
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`Scheduling Order provides that any arguments and evidence not contained in the
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`Patent Owner Response will be ‘deemed waived.’”); see also Paper No. 18, at 5, or
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`rejected for the same reasons they were rejected in the institution decision.
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`15
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`1501 K Street, NW
`Washington, DC 20005
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`16
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), I hereby certify that on this 9th day of
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`August, 2019, I caused to be served a true and correct copy of the foregoing
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`PETITIONER’S REPLY by electronic mail on the following counsel:
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`Albert B. Deaver, Jr.: adeaver@md-iplaw.com
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`Robert J. McAughan, Jr.: bmcaughan@md-iplaw.com
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`Christopher M. Lonvick: clonvick@md-iplaw.com
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`Dated: August 9, 2019
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`Respectfully Submitted,
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`/Joseph Micallef/
`Joseph A. Micallef
`Reg. No. 39,772
`Sidley Austin LLP
`1501 K Street, NW
`Washington, DC 20005
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`17
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`Petitioner’s Reply for Inter Partes Review of U.S. Patent No. 5,699,275
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`CERTIFICATE OF COMPLIANCE
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`I hereby certify that this Petitioners’ Reply To Patent Owner’s Response
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`complies with the type-volume limitations of 37 C.F.R. § 42.24(c)(1) because it
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`contains 3,475 words (as determined by the Microsoft Word word-processing
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`system used to prepare this reply), excluding the parts of the reply exempted by 37
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`C.F.R. § 42.24(c).
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`Dated: August 9, 2019
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`Respectfully Submitted,
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`/Joseph Micallef/
`Joseph A. Micallef
`Reg. No. 39,772
`Sidley Austin LLP
`1501 K Street, NW
`Washington, DC 20005
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`18
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