`
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`
`UNIFIED PATENTS, LLC,
`Petitioner
`
`v.
`
`SYNCHVIEW TECHNOLOGIES, LLC,
`Patent Owner
`
`
`
`
`Case No. IPR2019-00470
`Patent No. 6,788,882
`
`
`
`
`
`
`PETITIONER’S SUR-REPLY REGARDING THE
`BOARD’S APRIL 22, 2020 ORDER
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`
`
`
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`TABLE OF CONTENTS
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`I. The Board Should Not Deny Institution Under 35 U.S.C. § 325(d) ................. 1
`II. Girard Discloses a Digital Video Recorder ...................................................... 5
`III. Girard Discloses Concurrent Recording and Playback of Programs
`In the Same Manner as Disclosed by the ’882 Patent .....................................11
`IV. Synchview’s Unaddressed Arguments Are Also Incorrect .............................14
`V. Conclusion .....................................................................................................15
`
`
`
`
`i
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`Case No. IPR2019-00470
`U.S. Patent 6,788,882
`The Board Should Not Deny Institution Under 35 U.S.C. § 325(d)
`
`Synchview fails to satisfy the first prong of the two-part framework set forth
`
`I.
`
`
`in Advanced Bionics v. MED-EL Elektromedizinische Geräte GmbH, IPR2019-
`
`01469, Paper 6, at 7-11 (PTAB Feb. 13, 2020) (precedential) (“Advanced Bionics”),
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`with its argument that Girard is cumulative of the Young reference that was
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`considered by the Examiner and that institution should be denied under § 325(d).
`
`See Paper 14 (“Order”) at 4-5 (citing Paper 8 (“POPR”) at 3-4). With regard to step
`
`(1), Synchview’s only contention is that Girard is “substantially the same art” that
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`was before the Office because Synchview contends “Girard is cumulative to Young
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`as it relates to the ‘synchronization’ element.” Paper 15 (“PO Br.”) at 3. It is not.
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`First, the technology described in Young is completely different from Girard’s
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`system. Young describes a system with an interface for controlling operation of a
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`VCR, such as by allowing a selection of a future program from a program guide to
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`be recorded. See, e.g., Ex. 2006 at 1:15-27, 2:3-6, 13:28-38, 14:1-28; Figs. 22A-22B.
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`The system 180 depicts a schedule/tape controller 220 external to the VCR 206,
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`while the system 182 depicts an alternative embodiment where the schedule/tape
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`controller 220 is embedded in the VCR 211. Id. at 12:53-65, 13:28-38, 14:16-19,
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`Figs. 22A-22B. In both embodiments, the system’s CPU, upon detecting that the
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`clock matches the scheduled time for a selected program, will change the tuner to
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`the channel for the program and cause the VCR to power on and begin recording to
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`U.S. Patent 6,788,882
`a tape in the VCR. Id. at 13:28-38, 14:23-24. A tape index screen displays the
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`contents of the video tape in a virtual tape directory that is stored off-tape in a
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`separate external non-volatile memory.
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`VCRs, of course, cannot record and digitally store multiple programs
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`concurrently, as required by the ’882 Patent claims, and instead record programs in
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`analog sequentially on a tape—an aspect of VCRs disparaged by the ’882 Patent.
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`Ex.1001 at 1:24-30 (VCRs record to magnetic tape which is “inherently sequential
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`and slow in access”), 1:43-47 (“the user [of a VCR] cannot watch a recorded
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`program and simultaneously record another”). The ’882 Patent describes “the
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`temporal storage of more than one video channel (e.g., television or cable channels)”
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`(id. at 5:22-28) and states that the traditional recording techniques of VCRs do not
`
`support its requirements. Id. at 5:58-63. Instead, “[t]he present invention provides
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`for all channels, or some subset thereof, to be concurrently recorded, at all times,
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`onto a random-access medium” and describes computer hard disks as the primary
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`examples.1 Id. at 5:64-6:4, 6:54-65, 7:35-47 (describing ability to record 213
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`channels for 24 hours on a commercially available 47 GB drive). As Young
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`acknowledges, a video tape is a “non-random access storage” (Ex. 2006 at 8:58-64),
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`and Young is forced to provide a virtual tape index with an on-screen tape position
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`1 All emphases have been added unless indicated otherwise.
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`2
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`U.S. Patent 6,788,882
`gauge 94 with pointer arrow 80 to help the user determine how far to rewind or fast-
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`forward to get to a desired program on the tape. Id. at 8:35-57, 9:17-10:27, Fig. 13.
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`In contrast, as Synchview has not disputed, Girard’s system both concurrently
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`and digitally stores multiple television programs airing at the same time using a
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`“continuous media server” having multiple dedicated servers that control multiple
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`disk array storage subsystems having high capacity disks, each individually on the
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`order of gigabytes in size. See Paper 1 (“Pet.”) at 16-19; See also Ex. 1003 at 4:48-
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`5:14, 6:13-20. While Young refers to using “a video cassette recorder (VCR) or
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`other recording device,” it never describes any such “other recording device,” and it
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`never discloses digitally storing television programs. Young also never discloses
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`concurrently recording and digitally storing multiple programs at the same time.
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`Synchview misleadingly suggests Young’s guide depicted in Figures 1-3 shows
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`plural “programs currently being recorded” (PO Br. at 2) but the figures only depict
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`a single program currently being recorded (as would be expected with a VCR). Ex.
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`2006 at Figs. 1-3; 6:25-34. Girard, therefore, is not cumulative of Young and differs
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`in significant ways that are fundamental to the ’882 Patent, including the concurrent
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`digital storage of multiple programs and the departure from traditional VCR
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`technology. Both Becton factors (a) and (b), therefore, weigh in favor of institution.
`
`See Becton, Dickinson & Co. v. B. Braun Melsungen AG, IPR2017-01586, Paper 8
`
`(Dec. 15, 2017) (precedential as to § III.C.5, first paragraph) (“Becton”).
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`U.S. Patent 6,788,882
`Second, Synchview appears to contend that Girard is cumulative of Young
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`only with regard to the so-called “‘synchronization’ element.” PO Br. at 4-5. But the
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`Examiner never applied Young to the “synchronization element,” nor to any element
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`of the independent claims. The Examiner only applied Young to certain dependent
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`claims—specifically for the channel guide displaying content information required
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`by original claims 7-8 and 26-27. Ex. 1002 at 120-121. Thus, Petitioner is not
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`applying Girard in any way that Young was applied by the Examiner or argued
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`against by the applicant during prosecution.
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`Synchview misleadingly suggests the Examiner made an express finding that
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`Young’s guide “had nothing to do with the storage of programs” in justifying why
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`the Examiner “did not apply Young against the ‘synchronization’ element.” PO Br.
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`at 4. The applicant had argued that Young’s channel guide was not combinable with
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`Logan’s system for claims 7-8 and 26-27 because Young discloses “the type of serial
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`access video tape technology that Logan et al. was intended to replace.” Ex. 1002 at
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`158-159. The Examiner’s statement was merely indicating that the element of Young
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`being combined—its channel guide—would not be dependent on the particular
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`recording medium used. The synchronization element was not even required by
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`those particular claims (id. at 60-66), and the Examiner was not suggesting that using
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`stored time information, such as program start times, presented in a program guide,
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`along with stored concurrent programs would not “allow” those stored programs “to
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`U.S. Patent 6,788,882
`be synchronized with respect to one another,” as recited in the issued claims. And
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`the file history, of course, does not reflect whether the Examiner made any such
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`conscious decision to “not apply Young” to other elements—indeed, the most
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`plausible explanation for the Examiner’s limited reliance on Young is Young’s
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`failure to disclose key limitations fundamental to the ’882 invention, including the
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`concurrent receipt and digital storage of multiple television programs. Becton factor
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`(d), therefore, also supports institution. All three Becton factors relevant to step (1)
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`in the Advanced Bionics framework (i.e., (a), (b), and (d)) demonstrate that the
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`Office has not previously considered “substantially the same art” or “substantially
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`the same arguments” relied on by Petitioner because Young is not substantially the
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`same art as Girard and was not applied or argued similarly. Therefore, § 325(d) does
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`not apply under Advanced Bionics, and step (2) is not reached.
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`II. Girard Discloses a Digital Video Recorder
`
`Synchview does not dispute that Girard’s interactive television system 20
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`records and stores video digitally for a plurality of channels and programs
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`concurrently. Yet Synchview contends this system does not disclose a “digital video
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`recorder” (DVR) because it is “an on-demand system rather than a DVR” based on
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`a false dichotomy that a digital video recorder and an on-demand system that records
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`video digitally are mutually exclusive concepts. PO Br. at 6-7. This is flatly
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`U.S. Patent 6,788,882
`contradicted by the ’882 Patent’s own words discussing the drawbacks of VCRs and
`
`the need to record channels concurrently to enable future “on demand” viewing:
`
`Ideally, a user should be able to walk up to his television set and be able
`to view, on demand and without delay, everything that he missed
`during some previous period of time (for instance one day), regardless
`of channel. Therefore, what is needed in the art is a fundamental
`increase in the flexibility afforded a user in viewing programs aired
`over multiple channels.
`
`Ex. 1001 at 1:50-56. The ’882 Patent facilitates such “on demand” viewing
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`“regardless of channel” with embodiments that record the plurality of channels “as
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`a matter of course, and without being specifically prompted,” which “may be thought
`
`of as ‘automatic’ recording” where the user “is relieved of the responsibility of
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`starting and stopping recording, allowing the user to view any video recorded during
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`the window of time.” Id. at 2:34-43; see also id. at 2:6-16. And while the ’882 Patent
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`has embodiments that can facilitate allowing the user to select the plurality of
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`channels for recording, “[a]lternatively, the DVR may record all available
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`channels indiscriminately” and “is not limited to a particular manner in which
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`channels are selected for recording.” Id. at 3:59-67; see also id. at 5:24-28 (“[i]f
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`all channels available to the user in question are recorded”); 5:64-66 (“The present
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`invention provides for all channels, or some subset thereof, to be concurrently
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`recorded, at all times, onto a random-access medium.”); Pet. at 8. Thus, the ’882
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`6
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`Patent encompasses automatically recording all television channels available to the
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`user to allow the user to view any past programs on demand and regardless of
`
`channel. This is indistinguishable from Girard’s interactive television system 20 that
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`Synchview attempts to distinguish as an “on demand system.” To construe a “digital
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`video recorder (DVR)” as not encompassing such a system would be to improperly
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`exclude expressly disclosed preferred embodiments of “the present invention” of the
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`’882 Patent.
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`
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`Synchview’s related attempt to distinguish Girard’s system by arguing the
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`“set-top-box user has no control over what (or whether) programs are recorded” (PO
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`Br. at 7) fares no better. As set forth above, the ’882 Patent expressly contemplates
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`automatically recording all channels indiscriminately and is expressly not limited to
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`requiring user selection of a particular plurality of channels to be recorded. And the
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`plain claim language similarly imposes no such requirement of user selection. See,
`
`e.g., Claim 1. Synchview’s attempt to read such a requirement into the term “DVR”
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`via dictionary definitions is, therefore, directly contrary to the intrinsic evidence and
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`the expressly disclosed embodiments, and, thus, improper.
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`Synchview’s arguments regarding the applicant’s efforts to distinguish Shaw
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`and Hite are also misplaced. PO Br. at 8-9. The applicants did not distinguish Shaw
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`based on it being an on-demand system, nor did they argue that such systems that
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`record video digitally are not digital video recorders. The applicants distinguished
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`U.S. Patent 6,788,882
`Shaw by arguing it merely pre-stored movies and therefore never actually received
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`and recorded a plurality of television channels—not because it was an “on demand
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`system.” Ex. 1002 at 241. With regard to Hite, Synchview adds italics to the
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`applicant’s use of the term “video on-demand system” to suggest Hite was
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`distinguished based on being such a system (PO Br. at 9). But it was not. The
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`applicant distinguished Hite’s routing of targeted television commercials because
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`they were not “received and stored concurrently”—not because it was an on-demand
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`system. Ex. 1002 at 236. Applicants made no disavowal during prosecution (which
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`would have been contrary to the ’882 specification) that an on-demand system that
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`records and digitally stores video (like Girard) cannot be a “digital video recorder.”
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`Next, on an issue that the Board’s April 22, 2020 Order did not seek further
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`briefing on (Paper 14 at 3-5), Synchview contends that the Board was correct to
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`construe a “digital video recorder” as requiring “VCR-like functionality,” that “user
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`control over recording is a basic aspect of VCR-like functionality,” and that Girard
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`fails to teach such user control over recording. PO Br. at 9-12. Synchview appears
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`to be proposing a new construction that further narrows the Board’s construction to
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`impose a requirement of VCR-like functionality with respect to “user control over
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`recording.” Id. at 9-10. And Synchview then tries to use this further requirement to
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`argue that even though the ’882 Patent teaches that its DVR can “record[] all
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`channels without requiring the user to select particular channels or programs,” the
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`user is still “in control” because the user can cause the DVR to not record such as by
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`turning it off or not connecting it and because the ’882 Patent teaches that a user can
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`deselect a channel for recording. Id. at 12-13. Synchview then argues Girard does
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`not teach such control. Id. at 13. This argument is incorrect on numerous levels.
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`First, the Board’s claim construction of “DVR” had only required “VCR-like
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`functionality with respect to earlier-recorded, digitized content.” Paper 11 (“DI”) at
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`11, 13. The Board did not impose a requirement of VCR-like functionality with
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`respect to “user control over recording.” Id. While the Microsoft definition
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`referenced “the user picking the programs to be recorded” (DI at 10 (citing Ex. 2004
`
`at 303)), the Television Dictionary (Ex. 2005), adopted by the Board, did not refer
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`to such user control over recording and instead merely referred to the VCR-like
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`functions of “pause, rewind, slow motion, and fast forward control” (DI at 11 (citing
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`Ex. 2005 at 87)). These are VCR-like functions “with respect to earlier-recorded
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`digitized content” as found by the Board and not functions pertaining to user control
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`over recording, i.e., starting or stopping recording. And Girard, of course, plainly
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`teaches such VCR-like functions for recorded content. Ex. 1003 at 7:5-10 (using
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`“VCR” functions viewer can “fast forward, pause, replay, etc.”). Thus, Girard
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`satisfies the Board’s actual construction, which requires VCR-like functions “with
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`respect to earlier-recorded digitized content” and does not require Synchview’s
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`misleading “user-control over recording” requirement.
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`U.S. Patent 6,788,882
`Second, the intrinsic evidence does not support Synchview’s narrowing. The
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`plain claim language, of course, does not impose any such requirement of user
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`control over recording. See, e.g., Claim 1. And even when the ’882 Patent describes
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`examples of VCR-like functionality that its DVR can include, it describes “‘play,’
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`‘stop,’ ‘fast forward,’ and ‘rewind’” but does not refer to any start recording or stop
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`recording function. Ex. 1001 at 7:66-8:26. The ’882 Patent states, “Assuming
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`selected channels (or all channels) are automatically recorded, what is needed is a
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`way to access the recorded material for viewing” without requiring control over
`
`recording. Id. at 8:10-12. Indeed, the ’882 Patent seeks to overcome the drawback
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`of VCRs that required a user to “mak[e] a conscious effort to record the channel in
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`advance” and provides “automatic recording” so “[t]he user therefore is relieved of
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`the responsibility of starting and stopping recording, allowing the user to view any
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`video recorded during the window of time.” Id. at 1:47-49, 2:34-43.
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`Third, even if the ’882 Patent may disclose embodiments where a user is
`
`allowed to deselect a channel from being automatically recorded, the specification
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`does not impose this as a requirement for its DVR by definition or disavowal. And
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`it would be improper to read such a requirement into the claims from embodiments
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`disclosed in the specification.2
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`The Board should reject Synchview’s false dichotomy between on-demand
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`systems that record video digitally and “digital video recorders,” and the Board
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`should also reject Synchview’s improper efforts to read in “user control” limitations,
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`including those not required by the Board’s construction. Once those are stripped
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`away, it is clear Girard achieves the same objectives of the ’882 Patent in allowing
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`a user “be able to walk up to his television set and be able to view, on demand and
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`without delay, everything that he missed during some previous period of time (for
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`instance one day), regardless of channel” (Ex. 1001 at 1:51-53) and be “relieve[d]
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`of the responsibility of starting and stopping recording.” Id. at 2:34-43.
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`III. Girard Discloses Concurrent Recording and Playback of Programs In
`the Same Manner as Disclosed by the ’882 Patent
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`Petitioner continues to contend that the Institution Decision’s construction of
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`“DVR” improperly read in a requirement of “concurrent recording and playback”
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`2 Being mindful of the Board’s instructions, which did not invite comment on its
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`construction of “DVR,” Petitioner rests on its Rehearing Request (see Paper 12
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`(“RR”) at 4-10) and merely notes Synchview’s uninvited arguments (PO Br. at 11)
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`do not dispute there is evidence of change in meaning here given the application pre-
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`dating the commercial-DVR era of the non-contemporaneous definitions. RR at 5.
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`for the reasons set forth in its Rehearing Request but does not further argue that issue
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`in light of the scope of the Board’s instructions. See RR at 6-8; Order at 3-5.
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`Regardless, Girard nonetheless satisfies the Board’s construction because it
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`teaches the same “catch-up viewing” concept as the ’882 Patent where a user can
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`watch the beginning, recorded portion of a program (e.g., an episode of “Seinfeld”)
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`while the live portion is still concurrently being recorded in real time; as a result, the
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`user can “catch up” to the real-time feed. See RR at 10-11 (citing Pet. at 56 (quoting
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`Girard at 7:11-23)); Ex. 1001 at 5:32-35, 9:8-27; Fig. 12. Synchview makes a nearly
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`indecipherable argument regarding how Girard allegedly does not “continu[e] to
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`record the incoming live program, while retrieving the earlier part of the program
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`that was just recorded.” PO Br. at 13-15 (emphasis in original). To the extent
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`Petitioner understands the argument, Synchview suggests Girard does not satisfy this
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`requirement because its system must transition from the stored copy of the broadcast
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`television program that was recorded at the start of the show to a separate real-time
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`video stream of the live television broadcast—that is, it must transition from the
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`stored video data stream of the earlier recorded segment of the same Seinfeld
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`program to the separate real-time video data stream when the user “catches up.” Id.
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`at 14-15 (citing Girard at 7:11-23). But that is precisely how this feature is
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`accomplished in the ’882 patent. Figure 12 of the ’882 Patent demonstrates this
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`concept by separately illustrating the live TV broadcast feed, the recorded TV
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`broadcast, and then the way the recorded broadcast is presented to the user with
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`commercials between the program segments (PS) being skipped:
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`live
`stream
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`recorded
`stream
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`
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`Ex. 1001 at Fig. 12 (showing separate TV broadcast and recorded copy of the TV
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`broadcast). When the user time surfs back to the earlier recorded starting portion of
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`the show at PS1, they are watching a “recorded copy” and after the user “catches
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`up” such as by skipping commercials, the user is “no longer watching the recorded
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`copy,” as described by the ’882 Patent. Id. at 9:16-27. This is precisely how such
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`systems have to work—one cannot rewind a live TV broadcast feed—they must
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`access a recorded copy to “time surf” into the past. And this is precisely how Girard
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`works—by changing from “the real-time video data stream of the current ‘Seinfeld’
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`program to the stored video data stream of the earlier segment of the same ‘Seinfeld’
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`program.” Ex. 1003 at 7:11-23. Girard, therefore, teaches the Board’s construction’s
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`requirement of “the ‘ability to time shift viewing the program as it is being recorded,’
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`which is ‘accomplished by continuing to record the incoming live program, while
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`retrieving the earlier part of the program that was just recorded.” DI at 16.
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`IV. Synchview’s Unaddressed Arguments Are Also Incorrect
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`While the Board also invited comment on Synchview’s argument that “the
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`‘synchronization’ element” is not satisfied because the claims require allowing the
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`programs themselves to be synchronized rather than merely information about the
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`programs to be synchronized (Paper 14 at 4), Synchview does not appear to
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`comment on it. In any event, Petitioner does not merely rely on Girard allowing
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`only information about programs to be synchronized by presenting them on a guide,
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`because Girard allows programs themselves to be synchronized by allowing them to
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`be played back based on time slot. Pet. at 19-21. As Synchview acknowledges, “the
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`claimed synchronization” can, for example, allow “a user watching one stored
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`program at a given time [to] switch to a second program at a different time.” POPR
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`at 22 (citing Ex. 1001 at 14:40-44; 5:47-53 (describing a user hopping from 6 p.m.
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`yesterday to 5 p.m. today)). Girard similarly stores pointers to locations of stored
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`programs (like the ’882 Patent, see Ex. 1001 at 3:5-7) in a SQL database along with
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`scheduled viewing time, to allow a user to select and play back any of the past
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`recorded programs at different times. Pet. at 19-20 (citing Ex. 1001 at 6:23-32, 5:38-
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`41, 6:46-7:4; Figs. 2, 4)). For example, this storage of programs with time
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`information allows a user to watch “Frasier” recorded at 9:00 p.m. on Oct. 11 or to
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`switch to instead watch “Matlock” recorded at 8:00 p.m. on Oct. 13. Pet. at 20-21;
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`Ex. 1001 at 3:55-64, 4:12-20, 5:47-56; 6:23-32, 6:46-74, Figs. 2, 4; Ex. 1007 at ¶ 43.
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`This aligns precisely with the ’882 Patent’s synchronization of allowing “a user
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`watching one stored program at a given time [to] switch to a second program at a
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`different time.” See POPR at 22 (citing Ex. 1001 at 14:40-44; 5:47-53).
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`Synchview also does not comment on its argument that the “channel viewer”
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`element is not satisfied because Girard’s set-top box merely requests a previous
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`program rather than actually retrieving it (Paper 14 at 4), as invited by the Board.
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`Nonetheless, Girard’s set-top box clearly initiates the retrieval of the stored program
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`because it is “[w]hen the viewer selects a past program” on the electronic guide
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`running on the set-top box that the set-top box causes the pointer from the SQL
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`database on the head end server to be provided to the continuous media server so it
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`can retrieve the stored video data stream from the storage array and then “suppl[y]
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`the video data stream to the set-top box.” Pet. at 25-26 (quoting Ex. 1003 at 2:28-
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`35); see also id. at 3:8-10. The set-top box’s request is, therefore, of course, part of
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`its retrieval of the stored program, and it is immaterial that the continuous media
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`server participates in assisting the set-top box in retrieving the stored program so the
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`set-top box can then display it to the user.
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`V. Conclusion
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`Petitioner respectfully requests the Board grant rehearing and institute this
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`proceeding by granting one or more of the three (3) specific types of relief set forth
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`in its Rehearing Request. RR at 2-3.
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`15
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`Case No. IPR2019-00470
`U.S. Patent 6,788,882
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`Respectfully submitted,
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`BY: /s/ Jason R. Mudd _
`Jason R. Mudd, Reg. No. 57,700
`Eric A. Buresh, Reg. No. 50,394
`Ashraf Fawzy, Reg. No. 67,914
`Michelle Callaghan, Reg. 75,665
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`ATTORNEYS FOR PETITIONER
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`CERTIFICATE OF SERVICE
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`Case No. IPR2019-00470
`U.S. Patent 6,788,882
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies that the
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`foregoing was served on May 7, 2020 on counsel for Synchview by filing with PTAB
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`E2E and e-mailing to counsel of record for Synchview, including:
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`• cortneyalexander@kentrisley.com
`• dankent@kentrisley.com
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`Dated: May 7, 2020
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`By: /s/ Jason R. Mudd _
` Attorney for Petitioner
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