`
`
`
`
`Filed: September 30, 2022
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________
`
`GOOGLE LLC,
`
`PETITIONER,
`
`v.
`
`IPA TECHNOLOGIES INC.,
`
`PATENT OWNER.
`___________________
`
`Case No. IPR2019-00728
`U.S. Patent No. 6,851,115
`___________________
`
`PATENT OWNER’S RESPONSIVE REMAND BRIEF
`
`
`
`
`
`TABLE OF CONTENTS
`INTRODUCTION .......................................................................................... 1
`
`I.
`
`GOOGLE FAILS TO ESTABLISH THAT MARTIN QUALIFIES AS
`II.
`PRIOR ART UNDER THE DUNCAN FRAMEWORK ........................................... 1
`A. Duncan Step 1: Identify The Portions Of Martin Relied Upon. .................... 2
`B. Duncan Step 2: What Degree, If Any, Of The Relied Upon Portions Of
`Martin Were Conceived Of By Moran? ......................................................... 2
`C. Duncan Step 3: Was Any Contribution By Moran Significant As
`Measured Against The Full Anticipating Disclosure Of Martin To
`Render Moran A Joint Inventor Of The Applied Portions of Martin? .......... 6
`III. ANY WITNESS CREDIBILITY OR EVIDENTIARY CONFLICTS IN
`THE RECORD FAVOR IPA ..................................................................................... 7
`A. Dr. Moran’s General Credibility Is Not At Issue And Cannot Overcome
`The Lack of Specific Evidence Concerning His Alleged Contribution To
`The Claimed Facilitator .................................................................................. 7
`B. Mr. Cheyer And Mr. Martin’s Unrebutted Testimony Outweigh Dr.
`Moran’s Conclusory Statements .................................................................. 10
`CONCLUSION ............................................................................................ 12
`
`IV.
`
`
`
`
`
`
`
`
`
`
`i
`
`
`
`TABLE OF AUTHORITIES
`
`
`Cases
`Duncan Parking Technologies, Inc. v. IPS Group, Inc.,
`914 F.3d 1347 (Fed. Cir. 2019) ..................................................................... 2, 4, 6
`Google LLC v. IPA Techs. Inc.,
`34 F.4th 1081 (Fed. Cir. 2022) ............................................................. 2, 3, 5, 6, 8
`In re Katz,
`687 F.2d 450 (C.C.P.A. 1982) ............................................................................... 8
`McKenna v. Nestle Purina Petcare Co.,
`No. 2:08-CV-253, 2009 WL 799637 (S.D. Ohio Mar. 24, 2009) ....................... 12
`Yamaha Golf Car Co. v. Club Car, LLC,
`IPR2017-02142, Paper 63 (PTAB Apr. 2, 2019) ................................................. 10
`
`
`ii
`
`
`
`I.
`
`INTRODUCTION
`Patent Owner IPA Technologies LLC submits this responsive remand brief
`
`pursuant to the Board’s September 2, 2022, Order. (Paper 79 (“Order”).)
`
`Despite the Board’s instruction to submit briefing “apply[ing] the Duncan
`
`analysis to the disputed prior art reference” (Order, 3), Google failed to undertake
`
`any substantive analysis concerning the second and third Duncan steps. Google’s
`
`failure to show specific contributions by Dr. Moran to the facilitator described in
`
`the Martin reference (Ex. 1011 (“Martin”)), or any aspect of Martin relied on in
`
`the petition, confirms that Google has not sustained its burden. With no evidence in
`
`the record concerning Dr. Moran’s alleged contribution to the Martin facilitator,
`
`Google retreats to arguing that a finding that Dr. Moran is generally credible
`
`should be sufficient and then recycles its failed arguments that Dr. Moran was in a
`
`position to make contributions to Martin (regardless of whether he actually did).
`
`The Board has already rejected these arguments and should do so again.
`
`II. GOOGLE FAILS TO ESTABLISH THAT MARTIN QUALIFIES AS
`PRIOR ART UNDER THE DUNCAN FRAMEWORK
`The Federal Circuit instructed the Board to comprehensively analyze
`
`whether Martin is prior art under Duncan’s three-step framework, which requires:
`
`(1) determin[ing] what portions of the reference patent were relied on as prior art
`
`to anticipate the claim limitations at issue, (2) evaluat[ing] the degree to which
`
`those portions were conceived “by another,” and (3) decid[ing] whether that other
`
`
`
`1
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`
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`person’s contribution is significant enough, when measured against the full
`
`anticipating disclosure, to render him a joint inventor of the applied portions of the
`
`reference patent. Google LLC v. IPA Techs. Inc., 34 F.4th 1081, 1085 (Fed. Cir.
`
`2022) (“Remand Op.”) (citing Duncan Parking Technologies, Inc. v. IPS Group,
`
`Inc., 914 F.3d 1347 (Fed. Cir. 2019) (“Duncan”)).
`
`The Federal Circuit affirmed the Board’s determination that Google bears
`
`the burden of “establish[ing that] the Martin reference was prior art ‘by another’ by
`
`showing that Dr. Moran made a significant enough contribution to the portions
`
`relied on to invalidate the challenged patents to qualify as a joint inventor of those
`
`portions.” Remand Op. at 1086. In other words, this is something Google needed to
`
`establish in its petition. But Google did not make this required showing in its
`
`petition and has never cured that deficiency. Nothing in Google’s remand brief
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`alters the fundamental fact that “[t]he evidence introduced at trial has not
`
`sufficiently or persuasively addressed Dr. Moran’s testimony regarding his
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`contribution to the Martin reference”—a fatal defect. Paper 74 (“FWD”), 15.
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`A. Duncan Step 1: Identify The Portions Of Martin Relied Upon.
`IPA does not contest that Google identified the portions of Martin relied
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`upon in its petition.
`
`B. Duncan Step 2: What Degree, If Any, Of The Relied Upon Portions
`Of Martin Were Conceived Of By Moran?
`Google states that the Board “may focus specifically on Dr. Moran’s
`
`
`
`2
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`
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`contributions to the claim limitations directed to the facilitator” and limited its
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`briefing accordingly. (Paper 81 (“Br.”), 4.) Thus, the central inquiry at this step is
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`identifying to what degree (if any) Dr. Moran conceived of specific aspects of the
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`facilitator described in Martin that are also relied upon in the petition. As it
`
`pertains to the facilitator, the Federal Circuit observed that certain concepts from
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`Sections 4.1-4.5 of Martin ended up in the specification, including: “‘transparent
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`delegation,’ ‘handling of compound goals’ via delegation, optimization, and
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`interpretation, and using ‘strategies and advice given by the requesting agent.’”
`
`Remand Op. at 1087. Despite this cue from the Federal Circuit, Google does not
`
`discuss any of these aspects of the facilitator in its brief, nor is there any such
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`discussion in Dr. Moran’s declaration (Ex. 1007)—the terms “transparent
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`delegation,” “compound goal,” “delegate,” “delegation,” “optimize,”
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`“optimization,” “strategy,” or “advice” do not appear in those documents, nor are
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`these concepts referred to, even obliquely. Google’s failure to identify any specific
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`contribution by Dr. Moran to the aspects of the facilitator (or any aspect of Martin)
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`relied upon in the petition is fatal. (See FWD, 18 (“The level of such contribution
`
`and whether it is significant such that it evidences invention of subject matter of
`
`Martin is what is lacking from that evidence introduced at trial.”).)
`
`The Federal Circuit’s analysis in Duncan confirms that Google has failed to
`
`carry its burden. In Duncan, one of the “two big hurdles” in developing single-
`
`
`
`3
`
`
`
`space parking technology was “integrating the electronic components and
`
`designing software and a controller to coordinate the electrical system.” Duncan at
`
`1352. The Chief Technology Officer, Schwartz, was assigned “responsibility for
`
`‘figuring out how to implement the electronics.’” Id. There was (1) testimony from
`
`the CEO that Schwartz’s “inventive contribution [was] limited to conception and
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`development of how the various electrical components of the meter are
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`interconnected and operate together,” (2) evidence that Schwartz “generally took
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`responsibility for solving electronics obstacles,” and (3) Schwartz “drew a block
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`diagram conceptualizing the electrical connections between the components.” Id.
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`Based on the record, the Federal Circuit concluded that Schwartz conceived much
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`of the electrical system, including a key block diagram, and solved one of the “two
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`big hurdles” for the claimed technology. Id. at 1359. As a result, the reference at
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`issue qualified as prior art against patent-at issue.
`
`Here, there is no analogous evidence in the record concerning specific
`
`contributions by Dr. Moran. Despite having an entire year to prepare its petition
`
`and Dr. Moran’s declaration, Google was only able to coax Dr. Moran into saying
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`that he “played a significant role regarding the distributed agent-based approach,
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`and in particular using a facilitator” (Ex. 1007, ⁋39) without providing any
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`substantive details. There is no testimony or evidence concerning Dr. Moran’s
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`alleged role in conceiving the facilitator described in Martin, much less identifying
`
`
`
`4
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`
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`any specific contribution. (See Paper 1, 14-15 (petition citing Ex. 1007 at ⁋39 to
`
`establish alleged prior art status of Martin).) This gap is not surprising given the
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`overwhelming evidence IPA submitted that Dr. Moran’s role on the OAA project
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`was administrative in nature (as confirmed by Moran’s CV) and that he did not
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`contribute to the core infrastructure of OAA. (Paper 41 (“POR”), 40-42 (discussing
`
`how Moran’s CV confirms his administrative role within OAA), 48-51; Paper 66
`
`(“Sur-reply”), 15-19.) Even after hearing extensive contrary testimony from
`
`Cheyer and Martin, Google never submitted rebuttal evidence from Dr. Moran.
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`Instead, Google rested its case on the conclusory statement that Dr. Moran played
`
`an unspecified “role.” But playing a “role” is ambiguous at best and certainly does
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`not satisfy the preponderance of the evidence standard. (See POR, 36-39.)
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`Further, IPA asked Dr. Moran if he had any materials corroborating
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`statements in his declaration, and he candidly admitted there were none. (POR, 27-
`
`29). This lack of supporting materials explaining or identifying specific
`
`contributions by Dr. Moran highlights Google’s lack of evidence. Dr. Moran’s
`
`conclusory statement simply does not satisfy Google’s burden. See Remand Op. at
`
`1086 (“to be a joint inventor of the Martin reference, as recognized in Duncan
`
`Parking, [Moran] must have made an inventive contribution to the portions of the
`
`reference relied on and relevant to establishing obviousness.”)
`
`Given that Google cannot bring forth evidence of Dr. Moran’s specific
`
`
`
`5
`
`
`
`contributions, Google instead relies on its argument that if the Board finds Dr.
`
`Moran credible in a general sense that is enough to satisfy Duncan Step 2. That is
`
`not the law and not what the Federal Circuit instructed, nor does Google’s brief
`
`cite any case supporting its position.
`
`C. Duncan Step 3: Was Any Contribution By Moran Significant As
`Measured Against The Full Anticipating Disclosure Of Martin To
`Render Moran A Joint Inventor Of The Applied Portions of Martin?
`Google asserts that if “Dr. Moran is found to have contributed to the
`
`conception of the facilitator, that would end the inquiry.” (Br., 12.) Google is
`
`wrong. The Federal Circuit stated that “the Board did not complete the full Duncan
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`analysis,” which includes Duncan Step 3. Remand Op. at 1087. The footnote
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`Google cites says that if “joint inventorship is not found as to the relied-on portions
`
`of the Martin reference for the facilitator claim limitation,” the Board may need to
`
`consider “the recursion portions of the reference.” Remand Op. at fn. 4. However,
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`Google elected not to raise any substantive arguments concerning recursion
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`because it has none. (See Br., 4 (electing to focus brief solely on the facilitator).)
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`Once again, the Federal Circuit’s analysis in Duncan concerning Step 3 is
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`instructive. In Duncan, the record reflected that the creation of the block diagram
`
`in the record “was not a minor task” and that “Schwartz’s contribution…discloses
`
`a parking meter device with a detailed electrical system, a challenge [the CEO]
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`described as one of ‘two big hurdles’ to the invention.” Duncan at 1359. Thus,
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`
`
`6
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`
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`Schwartz’s contribution was significant to the overall invention. Here, Google
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`defaulted on its burden and did not attempt to measure any alleged contribution by
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`Dr. Moran to the facilitator described in Martin (because Google identifies none)
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`against the full anticipating disclosure of Martin. Google bears both the initial
`
`burden of production and persuasion. Failing to substantively address and
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`undertake any Step 3 analysis ruins Google’s chances of proving its case.
`
`III. ANY WITNESS CREDIBILITY OR EVIDENTIARY CONFLICTS IN
`THE RECORD FAVOR IPA
`Google defaulted on its obligations to provide any substantive analysis under
`
`Duncan Steps 2 and 3. Instead, as mentioned above, Google pivots to incorrectly
`
`argue that Dr. Moran’s general credibility is the only issue. But the Board already
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`considered the competing testimony and evidence in the record and correctly
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`concluded that Google did not carry its burden. (See FWD.) The Board’s decision
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`could not have been reached if the testimony and evidence submitted by IPA were
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`not more credible and compelling when weighed against Paragraph 39 of Dr.
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`Moran’s declaration. Even if witness credibility were the sole issue (it is not), IPA
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`still prevails because Google’s evidence cannot satisfy the preponderance of the
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`evidence standard. (POR, 51-52; Paper 73 (“Hrg. Tr.”), 103:8-104:8 (discussing
`
`how the evidentiary scales never tip in Google’s favor).)
`
`A. Dr. Moran’s General Credibility Is Not At Issue And Cannot
`Overcome The Lack of Specific Evidence Concerning His Alleged
`Contribution To The Claimed Facilitator
`
`
`
`7
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`
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`Google continues to rely on Dr. Moran’s co-author status as evidence of his
`
`contribution to the Martin reference. While the Federal Circuit has stated that co-
`
`authorship may be “corroborating evidence,” the Court has never overruled
`
`established precedent that “authorship of an article by itself does not raise a
`
`presumption of inventorship with respect to the subject matter disclosed in the
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`article.” In re Katz, 687 F.2d 450, 455 (C.C.P.A. 1982)). Co-authorship alone is
`
`not sufficient—if it were, the Federal Circuit would not have remanded here.
`
`Google claims the Moran declaration was “thorough” because it described
`
`his general education, work experiences, and affiliation with the OAA project. (Br.
`
`6-7). This is simply a re-packaging of Google’s failed argument that Dr. Moran
`
`was in a position to make contributions, an argument this Board has rightly
`
`rejected. (See FWD, 13.) The Federal Circuit explicitly said that while it is
`
`“evident that Dr. Moran made general technical contributions to the OAA
`
`project…. that is not the relevant inquiry.” Remand Op. at 1086 (emphasis
`
`added). Google has never explained how Dr. Moran’s education or experience
`
`“reflect[s] his contribution to the inventorship of the Martin reference beyond
`
`supporting foundational concepts” because there is nothing in the record for
`
`Google to point to. (FWD, 16; see also id., 17 (noting Moran’s testimony is “not
`
`inconsistent with the assertion that the specific disclosure in Martin that is relied on
`
`in Petitioner’s challenge is the sole work of the two named inventors.”).
`
`
`
`8
`
`
`
`Next, Google states that Dr. Moran testified out of a “moral obligation.”
`
`(Br., 6). First, Dr. Moran did not make that statement in any declaration or
`
`testimony in the record. Second, there is no dispute that Dr. Moran, in contrast
`
`with the inventors, was paid for his participation and agreed to submit a declaration
`
`only after being contacted by Google. (See POR, 48; Sur-reply, 5-7 (citing
`
`testimony).) Third, any unsubstantiated motivation for Dr. Moran’s testimony
`
`cannot substitute for the lack of evidence in the record.
`
`Google also relies on Dr. Moran’s co-authorship status on other OAA-
`
`related papers. (Br., 7.) However, this post-hoc attorney argument is entitled to no
`
`weight as Dr. Moran does not discuss those papers in his declaration. For all
`
`anyone knows, Dr. Moran was named as a co-author on other papers for the same
`
`reason he appears as a co-author on Martin—as a sign of respect, but not for any
`
`technical contribution. (See Section III(B), infra; Sur-reply, 9.) At best, these
`
`articles are cumulative in showing that Dr. Moran was affiliated with the OAA
`
`project, which IPA has never contested. (Sur-reply, 11-12.) There is no testimony
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`in the record from Dr. Moran concerning his specific alleged contributions to other
`
`papers, nor does Google explain how these other papers provide any detail
`
`concerning Dr. Moran’s alleged contributions to the facilitator described in Martin.
`
`Finally, Google’s argument that Dr. Moran “consistently described his role
`
`on the OAA team for many years” (Br., 8) misses the mark. The inquiry here is not
`
`
`
`9
`
`
`
`whether Dr. Moran was affiliated with OAA but the degree to which Dr. Moran
`
`conceived of the facilitator described in Martin. Google never satisfies this inquiry.
`
`B. Mr. Cheyer And Mr. Martin’s Unrebutted Testimony Outweigh Dr.
`Moran’s Conclusory Statements
`Inventors Cheyer and Martin have maintained a consistent story for decades.
`
`Starting with the Rule 1.132 declarations submitted during prosecution (when
`
`events were fresh), the inventors attested that Dr. Moran did not contribute to the
`
`portions of Martin relied upon by the examiner, including the facilitator. (POR, 16-
`
`17; Sur-reply, 10-11). That is the same position they maintained years later during
`
`their IPR depositions, despite having no interest in the outcome of the proceedings
`
`and receiving no compensation. (POR, 48-51; Ex. 2037, 39:2-40:8; Sur-reply, 5-7.)
`
`Cheyer and Martin independently testified that Dr. Moran’s role with OAA
`
`was administrative and that he was included as a co-author on Martin as a sign of
`
`respect, not for any inventive contribution. (POR, 48-51; Sur-reply, 15-19; Ex.
`
`2037, 35:24-37:20; Ex. 2038, 44:5-24). Google did not submit rebuttal testimony
`
`from Dr. Moran on these points, despite having the opportunity to do so in its
`
`Reply. (See Paper 59 (“Reply”), 4 at fn. 1 (Google arguing that “the introduction of
`
`evidence to rebut IPA’s new arguments and evidence is entirely appropriate.”));
`
`see also Yamaha Golf Car Co. v. Club Car, LLC, IPR2017-02142, Paper 63 at 15
`
`(PTAB Apr. 2, 2019) (“Yamaha never disputes that rebuttal testimony from Club
`
`Car’s expert, which is telling.”) In addition, both inventors independently testified
`
`
`
`10
`
`
`
`that Dr. Martin did not make technical contributions to “the core infrastructure [of
`
`OAA],” which would have included the facilitator. (POR, 49-50; Ex. 2037, 33:9-
`
`35:22, 37:12-38:7, 64:16-65:4, 92:20-95:3; Ex. 2038, 36:2-21, 42:16-46:2, 67:12-
`
`15, 73:24-74:10, 123:11-19.)1
`
`As explained in its POR, the source code files listing Cheyer and Martin as
`
`authors were submitted with the application to help practitioners construct a
`
`preferred embodiment of the invention. (POR, 19-20; Sur-reply, 13). As it pertains
`
`to aspects of the Martin facilitator identified by the Federal Circuit: (1)
`
`compound.pl “provides handling of compound goals by the facilitator” (Ex. 1004,
`
`626) and (2) fac.pl “the facilitator agent” “provides communications and
`
`coordination of the activities of a dynamic collection of client agents” (Ex. 1004,
`
`647). Both files list Cheyer and Martin as authors and are prima facia evidence
`
`corroborating Cheyer and Martin’s testimony that they, not Moran, were
`
`responsible for the conception of the facilitator, including as described in Martin.
`
`That Dr. Moran did not write code (because of a neck injury) is irrelevant. The
`
`
`1 Google misleadingly quotes testimony to argue that “Mr. Martin agreed that Dr.
`
`Moran” “may have made” technological contributions that included the facilitator.
`
`(Br. 9.) The removed testimony in Google’s citation shows Mr. Martin was not
`
`asked about facilitators and was not discussing facilitators. (Ex. 2038, 116:2-8.)
`
`
`
`11
`
`
`
`question is what Dr. Moran allegedly conceived, not what he did not do.
`
`Finally, Google recycles its unsupported assertions that IPA led the
`
`inventors to believe they “stood to bear substantial financial risk and/or loss of
`
`recognition” or told Mr. Cheyer that “Dr. Moran was claiming he should have been
`
`named as an inventor.” IPA has already addressed these disparaging comments –
`
`they are blatantly false. (See Sur-reply, 7 at fn. 3.) Resorting to attacks of
`
`professional integrity, aside from exposing counsel to potential sanctions, does
`
`nothing to advance Google’s position and only highlights the weaknesses of its
`
`arguments on the merits. See McKenna v. Nestle Purina Petcare Co., No. 2:08-
`
`CV-253, 2009 WL 799637, at *6 (S.D. Ohio Mar. 24, 2009) (“impugn[ing] the
`
`honesty or integrity of opposing counsel without factual support” is sanctionable.)
`
`IV. CONCLUSION
`Google’s has failed to demonstrate Dr. Moran conceived of any specific
`
`aspects of the facilitator described in Martin using the Duncan analysis. Further,
`
`the Board’s prior FWD could not have been reached without implicitly resolving
`
`any evidentiary conflicts in IPA’s favor. Therefore, IPA respectfully requests the
`
`Board make explicit what was implicit in the FWD and once again affirm that
`
`Martin does not qualify as prior art, that the testimony and evidence from Cheyer
`
`and Martin outweighs Dr. Moran’s conclusory statements, and that Google has not
`
`met its burden by a preponderance of the evidence.
`
`
`
`12
`
`
`
`Dated: September 30, 2022
`
`
`Respectfully Submitted,
`
`/Steven W. Hartsell/
`Steven W. Hartsell (Reg. No. 58,788)
`SKIERMONT DERBY LLP
`1601 Elm St., Ste. 4400
`Dallas, Texas 75201
`P: 214-978-6600/F: 214-978-6601
`Lead Counsel for Patent Owner
`
`Alexander E. Gasser (Reg. No. 48,760)
`Sarah E. Spires (Reg. No. 61,501)
`Paul J. Skiermont (Pro Hac Vice)
`Jaime K. Olin (Pro Hac Vice)
`SKIERMONT DERBY LLP
`1601 Elm St., Ste. 4400
`Dallas, Texas 75201
`P: 214-978-6600/F: 214-978-6621
`Back-Up Counsel for Patent Owner
`
`13
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), I certify that I caused to be served on the
`
`counsel for Petitioner a true and correct copy of the foregoing Patent Owner’s
`
`Responsive Remand Brief by electronic means on September 30, 2022, at the
`
`following addresses or record:
`
`Naveen Modi
`Joseph E. Palys
`Daniel Zeilberger
`Arvind Jairam
`PAUL HASTINGS LLP
`PH-Google-IPA-IPR@paulhastings.com
`
`Dated: September 30, 2022
`
`
`
`
`
`
`Respectfully Submitted,
`
`/Steven W. Hartsell/
`Steven W. Hartsell (Reg. No. 58,788)
`Counsel for Patent Owner
`
`
`
`
`
`
`
`
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