Filed on behalf of Telebrands Corp. by:
`
`Robert T. Maldonado (Reg. No. 38,232)
`Tonia A. Sayour (Reg. No. 58,404)
`Vishal J. Parikh (Reg. No. 73,935)
`Cooper & Dunham LLP
`30 Rockefeller Plaza
`New York, NY 10112
`(212)278-0400
`rmaldonado@cooperdunham.com
`tsayour@cooperdunham.com
`vparikh@cooperdunham.com
`
`
`
`Eric J. Maurer (Reg. No. 43,782)
`Boise, Schiller, & Flexner LLP
`1401 New York Ave, NW
`Washington, DC 20005
`(202) 274-1151
`emaurer@bsfllp.com
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`TELEBRANDS CORP.,
`Petitioner,
`
`v.
`
`TINNUS ENTERPRISES, LLC,
`Patent Owner.
`____________
`PGR2017-00015
`U.S. Patent No. 9,527,612
`____________
`PETITIONER’S SUPPLEMENTAL REPLY BRIEF
`
`
`
`
`
` 
`
`

`

`PGR2017-00015
`U.S. Patent No. 9,527,612
`
`
`TABLE OF CONTENTS
`
`BACKGROUND ................................................................................................. 1
`I.
`II. CLAIMS 1-4 OF THE ’612 PATENT ARE OBVIOUS UNDER 35 U.S.C §
`103 ....................................................................................................................... 2
`A. Donaldson Discloses An Elastic Fastener With A Tension Low Enough To
`Permit A Container To Detach By Filling With Water ................................... 2
`B. It Would Have Been Obvious To A POSA To Combine Saggio And
`Donaldson ........................................................................................................ 5
`C. Lee Discloses An Elastic Fastener That Permits Detachment ......................... 7
`D. It Would Have Been Obvious To A POSA To Combine Saggio And Lee ..... 8
`E. Secondary Considerations Do Not Overcome A Strong Prima Facie Case Of
`Obviousness ................................................................................................... 10
`III. THE PRESSING LIMITATION OF CLAIM 3 IS NOT SUPPORTED BY
`THE WRITTEN DESCRIPTION ..................................................................... 11
`IV. CONCLUSION ................................................................................................. 11
` 
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`i
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`PGR2017-00015
`U.S. Patent No. 9,527,612
`
`
`TABLE OF AUTHORITIES
`
`Cases
`In re Clay,
`966 F.2d 656 (Fed. Cir. 1992) ................................................................................ 9
`Intercontinental Great Brands LLC v. Kellogg North Am. Co.,
`2017 WL 3906853 (Fed.Cir. 2017) ...................................................................... 11
`Iron Grip Barbell Co., Inc. v. USA Sports, Inc.,
`392 F.3d 1317 (Fed. Cir. 2004) .............................................................................. 9
`Martin v. Mayer,
`823 F.2d 500 (Fed. Cir. 1987) .............................................................................. 11
`PAR Pharm., Inc. v. TWI Pharm., Inc.,
`773 F.3d 1186 (Fed. Cir. 2014) .............................................................................. 3
`SAS Inst., Inc. v. Iancu,
`2018 WL 1914661 (U.S. Apr. 24, 2018) ................................................................ 1
`Tinnus Enterprises, LLC et al. v. Telebrands Corp. et al.,
`846 F.3d 1190 (Fed. Cir. 2017) .............................................................................. 9
`Wyers v. Master Lock Co.,
`616 F.3d 1231 (Fed. Cir. 2010) .............................................................................. 9
`
`
`
`
`
` 
`
`ii
`
`

`

`PGR2017-00015
`U.S. Patent No. 9,527,612
`
`
`BACKGROUND
`
`On May 3, 2018, the Board issued an Order in response to the recent Supreme
`
`I.
`
`Court ruling in SAS Inst., Inc. v. Iancu holding that the Board may not institute on
`
`less than all claims challenged in the petition. (see Paper#30; SAS Inst., Inc. v. Iancu,
`
`2018 WL 1914661, at *10 (U.S. Apr. 24, 2018)). In the Board’s Order, the Board
`
`modified its October 11, 2017 Institution Decision instituting on only claim 3 of U.S.
`
`Patent No. 9,527,612 (the “’612 Patent”) for indefiniteness, to instituting on all
`
`claims and grounds raised in Petitioner’s petition. (See Paper#30.) The Board
`
`authorized Telebrands to file a supplemental reply brief with additional evidence.
`
`(See id., p.4.) Tinnus refused to participate any further in this PGR, preferring instead
`
`to rely on its Preliminary Patent Owner Response as supplementing its Patent Owner
`
`Response and the other evidence of record in this PGR.1 (See id., p.3)
`
`
`
`
`
`
`
`                                                            
`1     Tinnus argued that all the disputed issues in this PGR proceeding have been
`resolved by the Final Written Decisions in PGR2016-00030 and PGR2016-00031.
`(See Ex.2035.) However, those other proceedings involve different patents with
`different claims, and the evidence and argument in those proceedings is not of record
`in this proceeding. 
`
`
`
`1
`
`
`
`

`

`PGR2017-00015
`U.S. Patent No. 9,527,612
`
`II. CLAIMS 1-4 OF THE ’612 PATENT ARE OBVIOUS UNDER 35 U.S.C
`§ 103
`
`A. Donaldson Discloses An Elastic Fastener With A Tension Low Enough
`To Permit A Container To Detach By Filling With Water
`
`
`Tinnus contends that the ’612 patent is not obvious because Donaldson fails
`
`to disclose the claimed elastic fastener having a tension low enough to permit the
`
`container to detach by filling with water. (See Paper#13, p.26.) Tinnus is incorrect,
`
`and has submitted no evidence, expert or otherwise, to support its argument.
`
`Donaldson discloses a balloon, clamped to an inner tube and an outer tube,
`
`that is inflated with pressurized gas which causes the balloon to detach from a tube.
`
`(Ex.1013, 4:53-5:6). The balloon in Donaldson is detached as the pressure inside
`
`the balloon is pushing outward more than the air pressure from the outside is pushing
`
`the balloon inward. (Ex.1034, ¶¶5-6). The pressurized gas also aids in applying a
`
`force to an inner tube, causing it to move in a direction away from the neck of the
`
`balloon, aiding in the balloon detaching. (Ex.1013, 4:61-5:3; Ex.1034, ¶6.) It is
`
`indisputable that the pressurized gas causes the detachment. That mechanical
`
`actuation may assist in detachment does not mean that “at least partially filling” does
`
`not cause the detachment, particularly when the “at least partially filling” is causing
`
`the mechanical actuation.
`
`If the tension of the O-ring of Donaldson did not have a tension low enough
`
`to permit the balloon to detach, then the O-ring would never detach from the tube,
`
`2
`
`
`
`

`

`PGR2017-00015
`U.S. Patent No. 9,527,612
`
`as the frictional force of the O-ring clamping the neck of the balloon to the tube
`
`would be too great to overcome. (Ex.1034, ¶7). This would result in the balloon
`
`bursting instead of detaching. (Id.) This is clearly not the case in Donaldson. (Id.)
`
`The force required to remove the O-ring from the tube is just the force necessary to
`
`overcome the frictional force of the O-ring. (Id.) Since Donaldson discloses that
`
`the O-ring can be detached, it is clear that the O-ring of Donaldson inherently must
`
`have a tension low enough to permit the balloon to detach from the tube. (Id.). See
`
`PAR Pharm., Inc. v. TWI Pharm., Inc., 773 F.3d 1186, 1195-96 (Fed. Cir. 2014) (to
`
`establish inherency in an obviousness analysis, “the limitation at issue necessarily
`
`must be present, or the natural result of the combination of elements explicitly
`
`disclosed by the prior art.”)
`
`Tinnus argues that Telebrands failed to discuss the spring of Donaldson, and
`
`that the Donaldson device discloses gas and not water. (See Paper#13, pp.28-29.)
`
`In his Supplemental Declaration, Dr. Kamrin explains that while the spring of
`
`Donaldson plays a role in the movement of the inner tubes, the movement is caused
`
`by at least partially filling the balloon with pressurized gas. (Ex.1034, ¶6). The
`
`pressure inside the tube causes the displacement of the spring. (Id.). Second, the
`
`fact that Donaldson is not used with water is of no significance. (Id., ¶9). Even if
`
`the O-ring of Donaldson were to be used with a balloon filled with a different fluid,
`
`e.g. water instead of gas, for the balloon to detach from the tube, the force acting on
`
`3
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`
`

`

`PGR2017-00015
`U.S. Patent No. 9,527,612
`
`the balloon must still be greater than the frictional force of the O-ring. (Id.) As
`
`stated above, the only determination necessary is the force needed to overcome the
`
`frictional force of the O-ring. (Id., ¶7). Regardless of the fluid inside the balloon or
`
`the force applied, a POSA would still look to the structure and function of the O-
`
`ring disclosed by Donaldson to clamp a balloon to a tube so that it detaches by
`
`partially filling. (Ex.1034, ¶9).
`
`Moreover, contrary to Tinnus’s assertions, Donaldson does teach an O-ring
`
`that permits a balloon to detach from a tube. Tinnus asserts that Telebrands only
`
`argues that the O-ring of Donaldson is “capable of” permitting the balloon to detach.
`
`(See Paper#13, p.31.) However, it is clear from Donaldson that the O-ring is not
`
`only “capable of” permitting it to detach, the O-ring of Donaldson actually permits
`
`the balloon to detach. (Ex.1013, 4:61-5:3). Tinnus has not argued, and cannot argue,
`
`that at least partially filling the balloon with a fluid does not cause the tube to
`
`displace. Tinnus already has argued that the tubular displacement causes the balloon
`
`to detach. Thus, the elastic fastener permits detachment.2
`
`                                                            
`2 Telebrands asserts that FIGS. 3-5 of the Donaldson reference show the balloon
`detaching without mechanical actuation—the tubes do not move relative to one
`another. (Ex.1013, FIGs. 3-5). In any event, even if there were mechanical actuation,
`as described in the text of the reference, it is caused by the pressurized air. (Ex.1034,
`¶6). The result is the same either way.
`
`
`
`4
`
`
`
`

`

`PGR2017-00015
`U.S. Patent No. 9,527,612
`
`Finally, Tinnus relies on the Examiner’s statement that “it is not true that all
`
`elastic bands have the same elastic force as an inherent property, there is no basis to
`
`conclude that the bands disclosed in the prior art would be capable of functioning as
`
`claimed.” (See Paper#13, p.30.) However, Telebrands has demonstrated that
`
`although not all elastic fasteners have the same strength, the O-ring of Donaldson
`
`does function as the claimed elastic fastener. The O-ring of Donaldson has a tension
`
`to clamp a balloon to a tube, to permit detachment of the balloon from the tube by
`
`at least partially filling the balloon, and to seal the balloon upon detachment, just
`
`like the claimed elastic fastener. (Ex.1034, ¶8). Therefore, Donaldson discloses the
`
`structure and function of the claimed elastic fastener.
`
`
`
`B. It Would Have Been Obvious To A POSA To Combine Saggio And
`Donaldson
`
`Tinnus has not argued that a POSA would not have been motivated to combine
`
`Saggio and Donaldson, and this Board has previously held that, based on the same
`
`affirmative evidence, Telebrands has demonstrated a motivation to combine Saggio
`
`and Donaldson.3 (Ex.1025, pp.27-28; Ex.1026, pp.28-30). Tinnus has, however,
`
`relied on findings by the district court, based on a different record, that there is no
`
`                                                            
`3 In those prior PGRs, Tinnus presented evidence against motivation to combine
`that it did not present here, yet the Board still found Telebrands’ evidence
`sufficient.
`
`
`
`5
`
`
`
`

`

`PGR2017-00015
`U.S. Patent No. 9,527,612
`
`motivation to combine. (See Paper#13, p.10, citing Ex.2004, p.7.) A POSA would
`
`have motivated to combine the O-ring of Donaldson with the balloon filling device
`
`of Saggio, as Donaldson discloses an O-ring meeting the limitations of the claimed
`
`elastic fastener. (Ex.1034, ¶¶10-16). Specifically, the ’612 Patent addresses the
`
`problem of filling multiple balloons simultaneously, which is addressed by the prior
`
`art in Saggio and Boise. (Ex.1034, ¶10; Ex.1011; Ex.1014). Saggio discloses a
`
`device for filling multiple self-sealing balloons containing an elastic internal
`
`membrane. (Ex.1034, ¶11). Saggio does not teach an external elastic fastener that
`
`attaches, detaches, and seals a balloon from a tube. (Id., ¶10). To attach, detach,
`
`and seal a balloon from a tube, a POSA would look to ways other individuals have
`
`attached and detached a balloon from a tube, and means that others have used to seal
`
`balloons upon detachment, such as a device that fills one balloon at a time, as long
`
`as the device does not disclose that the balloons have to be manually held onto the
`
`tubes or manually tied to seal upon detachment. (Id.). A POSA would therefore
`
`look to a device such as the one disclosed in Donaldson to attach, detach, and seal a
`
`balloon from a tube. (Id.). Both the O-ring of Donaldson and the elastic internal
`
`membrane of Saggio are used to automatically seal a fluid in a balloon when the
`
`balloon is detached from the hollow tube, thus addressing the same problem. (Id.,
`
`¶11). Using the O-ring of Donaldson as a substitution of the elastic internal
`
`membrane of Saggio would have been a simple, cheaper substitution of known
`
`6
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`
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`

`

`PGR2017-00015
`U.S. Patent No. 9,527,612
`
`elements that achieved predictable results as O-rings have been well-known to
`
`perform clamping, detaching, and sealing functions. (Id., ¶11). The balloon of
`
`Saggio would require special tooling, which would have cost many thousands of
`
`dollars, and would require extra material (and cost) for creating the elastic internal
`
`membrane. (Id., ¶12). It would have been much simpler and cheaper for a POSA to
`
`use off-the-shelf balloons and O-rings, which would be very inexpensive. (Id., ¶¶13-
`
`15.) It would also be easy to apply the O-rings to the tubes to attach the balloons.
`
`(Id., ¶14, Ex.1035). It would have been obvious for a POSA to look to similar
`
`functioning structures, such as the O-ring of Donaldson, to replace the elastic
`
`internal membrane of Saggio to save cost, time and effort. (Id. ¶¶11-16; see also
`
`KSR Int’l Co. v. Teleflex, Inc., 550 U.S. 398, 416 (2007)).
`
`C. Lee Discloses An Elastic Fastener That Permits Detachment
`
`Contrary to Tinnus’s assertions, Lee teaches that after a balloon is expanded
`
`with an amount of air, an outer guide pushes the rubber band and balloon off of a
`
`tube. (Ex.1034, ¶17; Lee, ¶33). Manually pushing the rubber band applies a force
`
`to the rubber band to cause detachment of the rubber band and balloon from the tube.
`
`(Ex.1034, ¶17). The tension of the rubber band of Lee must be below a certain limit
`
`so that the rubber band can be pushed off the tube. (Id.). In other words, the tension
`
`of the rubber band of Lee must not be so high as to prevent the rubber band from
`
`being pushed off the tube. (Id.). If the rubber band of Lee did not have any upper
`
`7
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`

`

`PGR2017-00015
`U.S. Patent No. 9,527,612
`
`limit to the tension of the rubber band, as Tinnus asserts, then the rubber band of Lee
`
`could have a tension so high as to prevent any non-destructive applied force from
`
`overcoming the frictional force, not permitting the balloon of Lee to detach. (Id.,
`
`¶17). This would render Lee inoperable for its intended use, as the balloon in Lee
`
`would never detach. (Id.). Similar to Donaldson above, Tinnus does not provide
`
`any expert testimony to support any of its assertions.
`
`Further, the determination of the force required to push the rubber band of Lee
`
`off the tube is similar to the determination of the force discussed above in regard to
`
`O-ring of Donaldson. The force applied to the rubber band need only be greater than
`
`the frictional force of the rubber band clamping the rubber band to the tube to detach
`
`the rubber band from the tube. (Id., ¶18). This force determination does not change
`
`if the balloon is filled with air or water. (Id., ¶18). Therefore, the determination of
`
`the force required to overcome the frictional force of the rubber band and detach the
`
`balloon from the tube is the same regardless of whether the balloon is filled with air
`
`or water, or how the force is applied. (Id., ¶18).
`
`D. It Would Have Been Obvious To A POSA To Combine Saggio And
`Lee
`Similar to Donaldson discussed above, A POSA would have motivated to
`
`combine the rubber band of Lee with the balloon filling device of Saggio, as the
`
`rubber band of Lee is also functionally equivalent to the elastic internal membrane
`
`described in Saggio. (Ex.1034, ¶20). Saggio and Lee both are analogous art as they
`
`8
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`

`

`PGR2017-00015
`U.S. Patent No. 9,527,612
`
`solve the same problem of sealing a balloon without tying a knot in the neck of the
`
`balloon, which can be tedious and time-consuming.4 (Id.; see also Wyers v. Master
`
`Lock Co., 616 F.3d 1231, 1237 (Fed. Cir. 2010)). Further, although Lee is a medical
`
`reference, the ’612 Patent discloses an embodiment where elastic fasteners are used
`
`to self-seal a balloon in a medical procedure. (Ex.1034, ¶19; Ex.1001, FIGs. 5-6,
`
`5:24-43). Further, similar to Donaldson, Lee teaches a simpler, cheaper, and
`
`commercially available alternative to the self-sealing balloons of Saggio and a
`
`POSA would look to Lee as an alternative to the elastic internal membrane of Saggio.
`
`(Ex.1034, ¶20).
`
`
`
`                                                            
`4 Telebrands notes that the Federal Circuit in Tinnus Enterprises, LLC et al. v.
`Telebrands Corp. et al., 846 F.3d 1190 (Fed. Cir. 2017), based on a different
`record, stated that the problem facing the inventor in a patent in the same family as
`the ’612 Patent was “how to rapidly fill multiple containers with fluid” and that
`this was “far removed” from the disclosure of the Lee reference. See Tinnus
`Enterprises, LLC, 846 F.3d at 1207 (emphasis added). Lee discloses how to
`rapidly fill and seal a single container with fluid. The Federal Circuit has held that
`prior art disclosing a device pertaining to a single element is analogous to a patent
`disclosing a device pertaining to multiple elements. See Iron Grip Barbell Co.,
`Inc. v. USA Sports, Inc., 392 F.3d 1317, 1321-22 (Fed. Cir. 2004) (a prior art
`reference disclosing a single elongated handle on a weight plate was analogous art
`to a patent disclosing multiple (three) handles on a weight plate.) Alternatively,
`the Federal Circuit has also held that as long as the prior art reference is from the
`same field of endeavor, the reference does not have address the same problem
`being solved. See In re Clay, 966 F.2d 656, 658-59 (Fed. Cir. 1992). Both Lee
`and the ’612 Patent are from the field of filling and sealing a balloon with fluid and
`both have applications in a medical context. Therefore, Lee is analogous art to
`the ’612 Patent.
` 
`
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`9
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`

`

`PGR2017-00015
`U.S. Patent No. 9,527,612
`
`E. Secondary Considerations Do Not Overcome A Strong Prima Facie
`Case Of Obviousness
`
`In its Preliminary Patent Owner Response, Tinnus does not argue that
`
`secondary considerations overcome a finding of obviousness. Tinnus presented
`
`certain evidence that theoretically could relate to secondary considerations,
`
`consisting only of one article about its Bunch O Balloons product (Ex.2002), and
`
`two awards received by the Bunch O Balloons product (Exs.2010, 2015.).
`
`Defendants also have submitted Complaints in district court litigation (Exs.2003,
`
`2006, 2009, 2011), but those complaints contain mere allegations, and do not
`
`constitute evidence of the facts alleged therein.5 Finally, Tinnus has submitted no
`
`evidence that any of these documents relates to ’612 patent. Instead, Tinnus makes
`
`a conclusory statement, unsupported by any expert testimony or claim charts, that
`
`the Bunch O Balloons product is coextensive with the claims of the ’612 Patent. To
`
`the extent that the Board considers the evidence, one article is insufficient to
`
`establish industry praise, and there is no evidence of the criteria for the two awards.
`
`In other proceedings, the Board has held that such evidence is insufficient. (Ex.1036,
`
`p.11; Ex.1037, p.10). There also is no evidence that the article or awards related to
`
`the features claimed in the ’612 patent. Importantly, even if credited, these
`
`                                                            
`5 Tinnus also cites Orders for the district court on preliminary injunctions. (Exs.2004,
`2007.) But those Orders are not binding in this proceeding, are preliminary in nature,
`and are based upon evidence that is not before this Board.
`
`10
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`PGR2017-00015
`U.S. Patent No. 9,527,612
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`“secondary considerations” cannot overcome a strong prime facie case of
`
`obviousness. See Intercontinental Great Brands LLC v. Kellogg North Am. Co.,
`
`2017 WL 3906853 at *8 (Fed.Cir. 2017)
`
`III. THE PRESSING LIMITATION OF CLAIM 3 IS NOT SUPPORTED
`BY THE WRITTEN DESCRIPTION
`
`Tinnus contends the “pressing limitation” of dependent claim 3 – “press
`
`against each other, regardless whether the first and second ones of the plurality of
`
`containers are in a filled or an unfilled state” – is sufficiently described in the
`
`specification. (Paper#13, p.38.). Contrary to Tinnus’s assertions, the specification
`
`merely recites that as the containers become filled, they may push against other.
`
`However, unfilled is the exact opposite of filled. The specification fails to disclose
`
`containers pressing against each other in an unfilled state. See Martin v. Mayer, 823
`
`F.2d 500, 505 (Fed. Cir. 1987) (written description requirement is “not a question of
`
`whether one skilled in the art might be able to construct the patentee’s device from
`
`the teachings of the disclosure.... Rather, it is a question whether the application
`
`necessarily discloses that particular device.”)
`
`IV. CONCLUSION
`
`For all the foregoing reasons, and for the reasons set forth in Telebrands’
`
`Petition, claims 1-4 of the ’612 patent, are unpatentable under 35 U.S.C. §§ 112(a)
`
`and 103.
`
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`11
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`Dated: July 2, 2018
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`PGR2017-00015
`U.S. Patent No. 9,527,612
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`Respectfully submitted,
`
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`/s Robert T. Maldonado/
`Robert T. Maldonado (Reg. No. 38,232)
`Tonia A. Sayour (Reg. No. 58,404)
`Vishal J. Parikh (Reg. No. 73,935)
`Cooper & Dunham LLP
`30 Rockefeller Plaza
`New York, NY 10112
`Tel: (212) 278-0400
`Fax: (212) 391-0525
`
`Eric J. Maurer (Reg. No. 43,782)
`Boise, Schiller, & Flexner LLP
`1401 New York Ave, NW
`Washington, DC 20005
`Tel: (202) 274-1151
`emaurer@bsfllp.com
`
`
`
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`12
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`CERTIFICATION OF WORD COUNT
`
`Pursuant to the Board’s May 31, 2018 Order (the “Order”), Paper No. 36, the
`
`undersigned certifies that the forgoing document, excluding exempted portions,
`
`contains 2,841 words, which is less than the limit of 3,000 words set forth in the
`
`Order.
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`Dated: July 2, 2018
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`Respectfully submitted,
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`/s Robert T. Maldonado/
`Robert T. Maldonado (Reg. No. 38,232)
`Tonia A. Sayour (Reg. No. 58,404)
`Vishal J. Parikh (Reg. No. 73,935)
`Cooper & Dunham LLP
`30 Rockefeller Plaza
`New York, NY 10112
`Tel: (212) 278-0400
`Fax: (212) 391-0525
`
`Eric J. Maurer (Reg. No. 43,782)
`Boise, Schiller, & Flexner LLP
`1401 New York Ave, NW
`Washington, DC 20005
`Tel: (202) 274-1151
`emaurer@bsfllp.com
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`TELEBRANDS CORP.
`Petitioner,
`v.
`TINNUS ENTERPRISES, LLC.
`Patent Owner.
`____________
`PGR2017-00015
`
`U.S. Patent No. 9,527,612
`___________
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`CERTIFICATE OF SERVICE
`____________
`I hereby certify that the foregoing PETITIONER’S SUPPLEMENTAL REPLY
`BRIEF was served this 2nd day of July 2018 by email to Counsel for Tinnus at:
`rsterne@skgf.com
`jasone-ptab@skgf.com
`jtuminar-ptab@skgf.com
`dglenn-ptab@skgf.com
`tmerrell-ptab@skgf.com
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`Dated: July 2, 2018
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` /s Vishal J. Parikh/
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