Apple Inc. v Rensselaer Polytechnic Institute and Dynamic Advances, LLCDownload PDFPatent Trial and Appeal BoardApr 15, 201409861860 (P.T.A.B. Apr. 15, 2014) Copy Citation Trials@uspto.gov Paper 12 571-272-7822 Entered: April 15, 2014 UNITED STATES PATENT AND TRADEMARK OFFICE ____________ BEFORE THE PATENT TRIAL AND APPEAL BOARD ____________ APPLE INC. Petitioner v. RENSSELAER POLYTECHNIC INSTITUTE and DYNAMIC ADVANCES, LLC Patent Owner Case IPR2014-00077 Patent 7,177,798 B2 Before JOSIAH C. COCKS, BRYAN F. MOORE, and MIRIAM L. QUINN, Administrative Patent Judges. MOORE, Administrative Patent Judge. DECISION Denying Institution of Inter Partes Review 37 C.F.R. § 42.108 Case IPR2014-00077 Patent 7,177,798 B2 2 INTRODUCTION Apple Inc. (“Petitioner”) filed a corrected petition requesting an inter partes review of claims 1-21 of U.S. Patent No. 7,177,798 B2 (Ex. 1001, “the ’798 patent”). Paper 4 (“Pet.”). In response, Rensselaer Polytechnic Institute and Dynamic Advances, LLC (“Patent Owner”) filed a patent owner preliminary response on January 30, 2014. Paper 11 (“Prelim. Resp.”). We have jurisdiction under 35 U.S.C. § 314. The standard for instituting an inter partes review is set forth in 35 U.S.C. § 314(a), which provides as follows: THRESHOLD—The Director may not authorize an inter partes review to be instituted unless the Director determines that the information presented in the petition filed under section 311 and any response filed under section 313 shows that there is a reasonable likelihood that the petitioner would prevail with respect to at least 1 of the claims challenged in the petition. For the reasons that follow, the Board does not institute an inter partes review. A. Related Proceedings Petitioner indicates that the ’798 patent is involved in co-pending litigation captioned Rensselaer Polytechnic Inst. & Dynamic Advances, LLC v. Apple Inc., No. 1:13-cv-00633-DNH-DEP (N.D.N.Y). Pet. 2. B. The ’798 Patent The ’798 patent is to natural language processing on computers, and more specifically, to computer-user interfaces that recognize natural language. Ex. 1001, col. 1, ll. 21-23. The invention is directed to technology that allows a user to communicate verbally with a computer in the same manner that he or she would communicate naturally with another Case IPR2014-00077 Patent 7,177,798 B2 3 person, i.e., through a natural language interface (“NLI”). Id. at col. 6, ll. 35-39. The system processes a user’s natural language input by identifying database objects through a search of the properly structured metadata database. Id. at col. 7, ll. 57-63. The metadata database that is searched to interpret the user’s input has four types of information as the resources-of- search—case information, keywords, information models, and database values. Id. at col. 8, ll. 50-57. C. Illustrative Claim Of the challenged claims, claims 1 and 9 are independent claims. Claim 1 is exemplary of the claimed subject matter of the ’798 patent, and is reproduced as follows: 1. A method for processing a natural language input provided by a user, the method comprising: providing a natural language query input by the user; performing, based on the input, without augmentation, a search of one or more language-based databases including at least one metadata database comprising at least one of a group of information types comprising: case information; keywords; information models; and database values; providing, through a user interface, a result of the search to the user; identifying, for the one or more language-based databases, a finite number of database objects; and determining a plurality of combinations of the finite number of database objects. Case IPR2014-00077 Patent 7,177,798 B2 4 D. Prior Art Relied Upon Petitioner relies upon the following prior art references: Shwartz US 5,197,005 Mar. 23, 1993 (Ex. 1007) Warthen US 6,584,464 B1 June 24, 2003 (Ex. 1011) Jürgen M. Janas, The Semantics-Based Natural Language Interface to Relational Databases, in COOPERATIVE INTERFACES TO INFORMATION SYSTEMS 143 (L. Bolc & M. Jarke eds., 1986) (Ex. 1008). Beatrice Bouchou & Denis Maurel, Using Transducers in Natural Language Database Query, PROC. 4TH INT’L CONF. NLDB (1999) (Ex. 1009). Shaul Dar et al., DTL’s DataSpot: Database Exploration Using Plain Language, PROC. 24TH VLDB CONF. 645 (1998) (Ex. 1010). David L. Waltz, An English Language Question Answering System for a Large Relational Database, 21 COMM. ACM 526 (1978) (Ex. 1012). E. The Asserted Grounds Petitioner asserts that the challenged claims are unpatentable based on the following grounds: Reference(s) Basis Claims challenged Shwartz § 102 1-21 Janas § 102 1-11, 13, 15, 16, and 18-21 Bouchou § 102 1-6, 8-12, 14-16, 20, and 21 Dar § 102 9, 10, and 13-16 Warthen § 102 1-11 and 13-21 Janas and ordinary skill in the art § 103 12 and 14 Janas and Waltz § 103 17 Warthen and ordinary skill in the art § 103 12 Warthen and Waltz § 103 17 Bouchou and Waltz § 103 17 Dar and ordinary skill in the art § 103 11 and 12 Dar and Waltz § 103 17 Case IPR2014-00077 Patent 7,177,798 B2 5 ANALYSIS A. Claim Construction In an inter partes review, claim terms in an unexpired patent are given their broadest reasonable construction in light of the specification of the patent in which they appear. 37 C.F.R. § 42.100(b). Under the broadest reasonable construction standard, claim terms are given their ordinary and customary meaning, as would be understood by one of ordinary skill in the art in the context of the entire disclosure. In re Translogic Tech., Inc., 504 F.3d 1249, 1257 (Fed. Cir. 2007). Any special definition for a claim term must be set forth with reasonable clarity, deliberateness, and precision. In re Paulsen, 30 F.3d 1475, 1480 (Fed. Cir. 1994). The following claim construction applies for purposes of this decision. 1. “case information” (claims 1-21) Petitioner argues that the phrase “case information” means “information about instances of use of the natural language processing method.” Pet. 6. Patent Owner argues that “‘case information’ refer[s] to the NLI’s information about prior instances of the NLI’s natural language processing that can be used to improve the processing of subsequent natural language inputs.” Prelim. Resp. 11. The specification discloses that case information is related to “usage patterns.” Ex. 1001, col. 5, ll. 36-38 (“The NLI could also retain valuable cases (usage patterns) so that the NLI could improve its performance.”). The specification also states that a case in the context of the invention generally includes a problem definition and a solution. The problem definition is generally a set of known terms and the solution is the user’s selection among possible choices for the meaning of the term. Id. at col. 16, Case IPR2014-00077 Patent 7,177,798 B2 6 l. 52 – col. 17, l. 5. Thus, Petitioner’s proposed construction of that phrase appears to be consistent with the specification. As applied to the prior art, however, Petitioner appears to construe “instances of use” of the system to mean indications of how to use the system, e.g., how the system interprets words or phrases. On the contrary, we agree with Patent Owner that a “case” is a prior use of the system, not a rule regarding how the system interprets current word or phrase input. Additionally, we agree with Patent Owner that the prior uses must be uses of the system contemplated by the invention, not uses of any other natural language processing system. On the record before us, we construe “case information” to mean “information about prior instances of use of the natural language processing method.” 2. “metadata database comprising at least one of a group of information types comprising: case information; keywords; information models; and database values” (claims 1-8); and “metadata database comprising at least one of a group of information comprising case information, keywords, information models, and database values” (claims 9-21) Petitioner argues that “[t]he clause ‘at least one of’ followed by a list of elements . . . requires the listed elements in the alternative—to disclose the claim limitation, a prior art reference needs only describe one of the elements in the list.” Pet. 7. Although not explicitly argued in the petition, Petitioner’s declarant, Dr. Allen, explains that “where claim 1 of the ’798 patent recites ‘at least one of a group of information types comprising: case information; keywords; information models; and database values,’ a prior art reference that discloses all other claim limitations but only discloses ‘case information’ or only ‘keywords’ anticipates the claim.” Ex. 1005 ¶ 62. Case IPR2014-00077 Patent 7,177,798 B2 7 Patent Owner argues the limitation at issue means “the referenced metadata database comprises one or more groups of information types, and at least one of the groups in the metadata database must contain at least the following four information types: case information, keywords, information models, and database values.” Prelim. Resp. 18. The specification discloses that “there are four layers of enterprise metadata (resources of search) considered; i.e., cases, keywords, information models, and database values.” Ex. 1001, col. 8, ll. 51-54. Further, “[t]he new approach includes designing a reference dictionary of concepts that integrates enterprise information models and contextual knowledge with user-oriented keywords and past cases of usage . . . .” Id. at col. 12, ll. 22- 28. Finally, “[a] reference dictionary according to one embodiment of the invention has four fundamental attributes, as compared to conventional systems: the reference dictionary . . . generates . . . [a] representation of all four layers of resources.” Id. at col. 14, ll. 30-34. Thus, Patent Owner’s proposed construction of that phrase is more consistent with the specification than Petitioner’s proposed construction. Additionally, the Federal Circuit, when faced with similar claim language, determined that the phrase “at least one” followed by a list of categories separated by “and” rather than “or” suggests a conjunctive list in which each one of the members of the list is necessary to satisfy the claim. SuperGuide Corp. v. DirecTV Enters., Inc., 358 F.3d 870, 885-86 (Fed. Cir. 2004) (“A common treatise on grammar teaches that ‘an article of a preposition applying to all the members of the series must either be used only before the first term or else be repeated before each term.’”) (quoting WILLIAM STRUNK, JR. & E.B. WHITE, THE ELEMENTS OF STYLE 27 (4th ed. Case IPR2014-00077 Patent 7,177,798 B2 8 2000)). On the record before us, consistent with the plain English meaning and the specification, we construe “metadata database comprising at least one of a group of information [or information types] comprising: case information; keywords; information models; and database values” to require that each of the listed information types must be present in a prior art metadata database to meet that claim limitation. 3. remaining claim terms All remaining claim terms recited in claims 1-21 need not be construed explicitly at this time.. B. Claims 1-21 – Anticipated by Shwartz (Ex. 1007) Petitioner argues that claims 1-21 are unpatentable under 35 U.S.C. § 102(b) over Shwartz. Pet. 2. Shwartz describes a database retrieval system having an NLI. Ex. 1007, Abstract. Shwartz is built around a Knowledge Base (or reference dictionary) with information about structuring and using data that would enable the system, in an efficient and economical manner, to retrieve and report data from a database responsive to an unskilled user’s query articulated in conversational English (in a way that a native speaker could understand and use sensibly). Id. at col. 1, l. 62 – col. 3, l. 15; col. 3, l. 40 – col. 4, l. 3. Claim 1 recites “at least one metadata database comprising at least one of a group of information types comprising: case information; keywords; information models; and database values.” Claim 9 recites essentially the same limitation. Our construction of these limitations requires that the Knowledge Base of Shwartz contain, at least, “case information” to meet these limitations. As noted above, our construction of Case IPR2014-00077 Patent 7,177,798 B2 9 “case information” is “information about prior instances of use of the natural language processing method.” Petitioner asserts that Shwartz’s system meets the limitation calling for case information by including “rules” in its Knowledge Base. Pet. 15. Specifically, Shwartz recites “[t]he semantic knowledge base contains dictionary information used by the language processing facility, and conceptual information about application databases. This knowledge base includes . . . rules (including data class-to-table rules and word-to-data class rules).” Id. (quoting Ex. 1007, col. 10, ll. 27-38). Petitioner’s declarant, Dr. Allen, explains that “word-to-data class rules allow the Query System to handle particular input cases by identifying the appropriate corresponding data groups or data categories,” and that “[d]ata class-to-table rules allow the Query System to handle particular input cases by specifying which of several columns referred to by a particular data class should be used.” Ex. 1005 ¶ 115. Nonetheless, Petitioner has not explained how the use of rules to handle a current particular user input relates to storing prior instances of using the natural language processing method of Shwartz in the Knowledge Base. It is the rules themselves that Shwartz stores in the Knowledge Base. Petitioner did not explain how the rules represent or incorporate prior uses of the natural language processing method of Shwartz. Thus, on the record before us, Petitioner has not shown sufficiently that Shwartz discloses “at least one metadata database comprising at least one of a group of information types comprising: case information; keywords; information models; and database values” as required by claims 1 and 9. Upon review of Petitioner’s analysis and supporting evidence and Patent Owner’s preliminary response, we determine that Petitioner has not Case IPR2014-00077 Patent 7,177,798 B2 10 demonstrated that there is a reasonable likelihood that it would prevail with respect to claims 1 and 9, or claims 2-8 and 10-21, which depend ultimately from claims 1 and 9, on the ground that these claims are unpatentable over Shwartz. C. Claims 1-11, 13, 15, 16, and 18-21 – Anticipated by Janas (Ex. 1008) Petitioner argues that claims 1-11, 13, 15, 16, and 18-21 are unpatentable under 35 U.S.C. § 102(b) over Janas. Pet. 3. Janas describes a system to evaluate a natural language input by following a sequence of steps to translate the query into an equivalent query graph by making reference to a vocabulary (reference dictionary) and a database graph of the database to be accessed. Ultimately, the system translates a query graph representing the optimal interpretation of the user’s query into a formal query language for execution. Ex. 1008, pp. 5-6, 9-12, 14. Claim 1 recites “at least one metadata database comprising at least one of a group of information types comprising: case information; keywords; information models; and database values.” Claim 9 recites essentially the same limitation. Our construction of these limitations requires that the vocabulary of Janas contain, at least, “case information” to meet these limitations. As noted above, our construction of “case information” is “information about prior instances of use of the natural language processing method.” Petitioner asserts that Janas’s system meets the limitation calling for case information by including “natural language words and phrases” in its vocabulary. Pet. 25. Specifically, Janas recites, “[a]s a result of compiling the designations of relations, attributes and values we obtain a vocabulary of natural language words and phrases which refer to the constituents of the Case IPR2014-00077 Patent 7,177,798 B2 11 database.” Id. (quoting Ex. 1008, p. 9). Designations are words used to refer to the relations, attributes, and values in a database. Ex. 1005 ¶ 170 (citing Ex. 1008, pp. 7-8). We note, however, that Petitioner has not explained how storing words representing relations, attributes, and values relates to storing prior instances of using the natural language processing method of Janas in the reference dictionary. In that regard, Petitioner has not explained how the designations represent or incorporate prior uses of the natural language processing method of Janas. Thus, on the record before us, Petitioner has not shown sufficiently that Janas discloses “at least one metadata database comprising at least one of a group of information types comprising: case information; keywords; information models; and database values” as required by claims 1 and 9. Upon review of Petitioner’s analysis and supporting evidence, we determine that Petitioner has not demonstrated that there is a reasonable likelihood that it would prevail with respect to claims 1 and 9, or claims 2-8, 10, 11, 13, 15, 16, and 18-21, which depend ultimately from claims 1 and 9, on the ground that these claims are unpatentable over Janas. D. Claims 1-6, 8-12, 14-16, 20, and 21 – Anticipated by Bouchou (Ex. 1009) Petitioner argues that claims 1-6, 8-12, 14-16, 20, and 21 are unpatentable under 35 U.S.C. § 102(a) over Bouchou. Pet. 3. Bouchou describes a natural language database querying system that is based on an electronic reference dictionary built with information from the database itself (fields, tables, etc.), the contents of the database, and dictionaries of synonyms. Ex. 1009, p. 11. A database administrator guides the construction of this electronic dictionary by choosing natural language words that represent each table or field in the database, adding synonyms for Case IPR2014-00077 Patent 7,177,798 B2 12 the words in the lexicon, and providing alternate forms of the nouns (e.g., singular/plural) and verbs (e.g., conjugations) in the lexicon. Id. Claim 1 recites “at least one metadata database comprising at least one of a group of information types comprising: case information; keywords; information models; and database values.” Claim 9 recites essentially the same limitation. Our construction of these limitations requires that the electronic dictionary of Bouchou contain, at least, “case information” to meet these limitations. As noted above, our construction of “case information” is “information about prior instances of use of the natural language processing method.” Petitioner asserts that Bouchou’s system meets the limitation calling for case information by including linguistic knowledge of operators in its lexicon. Pet. 34. Specifically, Bouchou recites, “[t]he electronic dictionary is built starting from 4 sources: . . . linguistic knowledge of general operators on the one hand, and operators related to the domain on the other hand.” Id. (quoting Ex. 1009, p. 11). Petitioner’s declarant, Dr. Allen, explains that “[t]ransducers 2 and 3 of the cascade of transducers store system knowledge of these linguistic operators.” Ex. 1005 ¶ 216 (citing Ex. 1009, pp. 11-12, 15). Nonetheless, Petitioner has not explained how the knowledge of operators or the use of transducers relates to storing prior instances of using the natural language processing method of Bouchou in the electronic dictionary. The knowledge of operators is not characterized as a prior use of the natural language processing method of Bouchou. Petitioner has not explained how transducers represent or incorporate prior uses of the natural language processing method of Bouchou. Thus, on the record before us, Petitioner has not shown sufficiently that Bouchou discloses “at least one Case IPR2014-00077 Patent 7,177,798 B2 13 metadata database comprising at least one of a group of information types comprising: case information; keywords; information models; and database values” as required by claims 1 and 9. Upon review of Petitioner’s analysis and supporting evidence, we determine that Petitioner has not demonstrated that there is a reasonable likelihood that it would prevail with respect to claims 1 and 9, or claims 2-6, 8, 10-12, 14-16, 20, and 21, which depend ultimately from claims 1 and 9, on the ground that these claims are unpatentable over Bouchou. E. Claims 9, 10, and 13-16 – Anticipated by Dar (Ex. 1010) Petitioner argues that claims 9, 10, and 13-16 are unpatentable under 35 U.S.C. § 102(b) over Dar. Pet. 3. Dar describes a database publishing tool designed to provide a means for exploring databases of business information. Ex. 1010, p. 645. Dar’s system discloses a data structure called a “hyperbase” that represents data as a graph of associated elements tailored to support free-form query algorithms. Nodes in the hyperbase represent data objects, and edges represent associations between data objects. Id. at 645-46. To perform a search, first Dar finds in the hyperbase the records that are related to the words in the user natural language query through relational and linguistic associations. Heuristics are applied that select “distinguished answer node[s],” and a list of answers are presented to the user. Id. at 647. Claim 9 recites “a metadata database comprising at least one of a group of information comprising case information, keywords, information models, and database values.” Our construction of these limitations requires that the hyperbase of Dar contain, at least, “case information” to meet these limitations. As noted above, our construction of “case information” is Case IPR2014-00077 Patent 7,177,798 B2 14 “information about prior instances of use of the natural language processing method.” Petitioner asserts that Dar’s system meets the limitation calling for case information by including linguistics and user-defined associations in its hyperbase. Pet. 15. Specifically, Dar allows for “built-in associations, such as concepts, numbers and dates, and allows for user-defined associations (e.g. geographical information)” and that “linguistic associations may also include related words and concepts associated via a thesaurus.” Ex. 1010, p. 647. Petitioner has not explained how the use of a thesaurus and other “associations” relates to storing prior instances of using the natural language processing method of Dar in the hyperbase. Thus, on the record before us, Petitioner has not shown sufficiently that Dar discloses “a metadata database comprising at least one of a group of information comprising case information, keywords, information models, and database values” as required by claim 9. Upon review of Petitioner’s analysis and supporting evidence, we determine that Petitioner has not demonstrated that there is a reasonable likelihood that it would prevail with respect to claim 9, and also claims 10 and 13-16 that depend ultimately from claim 9, on the ground that these claims are unpatentable over Dar. F. Claims 1-11 and 13-21 – Anticipated by Warthen (Ex. 1011) Petitioner argues that claims 1-11 and 13-21 are unpatentable under 35 U.S.C. § 102(b) over Warthen. Pet. 3. Warthen describes a Web-based search engine system that responds to natural language queries. Ex. 1011, col. 1, ll. 33-51; col. 2, l. 55 – col. 3, l. 17. A query processor uses a dictionary and a semantic net snapshot (knowledge base) to process the Case IPR2014-00077 Patent 7,177,798 B2 15 natural language input to generate template questions in response to a user- entered question. Id. at col. 3, ll. 46-50; col. 2, ll. 3-11. Claim 1 recites “at least one metadata database comprising at least one of a group of information types comprising: case information; keywords; information models; and database values.” Claim 9 recites essentially the same limitation. Our construction of these limitations requires that the reference dictionary of Warthen contain, at least, “case information” to meet these limitations. As noted above, our construction of “case information” is “information about prior instances of use of the natural language processing method.” Petitioner asserts that Warthen’s system meets the limitation calling for case information by including “template questions” in its knowledge base. Pet. 46. Specifically, Warthen recites “QPE 30 is coupled to dictionary 34 and semantic net snapshot 40 and uses the information obtained from those sources to generate template questions in response to a user-entered question. Template questions are questions that are mapped to answers in question-answer mapping table 42.” Id. (quoting Ex. 1011, col. 3, ll. 46-50; col. 2, ll. 3-11). Petitioner’s declarant, Dr. Allen, explains “the question-answer mapping table in the knowledge base stores information used to map template questions to answers. Thus the mapping information and the knowledge base both represent instances of use of the natural language processing method (i.e., cases).” Ex. 1005 ¶ 312 (citation omitted). Nonetheless, Petitioner has not explained how the use of question- answer mapping to map template questions to answers relates to storing prior instances of using the natural language processing method of Warthen in the reference dictionary. The question-answer mapping itself is what is Case IPR2014-00077 Patent 7,177,798 B2 16 stored in the reference dictionary. Ex. 1011, col. 3, ll. 46-50; col. 2, ll. 3-11. Petitioner has not explained how the question-answer mapping represents or incorporates prior uses of the natural language processing method of Warthen. Thus, on the record before us, Petitioner has not shown sufficiently that Warthen discloses “at least one metadata database comprising at least one of a group of information types comprising: case information; keywords; information models; and database values” as required by claims 1 and 9. Upon review of Petitioner’s analysis and supporting evidence, we determine that Petitioner has not demonstrated that there is a reasonable likelihood that it would prevail with respect to claims 1 and 9, or claims 2-8, 10, 11, and 13-21, which depend ultimately from claims 1 and 9, on the ground that these claims are unpatentable over Warthen. G. Remaining Challenges Petitioner contends that claim 17 is unpatentable under 35 U.S.C. § 103(a) as obvious over a combination of Janas and Waltz. A patent claim is unpatentable under 35 U.S.C. § 103(a) if the differences between the claimed subject matter and the prior art are such that the subject matter as a whole would have been obvious at the time the invention was made to a person having ordinary skill in the art to which said subject matter pertains. KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 406 (2007). The question of obviousness is resolved on the basis of underlying factual determinations including: (1) the scope and content of the prior art; (2) any differences between the claimed subject matter and the prior art; (3) the level of skill in the art; and (4) where in evidence, so-called secondary considerations. Graham v. John Deere Co., 383 U.S. 1, 17-18 (1966). Case IPR2014-00077 Patent 7,177,798 B2 17 Based on the arguments and evidence presented by Petitioner, we are unpersuaded that it has established a reasonable likelihood that it would prevail on showing the unpatentability of claim 17 under 35 U.S.C. § 103 as obvious over Janas and Waltz. As discussed above in the context of the anticipation analysis with regard to Janas, Petitioner has not shown sufficiently that Janas discloses a metadata database that contains case information, as is required by each of independent claims 1 and 9. Petitioner’s obviousness argument assumes that Janas discloses that limitation. Pet. 54. Petitioner bears the burden of proof of showing that limitation for each independent claim. Petitioner’s remaining challenges are similarly based on one of the anticipation challenges above to meet the “case information” limitation required by claims 1 and 9. Pet. 54, 56-59. However, as shown above, none of the challenges relied on to meet claims 1 and 9 has shown sufficiently the required “case information.” Thus, upon review of Petitioner’s analysis and supporting evidence, we determine that Petitioner has not demonstrated that there is a reasonable likelihood that it would prevail with respect to: the ground that claims 12 and 14 are unpatentable over Janas and ordinary skill; the ground that claim 12 is unpatentable over Warthen and ordinary skill; the ground that claim 17 is unpatentable over Warthen and Waltz; the ground that claim 17 is unpatentable over Bouchou and Waltz; the ground that claims 11 and 12 are unpatentable over Dar and ordinary skill; and the ground that claim 17 is unpatentable over Dar and Waltz. Case IPR2014-00077 Patent 7,177,798 B2 18 CONCLUSION The information presented does not show that there is a reasonable likelihood that Petitioner would prevail at trial with respect to at least one claim of the ’798 patent, based on any ground presented in the petition. On this record, we deny the petition for inter partes review of claims 1-21. ORDER Accordingly, it is ORDERED that that the petition is denied as to all challenged claims, and no trial is instituted. Case IPR2014-00077 Patent 7,177,798 B2 19 For PETITIONER: Hector Ribera Jennifer Bush FENWICK & WEST LLP hribera@fenwick.com jbush@fenwick.com For PATENT OWNER: Tarek Fahmi FAHMI, SELLERS, EMBERT & DAVITZ tarek.fahmi@fseip.com Donald E. Tiller SKIERMONT PUCKETT LLP dynamic_team@skiermontpuckett.com Copy with citationCopy as parenthetical citation