[00:00:00] Speaker 04:
Our first case is Comcast Cable Communications versus Real Time Adaptive Streaming, 2020-22-81.

[00:00:09] Speaker 04:
Mr. Day.

[00:00:17] Speaker 02:
Good morning.

[00:00:20] Speaker 02:
All right.

[00:00:23] Speaker 02:
Good morning.

[00:00:25] Speaker 02:
And may it please the court.

[00:00:27] Speaker 02:
I'm James Day, representing Appellant Comcast.

[00:00:31] Speaker 02:
And we're here to discuss the decision of the PTAD.

[00:00:34] Speaker 02:
found an IPR proceeding where we challenged the 046 patent as obvious.

[00:00:40] Speaker 02:
And I think there are two basic topics we want to discuss today, two things to cover, two general areas.

[00:00:46] Speaker 02:
First, what theory did we actually advance before the PTAB?

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And did the board consider that theory?

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And the second,

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area to cover is motivation to combine.

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I'd like to start with the first.

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And I think the briefing here has really crystallized the issue about whether or not, down to whether or not the board actually considered the theory we advanced.

[00:01:09] Speaker 00:
And when you say theory, just so you can cover what I need to know, is this deal with the fact that you were just dealing with one reference code?

[00:01:20] Speaker 00:
Cowan-Hogan, Your Honor.

[00:01:22] Speaker 00:
Or the combination of that and the second reference?

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Is that what you say in terms of what your theory was?

[00:01:28] Speaker 02:
That's exactly right, Your Honor.

[00:01:29] Speaker 02:
So we presented a theory where you start with a my, which just closes this compression system.

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that sits on a server in a network like the internet, and it sends data out over the internet to a client computer sitting somewhere else.

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And our theory was you start with MI and you modify that based on this rate buffer that Kallenhoven is talking about.

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And so what you end up with is a MI with a rate buffer.

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Was MI mentioned in your petition?

[00:02:02] Speaker 04:
Your opposing council says it wasn't.

[00:02:05] Speaker 02:
Right, Your Honor.

[00:02:06] Speaker 02:
So what Realtime says is, in the section of our petition where we discuss one of the limitations.

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The limitation that's really in dispute in this case.

[00:02:16] Speaker 02:
Exactly.

[00:02:17] Speaker 00:
Limitation 1B, we just talked about cow and hobbit.

[00:02:20] Speaker 00:
And that's correct, is it not?

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That's a true statement.

[00:02:23] Speaker 00:
Yes.

[00:02:23] Speaker 00:
Yes.

[00:02:24] Speaker 00:
So how did you not forfeit it if, in discussing the limitation that's in dispute, you never included a reference other than cow help?

[00:02:36] Speaker 02:
So a couple of answers to that.

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First, if we start with the petition and look at the petition more broadly, it says round one, the one that challenges claim one, is based on Imai and Cowan-Hopin.

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And there's an introductory paragraph in the petition to the argument that says, explicitly, it would have been obvious to a person of ordinary skill in the art to start with a my and modify it based on the rate buffer teachings of Cowenhove.

[00:03:05] Speaker 00:
So the petition, that entire- Do you have the appendix site to that page that you're referring to in the description?

[00:03:13] Speaker 00:
Yes, sure.

[00:03:21] Speaker 02:
Yeah, that's at appendix 93.

[00:03:29] Speaker 02:
So Posita would have found it obvious to use Amai's teachings regarding multi-algorithm compression systems, et cetera, as a starting point and apply Kalinhoven's buffer feedback and throughput teachings to select the compressor.

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So the theory of ground one

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in general, is a combination.

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And so we get to limitation 1b, and the teaching of Kauenhofen is the most relevant thing, but only in the context of combining with a my.

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And there are other places in the petition that confirm this.

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When we get to limitation 1C, that limitation sort of refers back to what you did in step 1B.

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1B says you tracked the throughput.

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1C says you used that tracked throughput.

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And it explicitly says Kallenhoven in light of mine.

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So we didn't repeat that phrase for every limitation.

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But we think, at least implicitly, by beginning the entire discussion, by saying, here's the combination we're proposing, it should have been clear.

[00:04:36] Speaker 00:
But if you're the board, if you're just sitting on the board, and you've got several limitations that are in dispute, and you get to the portion of the petition at 105, which is dealing with 1B, which is the issue before us,

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Isn't the board doing its job by taking all of the arguments you make under 1B and disposing and dealing with those?

[00:05:01] Speaker 00:
And shouldn't it be able to assume that having done that, it's covered all its territory?

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And so given that you didn't refer to this other reference,

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any of your discussion labeled 1b limitation why isn't that I don't like the word forfeit but why isn't that a basis for which the board did not not do what it should by not dealing with an additional issue that was more general and generic

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Well, as I've said, Your Honor, we think the petition clearly sets out the theory.

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And so you would read each limitation in light of that theory.

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So that's part of the answer.

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But the other part is, in its institution decision, the board said, and the parties are invited to further develop their positions with regard to limitation 1B explicitly.

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And that's what happened.

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So they deposed our expert.

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He provided his testimony with regard to putting packets in a buffer, which is our theory, that if you use a my, you would be putting network packets into the buffer.

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Then Realtime filed its opposition brief, its patent owner's response, and focused only on Kallenhoven.

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So in our reply, we said, wait a minute, that's the wrong theory.

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You're misunderstanding our theory.

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And we pointed back to the petition.

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We didn't introduce any new evidence at that point.

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We just pointed back to our petition to the expert's declaration.

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In the expert declaration, paragraph 135, the expert had said, these are our requests.

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buffered data packets, so data packets of MI in the buffer, that's what we're tracking.

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And so we pointed back and said, look, your argument is irrelevant because that's not the theory we presented.

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So now by the reply, we've very clearly explained our position or changed it.

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I would say we very clearly explained our position by that point.

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And then again, at oral argument, we explained what the position was, which is stated in the petition in the introductory paragraph to the entire ground.

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So I think we clarified.

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Does any of the discussions that you've been engaged in up till now about Kangenhofen and MI bear on

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the board's conclusion that putting aside what one makes of packets, counting data requests is not met by seeing how full the buffer is?

[00:07:39] Speaker 02:
Yeah, so it answers that question.

[00:07:41] Speaker 02:
So what the board did and what Realtime did in its analysis is it said, look, in Kallenhoven, you've got this buffer, and it's going to fill up with data of variable different sizes.

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So you could have really small chunks.

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You could have big chunks.

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So when the buffer is half full, you don't know how many chunks of data you've got.

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It could be one really big one.

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It could be a lot of really small ones.

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But if you implement in My with a rate buffer, that rate buffer is going to fill up with data packets that go out over a network like the internet that are all the same size.

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So if you have a buffer that will hold 10 packets and you set a threshold at 50%,

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You know when you get there, you've got five packets because they're all the same size.

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And that's why this matters.

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That's why we clarified in our reply that that's the theory.

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But when we clarified, we didn't bring in new evidence.

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And I would say we did not bring in new arguments.

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We pointed back to the petition.

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We pointed back to our expert declaration.

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And we pointed to the expert testimony during deposition.

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All of that was provided before the patent owner's response.

[00:08:50] Speaker 04:
Now, you've argued that some of the claims that were rejected did not have the crucial tracking the number of pending requests limitation.

[00:08:59] Speaker 04:
But the board said they were similar.

[00:09:02] Speaker 02:
Right.

[00:09:02] Speaker 02:
And I think that that conclusion is just not supported by any evidence.

[00:09:08] Speaker 03:
Nor is the contrary argument supported by anything you said in your petition or, indeed, your reply to the board.

[00:09:16] Speaker 02:
I think the problem there is we didn't anticipate that the court would apply an argument that doesn't apply to claims like 11.

[00:09:24] Speaker 02:
So what happened is, in its opposition and its patent owner response, real time only talked about claim one.

[00:09:33] Speaker 02:
It didn't analyze for it.

[00:09:34] Speaker 03:
But you didn't say in your reply, if I remember right, just tell me if I'm wrong, that patent owner's response makes an argument applicable only to language in claim one.

[00:09:45] Speaker 03:
Such language does not appear in a bunch of the other claims.

[00:09:49] Speaker 03:
And for those, that argument wouldn't apply.

[00:09:52] Speaker 03:
I don't think that appears in your reply.

[00:09:54] Speaker 02:
We did not state the second part of that.

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We did say in our reply, and we quote this in our briefing, we did say real time only argues about limitation 1B and 1C, motivation to combine.

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And it effectively concedes that the prior art discloses all other limitations.

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And in our petition, we said claim 11B, one that doesn't have the language we're interested in, is a broader limitation.

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And so that's a different limitation.

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So what we did not do, and I agree, we did not take, they made a lot of arguments.

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We didn't take every one of their arguments

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and say, well, if you adopt this one, it only applies to these claims.

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And if you adopt that one, it applies to these other claims.

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And I don't think that was our burden.

[00:10:38] Speaker 00:
I think real time should have done it.

[00:10:41] Speaker 00:
Well, I'm looking at Red, page 24, and where it quotes the one paragraph, which it contends, and I don't think you dispute, is the entire showing with respect to 11b.

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And it's this one paragraph which starts, limitation 11b is included in 1b and obvious for the same reasons.

[00:11:02] Speaker 02:
That's right.

[00:11:03] Speaker 02:
I think our evidence for why it was obvious was the same.

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But in that paragraph, in that same paragraph, we said 11b is broader.

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So it's not the same.

[00:11:12] Speaker 00:
Scope well what you say is well 11b is broader and could be satisfied in other ways though You don't say that you say the 46 patent is clear that it can at least be satisfied By tracking a number of pending requests for data transmission.

[00:11:29] Speaker 00:
That's true, right?

[00:11:31] Speaker 02:
That's true so our position on why it was obvious in the first place was based on our same theory that you would take Cowenhoven and bake it into in my

[00:11:40] Speaker 02:
The problem with what the court did is it equated the scope of claims that are different.

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And it focused in on this language and said it's not in Kallenhoven.

[00:11:50] Speaker 02:
But that language is not in about half of the claims.

[00:11:53] Speaker 00:
Yeah, but you have to make the argument to the board.

[00:11:55] Speaker 00:
I mean, it's not like there's no limitation on data transmission.

[00:11:59] Speaker 00:
in the other claims.

[00:12:02] Speaker 00:
It's just that the wording is somewhat different.

[00:12:04] Speaker 00:
And somewhere, somebody did a good job in their brief of putting them side by side.

[00:12:09] Speaker 00:
So there is something you had to show with respect to 11b, even if you had differentiated the two, which you maybe did a little, maybe not.

[00:12:19] Speaker 00:
But you haven't given the board any basis for reaching a different conclusion on that limitation, right?

[00:12:24] Speaker 02:
Well, I think the problem here is the board focused in on language in 1B that just doesn't exist in 11B.

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And I don't think we anticipated the board would make a factual finding on a limitation that doesn't exist in some of the claims.

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Now, Realtime made other arguments that would have applied more broadly.

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And again, I concede we did not go through each of their arguments to say,

[00:12:49] Speaker 02:
which would apply to which claims.

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But what we said is they've only argued about one B and one C, and they effectively concede for others.

[00:12:59] Speaker 00:
The other problem- Did you actually say that?

[00:13:02] Speaker 02:
Yeah, in our reply, we say they, I don't remember the exact language, but they've essentially conceded that the prior art discloses the other claims or other limitations.

[00:13:13] Speaker 04:
Counsel, we're working on real time here, too, and it's moving fast.

[00:13:17] Speaker 04:
Yeah.

[00:13:18] Speaker 04:
So would you like to save your rebuttal time?

[00:13:21] Speaker 02:
Well, I'm already rebuttal time.

[00:13:23] Speaker 04:
I would, Your Honor.

[00:13:23] Speaker 04:
Thank you.

[00:13:25] Speaker 04:
Mr. Kroger, is it?

[00:13:27] Speaker 01:
Yes, correct, Your Honor.

[00:13:30] Speaker 01:
May it please the court, Paul Kroger for Appellee and Patent Owner Real-Time Adaptive Streaming.

[00:13:36] Speaker 01:
I think Mr. Day put it best when he said the question for this court is

[00:13:41] Speaker 01:
what's in the petition.

[00:13:42] Speaker 01:
Because if you actually look at the petition, the argument they're advancing now on appeal simply was not present.

[00:13:52] Speaker 01:
The entirety of the argument with respect to limitation 1B focused only on the text and teaching of Cowenhoven.

[00:13:59] Speaker 01:
And that's what the board rightly considered.

[00:14:01] Speaker 00:
But what about your friend's argument that at the beginning of the petition, it makes clear that the underlying everything we're about to say is this thing and the other reference?

[00:14:13] Speaker 01:
He is correct that they were arguing that in totality, we were looking at a combination of MI and Cowenhoven.

[00:14:20] Speaker 01:
But in terms of how that combination is actually applied, it's their burden to actually explain it and explain their theory.

[00:14:27] Speaker 01:
So for example, limitation 1A is based primarily on MI.

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Limitation 1B is based entirely on Cowenhoven.

[00:14:36] Speaker 01:
To the extent they were claiming

[00:14:38] Speaker 01:
The combination of Ima and Kauenhoven meant you had to modify Kauenhoven's teachings.

[00:14:44] Speaker 01:
That was their burden to explain in the petition.

[00:14:47] Speaker 01:
And they did not do that.

[00:14:49] Speaker 03:
Specifically for 1B.

[00:14:51] Speaker 01:
Correct.

[00:14:52] Speaker 01:
If you look at limitation 1B, and this is an appendix 105 to 108, the word MI simply does not appear.

[00:15:03] Speaker 01:
Similarly, if you look at the motivation to combine section of the petition, this is an appendix 94 to 99, where they explain their entire theory of combinations.

[00:15:14] Speaker 01:
They are talking only about taking the teachings of Cowenhoven and putting them into MI.

[00:15:19] Speaker 01:
They are never talking about using MI to modify Cowenhoven and use the data packets with Cowenhoven.

[00:15:27] Speaker 01:
That discussion doesn't occur.

[00:15:29] Speaker 01:
So for example, at appendix 94 to 95, they state, a posita would have been motivated to apply Cowenhoven's teachings to MI

[00:15:38] Speaker 01:
because MI suggests the rate of compression should be controlled, and Cowenhoven provides specific teachings for doing so.

[00:15:45] Speaker 01:
They say something similar to appendix 97 and 98.

[00:15:47] Speaker 01:
Again, their theory was you take Cowenhoven and you plug it into MI, and that was the theory the board answered.

[00:15:55] Speaker 01:
I think it's telling that in their blue brief on page 37, they contend the key teaching of MI about these data packets comes from paragraphs 51 and 66

[00:16:07] Speaker 01:
And the discussion, and this is a quote from their brief, of cutting the input signal into units of frame having predetermined lengths to go for a packet.

[00:16:17] Speaker 01:
And again, they claim that comes from paragraphs 51 and 66 of MI on page 37 of the blue brief.

[00:16:23] Speaker 01:
Those paragraphs of MI, paragraphs 51 and 66, are not referenced, cited, or discussed in the section of the petition about limitation 1B at all.

[00:16:35] Speaker 01:
Those paragraphs, paragraphs 51 and 66 of MI, are not discussed in the motivation to combine section of the petition.

[00:16:43] Speaker 01:
And moreover, they are not relied in the corresponding portions of their expert, Dr. Storer's, declaration.

[00:16:50] Speaker 01:
Simply put, this discussion about modifying Cowan-Hopin to use data packets is not in the petition.

[00:16:57] Speaker 01:
It's something they came up with later.

[00:16:59] Speaker 01:
It's not an argument that was fairly raised.

[00:17:01] Speaker 01:
It's not an argument the board had any reason or any obligation to consider.

[00:17:08] Speaker 01:
Turning briefly to the other argument, once again, Your Honor, we're here to analyze the arguments they raised in the petition, not the arguments that they could have raised.

[00:17:19] Speaker 03:
This is about the claims other than claim one?

[00:17:21] Speaker 01:
Correct.

[00:17:22] Speaker 01:
They were clear in their petition.

[00:17:25] Speaker 01:
So for example, on appendix 123, they say limitation 11b is included in 1b and is obvious for the same reasons.

[00:17:35] Speaker 01:
As Judge Prost noted on pages 24 and 25 of our brief, the red brief, we cite every place in the appendix where they make that same statement for every similar limitation.

[00:17:46] Speaker 00:
Well, except they say some stuff after that one sentence you quoted on 123.

[00:17:53] Speaker 01:
They do mention that it's broader, but they never explain why that matters, to the extent that they rely solely on their prior arguments.

[00:18:04] Speaker 01:
To the extent they had any basis for saying it's broader, but the SART disclosed it for this lesser reason, that's the part that's absent from the petition.

[00:18:12] Speaker 01:
I mean, if your honors were to remand this back to the board to consider solely these other limitations, there's nothing for the board to consider, because there's no lesser arguments presented in the petition about how these claim limitations are met based on anything other than their arguments on 1B.

[00:18:29] Speaker 01:
That's all they rely on.

[00:18:30] Speaker 00:
But the board didn't say anything about this at all, right?

[00:18:36] Speaker 00:
Maybe they did.

[00:18:38] Speaker 00:
Did they say anything about when they haven't made any, even though these other claims have different language, they haven't made any argument that's different for these claims?

[00:18:47] Speaker 01:
I believe the board simply deferred to their reliance on the same arguments in the final written decision.

[00:19:03] Speaker 01:
What they say, and this is Appendix 28, although these claims do not depend from Claim 1, they each require tracking the throughput of a data processing system similar to Claim 1.

[00:19:15] Speaker 01:
Therefore, for the same reasons, Petitioner fails to meet its burden with regards to Claim 1, and we determine Petitioner fails to meet the burden with regard to these specific claims.

[00:19:24] Speaker 00:
And nobody's challenged the correctness of that statement, because even in blue at 40, when they compare the two claims, what the board said about the claims is correct.

[00:19:36] Speaker 01:
That's correct.

[00:19:40] Speaker 01:
And unless any of you have any further questions, I'm happy to see the rest of my time.

[00:19:47] Speaker 04:
Thank you, counsel.

[00:19:49] Speaker 04:
We'll see you again in a little while.

[00:19:53] Speaker 04:
Mr. Jay will give you three minutes for a bottle if you need it.

[00:19:58] Speaker 00:
Can I just ask you a threshold housekeeping question, which is if hypothetically we were to agree with your friend on the first two arguments that you presented, the motivation to combine, which is your third argument, goes away.

[00:20:14] Speaker 02:
If you were to agree on the first two arguments, I think that's right.

[00:20:18] Speaker 02:
I think if you agree with us that you can't just look at Kallenhove and then both of those arguments go away.

[00:20:28] Speaker 02:
And also on motivation to combine, I also think, and I want to make sure that this gets out in response to what Council said, if we presented this combination that I'm suggesting,

[00:20:39] Speaker 02:
and then the board didn't consider it, then that necessarily skewed its view of our motivation to combine evidence.

[00:20:47] Speaker 02:
And so I think this all boils down to what theory do we present.

[00:20:53] Speaker 02:
And should the board have to consider the theory that I am suggesting we present it?

[00:20:59] Speaker 02:
And at one point, I want to make sure it gets out, is an IPR proceeding is not an, obviously, it's guided by the petition.

[00:21:09] Speaker 02:
That's right.

[00:21:09] Speaker 02:
The Supreme Court has told us that.

[00:21:11] Speaker 02:
But it's not an evaluation of how fulsome the petition is.

[00:21:15] Speaker 02:
It's an adversarial proceeding where the evidence and arguments are developed through a trial phase.

[00:21:21] Speaker 02:
And in our reply brief, we were very clear about our theory.

[00:21:25] Speaker 02:
And we only pointed back to arguments and evidence that either were in our petition, our expert's declaration submitted with the petition, and deposition testimony of our experts.

[00:21:38] Speaker 02:
So it's all original arguments, evidence, and then evidence through deposition before Pat and Ona responded.

[00:21:46] Speaker 02:
And the board never said that we were too late.

[00:21:49] Speaker 02:
It didn't say, we're not going to consider that because you're too late.

[00:21:52] Speaker 02:
It just didn't consider it.

[00:21:54] Speaker 02:
And that, I think, is your more recent decisions from this court.

[00:21:58] Speaker 02:
There's an ever star non-precedential decision from not too long ago.

[00:22:01] Speaker 02:
It says it's an abuse of discretion to not consider a reply that is just clarifying positions made in response to an argument.

[00:22:09] Speaker 02:
That's what happened here.

[00:22:11] Speaker 02:
We set out in our petition what we thought was a clear argument.

[00:22:15] Speaker 02:
Real time responded to it by saying, no, no, no, you only look at Kalinhoven.

[00:22:20] Speaker 02:
And we, in our reply, said, wait, you're misunderstanding, pointed back to our petition, our original evidence, and said, here's our theory.

[00:22:29] Speaker 02:
And I believe we're allowed to do that.

[00:22:32] Speaker 02:
And that's what happened.

[00:22:33] Speaker 02:
The board never said that we weren't allowed to do that.

[00:22:35] Speaker 02:
So there was never a debate about that.

[00:22:40] Speaker 02:
And so I think that was incorrect.

[00:22:43] Speaker 03:
And I also think that if- Can you remind me, did this come up at the oral argument?

[00:22:49] Speaker 02:
Which, the theory?

[00:22:52] Speaker 03:
Yes.

[00:22:53] Speaker 03:
This question of, yeah, about whether to get one B in particular, you are relying on MI plus time and not

[00:23:07] Speaker 03:
whether to get the entirety of the combination relying on the two, which is not true.

[00:23:11] Speaker 02:
Yes.

[00:23:11] Speaker 02:
It was addressed at oral argument.

[00:23:12] Speaker 02:
In our reply brief here, we cite appendix pages where it came up at oral argument.

[00:23:18] Speaker 02:
And we were consistently clear on that theory once real time questioned, frankly, what the theory was.

[00:23:27] Speaker 02:
My final thought?

[00:23:30] Speaker 02:
Thank you.

[00:23:31] Speaker 02:
The final thought is, we haven't talked about the motivation to combine.

[00:23:34] Speaker 02:
I do.

[00:23:36] Speaker 02:
I'm going to, in my 30 seconds, as I- No, you don't have 30 seconds.

[00:23:42] Speaker 02:
Oh, I'm sorry.

[00:23:42] Speaker 04:
In arrears in 30 seconds.

[00:23:43] Speaker 02:
I'm 30 seconds.

[00:23:44] Speaker 02:
In arrears.

[00:23:45] Speaker 02:
I'm sorry, Your Honor.

[00:23:46] Speaker 02:
Thank you very much for your indulgence today.

[00:23:48] Speaker 02:
I appreciate your time.

[00:23:49] Speaker 02:
Thank you.

[00:23:50] Speaker 02:
The case is submitted.