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All rise.

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The United States Court of Appeals for the Federal Circuit is now open and in session.

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God save the United States and this honorable court.

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Thank you.

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Be seated.

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We have an admission this morning.

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Mr. Nelson, will you come forward?

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It's my great pleasure to move the admission of

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Michael Eric Nelson, who is a member of the Bar and in good standing with the highest courts of Virginia and the District of Columbia.

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I have knowledge of his credentials.

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I'm satisfied that he possesses the necessary qualifications.

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Sir Nelson has been my law clerk for a while, has performed admirably in that role.

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So it is my great pleasure to move his admission to the Bar of this court.

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And I invite Judge Wallach to ascertain

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if the vote of the panel.

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Chair Clevenger, I'll vote you.

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With great pleasure.

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I vote affirmatively on the motion.

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And I will at least concur.

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So the motion carries.

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The motion is granted.

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Will you approach the bailiff who will administer the oath?

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Please raise your right hand.

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Do you solemnly swear or affirm that you will comport yourself as an attorney and counsel of this court?

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Uprightly and according to law, that you will support the constitution of the United States of America.

[00:01:42] Speaker 00:
I do.

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Welcome to the bar of the United States Court of Appeals.

[00:01:44] Speaker 00:
Thank you very much, sir.

[00:01:47] Speaker 06:
Thank you.

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Welcome, Mike, to the bar of the court.

[00:01:50] Speaker 04:
Indeed, welcome.

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We shall proceed with the first argued case this morning, number 16.

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1954, in Ray Knowles Electronics, LLC, Mr. Rainey.

[00:02:08] Speaker 03:
Good morning, Your Honors, and may it please the Court.

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I'm Richard Rainey on behalf of Appellant Knowles.

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Your Honors, we submit that the Board reversibly erred in affirming the examiner's anticipation and obviousness rejections in this case.

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As to anticipation,

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Our position is the board erred in either not engaging on the critical issue with respect to the claim term package, that is, does a package require a mounting mechanism, and or concluding in a way we believe to find that the prior art met the claim limitation package, even though we would submit it's undisputed.

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It does not have any form of a mounting mechanism.

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It certainly is contemplated by this invention.

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As to obviousness,

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We would submit the board aired by substituting a mode of operation rationale for combining references that was nowhere found.

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Where does the patent disclose the type of interconnection used to electrically connect the package to an external circuit?

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So the patent discloses two types of mounting mechanisms, which perform the two functions.

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They mechanically hold.

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the device in place, fix it, and they also electrically connect it to the next level.

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In the background of the invention, the patent specifically talks about through-hole approach, a dip, for example, and talks about those being more difficult to manufacture.

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And in the embodiments, figures four and five in particular, which show the sort of finished product, show solder pads.

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One embodiment shows solder pads only on the bottom, which at the time of the invention was a well-known solder mount surface mount package.

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And the other embodiment shows solder pads on the top and on the bottom, which was also at the time of the invention a well-known approach to a surface mounting mechanism for a package.

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So in addition on this issue of package,

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This court actually addressed the same claim term in the Memstech decision.

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We think this is a somewhat unique situation because not only has the Federal Circuit spoken on what a package means in related patents, but it's also cited on the face of this particular patent.

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So Memstech is not only a persuasive decision by this court, it's actually intrinsic evidence.

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We would argue kind of like a super definition of what the term means.

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And in MEMSTEC, what we think is significant and why we think it relates so significantly to BRI, we recognize the standards are different.

[00:04:46] Speaker 04:
MEMSTEC construed package to require protection from the environment and first and second level interconnects.

[00:04:56] Speaker 04:
That's correct, but the court also went on to say... Either construction required that the package be connected to a printed circuit board.

[00:05:04] Speaker 03:
I'm sorry?

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Neither construction required that the package be connected to a printed circuit board.

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And we've not taken the position that a printed circuit board per se is required.

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I will say that as a practical matter, that's how these devices are connected to the next level.

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They typically go on to a PCB, but you're right.

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And we cited MEMSTEC for that very proposition, or the like, it says, this court said.

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But the court also went on to make clear that a mountable package

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was an important characteristic of Mr. Minervini's invention.

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It seems illogical to us and wrong for the board to say a BRI can ignore what this court has said is an important characteristic of an invention.

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So that goes to this issue of why we think having the components come together in a way that securely mounts them to the next level as well as electrically connecting them is so critical.

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In addition, we cited numerous extrinsic sources, which are fully consistent with the intrinsic two types of mounting mechanisms.

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All of those extrinsic sources, consistent with our understanding of what a package meant at or around the time of the invention, they talk about two ways of mounting a package, surface, mount, and through hole.

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There's nothing in those references that's in any way inconsistent with that, and the boards

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grasping on the phrase in general, we think, was wrong, particularly in light of the intrinsic evidence and in light of this court's Memstech decision.

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And then when you look at Haltern itself, it seems apparent to us and I think as a matter of law, you can conclude it has no mounting mechanism.

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Haltern is a very different kind of thing.

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It's an assembly which has a flexible material

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that is between the contact pads, which is where Halterin connects electronically to other things, and the part of Halterin where the microphone is placed.

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And in fact, to suggest that it's mounted, it seemed to me the best analogy I could come up with is if you were interested in, you know, if you bought a new flat screen TV and you hired an installer and you said to the installer, I'd like you to mount

[00:07:29] Speaker 03:
my flat screen TV on my wall in my family room and you came home and the installer had plugged it in and simply sat the TV against the wall and plugged it in, you would be very upset because your TV is not mounted on the wall simply because it's plugged in at the end of a flexible wire.

[00:07:46] Speaker 03:
Mounting of a TV requires a bracket to hold that TV in place up on the wall.

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So you don't have a mountable structure simply because you can flexibly plug or connect something in into the wall.

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So we would submit

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Haltern has no mounting mechanism.

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Nowhere did the board ever explain where a mounting mechanism is in Haltern.

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We would submit to you, frankly, the board's analysis on this is wholly inadequate.

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I was thinking if this court were to have the correctness or incorrectness of some invalidity contentions before it, nowhere does the board say here is the element in Haltern that we say satisfies this

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claim limitation.

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They simply say halter-in, our approach to package is broad enough to encompass halter-in.

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Well, why?

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There were some critical disputes before the board, and we would urge the court that the failure to engage on those at the very least requires vacancy.

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Let me just turn to the issue of obviousness.

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It seems apparent, if you look at the examiner's approach to obviousness in this case, that the examiner simply concluded that it would have been obvious to substitute the MEMS microphone of Halterin for the ECM microphone in UNE, if I'm pronouncing that correctly.

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This is an interesting conclusion in and of itself, given that, as the National Science papers, all the evidence we've pointed to Court 2 in the briefing and pointed to Board 2 below shows

[00:09:16] Speaker 03:
Packaging a MEMS microphone at or around this time was a major problem, a serious issue.

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So the examiner, rather than giving any explanation, just simply concluded it would have been obvious.

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On appeal for the first time, we now have the board substituting an analysis suggesting that the mode of operation of an ECM microphone is somehow similar to the mode of operation of a MEMS microphone.

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We would submit we never had an opportunity to respond to that below as a fundamental matter

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of this court's precedent at a bare minimum that should be remanded for us to address, it is factually a completely inaccurate conclusion.

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Yes, they are both microphones, but that is about where the analogy ends.

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Men's microphones are far more sophisticated in their operation than an ECM microphone, require additional circuitry and additional design considerations.

[00:10:09] Speaker 03:
And frankly, this

[00:10:13] Speaker 03:
new finding on appeal is exactly why this is such a prejudicial finding in our favor.

[00:10:18] Speaker 03:
We would ask that the court vacate the obviousness finding by the board and instruct the board to remand it for us to introduce evidence on that issue.

[00:10:29] Speaker 06:
Perhaps this is a question you're not prepared to answer, but what is your perception of why the result was different in the ITC and here?

[00:10:43] Speaker 03:
The only conclusion I can come to is that the board felt the BRI standard authorized it to basically ignore what this court had done in the Memstech decision.

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And for whatever reason, looked at the halter in reference and said, we think this meets the claims, although we're not going to really tell you why.

[00:11:06] Speaker 03:
That's the best explanation I have.

[00:11:08] Speaker 06:
I didn't see an answer either.

[00:11:10] Speaker 06:
That's why I asked you.

[00:11:13] Speaker 03:
If the court has no further questions, I'll reserve the remaining time I have for rebuttal.

[00:11:17] Speaker 06:
Thank you.

[00:11:24] Speaker 06:
OK.

[00:11:24] Speaker 06:
Thank you.

[00:11:25] Speaker 06:
Ms.

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Silverman.

[00:11:35] Speaker 05:
Thank you.

[00:11:35] Speaker 05:
Please, the court.

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I would like to start with the claim construction issue.

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Knowles is advocating a construction.

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Ms.

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Sylvan, who are you representing?

[00:11:47] Speaker 05:
The USPTO.

[00:11:49] Speaker 06:
So this is the tribunal has come in to defend its decision?

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That's right.

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Because the petitioner no longer is interested in the defense?

[00:12:02] Speaker 06:
That's right.

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On what basis does the tribunal take that position?

[00:12:07] Speaker 05:
The USPTO has under the statute the ability to

[00:12:12] Speaker 05:
to intervene in these cases.

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That's a broad interpretation of the statute, is it not?

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For a tribunal to defend itself when the other side no longer cares if it wins or loses?

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This court has routinely allowed the USPTO to come in and defend the decisions of the board on appeal.

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It would result in sort of a lopsided proceeding, I would think, if only one party were here.

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So you're not saying you're here in the public interest.

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You're here to defend the decision that's being appealed from.

[00:12:50] Speaker 06:
The tribunal is coming in to say you shouldn't reverse me?

[00:12:58] Speaker 05:
No, it's both.

[00:13:00] Speaker 05:
We believe it's in the public interest.

[00:13:02] Speaker 06:
On what basis are you representing the public interest?

[00:13:06] Speaker 05:
Representing the USPTO, which is

[00:13:09] Speaker 05:
here to represent the public interest.

[00:13:11] Speaker 05:
That's our job.

[00:13:13] Speaker 05:
That's the board's job as well.

[00:13:16] Speaker 06:
But we've held that entities representing the public interest, consumer watchdog, for instance, have no standing to come into court.

[00:13:26] Speaker 05:
That's true for non-governmental entities, yes, Your Honor.

[00:13:30] Speaker 05:
For the government, the analysis is different, I believe.

[00:13:35] Speaker 05:
particularly when the statute discusses the ability of the USPTO to come and defend the decision of the board below.

[00:13:45] Speaker 06:
Proceed with your argument, in any case.

[00:13:47] Speaker 06:
Thank you, Your Honor.

[00:13:50] Speaker 05:
On the claim construction issue, Knowles would like the term package to include not just housing and protection from external forces,

[00:14:04] Speaker 05:
and first and second level interconnects, but that the package must be connected to a printed circuit board via one of two methods, surface mounting or through-hole mounting.

[00:14:17] Speaker 04:
Well, when I asked your opposing counsel, he said, no, it didn't have to be a printed circuit board.

[00:14:23] Speaker 05:
Well, I suppose that's not how I read their brief.

[00:14:27] Speaker 05:
There was not one single construction advocated.

[00:14:32] Speaker 05:
But the way I read their brief was that it has to be mounted via through hole or surface mount.

[00:14:40] Speaker 05:
Perhaps it doesn't have to be to a printed circuit board.

[00:14:43] Speaker 05:
And we agree with that, that it does not have to be to a printed circuit board.

[00:14:46] Speaker 05:
But we also think that the- It has to be mounted to something.

[00:14:49] Speaker 05:
What's that?

[00:14:50] Speaker 04:
It has to be mounted to something.

[00:14:52] Speaker 05:
Not necessarily.

[00:14:53] Speaker 05:
So the construction that the board was operating under

[00:15:01] Speaker 05:
It has to connect to an external circuit in some way, yes.

[00:15:04] Speaker 05:
But it could do that through a socket or a connector or directly to another wire.

[00:15:11] Speaker 05:
Those are some examples that the expert discussed in this case and that the examiner discussed as well.

[00:15:19] Speaker 04:
But their position is it has to be mounted to something.

[00:15:23] Speaker 05:
That's true.

[00:15:24] Speaker 05:
That seems to be their position, yes.

[00:15:26] Speaker 05:
And as we explained in our brief, the claims

[00:15:30] Speaker 05:
the specification, this court's decision in MEMS technology, and the extrinsic evidence all support the construction that it need not be mounted to anything.

[00:15:43] Speaker 05:
It could be connected via some other methods.

[00:15:46] Speaker 05:
So the claims to start with, the broadest claim here is claim one, and it claims a package.

[00:15:54] Speaker 05:
Claim 15 is a dependent claim, which is narrower, and it adds

[00:15:59] Speaker 05:
an additional element such as a solder pad or other things that make it mountable, still not necessarily through hole or surface mount, but mountable.

[00:16:13] Speaker 05:
And that is the narrower of the claims.

[00:16:17] Speaker 05:
And then if you look at the 089 patent, which is one of the ones that was at issue in the MEMS technology decision, that claims an even narrower surface mountable package.

[00:16:28] Speaker 05:
So looking at the claims as a whole, package does not require either of those additional limitations.

[00:16:35] Speaker 06:
So are you saying that this court was wrong in its claim construction in MEMS tech?

[00:16:40] Speaker 05:
Oh, no.

[00:16:41] Speaker 05:
No, Your Honor.

[00:16:42] Speaker 05:
This court's construction in MEMS technologies was that one of its ordinary skill in the art would know that a package is a self-contained unit that has two levels of connection to the device and to a circuit or other system.

[00:16:56] Speaker 05:
So it's the same invention.

[00:16:58] Speaker 05:
It is.

[00:16:58] Speaker 05:
Well, it's a related patent, yes.

[00:17:02] Speaker 06:
Yes, for the same origin, the same specification.

[00:17:05] Speaker 05:
Yes.

[00:17:06] Speaker 05:
And so it said that it has to be to a circuit or other system.

[00:17:09] Speaker 05:
It does not say mounted.

[00:17:12] Speaker 05:
It doesn't say to a printed circuit board.

[00:17:14] Speaker 05:
It doesn't say via through hole or surface mount.

[00:17:17] Speaker 06:
I'm trying to understand why the results should be different.

[00:17:21] Speaker 05:
The results should be the same, Your Honor, that that claim construction of package is

[00:17:27] Speaker 05:
that it does not require a surface mount or through-hole mount.

[00:17:33] Speaker 06:
The same claims that you can't distinguish in one case on the same claim construction have been held valid and affirmed by this court and now have been held invalid by another tribunal, which is not here to defend itself.

[00:17:48] Speaker 05:
Well, those claims in MEMS technology, some of them actually

[00:17:55] Speaker 05:
claimed surface mountable package.

[00:17:58] Speaker 05:
And so in that case, yes, surface mountable package must be mountable to a printed circuit board by a surface mount.

[00:18:07] Speaker 05:
But package standing alone does not have to be.

[00:18:11] Speaker 05:
So there are different claims here than were at issue in MEMS technology.

[00:18:18] Speaker 05:
But the claim instruction that we are talking about is the same one that this court was

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operating on Invenus technology.

[00:18:30] Speaker 05:
And on top of that, the extrinsic evidence here also supports the claim construction.

[00:18:40] Speaker 05:
Dr. Peck, in his declaration, discussed the ability to connect packages at the time of the invention to sockets and connectors and directly to wire.

[00:18:52] Speaker 05:
That's at page 2903 of the joint appendix.

[00:18:56] Speaker 05:
And the examiner discussed that in his decision.

[00:18:59] Speaker 05:
And regardless, as we mentioned in our brief, halterin, under any of these constructions, halterin, nothing prevents someone from connecting halterin to a printed circuit board.

[00:19:16] Speaker 05:
So halterin is designed, as Mr. Rainey discussed, to connect to a connector.

[00:19:22] Speaker 05:
And certainly it can do that.

[00:19:24] Speaker 05:
But Dr. Tamala in the record here explained that halterin could also be soldered directly to a printed circuit board.

[00:19:40] Speaker 05:
And so even under the construction that requires mounting to a printed circuit board via through hole or surface mount, halterin could still be surface mounted to a printed circuit board.

[00:19:54] Speaker 05:
If I may move on to the method claims quickly, the examiner and the board both determined that the capacitor microphone could be replaced with halter and silicon capacitor microphone, and that it was a simple substitution of known components.

[00:20:24] Speaker 05:
The principle on which these capacitor microphones operate was well known.

[00:20:29] Speaker 05:
It is the way capacitors operate, which is that the distance between two plates reflects a voltage.

[00:20:38] Speaker 05:
And if that distance changes by the pressure of sound, then the voltage will change.

[00:20:44] Speaker 05:
And so the board explained the same principle, which is that

[00:20:50] Speaker 05:
This was a simple substitution of a silicon capacitor microphone for the existing capacitor microphone in UNEI.

[00:21:01] Speaker 05:
And the board added a little bit of discussion of that principle of the way a capacitor microphone works.

[00:21:08] Speaker 05:
But all of this was well known by the examiner as well as the board.

[00:21:13] Speaker 05:
And it was certainly not a new ground of rejection.

[00:21:18] Speaker 06:
Let me ask you the same question I asked Mr. Rainey.

[00:21:23] Speaker 06:
How do you explain the different results of these two tribunals?

[00:21:27] Speaker 05:
I don't think there are different results, Your Honor.

[00:21:29] Speaker 06:
In one case, the claims are valid.

[00:21:31] Speaker 06:
In another, they're invalid.

[00:21:33] Speaker 06:
Right.

[00:21:33] Speaker 06:
And they're different claims.

[00:21:35] Speaker 05:
There are different claims in the two different tribunals.

[00:21:38] Speaker 05:
So the construction that we are talking about is the same.

[00:21:43] Speaker 05:
as the ITC's construction and this court's construction in MEMS technology.

[00:21:49] Speaker 05:
The construction of the word package is the same.

[00:21:52] Speaker 05:
The result may be different because of the different claims at issue.

[00:21:57] Speaker 05:
But the claim term itself, as construed by all of the different tribunals, is the same.

[00:22:05] Speaker 01:
So the prior art that was found to be pertinent for a 102 analysis in this case was not pertinent in the other case because of the difference in the claims.

[00:22:14] Speaker 05:
I believe that's true.

[00:22:15] Speaker 05:
I don't know that for sure, Your Honor.

[00:22:18] Speaker 05:
I'd have to look back at the decision to know if this prior art was an issue.

[00:22:25] Speaker 06:
OK, any more questions?

[00:22:27] Speaker 06:
No questions?

[00:22:28] Speaker 06:
Thank you.

[00:22:29] Speaker 06:
Mr. Rainey?

[00:22:33] Speaker 03:
Briefly, Your Honors, the solicitor's concession that MEMSTEC is actually controlling in this case, we think, mandates a reversal.

[00:22:42] Speaker 03:
I would urge the court to look at the claims in the 231 patent, which does not have the phrase surface-meltable in the word package.

[00:22:51] Speaker 03:
It just has the phrase package.

[00:22:53] Speaker 03:
And in analyzing the claims of the 231 patent, this court said the requirement, I'm quoting from Appendix 3174, the requirement that the components listed in the claim body, which I would argue are essentially the same components at issue here.

[00:23:09] Speaker 03:
It's the same essential claim.

[00:23:12] Speaker 03:
The requirement that the components listed in the claim body come together to form a mountable package is thus an important characteristic of the claimed invention.

[00:23:21] Speaker 03:
Mountable package.

[00:23:23] Speaker 03:
That's exactly what this court held was the important characteristic of Mr. Minervini's invention.

[00:23:30] Speaker 03:
And this approach that we see, we saw it at the board, we're seeing it again here, of taking words out of context and arguing they're all the same is missing the point.

[00:23:41] Speaker 03:
We have advocated consistently that these claims require a mounting mechanism.

[00:23:46] Speaker 03:
Now, it is true that we were aware of two types of mounting mechanisms, through-hole and surface mount.

[00:23:54] Speaker 03:
But put those aside for a minute.

[00:23:57] Speaker 03:
If there's some other way of mounting it, fine.

[00:23:59] Speaker 03:
The issue, though, is there still has to be a mounting mechanism that does what those two mounting mechanisms do.

[00:24:07] Speaker 03:
Those are the only two disclosed in the intrinsic record.

[00:24:10] Speaker 03:
And we would argue all of the extrinsic evidence is to that point.

[00:24:14] Speaker 03:
Another point the solicitor made that I thought was kind of interesting is arguing that nothing prevents halterin from being modified in some way to mount it.

[00:24:23] Speaker 03:
That is, this is an anticipation rejection.

[00:24:25] Speaker 03:
This is not an obviousness rejection.

[00:24:28] Speaker 03:
We're not arguing about modifying halterin.

[00:24:31] Speaker 03:
We're arguing about what halterin teaches.

[00:24:33] Speaker 03:
And what the board pointed to, what the examiner pointed to, was the figure that we've reproduced in the patent, which shows a flexible substrate with connectors at one end, not connected to anything, and a microphone in a housing on the other end.

[00:24:48] Speaker 03:
That is not a mountable package under any approach we would submit.

[00:24:56] Speaker 03:
If the court has no further questions, that's all we have.

[00:24:58] Speaker 03:
We would advocate for reversal.

[00:25:00] Speaker 06:
Thank you, Mr. Ranney.

[00:25:02] Speaker 06:
Thank you both.

[00:25:03] Speaker 06:
The case is taken under submission.