U.S. Patent No. 8,311,522 ( NUNCHI )
Petitioners fail to meet their burden of showing a likelihood of success in proving that Miluzzo in view of Robarts renders the ’522 patent claims obvious.
1. Petitioners have not met their burden of showing a
reasonable likelihood that it will prevail in demonstrating
that either Miluzzo or Robarts disclose (1) “a memory
which stores social templates each social template
corresponding to a unique social signature comprising a
first sensor value range and a second sensor value range
other than the first sensor value range,” (2) “determines
which of the social signatures of the stored social templateshas a greatest correspondence with the created social signature through comparison of the first and second detected sensor values and the first and second sensorValue ranges of each stored social template,” and (3)“retrieves from the memory the determined one social template having the greatest correspondence and having the detected amount of light within the first sensor value range and the detected sound level within the second sensor value range”
Petitioners fail to offer any meaningful analysis as to why the combination of Miluzzo and Robarts would have been obvious to one of ordinary skill in the art at the time of the invention.
Based on the foregoing, Petitioners have failed to demonstrate a reasonable likelihood of success on the merits. Patent Owner therefore respectfully requests that the Petition for Inter Partes Review be denied in its entirety.
Respectfully submitted,
/Robert E. Purcell/
Robert E. Purcell
Registration No. 28,532
Counsel for Patent Owner
THE LAW OFFICE OF ROBERT E.
PURCELL, PLLC
211 West Jefferson Street
Suite 24
Syracuse, New York 13202
(315) 671-0710
