Masimo Corporation

Patent Trials and Appeals Board

Dec 2, 2020

IPR2020-01082 (P.T.A.B. Dec. 2, 2020)

Trials@uspto.gov Paper No. 14
571-272-7822 Date: December 2, 2020

UNITED STATES PATENT AND TRADEMARK OFFICE
____________

BEFORE THE PATENT TRIAL AND APPEAL BOARD
____________

SOTERA WIRELESS, INC.,
Petitioner,

v.

MASIMO CORPORATION,
Patent Owner.
____________

IPR2020-01082
Patent 10,255,994 B2
____________

Before GEORGE R. HOSKINS, JENNIFER MEYER CHAGNON, and
AMANDA F. WIEKER, Administrative Patent Judges.

WIEKER, Administrative Patent Judge.

DECISION
Denying Institution of Inter Partes Review
35 U.S.C. § 314

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I. INTRODUCTION
A. Background
Sotera Wireless, Inc. (“Petitioner”) filed a Petition requesting an inter
partes review of claims 1–8 (“challenged claims”) of U.S. Patent
No. 10,255,994 B2 (Ex. 1001, “the ’994 patent”). Paper 1 (“Pet.”). Masimo
Corporation (“Patent Owner”) filed a Preliminary Response. Paper 8
(“Prelim. Resp.”). With our authorization, Petitioner filed a Preliminary
Reply (Paper 12 (“Prelim. Reply”)) and Patent Owner filed a Preliminary
Sur-reply (Paper 13 (“Prelim. Sur-reply”)),1 both directed to Patent Owner’s
argument that we should exercise discretion to deny institution under
35 U.S.C. § 314(a) based on a parallel district court proceeding.2
We have authority to determine whether to institute an inter partes
review, under 35 U.S.C. § 314 and 37 C.F.R. § 42.4. An inter partes review
may not be instituted unless it is determined 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.”
35 U.S.C. § 314; see also 37 C.F.R § 42.4(a) (“The Board institutes the trial
on behalf of the Director.”).

1 The parties include arguments directed to the merits of the asserted
grounds in their papers. See Prelim. Reply 7; Prelim. Sur-reply 5–7. We do
not rely on these belated arguments in our determination below that
Petitioner has not presented a reasonable likelihood of success on the merits
(see infra Sections II.D–F).
2 Because we deny institution on the merits of Petitioner’s asserted grounds
of unpatentability, we need not address these arguments.
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For the reasons provided below, we determine that Petitioner has not
demonstrated a reasonable likelihood of prevailing in demonstrating the
unpatentability of any of the challenged claims. Accordingly, we do not
institute an inter partes review.
B. Related Proceedings
The parties identify the following matter pending in district court and
related to the ’994 patent: Masimo Corp. v. Sotera Wireless, Inc., Case 3:19-
cv-01100 (S.D. Cal.). Pet. 2–3; Paper 7, 1. Patent Owner also identifies the
following inter partes review proceedings involving patents asserted in the
parallel district court proceeding:
IPR2020-00912, challenging U.S. Patent No. 10,213,108;
IPR2020-00954, challenging U.S. Patent No. 9,788,735;
IPR2020-00967, challenging U.S. Patent No. RE47,244;
IPR2020-01015, challenging U.S. Patent No. 9,795,300;
IPR2020-01019, challenging U.S. Patent No. RE47,353;
IPR2020-01033, challenging U.S. Patent No. RE47,249;
IPR2020-01054, challenging U.S. Patent No. 9,872,623; and
IPR2020-01078, challenging U.S. Patent No. RE47,218.
Paper 7, 2.
Patent Owner further identifies various applications that claim priority
to, or share a priority claim with, the ’994 patent. Id. at 1–2.
C. The ’994 Patent
The ’994 patent is titled “Physiological Parameter Alarm Delay,” and
issued on April 9, 2019, from U.S. Patent Application No. 15/894,393, filed
February 12, 2018. Ex. 1001, codes (21), (22), (45), (54).
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The ’994 patent discloses a “system configured to reduce a frequency
of alarms from a physiological monitoring system” by “delay[ing] a
notification of [an] alarm condition until a predetermined alarm delay period
has elapsed.” Id. at code (57). The disclosed physiological monitoring
system includes a plurality of bedside patient monitoring devices, which
may include ECG sensors, acoustic sensors, or pulse oximeters, and which
communicate with clinicians and other end users over a shared network. Id.
at 8:17–58, Fig. 1 (system 100, bedside devices 110, sensors 102,
network 126). Each sensor includes a processing module that “generates
alarms in response to physiological parameters exceeding certain safe
thresholds.” Id. at 8:59–9:11, Fig. 1 (processing modules 104). More
specifically, an alarm condition exists when a parameter is detected to be
outside a predetermined range. Id. at 61:54–59. In such a circumstance,
“various actions can be taken. For example, the bedside medical monitor
can emit an audible or visual alarm.” Id. at 61:59–62. The ’994 patent also
explains that, “after the alarm condition has persisted for some set amount of
time (e.g., 5 sec.), the alarm condition can be displayed at, for example, a
central patient monitoring station” and, if the alarm condition continues even
longer, e.g., 10 seconds, a clinician can be notified directly through a pager
or other notification device. Id. at 61:62–62:3.
Among other features, the ’994 patent also discloses that a reporting
module can use collected patient monitoring data to “simulate the alarm
events that would have been detected had the patient monitoring devices . . .
used a different set of alarm criteria than those that were actually used,” and
can change the alarm criteria that are used thereafter based on the
simulation. Id. at 64:40–47; see also, e.g., id. at 65:8–66:61 (changing,
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e.g., an oxygen saturation alarm threshold from 94% to 92%), Fig. 31. The
’944 patent also discloses that simulations may be conducted to evaluate
changes to an alarm notification delay time between the detection of an
alarm condition and the transmittal of an alarm notification to a central
monitoring station or clinician. Id. at 71:11–26. For example, a simulation
might vary the delay time from 5 seconds to 7 seconds. Id. at 71:37–72:56.
In some cases, if the alarm condition is only transient in
nature, a relatively small lengthening of the alarm notification
delay time could result in the alarm condition ceasing before an
alarm notification event is generated. In this way, adjustment of
the alarm notification delay time can potentially safely reduce the
number of alarm notification events to which clinicians must
respond. This can in turn increase the effectiveness of patient
care by allowing clinicians to focus their time on attending to
alarm events that are non-transient.
Id. at 72:13–28. According to the ’994 patent, this ability to simulate new
alarm notification delay times, without actually implementing them on live
patients, is advantageous to hospitals. Id. at 72:34–43.
D. Illustrative Claims
Of the challenged claims, claims 1 and 5 are independent. Claims 1
and 5 are directed to a system and a method, respectively, and have similar
recitations. Claims 1 and 5 are illustrative and reproduced below, with
italics added to highlight the limitations on which our discussion centers.
1. A system configured to reduce a frequency of alarms
from a physiological monitoring system, the system comprising:
a physiological sensor configured to detect signals
representative of a physiological condition of a patient;
one or more processors configured to receive the detected
signals and determine a physiological parameter of the patient,
the one or more processors further configured to detect an alarm
condition for the physiological parameter and delay a notification
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of the alarm condition until the alarm condition persists for a
predetermined alarm notification delay time, wherein said one or
more processors are configured to provide a notification of the
alarm condition responsive to the alarm condition persisting
through the alarm notification delay time, the one or more
processors being associated with a care unit; and
a reporting module configured to simulate, using
measurements obtained from the care unit, different alarm
notification delay times to determine whether any of the different
alarm notification delay times would have resulted in an alarm
notification event, the alarm notification event for each different
alarm notification delay time indicating that an alarm condition
persisted for at least that alarm notification delay time, and to
provide an indicator of the effect of a change in alarm
notification delay time on frequency of alarm notification events;
wherein the indicator is indicative of a change in the alarm
notification delay time that is effective to reduce the frequency
of transient or false alarms and wherein the indicator is
configured to be used to program one or more physiological
monitoring systems with alarm notification delay times.
5. A method of reducing a frequency of alarms, the method
comprising:
collecting signals representative of a physiological
condition of a patient;
determining a physiological parameter of the patient;
detecting an alarm condition for the physiological
parameter;
delaying notification of the alarm condition until the alarm
condition persists for a predetermined alarm notification delay
time;
providing a notification of the alarm condition responsive
to the alarm condition persisting through the alarm notification
delay time;
simulating, using measurements obtained from a care
unit, different alarm notification delay times to determine
whether any of the different alarm notification delay times would
have resulted in an alarm notification event, the alarm
notification event for each different alarm notification delay time
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indicating that an alarm condition persisted for at least that alarm
notification delay time; and
providing an indicator of the effect of a change in alarm
notification delay time on frequency of alarm notification events;
wherein the indicator is indicative of a change in the alarm
notification delay time that is effective to reduce the frequency
of transient or false alarms and wherein the indicator is
configured to be used to program one or more physiological
monitoring systems with alarm notification delay times.
Ex. 1001, 75:35–76:9, 76:20–48 (emphases added).
E. Applied References
Petitioner relies upon the following references:
Lynn, U.S. Patent Application Publication No.
2008/0287756 A1, filed May 16, 2008, published Nov. 20,
2008 (Ex. 1010, “Lynn”);
Batchelder et al., U.S. Patent Application Publication No.
2009/0247851 A1, filed Mar. 24, 2009, published Oct. 1, 2009
(Ex. 1011, “Batchelder”);
Wang et al., U.S. Patent Application Publication No.
2009/0326340 A1, filed June 30, 2008, published Dec. 31, 2009
(Ex. 1012, “Wang”); and
A.T. Rheineck-Leyssius and C.J. Kalkman, Influence of
Pulse Oximeter Lower Alarm Limit on the Incidence of
Hypoxaemia in the Recovery Room, 79 British J. of Anaesthesia
460–464 (1997) (Ex. 1013, “Kalkman”).
Pet. 7–8. Petitioner submits the Declaration of George E. Yanulis
(Ex. 1003). Patent Owner does not submit declaratory evidence.
F. Asserted Grounds of Unpatentability
Petitioner challenges the patentability of claims 1–8 of the ’994 patent
based on the following grounds. Pet. 8.
Claims Challenged 35 U.S.C. § References/Basis
1–3, 5–7 103 Lynn, Kalkman
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Claims Challenged 35 U.S.C. § References/Basis
3, 4, 7, 8 103 Lynn, Kalkman, Wang
1–8 103 Wang, Batchelder, Kalkman
II. DISCUSSION
A. Claim Construction
For petitions filed on or after November 13, 2018, a claim shall be
construed using the same claim construction standard that would be used to
construe the claim in a civil action under 35 U.S.C. § 282(b), including
construing the claim in accordance with the ordinary and customary
meaning of such claim as understood by one of ordinary skill in the art and
the prosecution history pertaining to the patent. 37 C.F.R. § 42.100(b). The
Petition was filed June 11, 2020. Thus, we apply the claim construction
standard as set forth in Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir.
2005) (en banc).
Only those claim terms that are in controversy need to be construed,
and only to the extent necessary to resolve the controversy. Nidec Motor
Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed.
Cir. 2017).
Although the record reflects certain disputes regarding the claim
language, it is not necessary for us to resolve those disputes in order to
determine whether Petitioner has satisfied its burden of demonstrating a
reasonable likelihood of prevailing. See also Pet. 16–19 (construing the
claim terms “alarm condition” and “alarm notification delay time,” but
stating that the “Board need not construe these terms because the claims are
invalid under either [parties’ proposed] interpretation”); Prelim. Resp. 27–31
(agreeing that “the Board does not need to construe any claim terms for
purposes of deciding whether to institute the Petition,” but also arguing that
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Petitioner failed to identify corresponding structure for the purported means-
plus-function term, “reporting module”). Accordingly, we determine that no
claim term requires express construction for purposes of this Decision.
B. Principles of Law
A claim is unpatentable under 35 U.S.C. § 103 if “the differences
between the subject matter sought to be patented 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) objective evidence of non-
obviousness.3 Graham v. John Deere Co., 383 U.S. 1, 17–18 (1966). When
evaluating a combination of teachings, we must also “determine whether
there was an apparent reason to combine the known elements in the fashion
claimed by the patent at issue.” KSR, 550 U.S. at 418 (citing In re Kahn,
441 F.3d 977, 988 (Fed. Cir. 2006)). Whether a combination of prior art
elements would have produced a predictable result weighs in the ultimate
determination of obviousness. Id. at 416–417.
In an inter partes review, the petitioner must show with particularity
why each challenged claim is unpatentable. Harmonic Inc. v. Avid Tech.,
Inc., 815 F.3d 1356, 1363 (Fed. Cir. 2016); 37 C.F.R. § 42.104(b). The

3 Patent Owner has not presented objective evidence of non-obviousness.
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burden of persuasion never shifts to Patent Owner. Dynamic Drinkware,
LLC v. Nat’l Graphics, Inc., 800 F.3d 1375, 1378 (Fed. Cir. 2015).
We analyze the challenges presented in the Petition in accordance
with the above-stated principles.
C. Level of Ordinary Skill in the Art
Petitioner contends that a person of ordinary skill in the art “would
have been a person with at least a B.S. degree in electrical or biomedical
engineering or a related field with at least two years’ experience designing
patient monitoring systems,” wherein “[l]ess work experience may be
compensated by a higher level of education, such as a master’s degree, and
vice versa.” Pet. 15 (citing Ex. 1003 ¶¶ 41–43). Patent Owner does not
offer a position as to the level of ordinary skill in the art. See generally
Prelim. Resp.
For purposes of this Decision, we adopt Petitioner’s assessment,
which appears consistent with the level of skill reflected in the Specification
and asserted prior art.
D. Obviousness over Lynn and Kalkman
Petitioner contends that claims 1–3 and 5–7 of the ’994 patent are
unpatentable as obvious over the combined teachings of Lynn and Kalkman.
Pet. 29–50. Patent Owner disagrees. Prelim. Resp. 38–48.
1. Overview of Lynn (Ex. 1010)
Lynn is a U.S. Patent Application Publication titled “Pulse Oximetry
Relational Alarm System for Early Recognition of Instability and
Catastrophic Occurrences.” Ex. 1010, code (54).
Lynn discloses a relational alarm system for detecting patterns in
monitored physiological parameters. Id. ¶ 30. Lynn’s system includes a
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portable bedside monitor that includes a pulse oximeter. Id. The system
monitors oxygen saturation and pulse rate, and sounds an alarm if either
parameter falls below a threshold, e.g., if oxygen saturation falls below 85%
or if pulse rate falls below 50 beats per minute. Id. ¶ 31. Lynn discloses that
the system also monitors for “a relational output suggestive of an adverse
event,” which the ’994 describes as occurring when a “primary threshold is
not reached but a secondary threshold is reached,” e.g., when, within 45
seconds, the system detects a fall of 5% in oxygen saturation and a
concurrent fall of 8 beats per minute in heart rate, where both parameters fell
at or about the same time. Id. In such a case, the alarm sounds. Id.; see also
id. ¶ 32 (explaining that relational patterns can be customized and providing
an example “defined by a fall in oxygen saturation of X (say greater than or
equal to 8%) coupled with a rise in respiration rate of Y (say 50% or more)
lasting for at least Z (say 5–10 minutes)”).
Lynn also discloses an oximeter testing apparatus with a processor in
connection with a dynamic simulator, which interfaces with the probe of an
oximeter to be tested. Id. ¶¶ 33, 35. The processor is “programmed to
simulate the time series of arterial oxygen saturation and one or more
additional parameters, which are generated in association with the
occurrence of a precipitous apnea or respiratory arrest.” Id. ¶ 33. Lynn’s
processor begins the simulation of the respiratory arrest and “sets the clock
at the onset” of the simulation. Id. ¶ 34. When the oximeter detects the
respiratory arrest, it outputs an alarm and records the time of alarm
occurrence. Id. The difference in recorded time between the onset of the
simulated respiratory arrest and the onset of the alarm is termed “T-Arrest”
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and “is a single number used to provide evidence of the performance of the
oximeter as an early warning device.” Id. ¶ 35.
2. Overview of Kalkman (Ex. 1013)
Kalkman is an article published in the British Journal of Anaesthesia
titled “Influence of Pulse Oximeter Lower Alarm Limit on the Incidence of
Hypoxaemia in the Recovery Room.” Ex. 1013, 1.
Kalkman describes a study that investigated the effects of two
oximeter lower alarm limit (“LAL”) settings—85% oxygen saturation and
90% oxygen saturation—and the effect of introducing a time delay of 0 to
60 seconds between the onset of an alarm condition and the triggering of an
alarm, in the 90% LAL group. Id. at 1, 2 (delay). The study classified
alarms “as either true positive (generated by hypoxaemia) or false positive
(generated by artifact).” Id. at 2. The study concluded that the incidence of
hypoxaemia was greater in the 85% LAL group. Id. The study also
concluded that “[m]aintaining the LAL at 90% and instituting a 15 s[econd]
time delay before triggering the audible alarm is an equally effective
approach to reduce the frequency of alarms that might not hamper rapid
detection of hypoxaemia.” Id. at 4.
3. Analysis
Independent claim 1 recites, inter alia, “a reporting module
configured to simulate, using measurements obtained from the care unit,
different alarm notification delay times to determine whether any of the
different alarm notification delay times would have resulted in an alarm
notification event . . . .” Ex. 1001, 75:52–76:9. Independent claim 5
contains a similar recitation, but in method form and without “a reporting
module.” Id. at 76:32–48.
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Petitioner makes alternate contentions regarding these limitations, to
account for different claim constructions of “alarm notification delay time.”
i. Lynn
Pre-Alarm Delays
Petitioner’s first contention applies “to the extent [Patent Owner]
contends the simulation of ‘alarm notification delay times’ refers to
pre-alarm delays,” i.e., “the amount of time between when a physiological
parameter measurement exceeds an alarm threshold before an alarm
sounds.”4 Pet. 17, 38.
According to Petitioner, Lynn discloses a relational alarm system with
both pre-alarm delays and alarm notification delays, and an oximeter testing
apparatus that includes a processor in conjunction with a dynamic simulator.
Id. at 36–37. Petitioner contends that “Lynn teaches the processor ‘may be
programmed to simulate the time series of arterial oxygen saturation and one
or more additional parameters, which are generated in association with the
occurrence of a precipitous apnea or respiratory arrest as from functional
residual capacity.’” Id. According to Petitioner, “[w]hen the monitor being
tested determines the physiological value exceeds the alarm criteria and
sounds an alarm,” the simulation records the time of the alarm occurrence.
Id. Then, the “difference between the time of onset of the simulation of the
respiratory arrest and the onset of the alarm occurrence is calculated by the
processor and outputted as the ‘TA’ or ‘T-Arrest’ value (given in seconds).”

4 As noted in the Claim Construction section, we do not construe “alarm
notification delay times.” For sake of argument, we consider Petitioner’s
application of the prior art to the claim language under this presumed
construction of “alarm notification delay time” in claim 1.
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Id. (quoting Ex. 1010 ¶ 34). In light of this teaching, Petitioner contends
that an ordinarily skilled artisan “would understand Lynn to teach a
processor configured to conduct simulations, using measurements from the
care unit, that determine the delay time between the onset of a physiological
condition and triggering of the alarm and to provide an indication of such
delay (i.e., a ‘TA value’).” Id. at 38; see also id. at 49 (analysis of claim 5,
incorporating analysis of claim 1).
We are not persuaded by Petitioner’s contentions. As an initial
matter, the Petition does not identify what structure in Lynn is relied upon as
the “reporting module” of claim 1. The Petition fails to specify whether it
relies upon Lynn’s “relational alarm system,” Lynn’s “oximeter testing
apparatus,” or Lynn’s “processor in conjunction with a ‘dynamic simulator’”
to satisfy the recited “reporting module.” Pet. 36–37. Moreover, we
disagree with the testimony of Petitioner’s declarant, Dr. Yanulis, that this
claim limitation “is broadly directed to a result that is taught by the prior
art.” Ex. 1003 ¶ 101 (emphasis added).5 To the contrary, claim 1 recites a
system comprised of structures including “a reporting module.” It is
Petitioner’s burden to identify what element of the prior art it contends
anticipates or renders obvious this limitation. With respect to its contentions
regarding Lynn, Petitioner has failed to do so. See Pet. 36–37.6

5 In this proceeding, Petitioner did not allege that this limitation is written in
means-plus-function format, pursuant to 35 U.S.C. § 112 ¶ 6, despite having
taken that position in district court. See Prelim. Resp. 27–33.
6 Our conclusion regarding the “reporting module” applies equally to the
“notification delay” alternative. See infra § II.D.3.i.Notification Delays.
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Moreover, we are not persuaded that Lynn discloses “simulat[ing] . . .
different alarm notification delay times” as required by independent claims 1
and 5. Rather than simulating alarm notification delay times, Lynn discloses
simulating a respiratory arrest event in order to test the responsiveness of an
oximeter. Specifically, Lynn discloses oximeter testing apparatus 10, which
includes processor 12 and dynamic simulator 14. Ex. 1010 ¶ 33, Fig. 3.7
Lynn explains that the processor is programed to simulate “the occurrence of
a precipitous apnea or respiratory arrest,” e.g., to simulate a patient having
stopped breathing. Id. ¶¶ 33–34. “The processor sets the clock at the onset
of the simulated respiratory arrest,” and then identifies the time at which an
alarm sounds to indicate that the oximeter detected the simulated respiratory
arrest. Id. ¶ 34. This difference in time values, i.e., “[t]he time from the
onset of a standardized respiratory arrest simulation to the onset of the
alarm,” is identified as “T-Arrest” and “is a single number used to provide
evidence of the performance of the oximeter as an early warning device.”
Id. ¶ 35.
Plainly, simulating a respiratory arrest is not simulating different
alarm notification delay times. See Prelim. Resp. 40–43. To be sure, Lynn’s
T-Arrest number is calculated after the simulated respiratory arrest, and
provides an indication of the time it took the oximeter to recognize the
simulated respiratory arrest, i.e., the oximeter’s “delay” in recognizing the
simulated respiratory arrest. However, that is not what claims 1 and 5

7 In an apparent typographical error, the reference numbers appearing in
Figure 3 of Lynn include an additional zero as compared to the reference
numbers in the Specification, e.g., Figure 3 identifies the oximeter testing
apparatus as “100,” the processor as “120,” and the dynamic simulator as
“140.”
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require. See Ex. 1001, 75:52–76:9, 76:32–48. Similarly, Petitioner’s
contention that an ordinarily skilled artisan “would understand Lynn to teach
a processor configured to conduct simulations . . . that determine the delay
time” does not address the pertinent claim language of “simulat[ing]
different alarm notification delay times.” Pet. 38 (emphasis added); see also
Ex. 1003 ¶ 103 (testifying that Lynn performs “simulations of alarm criteria
. . . to determine the delay time”).
For this reason, we are not persuaded by Petitioner’s contentions.
Notification Delays
Petitioner’s second contention applies “[t]o the extent ‘alarm
notification delay times’ is properly construed to mean delaying notification
of an active bedside alarm to a remote location” as proposed by Petitioner,
i.e., “the elapsed time between alarm condition[8] and transmission of
notification.”9 Pet. 18, 38. According to Petitioner, “Lynn teaches that, in
an alternative configuration, the simulator can include a transmitter to
simulate the delay between onset of the alarm condition and transmission of
the alarm notification.” Id. Petitioner relies upon the following portion of
Lynn’s disclosure:
In some situations, the oximeter under test may also include a
transmitter, which transmits the oxygen saturation output back to
a central nursing station where the alarm will sound. Since such
transmissions also may include averaging intervals or long

8 Petitioner argues “‘alarm condition’ is a patient condition that satisfies all
alarm criteria resulting in a triggered alert,” e.g., “at the bedside monitor.”
Pet. 16.
9 Again, for sake of argument, we consider Petitioner’s application of the
prior art to the claim language under this presumed construction of “alarm
notification delay time” in claim 1.
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intervals (20 seconds) between sample transmissions, the effect
of this delay can also be determined by this system 100. The
system 100 can be used for spot (surprise) checks of the alarm
response times in a nursing ward where all of the factors: patient
physiologic delay, signal processing delay, transmission delay,
alarm output delay, personnel response delay, and the delay
associated with the time to reach the bedside (where the nurse
inputs the endpoint) are automatically included, providing a true
index of the effective hospital response to an actual alarm
indicative of a life threatening event.
Id. at 38–39 (quoting Ex. 1010 ¶ 38); see also id. at 49 (analysis of claim 5,
incorporating analysis of claim 1).
We are not persuaded that this disclosure satisfies the limitations of
claims 1 and 5 reciting, “simulat[ing] . . . different alarm notification delay
times.” At the cited passage, Lynn explains that the oximeter being tested
may include a transmitter for conveying measured oxygen saturation levels
to a central nursing station, where an alarm will sound after respiratory arrest
is detected by the oximeter. Ex. 1010 ¶ 38 (“[T]he oximeter under test may
also include a transmitter.”); see also id. ¶ 34. No portion of the cited
disclosure supports Petitioner’s statement that Lynn’s “simulator can include
a transmitter to simulate the delay.” Id. ¶ 38; Pet. 38 (emphasis added).
Moreover, the passage explains that some delay is innately involved
in the detection and transmission of oxygen saturation levels from the patient
to the oximeter to the nursing station, including “patient physiologic delay,
signal processing delay, transmission delay, alarm output delay, personnel
response delay, and the delay associated with the time to reach the bedside.”
Ex. 1010 ¶ 38. Neither Petitioner nor Dr. Yanulis explain, however, how
these innate delays associated with the capture of physiological parameters,
signal processing, transmission, alarm recognition, or personnel response
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relate to the claim requirement of simulating different alarm notification
delay times. Pet. 38–39. Instead, Lynn explains that the system can be used
for “spot (surprise) checks of the alarm response times in a nursing ward
where all of the[se] factors . . . are automatically included providing a true
index of the effective hospital response to an actual alarm indicative of a life
threatening event.” Ex. 1010 ¶ 103. Notably, no part of the cited disclosure
concerns simulating anything other than respiratory arrest.
For this reason, we are not persuaded by Petitioner’s contentions.
ii. Lynn and Kalkman
Next, Petitioner contends that a person of ordinary skill in the art
would have been motivated to modify Lynn in view of Kalkman. According
to Petitioner,
To the extent Lynn does not expressly inform a [person of
ordinary skill in the art] how to simulate pre-alarm delays and
alarm notification delays using measurements from a case unit,
or how to use those simulations to “provide an indicator of the
effect of a change on the alarm notification delay time on
frequency of alarm notification events; wherein the indicator is
indicative of a change in the alarm notification delay time that is
effective to reduce the frequency of transient or false alarms” and
to use the indicator to “program one or more physiological
monitoring systems with alarm notification delay times,” a
[person of ordinary skill in the art] would have been motivated
to modify Lynn . . . in view of Kalkman.
Pet. 39 (citing Ex. 1003 ¶ 104). Again, Petitioner makes different
contentions to account for different claim constructions.
Pre-Alarm Delays
Regarding “pre-alarm delays,” Petitioner contends that Kalkman
describes a study that “simulate[d] theoretical pre-alarm delays and
output[ted] a graph indicating the effect of the theoretical delays on the
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number of alarms generated, and in particular, [found] the optimal pre-alarm
delay to reduce transient and false alarms.” Pet. 39–40, 42 (introducing an
alarm delay “eliminates short-lasting alarms”). According to Petitioner,
Kalkman discloses that these simulations were performed using a “PC (i.e.,
‘a reporting module’).” Id. at 40–41.
In light of these teachings, Petitioner contends that a person of
ordinary skill in the art “would have been motivated to implement
Kalkman’s simulation method using real patient data to find the optimal ‘Z’
delay period for Lynn.” Id. at 42. Petitioner also asserts that such a person
“would have been motivated to modify the system of Lynn to use the
pre-alarm delay time simulation of Kalkman to achieve the predictable result
of optimizing pre-alarm delay times and reducing false and transient alarms
that can lead to ‘alarm fatigue’” and “to customize pre-alarm delay times for
different care units treating patients in different physiological conditions . . .
[which] would have predictably resulted in a system that considers and finds
an optimal pre-alarm delay for a particular subset of patients.” Id. at 42–44;
see also id. at 49 (analysis of claim 5, incorporating analysis of claim 1).
We are unpersuaded by Petitioner’s contentions. First, as above, the
Petition fails to identify clearly what structure is relied upon as the
“reporting module” of claim 1, in the proposed combination of Lynn and
Kalkman.10 Although the Petition refers to Kalkman’s PC as a “reporting
module,” see Pet. 40–41, Petitioner proposes modifying Lynn’s system to
incorporate Kalkman’s simulations of different alarm delay notification
times, and does not propose modifying Lynn to incorporate Kalkman’s PC.

10 Our reasoning regarding the “reporting module” applies equally to the
“notification delay” alternative. See infra § II.D.3.ii.Notification Delays.
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Id. at 42–43 (proposing to “modify the system of Lynn to use the pre-alarm
delay time simulation of Kalkman”), 43–44 (proposing to “use Kalkman’s
simulation”). As such, Petitioner fails to identify a “reporting module,” as
recited in claim 1, in the combination of prior art upon which Petitioner
relies.
Moreover, we are not persuaded that the combined teachings of Lynn
and Kalkman satisfy the limitations of claims 1 and 5 that require simulating
different alarm notification delay times. Petitioner contends that Lynn, like
Kalkman’s disclosure of simulating pre-alarm delays, “also describes a pulse
oximetry monitor that simulates pre-alarm delays and alarm notification
delay times.” Pet. 40. As discussed above, however, Lynn simulates
respiratory arrest, not alarm notification delay times. Ex. 1010 ¶¶ 33–35.
Thus, we agree with Patent Owner that Lynn and Kalkman are directed to
different concepts. Prelim. Resp. 45–46.
Moreover, Petitioner provides insufficient reasoning to show that a
skilled artisan would have been motivated to modify Lynn’s system to
implement Kalkman’s simulation. We agree with Patent Owner that such a
modification would render Lynn unsuitable for its intended purpose as an
oximeter testing apparatus. Prelim. Resp. 46–47. For example, Petitioner
does not explain how Lynn’s system would achieve its intended purpose of
testing the responsiveness of an oximeter if the system were modified to
simulate pre-alarm delay times instead of respiratory arrest. See, e.g.,
Pet. 43 (“[A] PHOSITA would have been motivated to modify the system of
Lynn to use the pre-alarm delay time simulation of Kalkman to achieve the
predictable result of optimizing pre-alarm delay times and reducing false and
transient alarms.”). Neither Petitioner nor Dr. Yanulis explain why a person
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of ordinary skill in the art would have been motivated to abandon Lynn’s
intended purpose as an oximeter testing apparatus, even if such a
combination would have resulted in the optimization of pre-alarm delay
times, as Petitioner contends. Pet. 42–44; Ex. 1003 ¶¶ 110–113. Petitioner
does not discuss this trade-off in functionality or intended purpose at all.
For these reasons, we are not persuaded by Petitioner’s contentions.
Notification Delays
Regarding notification delays, Petitioner contends that, if the phrase
“alarm notification delay times” is understood to mean “delaying
notification of an active alarm condition to a remote location, a [person of
ordinary skill in the art] would have been motivated to [further] modify the
teachings of Kalkman to include the simulation of such alarm notification
delays,” for similar reasons as discussed above regarding pre-alarm delays.
Pet. 44. According to Petitioner,
In both instances, the PC uses collected data to simulate the
length of a delay between two events—the time between when a
physiological value crosses a threshold and the time at which an
alert sounds (pre-alarm delays), or the time between the
activation of a bedside alarm and transmission of the alarm
notification to a remote location (alarm notification delays). The
implementation would likewise achieve predicable results—
namely reducing the number of transient/false alarms and alarm
notifications, respectively, to which a clinician must respond.
Both pre-alarm delays and alarm notification delays use time to
confirm an alarm condition before notifying a clinician (either
locally or remotely). Thus, Kalkman’s simulation would
similarly help find an optimal alarm notification delay time
before remotely notifying a clinician of an alarm, by simply
further considering whether alarms are locally addressed, as
taught by Lynn.
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Id. at 44–45 (citations omitted). Petitioner contends that a person of
ordinary skill in the art “would have been motivated to modify Lynn’s
system to use the same simulation method of Kalkman because Lynn already
compiles the data necessary to simulate the effect of alarm notification
delays”—e.g., transmission delay and alarm output delay (Ex. 1010 ¶ 38)—
“and it would be advantageous to implement custom alarm notification
delays because the staffing and physical layout of each care unit are unique.”
Id. at 45; see also id. at 49 (analysis of claim 5, incorporating analysis of
claim 1).
Petitioner’s contentions in this regard fail for the same reasons
discussed above regarding pre-alarm delays. Petitioner does not present
persuasive reasoning to show that a skilled artisan would have found it
obvious to modify Lynn’s system to simulate different alarm notification
delay times, instead of simulating respiratory arrest, where such a
modification would have rendered Lynn unsuitable for its intended purpose
as an oximeter testing apparatus.
For these reasons, we are not persuaded by Petitioner’s contentions.
4. Summary
For the foregoing reasons, Petitioner has not shown a reasonable
likelihood of prevailing with respect to independent claims 1 or 5.
Petitioner’s additional contentions regarding dependent claims 2, 3, 6, and 7
do not cure these deficiencies regarding claims 1 and 5, and fail for the same
reasons.
E. Obviousness over Lynn, Kalkman, and Wang
Each of claims 3, 4, 7, and 8 depend from either claim 1 or claim 5.
Regarding these claims, Petitioner additionally relies upon Wang. Pet. 51–
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52. For the same reasons discussed above, see supra § II.D.3, Petitioner has
not demonstrated a reasonable likelihood of prevailing with respect to
independent claims 1 or 5. Petitioner’s contentions regarding Wang do not
cure the deficiencies regarding claims 1 or 5. Accordingly, for the same
reasons, Petitioner has not shown a reasonable likelihood of prevailing with
respect to claims 3, 4, 7, and 8.
F. Obviousness over Wang, Batchelder, and Kalkman
Petitioner contends that claims 1–8 of the ’994 patent are unpatentable
as obvious over the combined teachings of Wang, Batchelder, and Kalkman.
Pet. 52–75. Patent Owner disagrees. Prelim. Resp. 36–37, 49–64.
1. Overview of Wang (Ex. 1012)
Wang is a U.S. Patent Application Publication titled “Patient Monitor
Alarm System and Method.” Ex. 1012, code (54).
Wang discloses a patient monitoring alarm escalation system that
generates alarms related to various monitored patient conditions. Id. ¶ 13,
Fig. 1. Wang explains that “[w]hen alarm conditions are detected, the
system 10 may emit alarm signals from any one of the monitors 12, the
central management system 16, and/or the alarm paging system [18].
Further, if the alarm is not acknowledged, the monitoring system 10 may
escalate the alarm.” Id. ¶ 15. As an example, Wang explains that upon
detecting an alarm condition the system will generate a primary alarm at the
patient bedside monitor and at the central management station. Id. If that
alarm is not acknowledged within a predefined amount of time, the system
will send a second alarm to a wireless device of the caregiver. Id.
Additionally, Wang explains that if “the second alarm remains
unacknowledged for a predefined amount of time (e.g., half of the time
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allotted to acknowledge the primary alarm), a third alarm may be sent to an
additional wireless device . . . and so forth.” Id.; see also id. at Fig. 4.
Wang discloses a pulse oximeter as an example of a patient monitor.
Id. ¶ 16, Fig. 2. Wang’s pulse oximeter provides alarms when monitored
parameters cross certain thresholds, which “may be designated by set points
or by designating patterns of values (e.g., patterns in an SpO[2] trend) or
limits that can be entered via adjustment buttons.” Id. ¶ 22. Wang also
discloses that, “in some embodiments, the alarm system employs SatSeconds
by Nellcor Puritan Bennett, incorporated, to detect alarms and manage
nuisance alarms. SatSeconds may include alarming based on an integral of
time and depth of a desaturation event.” Id.
2. Overview of Batchelder (Ex. 1011)
Batchelder is a U.S. Patent Application Publication titled “Graphical
User Interface for Alarm Management.” Ex. 1011, code (54).
Batchelder describes an alarm integration method that reduces
nuisance alarms on patient monitors. Id. ¶ 15. “An exemplary alarm
management system may be the SatSecondsTM alarm management
technology.” Id. Batchelder’s Figure 1 is reproduced below.

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Figure 1 “is a graph illustrating a patient’s measured SpO2 versus time.” Id.
¶ 9. Line 4 represents a threshold SpO2 value. Id. ¶ 15. “Rather than
sounding an alarm as soon as the patient’s measured SpO2 (plot 3) drops
below the threshold value (line 4), the SatSeconds system measures [] area 5
(shaded in FIG. 1) by integrating the difference between [] plot 3 and []
line 4 when [] plot 3 is below [] line 4.” Id. “[S]ignificant desaturation
event 6 (e.g., a large drop in SpO2) may cause the alarm to activate quickly
because the SatSeconds threshold value may be exceeded in [] short period
of time 7.” Id. “In contrast, [] minor desaturation event 8 . . . may not cause
the alarm to be activated quickly. That is, [] minor desaturation event 8 may
continue for [] relatively long period of time 9 before the SatSeconds
threshold value is exceeded.” Id.
Batchelder explains that, “[b]ecause the SatSeconds technology is
relatively new in the medical field, it may be desirable to assist the caregiver
in efficiently determining the desired SatSeconds threshold value.
Accordingly, a patient monitoring system in accordance with embodiments
of the present disclosure may include one or more user interfaces which
enable the caregiver to change the SatSeconds threshold value and/or the
SpO2 threshold value.” Id. ¶ 16. Batchelder describes a monitor device
including a display, a speaker, and user inputs. See id. ¶ 24. The user inputs
enable the caregiver to change the SpO2 and SatSeconds threshold values.
Id. ¶¶ 25, 26. “For example, [] SpO2 thresholds 112 may be adjusted in
increments of 1% while [] SatSeconds thresholds 114 may be adjusted in
increments of 25. A number of discreet values may be available for []
thresholds 112 and 114, or the value adjustment may be continuous.” Id.
¶ 28.
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Figures 5–8, reproduced below, illustrate how changes in SpO2 and
SatSeconds thresholds effect the alarm settings.

Figures 5–8 illustrate a graphical user interface of a pulse oximeter. Id. ¶ 12.
These figures depict, e.g., a change in SatSeconds threshold 114 from 25
(see Fig. 5) to 100 (see Figs. 6–7).11 Id. ¶ 30. Likewise, the figures depicts

11 Batchelder’s description of these figures in paragraphs 30–32 appears to
incorrectly describe the content of the figures. Compare, e.g., Ex. 1011 ¶ 30
(describing Figure 5 as showing an increased SatSeconds threshold 114 of
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a change in SpO2 threshold 112 from 85% (see Figs. 5–6) to 90% (see
Fig. 7–8). Id. ¶ 31. The figures depict changes in alarm indicator 122 and
shaded area 126 as SatSeconds threshold 114 and SpO2 threshold change.
For example, SatSeconds threshold 114 is reached earlier in Figure 7 than in
Figure 6, thereby activating the alarm earlier, as the SpO2 threshold
increases from 85% to 90%. Id. ¶ 31. Additionally, in Figure 8, SatSeconds
threshold 114 is set to 0, so that “the alarm will be activated as soon as []
SpO2 plot 118 falls below [] threshold line 120 as indicated at 122.” Id.
¶ 32.
3. Analysis
Again, we focus on the language of independent claim 1 that recites
“a reporting module configured to simulate, using measurements obtained
from the care unit, different alarm notification delay times . . .” (Ex. 1001,
75:52–76:9) and the similar method claim recitation of independent claim 5
(id. at 76:32–48 (but lacking a “a reporting module”)).
Petitioner again makes alternate contentions to account for different
claim constructions of “alarm notification delay time.”
Pre-Alarm Delays
Petitioner’s first contention applies to the construction of “alarm
notification delay times” as referring to “pre-alarm delays,” i.e., “the amount

100), with id. Fig. 5 (depicting a SatSeconds threshold 114 of 25). Our
description reflects the content of the figures as depicted.
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of time between when a physiological parameter measurement exceeds an
alarm threshold before an alarm sounds.”12 Pet. 17, 62–68.
According to Petitioner “Wang teaches the use of SatSeconds
(time + severity) for implementing pre-alarm delays, and Batchelder teaches
that a medical monitor’s user interface assists in setting an optimal alarm
delay by simulating different threshold values on data received by the
medical monitor.” Pet. 62. Petitioner contends that Batchelder teaches that
a clinician can change the pre-alarm delay by varying either the oxygen
saturation threshold or the SatSeconds threshold, and can thereby optimize
the pre-alarm delay time through simulations that determine “how the
changes in thresholds affected the plotted data . . .[,] whether alarms would
have triggered[,] and the amount of pre-alarm delay in the plotted data.” Id.
at 62–64. “Thus, Batchelder’s monitor 14 simulates, using measurements
obtained from the monitor, different pre-alarm delay times (e.g., through
changes to the SatSeconds and SpO2 thresholds) to determine whether any of
the different pre-alarm delay times would have resulted in an alarm
notification event.” Id. at 64.
Petitioner further relies upon Kalkman as teaching simulations across
a care unit. Id. at 64–67. According to Petitioner, “Wang/Batchelder in
view of Kalkman provides the motivation to simulate different SatSeconds
thresholds, and thereby different alarm delays, across an entire care unit,”
wherein this combination “applies a known technique (simulating across a
care unit) to a known device (Wang/Batchelder’s monitor 14) ready for

12 Again, for sake of argument, we consider Petitioner’s application of the
prior art to the claim language under this presumed construction of “alarm
notification delay time” in claim 1.
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improvement to yield predictable results,” such as “finding . . . an optimal
integral threshold setting for a care unit, which could be used as a default
value programmed into the monitor’s processor, while still allowing for
further adjustment at the individual level, as taught by Batchelder.” Id. at
66; see also id. at 73 (analysis of claim 5, incorporating analysis of claim 1).
We are unpersuaded by Petitioner’s contentions. First, as above,
Petitioner has not identified what prior art structure is relied upon as the
“reporting module” of claim 1.13 In this Ground, Petitioner mentions
“reporting module” once, in reference to Kalkman’s PC. Pet. 65 (“Database
software running on processors in a PC (i.e., a ‘reporting module’).”).
As Patent Owner notes, however, Petitioner does not propose incorporating
Kalkman’s PC into the combined Wang/Batchelder system. Pet. 64
(“Kalkman provides the motivation to further simulate data across a care
unit.”), 66 (“Wang/Batchelder in view of Kalkman provides the motivation
to simulate different SatSeconds thresholds, and thereby different alarm
delays, across an entire care unit.”); Prelim. Resp. 49–50; cf. supra
§ II.D.3.ii.Pre-Alarm Delays. Thus, Petitioner fails to identify a “reporting
module,” as recited in claim 1, in the combination of prior art upon which
Petitioner relies.
Additionally, Petitioner does not contend that Wang discloses the
claim limitations of “simulat[ing] different alarm notification delay times.”
Pet. 62–64. Even accepting Petitioner’s contention that Batchelder discloses
such simulations, Petitioner has not shown that a skilled artisan would have
been motivated to incorporate those simulations into Wang. Specifically,

13 Our reasoning regarding the “reporting module” applies equally to the
“notification delay” alternative. See infra § II.F.3.Notification Delays.
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Petitioner acknowledges that it is Batchelder’s monitor and user interface
that perform the simulations. Id. at 64 (“Batchelder’s monitor 14 simulates,
using measurements obtained from the monitor, different pre-alarm delay
times.”). However, Petitioner does not propose modifying Wang to
incorporate Batchelder’s monitor and user interface, or the simulations it
performs. See, e.g., id. at 54 (“Combining Wang and Batchelder does not
modify the teachings of Wang.”).
To the contrary, Petitioner explains that both Wang and Batchelder
disclose use of the same SatSeconds technology, “which causes ‘alarming
based on an integral of time and depth of a desaturation event.’” Id. at 53–
54 (quoting Ex. 1012 ¶ 22) (also noting that both Wang and Batchelder use
“‘SatSeconds’ technology sold by ‘Nellcor Puritan Bennett’”) (citing
Ex. 1011 ¶ 15; Ex. 1012 ¶ 22). According to Petitioner,
Batchelder merely represents common knowledge in the art or
well-known prior art techniques. Combining Wang and
Batchelder does not modify the teachings of Wang, but rather
expressly states features Wang infers (i.e., a detailed description
of “SatSeconds” commercial technology) because they were
unnecessary to enable his invention. The combination of Wang
and Batchelder is proper because Batchelder expressly discloses
that which Wang implicitly teaches—a caregiver may use
SatSeconds technology to implement various pre-alarm delay[]
periods based on the severity of a parameter measurement or the
value of a SatSeconds integration threshold, which in turn
reduces false or transient alarms.
Id. at 54–55 (citing Ex. 1003 ¶ 139 (substantially identical)) (emphasis
added). Thus, Petitioner’s proposed modification of Wang incorporates
Batchelder’s express disclosure of “us[ing] SatSeconds technology to
implement various pre-alarm delay[] periods,” but does not incorporate
Batchelder’s disclosure of simulating different alarm notification delay
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times. Ex. 1011 ¶ 16 (“Because the SatSeconds technology is relatively new
in the medical field, it may be desirable to assist the caregiver in efficiently
determining the desired SatSeconds threshold value. Accordingly, a patient
monitoring system in accordance with embodiments of the present
disclosure may include one or more user interfaces which enable the
caregiver to change the SatSeconds threshold value and/or the SpO2
threshold value.”); see also Prelim. Resp. 36–37.
For these reasons, we are not persuaded by Petitioner’s contentions.
Notification Delays
Petitioner’s second contention applies to the construction of “alarm
notification delay times” as referring to “delaying notification of an active
bedside alarm to a remote location” as proposed by Petitioner, i.e., “the
elapsed time between alarm condition and transmission of notification.”14
Pet. 18, 67–70.
Petitioner relies on Wang’s alarm escalation method in which Wang’s
system delays transmission of an alarm notification to, e.g., a central nursing
station or clinician. See id. at 55, 68; Ex. 1012 ¶¶ 26–27. According to
Petitioner, an ordinarily skilled artisan “would have been motivated to
modify the system taught in Wang/Batchelder to simulate theoretical alarm
notification delays using the same simulation method taught in Kalkman and
based on the alarm history data collected by the monitoring system of
Wang.” Pet. 69 (citing Ex. 1003 ¶ 161). Petitioner contends this further
modification would have “reduc[ed] the number of alarms generally and . . .

14 Again, for sake of argument, we consider Petitioner’s application of the
prior art to the claim language under this presumed construction of “alarm
notification delay time” in claim 1.
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decrease[d] the number of nuisance or false alarms.” Id. Additionally,
Petitioner contends that simulating notification delay times is a safe option.
Id. at 69–70; see also id. at 73 (analysis of claim 5, incorporating analysis of
claim 1).
Petitioner’s contentions in this regard fail for the same reasons
discussed above. Namely, Petitioner’s contentions turn on the premise that
the combined Wang/Batchelder system simulates pre-alarm delays and that
it would have been obvious to modify that system to simulate notification
delays in the same manner. Pet. 68–69. However, as discussed above
regarding pre-alarm delays, Petitioner has not established that “the system
taught in Wang/Batchelder” simulates anything because Petitioner has not
shown that a person of ordinary skill in the art would have been motivated to
incorporate Batchelder’s simulations, or Batchelder’s monitor and user
interface (which conduct the simulations), with Wang’s system. Therefore,
Petitioner has not demonstrated persuasively that a person of ordinary skill
in the art would have been motivated to modify this system to “simulate
theoretical alarm notification delays.” Id. at 69. For example, Petitioner
fails to explain how Wang’s system (modified by Batchelder to include its
express SatSeconds disclosures, but no simulations) would have been
modified to conduct simulations of notification delay times. Id. at 68–70.
4. Summary
For the foregoing reasons, Petitioner has not shown a reasonable
likelihood of prevailing with respect to independent claims 1 or 5.
Petitioner’s additional contentions regarding dependent claims 2–4 and 6–8
do not cure these deficiencies regarding claims 1 and 5, and fail for the same
reasons.
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III. CONCLUSION
For the foregoing reasons, we determine that Petitioner has not
demonstrated a reasonable likelihood it would prevail in establishing the
unpatentability of any challenged claim of the ’994 patent. Accordingly, we
deny institution of an inter partes review.
IV. ORDER
Upon consideration of the record before us, it is:
ORDERED that the Petition is denied as to all challenged claims, and
no trial is instituted.

PETITIONER:

Rudolph A. Telscher, Jr.
Daisy Manning
Nathan P. Sportel
HUSCH BLACKWELL LLP
PTAB-RTelscher@huschblackwell.com
PTAB-DManning@huschblackwell.com
Nathan.Sportel@huschblackwell.com

PATENT OWNER:
Benjamin A. Katzenellenbogen
Irfan A. Lateef
Brian C. Claassen
KNOBBE, MARTENS, OLSON, & BEAR, LLP
2bak@knobbe.com
2ial@knobbe.com
2bcc@knobbe.com