UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`LIBERTY MUTUAL INSURANCE CO.
`Petitioner
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`v.
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`PROGRESSIVE CASUALTY INSURANCE CO.
`Patent Owner
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`Case CBM2013-00009
`Patent 8,140,358
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`PATENT OWNER’S OPPOSITION TO LIBERTY’S
`MOTION TO EXCLUDE EVIDENCE
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`CLI-2148004v1
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`LIBERTY MUTUAL INSURANCE CO.
`Petitioner
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`v.
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`PROGRESSIVE CASUALTY INSURANCE CO.
`Patent Owner
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`Case CBM2013-00009
`Patent 8,140,358
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`PATENT OWNER’S OPPOSITION TO LIBERTY’S
`MOTION TO EXCLUDE EVIDENCE
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`Patent Owner Progressive Casualty Ins. Co. (“Progressive”) hereby opposes
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`the motion to exclude filed by Liberty Mutual Insurance Co. (“Liberty”). (Paper
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`No. 40.)
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`I.
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`SUMMARY OF ARGUMENT
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`Liberty has failed to demonstrate good cause to exclude evidence introduced
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`by Progressive. Liberty bases its motion on a misunderstanding of the facts and a
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`misapprehension of the law. The attacks lodged by Liberty in its motion go to the
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`sufficiency of the Progressive evidence in question, not to its admissibility, and
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`Liberty’s motion to exclude should therefore be denied.
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`II. LEGAL STANDARD
`A. Not Proper To Argue Weight Of Evidence In Motion To Exclude
`“A motion to exclude must explain why the evidence is not admissible (e.g.,
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`relevance or hearsay)[.]” 77 Fed. Reg. 48,756, 48,767 (Aug. 14, 2012). However,
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`the Office Patent Trial Practice Guide makes clear that such a motion to exclude
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`“may not be used to challenge the sufficiency of the evidence to prove a particular
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`fact.” Id. (emphasis added). Indeed, as set forth in the caselaw cited by Liberty,
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`the “sufficiency of evidence relates not to admissibility but to the weight of the
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`evidence and is a matter for the trier of fact to resolve.” SEC v. Guenthner, 395 F.
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`Supp. 2d 835, 842 n.3 (D. Neb. 2005) (emphasis added).
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`Liberty Argues That Progressive’s Evidence Should Be Admitted
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`B.
`Notwithstanding that Liberty is moving to exclude evidence, it spends
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`several pages of its ten-page motion, setting forth caselaw for the proposition that
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`the Board should not exclude evidence. (Motion at 1-3.) Indeed, Liberty claims
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`that there is no “need for formal exclusion,” and it is “better for the Board” to
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`admit evidence “than to exclude particular pieces.” (Motion at 1, 2.) Progressive
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`does not concede or agree that Liberty’s characterization of the law applies in all
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`instances, such as where new evidence is improperly submitted with a reply brief
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`or cross-examination of a witness indicates that his or her prior testimony was
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`unreliable. Nevertheless, since Liberty has not argued that, in evaluating
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`Progressive’s evidence, there is any reason to depart from the general principles
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`favoring the admission of evidence, its motion should be denied under the very
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`caselaw it cites.
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`III. ARGUMENT
`A. Liberty Fails To Show Good Cause As To Expert Dr. Ehsani
`Liberty has failed to satisfy its burden of showing good cause that portions
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`of Progressive’s expert Dr. Mark Ehsani’s declaration (Exhibit 2015) should be
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`excluded. As demonstrated below, Liberty’s argument is based on its erroneous
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`speculation as to Dr. Ehsani’s qualifications, which is the result of its decision not
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`to depose him.
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`Liberty claims erroneously that Dr. Ehsani “does not” have “at least
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`one…year[] of experience with telematics systems[.]” (Motion at 7, emphasis in
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`original.) This allegation is unsupported in the record. Indeed, Liberty cites ¶ 11
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`from Dr. Ehsani’s expert report, in which he states: “I have more than 20 years of
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`experience in designing, researching and developing vehicle telematics systems.”
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`(Ex. 2015 at ¶ 11, emphasis added.)
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`Liberty also mischaracterizes ¶ 11, claiming that Dr. Esani “assert[s]
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`experience only with data ‘acquisition’ and ‘processing.’” (Motion at 7.) To the
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`contrary, Dr. Ehsani does not so limit his “more than 20 years of experience.” (Ex.
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`2015 at ¶ 11.) Indeed, he states in ¶ 11 that “telematics includes the acquisition of
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`automotive onboard vehicle data and its processing” and that he has “extensively
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`performed real-time vehicle data acquisition, logging, and analysis for driver-
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`specific drive cycle analysis.” (Id., emphasis added.)
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`Liberty further cites Dr. Ehsani’s CV as support for its mistaken claim that
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`he does not have “at least one” year of experience with telematics systems.
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`(Motion at 7.) Yet, even a cursory review of Dr. Ehsani’s CV undercuts this claim.
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`Dr. Ehsani’s CV details his nearly 40 years of continuous professional experience,
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`including as a Professor of Electrical Engineering and the Founding Director of the
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`Advanced Vehicle Systems Research Program and the Power Electronics and
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`Motor Drives Laboratory at Texas A&M University, where he has taught for 32
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`years. (Ex. 2016 at 1-3.) Prior to that, he worked as a research engineer at the
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`Fusion Research Center at the University of Texas and as a resident research
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`associate at the Argonne National Laboratory in Argonne, Illinois. (Id. at 1, 3.)
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`He received his PhD from the University of Wisconsin-Madison in 1981 in
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`electrical engineering. (Id. at 1, 4.) And since 1981, he has received grants of over
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`$16,000,000 in support of his research. (Ex. 2015 at 2.)
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`Dr. Ehsani’s CV also catalogs his numerous accolades and career
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`achievements. (Ex. 2016 at 1, 42-50.) For example, in 2005, he was elected as a
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`Fellow of the Society of Automotive Engineers (SAE). (Id. at 1, 48.) He received
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`the Prize Paper Awards in Static Power Converters and Motor Drives at the IEEE
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`Industry Applications Society in 1985, 1987, and 1992 Annual Meetings. (Id. at 1,
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`42-43.) He was selected for the IEEE Vehicular Society 2001 Avant Garde Award
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`for “Contributions to the Theory and Design of Hybrid Electric Vehicles.” (Id. at
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`1, 47.) In 2004, he was elected to the Robert M. Kennedy endowed Chair in
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`Electrical Engineering at Texas A&M University. (Id. at 1, 48.) Dr. Ehsani is also
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`the founder of the IEEE Vehicle Power and Propulsion Conference, the founding
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`chairman of the IEEE Vehicular Technology Society Vehicle Power and
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`Propulsion Committee, and chairman of Convergence Fellowship Committees.
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`(Id. at 2.) In 2002, he was elected to the Board of Governors of the IEEE
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`Vehicular Technology Society. (Id. ) He also serves on the editorial board of
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`several technical journals and is the associate editor of IEEE Transactions on
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`Industrial Electronics and IEEE Transactions on Vehicular Technology. (Id. at 42-
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`50, 52.)
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`The only other basis Liberty cites for its erroneous claim is a statement by its
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`own witness, Mr. Andrews, that Dr. Ehsani “does not have any experience…with
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`telematics systems that exchange data wirelessly between the vehicle and remote
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`locations.” (Motion at 7, citing Ex. 1027 at ¶ 14, emphasis added.) Yet,
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`Andrews’s statement is based on the same CV by Dr. Ehsani, which demonstrates
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`the opposite – that Dr. Ehsani has extensive experience in telematics and more than
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`qualifies as an expert to opine on the ordinary skill in the art. Further, Andrews’s
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`statement relates to “exchang[ing] data wirelessly,” which is not the same basis
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`that Liberty claims in its motion that Dr. Ehsani’s experience is inadequate.
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`Moreover, Andrews has admitted that he “do[es]n’t know what the requirements”
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`are for Dr. Ehsani to “render technical opinions in this matter[.]” (Ex. 2032,
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`Andrews Tr. at 261:9-14.)
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`The reason both Liberty and Andrews are confused as to Dr. Ehsani’s
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`background is that Liberty chose not to depose him. Indeed, Liberty noticed his
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`deposition for July 29, 2013 but then decided to cancel it. (Paper No. 23.) If
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`Liberty had wanted to understand the full extent of Dr. Ehsani’s experience in
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`telematics, it could have asked him during the deposition. Having chosen not to
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`cross-examine him, Liberty should not now be heard to argue that Dr. Ehsani lacks
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`the requisite experience based on his resume. See 77 Fed. Reg. at 48,643 (proper
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`means for party to challenge an expert’s qualifications involves cross-
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`examination).
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`Liberty’s own actions in not going forward with its deposition, as well as the
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`erroneous and unsupported claims it makes based on Dr. Ehsani’s CV, demonstrate
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`that it has failed to show good cause to exclude any testimony by Dr. Ehsani.
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`Liberty Fails To Show Good Cause As To Expert Mr. Zatkovich
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`B.
`Liberty has also failed to satisfy its burden of showing good cause that
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`portions of Progressive’s expert Mr. Ivan Zatkovich’s declaration (Exhibit 2020)
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`should be excluded. As demonstrated below, Liberty’s argument is based on a
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`misapprehension of the law and its erroneous speculation as to Mr. Zatkovich’s
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`qualifications, which is the result of Liberty’s own decision not to depose Mr.
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`Zatkovich.
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`The only basis Liberty cites in moving to exclude Mr. Zatkovich’s testimony
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`is his own Declaration. (Motion at 5-6.) Indeed, Liberty admits that Mr.
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`Zatkovich opines about a POSITA’s understanding in his declaration, but then
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`claims that – in the same declaration – he also “concedes…he had no such
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`experience[.]” (Id. at 5-6, emphasis in original.) Mr. Zatkovitch makes no such
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`concession, and his Declaration and CV demonstrate otherwise.
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`As with Dr. Ehsani, Liberty never deposed Mr. Zatkovich. It noticed his
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`deposition for July 15, 2013, and then without explanation chose to cancel it.
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`(Paper No. 25.) Liberty is left with trying to read negative limitations into the
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`experiences and accomplishments identified in Mr. Zatkovich’s resume. Yet this is
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`to no avail. Mr. Zatkovich received his Bachelor’s degree in Computer science,
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`with a minor in Electrical Engineering Digital Circuit Design, from the University
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`of Pittsburgh in 1980, and he completed a master’s thesis in Computer Networks.
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`(Ex. 2020 at 3.) He has “over thirty-one years experience in computer science,
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`network communications, and software development” and “more than 4 years
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`experience designing and implementing vehicle telematics systems and ha[s]
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`designed and implemented ecommerce computer systems for the insurance
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`industry, such as for Geico and Hartford.” (Id. at 2, 4-5, emphasis added; see
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`generally Ex. 2021.) Liberty’s attempt to read into Mr. Zatkovitch’s Declaration a
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`concession that “he has no such experience” in telematics is not supportable.
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`Not only is Liberty’s argument wrong as a matter of fact, but it is wrong as a
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`matter of law. Liberty claims that the POSITA’s knowledge is based on what was
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`known as of the priority date in 1996, and as such, Mr. Zatkovitch must also have
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`had the requisite experience as of 1996. (See Motion at 5-6.) This misstates the
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`law, and Liberty cites no case supporting this proposition. To the contrary, a
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`POSITA is a “hypothetical person,” who possesses the ordinary skill in the art.
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`Standard Oil Co. v. Am. Cyanamid Co., 774 F.2d 448, 454 (Fed. Cir. 1985)
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`(emphasis added). To testify as to the understanding of this hypothetical person,
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`an expert, like Mr. Zatkovitch, must possess at least the same ordinary level of
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`skill. See Sundance, Inc. v. DeMonte Fabricating Ltd., 550 F.3d 1356, 1363-64
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`(Fed. Cir. 2008) (explaining that testifying expert must be “qualified as a technical
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`expert in that art”). But, there is no requirement that the testifying expert possess
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`that skill as of the priority date at issue, and Liberty has cited no authority to the
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`contrary.
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`Liberty’s argument to exclude portions of Mr. Zatkovich’s declaration fails
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`as a matter of law and fact, and Liberty has not demonstrated good cause to
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`exclude any of his testimony.
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`C. Liberty Fails To Show Good Cause As To Excluding
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`Witnesses Alleged Not To Constitute Hypothetical POSITAs
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`Liberty also argues that Dr. Ehsani and Mr. Zatkovich fail to set forth a
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`legitimate basis for their opinions and ignore prior art. Liberty once again
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`premises its argument on a misapprehension of the law and has failed to satisfy its
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`burden of showing good cause to exclude evidence. Liberty relies on the caselaw
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`proposition that a POSITA “is presumed to be aware of all the pertinent prior art.”
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`(Motion at 9, citing Standard Oil, 774 F.2d at 227.) While this is a correct
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`statement of law, Liberty attempts to turn it into a rule of evidence requiring the
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`exclusion of any expert who is alleged to be not aware of every piece of prior art in
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`existence, including prior art not mentioned or asserted in an original petition and
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`that is deliberately withheld by a petitioner. No such rule of evidence exists.
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`More specifically, with its Reply, Liberty submitted seven new references to
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`combine with Kosaka (Exhibits 1028-1029 and 1034-1038), along with supporting
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`Reply Declarations from Andrews (Exhibit 1027 at ¶¶ 5-8) and O’Neil (Exhibit
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`1031, at ¶¶ 35, 37, 39, and 42), in an effort to state a prima facie case based on
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`Kosaka’s deficient disclosure. It was improper to introduce such new invalidity
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`arguments and evidence in a Reply, and Progressive has moved to exclude these
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`new references and supporting declaration evidence. (See Paper No. 28.) Liberty
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`(in its Reply) tried to blame its tardy submission on Progressive, claiming that
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`Progressive had “ignore[d]” “relevant prior art” and thus compelled Liberty to
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`introduce it in its Reply. (Reply at 14, emphasis added.) This was nothing more
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`than a smokescreen to cover Liberty’s improper introduction of new evidence with
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`its Reply, as Progressive could not have “ignored” these references since Liberty
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`never submitted them with its Petition.1
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`1 Liberty’s own experts did not mention anything about these references in
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`any Petition submissions. Either Liberty and its experts knew about them and
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`Liberty now rehashes this same ill conceived argument in its motion to
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`exclude, claiming that Progressive allegedly “ignore[d] art that a POSITA would
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`clearly have known” and should be penalized by having portions of its experts’
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`opinions excluded. (Motion at 8.) Liberty’s argument provides neither a
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`justification for introducing new evidence and arguments in its Reply, nor a basis
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`to exclude the testimony of Progressive’s experts.
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`Liberty still provides no caselaw support for its attempt to transform the
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`substantive law as to a POSITA’s knowledge into a new evidentiary rule. Rather,
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`Liberty argues that Progressive’s expert “Mr. Zatkovitch [] claims to be a POSITA
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`and thus is presumed to know of all relevant art[.]” (Motion at 8, emphasis added,
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`citing Standard Oil, 774 F.2d at 454.) But no real person is a POSITA. The
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`POSITA is a “hypothetical person,” as Judge Rich made clear in the very case that
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`Liberty cites. Standard Oil, 774 F.2d at 454 (emphasis added).
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`At the core of Liberty’s arguments is that it simply disagrees with how
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`Progressive’s experts view the prior art. This is not a basis for moving to exclude.
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`Indeed, these arguments go to the sufficiency of evidence Progressive has
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`(continued…)
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`concealed them from Progressive, or they did not know about them and Liberty’s
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`own experts would have to be excluded by virture of Liberty’s newly-created rule.
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`marshaled, and cannot be raised in a motion to exclude. (See supra at 1-2.) As
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`such, Liberty has failed to demonstrate good cause to exclude Progressive’s
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`evidence, and its motion should be denied.
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`D. Mr. Miller Has Not Relied On Improper Evidence
`Liberty attempts to exclude ¶ 17 of the Declaration of Progressive’s expert
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`Mr. Michael Miller (Exhibit 2013), claiming that Progressive improperly failed to
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`submit a copy of the “Statement of Principles” of the American Academy of
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`Actuaries. (Motion at 10.) This argument is a red herring, and, as demonstrated
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`below, it ignores the fact (i) that Progressive had already filed a copy of the
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`Statement of Principles as an exhibit in a related CBM Review between the parties,
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`(ii) that Miller specifically identified this exhibit as setting forth the Statement of
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`Principles, (iii) that Liberty’s own witness recognized that the Statement of
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`Principles were so filed in the related CBM Review, and (iv) that this Liberty
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`witness admitted the Statement of Principles were viewed as a guideline as of
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`1996.
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`In ¶ 17 of his expert Declaration, Mr. Miller opined as to the meaning of
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`“actuarial classes.” His opinion stands on its own, and Liberty identifies no basis
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`for excluding that opinion. Mr. Miller further noted in his Declaration that his
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`description of this “actuarial class” is “consistent with the definition in the Risk
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`Classification Statement of Principles of the American Academy of Actuaries” and
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`that a “person of ordinary skill in the art in 1996 would have adhered to this
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`Statement of Principles.” (Ex. 2013 at ¶ 17, emphasis added.)
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`There is no ambiguity as to the particular Statement of Principles to which
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`Mr. Miller referred in ¶ 17. Indeed, Progressive had already filed it as an exhibit in
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`a co-pending CBM Review between the parties. (See CBM2012-00002, Ex. 2012.)
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`In fact, when Liberty’s witness, Mary O’Neil, responded to Mr. Miller’s
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`Declaration, she specifically identified where the Statement of Principles had been
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`filed in the related CBM Review: “Mr. Miller has presented the Risk Classification
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`Statement of Principles (Ex. 2012 in CBM2012-00002)[.]” (Ex. 1031 at ¶ 17,
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`emphasis added; see also id at ¶ 16.) She also acknowledge that the Statement of
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`Principles was recognized as a “guideline” in 1996. (See id.)
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`Mr. Miller also submitted a Supplemental Declaration confirming that
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`“Progressive Exhibit 2012 in related CBM2012-00002 is the same ‘Risk
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`Classification Statement of Principles’ I referenced in paragraph 17 of my
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`declaration in this proceeding[.]” (Ex. 2026 at ¶ 5.) As such, Liberty cannot claim
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`any inability to locate the Statement of Principles or any prejudice in its ability to
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`fully respond to Mr. Miller’s reference to it.
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`Furthermore, Progressive has complied with the rule. 37 C.F.R. §42.6(c)
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`requires that “[e]ach exhibit must be filed with the first document in which it is
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`cited[,]” and Progressive complied with this rule when it first cited the Statement
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`of Principles in CBM2012-00002. (Emphasis added.) And, the Office Patent Trial
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`Practice Guide makes clear that the purpose of this rule is to “allow for uniformity
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`in citing to the record[,]” which Progressive accomplished by citing to the previous
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`filing of the Statement of Principles as Exhibit 2012 in CBM2012-00002. See 77
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`Fed. Reg. at 48,617. Moreover, Liberty cannot be heard to complain under 37
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`C.F.R. § 42.63(a), which requires that evidence be filed in the form of an exhibit,
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`as Liberty’s own witness admitted that the Statement of Principles had, in fact,
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`been filed as “Ex. 2012 in CBM2012-00002.” (Ex. 1031 at ¶ 17.) Nevertheless,
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`Progressive herewith files another copy of the Statement of Principles as Exhibit
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`2031, which is the same one filed in the co-pending CBM2012-00002 as Exhibit
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`2012 and cited by Liberty’s witness.
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`Liberty has failed to articulate any cognizable basis for excluding Mr.
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`Miller’s testimony, and the Board should deny Liberty’s motion.
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`IV. CONCLUSION
`For at least these reasons, Liberty’s Motion should be denied.
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`By:
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`Respectfully submitted,
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`JONES DAY
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`/s/Calvin P. Griffith
`Calvin P. Griffith
`Registration No. 34,831
`JONES DAY
`901 Lakeside Avenue
`Cleveland, Ohio 44114-1190
`(216) 586-3939
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`Attorney For Patent Owner
`Progressive Casualty Insurance Co.
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`October 4, 2013
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`CERTIFICATE OF SERVICE
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`I certify that a copy of the foregoing PATENT OWNER’S OPPOSITION
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`TO MOTION TO EXCLUDE EVIDENCE was served on October 4, 2013 by
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`causing them to be sent by email to counsel for Petitioner at the following email
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`addresses:
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`Steven.baughman@ropesgray.com
`Nicole.jantzi@ropesgray.com
`James.myers@ropesgray.com
`LibertyMutualPTABService@ropesgray.com
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`/s/ John V. Biernacki
`John V. Biernacki
`Registration No. 40,511
`JONES DAY
`901 Lakeside Avenue
`Cleveland, Ohio 44114-1190
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`Attorney For Patent Owner
`Progressive Casualty Insurance Co.
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