UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS AMERICA, INC. and
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner
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`v.
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`SMARTFLASH LLC,
`Patent Owner
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`Case CBM2014-00192
`Patent 8,033,458
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`PETITIONER’S REPLY IN SUPPORT OF
`MOTION TO EXCLUDE EVIDENCE UNDER 37 C.F.R. § 42.64(c)
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS AMERICA, INC. and
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner
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`v.
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`SMARTFLASH LLC,
`Patent Owner
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`Case CBM2014-00192
`Patent 8,033,458
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`PETITIONER’S REPLY IN SUPPORT OF
`MOTION TO EXCLUDE EVIDENCE UNDER 37 C.F.R. § 42.64(c)
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`TABLE OF CONTENTS
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`Case CBM2014-00192
`Attorney Docket No: 39843-0005CP1
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`INTRODUCTION ......................................................................................... 1
`I.
`II. ARGUMENT .................................................................................................. 1
`A. Contrary to PO’s Opposition, the Subject Deposition Excerpts
`Lack Proper Foundation .............................................................................. 2
`B. Contrary to PO’s Opposition, the Subject Deposition Excerpts Are
`Outside the Scope ......................................................................................... 5
`C. Contrary to PO’s Opposition, the Subject Deposition Excerpts Are
`Irrelevant ....................................................................................................... 7
`III. CONCLUSION ............................................................................................ 10
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`
`
`
`i
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`Case CBM2014-00192
`Attorney Docket No: 39843-0005CP1
`EXHIBIT LIST
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`SAMSUNG-1001 U.S. Patent No. 8,033,458 to Hulst et al. (“the ‘458 Patent” or
`“’458”)
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`SAMSUNG-1002 Excerpts from the Prosecution History of the ‘458 Patent (“the
`Prosecution History”)
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`SAMSUNG-1003 Declaration of Dr. Jeffrey Bloom re the ‘458 Patent (“Bloom”)
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`SAMSUNG-1004 U.S. Patent No. 5,530,235 (“Stefik ‘235” or “Stefik”)
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`SAMSUNG-1005 U.S. Patent No. 5,629,980 (“Stefik ‘980”) (incorporated by
`5,530,235)
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`SAMSUNG-1006 PCT Publication No. WO 00/08909 (“Gruse”)
`
`SAMSUNG-1007 PCT Application PCT/GB00/04110 (“the ‘110 Appln.” or
`“‘110”)
`
`SAMSUNG-1008 United Kingdom Patent Application GB9925227.2 (“the ‘227.2
`Appln.” or “‘227.2”)
`
`SAMSUNG-1009 Transitional Program for Covered Business Method Pa-tents—
`Definitions of Covered Business Method Patent and
`Technological Invention, 77 Fed. Reg. 157 (Aug. 14, 2012)
`
`SAMSUNG-1010 A Guide to the Legislative History of the America Invents Act;
`Part II of II, 21 Fed. Cir. Bar J. No. 4
`
`SAMSUNG-1011 Interim Guidance for Determining Subject Matter Eligibility for
`Process Claims in View of Bilski v. Kappos (Jul. 27, 2010)
`
`SAMSUNG-1012 Apple Inc. v. Sightsound Technologies, LLC, CBM2013-00019
`Paper No. 17 (entered Oct. 8, 2013) at 11-13
`
`ii
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`Case CBM2014-00192
`Attorney Docket No: 39843-0005CP1
`SAMSUNG-1013 Volusion, Inc. v. Versata Software, Inc. and Versata Devel-
`opment Group, Inc., CBM2013-00017 Paper No. 8 (entered
`Oct. 24, 2013)
`
`SAMSUNG-1014 Salesforce.com, Inc. v. VirtualAgility, Inc., CBM2013-00024
`Paper No. 16 (entered Nov. 19, 2013)
`
`SAMSUNG-1015 U.S. Patent No. 8,336,772 (“the ‘772 Patent” or “‘772”)
`
`SAMSUNG-1016 U.S. Patent No. 8,118,221 (“the ‘458 Patent” or “‘458)
`
`SAMSUNG-1017 U.S. Patent No. 8,061,598 (“the ‘598 Patent” or “‘598”)
`
`SAMSUNG-1018 RESERVED
`
`SAMSUNG-1019 U.S. Patent No. 7,942,317 (“the ‘317 Patent” or “‘317”)
`
`SAMSUNG-1020 U.S. Patent Application No. 12/014,558 (“the ‘558 Appln.” or
`“’558”)
`
`SAMSUNG-1021 U.S. Patent No. 7,334,720 (“the ‘720 Patent” or “‘720”)
`
`SAMSUNG-1022 RESERVED
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`SAMSUNG-1023 RESERVED
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`SAMSUNG-1024 U.S. Patent Application No. 12/943,847 (“the ‘847 Appln.” or
`“‘847”)
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`SAMSUNG-1025 RESERVED
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`SAMSUNG-1026 RESERVED
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`SAMSUNG-1027 RESERVED
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`SAMSUNG-1028 Weinstein “MasterCard Plans Point-of-Sale Product for
`Merchants Leery of Bank Cards”
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`iii
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`Case CBM2014-00192
`Attorney Docket No: 39843-0005CP1
`SAMSUNG-1029 Mayo Collaborative Serv v. Prometheus Labs., Inc., 132 S. Ct.
`1289 (2012)
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`SAMSUNG-1030 Gottschalk v. Benson, 409 U.S. 63 (1972)
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`SAMSUNG-1031 Cybersource Corp. v. Retail Decisions, Inc., 654 F.3d 1366
`(Fed. Cir. 2011)
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`SAMSUNG-1032 Bilski v. Kappos, 130 S. Ct. 3218 (2010)
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`SAMSUNG-1033 Alice Corp. v. CLS Bank International,134 S.Ct. 2347 (2014)
`
`SAMSUNG-1034 Bancorp Serv., L.L.C. v. Sun Life Assur. Co. (U.S.) 687 F.3d
`1266 (Fed. Cir. 2012)
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`SAMSUNG-1035 Dealertrack, Inc. v. Huber, 674 F.3d 1323 (Fed. Cir. 2012)
`
`SAMSUNG-1036 SiRF Tech., Inc. v. Int’l Trade Comm’n, 601 F.3d 1319 (Fed.
`Cir. 2010)
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`SAMSUNG-1037 In re Bilski, 545 F.3d 943, 88 U.S.P.Q.2d 1385 (Fed. Cir. 2008)
`
`SAMSUNG-1038 Accenture Global Services, GmbH v. Guidewire Software, Inc.,
`728 F.3d 1336 (Fed. Cir. 2013)
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`SAMSUNG-1039 Keith, Michael C., The Radio Station Broadcast, Satellite and
`Internet, Eighth Edition, 2009
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`SAMSUNG-1040 Affidavit in Support of Petitioner's Motion for Pro Hac Vice
`Admission of Ralph A. Phillips
`
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`SAMSUNG-1041 Ariosa Diagnostics, Inc. v. Sequenom, Inc., 14-1144, slip op.
`(Fed. Cir. June 12, 2015)
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`SAMSUNG-1042 Versata Development Group, Inc. v. SAP America, Inc. et al.,
`14-1194, slip op. (Fed. Cir. July 9, 2015)
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`iv
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`Case CBM2014-00192
`Attorney Docket No: 39843-0005CP1
`SAMSUNG-1043 Petitioner’s Response to Patent Owner’s Objections and Notice
`of Service of Supplemental Evidence Under 37 CFR §
`42.64(b)(2), Served on April 29, 2015
`
`SAMSUNG-1044 LG Electronics v. Advanced Micro Devices, IPR2015-00324,
`Paper 17
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`SAMSUNG-1045 CLS Bank Int'l v. Alice Corp., 717 F.3d 1269, 1304–05 (Fed.
`Cir. 2013) (en banc)
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`SAMSUNG-1046 Ultramercial, Inc. v. Hulu, LLC, 722 F.3d 1335, 1339 (Fed.
`Cir. 2013)
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`SAMSUNG-1047 Interthix, Inc. v. Corelogic Solutions, LLC, CBM2012-00007,
`Paper 58
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`SAMSUNG-1048 Apple Inc. v. Smartflash LLC, CBM2014-00102, Paper 8
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`SAMSUNG-1049 Vibrant Media v. General Electric Company, IPR2013-00172,
`Paper 50
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`SAMSUNG-1050 SK Innovation Co. LTD. v. Celgard, LLC, IPR2014-00680,
`Paper 57
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`SAMSUNG-1051 Declaration of Ms. Patricia Hoskins
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`SAMSUNG-1052 Apple Inc. v. Smartflash LLC, CBM2014-00106, Paper 52
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`v
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`Case CBM2014-00192
`Attorney Docket No: 39843-0005CP1
`
`I.
`
`INTRODUCTION
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`Pursuant to 37 C.F.R. § 42.64 and the Federal Rules of Evidence, Samsung
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`Electronics America, Inc. and Samsung Electronics., Ltd. (“Petitioner” or
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`“Samsung”) moved to exclude portions of Dr. Bloom’s deposition transcript. See
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`Papers 37/38. Patent Owner (“PO” or “Smartflash”) relied on these portions in
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`Patent Owner’s Response. See Papers 22/23. In opposing Samsung’s Motion to
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`Exclude, Smartflash continues to allege that Dr. Bloom is biased because
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`“similarity between his employer’s products and the claims of the patent would
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`provide Dr. Bloom with a motivation to be biased against the claims being found to
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`be statutory subject matter under 35 U.S.C. § 101.” Paper 40 (citing Papers 22/23,
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`at 6). Yet, Smartflash has failed show that Dr. Bloom was aware of any similarity
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`(even assuming that such similarity exists) between his employer’s products and
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`the subject patent at the time that Dr. Bloom rendered his declaration, a necessary
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`condition for the alleged bias. See Paper 40. Thus, Smartflash has not established
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`the alleged bias. See Paper 40. According, the subject portions from the
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`deposition transcript should be excluded, as requested by Samsung.
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`II. ARGUMENT
`Samsung objected to portions of Exhibits 2056 and 2057 in its Notice of
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`Objections served on June 8, 2015 as well as during the deposition on May 20,
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`2015. Smartflash relied on Exhibits 2056 and 2057 in its Response to the Petition
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`1
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`Case CBM2014-00192
`Attorney Docket No: 39843-0005CP1
`(Papers 22/23) filed on June 1, 20151. As requested by Samsung and despite the
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`opposition from Smartflash, the objected-to portions of Exhibits 2056 and 2057
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`should be excluded from this proceeding as inadmissible under the Federal Rules
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`of Evidence.
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`A. Contrary to PO’s Opposition, the Subject Deposition Excerpts
`Lack Proper Foundation
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`During deposition and over Samsung’s objection, Smartflash attempted to
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`solicit testimonies from Dr. Bloom as to whether “the SiriusXM Internet Radio
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`product that allows off-line playback [is] a subscription-based product.” See
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`Exhibit 2057, at 193:17-194:8 and 195:5-16. Samsung moves to exclude these
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`deposition excerpts under FRE 701 and 702. See Papers 37/38.
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`In opposing Samsung’s motion, Smartflash concedes that Dr. Bloom “has
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`not been advanced as an expert with regard to subscription-based business practice
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`of a third-party company.” See Paper 40 at 3. Yet, Smartflash insists that “Dr.
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`Bloom is currently employed by such ‘third-party company’ and its ‘subscription-
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`1Smartflash also relied on portions of Exhibit 2057 to which Samsung objected in
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`its Notice of Objections served on June 8, 2015 as well as during the deposition on
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`May 20, 2015. The Board ordered such portions of Exhibit 2057 under seal. See
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`Paper 29.
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`2
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`Case CBM2014-00192
`Attorney Docket No: 39843-0005CP1
`based business practices’ are both within Dr. Bloom’s job responsibilities and
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`relevant to the patent claims.” Id.
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`The insistence is unfounded. Consistent with Smartflash’s concession (that
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`Dr. Bloom has not been advanced as not been advanced as an expert with regard to
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`subscription-based business practice of a third-party company), Dr. Bloom also
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`testified under oath he does not know potentially relevant details of his employer’s
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`business practice.
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`Q. Does SiriusXM have a lot of subscribers?
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`A. I don't know how many they have.
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`Q. More than a million?
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`A. I don't know.
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`Exhibit 2056: 174:19-22.2
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`While insisting that “all of the factual foundation necessary for Smartflash’s
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`cross examination inquiry into Dr. Bloom’s knowledge of [a third-pary company’s]
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`product is set forth in his direct testimony in his declaration,” Smartflash conflates
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`2 Because of Dr. Bloom’s apparent lack of personal knowledge of such
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`subscription-based business practice of the third-party company, treating the
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`content of the subject deposition excerpts as lay witness opinion would be equally
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`improper.
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`3
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`Case CBM2014-00192
`Attorney Docket No: 39843-0005CP1
`an “[i]nquiry into how the third-party company’s products handle condidtional
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`access” with the subscription-based business practice of the third party. Paper 40
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`at 3. Without more, Smartflash then asserts that it “is entitled to have the Board
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`consider Dr. Bloom’s responses to the inquiry and how any similarity between Dr.
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`Bloom’s employer’s products and the claims of the patent would provide Dr.
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`Bloom with a motivation to be biased against the claims being found to be
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`statutory subject matter under 35 U.S.C. § 101.” Id.
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`Smartflash’s analysis is flawed at least because Smartflash failed to provide
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`any foundation for the entire line of questioning, a line of questioning that the
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`PTAB previously struck down in its consideration of the list of excluded motions3.
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`Aside from Dr. Bloom’s apparent lack of knowledge about the subscription-based
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`business practice of a third party company, Dr. Bloom also testified under oath that
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`he did not consider his employer’s products in relationship to the patent claims at
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`issue.
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`Q. In preparing your report, did you consider whether [a third-party
` company]'s system that enables limited use of paid for and/or
` licensed content is covered by any of the claims for which you
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`3 See Paper 13 (dismissing Smartflash’s contention that “an accused infringer who
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`pleads in the alternative that the challenged claims are unpatentable under § 101, a
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`question of law, is taking an inconsistent position with its non-infringement
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`position.”).
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`4
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`Case CBM2014-00192
`Attorney Docket No: 39843-0005CP1
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` provided an opinion?
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`A. No, I didn't consider that.
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`Q. Is there a reason that you didn't?
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`A. It didn't occur to me.
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`Exhibit 2056,174:23-175:5.
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`In other words, Dr. Bloom did not perceive any alleged similarity between a
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`third-party company’s product and the patent claims at issue. Therefore, even if a
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`third-party company’s products are relevant to the patent claims at issue, an inquiry
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`to which Smartflash never established a foundation, Smartflash failed to impute
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`knowledge of the alleged infringement to Dr. Bloom at the time of his rendering of
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`his declaration, a necessary condition for the alleged bias to exist. If mere
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`employment could suffice for such imputation, then all experts hired by one side
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`would have a motivation to be biased against the other side being found right.
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`That outcome would disqualify all experts and put the Board in a precarious
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`situation.
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`Because Smartflash sought to have Dr. Bloom opine on matters without
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`laying proper factual support, such portions of testimony should thus be excluded
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`under Rules 702 and 701.
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`B. Contrary to PO’s Opposition, the Subject Deposition Excerpts
`Are Outside the Scope
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`5
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`Case CBM2014-00192
`Attorney Docket No: 39843-0005CP1
`During deposition and over Samsung’s objection4, Smartflash solicited
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`testimony from Dr. Bloom that is outside the scope of the direct examination, and
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`Smartflash failed to demonstrate the testimony relates to matters affecting the
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`credibility of Dr. Bloom. See Exhibit 2056 at 179:1-20, and in Exhibit 2057 at
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`193:17-194:8 and 195:5-16 (inquiring whether a third-party company unrelated to
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`the instant proceeding “has a product that enables paid for and/or licensed content
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`to be stored locally and played back later in a disconnected fashion.”). Samsung
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`moves to exclude the subject deposition excerpts under FRE 611(b). See Papers
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`37/38. Smartflash opposes by asserting that the issue goes to “a matter affecting
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`the witness’s credibility” because “similarity between his employer’s products and
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`the claims of the patent would provide Dr. Bloom with a motivation to be biased
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`against the claims being found to be statutory subject matter under 35 U.S.C. §
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`101.” See Paper 40 at 4. As discussed in Section IIA, even if a third-party
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`company unrelated to the instant CBM proceeding may offer products within the
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`broad industry defined as consumer electronics, such an insinuaed applicability,
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`4 Contrast with Apple Inc. v Smartflash LLC CBM2014-00103 Paper 52 at 28-30
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`(discussing that “many of the questions and answers that Patent Owner now seeks
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`to exclude [for exceeding the scope of the direct testimony] were not objected to
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`during the deposition….”).
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`6
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`Case CBM2014-00192
`Attorney Docket No: 39843-0005CP1
`even if true5, would only suggest that the third-party company possibly has “a
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`motivation to be biased.” Id. Smartflash has not demonstrated that such a possible
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`motivation of the third-party company could be imputed to Dr. Bloom. Therefore,
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`Dr. Bloom’s testimony, as sought by Smartflash, does not relate to matters that
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`affect the credibility—including any motivation to be biased—of Dr. Bloom.
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`Because Smartflash solicited testimony from Dr. Bloom is both outside the
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`scope of the direct examination, and has no legitimate bearing on the issue of Dr.
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`Bloom’s credibility, such testimony portions should be excluded. See Rule 611(b).
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`C. Contrary to PO’s Opposition, the Subject Deposition Excerpts
`Are Irrelevant
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`During cross-examination and over Samsung’s objection, Smartflash
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`solicited testimony that is irrelevant to the salient issue of patent validity and that
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`does not have legitimate bearing on the question of Dr. Bloom’s credibility. See
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`Exhibit 2057, 193:17-194:8; 195:5-16. Smartflash repeatedly asserted that
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`“similarity between his employer’s products and the claims of the patent would
`
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`5 To the extent that Patent Owner requested discovery into alleged evidence of
`
`non-infringement and existence of non-infringing alternatives, the Board refused to
`
`authorize Patent Owner to file such motions to compel discovery. See generally,
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`Patent Owner List of Proposed Motions, Paper 12; Order-Conduct of the
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`Proceedings, Paper 13.
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`7
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`Case CBM2014-00192
`Attorney Docket No: 39843-0005CP1
`provide Dr. Bloom with a bias against the claims.” See Paper 40 at 6; Papers
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`22/23. This argument is unsustainable, as it is unproven and illogical.
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`Substantively, while Dr. Bloom is employed by a third-party company, there
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`is no evidence that Dr. Bloom perceived similarities between his employer’s
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`products and the claims of the patent prior to his deposition. That is, whether
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`alleged similarities existed or not, an allegation of bias would require a showing
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`that Dr. Bloom did indeed perceive such similarities when rendering the opinions
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`offered in the instant case. Smartflash had the opportunity to question Dr. Bloom
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`on this point during his deposition, yet the record is without such evidence6.
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`Logically, this argument is equally flawed. Without more, Smartflash seeks
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`to establish bias based on mere affiliation of an expert with an operating company.
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`6 Dr. Bloom did not perceive the insinuated infringement. See Exhibit
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`2056,174:23-175:5.
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`Q. In preparing your report, did you consider whether [a third-party
` company]'s system that enables limited use of paid for and/or
` licensed content is covered by any of the claims for which you
` provided an opinion?
`
`A. No, I didn't consider that.
`
`Q. Is there a reason that you didn't?
`
`A. It didn't occur to me.
`
`
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`8
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`Case CBM2014-00192
`Attorney Docket No: 39843-0005CP1
`Surely, for an expert to have bias, it is necessary for the expert to have knowledge
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`of the facts giving rise to the same. Mere employment is not enough, nor is
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`knowledge of the products offered by one’s employer. It is instead necessary to
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`perceive infringement for bias to exist, and for such perception to exist at the time
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`of an opinion’s rendering. On a record that is without a showing of either, this
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`argument fails to demonstrate the necessary prerequisite of knowledge as of the
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`time of the declaration.
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`As if recognizing the flaw in its position, Smartflash then asserts that its
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`“inquiry into whether Dr. Bloom considered whether his [employer’s] products
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`would read on the Smartflash patent claims reflects on the depth of Dr. Bloom’s
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`investigation and patentability opinion.” Paper 40 at 5. Based on Dr. Bloom’s
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`leadership role in managing a team of systems engineers and without providing
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`any additional foundation, Smartflash then professes that “[i]t is unfathomable that
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`a person in such a position would not consider whether any of his company’s own
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`products read on the patent claims he is evaluating.” Paper 40 at 6. Smartflash
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`then further attempts to belittle the rest of Dr. Bloom’s opinion and asks the Board
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`to “take that fact into consideration in assigning weight to Dr. Bloom’s testimony.”
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`Id. This line of reasoning is fatally flawed because it neglects to account for the
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`fact that Smartflash failed to impute knowledge of the alleged relevance by a third-
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`party company to Dr. Bloom at the time of his rendering of his declaration. In
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`9
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`Attorney Docket No: 39843-0005CP1
`other words, Smartflash never establishes a necessary condition for the alleged bias
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`to exist. Without the allged bisis, any insinuation of infringement7 by a third-party
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`company unrelated to the instant CBM proceeding is of no consequence to the
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`validity of the patent claims at issue.
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`Because Smartflash solicited a variety of opinions from Dr. Bloom that do
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`not tend to make any fact of consequence in this CBM proceeding, such portions of
`
`testimony should be excluded. See Rules 401 & 402.
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`III. CONCLUSION
`For the foregoing reasons, Petitioner requests that the evidence discussed
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`above be excluded.
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`
`
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`
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`Respectfully submitted,
`
`/Thomas A. Rozylowicz/
`
`Thomas A. Rozylowicz
`Reg. No. 50,620
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` 10/13/2015
`Date:
`
`
`
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`7To the extent that Patent Owner requested discovery into alleged evidence of non-
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`infringement and existence of non-infringing alternatives, the Board refused to
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`authorize Patent Owner to file such motions to compel discovery. See generally,
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`Patent Owner List of Proposed Motions, Paper 12; Order-Conduct of the
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`Proceedings, Paper 13.
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`10
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`Case CBM2014-00192
`Attorney Docket No: 39843-0005CP1
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`CERTIFICATE OF SERVICE
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`
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`Pursuant to 37 CFR §§ 42.6(e)(4) and 42.205(b), the undersigned certifies
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`that on October 13, 2015, a complete and entire copy of this Petitioner’s Reply in
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`Support of Motion to Exclude Evidence Under 37 C.F.R. § 42.64(c) and Exhibit
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`1052 was provided via email to the Patent Owner by serving the correspondence
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`email addresses of record as follows:
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`Michael R. Casey
`J. Scott Davidson
`Davidson Berquist Jackson & Gowdey, LLP
`8300 Greensboro Dr., Suite 500
`McLean, VA 22102
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`Email: mcasey@dbjg.com
`jsd@dbjg.com
` docket@dbjg.com
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`/Diana Bradley/
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`Diana Bradley
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(858) 678-5667
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