UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SMARTFLASH LLC,
`Patent Owner.
`________________________
`Case CBM2015-00016
`Patent 8,033,458 B2
`________________________
`
`PATENT OWNER’S MOTION TO EXCLUDE EVIDENCE
`
`
`
`
`
`
`
`
`
`
`________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SMARTFLASH LLC,
`Patent Owner.
`________________________
`Case CBM2015-00016
`Patent 8,033,458 B2
`________________________
`
`PATENT OWNER’S MOTION TO EXCLUDE EVIDENCE
`
`
`
`
`
`
`
`
`
`
`
`TABLE OF CONTENTS
`
`B.
`C.
`
`
`Statement of Precise Relief Requested ............................................................ 1
`I.
`Patent Owner Smartflash Timely Objected to Petitioner’s Exhibits ............... 1
`II.
`III. Argument ......................................................................................................... 1
`A.
`Exhibit 1202 is Inadmissible Other Evidence of the Content of a
`Writing, Irrelevant, and Cumulative ..................................................... 1
`Exhibit 1208 is Uncited and thus Irrelevant .......................................... 3
`Exhibits 1206, 1207, 1209, 1211, 1212, 1216, 1217, 1219, 1226, and
`1227 are Not Alleged to be Invalidating Prior Art and thus are
`Irrelevant ............................................................................................... 5
`Exhibits 1203, 1205, 1213, 1214, 1215, and 1218 are not the Basis for
`any Invalidity Grounds for Which CBM2015-00016 was Initiated and
`thus are Irrelevant .................................................................................. 6
`Exhibit 1220 Lacks Foundation, is Unreliable, and Relies on
`Irrelevant Exhibits ................................................................................. 8
`IV. Conclusion ..................................................................................................... 13
`
`
`D.
`
`E.
`
`i
`
`
`
`
`
`
`I.
`
`Statement of Precise Relief Requested
`
`Pursuant to 37 C.F.R. §§ 42.62 and 42.64(c), Patent Owner Smartflash LLC
`
`moves to exclude Exhibits 1202, 1203, 1205, 1206, 1207, 1208, 1209, 1211, 1212,
`
`1213, 1214, 1215, 1216, 1217, 1218, 1219, 1220, 1226 and 1227.
`
`II.
`
`Patent Owner Smartflash Timely Objected to Petitioner’s Exhibits
`
`Patent Owner Smartflash LLC timely objected to CBM2015-00016 Exhibits
`
`1202, 1203, 1205, 1206, 1207, 1208, 1209, 1211, 1212, 1213, 1214, 1215, 1216,
`
`1217, 1218, 1219, 1220, 1226 and 1227 by serving Patent Owner’s Objections to
`
`Admissibility of Evidence on April 24, 2015. Exhibit 2100.
`
`III. Argument
`Pursuant to 37 C.F.R. § 42.64(c), the Federal Rules of Evidence apply in
`
`Covered Business Method Review proceedings.
`
`A. Exhibit 1202 is Inadmissible Other Evidence of the Content of a
`Writing, Irrelevant, and Cumulative
`
`Patent Owner moves to exclude Exhibit 1202, (Plaintiff’s First Amended
`
`Complaint) on grounds that it is: inadmissible other evidence of the content of a
`
`writing under FRE 1004; inadmissible under FRE 402 because it fails the test for
`
`relevance set forth in FRE 401; and, even if relevant, is cumulative evidence under
`
`FRE 403.
`
`Petitioner cites Exhibit 1202 for the sole purpose of showing Patent Owner’s
`
`description of the subject matter of U.S. Patent 8,033,458 (“the ‘458 Patent”) as
`
`
`
`1
`
`
`
`
`
`“cover[ing] a portable data carrier for storing data and managing access to the data
`
`via payment information and/or use status rules” and “cover[ing] a computer
`
`network … that serves data and manages access to data by, for example, validating
`
`payment information.” Corrected Petition at 12 (citing Ex. 1202 ¶ 17). Petitioner
`
`does not need to cite to Exhibit 1202 to show the subject matter of the ‘458 Patent,
`
`however, because Exhibit 1201, the actual ‘458 Patent, is in evidence without
`
`objection. Under FRE 1004, other evidence of the content of a writing (here the
`
`‘458 Patent) is admissible if the original is lost, cannot be obtained, has not been
`
`produced, or the writing is not closely related to a controlling issue. None of those
`
`conditions apply here, given that the ‘458 Patent is in evidence and is the subject of
`
`the trial.
`
`Patent Owner’s description of the ‘458 Patent in Exhibit 1202 is not relevant
`
`to any of the issues here. Petitioner’s expert, Anthony J. Wechselberger’s
`
`Declaration, Exhibit 1220, (“Wechselberger Declaration”) does not cite Exhibit
`
`1202. The Board’s April 10, 2015 Decision – Institution of Covered Business
`
`Method Patent Review and Denying Motion for Joinder 37 C.F.R. § 42.208, 37
`
`C.F.R. § 42.222(b) (“PTAB Decision”), Paper 23, does not cite Exhibit 1202.
`
`Exhibit 1202 does not appear to make a fact of consequence in determining this
`
`action more or less probable than it would be without Exhibit 1202. As such,
`
`
`
`2
`
`
`
`
`
`Exhibit 1202 does not pass the test for relevant evidence under FRE 401 and is not
`
`admissible per FRE 402.
`
`Even if Exhibit 1202 was found to be relevant, it should also be excluded
`
`under FRE 403 as cumulative of Exhibit 1201.
`
`In the related CBM2014-00106, the Board declined to exclude the same
`
`exhibit because “[Patent Owner’s] characterization of the ‘458 patent in prior
`
`proceedings are (sic) relevant to the credibility of its characterization of the ‘458
`
`patent in this proceeding.” CBM2014-00106, Paper 52 at 25. There is no
`
`credibility issue here, however, that makes Exhibit 1202 relevant. There is nothing
`
`about Patent Owner’s characterization of the ‘458 Patent in this proceeding – that
`
`representative claim 1 “does not recite a ‘financial product or service’” in the way
`
`Congress intended (Patent Owner’s Preliminary Response, Paper 19 at 5-10) – that
`
`is contradicted by Exhibit 1202 such that the credibility of Patent Owner’s
`
`characterization is an issue. As such Exhibit 1202 is irrelevant and inadmissible.
`
`B. Exhibit 1208 is Uncited and thus Irrelevant
`Neither the Corrected Petition, nor the Wechselberger Declaration, nor the
`
`PTAB Decision cite to Exhibit 1208 (Russell Housley and Jan Dolphin, “Metering:
`
`A Pre-pay Technique,” Storage and Retrieval for Image and Video Databases V,
`
`Conference Volume 3022, 527 (January 15, 1997))(“the Uncited Exhibit”). The
`
`Uncited Exhibit does not appear to make a fact of consequence in determining this
`
`
`
`3
`
`
`
`
`
`action more or less probable than it would be without the Uncited Exhibit. As
`
`such, the Uncited Exhibit does not pass the test for relevant evidence under FRE
`
`401 and is not admissible per FRE 402.
`
`In CBM2014-00106 the Board declined to exclude exhibits that were
`
`uncited, finding that “[b]ecause Mr. Wechselberger attests that he reviewed these
`
`exhibits in reaching the opinions he expressed in this case, Patent Owner has not
`
`shown that they are irrelevant under FRE 401 and 402.” CBM2014-00106, Paper
`
`52 at 25. The Board’s analysis is inapplicable here because Exhibit 1208 is not
`
`listed among the items Mr. Wechselberger reviewed. Exhibit 1220 at p. 70-71.
`
`Moreover, the Board’s conclusion in CBM2014-00106 that mere review by an
`
`expert in reaching an opinion renders an exhibit relevant under FRE 401 and thus
`
`admissible under FRE 402 is overly broad under the Federal Rules of Evidence.
`
`Underlying facts and data need not themselves be admissible for an expert to rely
`
`on them in formulating an admissible opinion. FRE 703 (“An expert may base an
`
`opinion on facts or data in the case that the expert has been made aware of or
`
`personally observed. If experts in the particular field would reasonably rely on
`
`those kinds of facts or data in forming an opinion on the subject, they need not be
`
`admissible for the opinion to be admitted”). But nothing in the Federal Rules of
`
`Evidence supports that mere review of an exhibit by an expert renders the exhibit
`
`relevant or admissible. The Uncited Exhibit should be excluded.
`
`
`
`4
`
`
`
`
`
`C. Exhibits 1206, 1207, 1209, 1211, 1212, 1216, 1217, 1219, 1226, and 1227
`are Not Alleged to be Invalidating Prior Art and thus are Irrelevant
`
`Petitioner cites Exhibit 1206 (U.S. Patent No. 4,999,806)(“Chernow”)
`
`(Corrected Petition at 6, 7, 15, 17, 33, and 34), Exhibit 1207 (U.S. Patent No.
`
`5,675,734)(“Hair”) (Corrected Petition at 4, 15, 17, 33, and 34), Exhibit 1209 (U.S.
`
`Patent No. 4,878,245)(“Bradley”) (Corrected Petition at 15, 17, 27), Exhibit 1211
`
`(U.S. Patent No. 4,337,483)(“Guillou”) (Corrected Petition at 27), Exhibit 1212
`
`(U.S. Patent No. 5,103,392)(“Mori”) (Corrected Petition at 7, 33, and 34), Exhibit
`
`1216 (European Patent Application, Publication No. EP0809221A2)(“Poggio”)
`
`(Corrected Petition at 7, 16, 33, and 34), Exhibit 1217 (PCT Application
`
`Publication No. WO 99/43136)(“Rydbeck”) (Corrected Petition at 9 and 30),
`
`Exhibit 1219 (Eberhard von Faber, Robert Hammelrath, and Franz-Peter Heider,
`
`“The Secure Distribution of Digital Contents,” IEEE (1997))(“von Faber”)
`
`(Corrected Petition at 8), and Exhibit 1226 (U.S. Patent No.
`
`7,725,375)(“Shepherd”) (Corrected Petition at 32), Exhibit 1227 (International
`
`Publication No. WO 95/34857)(“Smith”) (Wechselberger Declaration ¶ 44).
`
`Although cited, neither the Corrected Petition nor the Wechselberger Declaration
`
`assert that 1206 (Chernow), Exhibit 1207 (Hair), Exhibit 1209 (Bradley), Exhibit
`
`1211 (Guillou), Exhibit 1212 (Mori), Exhibit 1216 (Poggio), Exhibit 1217
`
`(Rydbeck), Exhibit 1219 (von Faber), Exhibit 1226 (Shepherd) or Exhibit 1227
`
`(Smith) (“the Unasserted Exhibits”) are potentially invalidating prior art, either
`
`
`
`5
`
`
`
`
`
`alone or in combination with any other reference. The PTAB Decision did not
`
`base any of its analysis on the Unasserted Exhibits. Thus, the Unasserted Exhibits
`
`do not appear to make a fact of consequence in determining this action more or less
`
`probable than it would be without the Unasserted Exhibits. As such, the
`
`Unasserted Exhibits do not pass the test for relevant evidence under FRE 401 and
`
`are not admissible per FRE 402.
`
`In CBM2014-00106 the Board declined to exclude similarly unasserted
`
`exhibits, finding “[b]ecause these exhibits are evidence relied upon by Petitioner to
`
`support its assertions with respect to the state of the art and to knowledge of a
`
`person of ordinary skill in the art, which are relevant to obviousness, we are not
`
`persuaded that they are irrelevant under FRE 401 and 402.” CBM2014-00106,
`
`Paper 52 at 26 (emphasis added). The Board’s reasoning in CBM2014-00106 is
`
`inapplicable here, where review was instituted on § 101 statutory subject matter
`
`grounds only. The Board rejected the asserted § 103 obviousness grounds, making
`
`the state of the art and the knowledge of a person of ordinary skill in the art
`
`irrelevant. As such, the Unasserted Exhibits should be excluded.
`
`D. Exhibits 1203, 1205, 1213, 1214, 1215, and 1218 are not the Basis for any
`Invalidity Grounds for Which CBM2015-00016 was Initiated and thus
`are Irrelevant
`
`Petitioner cites Exhibit 1203 (U.S. Patent No. 5,925,127)(“Ahmad”), Exhibit
`
`1205 (U.S. Patent No. 5,940,805)(“Kopp”), Exhibit 1213 (U.S. Patent No.
`
`
`
`6
`
`
`
`
`
`5,530,235)(“Stefik ‘235”), Exhibit 1214 (U.S. Patent No. 5,629,980)(“Stefik
`
`‘980”), Exhibit 1215 (U.S. Patent No. 5,915,019)(“Ginter”), and Exhibit 1218 (JP
`
`Publication No. H11-164058A (translation))(“Sato”) (“the Alleged Prior Art
`
`Exhibits”) as alleged invalidating prior art. Corrected Petition at 19. The PTAB
`
`Decision, however, did not adopt any of the proposed invalidity grounds based on
`
`Exhibit 1203 (Ahmad), Exhibit 1205 (Kopp), Exhibit 1213 (Stefik ‘235), Exhibit
`
`1214 (Stefik ‘980), Exhibit 1215 (Ginter), or Exhibit 1218 (Sato) (“the Alleged
`
`Prior Art Exhibits”). Compare, PTAB Decision at 3 (table summarizing asserted
`
`grounds for challenging patentability under § 103), with PTAB Decision at 26
`
`(instituting covered business method patent review on § 101 and § 112 ¶ 2 grounds
`
`only). Thus, the Alleged Prior Art Exhibits fail the test for relevant evidence
`
`because nothing in the Alleged Prior Art Exhibits makes a fact of consequence in
`
`determining this action more or less probable than it would be without the Alleged
`
`Prior Art Exhibits. FRE 401(b). Being irrelevant evidence, the Alleged Prior Art
`
`Exhibits are not admissible. FRE 402.
`
`In CBM2014-00106 the Board declined to exclude similar alleged prior art
`
`that was uninstituted “[b]ecause these exhibits are evidence relied upon by
`
`Petitioner to support its assertions with respect to the state of the art and to
`
`knowledge of a person of ordinary skill in the art, which are relevant to
`
`obviousness, we are not persuaded that they are irrelevant under FRE 401 and
`
`
`
`7
`
`
`
`
`
`402.” CBM2014-00106, Paper 52 at 26 (emphasis added). The Board’s prior
`
`reasoning is inapplicable here, where review was instituted on § 101 statutory
`
`subject matter grounds only. The Board rejected the asserted § 103 obviousness
`
`grounds, making the state of the art and the knowledge of a person of ordinary skill
`
`in the art irrelevant. As such, the Alleged Prior Art Exhibits should be excluded.
`
`E.
`
`Exhibit 1220 Lacks Foundation, is Unreliable, and Relies on
`Irrelevant Exhibits
`
`Petitioner’s citations to Exhibit 1220 (Declaration of Anthony J.
`
`Wechselberger In Support of Apple Inc.’s Petition for Covered Business Method
`
`Patent Review (“Wechselberger Declaration”)) are too extensive to catalog
`
`individually; 94 citations in its 80-page Corrected Petition. Patent Owner moves to
`
`exclude Exhibit 1220 on grounds that it lacks foundation and is unreliable because
`
`it fails to meet the foundation and reliability requirements of 37 CFR § 42.65(a)
`
`and FRE 702.
`
`37 CFR § 42.65(a) provides:
`
`§ 42.65 Expert testimony; tests and data.
` Expert testimony that does not disclose the
`(a)
`underlying facts or data on which the opinion is based
`is entitled to little or no weight. Testimony on United
`States patent law or patent examination practice will not
`be admitted.
`
`37 CFR § 42.65(a) (emphasis added). FRE 702 provides:
`
`RULE 702. TESTIMONY BY EXPERT WITNESSES
`
`
`
`8
`
`
`
`
`
`FRE 702.
`
`A witness who is qualified as an expert by knowledge,
`skill, experience, training, or education may testify in the
`form of an opinion or otherwise if:
`(a) The expert’s scientific, technical, or other specialized
`knowledge will help the trier of fact to understand the
`evidence or to determine a fact in issue;
`(b) The testimony is based on sufficient facts or data;
`(c) The testimony is the product of reliable principles and
`methods; and
`(d) The expert has reliably applied the principles and
`methods to the facts of the case.
`
`Patent Owner moves to exclude the Wechselberger Declaration because it
`
`does not disclose the underlying facts or data on which the opinions contained are
`
`based as required by 37 CFR § 42.65(a), given that it does not state the relative
`
`evidentiary weight (e.g., substantial evidence versus preponderance of the
`
`evidence) used by Mr. Wechselberger in arriving at his conclusions. “A finding is
`
`supported by substantial evidence if a reasonable mind might accept the evidence
`
`to support the finding.” Q. I. Press Controls, B.V. v. Lee, 752 F.3d 1371, 1378-
`
`1379 (Fed. Cir. 2014)(citing Consol. Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S.
`
`Ct. 206, 83 L. Ed. 126 (1938)). Proof by a “preponderance of the evidence” means
`
`“that it is more likely than not.” See, O2 Micro Int'l Ltd. v. Beyond Innovation
`
`Tech. Co., 449 Fed. Appx. 923, 928 (Fed. Cir. 2011).
`
`Petitioner has cited, and likely will cite again, Apple Inc. v. Smartflash LLC,
`
`CBM2014-00106, Paper 8 at 4, and Vibrant Media v. General Electric Company,
`
`
`
`9
`
`
`
`
`
`IPR2013-00172, Paper 50 at 42, for the proposition that an expert need not
`
`expressly set forth the evidentiary standard used in formulating opinions. See,
`
`Petitioner’s Reply to Patent Owner’s Response, Paper 35, at 21. In particular,
`
`Petitioner will likely rely on the Board’s conclusion in Vibrant Media that “it is
`
`within [the Board’s] discretion to assign the appropriate weight to be accorded to
`
`evidence based on whether the expert testimony discloses the underlying facts or
`
`data on which the opinion is based.” Petitioner’s Reply, Paper 35 at 21 (citing
`
`Vibrant Media, Paper 50 at 42). The Board’s conclusion in Vibrant Media,
`
`however, ignores that under FRE 702, the admissibility of expert testimony
`
`requires a finding not only that “the testimony is based on sufficient facts or data”
`
`(FRE 702(b)), but also that “the testimony is the product of reliable principles and
`
`methods” (FRE 702(c)) and that “the expert has reliably applied the principles and
`
`methods to the facts of the case” (FRE 702(d)).
`
`Here, the Board cannot assess under FRE 702 whether Mr. Wechselberger’s
`
`opinion testimony is “based on sufficient facts or data,” is “the product of reliable
`
`principles and methods,” or if Mr. Wechselberger “reliably applied the principles
`
`and methods to the facts of the case” given that Mr. Wechselberger did not disclose
`
`the standard against which he measured the quantum of evidence in arriving at his
`
`opinions. Specifically, when Mr. Wechselberger opines that:
`
`the challenged claims are
`In my opinion, all of
`unpatentable under 35 U.S.C. § 101 because they are
`10
`
`
`
`
`
`
`
`directed to ineligible subject matter – in particular, the
`abstract idea of paying for and controlling access to
`content. The challenged claims are directed to the
`general concept of providing access to content based on
`payment or rules (which the patent also refers to as DRM
`or digital rights management). This basic concept is not
`patentable and was well-known in the prior art.
`
`Exhibit 1220 at ¶ 82, is he saying that he examined the evidence and a reasonable
`
`mind would find sufficient evidence to support these findings (substantial
`
`evidence); OR is he saying that he examined the evidence and it is more likely than
`
`not that his findings are true (preponderance of the evidence). There is no basis for
`
`the Board to know, because the Wechselberger Declaration is silent on the standard
`
`he used. As such, the Wechselberger Declaration should be excluded because it
`
`fails to meet the requirements of 37 CFR § 42.65(a) and FRE 702.
`
`To the extent that Exhibit 1220 is not excluded in its entirety as requested
`
`above, Patent owner moves to exclude the following paragraphs for the following
`
`reasons:
`
`Paragraphs 28-71 (and any other portion of the Wechselberger Declaration
`
`that is directed to patentability under 35 U.S.C. § 103) are not relevant to the
`
`instituted proceeding because the trial as instituted is limited to patentability under
`
`35 U.S.C. § 101 and § 112 ¶2. FRE 401. Being irrelevant evidence, those
`
`paragraphs are not admissible. FRE 402.
`
`
`
`11
`
`
`
`
`
`Paragraphs 24-26 and 72-75 should be excluded as unreliable and lacking
`
`foundation. These paragraphs deal with the issue of indefiniteness and the
`
`Wechselberger Declaration does not prove that Mr. Wechselberger is an expert
`
`whose testimony is relevant to the issue. While Mr. Wechselberger may opine that
`
`he was “one of ordinary skill in the art,” he does not, however, state that he is an
`
`expert in the types of methods and systems defined by the challenged claims nor
`
`does he provide proof that he is an expert. Thus, Mr. Wechselberger has not
`
`proven that his opinions are proper expert opinions upon which the PTAB can rely
`
`as opposed to inadmissible lay opinions. FRE 701 and 702. Thus, those portions
`
`of the Wechselberger Declaration should be excluded under FRE 602 as lacking
`
`foundation.
`
`Paragraphs 76-105 should be excluded because they deal with the strictly
`
`legal issue of statutory subject matter for which Mr. Wechselberger is not an
`
`expert. Thus, those portions of the Wechselberger Declaration are inadmissible
`
`under FRE 401 as not relevant, under FRE 602 as lacking foundation, and under
`
`FRE 701 and 702 as providing legal opinions on which the lay witness is not
`
`competent to testify. Being irrelevant evidence, those paragraphs are not
`
`admissible. FRE 402.
`
`
`
`
`
`
`
`12
`
`
`
`
`
`IV. Conclusion
`For these reasons, Patent Owner Smartflash, LLC respectfully requests that
`
`the Board exclude Exhibits 1202, 1203, 1205, 1206, 1207, 1208, 1209, 1211, 1212,
`
`1213, 1214, 1215, 1216, 1217, 1218, 1219, 1220, 1226 and 1227.
`
`Dated: October 1, 2015
`
`
`
`
`
`/ Michael R. Casey /
`
`Michael R. Casey
`Registration No. 40,294
`Davidson Berquist
`
`Jackson & Gowdey, LLP
`8300 Greensboro Drive
`Suite 500
`McLean, VA 22102
`Telephone: (571) 765-7705
`Fax: (571) 765-7200
`Email: mcasey@dbjg.com
`Attorney for Patent Owner
`
`
`
`
`
`13
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that this PATENT OWNER’S MOTION
`
`TO EXCLUDE EVIDENCE, PATENT OWNER’S LIST OF EXHIBITS and
`
`Exhibit 2100 in CBM2015-00016 were served today, by agreement of the parties
`
`by emailing a copy to counsel for the Petitioner as follows:
`
`
`
`J. Steven Baughman (steven.baughman@ropesgray.com)
`Ching-Lee Fukuda (ching-lee.fukuda@ropesgray.com)
`Megan Raymond (megan.raymond@ropesgray.com)
`ApplePTABService-SmartFlash@ropesgray.com
`
`
` /
`
` Michael R. Casey /
`
`
`Michael R. Casey
`Registration No. 40,294
`Davidson Berquist
`
`Jackson & Gowdey, LLP
`8300 Greensboro Drive
`Suite 500
`McLean, VA 22102
`Telephone: (571) 765-7705
`Fax: (571) 765-7200
`Email: mcasey@dbjg.com
`Attorney for Patent Owner
`
`
`
`Dated: October 1, 2015
`
`
`
`
`
`
`
`14
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