UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS AMERICA, INC. AND
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner
`
`v.
`
`SMARTFLASH LLC,
`Patent Owner
`
`Case CBM2015-00059
`Patent 8,336,772
`
`
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`
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`PETITIONER’S MOTION FOR JOINDER
`UNDER 35 U.S.C. § 325(c) AND 27 C.F.R. § 42.222(b)
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
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`SAMSUNG ELECTRONICS AMERICA, INC. AND
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner
`
`v.
`
`SMARTFLASH LLC,
`Patent Owner
`
`Case CBM2015-00059
`Patent 8,336,772
`
`
`
`
`
`PETITIONER’S MOTION FOR JOINDER
`UNDER 35 U.S.C. § 325(c) AND 27 C.F.R. § 42.222(b)
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`I.
`
`RELIEF REQUESTED
`
`Attorney Docket No.: 39843-0008CP3
`Case CBM2015-00059
`
`Samsung Electronics America, Inc. and Samsung Electronics Co., Ltd.
`
`(“Petitioner” or “Samsung”) hereby moves for joinder, pursuant to 35 U.S.C. § 325(c)
`
`and 37 C.F.R. § 42.222(b), of its earlier-filed CBM2015-00059 Petition (“Samsung
`
`Petition”) for Covered Business Method (“CBM”) review of U.S. Patent No. 8,336,772 (“the
`
`’772 Patent”) with each of the CBM reviews CBM2015-00031, 00032, and 00033
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`(hereinafter jointly referred to as the “Apple CBM Proceedings”), which were
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`instituted by the Board on May 28, 2015. See CBM2015-00031, 00032, and 00033,
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`Pap. 11.
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`Joinder is appropriate because, among other reasons discussed in Section III
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`below, it will promote efficient resolution of the validity of the ’772 Patent. The
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`Board has consolidated the schedules of the Apple CBM Proceedings, since each of
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`those Proceedings challenge a subset of the ’772 Patent claims under only 35 U.S.C.
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`§ 101. See CBM2015-00031, 00032, and 00033, Pap. 11. As explained in more
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`detail below, the Samsung Petition is similarly limited to 35 U.S.C. § 101, and it
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`challenges fewer than all claims collectively challenged in the Apple CBM Proceedings.
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`Thus, this case is ideal for joinder, as joinder could be granted without introducing
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`any new grounds against any new claims.
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`In fact, because the Apple CBM Proceedings are at an early stage, joinder
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`would also have, at most, a minimal impact on the consolidated schedules of the
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`1
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`proceedings.
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`Attorney Docket No.: 39843-0008CP3
`Case CBM2015-00059
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`II.
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`STATEMENT OF MATERIAL FACTS
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`1.
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`On November 25, 2014, Apple filed three petitions for CBM review of
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`the ’772 Patent (“Apple Petitions”). As a whole, these three petitions asserted
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`grounds of unpatentability of claims 1, 5, 8, 10, 14, 19, 22, 25, 26, 30, and 32 of the
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`’772 Patent under each of 35 U.S.C. §§ 101 and 103.
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`2.
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`On March 6, 2015, Patent Owner filed its preliminary responses in the
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`Apple CBM Proceedings.
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`3.
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`On May 28, 2015, the Board instituted CBM review in each of the
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`Apple CBM Proceedings, determining that Apple had shown that it is more likely
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`than not that claims 1, 5, 8, 10, 14, 19, 22, 25, 26, 30, and 32 are invalid under 35
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`U.S.C. § 101 as being directed to patent-ineligible subject matter. See CBM2015-
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`00031, 00032, 00033, Pap. 11. The Board declined to institute Apple’s proposed
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`grounds of rejection under 35 U.S.C. § 103. See id.
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`4.
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`On January 15, 2015, Samsung filed the Samsung Petition for review of
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`the ’772 Patent. The Samsung Petition asserted that claims 5, 10, 14, 26, and 32 of
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`the ’772 Patent are invalid under 35 U.S.C. § 101. CBM 2015-00059, Pap. 2.
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`5.
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`On May 11, 2015, Patent Owner filed its preliminary response in
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`CBM2015-00059.
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`6. As the table below indicates, the claims challenged in the Samsung
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`
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`2
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`Attorney Docket No.: 39843-0008CP3
`Case CBM2015-00059
`Petition are only a subset of the claims challenged in each of the three Apple CBM
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`
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`Proceedings, making it possible to comprehensively join grounds proposed by
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`Samsung with grounds proposed by Apple by joining the Samsung Petition to the
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`Apple CBM Challenges, with claims divided among the instituted proceedings in
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`the manner set forth by the Apple Petitions.
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`
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`CBM2015-00031 CBM2015-00032 CBM2015-00033
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`Claims challenged
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`1, 5, 8, and 10
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`14, 19, and 22
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`25, 26, 30, and 32
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`under 35 U.S.C. §
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`101 in Apple CBM
`
`Proceedings
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`Claims challenged
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`5 and 10
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`14
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`26 and 32
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`under 35 U.S.C. §
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`101 in Samsung
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`Petition
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`
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`7. Based upon the institution date of May 28, 2015 for the Apple CBM
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`Proceedings, the one-month-from-institution date under 37 C.F.R. § 42.222(b) falls
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`on June 28, 2015, a Sunday. The present motion for joinder is therefore timely under
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`35 U.S.C. § 21(b)
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`
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`3
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`
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`III. DISCUSSION
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`Attorney Docket No.: 39843-0008CP3
`Case CBM2015-00059
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`The requested joinder will serve to secure the just, speedy, and inexpensive
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`resolution of these proceedings, consistent with Congressional intent. Indeed,
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`under 35 U.S.C. § 325(c), the Director was provided authority to consolidate
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`review proceedings involving petitions challenging the same patent:
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`If more than 1 petition for a post-grant [or covered business method]
`review under this chapter is properly filed against the same patent and
`the Director determines that more than 1 of these petitions warrants
`the institution of a post-grant review under section 324, the Director
`may consolidate such reviews into a single post-grant [or covered
`business method] review.
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`Similarly, 37 C.F.R. § 42.222(b) provides that:
`
`Joinder may be requested by a patent owner or petitioner. Any request
`for joinder must be filed, as a motion under § 42.22, no later than one
`month after the institution date of any post-grant [or covered business
`method] review for which joinder is requested.”
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`The Board has further provided that a motion for joinder should: (1) set forth the
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`reasons why joinder is appropriate; (2) identify any new grounds of unpatentability
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`asserted in the petition; (3) explain what impact (if any) joinder would have on the
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`trial schedule of the existing proceeding; and (4) address specifically how briefing
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`and discovery may be simplified. See, e.g., Kyocera Corp. v. Softview LLC,
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`IPR2013-00004, Paper 15 at 4 (Apr. 24, 2013). These factors are addressed below
`4
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`and all point to granting the instant motion.
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`A.
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`Joinder is Appropriate
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`Attorney Docket No.: 39843-0008CP3
`Case CBM2015-00059
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`The Board has authority to join a properly-filed CBM petition to an instituted
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`CBM proceeding. See 35 U.S.C. § 325(c). Petitioner submits that this Motion for
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`Joinder is timely under 35 U.S.C. § 325(c) and 37 C.F.R. §§ 42.22 and 42.222(b).
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`Specifically, 37 C.F.R. § 42.222 provides that a motion for joinder must filed “no
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`later than one month after the institution date of any post-grant review for which
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`joinder is requested.” Inasmuch as the relevant Apple CBM Proceedings were
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`instituted on May 28, 2015. See CBM2015-00031, -00032, -00033, at Pap. 11. The
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`Petitioner is filing this Motion for Joinder on June 29, 2015, which is no later than
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`one month from the institution of the Apple CBM Proceedings when accounting for
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`June 28, 2015 falling on a Sunday.
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`Further, joinder is appropriate as the earlier filed Samsung Petition involves
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`the same ’772 Patent and same ground of patent eligibility, applied to a subset of the
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`claims already instituted by the Board in the Apple CBM Proceedings. In more
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`detail, as reflected by the above table, Samsung previously sought Covered Business
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`Method review of claims 5, 10, 14, 26, and 32 of the ’772 Patent on §101 grounds in
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`CBM2015-00059. In the Apple CBM Proceedings, the Board instituted review of
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`claims 1, 5, 8, 10, 14, 19, 22, 25, 26, 30, and 32 of the same ‘772 Patent on the basis
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`of 35 U.S.C. §101. Although, the Board has not yet issued a decision regarding
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`5
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`Attorney Docket No.: 39843-0008CP3
`Case CBM2015-00059
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`institution in CBM2015-00059, the Patent Owner is presently “on notice” of CBM
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`review of §101 as applied to more claims than challenged by Petitioner. In other
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`words, granting joinder will not create surprise or hardship for the Patent Owner. In
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`fact, Patent Owner already filed its Preliminary Responses in CBM 2015-00059 on
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`May 11, 2015, advancing responses to the very grounds that are set forth in the
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`Samsung Petition.
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`Notably, joinder is not required for the Board to find that the Samsung Petition
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`warrants institution of a CBM review.1 Therefore, joinder of the proceedings is
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`solicited simply to facilitate the efficient adjudication of all proceedings, particularly
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`in light of the above-noted commonalities. Indeed, because the issue of whether the
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`challenged claims are directed to patent-eligible subject matter is an issue of law2,
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`joinder of the Samsung Petition with the instituted Apple CBM Proceedings would
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`promote an efficient and holistic adjudication of the proceedings involving the same
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`patent, same claims, and same grounds of patent eligibility.
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`Accordingly, for at least the reasons outlined in this motion, joinder of the
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`Samsung Petition with the Apple CBM Proceedings is appropriate.
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`B.
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`No New Grounds of Unpatentability Are Asserted In the Earlier
`Filed Samsung Petition
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` 2
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` See Apple Inc. v. Smartflash LLC, CBM2015-00015, Paper 23 at 18.
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`6
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`Attorney Docket No.: 39843-0008CP3
`Case CBM2015-00059
`The Samsung Petition does not assert any new grounds of unpatentability.
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`Indeed, it exclusively challenged the patent eligibility (i.e. § 101 eligibility) of a
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`subset (i.e., claims 5, 10, 14, 26, and 32) of the claims at issue in the Apple CBM
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`Proceedings (i.e., claims 1, 5, 8, 10, 14, 19, 22, 25, 26, 30, and 32). CBM2015-
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`00031, 00032, and 00033, Paps. 5, 11.
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`C.
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`Joinder Should Not Have Any Impact On the Trial Schedule
`And Costs For the Existing Review
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`When ruling on motions for joinder between an instituted IPR proceeding and
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`a new petition, the impact of the proposed joinder on trial schedule is considered.
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`Compare Oxford Nanopore Technologies LTD. v. University of Washington and
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`UAB Research Foundation, IPR2015-00057 (The Board elected to exercise its
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`discretionary power to grant joinder so that IPR2015-00057, challenging claim 10 of
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`a patent on obviousness grounds based on a combination of art, was joined with
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`another instituted petition (i.e., IPR2014-00513) that also challenged claim 10, albeit
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`on anticipation grounds referencing non-overlapping art) with Wavemarket Inc. v.
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`Location Labs Paper 13 at 6-8 (The Board denied joinder because joinder would
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`introduce significant delay to the instituted proceeding (i.e., IPR2014-00199) at an
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`advanced stage, since a final written determination was less than five months away).
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`As will be demonstrated below, joinder need not affect any scheduling with regard to
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`the Apple CBM Proceedings.
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`In this case, joinder need not have an impact on the trial schedule, and it
`7
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`Attorney Docket No.: 39843-0008CP3
`Case CBM2015-00059
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`should introduce little, if any, additional costs for the existing review. In the Apple
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`CBM Proceedings, Patent Owner’s responses are due July 29, 2015. The institution
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`decision for the Samsung Petition is expected any time after mid-July. If CBM
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`review is instituted and joinder granted for the Samsung Petition, it is possible for the
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`Board to shorten the period of the Patent Owner’s responses, given the overlapping
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`subject matter. Here, again, the Samsung Petition sought CBM review of grounds
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`for which CBM review has been instituted in the Apple CBM Proceedings. Patent
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`Owner already filed its Preliminary Response on May 11, 2015. Patent Owner will
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`experience little, if any, prejudice as a result of accelerated due date of its responses
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`because Patent Owner will have been considering and preparing full responses to
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`grounds under § 101 since May 11, 2015. Accordingly, requiring Patent Owner’s
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`responses to be filed within a shortened period, for example, by July 29, 2015, would
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`not impose surprise or hardship on Patent Owner. To the extent this shorted period is
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`not deemed to be practical, however, and to the extent Patent Owner deems it
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`necessary despite its present and longstanding awareness of arguments and grounds
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`asserted by the Samsung Petition, Samsung will be amenable to reasonable
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`accommodations designed to avoid or minimize impositions on Patent Owner (e.g.,
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`provision of additional supplemental responses addressing peculiarities of the
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`Samsung Petition after current Due Date 1, on August 12, 2015). The remainder of
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`the existing schedule could then remain unchanged, as outlined in the attached
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`8
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`Attorney Docket No.: 39843-0008CP3
`Case CBM2015-00059
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`Petitioner’s Proposed Schedule. Alternatively, Samsung is amenable, in coordination
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`with Apple and Patent Owner, to other arrangements the Board deems appropriate.
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`Accordingly, the proposed joinder of proceedings will not necessarily have
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`any dilatory impact on the schedule of the Apple CBM proceedings. Rather, joining
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`the earlier filed Samsung Petition for CBM review of the ‘772 Patent on the sole
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`ground of § 101 to the Apple CBM Proceedings will promote efficiencies.
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`D.
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`Joinder Will Simplify Briefing and Discovery, and it Will
`Otherwise Promote Efficient Adjudication Because All
`Proceedings Share a Single Oral Hearing
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`Because grounds of unpatentability under § 101 are directed to legal issues,
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`there is necessarily less discovery involved than would normally be involved
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`with regard to grounds of unpatentability under §§ 102 and 103, which are
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`directed to a larger factual inquiry. See, e.g., CBM2015-00017, Paper 22 at page
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`10 (finding that consideration of claim 7 under § 101 is a question of law).
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`Apple and Petitioner rely on different declarations in their respective
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`proceedings. In particular, the Apple CBM petitions include a Declaration of Mr.
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`Anthony J. Wechselberger while the Samsung Petition includes a Declaration of
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`Dr. Jeffrey Bloom and a Declaration of Mr. Steven Blumenfeld. Petitioner will
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`work with Patent Owner to coordinate reasonable availability of both Dr. Jeffrey
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`Bloom and Mr. Steven Blumenfeld for deposition in order to facilitate reduced
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`travel expenses and related preparation time, thus reducing any attendant burdens
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`9
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`Attorney Docket No.: 39843-0008CP3
`Case CBM2015-00059
`perceived by Patent Owner. Moreover, to the extent Patent Owner relies upon
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`one or more common declarant(s) in its responses to the earlier filed Samsung
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`Petition and in the Apple CBM Proceedings, which would seem likely, joinder or
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`coordination of these proceedings will permit efficient discovery with regard to
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`the common declarant(s).
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`In addition, where, as here, multiple reviews and petition for review involve
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`the same claims of the same patent, there are general efficiencies gained in
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`coordinated briefing and discovery with regard to common issue of patent
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`eligibility, even when the reviews and petition for review are based on evolving §
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`101 jurisprudence. Moreover, there exist inherent efficiencies in simultaneously
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`preparing briefings and discovery involving a common claims, as the underlying
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`subject matter (i.e., the claims and their related disclosure), and thus familiarity
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`therewith, will be shared. Indeed, participation in an oral argument, if requested,
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`and subsequent preparation of one or more final written decisions will similarly
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`benefit from the coordination of any proceeding resulting from the earlier filed
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`Samsung Petition.
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`IV.
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`JOINDER RECORD AND PARTICIPATION
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`Above, Samsung solicits joinder with the Apple CBM Proceedings. In doing
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`so, Samsung is amenable to reasonable accommodations designed to promote speed
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`and efficiency. Among them, Samsung seeks to gain consideration of arguments and
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`10
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`Attorney Docket No.: 39843-0008CP3
`Case CBM2015-00059
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`evidence furnished when filing the Samsung Petition. Samsung further seeks to
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`maintain an active role. Samsung believes its arguments/evidence/participation
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`could each be useful in ensuring a full and fair assessment of the implicated ’772
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`Patent claims under 35 U.S.C. § 101. Indeed, unlike the Apple CBM Petitions which
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`were filed temporally proximate to the Ultramercial Decision and prior to several
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`that are briefed in the Samsung Petition, a comprehensive discussion and evidence
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`are elevated by the Samsung Petition.3 To illustrate further, the Samsung Petition
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`provides comprehensive discussion of, and application of, this recently-developed
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`case law that the instituted petitions did not address, paired with enhanced
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`evidentiary foundation in the form of testimony from a fact witness, Mr. Steven
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`Blumenfeld, and an expert witness, Dr. Jeffrey Bloom.
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`That said, if the Board does not grant joinder of the arguments articulated in
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`the Samsung Petition and accompanying evidence, Samsung alternatively
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`requests joinder, but accepts that the Board would, in that case, proceed on the
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`3 Because the instituted petitions were filed close in time to the Ultramercial decision
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`and prior to the DDR decision, the Apple Petitions did not attempt to apply the legal
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`framework or address issues in Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709 (Fed.
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`Cir. 2014) and DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245, (Fed. Cir.
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`2014).
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`11
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`Attorney Docket No.: 39843-0008CP3
`Case CBM2015-00059
`basis of arguments and evidence presented by Apple Inc. (“Apple”) in the Apple
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`CBM Proceedings.
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`V.
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`CONCLUSION
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`For the foregoing reasons, Samsung respectfully requests that the Board
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`grant this Motion for Joinder of the Samsung Petition with each of the Apple CBM
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`Proceedings. This request promotes the interest of just, speedy, and inexpensive
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`resolution of the proceedings, and it is timely, as it is being filed within the
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`prescribed one-month-from-institution date of June 28, 2015, accounting for June
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`28, 2015 falling on a Sunday. If arguments or evidence presented in Samsung’s
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`Petition prove an impediment to joinder, Samsung indicates its desire to
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`alternatively request joinder exclusively on the basis of arguments and evidence
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`presented by Apple Inc. (“Apple”) in the Apple CBM Proceedings.
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`12
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`Attorney Docket No.: 39843-0008CP3
`Case CBM2015-00059
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`Respectfully submitted,
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`/W. Karl Renner/
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`W. Karl Renner, Reg. No. 41,265
`Fish & Richardson P.C.
`P.O. Box 1022
`Minneapolis, MN 55440-1022
`T: 202-783-5070
`F: 202-783-2331
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`/Thomas A. Rozylowicz/
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`Thomas Rozylowicz, Reg. No. 50,620
`Fish & Richardson P.C.
`P.O. Box 1022
`Minneapolis, MN 55440-1022
`T: 202-783-5070
`F: 202-783-2331
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` 6/29/2015
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`Dated:
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` 6/29/2015
`Dated:
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`13
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`Attorney Docket No.: 39843-0008CP3
`Case CBM2015-00059
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`
`
`PETITIONER’S PROPOSED SCHEDULE
`
`Due Date 1
`Patent owner’s
`response to the
`petition
`Patent owner’s motion
`to amend the patent
`
`Due Date 2
`Petitioner’s reply to
`patent owner’s
`response to petition
`Petitioner’s opposition
`Due Date 3
`Patent owner’s reply to
`petitioner’s opposition
`to motion to amend
`Due Date 4
`Motion for observation
`regarding cross-
`examination of reply
`witness Motion to
`Due Date 5
`Response to
`observation Opposition
`Due Date 6
`Reply to opposition to
`motion to exclude
`Due Date 7
`Oral argument (if
`
`Current Schedule in
`CBM2015-00031, -00032,
`-00033 (See Pap. 12)
`July 29, 2015
`
`September 29, 2015
`
`Petitioner’s Proposal
`for Schedule with
`Joinder
`July 29, 2015
`To the extent necessary,
`a 7-page supplemental
`Response addressing the
`earlier filed Samsung
`Petition may be
`submitted on August 12,
`2015 (assuming
`institution decision circa
`July 28, 2015)
`September 29, 2015
`
`October 29, 2015
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`October 29, 2015
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`November 19, 2015
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`November 19, 2015
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`December 3, 2015
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`December 3, 2015
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`December 10, 2015
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`December 10, 2015
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`January 6, 2016
`
`January 6, 2016
`
`14
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`Attorney Docket No.: 39843-0008CP3
`Case CBM2015-00059
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`CERTIFICATE OF SERVICE
`
`
`Pursuant to 37 CFR §§ 42.6(e)(4) and 42.205(b), the undersigned certifies
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`U.S. Patent No. 8,336,772 Case CBM2015 00059
`
`Case CBM2015 00059
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`
`
`
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`that on June 29, 2015, a complete and entire copy of this Petitioner’s Motion for
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`Joinder was provided via email to the Patent Owner by serving the correspondence
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`email addresses of record as follows:
`
`Michael R. Casey
`J. Scott Davidson
`Davidson Berquist Jackson & Gowdey, LLP
`8300 Greensboro Dr., Suite 500
`McLean, VA 22102
`
`
` mcasey@dbjg.com
` jsd@dbjg.com
`docket@dbjg.com
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`
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`Email:
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`
`
`/Diana Bradley/
`Diana Bradley
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(858) 678-5667
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