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Filed on behalf of Patent Owner Network-1 Security Solutions, Inc.
`
`By: Robert G. Mukai, Esq.
`Charles F. Wieland III, Esq.
`BUCHANAN INGERSOLL & ROONEY PC
`1737 King Street, Suite 500
`Alexandria, Virginia 22314-2727
`Telephone (703) 836-6620
`Facsimile (703) 836-2021
`robert.mukai@bipc.com
`charles.wieland@bipc.com
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`
`AVAYA INC., DELL INC., SONY CORP. OF AMERICA, and
`HEWLETT-PACKARD CO.
`Petitioners
`
`v.
`
`NETWORK-1 SECURITY SOLUTIONS, INC.
`Patent Owner
`
`____________________
`
`Case IPR2013-000711
`Patent 6,218,930
`Administrative Patent Judges Joni Y. Chang, Justin T. Arbes, and Glenn J. Perry
`____________________
`
`PATENT OWNER’S OPPOSITION TO
`AVAYA’S MOTION TO EXCLUDE
`
`
`1
`IPR2013-00385 and IPR2013-00495 have been joined with this proceeding.
`
`

`

`Case No. IPR2013-00071
`
`
`
`
`In its Motion, Avaya makes two types of arguments:
`
`• evidentiary arguments as to why five categories of paragraphs of Dr. Knox’s 2nd
`
`Declaration should be excluded (addressed in Section I below); and
`
`• arguments relating to why the entire declaration should be excluded because it
`
`allegedly extends the Reply page limit (addressed in Section II below).
`
`I.
`
`Section I: The challenged paragraphs should not be excluded.
`
`A. The paragraphs not specifically cited in Network-1’s Reply should
`not be excluded.
`
`
`Avaya argues that each paragraph not specifically cited in Network-1’s
`
`Reply is inadmissible as irrelevant under Federal Rule of Evidence 401. Mot. at 2,
`
`4-5. These paragraphs fall into three sub-categories.
`
`Sub-category 1 includes 12 organizational paragraphs that provide structure
`
`to the declaration (¶¶227-229; 242; 246; 259 -260; 283; 300; 301; 315; 327), e.g.:
`
`
`
`Ex. N1-2024, ¶283. Such organizational paragraphs are regularly included in
`
`expert declarations and not cited in the corresponding briefs, as illustrated by
`
`comparing these challenged paragraphs with the corresponding uncited
`
`organizational paragraphs in Avaya’s own expert declarations. For example,
`
`paragraph 315 of Dr. Knox’s Declaration:
`
`
`
`

`

`
`
`Case No. IPR2013-00071
`
`(Ex. N1-2024) parallels uncited Paragraph 15 of Dr. Zimmerman’s Declaration:
`
`
`
`
`
`Ex. AV-1041; see id. ¶¶66-67.
`
`Sub-category 2 includes substantive paragraphs that are relevant under the
`
`controlling test set forth in Federal Rule of Evidence 401 (¶¶230-231; 241; 243;
`
`244-245; 247; 248; 249; 267-282; 284-291; 293; 298-299; 302; 316; 328-335).
`
`Under Rule 401, “[e]vidence is relevant if: (a) it has any tendency to make a fact
`
`more or less probable than it would be without the evidence; and (b) the fact is of
`
`consequence in determining the action.” Avaya does not apply this controlling
`
`standard to the paragraphs it moves to exclude because doing so would
`
`demonstrate that such evidence is relevant. Comparing the facts in Network-1’s
`
`Reply (which Avaya does not dispute are of consequence) with the evidence in the
`
`challenged paragraphs demonstrates that the challenged evidence has a “tendency
`
`to make [the facts in the Reply] more or less probable,” as shown in the following
`
`examples, including those specifically called-out by Avaya:
`
`2
`
`

`

`Case No. IPR2013-00071
`
`
`
`facts of consequence (from Reply)
`
`“‘the voltage’ in the proposed new
`
`evidence from challenged paragraph
`
`“‘the voltage’ in the proposed determining
`
`step refers to, and is the same as, the
`
`step refers to, and means the same thing
`
`“‘voltage level’ in the prior step.”
`
`as, the sensed ‘voltage level’ in the prior
`
`Reply at 2.
`
`sensing step.” ¶243.
`
`“the system disclosed in Matsuno
`
`“all that Matsuno determines based on the
`
`determines whether local power is
`
`sensed voltage (or voltage level) is
`
`being supplied based on whether the
`
`whether (a) the contact breaker points (8)
`
`contract breaker points (8) are
`
`are on or off, and (b) as a result, whether
`
`opened or closed.” Reply at 4.
`
`the local power supply is being supplied.”
`
`¶267 (called-out by Avaya, Mot. at 5)
`
`“If a device that cannot accept
`
`“if an access device with a resistive
`
`power (e.g., a device with a Bob
`
`termination (such as a Bob Smith
`
`Smith termination which is ‘unable
`
`termination) that cannot accept phantom
`
`to support remote power feed’
`
`remote power is connected to the
`
`(‘930, 3:7-11)) is connected and if
`
`subscriber line disclosed in Matsuno and
`
`local power stops, then the Matsuno
`
`the local power stops, then contact breaker
`
`circuitry would still send high
`
`points (8) will turn on and remote power
`
`power to the device even though it
`
`will be delivered to an access device that
`
`is not capable of accepting remote
`
`is not capable of accepting remote power.”
`
`3
`
`

`

`Case No. IPR2013-00071
`
`
`
`power.” Reply at 4.
`
`¶269 (called-out by Avaya, Mot. at 5)
`
`“Over 950 references have been
`
`“for the minimum of 917 references
`
`identified in the various
`
`identified in the various proceedings, it
`
`proceedings. … Distinguishing
`
`would take me 9170 hours to address the
`
`each would be time and cost
`
`known references (or almost 4 ½ years,
`
`prohibitive.” Reply at 5.
`
`working full time 40 hours a week, 50
`
`weeks a year).” ¶269 (called-out by
`
`Avaya, Mot. at 5).
`
`
`Avaya does not (and cannot) dispute that the evidence from these challenged
`
`paragraphs (on the right) tend to make the facts of consequence (on the left) more
`
`probable and, as a result, is relevant under Rule 401. The other paragraphs in this
`
`category (¶¶230-231; 241; 244-245; 247; 248; 249; 268; 270-282; 284-291; 293;
`
`298-299; 302; 316; 328-335) lay the necessary foundation for the cited paragraphs
`
`in the declaration and either directly support or build support for positions taken
`
`and arguments made in the Reply and are therefore relevant.
`
`Sub-category 3 includes four paragraphs from Dr. Knox’s Declaration that
`
`were inadvertently cited using incorrect paragraph numbers in the Reply. Dr.
`
`Knox’s 2nd Declaration was originally numbered starting with Paragraph 1 but was
`
`renumbered to start with Paragraph 219 to continue the numbering from his first
`
`declaration. See Ex. N1-2024 ¶220. In doing so, however, the paragraphs in
`
`4
`
`

`

`
`
`Argument 7 on page 5 of the Reply were inadvertently not renumbered. The
`
`Case No. IPR2013-00071
`
`correct corresponding correct paragraphs numbers are: ¶199 = ¶331; ¶120 = ¶332;
`
`¶121 = ¶333; and ¶122 = ¶334, which can easily be confirmed by comparing the
`
`substance of Argument 7 of the Reply (“Whether Network-1 was required to
`
`address each known reference”) with (a) paragraphs 119–122 from Dr. Knox’s 1st
`
`Declaration (Ex. N1-2015) which have nothing to do with this argument, and (b)
`
`paragraphs 331–334 from Dr. Knox’s 2nd Declaration, which correspond perfectly
`
`with the facts presented in the Reply. Accordingly, these paragraphs (while
`
`mistakenly cited) are “relied upon in Patent Owner’s Reply Brief.” Mot. at 5.
`
`Rather than applying the appropriate standard (Rule 401) to the challenged
`
`paragraphs, Avaya asserts a made-up rule (not found in the Rules of Evidence) that
`
`unless a paragraph in a supporting declaration is specifically referenced in a brief,
`
`it cannot be relevant because (a) a motion must provide a full statement of the
`
`reasons for relief (37 C.F.R. § 42.22(a)(2)), (b) a reply must comply with the
`
`contents of a motion (37 C.F.R. § 42.23(a)), and (c) because the challenged
`
`paragraphs are not cited in the Motion or Reply, they must be irrelevant because
`
`they are not a “reason for relief.” This argument fails at every level.
`
`First, Avaya misinterprets 37 C.F.R. § 42.22. A reply is not required to
`
`present a full statement of the reasons for relief (i.e., repeat every argument from a
`
`motion). In addition to the logistical challenge of repeating every argument in a 5
`
`5
`
`

`

`
`
`page reply, 37 C.F.R. § 42.23(b) confirms the exact opposite – that a reply is not
`
`Case No. IPR2013-00071
`
`required to (and may be prohibited from) presenting all “reasons for relief”
`
`because it can only respond to arguments raised in an opposition: “(b) All
`
`arguments for the relief requested in a motion must be made in the motion. A
`
`reply may only respond to arguments raised in the corresponding opposition….”
`
`Second, there are various reasons why paragraphs in expert declarations are
`
`relevant but generally not cited in briefs; for example they provide (a) expert
`
`qualifications (e.g., N1-2015 ¶¶2-6), (b) foundational background (e.g., ¶¶219 –
`
`223), and (c) the required foundation for the expert’s conclusions (e.g., ¶284
`
`presenting an overview of a reference). Such reasons are illustrated in Avaya’s
`
`own briefs which do not cite the same types of paragraphs that are not cited from
`
`Dr. Knox’s Declaration (e.g., Avaya does not cite to the first 16 paragraphs of
`
`Zimmerman’s Declaration in any of its briefs – AV-1011 ¶¶1-16).
`
`Third, such an argument would improperly exalt form over substance. If the
`
`rule were that paragraphs cited in briefs are admissible but paragraphs that are not
`
`cited are inadmissible, all paragraphs in a declaration would be routinely cited to
`
`make them admissible, whether they are relevant or not. And any relevant uncited
`
`paragraph would be excluded. To avoid such an absurd result, whether a
`
`paragraph is relevant and admissible must depend on the test set forth in Rule 401,
`
`not whether the paragraph is specifically cited in a brief.
`
`6
`
`

`

`
`
`Case No. IPR2013-00071
`
`B. Dr. Knox does not render patent law opinions.
`
`Avaya argues that Dr. Knox improperly renders patent law opinions. Mot. at
`
`2; 6-7. The paragraphs identified by Avaya fall into two general categories, neither
`
`of which constitutes inadmissible patent law opinions.
`
`Category 1 includes paragraphs in which Dr. Knox: (a) sets forth his
`
`understanding of the law provided to him by counsel (see Ex. N1-2015, ¶10) that
`
`he uses as context for his technical opinions, and (b) then applies his technical
`
`opinions to such understanding (¶¶230, 232, 244). Because Dr. Knox presents his
`
`understanding of the law as the general premise to which he applies technical facts
`
`and opinions, Network-1 does not rely (and correspondingly the Board would not
`
`rely) on Dr. Knox as support for the law. Rather, Network-1 relies on (a)
`
`controlling legal authority for the legal premises, and (b) Dr. Knox’s declaration
`
`for the technical facts and opinions that Network-1 applies to the controlling law.
`
`As a concrete example, Paragraph 310 provides:
`
`In this paragraph, Dr. Knox does not render legal opinions but rather identifies his
`
`understanding of the law (provided by counsel) regarding analogous art. Dr. Knox
`
`then uses this understanding (provided by counsel) as a framework to apply his
`
`
`
`7
`
`

`

`
`
`technical opinions in paragraphs 311 – 314 that follow. As set forth in the briefing,
`
`Case No. IPR2013-00071
`
`Network-1 relied on Federal Circuit authority (rather than Dr. Knox’s
`
`understanding) for this legal premise:
`
`
`
`Paper 42 at 51. Because Dr. Knox references the law as a framework rather than
`
`provides legal opinions, such references are not inadmissible. See Hangarter v.
`
`Provident Life & Accident Ins. Co., 373 F.3d 998, 1017 (9th Cir. 2004 ) (“[A]
`
`witness may refer to the law in expressing an opinion without that reference
`
`rendering the testimony inadmissible.”).
`
`Category 2 includes paragraphs in which Dr. Knox identifies Avaya’s and
`
`Dr. Zimmerman’s arguments (¶¶231, 242-243, 300, and 315), for example:
`
`
`
`8
`
`

`

`Case No. IPR2013-00071
`
`
`
`¶300. Identifying Avaya’s arguments is not improperly presenting legal opinions.
`
`
`
`Paragraph 245 does not fall into either category identified above but instead
`
`quotes certain passages from the ‘930 Patent and presents opinions as to how one
`
`of ordinary skill in the art would understand such passages. Paragraph 335 simply
`
`states that the same secondary factors addressed in Dr. Knox’s first declaration
`
`“apply to the proposed substitute claims.”
`
`C. Paragraphs 331-334 (estimating the costs associated with Dr.
`Knox addressing all known references) are based on admissible
`facts to which Dr. Knox has personal knowledge.
`
`
`Avaya asserts that Paragraph 331–334 are expert opinions outside of Dr.
`
`Knox’s expertise regarding “overall litigation costs” and, as a result, are
`
`inadmissible opinions under Rule 702 and lack foundation under Rule 602.
`
`Contrary to Avaya’s assertion, the facts presented in these paragraphs are not
`
`opinions about “overall litigation costs” unknown to Dr. Knox but rather are facts
`
`known to Dr. Knox based on his personal knowledge from the Cisco Litigation. In
`
`particular, Dr. Knox has personal knowledge about the following facts: [a] “the
`
`Invalidity Contentions in the Cisco Litigation” and the number of references
`
`identified (¶¶331, 333); [b] the time it takes him to address references (¶334); [c]
`
`the hourly rate he charges (¶334); and [d] whether it would be “practically
`
`impossible and cost prohibitive [for him] to address each prior art reference that is
`
`known to Network-1 as a result of the various litigations, Inter Partes Reviews,
`
`9
`
`

`

`
`
`and re-examination proceeding.” ¶331. Paragraph ¶332 is not an opinion on
`
`Case No. IPR2013-00071
`
`litigation costs but simply presents his understanding of the law (as provided by
`
`counsel) that gives his factual statements context. See Section I(2) above.
`
`Avaya asserts: “While Knox did serve as an invalidity expert in the prior
`
`litigations and might have knowledge regarding the large volume of prior art, he
`
`has no knowledge or expertise relating to overall litigation costs, including the fees
`
`and costs incurred, the discovery burden on parties, and the possible disruption to
`
`business caused by litigation.” Mot. at 8. This argument is a red herring. Nothing
`
`in Paragraphs 331-334 refer to “overall litigation costs, including the fees and costs
`
`incurred, the discovery burden on the parties, and the possible disruption to
`
`business caused by litigation.” Dr. Knox never made any statements (or expressed
`
`any opinions) regarding such costs and fees – he does not compare the costs of an
`
`IPR proceeding to the overall costs of litigation. Rather, based on his personal
`
`knowledge, Dr. Knox states the undisputed proposition that addressing all 950
`
`references would not be “an efficient and cost-effective alternative.” Knox ¶333.
`
`Avaya’s argument would only make sense if Dr. Knox opined that IPRs were less
`
`costly than litigation. Dr. Knox makes no such assertion.
`
`D.
`
`Paragraph 328 (identifying how Chang was addressed in the Cisco
`Litigation) is admissible based on Dr. Knox’s personal knowledge.
`
`
`Avaya asserts that Paragraph 328 is inadmissible under Rule 602 as
`
`“speculative testimony” and that Dr. Knox lacks personal knowledge regarding the
`
`10
`
`

`

`
`
`statements made in this paragraph. Mot. at 8-9. Avaya’s argument is misplaced.
`
`Case No. IPR2013-00071
`
`In Paragraph 328, Dr. Knox stated:
`
` “Although the Defendants in the prior litigations were aware of the
`
`various art cited by Avaya, they focused on Chang. This is reflected
`
`in my Rebuttal Report in which I (a) addressed Chang as the first
`
`reference; and (b) spent more time addressing Chang than any other
`
`reference, as reflected in the table of contents of my Rebuttal Report.
`
`AV-1030 (ii–v; Table of Contents).”
`
`Contrary to Avaya’s assertion, Dr. Knox, who served as the validity expert
`
`in the prior litigation, has personal knowledge of what art the Defendants in
`
`the Cisco Litigation focused on (i.e., presented to Network-1 and the Court)
`
`and, in particular, (a) what art the Defendants were aware of (see Exhibits
`
`N1-1003, N1-0027), (b) the order that Dr. Knox addressed the art in his
`
`Expert Report, and (c) the amount of time that Dr. Knox spent addressing
`
`the references. (And because a defendant wants to present its most
`
`persuasive case, a defendant tends to focus on the prior art it believes is most
`
`relevant). Because Dr. Knox had personal knowledge of such facts, Avaya’s
`
`argument that Dr. Knox lacks personal knowledge is misplaced.
`
`E. Paragraph 326 (quoting Exhibit N1-2020 which is in evidence in
`this proceeding) is not inadmissible hearsay.
`
`Avaya asserts that Paragraph 326 is inadmissible hearsay because Dr. Knox
`
`quotes from Exhibit N1-2020 which, Avaya asserts, is inadmissible hearsay. Mot.
`
`11
`
`

`

`
`
`at 9-10 (“[t]he quoted portion thus constitutes hearsay.”) Quoting evidence that is
`
`already in the record is not inadmissible hearsay. Avaya did not object or move to
`
`Case No. IPR2013-00071
`
`exclude Exhibit N1-2020. In fact, in his first declaration, Dr. Knox quoted this
`
`same paragraph from Exhibit N1-2020 and Avaya neither objected to the exhibit
`
`nor Dr. Knox’s declaration quoting the exhibit. See Exh. 2015 at §191. As a
`
`result, Exhibit N1-2020 is evidence in the record and Dr. Knox’s reference to such
`
`evidence is not inadmissible.
`
`II.
`
`Section II: Avaya’s “dumping ground” page-limit argument fails.
`
`Avaya asserts that Dr. Knox’s declaration should be excluded in its entirety
`
`because Network-1 has a “pattern and practice of using its expert’s declarations as
`
`a ‘dumping grounds’ for inadmissible arguments” to extend the page limit of its
`
`briefs. Mot. at 3 (apparently referring to Dr. Knox’s 1st Declaration, to which
`
`Avaya did not object, and his 2nd Declaration, which constitute the only two
`
`declarations submitted by Network-1 in this proceeding). Avaya’s “dumping
`
`ground” page limit arguments fail at every level, both procedurally and
`
`substantively.
`
`A. Procedural response.
`
`Avaya’s argument fails at two procedural levels.
`
`First, a Motion to Exclude is not the proper vehicle for arguing that Dr.
`
`Knox’s entire declaration should be excluded under policy grounds. As this Board
`
`12
`
`

`

`
`
`confirmed: “[a] motion to exclude may only raise issues related to the
`
`Case No. IPR2013-00071
`
`admissibility of evidence (e.g., hearsay)...” Paper 75 at 4. Avaya’s page-limit
`
`argument is not an admissibility argument but rather, as acknowledged by Avaya,
`
`is based on “policy concerns” (Opp. at 2) and should not be addressed in this
`
`Motion.
`
`Second, Avaya did not previously object to Dr. Knox’s declaration in its
`
`entirety or object based on page-limit grounds. A Motion to Exclude can only
`
`address objections presented in the notice of objections, thereby giving a party a
`
`chance to cure any alleged defect:
`
`• “The objection must identify the grounds for the objection with sufficient
`
`particularity to allow correction in the form of supplemental evidence.”
`
`37 C.F.R. §42.64(b).
`
`• “The motion must identify the objections in the record ....” 37 C.F.R.
`
`§42.64(c).
`
`In particular, “[a] motion to exclude evidence must: (a) Identify where in the
`
`record the objection originally was made.” Office Patent Trial Practice Guide, 77
`
`Fed. Reg. 48756, 48767. Avaya did not previously object to Dr. Knox’s entire
`
`Declaration as a “dumping ground” that improperly extends page limits. See Paper
`
`72. Accordingly, Avaya’s page-limit argument should be rejected based on this
`
`second procedural basis.
`
`13
`
`

`

`
`
`B.
`
`Substantive response.
`
`Case No. IPR2013-00071
`
`Substantively, Dr. Knox’s Declaration is not a “dumping ground” that
`
`improperly extends the page limit of Network-1’s reply. First, contrary to Avaya’s
`
`assertions, as set forth above in Section I, the objected paragraphs are not a
`
`“mishmash of topics” constituting “inadmissible arguments” (Mot. at 1) but rather
`
`relevant technical facts and opinions that form the foundation for the arguments
`
`presented in Network-1’s Reply. Second, that Knox’s Declaration is lengthy is a
`
`reason to include rather than exclude such evidence. Conclusory opinions in
`
`declarations are inadmissible. See, e.g., Carotek, Inc. v. Kobayashi Ventures, LLC,
`
`875 F. Supp. 2d 313, 337 (S.D.N.Y. 2012) (“An expert opinion is inadmissible as
`
`conclusory if it ‘cannot reasonably be assessed for reliability.’”) (quoting Comm.
`
`Note to Fed. R. Evid. 702 (2000)). To avoid conclusory opinions, Dr. Knox
`
`included detailed foundation – facts and opinions – to support his conclusions (e.g.,
`
`he presented an “Overview of Woodmas” (¶284) to support his conclusions about
`
`what Woodmas discloses). That Dr. Knox’s opinions are supported by substantial
`
`facts (resulting in a lengthy declaration) is a reason why Dr. Knox’s Declaration is
`
`admissible, not inadmissible.
`
`Avaya Asserts: “Patent Owner uses its technical expert as a mouthpiece to
`
`‘testify’ on a mishmash of topics, including United States patent law, the beliefs of
`
`prior adverse parties, and the cost-effectiveness of inter partes proceedings
`
`14
`
`

`

`
`
`compared to district court litigation.” Mot. at 1. Avaya is wrong: Dr. Knox did
`
`not “testify” on any of the “mishmash” topics identified by Avaya. As explained
`
`Case No. IPR2013-00071
`
`above: (1) Dr. Knox did not testify about patent law but rather stated his
`
`understanding of the law as presented by counsel, (2) presented facts based on his
`
`personal knowledge from the Cisco Litigation, and (3) presented the costs
`
`associated with addressing 900+ references based on his percipient knowledge.
`
`
`
`
`
`Respectfully submitted,
`
`BUCHANAN INGERSOLL & ROONEY PC
`
`Date: December 23, 2013
`
`1737 King Street, Suite 500
`Alexandria, VA 22314
`Telephone (703) 836-6620
`
`By: /Charles F. Wieland III
`Charles F. Wieland III
`Registration No. 33,096
`Counsel for NETWORK-1 SECURITY
`
` SOLUTIONS, INC.
`
`
`
`
`
`15
`
`

`

`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing PATENT
`
`OWNER’S OPPOSITION TO AVAYA’S MOTION TO EXCLUDE is being
`
`served via electronic mail (with Petitioner’s Consent) upon the following this 23rd
`
`day of December 2013, via electronic mail, as follows:
`
`
`
`Jeffrey D. Sanok and Jonathan Lindsay
`AV1-PRPS@Crowell.com
`JSanok@Crowell.com
`JLindsay@Crowell.com
`Counsel for Avaya Inc.
`
`Michael J. Scheer and Thomas M. Dunham
`WINSTON & STRAWN LLP
`mscheer@winston.com
`tdunham@winston.com
`Counsel for Dell, Inc.
`
`Lionel M. Lavenue and Erika Arner
`FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, LLP
`lionel.lavenue@finnegan.com
`erika.arner@finnegan.com
`Counsel for Sony Corp. of America
`
`Robert J. Walters and Charles J. Hawkins
`McDERMOTT WILL & EMERY LLP
`rwalters@mwe.com
`chawkins@mwe.com
`Counsel for Hewlett-Packard Co.
`
`Date: December 23, 2013
`
`
`
`
`
`
`
`
`
`
`/Charles F. Wieland III/
`Charles F. Wieland III
`Registration No. 33,096
`Counsel for NETWORK-1 SECURITY
` SOLUTIONS, INC.
`
`

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