Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`WINTEK CORPORATION
`Petitioner,
`
`v.
`
`TPK TOUCH SOLUTIONS INC.
`Patent Owner
`________________
`
`Case IPR 2013-00568
`U.S. Patent No. 8,217,902
`
`PATENT OWNER MOTION TO EXCLUDE
`PURSUANT TO 37 C.F.R. § 42.64(c)
`
`
`U.S. Patent No. 8,217,902
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`WINTEK CORPORATION
`Petitioner,
`
`v.
`
`TPK TOUCH SOLUTIONS INC.
`Patent Owner
`________________
`
`Case IPR 2013-00568
`U.S. Patent No. 8,217,902
`
`PATENT OWNER MOTION TO EXCLUDE
`PURSUANT TO 37 C.F.R. § 42.64(c)
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`
`TABLE OF CONTENTS
`
`I.
`
`II.
`
`INTRODUCTION .........................................................................................1
`
`LEGAL STANDARD....................................................................................2
`
`III. ARGUMENT..................................................................................................4
`
`A.
`
`B.
`
`C.
`
`The Board Should Exclude Wintek From Relying On New “Prior Art”
`References As Misleading, Prejudicial And Beyond The Scope Of Its
`Reply......................................................................................................4
`
`The Board Should Exclude Wintek’s Arguments Relating to Digital
`Empire’s Petition for Inter Partes Review of U.S. Patent No.
`7,864,503 as Irrelevant and Prejudicial.................................................6
`
`The Board Should Exclude Wintek from Relying on Additional Prior
`Art References Disclosed in Digital Empire’s IPR Petition as
`Irrelevant and Untimely. .......................................................................9
`
`IV. CONCLUSION ............................................................................................11
`
`i
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`
`TABLE OF AUTHORITIES
`
`CASES
`
`None
`
`STATUTES AND RULES
`
`37 C.F.R. § 42.64(c)...................................................................................................1
`
`37 C.F.R. § 42.23(b) ..................................................................................................2
`
`Office Patent Trial Practice Guide, 77 Fed. Reg. 48756, 48758 (Aug. 14, 2012)....2
`
`Office Patent Trial Practice Guide, 77 Fed. Reg. 48756, 48767 (Aug. 14, 2012)....3
`
`ii
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`
`LIST OF EXHIBITS
`
`Document Description
`G. Barrett & R. Omote, “Projected-Capacitive Touch
`Technology”
`Declaration of Joshua R. Smith
`Curriculum Vitae of Joshua R. Smith
`Walker, “Fundamentals of Touch Technologies and
`Applications”
`Hotelling et al., U.S. Patent No. 7,920,129
`Geaghan, U.S. Patent No. 8,279,187
`Crosby, “Self Capacitive Sensing Brings Touch to Large-
`Screen Products”, Zytronic
`Walker, “Part 1: Fundamentals of Projected-Capacitive Touch
`Technology”
`Deposition Transcript of Dr. Vivek Subramanian, June 11, 2014
`Decision – Institution of Inter Partes Review, Case IPR2013-
`00568 (not submitted)
`Decision – In the Matter of Certain Mobile Devices, and Related
`Software Thereof, ITC Inv. No. 337-TA-750
`Figure 2 from Japanese Published Patent Appl. No. 61-84729 to
`Honeywell (excerpt of Wintek Ex. 1007)
`Information Display Journal, Vol. 26, No. 3, March 2010
`Decision – Institution of Inter Partes Review, Case IPR2013-
`00567 (not submitted)
`Testimony of Dr. Subramanian in ITC Inv. No. 337-TA-750
`Binstead, U.S. Patent Publication No. 2012/0188201
`Declaration of Ted Tsai in Support of Patent Owner’s Response
`Daiwa Capital Markets, March 2012 market report
`Amazon Kindle Electrode Structure (Filed Under Seal)
`NPD DisplaySearch, Q1’14 Quarterly Touch Panel Market
`
`iii
`
`TPK Exhibit
`TPK 2001
`
`TPK 2002
`TPK 2003
`TPK 2004
`
`TPK 2005
`TPK 2006
`TPK 2007
`
`TPK 2008
`
`TPK 2009
`TPK 2010
`
`TPK 2011
`
`TPK 2012
`
`TPK 2013
`TPK 2014
`
`TPK 2015
`TPK 2016
`TPK 2017
`TPK 2018
`TPK 2019
`TPK 2020
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`
`TPK Exhibit
`
`TPK 2021
`TPK 2022
`
`TPK 2023
`
`TPK 2024
`TPK 2025
`TPK 2026
`TPK 2027
`TPK 2028
`
`Document Description
`Analysis, April 2014
`Economic Daily News Article, February 2009
`J.P. Morgan, TPK Holding Co., Ltd. research report, October
`2012
`NPD Display Search, Touch Panel Market Analysis Q4’12
`Update, December 2012
`Stipulated Protective Order – Clean
`Stipulated Protective Order – Redlined
`Affidavit of Derek Tang
`Supplemental Affidavit of Derek Tang
`Patent Owner’s Objections to Petitioner’s Evidence, October 3,
`2014
`
`iv
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`
`I.
`
`INTRODUCTION
`
`TPK Touch Solutions Inc. (“Patent Owner”) submits this Motion to Exclude
`
`pursuant to 37 C.F.R. § 42.64(c) seeking exclusion of certain documents, Exhibits,
`
`and/or portions thereof, submitted in connection with Petitioner’s Reply to the
`
`Patent Owner Response, namely: 1) Petitioner’s Reply to the Patent Owner
`
`Response (Paper 45), 2) Exhibits 1022-1024,
`
`3) Exhibits 1028-1031 and 4)
`
`Exhibits 1032-1039. Petitioner provided each of these submissions, for the first
`
`time, along with its Reply on September 26, 2014. Patent Owner timely objected
`
`to Petitioner’s reply and related evidence on October 3, 2014.
`
`Wintek filed its Reply on September 26, 2014.
`
`(See Paper No. 45.)
`
`In its
`
`Reply, Wintek attached 22 new exhibits, including multiple new patents and patent
`
`applications not previously identified in its Petition.
`
`(Paper No. 46.) Wintek’s
`
`Reply contained no declaration or other
`
`testimony from its expert, Dr.
`
`Subramanian.
`
`Instead, Wintek relied heavily on the testimony of an entirely
`
`different expert, Dr. George Gerpheide, submitted in connection with a different
`
`petition for inter partes review of an unrelated patent.
`
`On October 3, 2014, TPK timely served Wintek with objections to the
`
`evidence presented in Wintek’s Reply. (Ex. 2028.) TPK specifically objected to
`
`each of the materials identified above and set forth the bases for its exceptions.
`
`(Id.) Wintek provided no response to TPK’s objections, either before or after the
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`deadline of October 17, 2014. TPK has met and conferred with Wintek, but the
`
`parties have been unable to reach agreement regarding any of TPK’s objections.
`
`Accordingly, TPK respectfully requests that
`
`the Board grant
`
`its Motion and
`
`exclude the evidence identified herein from consideration.
`
`II.
`
`LEGAL STANDARD
`
`“Admissibility of evidence is generally governed by the Federal Rules of
`
`Evidence.” Office Patent Trial Practice Guide, 77 Fed. Reg. 48756, 48758 (Aug.
`
`14, 2012). Rule 403 of the Federal Rules of Evidence explains that relevant
`
`evidence may be excluded “if its probative value is substantially outweighed by a
`
`danger of one or more of the following: unfair prejudice, confusing the issues,
`
`misleading the [Board], undue delay, wasting time, or needlessly presenting
`
`cumulative evidence.”
`
`Moreover, the scope of permissible evidence raised in a party’s reply is
`
`limited by 37 C.F.R. § 42.23(b), which states that “[a]ll 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 or patent owner response.” The
`
`Patent Office Trial Practice Guide further states:
`
`A reply may only respond to arguments raised in the
`corresponding opposition. § 42.23. While replies can
`help crystalize issues for decision, a reply that raises a
`new issue or belatedly presents evidence will not be
`
`2
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`considered and may be returned. The Board will not
`attempt to sort proper from improper portions of the
`reply. Examples of indications that a new issue has been
`raised in a reply include new evidence necessary to make
`a prima facie case
`out
`for
`the patentability or
`unpatentability of an original or proposed substitute
`claim, and new evidence that could have been presented
`in a prior filing.
`Office Patent Trial Practice Guide, 77 Fed. Reg. 48756, 48767 (Aug. 14,
`
`2012).
`
`A motion to exclude evidence must explain why the cited evidence is not
`
`admissible and must: (a) identify where in the record the objection originally was
`
`made; (b) identify where in the record the evidence sought to be excluded was
`
`relied upon by an opponent; (c) address objections to Exhibits in numerical order;
`
`and (d) explain each objection. Office Patent Trial Practice Guide, 77 Fed. Reg.
`
`48756, 48767 (Aug. 14, 2012).
`
`As set forth above, each objection set forth in the present Motion pertains to
`
`Wintek’s Reply and the Exhibits cited therein. TPK timely identified and served
`
`its objections on Wintek within five days of receiving Wintek’s Reply.
`
`(See Ex.
`
`2028.)
`
`3
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`
`III. ARGUMENT
`
`A.
`
`The Board Should Exclude Wintek From Relying On New “Prior
`Art” References As Misleading, Prejudicial And Beyond The
`Scope Of Its Reply.
`
`Despite having filed three separate IPR petitions on the ’902 patent,
`
`Wintek’s petitions have failed to identify a single prior art reference that allegedly
`
`anticipates the claims of the ’902 patent that explicitly require the use of mutual
`
`capacitance to detect a position of touch (i.e., claims 17-19, 21, 22, 25-27, 29, 35,
`
`44, and 68).
`
`Instead, to challenge these claims, Wintek has relied only on the
`
`argument that it would have been obvious to combine references disclosing the use
`
`mutual capacitance with other references disclosing an electrode structure where
`
`all conductors are located on a single layer—i.e, in the present proceeding, the
`
`combination of Miller with Fujitsu. Nevertheless, in its Reply, Wintek identifies
`
`for the first time several new patents and patent applications (Exs. 1022, 1023 and
`
`1024), which it asserts disclose these claimed elements of the ’902 patent (Paper
`
`No. 45, Reply at 14-15.) Wintek’s arguments regarding these new references are
`
`irrelevant, untimely, misleading and prejudicial, and should be excluded.
`
`Exs. 1022 and 1023. Wintek argues for the first time in its Reply that U.S.
`
`Patent No. 6,188,391 (Ex. 1022) discloses a “prior art mutual-capacitance touch
`
`panel with sensors on the same side of a substrate.” (Paper No. 45, Reply at 14-
`
`15.) However, Wintek’s characterization of this reference is highly misleading, as
`
`4
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`in fact each passage cited by Wintek explicitly describes a “two-layer” capacitive
`
`structure. (See, e.g., Ex. 1022 at 1:61-63 (“The subject patent application relates to
`
`a capacitive touchpad using a two-layer printed circuit board . . . .”), 8:8-10 (“A
`
`method of fabricating two-layer touchpad for use in a system . . .”).) Nor is
`
`Wintek’s position supported by its citation (again, for the first time) to U.S. Patent
`
`No. 5,543,590 (Ex. 1023), which it argues is incorporated by reference in U.S.
`
`Patent No. 6,188,391.
`
`(Paper No. 45, Reply at 15.) Wintek cites to this patent
`
`only for its disclosure of the use of mutual capacitance. (See id.)
`
`Accordingly, to the extent that Wintek has submitted Exhibits 1022 and
`
`1023 in an attempt to refute TPK’s argument that that objective considerations
`
`demonstrate non-obviousness because other parties failed to develop a single-layer
`
`mutual-capacitance touch panel prior to the ’902 patent, Wintek’s arguments are at
`
`best nonresponsive, and therefore irrelevant—and at worst grossly misleading, and
`
`therefore prejudicial. Moreover, to the extent that Wintek relies on Exhibits 1022
`
`and 1023 in an attempt to bolster its arguments that the ’902 patent is anticipated
`
`by the prior art, Wintek’s arguments are untimely. Wintek did not cite either
`
`reference in its Petition, and TPK and its expert have not had the opportunity to
`
`analyze and respond to Wintek’s characterizations of these references. Therefore,
`
`the Board should exclude both references, as well as the corresponding statements
`
`and arguments in Wintek’s Reply regarding these references.
`
`5
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`Exhibit 1024. Wintek also argues for the first time in its Reply that “Apple
`
`came up with the concept of a single-layer mutual-capacitance touch sensor in
`
`2007.” (Paper No. 45, Reply at 14.) In support of this new argument, Wintek cites
`
`U.S. Patent App. No. 2008/0309625 (Ex. 1024). However, Wintek’s reliance on
`
`this newly-raised reference also is irrelevant because Apple’s patent application
`
`was not filed until June 13, 2007, after the April 2007 priority date of the ’902
`
`Patent. (Id.) In other words, because Apple’s patent application postdates the ’902
`
`patent, it is not responsive either to TPK’s arguments regarding the state of the art
`
`at the time of the ’902 patent, or to Wintek’s arguments regarding anticipation.
`
`Any attempt by Wintek to suggest otherwise is misleading and prejudicial.
`
`For these reasons, the Board should exclude Exhibits 1022, 1023 and 1024
`
`as nonresponsive, as well as Wintek’s misleading and inaccurate characterizations
`
`of these references in the second paragraph on page 14 of its Reply.
`
`B.
`
`The Board Should Exclude Wintek’s Arguments Relating to
`Digital Empire’s Petition for Inter Partes Review of U.S. Patent
`No. 7,864,503 as Irrelevant and Prejudicial.
`Exs. 1028-1031. In its Reply, Wintek offered no testimony from its expert,
`
`Dr. Vivek Subramanian, to rebut or otherwise reply to TPK’s Patent Owner’s
`
`Response and the testimony of TPK’s expert, Dr. Joshua Smith.
`
`(See Paper No.
`
`45.) In particular, Wintek provided no testimony from Dr. Subramanian disputing
`
`Dr. Smith’s observation that Dr. Subramanian had advanced and agreed with
`
`6
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`TPK’s own proposed claim construction positions. (Id.; see also Ex. 2002, Decl.
`
`of J. Smith ¶ 80.) Instead, Wintek submitted a declaration provided by Dr. George
`
`Gerpheide (Ex. 1029) in an entirely different IPR petition (Ex. 1028)—the petition
`
`of Digital Empire Ltd. seeking inter partes review of U.S. Patent No. 7,864,503
`
`(Ex. 1030), a patent not at issue in the present proceeding. (Paper No. 45, Reply at
`
`5-6.) Wintek further submitted the Board’s decision to institute review of U.S.
`
`Patent No. 7,864,503 (Ex. 1031) as evidence of the credibility of Dr. Gerpheide’s
`
`declaration. (Paper No. 45, Reply at 6.) Because Digital Empire’s briefing in its
`
`petition for review of U.S. Patent No. 7,864,503 is not relevant to the present
`
`proceeding and its inclusion in the record is highly prejudicial to TPK, the Board
`
`should not permit Wintek to avoid providing Dr. Subramanian for additional cross-
`
`examination by submitting arguments made in an unrelated proceeding as its own.
`
`The Board should exclude the arguments in Wintek’s Reply relating to Digital
`
`Empire’s IPR petition, as well as the corresponding Exhibits 1028-1031 from the
`
`record.
`
`In its Reply, Wintek submitted Digital Empire’s petition for inter partes
`
`review of U.S. Patent No. 7,864,503 to support its argument that the Binstead
`
`reference discloses the “conductor cells” and “conduction lines” required by each
`
`challenged claim of the ’902 patent. (Paper No. 45, Reply at 5-6.) However, the
`
`opinions of Digital Empire and its expert regarding the unrelated U.S. Patent No.
`
`7
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`7,864,503 have no relevance to the current IPR proceeding. Digital Empire’s
`
`petition and Dr. Gerpheide’s corresponding declaration make no reference to
`
`TPK’s ’902 patent or any of its claims. Accordingly, the arguments in its petition
`
`are not probative of Wintek’s argument that Binstead discloses any of the claimed
`
`elements of the ’902 patent. To the contrary, Wintek’s reliance on different claim
`
`terms in U.S. Patent No. 7,864,503 (e.g., “bridging lines”) misleadingly conflates
`
`two different patents. Wintek offers no support for the position that the terms of
`
`U.S. Patent No. 7,864,503 are to be construed as having the same meanings as the
`
`terms of TPK’s ’902 patent.
`
`Moreover, Wintek’s attempts to attribute Dr. Gerpheide’s opinions regarding
`
`U.S. Patent No. 7,864,503 to TPK are inaccurate and highly prejudicial. Wintek’s
`
`repeated references to Dr. Gerpheide as “TPK’s other expert” (Paper No. 45, Reply
`
`at 5) because of his past involvement in the prosecution of the ’902 patent
`
`misleadingly suggest
`
`that Dr. Gerpheide presently serves as TPK’s expert.
`
`Wintek’s attempts to manufacture a connection between Digital Empire’s petition
`
`and the current IPR proceeding should be rejected.
`
`Accordingly, the Board should exclude section II.b of Wintek’s Reply,
`
`which is based solely on the inapplicable arguments of Digital Empire and its
`
`expert in an irrelevant IPR petition of an unrelated patent. For the same reasons,
`
`the Board should exclude from the record the corresponding underlying exhibits:
`
`8
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`(i) Exhibit 1028 (Digital Empire’s IPR petition), (ii) Exhibit 1029 (Dr. Gerpheide’s
`
`declaration in support of Digital Empire’s petition), (iii) Exhibit 1030 (U.S. Patent
`
`No. 7,864,503), and (iv) Exhibit 1031 (the Board’s decision instituting review of
`
`U.S. Patent No. 7,864,503).
`
`C.
`
`The Board Should Exclude Wintek from Relying on Additional
`Prior Art References Disclosed in Digital Empire’s IPR Petition
`as Irrelevant and Untimely.
`Exs. 1032-1039.
`
`In its Reply, Wintek also submitted no less than eight
`
`additional references cited in the declaration of Dr. Gerpheide to support its
`
`arguments regarding the combination of Fujitsu and Miller, concluding that
`
`“TPK’s prosecution expert had no issue with combining Fujitsu with multiple-
`
`layer type touch panel systems to support an obviousness position.” (Paper No. 45,
`
`Reply at 12; Exhibits 1032-1039.) For the reasons set forth above, Wintek’s
`
`reliance on the arguments made by Digital Empire in its petition for inter partes
`
`review of U.S. Patent No. 7,864,503, along with its repeated references to Dr.
`
`Gerpheide as “TPK’s expert,” is improper. Moreover, Wintek’s reliance on the
`
`combinations of references asserted by Digital Empire against U.S. Patent No.
`
`7,864,503 is irrelevant and untimely.
`
`First, the purported combinations of Fujitsu and other references identified
`
`by Digital Empire are not relevant to Wintek’s argument that it would be obvious
`
`to combine Fujitsu and Miller to arrive at the challenged claims of the ’902 Patent.
`
`9
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`Wintek offered no explanation how any such purported combination would relate
`
`to the challenged claims of the ’902 Patent.
`
`In particular, although Wintek cited
`
`these combinations to respond to TPK’s argument that a person of ordinary skill
`
`would not have found it obvious to combine Fujitsu with the mutual-capacitance
`
`detection system disclosed in Miller, Wintek argued only that Dr. Gerpheide “had
`
`no issue with combining Fujitsu with multiple-layer type touch panel systems”
`
`(Paper No. 45, Reply at 12) and said nothing about whether the references in fact
`
`disclosed mutual-capacitance touch detection.
`
`Indeed, in its Reply, Wintek simply
`
`pointed to each additional reference in its entirety and failed to provide any
`
`specific citations at all to any reference. (Id.)
`
`Moreover, to the extent that Wintek attempted to rely on these additional
`
`combinations to suggest that other combinations of Fujitsu exist that would render
`
`obvious the challenged claims of the ’902 patent, such arguments are improper and
`
`untimely. Wintek did not raise these purported combinations in its petition for
`
`inter partes review, and TPK and its expert have not had the opportunity to opine
`
`on the potential combination of Fujitsu and any reference identified for the first
`
`time in Wintek’s Reply.
`
`Accordingly, the Board should exclude Exhibits 1032-1039, as well as the
`
`portion of Wintek’s Reply relying on these references to support its obviousness
`
`arguments (Paper No. 45, Reply at 12) as irrelevant and untimely.
`
`10
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`
`IV. CONCLUSION
`
`For the foregoing reasons, Patent Owner respectfully requests that its Motion
`
`to Exclude be granted.
`
`Date: October 31, 2014
`
`Respectfully submitted,
`
`By: /Joseph J. Richetti, Reg. No. 47024/
`Joseph J. Richetti, Reg. No. 47,024
`BRYAN CAVE LLP
`1290 Avenue of the Americas
`New York, NY 10104
`General Tel: (212) 541-2000
`Direct Tel: (212) 541-1092
`Fax: (212) 541-4630
`Email: joe.richetti@bryancave.com
`
`David Bilsker, Reg. No. 39,611
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`50 California Street, 22nd Floor
`San Francisco, CA 94111
`General Tel: (415) 875-6600
`Direct Tel: (415) 875-6432
`Fax: (415) 875-6700
`Email: davidbilsker@quinnemanuel.com
`
`Attorneys for Patent Owner –
`TPK Touch Solutions Inc.
`
`11
`
`
`
`Case No. IPR 2013-00568
`U.S. Patent No. 8,217,902
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the foregoing PATENT OWNER
`
`MOTION TO EXCLUDE PURSUANT TO 37 C.F.R. § 42.64(c) was served
`
`electronically via e-mail on October 31, 2014, in its entirety on the following:
`
`Joseph E. Palys
`PAUL HASTINGS LLP
`875 15th Street, N.W.
`Washington, DC 20005
`josephpalys@paulhastings.com
`
`Naveen Modi
`PAUL HASTINGS LLP
`875 15th Street, N.W.
`Washington, DC 20005
`naveen.modi@paulhastings.com
`
`Respectfully submitted,
`
`By: /Joseph J. Richetti, Reg. No. 47024/
`Joseph J. Richetti
`Lead Attorney for Patent Owner
`Reg. No. 47,024
`BRYAN CAVE LLP
`1290 Avenue of the Americas
`New York, NY 10104
`General Tel: (212) 541-2000
`Direct Tel: (212) 541-1092
`Fax: (212) 541-4630
`Email: joe.richetti@bryancave.com
`
`Attorney for Patent Owner –
`TPK Touch Solutions Inc.
`
`Date: October 31, 2014
`
`
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