`
`
`By:
`
`
`
`
`
`
`
`
`
`
`Thomas Engellenner
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`(617) 204-5100 (telephone)
`(617) 204-5150 (facsimile)
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`YAMAHA CORPORATION OF AMERICA
`Petitioner
`
`v.
`
`BLACK HILLS MEDIA, LLC
`Patent Owner
`___________________
`
`Case No. IPR2013-00594
`Patent 8,050,652
`___________________
`
`
`PATENT OWNER’S MOTION TO EXCLUDE
`PURSUANT TO 37 C.F.R. § 42.64(c)
`
`
`
`
`
`TABLE OF CONTENTS
`TABLE OF AUTHORITIES .................................................................................... ii
`
`IPR2013-00594
`U.S. Patent No. 8,050,652
`
`TABLE OF EXHIBITS ........................................................................................... iii
`
`I.
`II.
`
`INTRODUCTION .......................................................................................... 1
`EXHIBITS 1017 AND 1018 SHOULD BE EXCLUDED ............................ 1
`A.
`Exhibit 1017 – the Microsoft Application ........................................... 2
`B.
`Exhibit 1018 – the Apple Patent .......................................................... 5
`III. EXHIBIT 1021 SHOULD BE EXCLUDED ................................................. 7
`IV. EXHIBIT 1020 SHOULD BE EXCLUDED ............................................... 10
`V.
`CONCLUSION ............................................................................................. 12
`
`
`
`-i-
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`IPR2013-00594
`U.S. Patent No. 8,050,652
`
`TABLE OF AUTHORITIES
`
`
`CASES
`Trivascular, Inc. v. Shaun L. W. Samuels, IPR2013-00493, September 2,
`2014, Paper 39 ...................................................................................................... 9
`
`Page(s)
`
`OTHER AUTHORITIES
`
`37 C.F.R. § 42.64(c) ................................................................................................... 1
`
`FRE 401 ................................................................................................... 1, 2, 4-8, 11
`
`FRE 402 ......................................................................................................... 1, 2, 4-8
`
`FRE 403 ............................................................................................. 1, 2, 4-7, 10, 11
`
`FRE 613(b) ..................................................................................................... 1, 10, 11
`
`FRE 703 ..................................................................................................................... 4
`
`FRE 802 ............................................................................................................. 1, 4, 6
`
`FRE 803 ................................................................................................................. 4, 6
`
`
`
`
`
`-ii-
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`IPR2013-00594
`U.S. Patent No. 8,050,652
`
`UPDATED TABLE OF EXHIBITS
`
`
`
`Previously filed
`
`Exhibit Description
`
`First Amended Complaint in Black Hills Media, LLC
`v. Yamaha Corp. of America, D. Del. 1:12-cv-00635.
`
`Declaration of Thomas Engellenner in Support of
`Motion for Admission Pro Hac Vice
`
`First Amended Complaint in Black Hills Media, LLC
`v. Pioneer Corp., et al., D. Del. 1:12-cv-00634.
`
`Black Hills Media Technology Tutorial Presented to
`Court at Scheduling Conference on November 12,
`2013, in in Black Hills Media, LLC v. Yamaha Corp.
`of America, C.D. Ca. 2:13-cv-06054 and Black Hills
`Media, LLC v. Pioneer Corp., et al., C.D. Ca. 2:13-
`cv-05980.
`
`Transcript of the November 12, 2013, Scheduling
`Conference in Black Hills Media, LLC v. Yamaha
`Corp. of America, C.D. Ca. 2:13-cv-06054 and Black
`Hills Media, LLC v. Pioneer Corp., et al., C.D. Ca.
`2:13-cv-05980.
`
`Pioneer’s Notice of Election Regarding Certain Inter
`Partes Reviews in Black Hills Media, LLC v. Pioneer
`Corp., et al., C.D. Ca. 2:13-cv-05980.
`
`Summons Returned Executed by Black Hills Media,
`LLC on Yamaha Corporation of America in Black
`Hills Media, LLC v. Yamaha Corp. of America, D.
`Del. 1:12-cv-00635.
`
`Summons Returned Executed by Black Hills Media,
`LLC on Pioneer Electronics (USA) Inc. in Black Hills
`Media, LLC v. Pioneer Corp., et al., D. Del. 1:12-cv-
`00634.
`
`-iii-
`
`Exhibit #
`
`2003
`
`2003 [sic]
`
`2004
`
`2005
`
`2006
`
`2007
`
`2008
`
`2009
`
`
`
`
`
`UPDATED TABLE OF EXHIBITS (CONTINUED)
`
`IPR2013-00594
`U.S. Patent No. 8,050,652
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`Previously filed (continued)
`
`Exhibit Description
`
`Summons Returned Executed by Black Hills Media,
`LLC on Pioneer Corporation in Black Hills Media,
`LLC v. Pioneer Corp., et al., D. Del. 1:12-cv-00634.
`
`Exhibit #
`
`2010
`
`Declaration of Ivan Zatkovich
`
`TerraTec M3PO High Quality Audio
`Decoder Manual (May 18, 2000)
`
`Siren Juken Operating Manual (2000)
`
`Microsoft Windows Media Player 7 Handbook, Ch. 2
`(October 4, 2000)
`
`Bove Deposition Transcript and Exhibits, May 30,
`2014
`
`Bove Deposition Transcript and Exhibits, May 29,
`2014
`
`2011
`
`2012
`
`2013
`
`2014
`
`2015
`
`2016
`
`New
`
`Patent Owner’s Objections to Evidence Served on
`August 18, 2014, In Response To Petitioner’s Reply
`
`2017
`
`
`
`-iv-
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`IPR2013-00594
`U.S. Patent No. 8,050,652
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`PATENT OWNER MOTION TO EXCLUDE
`PURSUANT TO 37 C.F.R. § 42.107
`
`I.
`
`INTRODUCTION
`
`Pursuant to 37 C.F.R. § 42.64(c), Black Hills Media, LLC (“Patent Owner”)
`
`hereby moves to exclude Exhibits 1017, 1018, 1020, and 1021 submitted by
`
`Yamaha Corporation of America (“Petitioner”) in support of its Reply (Paper No.
`
`31). On August 18, 2014, Patent Owner served timely objections (Ex. 2017) to
`
`this evidence.
`
`Petitioner’s Exhibits 1017, 1018, and 1021 should be excluded as hearsay,
`
`irrelevant, lacking foundation, and prejudicial. See Federal Rules of Evidence
`
`(FRE) 802, 401, 402, 403. Petitioner’s Exhibit 1020 is inadmissible under FRE
`
`613(b) and should also be excluded as irrelevant, lacking foundation, and
`
`prejudicial. See Federal Rules of Evidence (FRE) 401, 402, 403.
`
`II. EXHIBITS 1017 AND 1018 SHOULD BE EXCLUDED
`With its Reply, Petitioner submitted two new exhibits (Exs. 1017 and 1018),
`
`excerpts of which Petitioner improperly relied upon in violation of Rule 802 of the
`
`Federal Rules of Evidence against hearsay. Unwilling or unable to obtain an
`
`expert declaration opining on the significance of the relied-upon statements to a
`
`person of ordinary skill in the art, Petitioner proffered selected passages of Exhibits
`
`1017 and 1018as unassailable facts in an improper attempt to support the attorney
`
`-1-
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`
`
`
`argument contained within the Reply, and further, without establishing any
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`IPR2013-00594
`U.S. Patent No. 8,050,652
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`foundation or relevance of these exhibits to the claims in this proceeding.
`
`Petitioner’s gambit has also precluded the Patent Owner from cross-
`
`examining Petitioner’s expert regarding these exhibits. As such, Petitioner’s
`
`belated submission of Exhibits 1017 and 1018 not only violates the rule against
`
`hearsay, but also prejudices Patent Owner, who is afforded no opportunity to rebut
`
`the contents of these exhibits through cross-examination of Petitioner’s expert or
`
`through submission of its own expert testimony. Exhibits 1017 and 1018 should
`
`also be excluded on the basis of Rules 401/402 or 403 of the Federal Rules of
`
`Evidence.
`
`A. Exhibit 1017 – the Microsoft Application
`Exhibit 1017 is U.S. Patent Publication No. 20040267899, which was filed
`
`on June 27, 2003, and is assigned on its face to the Microsoft Corporation (the
`
`“Microsoft Application”). The Microsoft Application bears no relationship to the
`
`patent at issue in this proceeding and Petitioner made no attempt to show
`
`otherwise.
`
`In connection with the Patent Owner’s Response, Patent Owner’s expert,
`
`Mr. Zatkovich, cited to a Microsoft Windows Media Player 7 Handbook (Ex.
`
`2015, the “Microsoft Handbook”) as “us[ing] ‘playlist’ consistent with the common
`
`understanding of the term at the time of the ‘652 Patent.” (Ex. 2011 at ¶57
`
`-2-
`
`
`
`
`(emphasis added)). For example, Mr. Zatkovich testified that “[i]n my opinion,
`
`IPR2013-00594
`U.S. Patent No. 8,050,652
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`each of the above exemplary references is consistent with the understanding by a
`
`person having ordinary skill in the art in 2000 that the term “playlist” denoted a
`
`sequence. See, e.g., . . . the Microsoft Handbook, p. 40 (“Shuffle – This plays the
`
`items in the current playlist in a random order. It does not change the order of the
`
`items in the playlist, only the order in which they are played while the shuffle
`
`option is selected”). (Ex. 2011 at ¶58 (emphasis original)). Similarly, Mr.
`
`Zatkovich cited to an exemplary portion of the Microsoft Handbook and opined
`
`that it was “consistent with the understanding by a person having ordinary skill in
`
`the art in 2000 that the term ‘playlist’ denoted that the media items were to be
`
`played in a sequence one after another (i.e., as a group, without having to select
`
`individual songs for playback).” (Ex. 2011 at ¶59 (emphasis original)).
`
`In its Reply, Petitioner addresses Patent Owner’s statements regarding the
`
`Microsoft Handbook by citing – for the first time – to the Microsoft Application.
`
`(Paper 31 at 7-9). Immediately after alleging that “Mr. Zatkovich confirmed that
`
`the meaning of ‘playlist’ has not changed to the present day,” the Petitioner
`
`asserted that “[i]n a 2003 Microsoft patent application, . . . Microsoft itself
`
`indicated that ‘playlist’ is not as narrow as Patent Owner now asserts.” (Paper 31
`
`at 9). The Petitioner then provides a single, selected passage from the Microsoft
`
`Application in an effort to establish 1) the truth of the Microsoft’s inventor’s usage
`
`-3-
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`
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`the term “playlist,” and/or 2) that the meaning of playlist has changed from the
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`IPR2013-00594
`U.S. Patent No. 8,050,652
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`time of the invention claimed in the ’652 Patent to the present time (e.g., at the
`
`time of filing of the Microsoft Application).
`
`The selected passage from the Microsoft Application is therefore proffered
`
`for the truth of the matter asserted in Ex. 1017 and is improper hearsay. There is
`
`no non-hearsay basis for which the Petitioner can now attempt to re-cast its
`
`reliance on Ex. 1017. Moreover, the Microsoft Application does not meet any of
`
`the exceptions to the rule against hearsay under FRE 803. Accordingly, the
`
`Microsoft Application is inadmissible under FRE 802 such that Exhibit 1017
`
`should be excluded.
`
`Further, even if the Microsoft Application of Ex. 1017 is of the type that an
`
`expert could rely upon under FRE 703, Petitioner neither questioned Mr. Zatkovich
`
`regarding the Microsoft Application during his cross-examination nor submitted an
`
`expert declaration with its Reply to address the significance of the cited passage to
`
`a person of ordinary skill in the art.
`
`Exhibit 1017 should also be excluded under FRE 401/402 or 403. Petitioner
`
`has failed to establish any foundation as to why a third-party patent application that
`
`is unrelated to the ’652 Patent has any relevance to inform the claim construction
`
`in the ’652 Patent.
`
`-4-
`
`
`
`Though Petitioner will claim that the Microsoft Application speaks for itself,
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`IPR2013-00594
`U.S. Patent No. 8,050,652
`
`
`
`it is well-recognized that an applicant for a patent can act as his own lexicographer.
`
`As such, the definition of a term appearing in an unrelated patent application to
`
`another inventor does not speak to the plain and ordinary meaning of the term in
`
`the ’652 Patent or inform the ’652 Patent inventor’s usage of the term. As such,
`
`Ex. 1017 is improper extrinsic evidence for purposes of claim construction.
`
`Petitioner’s citation to Exhibit 1017 therefore lacks foundation and relevance
`
`and confuses the issues in the instant proceedings under FRE 401/402.
`
`Alternatively, Petitioner’s reliance on Exhibit 1017 at this late stage of the
`
`proceeding in a manner that precludes any expert examination as to the document’s
`
`teachings is prejudicial under FRE 403.
`
`Exhibit 1018 – the Apple Patent
`
`B.
`Exhibit 1018 is U.S. Patent No. 6,728,729, which was filed on April 23,
`
`2003, and is assigned on its face to Apple Computer, Inc. (the “Apple Patent”).
`
`Petitioner’s reliance on Exhibit 1018 is not supported by any expert testimony.
`
`As with the Microsoft Application (Ex. 1017), Petitioner cites to the Apple
`
`Patent in an attempt to establish that in 2003 Apple “defined playlist in a similarly
`
`unconstrained manner.” (Paper 31 at 9). That is, in contradistinction to Mr.
`
`Zatkovich’s learned opinion that a person of ordinary skill in the art would
`
`understand a playlist to be “a list referencing media items arranged to be played in
`
`-5-
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`
`
`
`a sequence,” Petitioner attempts to argue that Apple defines playlists as
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`IPR2013-00594
`U.S. Patent No. 8,050,652
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`“collections of media that may or may not be in any particular order.” (Id. quoting
`
`Ex. 1018 at 5:9-12). This out-of-court statement in the Apple Patent is proffered
`
`by Petitioner in an attempt to prove the truth of Apple’s definition of playlist, and
`
`is therefore impermissible hearsay. Further, there is no non-hearsay basis for
`
`which Petitioner can now re-cast its arguments, and the Apple Patent does not meet
`
`any of the exceptions to the rule against hearsay under FRE 803. Accordingly, the
`
`Apple Patent is inadmissible under FRE 802 such that Exhibit 1018 should be
`
`excluded.
`
`The Apple Patent should also be excluded under FRE 401/402 or 403. As
`
`with Exhibit 1017, the Petitioner did not present the Apple Patent to either Mr.
`
`Zatkovich or Petitioner’s own expert to provide evidence of how a person of
`
`ordinary skill in the art would have understood Ex. 1018. Moreover, Petitioner
`
`presented no evidence that the inventor/lexicographer of the Apple Patent defined
`
`the term “playlist” according to its plain and ordinary meaning. The Apple Patent
`
`is a third-party patent document in which the applicant has discretion to define and
`
`use the term in any manner it desires, and Petitioner’s Reply fails to establish how
`
`this statement, purportedly by Apple Computer, Inc., has any bearing on the
`
`understanding of one or ordinary skill in the art or with specific regard to the
`
`claims at issue in this proceeding. Moreover, the definition of a term appearing in
`
`-6-
`
`
`
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`an unrelated patent application to another inventor does not speak to the plain and
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`IPR2013-00594
`U.S. Patent No. 8,050,652
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`ordinary meaning of the term in the ’652 Patent.
`
`Petitioner’s citation to Exhibit 1018 therefore lacks foundation and relevance
`
`and confuses the issues in the instant proceedings under FRE 401/402.
`
`Alternatively, Petitioner’s reliance on Exhibit 1018 for the first time in its Reply in
`
`a manner that precludes any examination as to the context of this purported
`
`definition renders Exhibit 1018 prejudicial under FRE 403. As such, Exhibit 1018
`
`should be excluded.
`
`III. EXHIBIT 1021 SHOULD BE EXCLUDED
`With its Reply, Petitioner introduced for the first time Exhibit 1021, which
`
`purports to be an on-line user’s manual for the Nomad Jukebox, which bears a
`
`copyright date of 2000 (the “Nomad Manual”).
`
`The Reply relies on Exhibit 1021 as standing for the proposition that “[i]n
`
`the 2000 timeframe, a single song or several songs could be selected from a list
`
`and played.” (Paper 31 at 6 (emphasis added)). However, the Petitioner’s reliance
`
`on Exhibit 1021 is not relevant to these proceedings within the meaning of Rule
`
`401 of the Federal Rules of Evidence.
`
`Mr. Zatkovich would not and, indeed, does not dispute that it was known
`
`that an item selected from a “list” can be played. For example, in describing
`
`Berman, Mr. Zatkovich’s Declaration provides that “[o]nce the DUL server (107)
`
`-7-
`
`
`
`
`has verified that the playback unit (100) has the latest version of the Song List
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`IPR2013-00594
`U.S. Patent No. 8,050,652
`
`(steps 306 and 308), the user can then select which song they wish to play (step
`
`310). See Berman, 7:21-30.” (Ex. 2011 at ¶100). Rather, what Mr. Zatkovich
`
`contends is that a “list” from which an item can be selected does not constitute a
`
`“playlist.” (See, e.g., Ex. 2011 at ¶114 (“Rather, only after the Song List is
`
`updated in step 308, can the user select one or more songs in step 310. Because
`
`Berman does not disclose that the songs identified in the Song List are provided for
`
`playback in a sequence one after another, without having to select each individual
`
`song for playback, the Song List would not be considered by a person having
`
`ordinary skill in the art to be a ‘playlist’ within the meaning of the ‘652 Patent.”)).
`
`The Petitioner relies on Exhibit 1021 merely for its description of a “list”
`
`from which an item can be selected, but not for any notion as to what a “playlist”
`
`is. As such, Exhibit 1021 does not make any fact at issue in this proceeding more
`
`or less probable as required to establish relevance according to Rule 401 of the
`
`Federal Rules of Evidence. Exhibit 1021 should therefore be excluded pursuant to
`
`FRE 402.
`
`Moreover, the Petitioner’s selective reliance on the Nomad Manual confuses
`
`the issues, is prejudicial, and should be excluded pursuant to Rule 403 of the
`
`Federal Rules. Because Petitioner did not seek any expert opinion in support of its
`
`reliance on the Nomad Manual, Patent Owner is unfairly prejudiced by Petitioner’s
`
`-8-
`
`
`
`
`late introduction of material not previously made of record in the proceeding,
`
`IPR2013-00594
`U.S. Patent No. 8,050,652
`
`principally because, at this late stage in the proceeding, it has no opportunity to
`
`subject the material to expert witness scrutiny. See Trivascular, Inc. v. Shaun L.
`
`W. Samuels, IPR2013-00493, September 2, 2014, Paper 39, at 3 (barring Patent
`
`Owner from using demonstrative exhibits not previously made of record and
`
`noting the prejudice to the Petitioner).
`
`By introducing the Nomad Manual only after Patent Owner’s Response, and
`
`further, by neither presenting this document to Mr. Zatkovich during his deposition
`
`nor presenting this document via expert testimony submitted with Petitioner’s
`
`Reply, Petitioner has effectively precluded Patent Owner from challenging
`
`Petitioner’s characterization of this document or exploring its significance, as a
`
`whole. The rules for inter partes review do not enable Patent Owner to present
`
`any expert testimony (or cross-examine Petitioner’s expert, as no expert opinion
`
`was submitted on Ex. 1021) on portions of the Nomad Manual that are not cited by
`
`the Petitioner such as, for example, the Nomad Manual’s indication that “[w]hen
`
`viewing DETAILS, the word in the lower right corner of the screen indicates the
`
`current playback setting for the play list: ONCE, SHUFFLE, RANDOM, or
`
`REPEAT.” (Ex. 1021 at 15). While this passage actually refers to a “play list” and
`
`thus may be relevant to these proceedings, reference to this passage is noticeably
`
`omitted from Petitioner’s Reply.
`
`-9-
`
`
`
`As such, Petitioner’s belated submission of Exhibit 1020 prejudices Patent
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`IPR2013-00594
`U.S. Patent No. 8,050,652
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`
`
`Owner, who is afforded no further opportunity to rebut and/or further develop the
`
`contents of these exhibits through cross-examination of Petitioner’s expert or
`
`through submission of its own expert testimony. Exhibit 1020 should therefore be
`
`excluded on the basis of Rule 403 of the Federal Rules of Evidence.
`
`IV. EXHIBIT 1020 SHOULD BE EXCLUDED
`Petitioner’s desire to avoid confrontation on any of its unsupported
`
`statements contained within the Reply is further demonstrated by Petitioner’s
`
`belated submission of Exhibit 1020 in violation of Rule 613(b) of the Federal
`
`Rules of Evidence.
`
`Petitioner’s desire to avoid confrontation on any of its unsupported attorney
`
`arguments in the Reply is further demonstrated by Petitioner’s belated submission
`
`of Exhibit 1020 in violation of Rule 613(b) of the Federal Rules of Evidence.
`
`Exhibit 1020 is a Declaration of Ivan Zatkovich submitted in an unrelated covered
`
`business method review concerning an unrelated patent. Rather than question Mr.
`
`Zatkovich regarding his opinions as to the level of ordinary skill in the art during
`
`his deposition in the present proceeding, Petitioner avoided the subject altogether.
`
`See Ex. 1017. Instead, on Reply, Petitioner attempted to improperly rebut opinions
`
`set out in Mr. Zatkovich’s expert declaration (Ex. 2011) by citing a prior
`
`declaration by Mr. Zatkovich from an unrelated proceeding.
`
`-10-
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`
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`Petitioner failed to provide an opportunity to Mr. Zatkovich to explain or
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`IPR2013-00594
`U.S. Patent No. 8,050,652
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`
`
`deny the statement at his deposition in the present proceeding. Petitioner also
`
`failed to provide an opportunity to Patent Owner’s counsel to examine the witness
`
`on Exhibit 1020. Because under FRE 613(b) “extrinsic evidence of a witness’s
`
`prior inconsistent statement is admissible only if the witness is given an
`
`opportunity to explain or deny the statement and an adverse party is given an
`
`opportunity to examine the witness about it,” Exhibit 1020 should be excluded for
`
`at least this reason.
`
`Petitioner’s citation to Mr. Zatkovich’s declaration in an unrelated
`
`proceeding is also not relevant to the instant proceedings under Rule 401, and
`
`Petitioner has failed to establish any foundation for its relevance. Further, even if
`
`Exhibit 1020 were deemed relevant, it should nonetheless be excluded pursuant to
`
`Rule 403 of the Federal Rules of Evidence due to the prejudice caused by
`
`Petitioner’s belated submission of Exhibit 1020 and its failure to cross-examine
`
`Mr. Zatkovich regarding the same.
`
`
`
`
`
`-11-
`
`
`
`
`V. CONCLUSION
`Based on the foregoing, Exhibits 1017, 1018, 1020, and 1021 introduced for
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`IPR2013-00594
`U.S. Patent No. 8,050,652
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`the first time with Petitioner’s Reply should be excluded.
`
`Dated: September 12, 2014
`
`Respectfully submitted,
`
`By: /Thomas Engellenner/
`Thomas Engellenner, Reg. No. 28,711
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`(617) 204-5100 (telephone)
`(617) 204-5150 (facsimile)
`Attorney for Patent Owner
`
`-12-
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`IPR2013-00594
`U.S. Patent No. 8,050,652
`
`CERTIFICATE OF SERVICE
`
`
`
`
`
`
`
`
`
`
`
`I hereby certify that on September 12, 2014, a true and accurate copy of
`
`this paper, PATENT OWNER’S MOTION TO EXCLUDE PURSUANT TO 37 C.F.R.
`§ 42.64(C), was served on the following counsel for Petitioner via email:
`
`David L. Fehrman
`Mehran Arjomand
`Morrison & Foerster LLP
`707 Wilshire Boulevard
`Los Angeles, CA 90017-3543
`Tel: (213) 892-5630
`Fax: (323) 210-1329
`
`
`Dated: September 12, 2014
`
`dfehrman@mofo.com
`marjomand@mofo.com
`
`
`By: /Thomas Engellenner/
`Thomas Engellenner, Reg. No. 28,711
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`(617) 204-5100 (telephone)
`(617) 204-5150 (facsimile)
`Attorney for Patent Owner
`
`
`
`
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