`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`AMERICAN HONDA MOTOR CO., INC., ET. AL
`Petitioner
`
`v.
`
`CRUISE CONTROL TECHNOLOGIES LLC
`Patent Owner
`_______________
`
`Case: IPR2014-00289
`
`Patent 6,324,463
`_______________
`
`OPPOSITION TO PATENT OWNER’S MOTION FOR JOINDER OF
`INTER PARTES REVIEW PROCEEDINGS: IPR2014-00279,
`IPR2014-00280, IPR2014-00281, IPR2014-00289, AND IPR2014-00291
`
`
`
`
`
`
`
`
`
`TABLE OF CONTENTS
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`
`
`I.
`
`II.
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`BACKGROUND ............................................................................................ 2
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`PATENT OWNER’S STATEMENT OF MATERIAL FACTS ................. 5
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`III. ARGUMENT ................................................................................................................. 5
`
`A.
`
`B.
`
`C.
`
`Patent Owner Has Not Met Its Burden To Demonstrate The
`Proceedings Should Be Joined .................................................................... 5
`
`Joinder Of The Proceedings Will Not Result In Increased
`Efficiency ............................................................................................................. 6
`
`Petitioner Would Be Prejudiced If The IPR Proceedings
`Are Joined ......................................................................................................... 11
`
`D.
`
`Patent Owner’s Motion For Joinder Is Premature ........................... 11
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`IV. PATENT OWNER DID NOT HAVE AUTHORIZATION TO SEEK
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`DENIAL OF THE PETITIONS ........................................................................... 13
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`V. CONCLUSION ........................................................................................................... 15
`
`
`
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`
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`IPR2014-00289
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`American Honda Motor Co., Inc. (“Honda”), Toyota Motor North America,
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`Inc. (“Toyota”), Nissan North America, Inc. (“Nissan”), Ford Motor Company
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`(“Ford”), Jaguar Land Rover North America LLC (“JLRNA”), Subaru of America
`
`Inc. (“Subaru”) and Volvo Cars of North America LLC (“Volvo”) (collectively
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`“Petitioner”) respectfully request that the Board deny Cruise Control Technologies
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`LLC’s (“Patent Owner’s”) Motion for Joinder of Inter Partes Review Proceedings
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`IPR2014-00279, IPR2014-00280, IPR2014-00281, IPR2014-00289, and IPR2014-
`
`00291 (“Motion”).
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`As the moving party, Patent Owner has the burden to establish that
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`IPR2014-00289 should be joined with the other four IPR proceedings. See 37
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`C.F.R. §§ 42.20(c) and 42.122(b). Patent Owner has not carried its burden and its
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`motion for joinder should be denied.
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`First, Patent Owner cannot demonstrate that it is entitled to joinder of the
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`proceedings, as it failed to address any of the factors considered by the Board when
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`deciding whether to grant a motion for joinder.
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`Second, Patent Owner disregards significant differences in the five IPR
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`proceedings. Each of the differences alone would add complexity and inefficiency
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`to a joined proceeding; together, the differences would make conducting a joined
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`proceeding unfeasible.
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`1
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`IPR2014-00289
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`Third, Petitioner would be severely prejudiced by joinder of the five IPR
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`proceedings, as replying to Patent Owner’s argument on a large number of issues
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`in a single, limited briefing would handicap Petitioner’s ability to meet its burden
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`to prove unpatentability of the challenged claims.
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`Fourth, as the Board has not yet reached its decision on institution, Patent
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`Owner’s motion for joinder is premature.
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`I.
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`BACKGROUND
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`On December 20, 2013, Petitioner, led by Subaru, filed a petition in
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`IPR2014-00279 (“the Subaru petition”). Subaru of America, Inc., et al. v. Cruise
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`Control Technologies LLC, IPR2014-00279, Paper No. 1. Matthew D. Satchwell
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`is the only lead counsel identified in the Subaru petition. Id. at 3. The Subaru
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`petition requests inter partes review of claims 1-5, 12-16, 18-21, 23, 25-31, and
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`34-36 of U.S. Patent No. 6,324,463 (“the ‘463 patent”) based on two references:
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`Mizuno and Miura. Id. at 6. The Subaru petition is supported the expert opinions
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`of Mr. David A. McNamara. IPR2014-00279, Exhibit 1007.
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`On December 20, 2013, Petitioner, led by Toyota, filed a petition in
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`IPR2014-00280 (“the Toyota petition”). Toyota Motor North America, Inc., et al.
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`v. Cruise Control Technologies LLC, IPR2014-00280, Paper No. 1. William H.
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`Mandir is the only lead counsel identified in the Toyota petition. Id. at 2-3. The
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`Toyota petition requests inter partes review of claims 1-5, 12-16, 18, 19, 21, 25-
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`
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`2
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`IPR2014-00289
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`28, and 34-36 of the ‘463 patent based on four references: the Diamante Owner’s
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`Manual, the Preview Distance Control Manual, Watanabe and Celsior. Id. at 6.
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`The Toyota petition is supported by the expert opinions of Dr. Paul Green.
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`IPR2014-00280, Exhibit 1011.
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`On December 20, 2013, Petitioner, led by Ford, filed a petition in IPR2014-
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`00281 (“the Ford petition”). Ford Motor Co., et al. v. Cruise Control
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`Technologies LLC, IPR2014-00281, Paper No. 1. Matthew J. Moore is the only
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`lead counsel identified in the Ford petition. Id. at 2-3. The Ford petition requests
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`review of claims 1-5, 12-31, and 34-36 of the ‘463 patent based on four references:
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`Narita, Beiswenger, the NHTSA Report and Nagashima. Id. at 5-6. The Ford
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`petition is supported by the expert opinions of Mr. Daniel A. Crawford. IPR2014-
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`00281, Exhibit 1011.
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`On December 23, 2013, Petitioner, led by Honda, filed IPR2014-00289 (“the
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`Honda petition”). American Honda Motor Co., Inc., et al. v. Cruise Control
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`Technologies LLC, IPR2014-00289, Paper No. 3. John M. Caracappa is the only
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`lead counsel identified in the Honda petition. Id. at 3-4. The Honda petition
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`requests review of claims 1-5, 12-15, 18-20, 25-28, and 34-36 of the ‘463 patent
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`based on four references: Yagihashi, Yoshimitsu, the 300zx Manual, and
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`Nagashima. Id. at 15-60. The Honda petition is supported by the expert opinions
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`of Mr. David A. McNamara. IPR2014-00289, Exhibit 1012.
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`3
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`IPR2014-00289
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`On December 23, 2013, Petitioner, led by Nissan, filed IPR2014-00291
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`(“the Nissan petition”). Nissan North America, Inc., et al. v. Cruise Control
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`Technologies LLC, IPR2014-00291, Paper No. 1. Vaibhav P. Kadaba is the only
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`lead counsel identified in the Nissan petition. Id. at 3-4. The Nissan petition
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`requests review of claims 1-5, 12-16, 18-19, 21, 25-31, and 34-36 of the ‘463
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`patent based on three references: Prometheus, Narita, and Celsior. Id. at 7. The
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`Nissan petition is supported by the expert opinions of Mr. David A. McNamara.
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`IPR2014-00291, Exhibit 1010.
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`On April 4, 2014, Patent Owner requested “a conference with the Board to
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`obtain permission to file a motion to join the following IPRs.” Ex. 1013, April 4,
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`2014 Email from J. Kasha to trials@uspto.gov. On April 9, 2014, the Parties
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`participated in a call with the Board to address Patent Owner’s request. IPR2014-
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`00289, Paper No. 10, at 2. During the call, the Board “authorized Patent Owner to
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`file its requested motion to join the five related proceedings.” Id. at 4. No other
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`motions were authorized during the call.
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`On April 24, 2014, Patent Owner filed a motion requesting, inter alia,
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`joinder of the five IPR proceedings, pursuant to 35 U.S.C. § 315(c) and 37 C.F.R. §
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`42.122(b). IPR2014-00289, Paper No. 11.
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`4
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`IPR2014-00289
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`II.
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`PATENT OWNER’S STATEMENT OF MATERIAL FACTS
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`For the purposes of this Opposition, Petitioner does not dispute any of Patent
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`Owner’s Statements of Material Fact.
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`III. ARGUMENT
`A.
`Patent Owner Has Not Met Its Burden To Demonstrate The
`Proceedings Should Be Joined
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`A motion for joinder should, at least, address (1) the reasons why joinder is
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`appropriate; (2) any differences in the grounds of unpatentability presented in each
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`petition; (3) what impact joinder would have on the schedule; and (4) how briefing
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`and discovery would be simplified in a joined proceeding. See Texas Instruments
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`Inc. v. Unifi Scientific Batteries, LLC, IPR2013-00213, Paper No. 19, at 3; NetApp,
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`Inc. v. PersonalWeb Technologies, LLC, IPR2013-00319, Paper No. 18, at 6.
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`Patent Owner has not addressed any of these factors in its motion for joinder, and
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`accordingly, the motion should be denied.
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`Patent Owner’s only effort to even touch upon the factors was to argue that
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`joinder is appropriate because it would be prejudiced by having “participate in,
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`[sic] five parallel proceedings.” Motion, at 11-12. However, Patent Owner’s
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`argument is belied by the fact that it is Patent Owner’s own actions that led to the
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`filing of the five IPR proceedings. Patent Owner filed lawsuits against each of the
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`petitioners, alleging infringement of the ‘463 patent. IPR2014-00289, Paper No. 1.
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`Challenges to the validity of the ‘463 patent are a predictable consequence of
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`5
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`IPR2014-00289
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`patent infringement lawsuits. As result, Patent Owner cannot credibly argue that it
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`is unfairly prejudiced by having to defend five IPRs proceedings.
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`B.
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`Joinder Of The Proceedings Will Not Result In Increased
`Efficiency
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`Patent Owner argues that the IPR proceedings should be joined because each
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`petition shares some similarities with each of the other petitions and the similarities
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`can be addressed more efficiently in a single proceeding. Motion, at 11. Patent
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`Owner’s argument fails, however, as Patent Owner overlooks significant
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`differences between each of the five IPR proceedings that weigh heavily against
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`joinder.
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`For instance, Patent Owner contends that the IPR proceedings should be
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`joined because the proceedings involve the same Petitioner and same counsel.
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`Motion, at 11. However, Patent Owner ignores that each petition has a different
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`lead counsel and a different lead petitioner. Honda, and its counsel, are lead on the
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`Honda petition. IPR2014-00289, Paper No. 3, at 3-4. Subaru, and its counsel, are
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`lead on the Subaru petition. IPR2014-00279, Paper No. 1, at 3. Toyota, and its
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`counsel, are lead on the Toyota petition, and so on. IPR2014-00280, Paper No. 1,
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`at 2-3. The fact that a petitioner is acting as lead on a given petition is more than
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`an administrative act; it has a procedural effect. In the event, the lead petitioner
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`settles with Patent Owner, the remaining petitioners on each petition have the
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`ability to maintain the petition. While all of the petitioners are joined on each
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`6
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`IPR2014-00289
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`petition for this procedural reason, each lead petitioner will litigate its own
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`proceeding.
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`Patent Owner also contends that joinder is proper because eighteen claims of
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`the ‘463 patent were challenged in each petition. Motion, at 11. But Patent Owner
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`disregards that ten of the challenged claims are not challenged in all five of the
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`petitions,1 and that no two petitions challenge the same subset of claims. IPR2014-
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`00279, Paper No. 1; IPR2014-00280, Paper No. 1; IPR2014-00281, Paper No. 1;
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`IPR2014-00289, Paper No. 3; and IPR2014-00291, Paper No. 1. As one example,
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`independent claim 21 is not challenged in all five petitions, and the patentability
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`analysis of claim 21 is unique. Id. Claim 21 includes the limitation, “after the
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`cruise control system is deactivated, displaying a symbol indicative of an unset
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`state of the preset speed.” IPR2014-00289, Ex. 1001, Claim 21. This limitation is
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`not found in any other claims, and the parties dispute the proper construction of
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`two separate phrases within the limitation – “cruise control system is deactivated”
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`and “displaying a symbol indicative of an unset state of the preset speed.” See,
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`e.g., IPR2014-00279, Paper No. 1, at 8-9; IPR2014-00279, Paper No. 15, at 7-10.
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`As a result, proceedings in which claim 21 is challenged include a different claim
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`1 Claims 16, 17, 20-24, and 29-31are not challenged in all five petitions.
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`7
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`IPR2014-00289
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`construction analysis and a different unpatentability analysis than proceedings in
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`which claim 21 is not being challenged.2
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`As another example, claims 29-31 are not challenged in all five petitions.
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`IPR2014-00279, Paper No. 1; IPR2014-00280, Paper No. 1; IPR2014-00281,
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`Paper No. 1; IPR2014-00289, Paper No. 3; and IPR2014-00291, Paper No. 1.
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`Claim 29, and its dependant claims 30 and 31, require “the first visual display
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`apparatus comprises an analog speedometer including a speed indicator operably
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`disposed adjacent an indicator dial,” and are the only challenged claims that
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`include an analog speedometer.
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` IPR2014-00289, Ex. 1001, Claim 29.
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`Consequently, proceedings in which claims 29-31 are challenged necessarily
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`include a discussion of prior art describing analog speedometers, which is a
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`different unpatentability analysis that is not otherwise present in proceedings that
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`are not challenging claims 29-31.
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`The difference in the unpatentability analyses between petitions is
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`compounded by the fact that there is significant variation in the references relied
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`on in each of the five petitions. IPR2014-00279, Paper No. 1, at 6; IPR2014-
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`00280, Paper No. 1, at 6; IPR2014-00281, Paper No. 1, at 5-6; IPR2014-00289,
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`Paper No. 3, at 15-60; and IPR2014-00291, Paper No. 1, at 7. For instance, there
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`2 Claims 22-24 depend from independent claim 21. Like claim 21, none of claims
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`22-24 are challenged in all five petitions.
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`8
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`IPR2014-00289
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`is no overlap in the primary references relied upon in the five petitions. Id. Of the
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`fifteen total references relied upon, thirteen of the references are cited in only one
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`petition. Id. The remaining two references are each relied on in only two
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`petitions. The first of those two references, Nagashima, is cited in the Ford and
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`Honda petitions. IPR2014-00281, Paper No. 1, at 6; IPR2014-00289, Paper No. 3,
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`at 39-43. But in each of those petitions, Nagashima is used to challenge a different
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`subset of claims. Id. The second reference, Narita, is cited in the Ford and Nissan
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`petitions. IPR2014-00281, Paper No. 1, at 6; IPR2014-00291, Paper No. 1, at 7.
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`Similar to Nagashima, Narita is also used to challenge a different subset of claims
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`in each of the petitions. Id.
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`The unpatentability analyses are further distinguished by Petitioner’s
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`reliance on three different expert declarants across the five IPR proceedings. The
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`Subaru, Honda, and Nissan petitions rely on the opinions of David A. McNamara.
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`IPR2014-00289, Exhibit 1012; IPR2014-00279, Exhibit 1007; IPR2014-00291,
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`Exhibit 1010. The Toyota petition relies on the opinions of Dr. Paul Green.
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`IPR2014-00280, Exhibit 1011. The Ford petition relies on the opinions of Daniel
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`A. Crawford. IPR2014-00281, Exhibit 1011.
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`The result of all of the differences in the five IPR proceedings is that, even
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`when the same claim is challenged in all five petitions, the issues would not be
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`simplified by joinder because that claim is challenged under different grounds
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`9
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`IPR2014-00289
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`using different prior art, which is explained by different experts and different
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`parties. See, e.g., Table 1, below.
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`Table 1: Summary of Challenges to Claim 5 of the ‘463 Patent
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`Subaru
`1. Mizuno
`
`Claim 5
`Prior Art
`Relied
`Upon
`
`Toyota
`1. Diamante
`Owner’s
`Manual
`
`Statutory
`Basis
`Expert
`
`102
`
`102
`
`Ford
`1. Narita;
`2. Narita in
`view of
`Admitted Prior
`Art;
`3. Narita in
`view of
`NHTSA
`Report
`102 and 103
`
`Honda
`1. Yagihashi in
`view of APA or
`Yoshimitsu
`
`Nissan
`1. Prometheus;
`2. Prometheus
`in view of
`Narita
`
`
`103
`
`102 and 103
`
`McNamara
`
`Green
`
`Crawford
`
`McNamara
`
`McNamara
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`Because each petition raises its own set of issues, any hypothetical
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`efficiencies gained by joining the proceedings are heavily outweighed by the
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`complexity that would be added by having unique subsets of claims challenged
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`under different statutory grounds based on various prior art references that are
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`explained by multiple experts.3 See, e.g., Liberty Mutual Insurance Co. v.
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`Progressive Casualty Insurance Co., CBM2012-00002, Paper No. 16 at 2 (“The
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`Board prefers to proceed without making any joinder or consolidation at this time,
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`3 The fact that the various prior art references are used to challenge different
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`subsets of claims under different statutory provisions strongly suggests a lack of
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`redundancy in the grounds of unpatentability raised in the five petitions.
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`
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`10
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`IPR2014-00289
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`given the focus and clarity afforded by two smaller proceedings with different
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`prior art issues.”). As such, joinder of the five IPR proceedings does not “secure
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`the just, speedy, and inexpensive resolution of every proceeding.” See 37 C.F.R. §
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`42.1(b). Instead, joinder of the five IPR proceedings would merely serve to amass
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`a large number of issues into a single, constrained proceeding.
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`C.
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`Petitioner Would Be Prejudiced If The IPR Proceedings Are
`Joined
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`If the proceedings are joined as Patent Owner has proposed, Patent Owner
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`would present its response in a single brief and Petitioner would present its reply in
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`a single brief. Motion, at 11-12. While on the surface this appears to have an
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`even-handed effect on the parties, in actuality the reduced ability to address the
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`grounds for unpatentability more severely handicaps Petitioner. Petitioner has the
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`burden to prove that the challenged claims are unpatentable by a preponderance of
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`the evidence. 35 U.S.C. 316(e) and 37 C.F.R. § 42.2(c). Accordingly, if Petitioner
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`and Patent Owner are unable to sufficiently address the grounds for unpatentability
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`in a single briefing, it is Petitioner who pays the price. In theory, Petitioner could
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`lose its challenge by presenting limited arguments, all while Patent Owner remains
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`silent.
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`D.
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`Patent Owner’s Motion For Joinder Is Premature
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`Patent Owner has requested joinder of the proceedings under 37 C.F.R. §
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`42.122(b). Motion, at 14. In relevant part, § 42.122(b) states, “Any request for
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`
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`11
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`IPR2014-00289
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`joinder must be filed, as a motion under §42.22, no later than one month after the
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`institution date of any inter partes review for which joinder is requested.” 37
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`C.F.R. § 42.122(b) (emphasis added). Patent Owner urges that this provision
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`should be interpreted to allow a motion for joinder to “be filed any time after a
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`petition is filed up until one month after institution.” Motion, at 14. Patent
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`Owner’s interpretation is incorrect.
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`Section 42.122(b) implements 35 U.S.C. § 315(c), which requires the
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`institution of an inter partes review before joinder is permitted:
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`(c) JOINDER.--If the Director institutes an inter partes
`review, the Director, in his or her discretion, may join as
`a party to that inter partes review any person who
`properly files a petition under section 311 that the
`Director, after receiving a preliminary response under
`section 313 or the expiration of the time for filing such a
`response, determines warrants the institution of an inter
`partes review under section 314.
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`35 U.S.C. §315(c) (emphasis added). Because § 42.122(b) stems from 35 U.S.C. §
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`315(c), institution of an inter partes review is also required before joinder can
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`occur under § 42.122(b). See, e.g., Fifth Third Bank v. Leon Stambler, IPR2014-
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`00244, Paper No. 4, at 5.
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`
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`In addition to the express statutory language, practicality supports that an
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`inter partes review proceeding be instituted before permitting joinder. Joinder is
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`12
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`IPR2014-00289
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`proper when it complies with the Board’s mandate “to secure the just, speedy, and
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`inexpensive resolution of every proceeding.” 37 C.F.R. § 42.1(b). Because the
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`Board has not reached an institution decision in any of the five IPR proceedings, it
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`is unclear which grounds the parties will ultimately move forward on in each
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`proceeding. As such, Patent Owner’s statements regarding any supposed
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`efficiencies gained through pre-institution joinder are purely speculative.
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`IV. PATENT OWNER DOES NOT HAVE AUTHORIZATION TO SEEK
`DENIAL OF THE PETITIONS
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`A motion will not be entered without Board authorization. 37 C.F.R. §
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`42.20(b). In this case, “the panel authorized Patent Owner to file its requested
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`motion to join the five related proceedings.” Paper No. 10, at 3-4 (emphasis
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`added). As such, Patent Owner had authority to file a motion for joinder, but
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`nothing more. While captioned as a motion for joinder, Patent Owner did not limit
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`its motion to the issue of joinder. Motion, Cover Sheet. Rather, Patent Owner
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`spent the bulk of its motion—over 10 of its 16 pages—arguing that Petitioner has
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`not complied with the so-called “One Petitioner, One Voice rule” 4 and asking the
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`4 The “One Petitioner, One Voice rule” cited by Patent Owner presumably refers to
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`the Board’s decision in Agilysys, Inc., et al. v. Ameranth, Inc., CBM2014-00014,
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`Paper No. 11. Contrary to the present case, in which the parties have designated a
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`single lead counsel and have agreed to speak with a single voice on each petition,
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`13
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`IPR2014-00289
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`Board to deny each of the five petitions pursuant to§ 42.10(a) and to require
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`Petitioner to re-designate its counsel. Motion, at 1-11. As Patent Owner did not
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`have permission to brief or make a motion regarding the “One Petitioner, One
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`Voice rule,” Petitioner asks that Patent Owner’s requests be denied.
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`To the extent the Board elects to consider Patent Owner’s request, Petitioner
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`maintains that it has not violated the supposed “One Petitioner, One Voice rule.”
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`In each of the five proceedings, Petitioner has designated a single lead counsel,
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`who has been selected to speak on behalf of all of the petitioners. See IPR2014-
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`00279, Paper No. 1, at 3-4; IPR2014-00280, Paper No. 1, at 2-3; IPR2014-00281,
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`Paper No. 1, at 2-3; IPR2014-00289, Paper No. 3, at 3-4; and IPR2014-00291,
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`Paper No. 1, at 4-5. Honda agrees with the other petitioners that each lead counsel
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`is the “single voice” for its respective petition, and Honda will not seek to advance
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`different positions, either orally or in writing, from those presented by the lead
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`counsel. As such, Petitioner has and will continue to speak with “one voice” in
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`each individual IPR proceeding. Nonetheless, Petitioner notes that nothing in the
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`rules or Board precedent supports the extraordinary remedy Patent Owner is
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`seeking—denial of institution—for alleged non-compliance with the “One
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`the thirty-five parties in Agilysys had designated fifteen separate lead counsel and
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`had each requested the ability to present their own positions. Id. at 2.
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`
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`14
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`
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`Petitioner, One Voice rule.” See, e.g., Agilysys, Inc., et al., v. Ameranth, Inc.,
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`IPR2014-00289
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`CBM2014-00014, Paper No. 11.
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`V. CONCLUSION
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`For at least the reasons discussed herein, Patent Owner has not met its
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`burden to establish that the proceedings should be joined. Accordingly, Petitioner
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`requests that the Board deny Patent Owner’s Motion for Joinder.
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`
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`Dated: May 8, 2014
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`
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`
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`By: /John M Caracappa Reg No 43532/
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`Respectfully submitted,
`
`John M. Caracappa
`Paul D. Lall
`Tremayne M. Norris
`Stephanie L. Schonewald
`STEPTOE & JOHNSON LLP
`1330 Connecticut Avenue, NW
`Washington, DC 20036-1795
`Telephone: 202-429-3000
`Facsimile: 202-429-3902
`
`Counsel for American Honda Motor Co. Inc.
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`15
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`
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a copy of the attached OPPOSITION TO
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`PATENT OWNER’S MOTION FOR JOINDER, was served via electronic mail on
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`May 8, 2014, to the following:
`
`John R. Kasha
`KASHA LAW LLC
`john.kasha@kashalaw.com
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` Respectfully submitted,
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`Date: May 8, 2014 By:
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`/Stephanie L Schonewald/
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`John M. Caracappa
`Paul D. Lall
`Tremayne M. Norris
`Stephanie L. Schonewald
`STEPTOE & JOHNSON LLP
`1330 Connecticut Avenue, NW
`Washington, DC 20036-1795
`Telephone: 202-429-3000
`Facsimile: 202-429-3902
`
`Counsel for American Honda Motor Co.
`Inc.
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