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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO. LTD., )
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`SAMSUNG ELECTRONICS AMERICA, INC., )
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`SAMSUNG TELECOMMUNICATIONS AMERICA, )
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`LLC, and )
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`SAMSUNG AUSTIN SEMICONDUCTOR, LLC, )
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` )
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` Petitioner, )
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` )
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` vs. ) Case IPR2014-00514
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`REMBRANDT WIRELESS TECHNOLOGIES, LP,) Patent 8,023,580
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` Patent Owner. )
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`____________________________________)
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` TRANSCRIPT OF TELEPHONIC CONFERENCE CALL,
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`commencing at 12:00 p.m., Monday, July 21, 2014, before
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`JAMESON LEE, HOWARD B. BLANKENSHIP and JUSTIN BUSCH,
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`Administrative Patent Judges, reported by Staci A.
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`Iwahashi, CSR 11807.
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`FILE NO.: 1900460
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`Veritext National Deposition & Litigation Services
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`Page 1
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`Exhibit 1020 01/19
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` A P P E A R A N C E S :
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`A D M I N I S T R A T I V E P A T E N T J U D G E S :
`J A M E S O N L E E , A d m i n i s t r a t i v e P a t e n t J u d g e
`H O W A R D B . B L A N K E N S H I P
`J U S T I N B U S C H
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`F O R T H E P E T I T I O N E R :
`D I C K S T E I N S H A P I R O , L L P
`B Y : J E F F R E Y A . M I L L E R , A T T O R N E Y A T L A W
`B Y : D A N I E L G . C A R D Y , A T T O R N E Y A T L A W
`1 8 4 1 P a g e M i l l R o a d
`S u i t e 1 5 0
`P a l o A l t o , C a l i f o r n i a 9 4 3 0 4
`( 6 5 0 ) 6 9 0 - 9 5 6 4
`( 6 5 0 ) 6 9 0 - 9 5 0 1 f a x
`m i l l e r j @ d i c k s t e i n s h a p i r o . c o m
`c a r d y g @ d i c k s t e i n s h a p i r o . c o m
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`F O R T H E P A T E N T O W N E R :
`P E P P E R H A M I L T O N , L L P
`B Y : T H O M A S E N G E L L E N N E R , A T T O R N E Y A T L A W
`B Y : R E Z A M O L L A A G H A B A B A , A T T O R N E Y A T L A W
`B Y : L A N A G L A D S T E I N , A T T O R N E Y A T L A W
`H i g h S t r e e t T o w e r
`1 2 5 H i g h S t r e e t
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`e n g e l l e n n e r t @ p e p p e r l a w . c o m
`m o l l a a g h a b a b a r @ p e p p e r l a w . c o m
`g l a d s t e i n l @ p e p p e r l a w . c o m
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`Exhibit 1020 02/19
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` TELEPHONE CONFERENCE CALL
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` MONDAY, JULY 21, 2014;
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` 12:00 P.M.
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` - - -
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` JUDGE LEE: Hi, good afternoon. This is Judge
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`Lee. I have my colleagues on the line with me Judge
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`Busch and Judge -- can you hear me?
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` MS. REPORTER: Yes.
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` JUDGE LEE: Great. This should be a telephone
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`conference call for two IPRs: IPR 2014-00514 and IPR
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`2014-00515. Is that correct?
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` MR. MILLER: Yes, Your Honor.
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` JUDGE LEE: Thank you. I'm wondering if
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`either party arranged for a court reporter?
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` MR. MILLER: Yes, Samsung arranged for a court
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`reporter. I think she just announced herself.
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` JUDGE LEE: Okay, wonderful. So the caption
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`for both cases is Samsung vs. Rembrandt. And I think
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`the petitioner requested the call, so we would like to
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`have the petitioner begin, but right after we take a
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`role call and see who's representing whom.
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` MR. MILLER: This is Jeffrey Miller
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`representing Samsung and, I believe, my colleague, Dan
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`Cardy, the backup counsel in these cases is also on the
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`Exhibit 1020 03/19
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`line.
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` JUDGE LEE: Thank you.
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` MR. ENGELLENNER: And this is Tom Engellenner
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`from Pepper Hamilton representing Rembrandt, and my
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`backup counsel Reza Mollaaghababa and Lana Gladstein
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`are here with me.
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` JUDGE LEE: Thank you.
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` Go ahead, Mr. Miller.
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` MR. MILLER: All right. Thank you --
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` MS. REPORTER: One second. I apologize, this
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`is the court reporter.
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` [Brief discussion]
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` JUDGE LEE: I'm Judge Lee, Jameson Lee. And
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`Samsung will be just Mr. Jeff Miller speaking; is that
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`right?
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` MR. MILLER: Unless I need some backup
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`assistance from Mr. Cardy, but yes, that's our plan.
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` JUDGE LEE: Okay. And for Rembrandt, the
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`person who will be --
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` MR. ENGELLENNER: Yes, Tom Engellenner.
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` MS. REPORTER: Okay. Very good. Thank you
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`for that, Judge.
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` JUDGE LEE: Thank you.
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` Go ahead, Mr. Miller.
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` MR. MILLER: Thank you.
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`Exhibit 1020 04/19
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` The reason we set up a call is that Samsung
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`would like to have an opportunity to file a short, you
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`know, maybe five-page response to the patent owner's
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`preliminary response in both of the IPRs. And the
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`reason is as follows: in these two particular IPRs, the
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`base reference that we've relied on to invalidate the
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`claims is a draft specification from the IEEE. And we
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`put in a declaration from a Mr. O'Hara who was on the
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`committee that was working on this standard. And in
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`the -- and he made certain statements that we were using
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`to show that this was a printed publication.
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` In the patent owner's preliminary response,
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`there really -- under the broad heading, there were two
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`things that were done that we would like to respond to.
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`The first is that they have accused certain of the
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`things that Mr. O'Hara said as basically not being true.
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`And in order to do so, they cite some evidence and we
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`think that that evidence has been misconstrued, and we
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`can go into details about it if you like. But generally
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`speaking, there's certain allegations that they make
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`referencing to documents that we think is inaccurate.
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` The second thing they've done is they have made
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`a hearsay objection in a form that we think is not in
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`accordance of the way that it should have been handled
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`and we would like an opportunity to respond to that as
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`Exhibit 1020 05/19
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`well.
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` JUDGE LEE: Well, I'm sure you know the
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`Board's rules in IPRs and that is to prohibit the
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`filing of replies by a petitioner.
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` Now, what you've just told us is probably
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`typical of every single IPR. So we're just wondering,
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`what in your mind would set your case apart from the
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`hundreds of other cases where the petitioner does not
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`get an opportunity to file a short reply? I'm sure in
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`many of those cases the petitioner would say, Well,
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`there's something I would like to respond to and the
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`patent owner's response. I mean, if we started doing
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`this for you, we'll have to do it for everybody. So
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`what makes your case stand out?
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` MR. MILLER: Well, I -- so, I guess I'll take
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`two things at a time. Firstly, with respect to, I
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`think most IPRs, I don't think that there's a situation
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`where, you know, the patent owner in its preliminary
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`response is -- refer to documents and it construes them
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`in -- assert that they say certain things that frankly
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`they don't say.
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` And so, you know, the Board I think in this
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`situation would be helped by, you know, a short -- we're
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`not asking for a lengthy response, but a short
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`explanation as to what Rembrandt in this case has --
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`Exhibit 1020 06/19
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`that it just went wrong.
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` And with respect to the hearsay objection, I
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`mean, I'm not sure what to say there. Normally my
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`understanding is that a hearsay objection was supposed
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`to have been served on us before it was brought out to
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`give us an opportunity to cure. And that wasn't done
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`here. So that's not really a problem of our making.
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` JUDGE LEE: Well, we are aware of our own
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`rules. So the patent owner does have some time after
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`institution to make the objection to evidence. So I
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`don't think you need to worry about your point No. 2.
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`I mean, if our rules say, Do not provide by hearsay
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`objections in a preliminary response, then we're likely
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`not going to pay any attention to it. We're just going
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`to look at your initial submission. So I don't think
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`your point No. 2 is really something that you need to
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`worry about.
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` We are aware of our own rules which provide the
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`patent owner an opportunity to make objection to
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`evidence relied on by the petitioner after institution.
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` But still, we're -- I'm still puzzled as to how
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`your case stands out. There's plenty of cases where the
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`patent owner relies on documents. Under our rules, they
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`simply cannot submit a new declaration but they
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`certainly can put in a reference to any preexisting
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`Exhibit 1020 07/19
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`declaration or refer to any other document. It seems
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`commonplace. So based on what you say, we're still at a
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`loss as to why you're asking us to make a major
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`deviation from the framework of IPR procedures.
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` MR. MILLER: Well, I mean -- so that's why we
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`asked for the call, which was to ask you how best to go
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`about doing this. And we're not trying to subvert any
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`rules of course. It just seems frankly in the IPRs
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`that I've been involved with, which admittedly it's a
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`fairly new process; there's not a ton of them. And,
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`you know, I watched the docket. This is -- it's not a
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`situation where they say a priori reference teaches X
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`and we don't agree with that. That's not what we're
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`trying to comment on.
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` What we're trying to say is that they said, for
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`example, that a document says that, um -- the standard
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`that we're talking about was not distributed. But a
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`person like Mr. O'Hara, for example, who actually has
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`knowledge and can state unequivocally that they're
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`wrong. I mean, the document that they refer to is
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`referring to different documents that aren't supposed to
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`be distributed.
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` And, you know, I will -- so, you know, we think
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`that in a situation like this, that we would like to
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`make sure that the record is clear when you make your
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`decision as to whether or not to institute that there
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`are certain statements that were made that are just not
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`true, very inaccurate.
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` JUDGE LEE: All right. I certainly appreciate
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`your deep concern for your own case but it really
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`sounds like a routine problem; that our rules simply do
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`not provide you an opportunity to reply. They are
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`prohibited from submitting new declaration evidence.
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`So whatever they relied on is not supported by new
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`declaration evidence and we are going to be able to
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`recognize something that is simply said by the attorney
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`or a characterization versus something that is
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`supported by a declaration testimony. So I'm not sure
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`how to alleviate your concerns except to say that we
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`know the difference between attorney argument and
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`something that is supported by declaration testimony.
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` MR. MILLER: Okay. I mean, that's why we
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`wanted to have this call, was that we were hoping to be
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`able to explain some of it. But if the Board feels as
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`though it would be able to read the submissions and be
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`able to see what's supported by a declaration and what
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`is not, then I guess we'll have to wait and see.
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` JUDGE LEE: All right.
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` How about Mr. Engellenner from Rembrandt? Do
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`you have anything you would like to say?
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` MR. ENGELLENNER: No, I think -- well, yes,
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`Your Honor, very briefly. I agree with you that the
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`statutory framework doesn't provide for petitioners to
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`have a reply and I don't see this case as exceptional
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`in any way.
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` As to the evidence and the hearsay objection,
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`what we are essentially saying in our reply is that the
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`declaration that was submitted is deficient, unreliable
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`and I think the evidence that we've submitted along with
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`our preliminary response will show all the reasons why
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`it's unreliable and does not support their case. It
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`does not support the case that the working standard of
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`1996 was indeed a printed publication at that time.
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` JUDGE LEE: Right. I wanted to make sure you
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`get an opportunity to speak.
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` MR. ENGELLENNER: Thank you.
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` JUDGE LEE: Mr. Miller, another thing I wanted
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`to mention is that, while we appreciate where you're
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`coming from, there's also another problem we would have
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`to handle if we were to allow you the five pages. It
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`would be extremely difficult for us to police how you
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`would be made to stay within strict boundaries.
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` Just for argument purposes, let's say that your
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`petition is extremely deficient; that your supporting
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`declaration is just bad. You didn't dot the Is and
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`cross the Ts and somehow you're able to -- like you
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`shoestring into something you're able to do, an
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`opportunity to cure all those deficiencies. And now you
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`can say, Well, there's something the patent owner said
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`in their preliminary response that -- because their
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`characterization is misleading and I want to respond to
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`that.
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` Let's say that, yes, we allow you to give a
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`brief clarification but it's really impossible to police
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`that you stay within those boundaries and not take the
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`furthest step to try to cure the deficiencies that
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`are -- existed in any way regardless of their
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`mischaracterization. You know, they can be without the
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`mischaracterizations and your declarations are still
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`deficient. And I just don't see any possible way to
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`make sure that you stay within the boundaries of what
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`you say you're going to do. Because you can put
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`anything you want in the five pages and then argue that
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`it's only for clarification, but in fact, you probably
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`have cured deficiencies in your declaration. So that's
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`another reason I'm very concerned about.
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` MR. MILLER: Okay. I understand what you're
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`saying. Just to be clear, I don't think that Rembrandt
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`is saying that the declaration is deficient. I think
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`what they're saying is that it is not reliable, and
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`that's why we wanted to respond.
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` JUDGE LEE: Well, same thing. You know, it's
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`deficient because it's not reliable. And if we allow
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`you to cure it by saying this, that and the other, then
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`we're going way outside our procedural framework. You
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`don't get a second opportunity to bolster or to further
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`support your initial declaration. You know, they get
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`to say why your declaration is unreliable. Period.
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`And if they're right and we are persuaded thereby, then
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`we don't institute a review. You don't get another
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`opportunity to say why they're wrong. That's why when
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`you file your petition you should do your homework and
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`make sure it's completely unassailable.
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` MR. MILLER: We believe we've done that, Your
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`Honor. We believe that the declaration is
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`unassailable. Of course it's difficult to have a
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`declarant say something and predict what someone's
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`going to misrepresent.
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` JUDGE LEE: Well, you know, in your e-mail
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`asking for the call you didn't say anything about
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`misrepresentation. So now you're taking it to another
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`level. So are you sure you want to say
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`misrepresentation versus their eager representation or
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`mischaracterization? You know, we don't take that word
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`lightly.
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` MR. MILLER: And I don't either. And you
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`know, when -- you know, it could be that they say --
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`you know, when they say that a document says something
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`but I happen to know it means something different,
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`maybe that to me is a misrepresentation and maybe
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`that's something else to somebody else.
`
` JUDGE LEE: Well, yeah. You got to know
`
`that's fighting word.
`
` MR. MILLER: Yeah.
`
` JUDGE LEE: And you can't just be, you think
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`one way and think the other; therefore, they
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`misrepresent it. Because I draw a line of distinction.
`
`If you say someone egregiously misrepresented
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`something, they need to be referred to OED and possibly
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`disbarred and sanctioned. Well, that's ringing the
`
`bell. We might give you an opportunity to say
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`something because that distinguishes from the hundreds
`
`of other cases that we have.
`
` So far, you haven't said that. But I just
`
`heard you utter the word "misrepresent", so which is it?
`
`You know, I don't want you to say it lightly. If you
`
`say you want to send them to OED and accuse them of
`
`something sanctionable by OED or you want to take them
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`to the State Bar, just let me know. But I don't think
`
`that's what you're saying.
`
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`Exhibit 1020 13/19
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`1
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`2
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`4
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` MR. MILLER: No, I -- that's not what I'm
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`saying.
`
` JUDGE LEE: All right. Then why don't you
`
`take back "misrepresent" because that's not what you
`
`want to say.
`
` MR. MILLER: All right. I will take back the
`
`"misrepresent." But we do assert that they have
`
`asserted the documents say things that they don't say,
`
`so.
`
` JUDGE LEE: All right. So let's -- that's
`
`routine. It's not anything unusual. Like I said
`
`before, we know the difference between something that's
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`just characterized in attorney argument versus
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`something that has full support in a declaration. I
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`don't think you have any worries for that, so.
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` I'm not going to decide this at the moment but
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`it's unlikely that you're going to get the relief you
`
`seek. But I'll have to talk to my colleagues after the
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`call and then you'll get our decision afterwards. But
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`it seems really unlikely based on what I said and based
`
`on the representation the parties made.
`
` Well, before we go, I'll give you an
`
`opportunity. You want us to -- you want the panel to
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`deliberate and give you an order or are you just
`
`satisfied that we had this call and you withdraw the
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`Exhibit 1020 14/19
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`
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`1
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`2
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`3
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`4
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`5
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`6
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`7
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`8
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`9
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`10
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`11
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`12
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`13
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`18
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`20
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`21
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`22
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`23
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`24
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`25
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`request?
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` MR. MILLER: I think that we'll withdraw the
`
`request.
`
` JUDGE LEE: All right. I'm glad we had the
`
`call too and I had the chance to explain some things,
`
`so. This is a good way to streamline matters and I'm
`
`glad everyone is reasonable. And thank you for the
`
`call. We are adjourned.
`
` MR. MILLER: Thank you.
`
` MR. ENGELLENNER: Thank you, Your Honor.
`
` (Ending time: 12:18 p.m.)
`
` --o0o--
`
` I declare under penalty of perjury
`
` that the foregoing is true and correct.
`
` DATED at Sacramento, California,
`
` this 24th day of July, 2014.
`
` ____________________________________
`
` STACI A. IWAHASHI, CSR No. 11807
`
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`Exhibit 1020 15/19
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`
`
`[02110-2736 - difference]
`
`0
`02110-2736 2:21
`1
`11807 1:19 15:21
`125 2:20
`12:00 1:16 3:3
`12:18 15:12
`150 2:12
`1841 2:11
`1900460 1:25
`1996 10:13
`19th 2:21
`2
`2 7:11,16
`2014 1:16 3:2 15:19
`2014-00514 3:11
`2014-00515 3:12
`204-5100 2:22
`204-5150 2:22
`21 1:16 3:2
`24th 15:19
`6
`617 2:22,22
`650 2:13,13
`690-9501 2:13
`690-9564 2:13
`8
`8,023,580 1:10
`9
`94304 2:12
`a
`able 9:10,19,20,21
`11:1,2
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`2:4,5
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`
`ahead 4:8,24
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`12:3
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`b 1:17 2:6
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`2:6
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`board 1:2 6:22 9:19
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`
`c 2:1
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`9:12 11:6
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`
`commonplace 8:2
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`3:11
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`
`dan 3:24
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`11:20
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`11:15,24 12:3
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`details 5:19
`deviation 8:4
`dickstein 2:10
`dicksteinshapiro.c...
`2:14,14
`difference 9:15
`14:12
`
`Page 1
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`Veritext National Deposition & Litigation Services
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`Exhibit 1020 16/19
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`
`
`[different - mischaracterizations]
`
`different 8:21 13:4
`difficult 10:21 12:16
`disbarred 13:15
`discussion 4:12
`distinction 13:12
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`document 8:1,16,20
`13:3
`documents 5:21
`6:19 7:23 8:21 14:8
`doing 6:12 8:7
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`draft 5:7
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`e
`e 2:1,1 12:19
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`electronics 1:5,5
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`4:3,20,20 9:24 10:1
`10:16 15:10
`engellennert 2:23
`essentially 10:7
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`evidence 5:17,18
`7:10,20 9:8,10 10:6
`10:9
`example 8:16,18
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`f
`fact 11:19
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`
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`
`g 2:11
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`14:22
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`11:17 12:5,18 14:16
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`h
`hamilton 2:18 4:4
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`7:12 10:6
`
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`i
`
`ieee 5:7
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`jameson 1:17 2:5
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`3:10,14,18 4:2,7,13
`4:13,18,22,23 6:2
`7:8 9:4,23 10:14,17
`12:2,19 13:7,10
`14:3,10 15:4
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`k
`know 5:3 6:2,18,22
`6:23 8:11,23,23
`9:15 11:13 12:2,7
`12:19,24 13:2,2,3,4
`13:7,21,24 14:12
`
`knowledge 8:19
`l
`lana 2:19 4:5
`law 2:10,11,18,19
`2:19
`lee 1:17 2:5 3:6,7,10
`3:14,18 4:2,7,13,13
`4:13,18,23 6:2 7:8
`9:4,23 10:14,17
`12:2,19 13:7,10
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`
`m
`mail 12:19
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`mill 2:11
`miller 2:10 3:13,16
`3:23,23 4:8,9,14,16
`4:24,25 6:15 8:5
`9:17 10:17 11:22
`12:14 13:1,9 14:1,6
`15:2,9
`millerj 2:14
`mind 6:7
`mischaracterization
`11:13 12:24
`mischaracterizatio...
`11:14
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`Page 2
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`Veritext National Deposition & Litigation Services
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`Exhibit 1020 17/19
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`
`
`[misconstrued - show]
`
`misconstrued 5:18
`misleading 11:6
`misrepresent 12:18
`13:12,20 14:4,7
`misrepresentation
`12:21,23 13:5
`misrepresented
`13:13
`mollaaghababa
`2:19 4:5
`mollaaghababar
`2:23
`moment 14:16
`monday 1:16 3:2
`n
`
`n 2:1
`need 4:16 7:11,16
`13:14
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`o
`o'hara 5:8,16 8:18
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`p
`
`p 2:1,1
`p.m. 1:16 3:3 15:12
`
`page 2:11 5:3
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`2:23,23,24
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`
`r 2:1
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`
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`s
`
`s 2:1
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`short 5:2 6:9,23,24
`show 5:11 10:10
`
`Page 3
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`Veritext National Deposition & Litigation Services
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`Exhibit 1020 18/19
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`
`
`[simply - yeah]
`
`simply 7:24 9:6,11
`single 6:6
`situation 6:17,23
`8:12,24
`somebody 13:6
`someone's 12:17
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`10:12
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`supported 9:9,13,16
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`sure 6:2,9 7:3 8:25
`9:13 10:14 11:16
`12:13,22
`
`t
`take 3:21 6:15 11:10
`12:24 13:23 14:4,6
`
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`telecommunications
`1:6
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`thank 3:14 4:2,7,9
`4:21,23,25 10:16
`15:7,9,10
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`12:2
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`6:20 14:8 15:5
`think 3:17,19 5:18
`5:21,23 6:17,17,22
`7:11,15 8:23 10:1,9
`11:23,24 13:10,11
`13:24 14:15 15:2
`thomas 2:18
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`15:12
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`u
`
`um 8:16
`unassailable 12:13
`12:16
`understand 11:22
`understanding 7:4
`
`unequivocally 8:19
`united 1:1
`unreliable 10:8,11
`12:8
`unusual 14:11
`utter 13:20
`v
`versus 9:12 12:23
`14:13
`vs 1:9 3:19
`w
`wait 9:22
`want 11:6,18 12:22
`13:21,22,23 14:5,23
`14:23
`wanted 9:18 10:14
`10:17 12:1
`watched 8:11
`way 5:24 10:5 11:12
`11:15 12:5 13:11
`15:6
`we've 5:6 10:9 12:14
`went 7:1
`wireless 1:10
`withdraw 14:25
`15:2
`wonderful 3:18
`wondering 3:14 6:6
`word 12:24 13:8,20
`working 5:9 10:12
`worries 14:15
`worry 7:11,17
`wrong 7:1 8:20
`12:11
`
`x
`
`x 8:12
`
`y
`yeah 13:7,9
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`Page 4
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`Exhibit 1020 19/19
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`