IPR2014-00648
`U.S. Patent No. 8,217,612
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`Filed on behalf of UUSI, LLC
`By: Monte L. Falcoff (mlfalcoff@hdp.com)
`Hemant M. Keskar (hkeskar@hdp.com)
`HARNESS, DICKEY & PIERCE, P.L.C.
`5445 Corporate Drive, Ste. 200
`Troy, MI 48098
`Telephone: (248) 641-1600
`Facsimile: (248) 641-0270
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`________________________________
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`WEBASTO ROOF SYSTEMS, INC.
`Petitioner
`
`v.
`
`UUSI, LLC
`Patent Owner
`______________
`
`Case IPR2014-00648
`Patent 8,217,612
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`
`
`
`PATENT OWNER’S OPPOSITION TO PETITIONER'S MOTION TO
`EXCLUDE THE OPINION TESTIMONY OF DR. MARK EHSANI AND
`INADMISSIBLE EXHIBITS
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`
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`U.S. Patent No. 8,217,612
`
`
`Filed on behalf of UUSI, LLC
`By: Monte L. Falcoff (mlfalcoff@hdp.com)
`Hemant M. Keskar (hkeskar@hdp.com)
`HARNESS, DICKEY & PIERCE, P.L.C.
`5445 Corporate Drive, Ste. 200
`Troy, MI 48098
`Telephone: (248) 641-1600
`Facsimile: (248) 641-0270
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________________________
`
`WEBASTO ROOF SYSTEMS, INC.
`Petitioner
`
`v.
`
`UUSI, LLC
`Patent Owner
`______________
`
`Case IPR2014-00648
`Patent 8,217,612
`
`
`
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`PATENT OWNER’S OPPOSITION TO PETITIONER'S MOTION TO
`EXCLUDE THE OPINION TESTIMONY OF DR. MARK EHSANI AND
`INADMISSIBLE EXHIBITS
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`IPR2014-00648
`U.S. Patent No. 8,217,612
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`TABLE OF CONTENTS
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`Page
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`1.
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`DR. EHSANI USED CORRECT LEGAL PRINCIPLES IN
`FORMING HIS OPINION AND PREPARING HIS
`DECLARATION................................................................................. 1
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`a.
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`b.
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`Dr. Ehsani did not prepare his Declaration with the incorrect
`understanding that the patent is presumed valid and requires
`clear and convincing evidence to invalidate ............................. 1
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`Dr. Ehsani formed his opinion and prepared his Declaration
`with the correct claim interpretation understanding ................. 3
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`c.
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`Dr. Ehsani did not construe claims contrary to their structure . 6
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`DR. EHSANI FULLY ANSWERED THE DEPOSITION
`QUESTIONS; PETITIONER SIMPLY DID NOT LIKE THE
`ANSWERS .......................................................................................... 8
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`PATENT OWNER DID NOT FILE INADMISSIBLE
`EXHIBITS ........................................................................................... 9
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`2.
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`3.
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`4.
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`CONCLUSION ................................................................................. 13
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`IPR2014-00648
`U.S. Patent No. 8,217,612
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`The Board should deny Petitioner's Motion to Exclude the Declaration of
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`Patent Owner's expert, Dr. Mark Ehsani, and certain exhibits relied on by Patent
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`Owner and its expert in its Response. The Board should deny the motion because
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`Dr. Ehsani formed his opinion and prepared his Declaration using the correct legal
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`standards and claim construction methods. Further, Dr. Ehsani fully answered
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`Petitioner's questions, often repeatedly asked by Petitioner over the course of two
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`days, and Petitioner's unhappiness with Dr. Ehsani's answers is not the same as his
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`resisting answering questions and is therefore insufficient grounds for excluding
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`his testimony. Additionally, the Board should deny the motion because the
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`exhibits at issue are properly relied on by Patent Owner and Dr. Ehsani, and/or are
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`simply demonstrative exhibits. Patent Owner disputes Petitioner's alleged material
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`facts and addresses them below.
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`1. DR. EHSANI USED CORRECT LEGAL PRINCIPLES IN
`FORMING HIS OPINION AND PREPARING HIS DECLARATION
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`a. Dr. Ehsani did not prepare his Declaration with the incorrect
`understanding that the patent is presumed valid and requires clear and
`convincing evidence to invalidate
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`Mischaracterizing Dr. Ehsani's deposition testimony, Petitioner alleges that
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`Dr. Ehsani's opinion is legally flawed because the opinion is based on his
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`allegedly incorrect understanding that the patent at issue must be invalidated by
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`clear and convincing evidence in this proceeding. Paper 26 at 6. In the cited
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`1
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`IPR2014-00648
`U.S. Patent No. 8,217,612
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`testimony, however, Dr. Ehsani merely explained his thorough understanding of
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`the examination process employed by the U.S. Patent Office in issuing patents.
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`Dr. Ehsani presumed that the patent examiner did a thorough job when the patent
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`issued as his testimony indicates: "the U.S. examiner will also independently,
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`through his own resources and expertise, bring to bear other prior art, and that
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`going through that exercise, which is rather rigorous, produces a fairly substantial
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`prosecution history and -- and record and most often modification and -- and
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`settlement on -- on specific claims -- claims. Through that laborious process, the
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`patent is finally issued[.]" Ex. 1023 at 3 (212:4-12). Petitioner conveniently
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`omitted this background testimony appearing on the same transcript page as the
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`portions it cites to.
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`Dr. Ehsani was neither clearly asked, nor did he clearly testify, that his
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`opinion in his Declaration is based on his understanding that the patent at issue
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`must be invalidated by clear and convincing evidence in this proceeding. In fact,
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`Dr. Ehsani was never asked anything about the burden of proof in this proceeding.
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`While Petitioner complains that Dr. Ehsani did not mention anything in his
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`Declaration about the presumption of validity and burdens in this proceeding, nor
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`did Petitioner's expert, Dr. Hamid A. Toliyat. It is noteworthy that Dr. Ehsani
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`reviewed Petitioner's corrected petitions and expert declarations (see Ex. 2001 at ¶
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`15, pp. 8-11); accordingly, Dr. Ehsani considered the correct burden of proof and
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`2
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`IPR2014-00648
`U.S. Patent No. 8,217,612
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`legal standards to the extent they were correctly stated by Petitioner and/or its
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`expert witnesses. Therefore, Petitioner's allegation that Dr. Ehsani's testimony is
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`unreliable because it is based on misapplication of legal principles is a blatant
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`mischaracterization of Dr. Ehsani's testimony and Dr. Ehsani's Declaration, which
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`fully satisfies the requirements of FRE 702 and is therefore admissible.
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`b. Dr. Ehsani formed his opinion and prepared his Declaration with the
`correct claim interpretation understanding
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`Petitioner further alleges that Dr. Ehsani's Declaration should be excluded
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`because he incorrectly interpreted the claims by confining them to the preferred
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`embodiment. Paper 26 at 8. In support, Petitioner cites Dr. Ehsani's deposition
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`testimony taken out of context and then exaggerates and mischaracterizes it. The
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`cited testimony was preceded by an extended colloquy about whether Claim 1 of
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`the '612 Patent can be practiced using parameters other than current and pulse
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`period mentioned in the '612 Patent. As evidenced by the emphasized portions of
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`the testimony excerpted below, Dr. Ehsani repeatedly indicated that the
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`parameters at issue are not limited to current and pulse period mentioned in the
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`alleged preferred embodiment.
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`Q. (BY MR. SANDERS) I'm not asking you about – I don't know
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`whether it's in your report. I don't care. I'm just entitled to ask you a
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`question and find out what assumptions you applied for your
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`analysis. So I'll ask it one more time. For the purpose of your analysis
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`3
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`IPR2014-00648
`U.S. Patent No. 8,217,612
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`for reaching the opinions you've set forth in these proceedings, did
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`you believe it was necessary for an apparatus to use the parameters
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`current and pulse period in order to satisfy Claim 1 of the '612
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`patent?
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`MR. KESKAR: Same objection, answer requires speculation.
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`A. I don't know if it's necessary. I know that it's sufficient.
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`Ex. 1022 at 15 (56:4-17) (emphasis added).
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`Q. (BY MR. SANDERS) From your perspective, as someone who
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`has been hired to offer technical expertise in this matter, are there
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`other parameters besides current and pulse period that an apparatus
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`could use and satisfy Claim 1 of the '612 patent?
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`A. As an expert, I can tell you that it is possible, not as a hired
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`person, but as an expert.
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`Id. at 15 (56:20-57:1) (emphasis added).
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`Q. And when you say, "these are the two parameters that are the
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`subject of the invention," which parameters are you referring to?
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`A. Speed and torque, and all other detectable variables that are
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`indicative of, you know, those in a one-to-one manner.
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`Id. at 16 (59:23-60:3) (emphasis added).
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`Q. In your view of the invention of the '612 patent are directed to an
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`obstacle detection methods that use some parameters that have one-
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`to-one linkage to speed and to torque, correct?
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`A. Well, as I recall, it says two parameters and we are -- the preferred
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`embodiment that narrows down. I'm not a lawyer to understand
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`IPR2014-00648
`U.S. Patent No. 8,217,612
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`interpretation outside of the preferred embodiment by the patent. I
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`have analyzed the preferred embodiment.
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`Q. So you --
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`A. I cannot tell if the patent can be interpreted more broadly than
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`that.
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`Id. at 17 (64:3-14) (emphasis added).
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`Significantly, Petitioner ignores Dr. Ehsani's prior testimony cited above,
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`where he repeatedly testified that while the alleged preferred embodiment of the
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`'612 Patent included parameters current and pulse period, these parameters are not
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`necessary but only sufficient and that the claim at issue could encompass all other
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`parameters indicative of speed and torque in one-to-one manner. Instead,
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`Petitioner deliberately cites only the concluding portion of the colloquy and
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`mischaracterizes Dr. Ehsani's last three sentences and misstates them as "his
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`testimony that he failed to heed the Federal Circuit's warning against confining the
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`claims to the preferred embodiment," which is simply not Dr. Ehsani's testimony.
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`Paper 26 at 8. Rather, Dr. Ehsani merely stated, after being repeatedly badgered,
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`that "I cannot tell if the patent can be interpreted more broadly than that" since he
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`is a technical expert and "not a lawyer" (see Ex. 1022 at 17 (64:9)). This is not the
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`same as testifying that "the patent cannot be interpreted more broadly than that,"
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`particularly in light of his earlier contrary testimony, which Petitioner
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`surreptitiously chooses to ignore. Indeed, Petitioner disregards Dr. Ehsani's
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`5
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`IPR2014-00648
`U.S. Patent No. 8,217,612
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`statement immediately preceding the cited testimony: "Well, as I recall, [the '612
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`patent] says two parameters and . . . the preferred embodiment that narrows
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`down[,]"(see Id. at 17 (64:7-8)) which further demonstrates Dr. Ehsani's correct
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`understanding that the two parameters in the claim at issue are broader than the
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`alleged preferred embodiment.
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`Therefore, Petitioner's allegation that Dr. Ehsani's testimony about what the
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`patent claims require in interpreting them and applying the prior art to them is the
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`product of his legally erroneous method of confining them to the preferred
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`embodiment is contrary to Dr. Ehsani's complete testimony, and Dr. Ehsani's
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`Declaration is therefore reliable and should not be excluded based on his
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`statements taken out of context by Petitioner.
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`c. Dr. Ehsani did not construe claims contrary to their structure
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`Petitioner again cites Dr. Ehsani's testimony taken out of context and
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`alleges that Dr. Ehsani does not understand the structure of claims. Paper 26 at 10.
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`By distorting Dr. Ehsani's testimony, Petitioner indignantly ridicules Dr. Ehsani's
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`expertise. The colloquy excerpted below that preceded the cited testimony
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`included many questions regarding the meanings of "sensing a collision" in clause
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`d) and "identifying a collision" in sub-clause d) iii) of Claim 1 of the '612 Patent.
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`In particular, note the following exchange:
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`IPR2014-00648
`U.S. Patent No. 8,217,612
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`Q. Now, identifying a collision of the window or panel with an
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`obstacle due to a change in the signal from a sensor, is part of how
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`the controller goes about sensing a collision with an obstruction when
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`power is applied to the controller or step D, correct?
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`A. I don't know if I agree with that characterization.
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`Ex. 1022 at 12 (44:17-23).
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`Q. (BY MR. SANDERS) Dr. Ehsani, do you agree that the
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`identifying step of D3 of Claim 1 of the '612 patent is a substep of
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`step D?
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`A. Are you talking about the legal point of view or from -- from the
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`pagination point of view?
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`Q. Dr. Ehsani, I'm asking you in the expert opinion that you've
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`applied for purposes of your analysis in these proceedings, do you
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`agree that step D3 is a substep of step D of Claim 1 of the '612
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`patent?
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`A. No, sir, I don't agree with that.
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`Id. at 13 (46:3-12).
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`Clearly, Dr. Ehsani, who is highly educated, understands the formatting
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`used in the claims; and in stating "No, sir, I don't agree with that," he was simply
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`reiterating his earlier testimony that "sensing a collision" in step d) is distinct from
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`"identifying a collision" in substep d) iii) and pointing out the ambiguity raised in
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`Petitioner's line of questioning. Therefore, Petitioner's allegation that Dr. Ehsani
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`construed the claims contrary to their structure and therefore his Declaration
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`should be excluded as unreliable is ludicrous.
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`IPR2014-00648
`U.S. Patent No. 8,217,612
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`In sum, Dr. Ehsani did not apply incorrect legal principles in preparing his
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`Declaration, and therefore his Declaration should not be excluded.
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`2. DR. EHSANI FULLY ANSWERED THE DEPOSITION
`QUESTIONS; PETITIONER SIMPLY DID NOT LIKE THE
`ANSWERS
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`Petitioner has incorrectly alleged that Dr. Ehsani "resisted answering basic
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`questions," that he "appeared concerned about making admissions that might not
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`be helpful to Patent Owner’s positions and avoided providing an answer," that he
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`was "acting as an advocate rather than an expert," and that his testimony will not
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`help trier of fact. Paper 26 at 10. These are Petitioner's mere subjective opinions
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`and form no legal basis for excluding Dr. Ehsani's Declaration.
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`Specifically, Petitioner does not explain why Dr. Ehsani's voluminous
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`testimony over two full days and three declarations will in fact not help the trier of
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`fact. The deposition transcript covers nearly 430 pages of testimony. Ex. 1023 at
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`88. This is hardly unresponsive. Many of Petitioner's questions were unclear to the
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`witness, were argumentative and repetitive, and involved levels of technical detail
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`that required lengthy rather than the succinct "sound bite" answers Petitioner
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`desired. This is evident from a full reading of the transcript rather than from a few
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`insignificant excerpts cited by Petitioner.
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`Further, Dr. Ehsani formed his opinions after considering and analyzing
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`broad-based evidence including cited art, prosecution history, and testimony of
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`IPR2014-00648
`U.S. Patent No. 8,217,612
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`various alleged experts from Petitioner's as well as other related proceedings. Ex.
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`2001 at ¶ 15, pp. 8-11. Dr. Ehsani's well-founded and well-formed opinions
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`therefore cannot be mischaracterized as mere advocacy, particularly since he
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`unequivocally testified that he answered questions without bias "not as a hired
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`person, but as an expert." Ex. 1022 at 15 (57:1).
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`Accordingly, Dr. Ehsani's Declaration should not be excluded for the
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`alleged failure to answer questions to Petitioner's subjection satisfaction.
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`3. PATENT OWNER DID NOT FILE INADMISSIBLE EXHIBITS
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`Dr. Ehsani has stated in his Declaration that he relied on Exhibits 2008-
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`2010, 2012, 2013, and 2017 in forming his opinion. Ex. 2001 at ¶ 15, pp. 8-11.
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`Exhibit 2009 includes the Declaration of Petitioner's alleged expert Dr. Toliyat,
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`filed in Petitioner's related IPR 2014-00650 for the '802 patent. Exhibits 2012 and
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`2013 include Declarations of alleged expert witness Dr. MacCarley, filed in the
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`related Brose IPR's 2014-00416 and 2014-00417 for the same '612 and '802
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`patents that are at issue in Petitioner's IPR's.
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`FRE 703 states: "An expert may base an opinion on facts or data in the case
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`that the expert has been made aware of or personally observed. If experts in the
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`particular field would reasonably rely on those kinds of facts or data in forming an
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`opinion on the subject, they need not be admissible for the opinion to be admitted.
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`But if the facts or data would otherwise be inadmissible, the proponent of the
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`IPR2014-00648
`U.S. Patent No. 8,217,612
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`opinion may disclose them to the jury only if their probative value in helping the
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`jury evaluate the opinion substantially outweighs their prejudicial effect."
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`FRE 703 specifically allows experts like Dr. Ehsani to rely on opinions of
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`other experts such as Dr. MacCarley. See, e.g., Ferrara & DiMercurio v. St. Paul
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`Mercury, 240 F.3d 1, 8-9 (1st Cir. 2001) (expert fire analyst could be expected to
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`examine another (now deceased) expert's report, as well as fire department report,
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`in the course of forming his own opinion on cause and origin of fire in question);
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`and U.S. v. 1014.16 Acres of Land, 558 F. Supp. 1238, 1242 (W.D. Mo. 1983),
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`aff'd, 739 F.2d 1371 (8th Cir. 1984) (expert allowed to rely on, among other things,
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`opinions of other experts). Therefore, Dr. Ehsani properly relied on expert
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`testimony of Drs. Toliyat and MacCarley included in Exhibits 2009, 2012, and
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`2013, and these exhibits are admissible under FRE 703. Exhibit 2010 includes the
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`'802 patent, which is the subject of Petitioner's related IPR 2014-00650; and
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`Exhibit 2017 includes the patent application to which the '612 Patent claims
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`priority. These exhibits are also properly filed and are admissible since Dr. Ehsani
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`relied on these exhibits in forming his opinions and preparing his declarations.
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`Patent Owner relied on the non-objected-to Exhibit 2004, the deposition
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`transcript of Petitioner's alleged expert Dr. Borelli from the related IPR 2014-
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`00649, for which the objected-to exhibit 2036 provides an errata sheet. Patent
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`10
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`Owner therefore properly filed Exhibit 2036 for completeness, and it is therefore
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`IPR2014-00648
`U.S. Patent No. 8,217,612
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`admissible.
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`Exhibit 2022 is merely a demonstrative exhibit that accurately summarizes
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`on a single sheet numerous unpatentability grounds Petitioner alleged in three
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`IPR's for which the Board has instituted trial. Since FRE 1006 allows use of
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`summaries and 37 CFR § 42.70 allows use of demonstrative exhibits at oral
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`argument, Patent Owner properly filed Exhibit 2022 well in advance to avoid
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`undue surprises later and to aid all concerned in these proceedings. Therefore,
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`Exhibit 2022 is admissible as a demonstrative exhibit.
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`Petitioner alleges that Exhibit 2008 is inadmissible hearsay. Exhibit 2008 is
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`the deposition transcript of alleged expert witness Dr. MacCarley, filed in the
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`related Brose IPR's 2014-00416 and 2014-00417 for the same '612 and '802
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`patents that are at issue in Petitioner's IPR's. FRE 703 expressly allows experts to
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`rely on opinions of other experts, and therefore Dr. Ehsani properly relied on Dr.
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`MacCarley's testimony under FRE 703. Further, under FRE 401, Dr. MacCarley's
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`testimony is highly relevant to resolve some of the vigorously disputed issues in
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`Petitioner's IPR's for which it is considered.
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`Additionally, Patent Owner properly relied on Exhibit 2008 under FRE 807
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`since Dr. MacCarley's testimony has equivalent circumstantial guarantees of
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`trustworthiness (filed under oath in a related IPR proceeding against Patent
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`11
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`IPR2014-00648
`U.S. Patent No. 8,217,612
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`Owner's interests); is offered as evidence of a material fact (at least the forty
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`millisecond issue); is more probative on the point for which it is offered than any
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`other evidence that the proponent can obtain through reasonable efforts (otherwise
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`Patent Owner would not offer it; Petitioner's expert Dr. Toliyat's testimony was
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`insufficient, incomplete, inconclusive, incorrect (e.g., insisting that derivative of
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`speed relative to distance is acceleration), and evasive on these and many other
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`points); and admitting it will best serve the purposes of these rules and the
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`interests of justice (advances the Board's goal of making all relevant evidence of
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`record and publicly available).
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`Further, Petitioner was served and notified of the filing of this exhibit, and
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`yet Petitioner never attempted or requested to depose Dr. MacCarley. Therefore,
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`Petitioner cannot now allege that admitting Exhibit 2008 unfairly prejudices it,
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`and Exhibit 2008 is therefore admissible.
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`Accordingly, Exhibits 2008-2010, 2012, 2013, 2017, 2022, and 2036 were
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`properly filed and are admissible, and Petitioner's motion to exclude these exhibits
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`should be denied.
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`In sum, Petitioner's motion to exclude the Declaration of Dr. Ehsani should
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`be denied because Dr. Ehsani did not prepare his Declaration using incorrect legal
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`standards and claim construction methods, and Dr. Ehsani did not resist answering
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`questions as Petitioner alleges. Additionally, the Board should deny the motion to
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`exclude the challenged exhibits because these exhibits are properly relied on by
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`Patent Owner and Dr. Ehsani and are admissible under FRE 401, 702, 703, 807,
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`IPR2014-00648
`U.S. Patent No. 8,217,612
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`1006, and 37 CFR § 42.70.
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`4. CONCLUSION
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`The Board should deny Petitioner's motion to exclude the opinion
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`testimony of Dr. Ehsani and the exhibits at issue.
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`/Hemant M. Keskar/
`
`By:
`HARNESS, DICKEY & PIERCE, P.L.C.
`Monte L. Falcoff (Reg. No. 37,617)
`Hemant M. Keskar (Reg. No. 61,776)
`5445 Corporate Drive, Ste. 200
`Troy, MI 48098
`(248) 641-1600
`(248) 641-0270 Fax
`mlfalcoff@hdp.com
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`hkeskar@hdp.com
`Attorneys for Patent Owner
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`13
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`IPR2014-00648
`U.S. Patent No. 8,217,612
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`Certificate of Service Under 37 C.F.R. § 42.6(e)(4)
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`A copy of this Patent Owner’s Opposition to Petitioner's Motion to Exclude
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`The Opinion Testimony of Dr. Mark Ehsani and Inadmissible Exhibits has been
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`served to counsel for the Petitioner at the following electronic mail addresses,
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`pursuant to consent of Petitioner, on this 5th day of June, 2015.
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`
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`Charles H. Sanders (Reg. No. 47,053) Timothy J. Rousseau (Reg. No. 59,454)
`csanders@goodwinprocter.com trousseau@goodwinprocter.com
`GOODWIN PROCTER LLP
`
` GOODWIN PROCTER LLP
`Exchange Place
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`
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` The New York Times Building
`53 State Street
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` 620 Eighth Avenue
`Boston, MA 02109
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` New York, New York 10018
`Telephone: (617) 570-1315
` Telephone: (212) 813-8000
`Fax: (617) 801-8804
`
`
` Fax: (212) 355-3333
`
`Phong T. Dinh (Reg. No. 67,475)
`(pdinh@goodwinprocter.com)
`GOODWIN PROCTER LLP
`901 New York Avenue., NW
`Washington, D.C. 22201
`Telephone: (202) 346-4320
`Fax: (202) 346-4444
`Attorneys of Record for Webasto Roof Systems, Inc.
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`By:
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`/Hemant M. Keskar/
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`HARNESS, DICKEY & PIERCE, P.L.C.
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`Monte L. Falcoff (Reg. No. 37,617)
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`Hemant M. Keskar (Reg. No. 61,776)
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`5445 Corporate Drive, Ste. 200
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`Troy, MI 48098
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`(248) 641-1600
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`(248) 641-0270 Fax
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`mlfalcoff@hdp.com
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`hkeskar@hdp.com
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`Attorneys for Patent Owner
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`14
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