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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF VIRGINIA
`Alexandria Division
`
`STRAIGHT PATH IP GROUP, INC.,
`
`PUBLIC VERSION
`
`v.
`
`VIZIO, INC., et al.,
`
`Plaintiff,
`
`Defendants.
`
`STRAIGHT PATH IP GROUP, INC.,
`
`Plaintiff,
`
`v.
`
`TOSHIBA CORPORATION, et al.,
`
`Defendants.
`
`STRAIGHT PATH IP GROUP, INC.,
`
`Plaintiff,
`
`v.
`
`LG ELECTRONICS, INC., et al.,
`
`Defendants.
`
`Civil Action No. 1:13-cv-934 (AJT/IDD)
`
`Civil Action No. 1:13-cv-934 (AJT/IDD)
`[formerly No. 3:13-cv-503, No. 1:13-cv-1070]
`
`Civil Action No. 1:13-cv-934 (AJT/IDD)
`[formerly No. 1:13-cv-933]
`
`PROPOSED INTERVENOR HULU, LLC’S REPLY IN SUPPORT OF MOTION TO
`INTERVENE PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 24
`
`866536
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`LG v. Straight Path, IPR2015-00198
`Straight Path - Exhibit 2002 - Page 1
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`I.
`
`PRELIMINARY STATEMENT
`Straight Path does not and cannot contest that Hulu has sought to intervene as soon as
`
`possible in this action, that this case is in its infancy, and that Hulu’s intervention as to the
`
`existing defendants alone would not broaden the case. Instead, Straight Path asks why Hulu did
`not intervene in the Eastern District of Texas case against Samsung.1 While not relevant, the
`answer is simple. Prior to September 18, 2014, Hulu’s technology was only implicated in the
`Samsung case. Straight Path had not accused Hulu functionality in the parallel International
`Trade Commission investigation against LG, Toshiba, and VIZIO. Straight Path had not accused
`
`Hulu functionality in any of its other pending lawsuits nationwide. It was not until mid-
`
`September that Straight Path revealed that it would attack Hulu’s partners piecemeal all over the
`
`United States, by providing to LG, Toshiba, and VIZIO in this case claim charts citing Hulu
`
`technology. Within days, Hulu sought to intervene here, the jurisdiction that indisputably would
`
`provide the fastest adjudication as to whether Hulu’s product infringes and Straight Path’s
`
`patents are invalid. (The Patent Trial and Appeals Board addressed the invalidity question
`
`earlier this month by finding the asserted claims of one of Straight Path’s three patents-in-suit
`invalid.2)
`Straight Path also argues—without factual support—that Hulu’s intervention as to all of
`
`its partners would broaden the scope of this case. Not so. Straight Path has presented only
`
`speculation that Hulu’s product operates differently across those devices or that Straight Path
`
`would require extensive third-party discovery to understand how Hulu’s product works on those
`
`devices. In fact, Hulu typically does not provide its source code to its partners; instead, it makes
`
`1As in Hulu’s opening brief, the following abbreviations apply throughout this reply: (1) “Hulu”
`means Hulu, LLC; (2) “LG” means LG Electronics, Inc., LG Electronics U.S.A., Inc., and LG
`Electronics MobileComm U.S.A., Inc.; (3) “Toshiba” means Toshiba Corporation, Toshiba
`America, Inc., and Toshiba America Information Systems, Inc.; (4) “VIZIO” means VIZIO, Inc.;
`and (5) “Straight Path” means Straight Path IP Group, Inc.
`2 See Sipnet EU S.R.O. v. Straight Path IP Grp., Inc., Case IPR2013-00246, 2014 WL 5144564
`(P.T.A.B. Oct. 9, 2014).
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`any changes desired by those partners itself. See Decl. of Xinan Wu in Support of Hulu’s
`
`Motion to Intervene (“Wu Decl.”), ¶ 3. Because Hulu’s product is not modified or personalized
`
`by its partners, Hulu’s intervention would result in only limited (if any) additional third-party
`
`discovery.
`
`Straight Path would have Hulu fight many skirmishes by suing Hulu’s partners in three—
`
`for now—courts nationwide. But it makes sense for Hulu, its partners, and the millions of
`
`people who use the devices at issue to adjudicate this dispute as quickly and efficiently as
`
`possible. Hulu’s counsel has already participated in scheduling and substantive discussions in
`
`this case, which demonstrates Hulu’s sincerity in securing a speedy adjudication. The Court
`
`should grant Hulu’s motion.
`
`II.
`
`ARGUMENT
`
`A.
`
`Hulu may intervene as a matter of right.
`
`Hulu’s motion to intervene is timely.
`1.
`Straight Path does not contest that Hulu sought to intervene timely. Straight Path
`
`attempts to distract from Hulu’s timely action by focusing on the ongoing litigation against
`
`Samsung in the Eastern District of Texas, but the key timeliness question for intervention
`purposes is whether any delay in Hulu’s intervention has prejudiced the parties to this case, not
`to any other case.3 Straight Path cites no authority for looking to cases other than the one in
`which intervention is sought in order to assess an intervenor’s timeliness.
`
`Even if the Court considers the Samsung case in determining the timeliness of Hulu’s
`
`motion, Hulu has acted as promptly as possible. Prior to September 18, Straight Path had only
`
`sued one Hulu partner—Samsung—and had never before accused Hulu technology in this case
`
`3 See Spring Constr. Co. v. Harris, 614 F.2d 374, 377 (4th Cir. 1980) (“The most important
`consideration is whether the delay has prejudiced the other parties.”); Mountain Top Condo.
`Assoc. v. Dave Stabbert Master Builder, Inc., 72 F.3d 361, 370 (3d Cir. 1995) (“[T]he stage of
`the proceeding is inherently tied to the question of the prejudice the delay in intervention may
`cause to the parties already involved.”) (emphasis added).
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`or in its investigation against the same defendants before the ITC. It was not until its partners
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`notified Hulu that Straight Path intended to allege infringement in this case on the basis of Hulu
`
`technology that Hulu understood Straight Path’s strategy: attack Hulu’s partners, one by one, all
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`over the country, in an attempt to extract settlements on the basis of Hulu technology, rather than
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`facing Hulu head-on. Once it became apparent that Hulu would not have to deal with one
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`partner sued in one jurisdiction, but five partners sued literally across the country in three
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`jurisdictions, it acted.
`
`2.
`
`Hulu has a significantly protectable interest related to the products at
`issue.
`Straight Path admits that Hulu is the designer and supplier of a technology that will be
`
`part of their infringement theory these cases. Dkt. 137 at 10 (conceding that Hulu is the supplier
`
`of an application that runs on defendants’ devices and that Hulu’s technology is one way
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`“Defendants’ infringement may be proven”). Straight Path’s litigation against LG, Toshiba, and
`
`VIZIO, both here and before the ITC, has always been focused on third-party applications on the
`
`defendants’ devices, rather than on the devices themselves. As Straight Path’s infringement
`
`contentions—just served last Friday—against LG, Toshiba, and VIZIO demonstrate, Hulu’s
`
`product will be front-and-center in this litigation. See Decl. of Katherine M. Lovett in Support of
`
`Hulu’s Reply in Support of Motion to Intervene (“Lovett Decl.”), Ex. A (Straight Path’s
`
`infringement charts accusing LG, Toshiba, and VIZIO). Courts have held time and again that a
`
`designer and supplier of a technology has a significant interest in its clients’ or customers’
`alleged infringement on the basis of the designer’s technology.4 Straight Path does not cite a
`single case holding otherwise.
`
`4 See, e.g., Select Retrieval, LLC v. ABT Elecs., 11-cv-3752, 2013 WL 6576861, at *2 (N.D. Ill.
`Dec. 13, 2013); Advanced Dynamic Interfaces, LLC v. Aderas Inc., 12-cv-963, 2013 WL
`6989428, at *1 n.1 (D. Del. Jan. 11, 2013); Honeywell Int’l, Inc. v. Audiovox Commc’ns Corp.,
`04-cv-1337, 2005 WL 2465898, at *4 (D. Del. May 18, 2005).
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`Furthermore, contrary to Straight Path’s arguments,5 Hulu has shown that it has an actual
`obligation to defend the existing defendants with respect to Straight Path’s claims against them.
`
`See Decl. of Anthony Garza in Support of Hulu’s Motion to Intervene (Dkt. 125-2), ¶ 4 (“Hulu
`has agreed to defend VIZIO and LG for infringement claims made by Straight Path against the
`Hulu product in this case.”) (emphasis added). Since filing its opening brief, Hulu has
`
`similarly agreed to defend Toshiba for infringement claims made by Straight Path against the
`
`Hulu product in this case. See Lovett Decl., Exs. B-D (letters from Hulu to LG, Toshiba, and
`
`VIZIO). Hulu’s recognition of its legal obligation to defend its partners is yet another well-
`
`established significantly protectable interest. See Fisherman’s Harvest Inc. v. United States, 74
`
`Fed. Cl. 681, 685 (Fed. Cl. 2006); Select Retrieval v. L.L. Bean, Inc., 12-cv-3, 2013 WL
`
`1099754, at *1 (D. Me. Mar. 15, 2013).
`
`3.
`
`The disposition of these actions may impair Hulu’s ability to protect
`its interests.
`The Court’s decision here—both as to invalidity and non-infringement—will have an
`
`impact on the other ongoing litigations against Hulu’s partners, as well as in any other suits
`
`Straight Path chooses to bring against Hulu or its partners. See ABT Elecs., 2013 WL 6576861,
`at *2. Moreover, the outcome of this case will have an impact on Hulu’s business with all of its
`
`partners. See Advanced Dynamic Interfaces, 2013 WL 6989428, at *1 n.1 (Oracle demonstrated
`
`that its interests would be impaired or affected by disposition of the action where the outcome of
`
`the action would directly impact Oracle economically). None of these effects are conclusory or
`
`contingent—they are the practical reality of the impact this case will have on Hulu’s product and
`
`future partnerships.
`
`The named defendants inadequately represent Hulu’s interests.
`4.
`Finally, Hulu’s interests are not adequately represented here by LG, Toshiba, and VIZIO.
`
`As the cases Straight Path cites show, Hulu satisfies this element merely by showing that
`
`5 See Dkt. 137 at 9-10.
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`representation “may be” inadequate. JLS, Inc. v. Pub. Serv. Comm’n of W. Va., 321 Fed. App’x
`
`286, 289 (4th Cir. 2009); Friend v. REMAC Am., Inc., 12-cv-17, 2014 WL 2440438, at *2
`
`(N.D.W.V. May 30, 2014). As one court in this District put it, “[t]here is good reason in most
`
`cases to suppose that the applicant is the best judge of the representation of his own interest and
`
`to be liberal in finding that one who is willing to bear the cost of separate representation may not
`
`be adequately represented by the parties.” Cooper Techs., Co. v. Dudas, 247 F.R.D. 510, 515
`
`(E.D. Va. 2007) (quoting 7C Wright, Miller, & Kane, Fed. Prac. & Proc. Civ. § 1909 (2d. ed.
`
`1986)).
`
`Hulu has plainly satisfied its minimal burden to show that its interests may not be
`
`adequately represented by LG, Toshiba, and VIZIO. It is indisputable that Hulu is the best—if
`
`not only—source of knowledge regarding its technology because Hulu developed the accused
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`application and Hulu supplies it to the defendants in executable form. Wu Decl., ¶ 3. Straight
`
`Path has presented no evidence demonstrating that the current defendants have the kind of in-
`
`depth knowledge about the functionality of Hulu’s product that Hulu will bring to bear in this
`
`case. Courts have consistently held that where the intervenor has superior knowledge of case-
`
`specific issues, the presumption of adequate representation is overcome. See JLS, Inc., 321 Fed.
`
`App’x at 290 (finding risk of nonfeasance where current defendant lacked the same knowledge
`
`of rail crew transportation as intervenor); Defenders of Wildlife v. N.C. Dep’t of Transp., 281
`F.R.D. 264, 269 (E.D.N.C. 2012).6
`In addition, the presumption of adequate representation is overcome where an intervenor
`
`shows that the existing parties lack the same motivation to vigorously and effectively protect the
`
`intervenor’s interests. See JLS, Inc., 321 Fed. App’x at 290. Straight Path is poised to accuse
`LG, Toshiba, and VIZIO on the basis of at least eight different technologies in addition to
`Hulu.7 Given that the existing defendants’ must divide their attention amongst so many different
`
`6 See also ABT Elecs., 2013 WL 6576861, at *2; Advanced Dynamic Interfaces, 2013 WL
`6989428, at *1 n.1; Honeywell, 2005 WL 2465898, at *4.
`7 Straight Path’s infringement charts accuse eight applications in addition to Hulu. Lovett Decl.,
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`accused applications, LG, Toshiba, and VIZIO will not have the same incentive to defend Hulu’s
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`technology as will Hulu itself. At the same time, Hulu has a broader interest in protecting the
`
`entirety of its partner and customer base and forestalling future lawsuits against its other
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`partners. See Select Retrieval LLC v. AmeriMark Direct LLC, 11-cv-812, 2013 WL 3381324, at
`
`*2 (D. Del. July 3, 2013).
`
`Alternatively, the Court should permit Hulu to intervene.
`B.
`Hulu plainly satisfies the test for permissive intervention, which merely requires a timely
`
`motion and that the proposed intervenor have a claim or defense that shares a common question
`
`of law or fact with the main action. Fed. R. Civ. P. 24(b)(1)(B). Straight Path concedes, as it
`
`must, that Hulu’s defenses share significant common questions of fact and law with LG,
`
`Toshiba, and VIZIO, both as to non-infringement by those defendants on the basis of Hulu
`
`technology and as to the invalidity of the asserted patents. See Dkt. 137 at 14 (“[T]hese claims
`
`do share a common question of law or fact with the main action in this case.”). In addition, as
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`explained above, Hulu’s motion is timely and, far from seeking to delay matters, Hulu seeks
`intervention specifically to secure an adjudication as soon as possible.8
`
`The Court should not condition or limit the scope of Hulu’s intervention.
`C.
`Straight Path appears to offer a compromise position: to permit Hulu’s intervention only
`
`as to LG, Toshiba, and VIZIO. The Court should reject that offer in favor of Hulu’s intervention
`
`without limitation.
`
`¶ 4. In addition, Straight Path has issued third-party subpoenas covering at least the following
`applications: Amazon Instant, Amazon Instant Video, Amazon Video on Demand, Prime Instant
`Video, LOVEFiLM Instant, CinemaNow, Hulu, Hulu Plus, Hulu +, M-GO, MLB.TV, NFL
`Mobile, NFL Now, Redbox Instant, Redbox Instant by Verizon, UStream, and Yahoo Screen.
`Lovett Decl., ¶ 5.
`8 Straight Path conflates the question of the propriety of Hulu’s intervention in this case with the
`question of the scope of that intervention. See Dkt 137 at 14-17 (arguing that Hulu should not be
`permitted to intervene because of the scope of Hulu’s complaint). But whether Hulu’s claims
`and defenses share a common question of fact and law with the current defendants does not
`depend in any way on the scope or breadth of Hulu’s complaint.
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`Straight Path’s argument that an adjudication as to all Hulu products will “balloon[ ] this
`
`case exponentially” is hyperbolic in the extreme. Dkt. 137 at 17. Straight Path’s infringement
`
`theories will, by necessity, be very similar across all Hulu partners. Hulu controls the source
`
`code for its applications and that code is not typically modified by its partners. Wu Decl., ¶ 3. In
`
`addition, the number of devices that Hulu supports is finite and limited. See
`
`http://www.hulu.com/plus/devices. Unlike in Financeware, Inc. v. UBS Financial Services, the
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`case relied upon by Straight Path to argue that the scope of Hulu’s intervention should be
`
`curtailed, to allow Hulu to settle the issue of its products’ infringement before this Court would
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`not “force Plaintiff into litigation it had not anticipated.” 11-cv-5503, 2011 WL 6092311, at *2
`
`(S.D.N.Y. Dec. 7, 2011). This is because Straight Path has already elected to broaden the scope
`
`of its litigation to include Hulu partners other than LG, Toshiba, and VIZIO.
`
`Many other courts have allowed developer-intervenors to bring claims that adjudicate
`
`infringement by the intervenors’ technology more broadly, regardless of whether intervention is
`by right or by permission.9 This approach makes sense. If it were otherwise, the efficiency
`value of a developer stepping in to defend its product would be undermined because the
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`developer would still be forced to face allegations against each and every one of its other
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`customers in fora all over the country. As one court aptly explained, in the interest of judicial
`
`economy, dealing with a product’s developer first “is the fairest and most efficient way to
`
`proceed. It is not a complication to be resisted.” Honeywell Int’l Inc., 2005 WL 2465898, at *3.
`
`9 Compare, e.g., Honeywell Int’l Inc., 2005 WL 2465898, at *4 (granting manufacturer Seiko
`Epson’s motion to intervene in case accusing seller defendants of infringement) with Dkt. 50-3
`of 1:04-cv-1337 (D. Del.) at 10 (Seiko Epson’s Proposed Complaint in Intervention seeking a
`declaration that “products manufactured, sold, offered for sale, imported or otherwise provided
`by Seiko Epson do not infringe and have not infringed any of the claims of the ’731 patent”);
`Reid v. Gen. Motors Corp., 240 F.R.D. 257, 260 (E.D. Tex. 2006) (permitting Microsoft to
`intervene in a case accusing its customer’s use of Microsoft technology of infringement) with
`Dkt. 106 in 2:05-cv-401 (E.D. Tex.) at 3 (Microsoft’s Complaint in Intervention stating that
`“Microsoft does not induce or contribute to infringement of any claim of the ’120 patent”); see
`also Dkt. 178 in 1:09-cv-354 (D. Del.) at 4 (Intel’s Complaint in Intervention, seeking
`declaratory judgment that “neither Intel nor any of its products infringe . . . any valid claim of the
`’617 Patent”).
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`Finally, as Straight Path recognizes in its brief,10 the Fourth Circuit has never resolved
`whether it is permissible to impose any conditions whatsoever on an intervenor as of right. See
`
`Columbus-Amer. Discovery Grp. v. Atl. Mut. Ins. Co., 974 F.2d 450, 470 (4th Cir. 1992). If such
`
`conditions are permissible, they are limited to those “of a housekeeping nature,” such as
`
`limitations on discovery and scheduling orders, and “should not be allowed to limit the
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`intervenor in the assertion of counterclaims or other new claims.” See 7C Wright, Miller, &
`
`Kane, Fed. Prac. & Proc. Civ. § 1922 (3d. ed. 2014); see also Columbus-Amer. Discovery Grp.,
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`974 F.2d at 470. The Court should reject Straight Path’s invitation to reach out and expand
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`significantly this Circuit’s decisional authority on intervention as of right.
`
`III.
`
`CONCLUSION
`Hulu has established that it is an intervenor of right and that the scope of its complaint in
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`intervention is appropriate and permissible. Hulu therefore respectfully requests that the Court
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`grant its motion in full.
`
`Dated: October 20, 2014
`
`By:
`
`Respectfully submitted,
`
`HULU, LLC
`
`/s/ Robert A. Angle
`Robert A. Angle (VSB No. 37691)
`robert.angle@troutmansanders.com
`Mary Catherine Zinsner (VSB No. 31397)
`mary.zinsner@troutmansanders.com
`K. Nicola Harrison (VSB No. 82194)
`nicola.harrison@troutmansanders.com
`TROUTMAN SANDERS LLP
`1850 Towers Crescent Plaza, Suite 500
`Tysons Corner, Virginia 22182
`Telephone: (703) 734-4334
`Facsimile: (703) 734-4340
`
`Ashok Ramani (pro hac vice)
`Matthias Kamber (pro hac vice)
`Sharif E. Jacob (pro hac vice)
`Katherine M. Lovett (pro hac vice)
`KEKER & VAN NEST LLP
`
`10 Dkt. 137 at 18:8-10.
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`633 Battery Street
`San Francisco, CA 94111-1809
`Telephone: 415 391 5400
`Facsimile: 415 397 7188
`
`Attorneys for Proposed Intervenor
`HULU, LLC
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`CERTIFICATE OF SERVICE
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`I hereby certify that on the 20th day of October, 2014, I served the counsel listed below
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`by e-mail and filed the foregoing with the Clerk of the Court using the CM/ECF system, which
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`will send a notice of electronic filing to the registered users listed below:
`
`Sona Rewari
`Hunton & Williams
`1751 Pinnacle Dr
`Suite 1700
`McLean, VA 22102
`(703) 714-7400
`srewari@hunton.com
`
`Gregory N. Stillman
`Hunton & Williams
`500 E Main St
`Suite 1000
`Norfolk, VA 23510
`(757) 640-5314
`Fax: (757) 625-7720
`gstillman@hunton.com
`Counsel for Straight Path IP Group, Inc.
`
`Elizabeth Diane Ferrill
`Finnegan Henderson Farabow Garrett &
`Dunner LLP (DC)
`901 New York Ave NW
`Washington, DC 20001-4413
`202-408-4445
`Fax: 202-408-4400
`elizabeth.ferrill@finnegan.com
`Counsel for LG Electronics, Inc., LG
`Electronics U.S.A., Inc., and LG Electronics
`MobileComm U.S.A., Inc.
`
`Brian L. Whisler
`Matthew Steven Dushek
`Baker & McKenzie LLP (DC)
`815 Connecticut Ave NW
`Suite 1100
`Washington, DC 20006
`202-452-7000
`brian.whisler@bakermckenzie.com
`matt.dushek@bakermckenzie.com
`Counsel for VIZIO, Inc.
`
`Scott Lloyd Smith
`Holly Beth Lance
`Buchanan Ingersoll & Rooney PC (VA)
`1737 King St
`Suite 500
`Alexandria, VA 22314-2727
`703-836-6620
`Fax: 703-836-2021
`lloyd.smith@bipc.com
`Holly.Lance@bipc.com
`Counsel for Toshiba America Information
`Systems, Inc. and Toshiba Corporation
`
`By: /s/ Robert A. Angle
`Robert A. Angle (VSB No. 37691)
`robert.angle@troutmansanders.com
`
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`TROUTMAN SANDERS LLP
`1850 Towers Crescent Plaza, Suite 500
`Tysons Corner, Virginia 22182
`Telephone: (703) 734-4334
`Facsimile: (703) 734-4340
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