UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`TOYOTA MOTOR CORPORATION
`
`Petitioner
`
`
`
`Patent No. 5,845,000
`Issue Date: December 1, 1998
`Title: OPTICAL IDENTIFICATION AND MONITORING SYSTEM USING
`PATTERN RECOGNITION FOR USE WITH VEHICLES
`__________________________________________________________________
`
`MOTION FOR JOINDER
`PURSUANT TO 35 U.S.C. § 315(C) AND
`37 C.F.R. §§ 42.22 AND 42.122(B)
`
`Case No. IPR2015-00262
`__________________________________________________________________
`
`
`
`
`
`
`
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`TOYOTA MOTOR CORPORATION
`
`Petitioner
`
`
`
`Patent No. 5,845,000
`Issue Date: December 1, 1998
`Title: OPTICAL IDENTIFICATION AND MONITORING SYSTEM USING
`PATTERN RECOGNITION FOR USE WITH VEHICLES
`__________________________________________________________________
`
`MOTION FOR JOINDER
`PURSUANT TO 35 U.S.C. § 315(C) AND
`37 C.F.R. §§ 42.22 AND 42.122(B)
`
`Case No. IPR2015-00262
`__________________________________________________________________
`
`
`
`
`
`
`
`
`
`Contemporaneously with this motion, Toyota Motor Corporation (“Toyota” or
`
`“Petitioner”) has filed a Petition for Inter Partes Review (“IPR”) of claims 10, 11, 16,
`
`17, 19, 20, and 23 of U.S. Patent No. 5,845,000 (“the ’000 patent”). Toyota
`
`respectfully requests that its Petition be granted and that the proceedings be joined in
`
`accordance with 35 U.S.C. § 315(c), 37 C.F.R. § 42.22, and 37 C.F.R. § 42.122(b) with
`
`an already instituted IPR filed by Mercedes-Benz USA LLC (“Mercedes”) that also
`
`relates to the ’000 patent: Mercedes-Benz USA, LLC, v. American Vehicular Sciences, LLC,
`
`Case No. IPR2014-00647 (the “Mercedes IPR,” or “Mercedes’ IPR”).
`
`Toyota’s petition challenges the same independent claims (and all but one of
`
`the dependent claims) on grounds that are the same as those that are now part of the
`
`Mercedes IPR. In its decision instituting the Mercedes IPR, the Board concluded
`
`that the ’000 patent’s claims are likely to be found unpatentable as obvious in view of
`
`U.S. 6,553,130 to Lemelson (“Lemelson”). Even though the Board found that
`
`Lemelson does not expressly disclose claim limitations requiring that the trained
`
`pattern recognition algorithm be “generated from data of possible exterior objects and
`
`patterns of received electromagnetic illumination from the possible exterior objects,”
`
`or “generated from data of possible sources of radiation including lights of vehicles
`
`and patterns of received radiation from the possible sources,” the Board noted that
`
`these limitations would be obvious from Lemelson in view of the knowledge of a
`
`person skilled in the art and/or in view of other prior art. (IPR2014-00647, Paper 13,
`
`at 16-17.)
`
`-1-
`
`
`
`In an earlier filed and presently pending IPR, (IPR 2013-00424), Toyota
`
`contends that the same ’000 patent claims are anticipated by Lemelson. The patent
`
`owner, American Vehicular Sciences, LLC (“AVS”), has responded that these claims
`
`are not anticipated because Lemelson fails to disclose the “generated from”
`
`limitations discussed above. In reply, however, Toyota was not allowed during
`
`discovery to interrogate AVS’s expert about whether this limitation would be obvious,
`
`or indeed, whether the AVS expert was effectively admitting this limitation would be
`
`obvious, because Toyota had not anticipated AVS’s response based on the “generated
`
`from” limitations and, therefore, had not included an argument that this limitation
`
`was obvious in the original petition. Now that Mercedes, with prior knowledge of the
`
`proceedings in Toyota’s earlier IPR, has squarely placed the obviousness of the
`
`“generated from” limitation in issue, and now that the Board has found that the
`
`claims of the ’000 patent are likely to be found unpatentable for that reason, this
`
`critically important obviousness issue should be finally resolved on the merits. These
`
`are the only grounds for unpatentability raised by Toyota’s current petition: the
`
`obviousness of the ’000 patent’s claims over Lemelson itself, or Lemelson combined
`
`with other prior art.
`
`The Board should exercise its discretion and authorize joinder in this case.
`
`Joinder is appropriate and will ensure the just, speedy, and inexpensive resolution of
`
`both the Mercedes IPR and Toyota’s petition. Most importantly, joinder will avoid
`
`possibly conflicting results, inequity, and undue prejudice. For instance, AVS has
`-2-
`
`
`
`dropped its infringement claims against Mercedes making it likely that the Mercedes
`
`IPR will terminate prior to the issuance of a final written decision. (See IPR2014-
`
`00647, Paper 15, at 2.) This will force Toyota to litigate obviousness issues raised by
`
`the Mercedes IPR (which the Board has already determined are likely to render the
`
`’000 patent unpatentable, and which Toyota was unable to raise in the instituted -
`
`00424 proceeding) in district court. Joinder will avoid this by allowing Toyota to
`
`continue pursuing obviousness grounds raised by the Mercedes IPR even if Mercedes
`
`itself withdraws. Joinder would also be highly efficient and appropriate for other
`
`reasons. For instance, the Lemelson-based obviousness issues raised by Toyota’s
`
`petition are identical to those in the Mercedes IPR. Thus, joinder will avoid
`
`unnecessary duplication. Indeed, while Toyota reserves its rights to participate to the
`
`extent it deems necessary, to the extent Mercedes continues to press forward with its
`
`IPR, Toyota does not anticipate it will need to participate actively, take separate
`
`discovery beyond the defense of its expert, or add duplicative filings to the
`
`proceedings.
`
`Joinder should also not significantly affect the schedule in the Mercedes IPR,
`
`or increase the complexity of that proceeding in any significant or meaningful way.
`
`Joinder will likewise allow for a substantially reduced volume of filings and discovery.
`
`And, neither patent owner American Vehicular Sciences, LLC (“AVS”) nor Mercedes
`
`will be unduly prejudiced by joinder.
`
`-3-
`
`
`
`Finally, if the Board issues its final written decision in connection with Toyota’s
`
`first IPR (IPR2013-00424) and finds some of the claims at issue to be not
`
`unpatentable on the grounds instituted, it is possible that AVS may argue that in view
`
`of that decision, 35 U.S.C. § 315(e)(1) would somehow require that Toyota be
`
`estopped from maintaining its second IPR or joining the Mercedes IPR . This is not
`
`the case. Estoppel extends only to “any ground that the petitioner raised or
`
`reasonably could have raised during” an earlier IPR that reached final written decision.
`
`Here, Toyota was prevented from addressing the obviousness of the “generated
`
`from” limitations during its first IPR. Toyota also did not anticipate AVS’s argument
`
`regarding the “generated from” language at least in part because it believed that, if real
`
`data, simulated data and partial data were equally possible ways to train a pattern
`
`recognition system, as AVS has argued, then Toyota believed that the “generated
`
`from” language would become a non-limiting process limitation in an apparatus claim
`
`that merely specifies the process by which the apparatus’s algorithm is generated
`
`without affecting the ultimate structure of the algorithm. Accordingly, the
`
`obviousness of the “generated from” limitation is not an issue or grounds that Toyota
`
`“raised or reasonably could have raised” during the earlier IPR, and estoppel does not
`
`apply.
`
`-4-
`
`
`
`I.
`
`BACKGROUND AND RELATED PROCEEDINGS
`
`The ’000 patent is owned by AVS. On June 25, 2012, AVS filed a complaint
`
`with the U.S. District Court for the Eastern District of Texas alleging that Toyota and
`
`a number of related entities infringes certain claims of the ’000 patent.
`
`On July 12, 2013, Toyota filed its first IPR petition in connection with the ’000
`
`patent. (See IPR2013-00424, Paper No. 2.) That petition sought review of claims with
`
`claims 10, 11, 16, 17, 19, 20, and 23. (Id.) Toyota’s petition was granted, and IPR was
`
`instituted on January 14, 2014. (See IPR2013-00424, Paper No. 16.) The grounds at
`
`issue in Toyota’s first IPR are as follows:
`
`•
`
`•
`
`•
`
`Claims 10, 11, 19, and 23 anticipated by Lemelson;
`
`Claims 10, 11, 19, and 23 obvious over Lemelson and U.S. Patent No.
`
`5,214,408 to Asayama (“Asayama”); and
`
`Claims 16, 17, and 20 obvious over Lemelson and Japanese Unexamined
`
`Patent App. Pub. No. S62-131837 to Yanagawa (“Yanagawa”).
`
`(Id. at 45.)
`
`In its response to Toyota’s first IPR petition, AVS argued that all of the claims
`
`at issue are patentable because Lemelson purportedly fails to disclose the “pattern
`
`recognition algorithm generated from data of possible exterior objects and patterns of
`
`received electromagnetic illumination from the possible exterior objects” of claims 10,
`
`11, 19, and 23 and the “pattern recognition algorithm generated from data of possible
`
`-5-
`
`
`
`sources of radiation including lights of vehicles and patterns of received radiation
`
`from the possible sources” of claims 16, 17, and 20. (See IPR2013-00424, Paper 29, at
`
`12-14.) According to AVS, these claim limitations require a pattern recognition
`
`algorithm trained with data from actual objects (i.e., “real data”), as opposed to
`
`simulated data or partial data. (Id.) On May 9, 2014, the Board issued an order in
`
`which it prohibited Toyota from seeking discovery regarding “the obviousness to one
`
`with ordinary skill in the art of the trained pattern recognition claim feature in light of
`
`Lemelson.” (See IPR2013-00424, Paper No. 33, at 2-4.) A hearing before the Board
`
`in connection with Toyota’s first IPR was held on August 18, 2014. As of the filing
`
`of this motion, the Board had not yet rendered its final written decision.
`
` On April 16, 2014, Mercedes filed its own IPR petition in connection with the
`
`’000 patent. The Board granted Mercedes’ petition and instituted IPR on October 23,
`
`2014. (See IPR2014-00647, Paper 13.) Claims 10, 11, 15, 16, 17, 19, 20, and 23 of the
`
`’000 patent are at issue in Mercedes’ IPR. (See id. at 2.) IPR was instituted on the
`
`following grounds:
`
`•
`
`•
`
`•
`
`•
`
`Claims 10, 11, 15, 19, and 23 obvious over Lemelson;
`
`Claims 10, 11, 15, 19, and 23 obvious over Lemelson and U.S. 5,541,590
`
`to Nishio (“Nishio”);
`
`Claims 10, 11, 15, 19, and 23 obvious over Lemelson and Asayama;
`
`Claims 16, 17, and 20 obvious over Lemelson and Yanagawa;
`
`-6-
`
`
`
`•
`
`•
`
`•
`
`•
`
`Claims 10, 15, 19, and 23 obvious over Nishio;
`
`Claims 10, 15, 19, and 23 obvious over Nishio and Asayama;
`
`Claims 10, 15, 16, 17, 19, 20, and 23 obvious over Nishio and Yanagawa;
`
`and
`
`Claims 10, 11, 15, 19, and 23 are unpatentable as obvious over Nishio
`
`and Lemelson.
`
`(See IPR2014-00647, Paper 13, at 16-28.) In granting Mercedes’ petition, the Board
`
`noted that it does not believe Lemelson to be anticipatory. The Board explained,
`
`however, that Mercedes will likely be able to establish that the ’000 patent’s claims are
`
`obvious. In particular, it would have been obvious to one of ordinary skill in the art
`
`to train prior art pattern recognition systems, like that disclosed by Lemelson, using
`
`“real data” as AVS apparently believes the ’000 patent’s claims require. (See, e.g., id. at
`
`16-17.) The Board issued a Scheduling Order on the same day it instituted Mercedes
`
`IPR. (See IPR2014-00647, Paper 14.) AVS’s response to Mercedes’ petition is due
`
`December 31, 2014. (IPR2014-00647, Paper 14, at 6.) A hearing is scheduled for
`
`June 4, 2015. (Id.)
`
`As noted above, concurrently with this motion, Toyota filed a second IPR
`
`petition seeking review on of all but one of the claims at issue in the Mercedes IPR.
`
`Toyota’s second IPR petition asserts the very same Lemelson-based obviousness
`
`-7-
`
`
`
`grounds as the Mercedes IPR (the first four grounds listed above in connection with
`
`the Mercedes IPR).
`
`II.
`
` ARGUMENT
`
`35 U.S.C. § 315(c) and 37 C.F.R. § 42.122(b) provide the Board with the
`
`discretionary ability to join IPR proceedings. A petitioner must file a motion for
`
`joinder within one month of the institution of the IPR the petitioner is seeking to
`
`join. 37 C.F.R. § 42.122(b). Since the Mercedes IPR was instituted October 23, 2014,
`
`Toyota’s motion was filed within the one month period following institution and is
`
`timely.
`
`The applicable rules governing the filing and progress of IPRs, including the
`
`rules relating to joinder, are meant to “secure the just, speedy, and inexpensive
`
`resolution of every proceeding.” 37 C.F.R. § 42.1(b). Joinder of Toyota’s petition
`
`with the Mercedes IPR will further these goals.
`
`1.
`
`Joinder Will Avoid Possibly Conflicting Results and Undue
`Prejudice
`AVS has accused both Toyota and Mercedes of infringing claims of the ’000
`
`patent. While Toyota has already filed an earlier IPR petition relating to the ’000
`
`patent (see IPR2014-00424), the Mercedes IPR will address additional obviousness
`
`grounds that Toyota was prohibited from exploring during its first IPR. In particular,
`
`the Mercedes IPR will address whether one of ordinary skill in the art would have
`
`known that the prior art pattern recognition system of Lemelson could be trained by
`
`-8-
`
`
`
`“real data” thus rendering the ’000 patent’s claims obvious. When it instituted the
`
`Mercedes IPR, the Board determined that the ’000 patent’s claims are likely
`
`unpatentable on these grounds. (See IPR2014-00647, Paper 13, at 16-28.)
`
`Joining Toyota’s petition with the Mercedes IPR will ensure that this
`
`obviousness issue is fully vetted by the Board, and will avoid the potential for possibly
`
`conflicting results and prejudice. Toyota’s first IPR petition asserted that Lemelson
`
`anticipates the ’000 patent’s claims. In instituting Mercedes’ IPR, however, the Board
`
`disagreed with Mercedes’ argument that Lemelson discloses all the limitations of these
`
`claims. If the Board arrives at a similar conclusion when it issues its final written
`
`decision in connection with Toyota’s first IPR, it may hold that the grounds in
`
`Toyota’s first IPR do not render the ’000 patent’s claims unpatentable (even though it
`
`is of the view that those claims are in fact unpatentable on the grounds asserted by
`
`Mercedes). It is also possible that Mercedes and AVS will reach a resolution of their
`
`dispute during the pendency of the Mercedes IPR leading to termination of that IPR
`
`without a final written decision.
`
`This series of events would significantly delay the resolution of the obviousness
`
`of the ’000 patent’s claims in view of Lemelson. It could also cause the issue to be
`
`litigated in district court. Litigating the ’000 patent in district court significantly
`
`increases the potential for possibly conflicting and thus prejudicial results. Among
`
`other things, instead of the preponderance of the evidence standard applicable here, a
`
`higher, clear and convincing burden of proof would apply. Forcing Toyota to litigate
`-9-
`
`
`
`the ’000 patent in district court and overcome a higher burden of proof, and also
`
`possibly require additional expert and other discovery, would be unduly prejudicial,
`
`especially since Toyota complied with all applicable statutes and regulations in filing
`
`its second IPR petition and this motion. Joinder will avoid all of these problems. It
`
`will ensure that both Mercedes and Toyota are similarly situated with respect to their
`
`patentability challenges. And, joinder will also ensure that the Lemelson-based
`
`obviousness grounds raised by the Mercedes IPR—which the Board has already
`
`determined are meritorious and likely to render the ’000 patent’s claims
`
`unpatentable—are fully considered and carried through to a final written decision.
`
`Additionally, there are no other reasons why Toyota’s joinder motion should be
`
`denied. For instance, while Toyota did file a previous IPR petition relating to the ’000
`
`patent, the Board prevented Toyota from addressing the obviousness of the
`
`“generated from” limitations in view of Lemelson during that IPR. Thus,
`
`obviousness of this limitation is a grounds that Toyota has not “raised or reasonably
`
`could have raised” in its first IPR, and the estoppel provisions of 35 U.S.C. § 315(e)(1)
`
`do not require denial of Toyota’s second IPR petition or the present joinder motion.
`
`2.
`
`Joinder Is Appropriate Because the Proceedings are Substantially
`Identical
`The issues raised by Toyota’s second IPR petition are substantively identical to
`
`issues in the Mercedes IPR. In particular, Toyota’s petition identifies prior art that is
`
`already identified in the Mercedes IPR, and include the same substantive analysis of
`
`-10-
`
`
`
`that prior art. In fact, there only few small differences between Toyota’s second IPR
`
`petition and the Mercedes IPR, none of which are meaningful. For instance, Toyota’s
`
`petition omits claim 15, which AVS asserted against Mercedes but not Toyota in its
`
`district court filings. Additionally, Toyota’s second petition includes only those
`
`grounds asserting that Lemelson (either itself or in combination with other prior art)
`
`renders the claims obvious. Thus, it has omitted those grounds relying primarily on
`
`Nishio. In addition to virtually identical grounds, Toyota’s petition references the
`
`same exhibits as the Mercedes IPR. While Toyota’s petition is supported by the
`
`declaration of a different expert, Toyota’s expert arrives at the same conclusions for
`
`the same reasons as Mercedes’ expert. Given the near identity between Toyota’s
`
`petition and the Mercedes IPR, joinder is not only highly appropriate, but is necessary
`
`to avoid a wasteful duplication of effort.
`
`3.
`
`Joinder Will Not Impact the Board’s Ability to Complete Review in
`a Timely Manner
`Joinder in this case will not impact the Board’s ability to complete its review in
`
`a timely manner. An IPR proceeding is meant to be completed within one year of
`
`institution. See Under 35 U.S.C. § 316(a)(11). While the Board is able to extend this
`
`one-year period by up to six months either for good cause or to accommodate
`
`joinder, Toyota does not believe that granting its motion will affect the Board’s ability
`
`to issue its final determination by October 2015. Again, Toyota’s petition does not
`
`raise any issues that are not already before the Board in connection with the Mercedes
`
`-11-
`
`
`
`IPR. No new grounds, prior art, arguments, analysis, or exhibits will be added that
`
`either the AVS or the Board will have to consider. And, while Toyota’s petition does
`
`rely on a different expert declaration than that at issue in the Mercedes IPR, Toyota’s
`
`expert’s opinions are not substantively different from those of Mercedes’ expert. In
`
`view of this, Toyota’s petition cannot and will not delay the resolution of the
`
`Mercedes IPR.
`
`Moreover, joinder should also not have any significant impact on the schedule
`
`in the Mercedes IPR. The first due date set by the Board’s scheduling order is AVS’s
`
`response to Mercedes’ petition, which is due December 31, 2014. (See IPR2014-
`
`00647, Paper 14, at 6.) This due date is more than a month-and-a-half away. To the
`
`extent any extension of the schedule is needed at all, it will be minor. This is because
`
`Toyota’s petition does not raise any new issues and thus will not require AVS to
`
`engage in analysis beyond what it is already required to undertake in responding to
`
`Mercedes’ petition.
`
`4.
`
`Joinder Will Allow for Consolidated Filings and Discovery
`
`Joinder will also allow for the consolidation of Toyota’s filings with those
`
`submitted by Mercedes. Rather than submitting separate responsive and reply papers
`
`that are duplicative of Mercedes’ (as it would if its IPR were not joined with
`
`Mercedes’), Toyota is willing to limit its filings to no more than seven pages directed
`
`only to points that are diverse from the position of Mercedes, with the understanding
`
`that it will not present any duplicate arguments in furtherance of those advanced by
`-12-
`
`
`
`Mercedes. This is similar to procedures that the Board has approved of in other
`
`proceedings. See, e.g., Hyundai Motor Corp. v. Am. Veh. Scis., IPR2014-01543, Paper No.
`
`11, at 4-6 (Oct. 24, 2014); Dell, IPR2013-00385, Paper No. 17, at 8 (adopting similar
`
`procedures); Motorola Mobility LLC v. Softview LLC, IPR2013-00256, Paper No. 10, at 9
`
`(same). Given that Toyota and Mercedes will be addressing the same prior art and the
`
`same bases for rejection, Toyota does not envision any differences in position with
`
`Mercedes, and does not believe that it is likely to make any separate filings at all. This,
`
`of course, assumes that Mercedes continues to press its IPR and actually files
`
`response and reply briefs. If Mercedes resolves its dispute regarding the subject
`
`matter of the IPR with AVS and withdraws, however, Toyota intends to continue to
`
`make the various filings contemplated by the Board’s schedule on its own.
`
`Joinder will also result in a substantial reduction of the amount of needed
`
`discovery. Without joinder, it is possible that AVS would need to make its own
`
`expert available for deposition multiple times: once in the Mercedes IPR and again in
`
`connection with Toyota’s second petition. Joinder will avoid this. Further, in the
`
`event that Mercedes continues to pursue its IPR, Toyota does not envision that it will
`
`need to take any separate discovery at all. While AVS may want to depose Toyota’s
`
`expert, this is choice it will confront regardless of whether joinder is ordered or not.
`
`As a result, granting Toyota’s motion will add no discovery to the consolidated
`
`proceeding, and will only result in simplification.
`
`-13-
`
`
`
`5.
`
`Joinder Will Not Prejudice AVS or Mercedes
`
`Permitting joinder will also not significantly prejudice either AVS or Mercedes.
`
`As explained above, the Lemelson-based obviousness grounds in Toyota’s petition are
`
`substantively identical to grounds already at issue in the Mercedes IPR. As a result, if
`
`Toyota’s second IPR is instituted and its joinder motion is granted, this should not
`
`significantly affect the timing of the Mercedes IPR, or the content of AVS’s response
`
`which is currently due to be filed December 31, 2014. And, in view of Toyota’s
`
`agreements regarding discovery and filings, Toyota’s participation in the Mercedes
`
`IPR will impose little if any additional costs on AVS and Mercedes. In fact, by
`
`eliminating a duplicative proceeding, joinder will actually serve to reduce costs.
`
`Finally, even if the Board were to determine that joinder requires minor
`
`extension of the schedule, such an extension is permitted by law and is not a reason
`
`for denying joinder. See, e.g., 35 U.S.C. § 316(a)(11); 37 C.F.R. § 42.100(c).
`
`III. CONCLUSION
`
`For the foregoing reasons, Toyota respectfully requests that IPR be instituted
`
`on the grounds set forth in its petition, and that the resultant IPR be joined with the
`
`Mercedes IPR.
`
`
`
`
`
`
`
`
`
`-14-
`
`
`
`Dated: November 17, 2014
`
`
`
`
`
`
`
`
`
` /Matt Berkowitz/
` Lead Counsel for Petitioner
`
`
`
`
`
`Matt Berkowitz (Reg. No. 57,215)
`Lead Counsel for Petitioner
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004
`Tel: 212-425-7200
`Fax. 212-425-5288
`Email: mberkowitz@kenyon.com
`
`-15-
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the forgoing motion for joinder was served
`
`November 17, 2014 via Federal Express upon the following:
`
`Brian Roffe, Esq.
`8170 McCormick Boulevard, Suite 223
`Skokie, IL 60076-2914
`Office: 516-448-6435
`
`Thomas J. WImbiscus
`McAndrews Held &Ma110y
`500 W. Madison, 34‘h floor
`Glicago, 111. 60661
`Tel. (312) 775-800
`Fax: (312) 775-8100
`
`/
`
`Lead Counsel for Petitioner
`Matt Berkovdtz (Reg. No. 57,215)
`
`
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