`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ORACLE CORPORATION, NETAPP ) Case Nos.
` INC., AND HUAWEI ) IPR2014-01197,
` TECHNOLOGIES CO., LTD., ) -01207, -01209,
` Petitioner, ) -01226, -01463,
` V. ) -01544; and
` CROSSROADS SYSTEMS, INC. ) IPRs2015-00772,
` Patent Owner ) -00773, -00777,
` ___________________________ ) -00822, -00825,
` Patent 6,425,035 ) -00852, -00854
`
` TELEPHONIC CONFERENCE BEFORE A
` PANEL OF ADMINISTRATIVE PATENT JUDGES:
` JUDGE HYUN J. JUNG
` JUDGE NEIL T. POWELL
` JUDGE KRISTINA M. KALAN
` HELD ON
` FRIDAY APRIL 24, 2015
`
`Reported by: BRENDA R. COUNTZ, RPR-CRR CSR NO. 12563
`Job No: 92922
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`Oracle Ex. 1012, pg. 1
`Oracle, et al. vs. Crossroads
`IPR2015-00825
`
`
`
`Page 2
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` Telephone conference taken
`telephonically from 4921 Escalon Avenue, Los
`Angeles, California, on Friday, April 24, 2015,
`before Brenda R. Countz, CSR No. 12563.
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`Oracle Ex. 1012, pg. 2
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`Page 3
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`APPEARANCES OF COUNSEL:
`
`FOR ORACLE CORPORATION, NETAPP, INC., AND HUAWEI
`TECHNOLOGIES COMPANY, LTD.:
` OBLON McLELLAND MAIER & NEUSTADT
` BY: GREG GARDELLA, ESQ.
` (Via telephone)
` 1940 Duke Street
` Alexandria, VA 22314
`
` ORACLE CORPORATION
` BY: RACHEL MAGUIRE, ESQ.
` (Via Telephone)
` 500 Eldorado Boulevard
` MS BRM01-200
` Broomfield, CO 80021
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`Oracle Ex. 1012, pg. 3
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`Page 4
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`APPEARANCES OF COUNSEL (Continued)
`FOR THE NETAPP, INC:
` NETAPP
` BY: CYNTHIA ROSSER, ESQ.
` (Via Telephone)
` 495 East Java Drive
` Sunnyvale, CA 94089
`
`FOR THE PETITIONERS CISCO AND QUANTUM:
` HAYNES AND BOONE
` BY: ANDREW EHMKE, ESQ.
` SCOTT JARRETT, ESQ.
` (Via Telephone)
` 2323 Victory Ave
` Dallas, TX 75219
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`Oracle Ex. 1012, pg. 4
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`
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`APPEARANCES OF COUNSEL (Continued)
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`Page 5
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`FOR THE PATENT OWNER CROSSROADS SYSTEMS, INC.
` WONG CABELLO LUTSCH RUTHERFORD & BRUCCULERI
` BY: JAMES HALL, ESQ.
` (Via Telephone)
` 20333 SH 249
` Houston, TX 77070
`
` - AND -
`
` SPRINKLE IP LAW GROUP
` BY: STEVEN SPRINKLE, ESQ.
` (Via Telephone)
` 1301 West 25th St
` Austin, TX 78705
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`Oracle Ex. 1012, pg. 5
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`Page 6
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` P R O C E E D I N G S
` (10:00 A.M.)
`
` JUDGE JUNG: With me are Judges Powell,
`Kalan and Lee. Do we have anybody for Petitioner
`Oracle, Netapp and Huawei?
` MR. GARDELLA: Yes, Your Honor. This
`is Greg Gardella. I am also joined potentially
`by Cindy Rosser from Netapp. And Eunhae Park
`from Oracle and I may also be joined by Scott
`McKeown from Oblon. I haven't heard him on the
`call yet though.
` MS. MAGUIRE: This is Rachel Maguire
`from Oracle. I'm going to be on the call instead
`of Eunhae Park.
` JUDGE JUNG: Very well.
` MS. ROSSER: This is Cindy Rosser for
`Netapp. I am on the call.
` MR. GARDELLA: And that's it for those
`three parties, Your Honor.
` JUDGE JUNG: Okay. Thank you.
` MR. GARDELLA: And by the way, as you
`probably heard, we do have a court reporter on
`and we will file the transcript promptly.
` JUDGE JUNG: Okay, thank you.
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`Oracle Ex. 1012, pg. 6
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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` Do we have anybody for petitioner Dot
`Hill Systems.
` MR. ARMON: Yes, Your Honor. This is
`Orion Armon with Cooley on behalf of petitioner
`Dot Hill Systems Corp.
` JUDGE JUNG: Thank you, Mr. Armon.
` Is there anybody here on behalf of
`Quantum?
` MR. EHMKE: Yes, Your Honor. This is
`Andrew Ehmke of Haynes and Boone. And I have
`with me Scott Jarrett.
` JUDGE JUNG: Okay. And for Patenter
`Crossroads, do we have anybody there.
` MR. HALL: Yes, Your Honor. This is
`James Hall with Wong, Cabello for Crossroads and
`I believe Steve Sprinkle with Sprinkle IP Law
`Group is also on the line for Crossroads.
` JUDGE JUNG: That's Steve Sprinkle?
` MR. HALL: Yes.
` JUDGE JUNG: Okay. And is there
`anybody else who has not yet made an
`introduction?
` (No Response.)
` JUDGE JUNG: All right. The purpose of
`this conference call is to discuss various
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`TSG Reporting - Worldwide - 877-702-9580
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`Oracle Ex. 1012, pg. 7
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`e-mails we've received over the past few months
`trying to consolidate or coordinate the schedules
`and maybe expedite the patent owners preliminary
`response to certain cases and other requests from
`other parties.
` I like to tell the petitioners for all
`the parties that we did receive your e-mails it
`looks like today at 12:30 discussing the first
`and second group of cases. So we will also
`discuss that.
` Also, before I begin, I'd like to know
`the status of the related litigation and some of
`the papers filed in some of these cases. They
`mentioned separate suits against each petitioner
`in the Western District of Texas.
` So let me start with Mr. Gardella. Do
`you know the status of your particular suit?
` MR. GARDELLA: I believe the suits are
`all pending and have not been stayed yet.
`Rachel, you can confirm but I believe that's the
`case.
` JUDGE JUNG: Okay. Ms. Rosser and Ms.
`Maguire is that correct?
` MS. ROSSER: That is correct. There is
`a pending motion to stay in the suits but it has
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`Oracle Ex. 1012, pg. 8
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`Page 9
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`not been ruled upon.
` JUDGE JUNG: Okay. Mr. Armon, do you
`agree?
` MR. ARMON: Yes, Your Honor. That's
`the case as to all of the lawsuits pending in the
`Western District of Texas. They are all pending.
`Motions for stay have been filed but have not yet
`been ruled on.
` JUDGE JUNG: Okay. Mr. Ehmke and Mr.
`Sprinkle and Mr. Hall do you have anything to
`add?
` MR. HALL: That is correct, Your Honor,
`what the other parties have said.
` THE COURT: Okay. And one other thing.
`We are dealing with several parties. Have any
`settlement discussions been raised or are there
`any settlement discussions ongoing?
` I know they might be confidential but
`if you don't want discuss that now, it's okay.
`But if there is anything that you can discuss
`please bring it up now. Mr. Gardella?
` MR. GARDELLA: On that score I think it
`would be efficient to defer to Mr. Hall. He's
`kind of the funnel for all those discussions.
` JUDGE JUNG: All right, Mr. Hall.
`
`TSG Reporting - Worldwide - 877-702-9580
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`Oracle Ex. 1012, pg. 9
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`Page 10
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` MR. HALL: Yes, Your Honor. There have
`been settlement discussions with petitioner
`quantum and petitioner Huawei. But it doesn't
`appear we are very close to settlement at this
`point.
` But obviously, we'll keep the board
`apprised if we are making any progress with any
`of the petitioners.
` JUDGE JUNG: Okay. Thank you.
` And it looks like there are three new
`cases that these particular panels were not aware
`of before, 1063, 1064 and 1066. But are there
`any other cases that do not look like we've
`mentioned in anyway before that are related to
`these patents related by Crossroads, Mr. Hall or
`Mr. Sprinkle.
` MR. HALL: We're not aware of any other
`cases, Your Honor.
` JUDGE JUNG: Okay. All right.
`Although the parties have coordinated together to
`propose a separate agenda, I'd like to stick with
`my original agenda. And I'll try to graft on
`your proposal onto the agenda I sent out earlier.
` So lets begin with cases IPR 2014-1197,
`2014-1226, 2015-777, 2015-822 and 2015-825. They
`
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`Oracle Ex. 1012, pg. 10
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`Page 11
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`challenge U.S. Patent 6,425,035. And I will
`refer to the patent as the 035 patent, and I will
`refer to this group of cases as the 035 cases
`hereafter.
` Now, it looks like from the e-mail, in
`my quick review, the parties have agreed that the
`patent owner will file a patent owner preliminary
`response but that filing will not be expedited.
` Is that correct Mr. Hall or
`Mr. Sprinkle.
` MR. HALL: Yes, Your Honor, that was
`what we discussed with the petitioner earlier
`this morning.
` And Your Honor, let me add as well the
`parties propose using the schedule in the 1463
`proceeding for all of these proceedings. One of
`the reasons that that was agreeable to the patent
`owner was that the preliminary responses would
`not be accelerated which we understood petitioner
`to agree to simply for the reason that if it was
`accelerated and we were under that schedule it
`would make the preliminary responses and the
`patent owner's responses due approximately the
`same time depending obviously on the
`acceleration.
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`Oracle Ex. 1012, pg. 11
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`Page 12
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` But that was not something that the
`patent owner wanted simply because of not having
`sufficient resources to be able to deal with all
`of the responses and preliminary responses at the
`same time.
` JUDGE JUNG: All right. I realize in
`some of the 035 cases that there is no expediting
`of the patent owner's preliminary response that
`the patent owner's responses --
` I'm sorry. Some of these cases will be
`joined after the patent owner's response in some
`of the earlier cases. Is the patent owner okay
`with that?
` MR. HALL: Yes, Your Honor. What we
`discussed with the petitioners and proposed to
`the board is as far as the motions for joinder
`the case is subject to the motions for joinder.
`We are not opposed to joinder should the Board
`decide that institution is appropriate.
` Obviously, we believe that the cases
`should not be instituted and we want to file our
`preliminary responses to that effect. But should
`the board then ultimately determine that they
`will institute, we don't oppose joinder and using
`the existing schedule based on the petitions and
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`Oracle Ex. 1012, pg. 12
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`Page 13
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`the motions for joinder statements that
`petitioners will be assuming purely an understudy
`role as they set forth there.
` So that's not a problem with us if they
`would be put on the same schedule.
` JUDGE JUNG: Okay. And it looks like
`out of the 035 cases one particular case, IPR
`2015-0077 has been placed in the parties'
`proposed second group. Let me see. Bear with me
`while I read over your paragraph. (Pause.)
` Mr. Hall and Mr. Sprinkle can either
`one of you kind of summarize what the party's
`proposal is for IPR 2015-0077 and other cases in
`that second group.
` MR. HALL: Yes, Your Honor. As we
`state in the e-mail, the parties don't believe
`the Board should take any action with respect to
`these at this time.
` Essentially all of these proceedings
`are the first set filed by Netapp are, for want
`of a better word, basically do-over petitions.
` They repeat the grounds from the
`initial set of petitions filed by Oracle and
`Netapp and Huawei. However, they correct the
`deficiencies which the Board noted in its
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`Oracle Ex. 1012, pg. 13
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`decision denying institution decision in which it
`denied institution on certain claims and grounds.
` So they are attempting to correct those
`in the second set. So those petitions and then
`the very recently filed Oracle petitions seeking
`to join them raised the same grounds as in the
`first set of petitions filed and there will be
`some new grounds and new claims that are not
`currently in either set of proceedings from
`Oracle or Cisco.
` So I think both parties agree that the
`Board's decisions in the earlier cases made moot
`some of those grounds. And obviously patent
`owner is going to request the Board not institute
`trial at all in those cases in it's preliminary
`response.
` So right now we would think that the
`best thing is to leave those proceedings to the
`side and should the Board decide to institute the
`parties will be in a better position at that time
`to decide the effect of the earlier proceedings
`on those proceedings and the Board will be in
`that same position.
` JUDGE JUNG: I see. Thank you. All
`right. Let me turn to the panel and see if they
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`Oracle Ex. 1012, pg. 14
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`Page 15
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`have any questions.
` (Discussion off the record.)
` JUDGE JUNG: Hello, this is Judge Jung
`again. Sorry for the delay. We were discussing
`your e-mail.
` MR. HALL: Your Honor, this is Mr. Hall
`again. The one thing I wanted to address that I
`may have left the wrong impression regarding
`consolidation, my previous comments are directed
`to the later filed where we referred to the
`second group petitions.
` As far as consolidation of, I guess,
`the first group of petitions that are referenced
`in the e-mail from Mr. Gardella, patent owner
`does not oppose consolidation.
` We think there may be some efficiencies
`traded by it but on that score we will defer to
`what the Board's ultimate determination is.
` JUDGE JUNG: Okay. Thank you,
`Mr. Hall.
` Are there any questions from the
`parties for the panel? There are no questions
`from the panel to the parties.
` MR. HALL: Your Honor, if the board is
`considering consolidation, one of the details we
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`TSG Reporting - Worldwide - 877-702-9580
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`Oracle Ex. 1012, pg. 15
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`Page 16
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`would want to address after the board makes that
`determination or if the board believes it's going
`to is the page limits for responses and so forth
`and how to put all of these proceedings together.
` JUDGE JUNG: Okay. Thank you,
`Mr. Hall. Yes, we will consider that.
` MR. GARDELLA: Mr. Gardella on behalf
`of Oracle, Netapp and Huawei.
` JUDGE JUNG: Okay, Mr. Gardella.
` MR. GARDELLA: It's a comment maybe
`more than a question but it could be either. I
`will leave that to you.
` So, in the event Your Honors are
`considering consolidation, I guess two aspects.
`Number 1, based upon the discussions the parties
`had it doesn't seem as though there is a material
`distinction between that and the joinder and
`synchronized schedules.
` So it's Oracle, Netapp and Huawei's
`position that consolidation doesn't appear to be
`necessary. To the extent Your Honors are
`envisioning that consolidation might occur, the
`Cisco -- Nevertheless might occur, I should
`say-- the Cisco and Quantum petitions raised
`different grounds than the Netapp, Oracle, Huawei
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`TSG Reporting - Worldwide - 877-702-9580
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`Oracle Ex. 1012, pg. 16
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`petitions.
` And for that reason if consolidation
`were to occur, we'd have to confront and deal
`with the one-voice issue and even the single
`ground of the Cisco Quantum petition it's based
`on some of the same art but not all the art even
`as to that single ground overlaps completely.
` So we would propose that there are
`substantial complexities and potential acute
`prejudices which would occur if consolidation
`were granted and the board were particularly to
`enforce page limits and the one-voice rule.
` So we would request briefing of that
`issue to the extent the board is considering
`consolidation. Because again, that could in fact
`raise substantial prejudice from petitioners'
`perspective.
` THE COURT: At this point we are just
`raising consolidation as a means to assert some
`efficiency in these cases. But thank you for
`raising that point.
` If we get to the point where we are
`actually considering consolidating these cases,
`we will discuss that with the parties as well.
` At this point we are just considering
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`Oracle Ex. 1012, pg. 17
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`different options on how to make these cases
`proceed on the same schedule or in a more
`coordinated fashion than they are now.
` I'm sorry, was that Mr. Gardella?
` MR. HALL: I'm sorry, Your Honor. This
`is Mr. Hall. I guess my question was are we
`following the agenda that you had sent, where we
`are just discussing the 035 petitions and we're
`going to move on.
` JUDGE JUNG: That is correct.
` MR. HALL: Okay. All right.
` JUDGE JUNG: So, if there are no other
`questions or issues for the 035 cases I will move
`on to the next set of cases. Actually, it
`appears to me that maybe we could wrap this up a
`little bit quicker.
` For the remainder of the cases, the
`second group of cases on my agenda they were IPR
`2014-1207, 1209, 1544 and IPRs 2015-773 and 852.
`They challenge U.S. Patent number 7,051,147 which
`I will refer to as the 147 patent.
` Now, after reviewing your e-mail it
`looks like what we discussed for the 035 cases
`also applied for the 147 cases. But if that's
`not correct, let me know starting with Mr. Hall
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`Oracle Ex. 1012, pg. 18
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`and Mr. Sprinkle.
` MR. HALL: That is correct, Your Honor.
` JUDGE JUNG: Okay. And do any of the
`petitioners object to that?
` MR. GARDELLA: I would just add-- This
`is Mr. Gardella-- that you might want to add
`1064 to the 147 bucket. That's one of the brand
`new petitions.
` They were just in the petition
`verification stage, by the way I think, when Your
`Honor sent out the e-mail. So that's why they
`may not have been on your radar screen.
` JUDGE JUNG: All right. That also
`challenges the 147 patent, I take it.
` MR. GARDELLA: The 147 is 1064, yes.
` JUDGE JUNG: Okay. Thank you,
`Mr. Gardella.
` And then if there's no objection we
`will move on to the next group of cases that
`challenge the U.S. patent 7,051,041 patent. And
`that includes IPR 2014-1463. And IPRs 2015-776
`and 854.
` Are there any differences or issues or
`other questions that the parties want to bring up
`starting with Mr. Hall or Mr. Sprinkle.
`
`TSG Reporting - Worldwide - 877-702-9580
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`Oracle Ex. 1012, pg. 19
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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` MR. HALL: Your Honor, nothing in
`particular with these. However, depending on the
`Board's decision as far as scheduling, we may
`have one more issue to bring up if the Board is
`going to not make a decision on the schedule
`today or put that off for a week.
` I don't know what the board's timetable
`is. However, we do have pending responses due in
`two of these sets of cases that are due Monday.
` And therefore, if the Board is not
`going to adopt the party's proposal of moving the
`schedule for these proceedings then we would
`request a week extension at least to give the
`time for the Board to make a decision so that
`filing the responses themselves will somehow
`impact the feasibility of putting these on the
`same schedule.
` MR. GARDELLA: This is Mr. Gardella of
`Oracle, Netapp and Huawei have no objection to
`that. It's in our cases, so to speak, that the
`responses are due.
` And I understand Mr. Hall's proposal
`will be given a week such that the Board can
`decide what they are going to do or what you are
`going to do with regard to the issues on the
`
`TSG Reporting - Worldwide - 877-702-9580
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`Oracle Ex. 1012, pg. 20
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`agenda today and I think that is quite
`reasonable.
` JUDGE JUNG: Okay.
` MR. EHMKE: And this is Andy Ehmke on
`behalf of Cisco and Quantum. No additional
`comments and no objections to that either, Your
`Honor.
` JUDGE JUNG: Thank you, Mr. Ehmke.
` Mr. Armon.
` MR. ARMON: Your Honor, no objections
`from Dot Hill Systems Corp.
` JUDGE JUNG: Okay. Thank you, Mr.
`Armon.
` All right. And we have one outlier
`case, IPR 2015-00772 which challenges U.S. patent
`7,987,311. And I'm not positive but it may be
`one of the new cases that also challenges the 311
`patent. Let me see.
` MR. GARDELLA: Yes. It's the 772 case,
`Your Honor. This is Greg Gardella speaking.
` And on agenda item number 4 which I
`guess that was the 041 patent, you might want to
`add 1066 to your list. That is the most recently
`filed joinder petition.
` JUDGE JUNG: Okay. Thank you.
`
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`Oracle Ex. 1012, pg. 21
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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` MR. GARDELLA: And as to the last one
`there is no corresponding brand new case that was
`filed in the last few days. It's just the 772.
` JUDGE JUNG: Okay. The last thing I
`wanted to talk about was having a combined oral
`hearing for the various different patents and the
`related cases.
` But it sounds like the parties are--
`There seems to be an agreement that maybe a
`combined oral hearing would be best for
`everybody.
` Is that correct for Mr. Hall?
` MR. HALL: Yes, Your Honor.
` JUDGE JUNG: And Mr. Gardella, any
`objections to a combined oral hearing?
` MR. GARDELLA: It may turn out that
`they might be at a separate time over the same
`day, but we will try to coordinate all these
`cases on the same day if possible, depending on
`the availability of the hearing room.
` JUDGE JUNG: Mr. Armon, any objections?
` MR. ARMON: No, Your Honor.
` JUDGE JUNG: Mr. Ehmke.
` MR. EHMKE: No objections to that
`proposed plan, Your Honor. No.
`
`TSG Reporting - Worldwide - 877-702-9580
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`Oracle Ex. 1012, pg. 22
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`IPR2015-00825
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` JUDGE JUNG: All right. I'm going to
`go on mute and talk to the panel and see if they
`have any further questions on the other group of
`cases. I will be back soon.
` (Discussion held off the record.)
` MR. HALL: While they are caucusing,
`Cindy and Rachel, anything additional that you'd
`like to raise before we adjourn?
` MS. MAGUIRE: Nothing from Rachel,
`thanks.
` MS. ROSSER: Nothing from us, thanks.
` MR. ARMON: Is there anything you want
`to raise with me on the other line?
` MR. HALL: Nothing from me.
` JUDGE JUNG: All right. The panel has
`discussed the parties' proposals regarding the
`first case. And in the e-mail sent this morning
`the first case group is IPR 2014-1197, -1207,
`-1209, -1226, -1463, -1544, and IPRs 2015-822,
`825, 852 and 854.
` The panel generally agrees that we can
`adjust the schedules for those cases to match the
`schedule in the 1463 case.
` So the parties can stipulate that the
`patent owner can delay his filing of this
`
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`IPR2015-00825
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`response in cases 1197, 1207 and 1209 from April
`27 to May 26th which I believe is the due date in
`the 1463 case for the patent owner response.
` MR. HALL: That's agreeable for patent
`owner, Your Honor.
` JUDGE JUNG: Okay. And any objections
`from the petitioners?
` MR. GARDELLA: This is Mr. Gardella.
`No objection here, Your Honor. Thank you.
` JUDGE JUNG: Mr. Armon?
` MR. ARMON: No objection, Your Honor.
` JUDGE JUNG: Mr. Ehmke?
` MR. EHMKE: No objection, Your Honor.
` JUDGE JUNG: Okay. If we need to we
`will send out an order discussing what we just
`talked about today on this conference.
` And the panel appreciates that the
`parties were able to coordinate amongst
`themselves and provide a proposal.
` I hope everyone has a good weekend.
`And if there are no other questions or issues
`this call is adjourned.
` MR. HALL: Thank you, Your Honor.
` MR. GARDELLA: Thank you, Your Honor.
`Have a good weekend.
`
`TSG Reporting - Worldwide - 877-702-9580
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`Oracle Ex. 1012, pg. 24
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`
`
`JUDGE JUNG: Thank you.
`(Whereupon, the teleconference was
` adjourned at 10:40 o'clock, a.m.)
`
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`Oracle Ex. 1012, pg. 25
`Oracle, et al. vs. Crossroads
`IPR2015-00825
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`STATE OF CALIFORNIA ) SS
`COUNTY OF LOS ANGELES )
` I, BRENDA R. COUNTZ, Certified Shorthand
`Reporter No. 12563 for the State of California,
`do hereby certify:
` That said teleconference was taken down
`by me in shorthand at the time herein named and
`thereafter reduced to typewriting via
`computer-aided transcription under my direction;
`and that the same is a true, correct, and
`complete transcript of said proceedings.
` I further certify that I am not related
`to any parties thereto or interested in the
`outcome of the action.
` In witness whereof, I have hereunto
`subscribed my name this 27th day of April
`2015.
`
` __________________________________
` Brenda R. Countz, CSR No. 12563
`
`TSG Reporting - Worldwide - 877-702-9580
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`Oracle Ex. 1012, pg. 26
`Oracle, et al. vs. Crossroads
`IPR2015-00825