Paper No. 14
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
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`APPLE INC.
`
`Petitioner,
`
`v.
`
`VIRNETX, INC.,
`
`Patent Owner.
`____________________
`
`Case No. IPR2015-00866
`Patent No. 8,458,341
`____________________
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`
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`PETITIONER’S MOTION TO SUBMIT SUPPLEMENTAL
`INFORMATION PURSUANT TO 37 C.F.R. § 42.123(a)
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
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`APPLE INC.
`
`Petitioner,
`
`v.
`
`VIRNETX, INC.,
`
`Patent Owner.
`____________________
`
`Case No. IPR2015-00866
`Patent No. 8,458,341
`____________________
`
`
`
`PETITIONER’S MOTION TO SUBMIT SUPPLEMENTAL
`INFORMATION PURSUANT TO 37 C.F.R. § 42.123(a)
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`IPR2015-00866
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`Paper No. 14
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`Table of Contents
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`I.
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`II.
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`Introduction .................................................................................................... 1
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`Background .................................................................................................... 2
`Legal Standard .................................................................................... 2
`A.
`This Proceeding ................................................................................... 3
`B.
`
`III. Argument ........................................................................................................ 4
`Petitioner’s Motion Is Timely and the Supplemental Information
`A.
`Is Relevant as Required by § 42.123(a) ............................................. 4
`Consideration of the Supplemental Information Relating to the
`Public Availability of Prior Art References Is Appropriate ........... 7
`IV. Conclusion ...................................................................................................... 9
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`B.
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`
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`i
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`IPR2015-00866
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`I.
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`Introduction
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`Paper No. 14
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`Petitioner Apple Inc. (“Petitioner”) respectfully moves to submit Exhibits
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`1060 to 10651 as supplemental information under 37 C.F.R. § 42.123(a). Each
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`exhibit is relevant to a claim at issue in this trial, as required by § 42.123(a)(2),
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`because each is evidence that RFC 2401 was published and publicly available in
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`November 1998. The exhibits include a declaration and deposition testimony
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`concerning the public availability of RFC 2401 and numerous other RFCs by
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`Sandy Ginoza, a representative of the Internet Engineering Task Force (“IETF”),
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`and additional documentation that addresses RFC 2401’s public availability.
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`The Board should admit these exhibits into the record because they are
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`“additional evidence that allegedly confirms the public accessibility of” prior art
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`references at issue in this trial. Palo Alto Networks, Inc v. Juniper Networks, Inc.,
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`IPR2013-00369, Paper 37 at 3 (Feb. 5, 2014). So, apart from being relevant to the
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`claims at issue, these exhibits merely supplement information already present in
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`the record, do not alter the scope of the instituted grounds, and their consideration
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`
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`1 Petitioner has moved to submit Exhibits 1057 to 1065 as supplemental
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`information in the proceedings that primarily rely on Aventail (IPR2015-00811
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`and -00871), and Exhibits 1060 to 1065 in the proceedings that primarily rely on
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`Beser (IPR2015-00810, -00812, -00866, -00868, and -00871).
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`1
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`will not unduly delay the trial’s schedule. Id. at 3-4 (granting motion under
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`§ 42.123(a) based on consideration of these factors). Accordingly, Petitioner
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`respectfully requests that its motion be granted.
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`II. Background
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`A. Legal Standard
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`A party may submit supplemental information under 37 C.F.R. § 42.123(a)
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`if: (1) a “request for the authorization to file a motion to submit supplemental
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`information is made within one month of the date the trial is instituted” and (2) the
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`“supplemental information [is] relevant to a claim for which the trial has been
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`instituted.” Unlike supplemental information submitted later in trial (§ 42.123(b))
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`or information not relevant to a claim for which trial was instituted (§ 42.123(c)), a
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`motion under § 42.123(a) need not “show why the supplemental information
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`reasonably could not have been obtained earlier, and that consideration of the
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`supplemental information would be in the interests-of-justice.”
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`Instead, under § 42.123(a) the Board has considered whether the information
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`changes “the grounds of unpatentability authorized in this proceeding” or “the
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`evidence initially presented in the Petition to support those grounds of
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`unpatentability.” Palo Alto Networks, IPR2013-00369, Paper 37 at 3; see also
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`Biomarin Pharma. Inc., v. Genzyme Therapeutic Prods Limited Partnership,
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`IPR2013-00534, Paper 80 at 5 (Jan. 7, 2015) (considering the same factors under §
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`2
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`42.123(b)). The Board has also considered whether granting the motion would
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`prevent the just, speedy, and inexpensive resolution of the proceeding, Palo Alto,
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`IPR2013-00369, Paper 37 at 4, or would prejudice the other party, Unified Patents
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`Inc., v. Dragon Intellectual Property, LLC, IPR 2014-01252, Paper 43 at 3 (Apr.
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`14, 2015); see also Rackspace US, Inc. v. Personal Web Techs., LLC, IPR2014-
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`00058, Paper 16 at 6 (Apr. 30, 2014) (denying motion to submit supplemental
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`expert report that was presented to challenge the Board’s claim constructions).
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`Where a party has sought to submit information that confirms the public
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`accessibility of a prior art reference at issue in the trial, the Board has repeatedly
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`found such evidence to be proper supplemental information. See, e.g., Biomarin,
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`IPR2013-00534, Paper 80 at 5 (granting motion under stricter standard of
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`§ 42.123(b)); Valeo North Am., Inc. v. Magna Elecs, Inc., IPR2014-01204, Paper
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`26 at 2-5 (Apr. 10, 2015); Palo Alto Networks, IPR2013-00369, Paper 37 at 2-5;
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`Motorola Sol’ns, Inc. v. Mobile Scanning Techs, LLC, IPR2013-00093, Paper 39 at
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`2 (July 16, 2013). As the Board has recognized, “a trial is, first and foremost, a
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`search for the truth.” Edmund Optics, Inc., v. Semrock, Inc., IPR2014-00599,
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`Paper 44 at 4 (May 5, 2015) (granting motion to submit supplemental information)
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`(citing TechSearch LLC v. Intel Corp., 286 F.3d 1360, 1378 (Fed. Cir. 2002)).
`
`B.
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`This Proceeding
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`On October 1, 2015, the Board instituted trial in this proceeding on several
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`3
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`grounds based on the combination of U.S. Patent No. 6,496,867 (“Beser”) and
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`RFC 2401, “Security Architecture for the Internet Protocol” (“RFC 2401”). See
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`Paper 8 at 2-3, 13. The Board found that the evidence supported a finding that
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`RFC 2401 is a prior art printed publication. Id. at 6-7. In a paper it filed in this
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`proceeding, Patent Owner VirnetX, Inc. has raised challenges as to whether RFC
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`2401 was publicly available. In its Preliminary Response Patent Owner VirnetX
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`Inc. contended that RFC 2401 was not accessible to the public as of the relevant
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`date to qualify as prior art in this proceeding. See Paper 6 at 2-9.
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`III. Argument
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`A.
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`Petitioner’s Motion Is Timely and the Supplemental Information
`Is Relevant as Required by § 42.123(a)
`
`Petitioner requested authorization to file a motion to submit supplemental
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`information via email on October 8, 2015, within one month of institution of trial.
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`Thus, Petitioner’s motion is timely under § 42.123(a)(1). In addition, the
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`information Petitioner requests to submit into the record is “relevant to a claim [at
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`issue in] the trial” as required by § 42.123(a)(2). As explained below, each exhibit
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`is relevant because it supports Petitioner’s assertions and the Board’s preliminary
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`findings about the publication and public availability of RFC 2401. Petitioner thus
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`submits that the supplemental information is proper under § 42.123(a)(1) and
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`should be entered into the record.
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`Exhibits 1060-1065 are evidence that RFC 2401 is a printed publication that
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`was publicly available via the Internet by November 1998. See Paper 8 at 6-7; Ex.
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`1005 at ¶¶ 186-193; Ex. 1036 at 6, 8; Pet. at 24.
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`Exhibit 1060 is a declaration from Sandy Ginoza, acting as a designated
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`representative of the IETF, created in response to a subpoena served as part of an
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`investigation initiated by Patent Owner before the International Trade Commission
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`(337-TA-858). Ex. 1060 at ¶¶ 1-5; Ex. 1063 at 6:23-7:4, 10:5-14. In her
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`declaration, Ms. Ginoza testified that RFC 2401 was published on the RFC
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`Editor’s website and was publicly available in November 1998. Ex. 1060 at
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`¶¶ 105-107. For example, Ms. Ginoza explained:
`
`Based on a search of RFC Editor records, I have determined that the
`RFC Editor maintained a copy of RFC 2401 in the ordinary course of
`its regularly conducted activities. RFC 2401 has been publicly
`available through the RFC Editor’s web site or through other means
`since its publication in November 1998.
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`Ex. 1060 at ¶ 107. Ms. Ginoza similarly testified that numerous other RFCs were
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`published on the RFC Editor’s website and were publicly available since the date
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`on the face of the documents. E.g., Ex. 1060 at ¶¶ 168-170. Exhibit 1061 is the
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`bates stamped copy of RFC 2401 that IETF produced in conjunction with Ms.
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`Ginoza’s declaration. Exhibit 1062 is a redline comparison showing there are no
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`substantive differences between Exhibit 1061 and Exhibit 1008, the copy of RFC
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`2401 Petitioner previously filed in this proceeding.
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`5
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`Paper No. 14
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`Exhibit 1063 is the transcript of Ms. Ginoza’s February 8, 2013 deposition
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`that was taken as part of the ITC action. At her deposition, Ms. Ginoza testified:
`
`Q []: You've just been handed what's been marked as Exhibit 16. It is
`titled "Request for Comments: 2401" with a Bates number of 337-TA-
`858-IETF001122 through 1183. Is that correct?
`A Yes.
`Q Was RFC 2401 produced in response to the subpoena?
`A Yes.
`* * *
`Q Is the document produced at this bits [sic] range a true and correct
`copy of the record of RFC 2401 as it's kept in the files of the RFC
`Editor?
`A Yes.
`* * *
`Q Was RFC 2401 publicly available as of the date listed on its face?
`A Yes.
`Q What date was RFC 2401 made publicly available?
`A November 1998.
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`Ex. 1063 at 39:14-24; see id. at 10:5-11:22 (confirming her knowledge of IETF
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`publishing practices as they relate to RFCs). Ms. Ginoza offered similar testimony
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`with respect to numerous other RFCs. E.g., Ex. 1063 at 45:5-46:17. During the
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`February 8, 2013 deposition, Patent Owner cross-examined Ms. Ginoza about her
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`testimony and declaration. See id. at 55:3-16; see also id. at 50:7-69:1.
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`Exhibit 1064 is an article from InfoWorld magazine (dated August 16, 1999)
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`and Exhibit 1065 is an article from NetworkWorld magazine (dated March 15,
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`1999). Each exhibit is an excerpt from an industry publication that states it was
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`known that RFCs, and RFC 2401 specifically, were publicly available through the
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`Internet, such as through the IETF’s website. See, e.g., Ex. 1064 at 9 (discussing
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`RFCs 2401 to 2408 and stating “All of these documents are available on the IETF
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`website: www.ietf.org/rfc.html”); Ex. 1065 at 3 (discussing IP security protocols
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`and stating “See the IETF documents RFC 2401 ‘Security Architecture for the
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`Internet Protocol’ at www.ietf.org/rfc/rfc2401.txt”).
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`These exhibits support Petitioner’s assertions that RFC 2401 is prior art to
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`the challenged claims.
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`B. Consideration of the Supplemental Information Relating to the
`Public Availability of Prior Art References Is Appropriate
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`The exhibits proffered by Petitioner satisfies other factors the Board has
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`considered when evaluating motions to submit supplemental information.
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`First, Petitioner’s exhibits provide additional evidence that the prior art for
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`each of the instituted grounds are indeed prior art, and as such does not change
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`“the grounds of unpatentability authorized in this proceeding” or “the evidence
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`initially presented in the Petition to support those grounds of unpatentability.” See,
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`e.g., Palo Alto Networks, Inc v. Juniper Networks, Inc. IPR2013-00369, Paper 37
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`at 3. Exhibits 1060 to 1065 supplement the information presented with the Petition
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`with respect to RFC 2401, and are additional evidence that an RFC is published as
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`of the date listed on its face. See Pet. at 24; Ex. 1005 at ¶¶ 186-193; Ex. 1036 at 6,
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`8; see also Ex. 1036 at 19-21. Public availability evidence is precisely the type of
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`information that is properly submitted as supplemental information.
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`Second, Petitioner’s supplemental information will not prejudice Patent
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`Owner or delay the proceedings. Patent Owner will have limited need (if any) to
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`investigate the proffered information because Patent Owner already investigated
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`most of the exhibits during one of the concurrent litigation proceedings. Patent
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`Owner received Ms. Ginoza’s declaration and RFC 2401 (Exs. 1060-1061) as part
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`of the Section 337 action in 2013, and it had the opportunity to cross-examine Ms.
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`Ginoza about RFC 2401’s publication date. See Ex. 1063 at 50:7-69:1. In
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`addition, Petitioner has served all of the exhibits on Patent Owner concurrently
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`with this motion.2
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`
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`2 Petitioner notes that while some panels of the Board have found it improper to
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`file supplemental information as exhibits concurrently with the filing of the
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`motion, see, e.g., Unified Patents, IPR 2014-01252, Paper 43 at 3 (“Our
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`authorization to file the Motion was not an authorization to file the supplemental
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`information as an exhibit with the Motion.”), other panels have found that “filing
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`proffered supplemental information” concurrently with the motion “facilitates
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`review of a motion to submit that information,” see, e.g., Valeo, IPR2014-1204,
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`Consideration of the supplemental information will not frustrate the Board’s
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`ability to complete this proceeding in a timely manner. The evidence supports the
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`Board’s preliminary findings, and Patent Owner will have an opportunity to
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`address the evidence in its Patent Owner response.
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`IV. Conclusion
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`For the foregoing reasons, Petitioner respectfully requests that it be
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`permitted to submit Exhibits 1060 to 1065 as supplemental information.
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`
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`Dated: October 16, 2015
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`Respectfully Submitted,
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`
`
`/ Jeffrey P. Kushan /
`Jeffrey P. Kushan
`Reg. No. 43,401
`Sidley Austin LLP
`1501 K Street NW
`Washington, DC 20005
`
`
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`Paper 26 at 5. Because the Board did not explicitly authorize Petitioner to file the
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`supplemental information as part of this motion, Petitioner is not concurrently
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`filing it with this motion.
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`PETITIONER’S MOTION TO SUBMIT
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`SUPPLEMENTAL INFORMATION
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`Attachment A:
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`Exhibit List
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`IPR2015-00866
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`Exhibit List - i
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`IPR2015-00866
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`Paper No. 14
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`Ex. # Reference Name
`1001 U.S. Patent 8,458,341
`1002 U.S. Patent 8,458,341 File History
`1003 U.S. Patent 8,516,131
`1004 U.S. Patent 8,516,131 File History
`1005 Declaration of Roberto Tamassia
`1006 Curriculum Vitae of Roberto Tamassia
`1007 U.S. Patent 6,496,867 to Beser
`1008 Kent, S., et al., RFC 2401, “Security Architecture for
`the Internet Protocol” (November 1998)
`1009 Aventail Connect v3.01/v2.51 Administrator’s Guide
`(1996-1999)
`1010 Aventail Connect v3.01/v2.51 User’s Guide (1996-
`1999)
`1011 Aventail ExtraNet Center v3.0 Administrator’s Guide
`(NT and UNIX)
`1012 U.S. Patent 5,237,566 to Brand
`1013 Handley, M., et al., RFC 2543, SIP: Session Initiation
`Protocol (March 1999)
`1014 RFC 793, DARPA Internet Program Protocol
`Specification (September 1991)
`1015 U.S. Patent Number 6,430,176 to Christie
`1016 U.S. Patent Number 6,930,998 to Sylvain
`1017
`Patent Owner Preliminary Response, IPR2014-00237,
`Paper 12 (March 6, 2014)
`1018 Leech, M., et al., RFC 1928, SOCKS Protocol Version 5
`(March 1996)
`1019 Microsoft Computer Dictionary (4th Ed.)
`1020 U.S. Patent Number 6,408,336 to Schneider
`1021 U.S. Patent Number 5,633,934 to Hember
`
`Filing Status
`3/17/2015
`3/17/2015
`3/17/2015
`3/17/2015
`3/17/2015
`3/17/2015
`3/17/2015
`3/17/2015
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`3/17/2015
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`3/17/2015
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`3/17/2015
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`3/17/2015
`3/17/2015
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`3/17/2015
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`3/17/2015
`3/17/2015
`3/17/2015
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`3/17/2015
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`3/17/2015
`3/17/2015
`3/17/2015
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`Exhibit List - ii
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`IPR2015-00866
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`Paper No. 14
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`Filing Status
`3/17/2015
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`1026
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`1027
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`Exhibit List - iii
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`Ex. # Reference Name
`1022 Declaration of James Chester, Reexamination
`95/001,697
`1023 Declaration of Chris Hopen, Reexamination 95/001,697 3/17/2015
`1024 U.S. Patent 6,557,037 to Provino
`3/17/2015
`1025 Gunter, M., “Virtual Private Networks Over the
`3/17/2015
`Internet” (1998)
`Patent Owner Preliminary Response, IPR2014-00404,
`Paper 9 (May 19, 2014)
`von Sommering, S., Space Multiplexed-Electrochemical
`Telegraph
`1028 Licklider, J.C.R., Memorandum for Members and
`Affiliates of the Intergalactic Computer Network
`(December 11, 2001)
`1029 BBN Report No. 1822, Interface Message Processor
`(January 1976)
`1030 Koblas, D., et al., “SOCKS-Usenix Unix Security
`Symposium III”
`1031 Windows NT for Dummies
`1032 Mockapetris, P., RFC 882, “Domain Names – Concepts
`and Facilities” (November 1983)
`1033 Mockapetris, P., RFC 883, “Domain Names –
`Implementation and Specification” (November 1983)
`1034 Mockapetris, P., RFC 1034, “Domain Names –
`Concepts and Facilities” (November 1987)
`1035 Mockapetris, P. RFC 1035, “Domain Names –
`Implementation and Specification” (November 1987)
`1036 Bradner, S., RFC 2026, “The Internet Standards Process
`– Revision 3” (October 1996)
`1037 Rosen, E., et al., RFC 2547, “BGP/MPLS VPNs”
`(March 1999)
`1038 W3C and WAP Forum Establish Formal Liason
`Relationship (December 8, 1999)
`1039 Wireless Application Protocol (WAP) Architecture
`Specification (April 30, 1998)
`1040 H.323 ITU-T Recommendation (February, 1998)
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`3/17/2015
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`3/17/2015
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`3/17/2015
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`3/17/2015
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`3/17/2015
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`3/17/2015
`3/17/2015
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`3/17/2015
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`3/17/2015
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`3/17/2015
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`3/17/2015
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`3/17/2015
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`3/17/2015
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`3/17/2015
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`3/17/2015
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`IPR2015-00866
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`Ex. # Reference Name
`1041 Kiuchi, T., et al., “C-HTTP – The Development of a
`Secure, Closed HTTP-Based Network on the Internet”
`(IEEE 1996) LOC Stamped
`1042 VirnetX’s Opening Claim Construction brief, VirnetX,
`Inc. v. Cicso Systems, Inc., et al., Civil Action No. 6:10-
`cv-417 (EDTX) (November 4, 20111)
`1043 Declaration of Michael Fratto, Reexamination
`95/001,682
`1044 U.S. Patent 5,898,830 to Wesinger
`1045
`Steiner, J., et al., “Kerberos: An Authentication Service
`for Open Network Systems” (January 12, 1988)
`1046 Harkins, D., et al., RFC 2409, “The Internet Key
`Exchange (IKE) (November 1998)
`1047 Maughan, D., et al., “Internet Security Association and
`Key Management Protocol (ISAKMP)” (November
`1998)
`1048 Data-Over-Cable Interface Specifications (DOCIS),
`Radio Frequency Interface Specification (March 26,
`1997)
`1049 U.S. Patent 6,886,095 to Hind et al.
`1050 U.S. Patent 8,560,705
`1051 U.S. Patent 8,560,705 File History
`1052 U.S. Patent 6,609,148 to Salo et al.
`1053 Dell Computer Corp., Fiscal 1999 in Review (1999)
`1054 Charlie Scott et al., Virtual Private Networks (2nd ed.
`1999)
`1055 Deposition of Fabien Newman Monrose, PhD.,
`IPR2014-00237, Exhibit 1083 (October 23, 2014)
`1056 Declaration of Scott M. Border
`1057
`Information Disclosure Statement, U.S. Appl. No.
`[New]
`13/339,257 (May 3, 2012) (issued as U.S. Patent No.
`8,504,697), including Rough Transcript of April 11,
`2012 Deposition of Chris Hopen, VirnetX Inc. v. Cisco
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`Exhibit List - iv
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`Paper No. 14
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`Filing Status
`3/17/2015
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`3/17/2015
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`3/17/2015
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`3/17/2015
`3/17/2015
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`3/17/2015
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`3/17/2015
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`3/17/2015
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`3/17/2015
`3/17/2015
`3/17/2015
`3/17/2015
`3/17/2015
`3/17/2015
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`3/17/2015
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`10/7/2015
`Not filed
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`
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`Paper No. 14
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`Filing Status
`
`Not filed
`
`Not filed
`
`Not filed;
`served with
`this motion
`
`Not filed;
`served with
`this motion
`Not filed;
`served with
`this motion
`Not filed;
`served with
`this motion
`Not filed;
`served with
`this motion
`Not filed;
`served with
`this motion
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`IPR2015-00866
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`1058
`[New]
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`1059
`[New]
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`1060
`[New]
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`Ex. # Reference Name
`Systems, Inc., Case No. 6:10-cv-00417 (E.D. Tex.)
`Declaration of Chris Hopen, Control No. 95/001682,
`filed as Exhibit P4 in April 11, 2012 Deposition of Chris
`Hopen, VirnetX Inc. v. Cisco Systems, Inc., Case No.
`6:10-cv-00417 (E.D. Tex.)
`Transcript of Jury Trial in VirnetX v. Microsoft
`Corporation, Case No. 6:07-cv-00080, Dkt. No. 398
`(E.D. Tex) (March 15, 2010)
`Declaration of Sandy Ginoza on behalf of the RFC
`Publisher for the Internet Engineering Task Force, dated
`January 23, 2013, submitted in Investigation No. 337-
`TA-858
`Kent, S., et al., RFC 2401, “Security Architecture for
`the Internet Protocol” (November 1998), bearing Bates
`Nos. 337-TA-858-IETF001122 through 001183
`Redline comparison of Exhibit 1008 (IPR2015-00810)
`to Exhibit 1061
`
`1061
`[New]
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`1062
`[New]
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`1063
`[New]
`
`Transcript of Feb. 8, 2013 deposition of Sandy Ginoza,
`ITC Inv. No. 337-TA-858
`
`1064
`[New]
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`The Reality of Virtual Private Networks, InfoWorld,
`Aug. 16, 1999 (Advertising Supplement)
`
`1065
`[New]
`
`Mark Gibbs, IP Security: Keeping your business
`private, NetworkWorld, Mar. 15, 1999
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`
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`Exhibit List - v
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`Paper No. 14
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`PETITIONER’S MOTION TO SUBMIT
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`SUPPLEMENTAL INFORMATION
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`Attachment B:
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`Proof of Service
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`IPR2015-00866
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`IPR2015-00866
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`Paper No. 14
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), this is to certify that on this 16th day of
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`October, 2015, I caused to be served a true and correct copy of the foregoing
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`Petitioner’s Motion to Submit Supplemental Information and Exhibits 1060-1065
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`on the following counsel for Patent Owner:
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`Joseph E. Palys
`E-mail: josephpalys@paulhastings.com
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`Naveen Modi
`E-mail: naveenmodi@paulhastings.com
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`Jason E. Stach
`E-mail: Jason.stach@finnegan.com
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`Dated:
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`October 16, 2015
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`Respectfully submitted,
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`/Jeffrey P. Kushan/
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`Jeffrey P. Kushan
`Reg. No. 43,401
`Sidley Austin LLP
`1501 K Street, N.W.
`Washington, D.C. 20005
`(202) 736-8914
`Attorney for Petitioner
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