IPR2015-01444
`Patent 7,039,033
`
`
`By: Andy H. Chan, Reg. No. 56,893
`Pepper Hamilton LLP
`333 Twin Dolphin Drive
`Suite 400
`Redwood City, CA 94065
`(650) 802-3602 (telephone)
`(650) 802-3650 (facsimile)
`chana@pepperlaw.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., AND APPLE INC.,
`Petitioner
`v.
`
`IXI IP, LLC
`Patent Owner
`___________________
`
`Case No. IPR2015-01444
`Patent 7,039,033
`___________________
`
`PATENT OWNER’S MOTION TO EXCLUDE EVIDENCE
`PURSUANT TO 37 C.F.R. §§ 42.62 AND 42.64(c)
`
`
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`

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`
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`TABLE OF CONTENTS
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`IPR2015-01444
`Patent 7,039,033
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`I.
`II.
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`Page(s)
`
`Introduction ..................................................................................................... 1
`Exhibits 1016 and 1017 Should be Excluded ................................................. 2
`Exhibits 1016 and 1017 Are Inadmissible Pursuant to 37 C.F.R.
`A.
`§§ 42.123(b) ......................................................................................... 2
`Exhibit 1016 Is Not Authenticated ....................................................... 5
`B.
`Exhibit 1016 Constitutes Hearsay ........................................................ 6
`C.
`Exhibits 1016 and 1017 Are Not Relevant .......................................... 7
`D.
`III. Exhibits 1002, 1014, and 1015 Should be Excluded .................................... 10
`IV. Conclusion .................................................................................................... 11
`
`i
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`

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`
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`TABLE OF AUTHORITIES
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`IPR2015-01444
`Patent 7,039,033
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`CASES
`Ex Parte Rembrandt Gaming Techs. LP,
`2014 WL 6847163, Control No. 90/012,379 (PTAB Dec. 3, 2014) .................... 6
`
`Page(s)
`
`Hilgraeve, Inc. v. Symantec Corp.,
`271 F. Supp. 2d 964 (E.D. Mich. 2003) ............................................................... 7
`
`Kinetic Technologies, Inc. v. Skyworks Solutions, Inc., IPR2014-00690,
`Paper 42 at 19 (PTAB Oct. 19, 2015) ................................................................... 6
`
`Toshiba Corp. v. Optical Devices, LLC,
`Case IPR2014-01445 (PTAB Mar. 9, 2016). ..................................................... 2
`
`OTHER AUTHORITIES
`
`37 C.F.R. § 42.6 ................................................................................................... 2, 10
`
`37 C.F.R. § 42.22 ................................................................................................. 2, 10
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`37 C.F.R. § 42.23 ....................................................................................................... 2
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`37 C.F.R. § 42.24 ................................................................................................. 2, 10
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`37 C.F.R. § 42.64 ....................................................................................................... 1
`
`37 C.F.R. § 42.104 ............................................................................................... 2, 10
`
`37 C.F.R. § 42.123 ............................................................................................passim
`
`FRE 401 ....................................................................................................... 2, 7, 9, 10
`
`FRE 402 ........................................................................................................... 2, 7, 10
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`FRE 403 ............................................................................................................... 2, 11
`
`FRE 801 ..................................................................................................................... 2
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`FRE 802 ............................................................................................................. 1, 6, 7
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`FRE 901 ............................................................................................................. 1, 5, 6
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`IPR2015-01444
`Patent 7,039,033
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`FRE 902 ..................................................................................................................... 6
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`iii
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`IPR2015-01444
`Patent 7,039,033
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`EXHIBIT LIST
`
`Description
`
`Declaration Of Dr. Narayan Mandayam In Support Of IXI IP, LLC’s
`Patent Owner Response
`Deposition Transcript of Safye Kiaei, IPR2015-01444, March 16,
`2016
`Deposition Transcript of Safye Kiaei, IPR2015-01443, March 15,
`2016
`Deposition Transcript of Safye Kiaei, IPR2015-01445 – 1446, March
`17, 2016.
`Specification of the Bluetooth System, Specification Volume 1
`(December 1, 1999) (Bluetooth Specification)
`IP Network Address Translator (NAT) Terminology and
`Considerations,” RFC 2663, August 1999
`
`
`
`
`
`Ex. #
`
`2301
`
`2302
`
`2303
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`2304
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`2305
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`2306
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`iv
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`IPR2015-01444
`Patent 7,039,033
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`I.
`
`INTRODUCTION
`
`Pursuant to 37 C.F.R. § 42.64(c), Patent Owner, IXI IP, LLC, hereby moves
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`to exclude Exhibits 1002, 1014, 1015, 1016, and 1017. Exhibits 1002, 1014, and
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`1015 were submitted by Petitioners Samsung Electronics Co. Ltd., Samsung
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`Electronics America, Inc. and Apple Inc. (collectively “Petitioner”) in support of
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`Petitioner’s Petition. (Paper 2.) On January 13, 2016, Patent Owner timely filed
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`and served objections to Exhibits 1002, 1014, and 1015.1 (Paper 10.) Exhibits
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`1016 and 1017 were submitted by Petitioner in support of its Reply to Patent
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`Owner’s Response. (Paper 18.) Patent Owner timely filed and served objections
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`to Exhibits 1016 and 1017 on June 28, 2016.2 (Paper 19.)
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`Petitioner’s Exhibits 1016 and 1017 should be excluded as improper
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`supplements, irrelevant, lacking foundation, and prejudicial. See 37 C.F.R. §
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`42.123(b); Federal Rules of Evidence (FRE) 401 and 402. Moreover, Exhibit 1016
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`should be excluded as impermissible hearsay and lacking authentication. FRE 901,
`
`
`1 Objections were filed within ten (10) business days from the institution of
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`trial on December 30, 2015. See 37 C.F.R. § 42.64(b)(1).
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`2 Objections were filed within five (5) business days of evidence proffered
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`with Petitioner’s Reply, dated June 21, 2016. See 37 C.F.R. § 42.64(b)(1).
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`1
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`

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`801 and 802. Petitioner’s Exhibits 1002, 1014, and 1015 should be excluded as
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`IPR2015-01444
`Patent 7,039,033
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`irrelevant and prejudicial (see FRE 401, 402 and 403) as well as in violation of 37
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`C.F.R. §§ 42.22(a)(2), 42.104(b)(4), 42.6(a)(3), and 42.24(a)(1)(i).
`
`II. EXHIBITS 1016 AND 1017 SHOULD BE EXCLUDED
`A. Exhibits 1016 and 1017 Are Inadmissible Pursuant to 37 C.F.R.
`§§ 42.123(b)
`
`Under 37 C.F.R. § 42.23(b), a reply may only respond to arguments raised in
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`the corresponding opposition or patent owner response, but that section does not
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`authorize or otherwise provide a means for supplementing the evidence of record.
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`See e.g., Toshiba Corp. v. Optical Devices, LLC, Case IPR2014-01445, Paper 31 at
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`30 (PTAB Mar. 9, 2016). Here, the evidence Petitioner submitted in its Reply is
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`not limited to arguments raised by the Patent Owner Response. Instead, they raise
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`new issues at this late stage and purport to provide additional evidence that could
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`have been provided in the Petition.
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`In its Reply, Petitioner attempts to belatedly present new evidence in the
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`form of Exhibits 1016 and 1017, without authorization. Exhibits 1016 and 1017
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`are inadmissible because Petitioner failed to seek authorization to file a motion to
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`submit supplemental information pursuant to 37 C.F.R. § 42.123(b). Once a trial
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`has been instituted, a party may file a motion to submit supplemental information.
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`37 C.F.R. § 42.123(a). However, “[a] party seeking to submit supplemental
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`information more than one month after the date the trial is instituted, must request
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`authorization to file a motion to submit the information.” 37 C.F.R. § 42.123(b).
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`IPR2015-01444
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`The motion to submit supplemental information must show: (1) “why the
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`supplemental information reasonably could not have been obtained earlier,” and
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`(2) “that consideration of the supplemental information would be in the interests-
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`of-justice.” Id. Petitioner has not and cannot meet its burden, and thus, Exhibits
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`1016 and 1017 are inadmissible.
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`Exhibit 1016 appears to be a document entitled “A Programmer’s Guide to
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`JINI Technology.” Petitioner contends that Exhibit 1016 was available prior to the
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`filing of the Petition. Therefore, Petitioner was or should have been aware of
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`Exhibit 1016 before the Petitioner was filed. For the first time in its Reply,
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`Petitioner attempts to rely on Exhibit 1016 to explain the capabilities of the
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`technology described in Exhibit 1005 (Marchand). Petitioner alleges that Exhibit
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`1016 demonstrates that Marchand’s JINI technology is plug and play and sufficient
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`to load and execute software. (Paper 18 at 24.) Petitioner was well aware of JINI
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`technology and the concept of plug and play as of the filing of the Petition. (See
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`Paper 2 at 42-43, 50-51.) Petitioner addressed JINI technology and plug and play
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`in the Petition, yet, Petitioner chose not to rely on Exhibit 1016. Id.
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`Petitioner further alleges, for the first time, that Exhibit 1016 shows that the
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`implementation of multiple JINI LUSs is “useful” in Marchand. (Paper 18 at 7,
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`12.) The implementation of multiple JINI LUSs was not presented prior to
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`3
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`

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`Petitioner’s Reply. Petitioner appears to rely on Exhibit 1016 to suggest that the
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`IPR2015-01444
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`Bluetooth Piconet taught in Marchand is capable of having multiple JINI LUSs.
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`See id. However, Petitioner points to no support in Marchand to suggest that it is
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`concerned with the use of multiple JINI LUSs. Petitioner improperly seeks to use
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`Exhibit 1016 to present a new argument that has never been presented, has no basis
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`in the ’033 Patent or the prior art and is inconsistent with record evidence.
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`Exhibit 1017, U.S. Patent No. 5,963,908 entitled “Secure Logon to
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`Notebook or Desktop Computers,” issued on Oct. 5, 1999. Petitioner was or
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`should have been aware of Exhibits 1017 before the Petition was filed. Petitioner
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`alleges that Exhibit 1017 demonstrates that webpage access for browsing the
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`internet is a well-known functionality of a laptop. (Paper 18 at 21.) Petitioner was
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`well aware of the concept of webpages as of the filing of the Petition. (See Paper 2
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`at 33.) Petitioner addressed webpages in the Petitioner, yet, Petitioner chose not to
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`rely on Exhibit 1017. Petitioner attempts to improperly use Exhibit 1016 to
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`supplement and adapt its previous arguments.
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`Petitioner now, having been shown the flaws in its analysis, attempts to
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`rehabilitate its arguments by improperly relying on new evidence not previously
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`asserted. Petitioner has failed to file a motion to submit Exhibits 1016 or 1017, let
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`alone seek the Board’s authorization to file such motion. Petitioner has not and
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`cannot demonstrate why the belated Exhibits 1016 and 1017 “reasonably could not
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`have been obtained earlier.” 37 C.F.R. § 42.123(b). Furthermore, Petitioner has
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`IPR2015-01444
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`not demonstrated “that consideration of the supplemental information would be in
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`the interests-of-justice,” particularly in light of its inexcusable delay in submitting
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`those exhibits. Id.
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`Accordingly, Exhibits 1016 and 1017 should be excluded because Petitioner
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`has failed to seek the Board’s authorization to file a motion to submit these
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`exhibits pursuant to 37 C.F.R. § 42.123(b).
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`Exhibit 1016 Is Not Authenticated
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`B.
`FRE 901 requires authentication with evidence sufficient to support a
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`finding that the matter in question is what its proponent claims. As a proponent of
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`the evidence, Petitioner bears the burden of establishing that the proffered
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`evidence, Exhibit 1016, meets the requirements of FRE 901. Because Petitioner
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`has failed to provide any evidence to support a finding that the documents are what
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`Petitioner claims they are, Exhibit 1016 is inadmissible and should be excluded.
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`Exhibit 1016 appears to be a document entitled “A Programmer’s Guide to
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`JiniTM Technology”. Petitioner has failed to provide any evidence to establish the
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`authenticity of Exhibit 1016. For example, Petitioner provides no evidence
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`identifying specifically from where Exhibits 1016 was obtained or when, if at all,
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`Exhibit 1016 was published or otherwise publicly available. Petitioner also fails to
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`provide testimonial evidence from any witness having personal knowledge of
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`Exhibit 1016 to establish its authenticity. Exhibit 1016 bears a copyright notice
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`IPR2015-01444
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`and a date of “2000”. (Exhibit 1016 at 3.) However, the copyright notices and
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`dates on the exhibits are inadequate on their face to demonstrate availability to the
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`public. See, e.g., Kinetic Technologies, Inc. v. Skyworks Solutions, Inc., IPR2014-
`
`00690, Paper 42 at 19 (PTAB Oct. 19, 2015); see also Ex Parte Rembrandt
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`Gaming Techs. LP, 2014 WL 6847163, at *3, Control No. 90/012,379 (PTAB Dec.
`
`3, 2014) (holding a copyright date does not show the requisite public availability,
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`but merely establishes only the date the document was created or printed)
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`(emphasis added). Petitioner’s supplemental evidence served on July 13, 2016 also
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`fails to provide any evidence showing the authenticity of Exhibit 1016.
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`Consequently, Exhibit 1016 is inadmissible under FRE 901 because
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`Petitioner has not put forth any evidence to support a finding that the Exhibit is
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`what Petitioner claims, or that Exhibit 1016 is self-authenticating under FRE 902.
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`As such, Exhibit 1016 should be excluded on that basis alone.
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`C. Exhibit 1016 Constitutes Hearsay
`To the extent Petitioner relies on any date information3 appearing on Exhibit
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`1016 to argue that the contents of the document were publicly available as of a
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`particular date, that information constitutes inadmissible hearsay. FRE 802.
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`Petitioner attempts to rely on Exhibit 1016 without explaining when or if the
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`3 For example, Exhibit 1016 bears a copyright notice and a date of “2000”.
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`IPR2015-01444
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`exhibit was published or otherwise publicly available. Petitioner cannot rely on the
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`date information appearing on Exhibit 1016 to prove the truth of the matter being
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`asserted; namely, that the contents of the document were publicly available, as of a
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`particular date. FRE 802; see also Hilgraeve, Inc. v. Symantec Corp., 271 F. Supp.
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`2d 964, 974 (E.D. Mich. 2003) (“Plaintiff correctly notes that the dates imprinted
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`on these documents are hearsay when offered to prove the truth of the matter
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`asserted, that is, that [documents were] accessible to the public as of the date set
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`forth on the documents.”). Petitioner has not shown that a hearsay exception
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`applies. Indeed, there is no applicable exception. As such, Exhibit 1016
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`constitutes inadmissible hearsay and should be excluded on that basis alone.
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`D. Exhibits 1016 and 1017 Are Not Relevant
`Exhibits 1016 and 1017 are not relevant and thus are inadmissible under
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`FRE 402. As discussed below, neither Exhibit 1016 nor Exhibit 1017 has any
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`tendency to make a fact more or less probable than it would be without the
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`exhibits, nor are the teachings of any of the exhibits of consequence in determining
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`what is disclosed in the Prior Art. See FRE 401.
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`As previously discussed, Exhibits 1016 and 1017 were, or should have been,
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`known to Petitioner at the time of filing the Petition, but Petitioner did not consider
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`them relevant enough to cite them or rely on them in any asserted ground. Now, in
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`its Reply, Petitioner improperly raises new issues and attempts to amend the
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`7
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`asserted combination of references by introducing and further combining the
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`IPR2015-01444
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`teachings of Exhibits 1016 and 1017.
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`Petitioner relies on Exhibit 1016 to allege that Marchand’s JINI technology
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`is plug and play and sufficient to load and execute software. (Paper 18 at 24.)
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`However, Petitioner provides no explanation regarding how or why this reference
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`demonstrates that Marchand’s JINI technology is plug and play and sufficient to
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`load and execute software. Petitioner offers a lone conclusory statement that
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`Marchand’s JINI technology is plug and play and sufficient to load and execute
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`software, citing to Exhibit 1016. See id. Petitioner’s lone citation is insufficient to
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`establish relevancy. Petitioner failed to identify any language in Exhibit 1016 or
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`any evidence from a person of ordinary skill in the art to establish that Exhibit
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`1016 relates to Marchand’s JINI technology, plug and play as claimed by the ’033
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`patent, the alleged prior art, or the asserted combination of references.
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`Petitioner’s further allegations that Exhibit 1016 shows that the
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`implementation of multiple JINI LUSs are useful in ad-hoc networks are also
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`irrelevant. (See Paper 18 at 7, 12.) Petitioner’s new argument in the Reply, that
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`JINI technology supports multiple LUSs, is irrelevant to the claims of the ’033
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`Patent and the alleged prior art. Petitioner has not cited to any portion of
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`Marchand, the ’033 Patent or any of the alleged prior art, or any evidence from a
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`person of ordinary skill in the art, concerning the use of multiple JINI LUSs.
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`8
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`Accordingly, Petitioner has failed to establish that Exhibits 1016 have any impact
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`IPR2015-01444
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`on the teachings of the ’033 Patent, the alleged prior art, or the asserted
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`combination of references.
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`Similarly, Petitioner, for the first time in the Reply, relies on Exhibit 1017 to
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`allege that webpage access for browsing the internet is a well-known functionality
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`of a laptop. (Paper 18 at 21.) Again, Petitioner’s conclusory statements fail to
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`establish how Exhibit 1017 demonstrates this functionality and how it relates to the
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`claims of the ’033 Patent or the alleged prior art. See id. Petitioner failed to
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`provide any analysis or any evidence or understanding from a person of ordinary
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`skill in the art regarding how the teachings of Exhibit 1017 relate to the ’033 Patent
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`or the alleged prior art. Accordingly, Petitioner has failed to establish that Exhibit
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`1017 has any impact on the teachings of the ’033 Patent, the alleged prior art, or
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`the asserted combination of references.
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`Exhibits 1016 and 1017 have no tendency to make a fact more or less
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`probable than it would be without the exhibit, nor are the teachings of any of the
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`exhibits of consequence in determining what is disclosed in the alleged prior art.
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`See FRE 401. As such, Exhibits 1016 and 1017 are irrelevant and should be
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`excluded.
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`9
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`III. EXHIBITS 1002, 1014, AND 1015 SHOULD BE EXCLUDED
`Exhibits 1002, 1014, and 1015 are inadmissible because they are not
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`IPR2015-01444
`Patent 7,039,033
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`referenced or explained at all in the Petition or the Reply, in violation of 37 C.F.R.
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`§ 42.22(a)(2) (requiring a petition to include “a detailed explanation of the
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`significance of the evidence”), § 42.104(b)(4) (requiring a petition to “specify
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`where each element of the claim is found in the prior art patents or printed
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`publications relied upon”). Neither the Petition nor the Reply makes any attempt
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`to explain the relevance of Exhibits 1002, 1014, and 1015, let alone explain
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`whether or how they discloses any claimed element of the ’033 Patent or render
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`any claim of the ’033 Patent invalid. To the extent that the Petitioner attempts to
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`incorporate Exhibits 1002, 1014, and 1015 by reference into the Petition, it is also
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`prohibited by § 42.6(a)(3) (“Arguments must not be incorporated by reference
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`from one document into another document.”). Petitioner’s attempt to rely upon
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`Exhibit 1002, 1014, and 1015 without referencing these exhibit in the Petition is
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`also an improper attempt to circumvent the page limit for Petitions. See 37 C.F.R.
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`§ 42.24(a)(1)(i).
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`Therefore, Exhibits 1002, 1014, and 1015 are not relevant under FRE 401
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`and 402 because they do not have any tendency to make a fact more or less
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`probable than it would be without the exhibits, nor are Exhibits 1002, 1014, 1015
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`of any consequence in determining the validity of the ’033 Patent. Furthermore,
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`Exhibits 1002, 1014, and 1015 should be excluded under FRE 403 as highly
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`IPR2015-01444
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`prejudicial. Petitioner never explained the relevance of Exhibits 1002, 1014, and
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`1015 in its Petition or Reply, and thus Patent Owner could not have had any
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`opportunity to address Exhibits 1002, 1014, and 1015. Allowing Petitioner to
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`introduce Exhibits 1002, 1014, and 1015 at trial would unfairly prejudice the
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`Patent Owner and confuse the issues presented in the Petition.
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`IV. CONCLUSION
`For at least the foregoing reasons, the evidence proffered by Petitioner in the
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`form of Exhibits 1002, 1014, 1015, 1016, and 1017 fail to comply with the Federal
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`Rules of Evidence and the Patent Rules; therefore, they should be excluded.
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`IPR2015-01444
`Patent 7,039,033
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`Respectfully submitted,
`
` /Andy H. Chan/
`By:
`Andy H. Chan, Reg. No. 56,893
`Pepper Hamilton LLP
`333 Twin Dolphin Drive,
`Suite 400
`Redwood City, CA 94065
`(650) 802-3600 (telephone)
`(650) 802-3650 (facsimile)
`
`George S. Haight IV, Reg. No. 54,146,
`Pepper Hamilton LLP
`125 High Street
`19th Floor High Street Tower
`Boston, MA 02110
`(617) 204-5165 (telephone)
`(617) 204-5150 (facsimile)
`
`Attorneys for Patent Owner
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`12
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`Dated: August 3, 2016
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`IPR2015-01444
`Patent 7,039,033
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`CERTIFICATE OF SERVICE
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`I hereby certify that on this 3rd day of August, 2016, a true and correct copy
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`of the foregoing Patent Owner’s Motion to Exclude Evidence Pursuant to 37
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`C.F.R. §§ 42.62 and 42.64(c) was served on the following counsel for Petitioner
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`via email:
`
`W. Karl Renner
`Email: axf@fr.com
`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Tel: (202) 783-5070
`Fax: (202) 783-2331
`
`
`Kevin Greene
`Email: IPR00035-0004IP1@fr.com
`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Tel: (202) 783-5070
`Fax: (202) 783-2331
`
`Jeremy Monaldo
`Email: PTABInbound@fr.com
`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Tel: (202) 783-5070
`Fax: (202) 783-2331
`
`Indranil Mukerji
`Email: PTABInbound@fr.com
`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Tel: (202) 783-5070
`Fax: (202) 783-2331
`
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`IPR2015-01444
`Patent 7,039,033
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`Katherine A. Vidal
`Email: PTABInbound@fr.com
`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Tel: 650-839-5084
`Fax: 877-769-7645
`
`
`Respectfully submitted,
`By: /Andy H. Chan/
`
`Andy H. Chan, Reg. No. 56,893
`Pepper Hamilton LLP
`333 Twin Dolphin Drive,
`Suite 400
`Redwood City, CA 94065
`(650) 802-3600 (telephone)
`(650) 802-3650 (facsimile)
`
`
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`14
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`Dated: August 3, 2016