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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`UNITED SERVICES AUTOMOBILE ASSOCIATION,
`Petitioner
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`v.
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`NADER ASGHARI-KAMRANI and KAMRAN ASGHARI-KAMRANI,
`Patent Owners
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`U.S. PATENT NO. 8,266,432
`Case IPR2015-01842
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`PETITIONER’S OPPOSITION TO PATENT OWNERS
`MOTION TO WITHDRAW CURRENT COUNSEL AND APPOINT MEI &
`MARK LLP
`
`
`
`
`
`Case IPR2015-01842
`Attorney Docket No: 36137-0007IP1
`
`I.
`
`INTRODUCTION
`
`Patent Owners are principals of a Patent Assertion Entity known as
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`Delphinus Technology and have demanded from USAA tens of millions of dollars
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`for alleged infringement of U.S. Patent No. 8,266,432, the subject of this
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`proceeding.
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`On December 29, 2015, Patent Owners appointed Mei & Mark as
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`prosecution counsel on a continuation application of the patent at issue in this
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`proceeding. Based on his participation in an Examiner Interview, it appears that
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`Mr. Nienstadt of Mei & Mark is serving as lead prosecution counsel for the Patent
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`Owners.1 On January 13, 2016, Patent Owners’ prior counsel, Novak, Kim & Lee,
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`PLLC, filed a Motion for Withdrawal of Counsel and now Patent Owners seek to
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`appoint Mei & Mark, LLP as new counsel in this proceeding. Petitioner was
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`unconcerned with this change, given the Patent Owners’ history of frequently
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`changing counsel. However, Petitioner later came to find that on January 13, 2016,
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`Patent Owners also sought to appoint the same counsel from Mei & Mark LLP as
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`litigation counsel in a related proceeding pending in the Eastern District of
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`Virginia. Petitioner opposes the Motion for Withdrawal of Counsel pending Mei
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`& Mark’s representation that it will agree to basic terms of a protective order in
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`this proceeding.
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`1 See Interview Summary mailed 1/20/16 in Ser. No. 13/606,538.
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`1
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`
`
`Case IPR2015-01842
`Attorney Docket No: 36137-0007IP1
`
`II. BACKGROUND
`1. Novak, Kim & Lee was appointed as counsel for Petitioner on September
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`23rd, 2015. The Novak firm was also appointed as counsel in the Patent Owners’
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`pending U.S. Application No. 13/606,538, which is a continuation of the
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`challenged patent. The Novak firm never made an appearance in any litigation
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`between Patent Owners and Petitioner and, to Petitioner’s knowledge, had no
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`involvement in any such litigation.
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`2. On October 30th, 2015, Patent Owners filed suit in the Eastern District of
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`Virginia, appointing McClanahan Powers, PLLC as counsel in a case styled
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`Ashgari-Kamrani et al. v. United Services Automobile Association, Case No. 2:15-
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`cv-00478-RGD-LRL. To Petitioner’s knowledge, the McClanahan firm never
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`made an appearance before the PTAB or the PTO on behalf of the Patent Owners.
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`3. Until the Mei & Mark firm started making appearances, the Patent
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`Owners separated their PTO/PTAB counsel and litigation counsel.
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`4. On January 13th, 2016, Patent Owners filed a Motion for Withdrawal
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`Counsel by the Novak firm.
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`5. On January 14th, 2016, Petitioner signaled its potential opposition to the
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`Motion to Withdraw for the Novak firm, noting that the proposed withdrawal and
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`substitution subjects Petitioner USAA to having its proprietary information abused
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`through the inter partes review. The PTAB asked both sides to meet and confer.
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`2
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`
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`Case IPR2015-01842
`Attorney Docket No: 36137-0007IP1
`6. On January 15, 2016 the parties conferred telephonically. Petitioner
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`identified its concern, but Mr. Nienstadt, on behalf of the Patent Owners, indicated
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`that USAA’s concern was likely premature and that the PTAB does not enter
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`protective orders.
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`7. Though premised by Mr. Nienstadt’s threat of sanctions, the parties
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`continued their efforts to resolve the issue via email, with the Patent Owners later
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`agreeing “to discuss[] … any reasonable protective order [Petitioner] seek[s] in the
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`IPR.” 2 Mr. Nienstadt also noted that “of course [Petitioner] can send me a draft
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`proposed protective order.”3
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`8. As Petitioner had no interest in holding up Mei & Mark’s or Mr.
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`Nienstadt’s appearance in this proceeding subject to negotiating a complete
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`protective order (which is a fairly complex agreement having numerous terms),
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`USAA sought to expedite matters for the parties and the Panel by offering to
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`withdraw its opposition if Patent Owners agreed to accept certain simple, non-
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`controversial terms in an eventual protective order.4
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`2 See attached email chain at pp. 2, 4 (highlighted for the Panel’s convenience;
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`emphasis original).
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`3 Id.
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`4 Id. at 1.
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`3
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`
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`Case IPR2015-01842
`Attorney Docket No: 36137-0007IP1
`9. Rather than consider Petitioner’s request, try to negotiate different terms,
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`or make even the appearance of trying to resolve this dispute, Mr. Nienstadt’s
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`entire response to USAA’s proposal reads: “We are not opposing [our own]
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`motion for withdrawal and substitution of counsel.”5
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`III. ARGUMENT
`The appointment of Mei & Mark, LLP as counsel for both district court
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`litigation and in this proceeding erodes previous safeguards that existed with
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`maintenance of separate counsel for IPR and district court litigation.6 The
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`potential for abuse through the amendment process is well documented with
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`protective orders becoming the common remedy to address such concerns.
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`Notwithstanding these concerns, Patent Owners refuse to even consider safeguards
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`in this proceeding. The terms proposed by Petitioner are hardly unusual and can be
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`found in virtually any protective order where one firm wants to wear as many hats
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`as Mei & Mark does.
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`The above-noted defects can be remedied with the adoption of a protective
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`5 Id. at 1.
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`6 Mr. Nienstadt’s role as lead prosecution counsel on a pending application for
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`Patent Owners raises another significant issue with respect to his appearance in the
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`parallel E.D. Va. proceeding, but that is outside the purview of the instant paper.
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`4
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`
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`Case IPR2015-01842
`Attorney Docket No: 36137-0007IP1
`order that protects Petitioner’s confidential information. Patent Owners’ proposed
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`new counsel relies upon one authority that allows a single firm to “participate” in
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`both litigation and before the PTAB. See Endo Pharmaceuticals Inc. v. Actavis
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`Inc., et al., No. 1:12-cv-08115-TPG-GWG (S.D.N.Y. Aug. 13, 2014). However,
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`Endo speaks to the importance of such safeguards in order to protect confidential
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`information and, in fact, restricts litigation counsel from conferring with patent
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`counsel on the amendment of patent claims and sharing confidential information.
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`In addition to offering the patently obvious point that the Patent Owners do
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`not oppose their own motion, Patent Owners have argued that discovery has not
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`yet begun in the related litigation, making protective measures unnnecesary. It is
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`unclear when the E.D. Va. court is going to even consider entry of a protective
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`order because of a pending motion to dismiss under 35 U.S.C. § 101. It is further
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`unclear when, if ever, a discovery schedule will be set. However, Patent Owners
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`ignore that their litigation counsel’s receipt of confidential information likely can
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`happen before either of those things occur. While Petitioner cannot reveal its
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`litigation strategy, it needs to be free to file briefing under seal in the E.D. Va.
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`court, provide service copies of that briefing to opposing litigation counsel, and
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`know that it can reveal confidential information in furtherance of the litigation
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`without that information being used against it in this IPR. For at least that reason,
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`USAA asks for agreement now on basic terms of a protective order than can be
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`5
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`Case IPR2015-01842
`Attorney Docket No: 36137-0007IP1
`more fully negotiated in the coming days or weeks.
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`Moreover, additional risks are raised in light of Patent Owners’ historical
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`behavior with respect to counsel. In the litigation (filed on October 30, 2015),
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`Patent Owners are already on their second law firm. In the course of its overtures
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`to USAA prior to filing the litigation, Patent Owners switched counsel once.
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`During prosecution of challenged U.S. Patent No. 8,266,432, Patent Owners went
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`through no fewer than five different law firms. As for pending continuation
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`application 13/606,538, Patent Owners are already on law firm number five.
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`Patent Owners’ penchant for switching firms puts USAA’s confidential
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`information at an inherent risk because each change in counsel means another firm
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`is going to have access to the information and another firm is going to have to be
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`bound not to use that information after conclusion of representation. Without
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`some sort of protection in place, USAA is left unprotected when the next firm
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`shows up.
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`Thus, in view of the foregoing and the Patent Owners’ relied-upon Endo
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`case, Petitioner submits that if Patent Owners wish to consolidate PTAB and
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`litigation counsel, Patent Owners must agree to safeguards that protect the abuse of
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`Petitioner’s confidential information in this proceeding and avoid the appearance
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`of impropriety. Therefore, Petitioners condition their consent to Mei & Mark’s
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`appearance in this proceeding upon their agreement that a protective order will be
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`6
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`
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`Case IPR2015-01842
`Attorney Docket No: 36137-0007IP1
`entered that, inter alia, prohibits anyone who receives access to USAA confidential
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`information in the related EDVA litigation from (1) using USAA confidential
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`information in this proceeding or providing such information to others working on
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`this proceeding and (2) amending, drafting, or consulting on amendments to the
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`claims of the challenged patent. As Patent Owners have failed to disclose their
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`objection to these very simple, commonplace terms, Petitioner is at a loss to advise
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`the Board as to the full nature of the dispute and observes that it is asking for very
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`little.
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`Respectfully submitted,
`
`/Thomas A. Rozylowicz/
`
`Thomas A. Rozylowicz
`Reg. No. 50,620
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`7
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` 1/20/2016
`Date:
`
`
`
`
`
`Case IPR2015-01842
`Attorney Docket No: 36137-0007IP1
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 CFR § 42.6(e)(1), the undersigned certifies that on January
`20, 2016, a complete and entire copy of this Petitioner’s Opposition to Patent
`Owners Motion to Withdraw Current Counsel and Appoint Mei & Mark LLP, and
`its attachment, were provided via email, to the Petitioner by serving the email
`correspondence addresses of record as follows:
`
`Jae Youn Kim
`Harold L. Novick
`Sang Ho Lee
`Novick, Kim & Lee, PLLC
`1604 Spring Hill Rd., Suite 320
`Vienna, VA 22182
`
`Email: skim@nkllaw.com
`Email: hnovick@nkllaw.com
`Email: slee@nkllaw.com
`
`
`
`
`
`
`
`
`/Edward G. Faeth/
`Edward G. Faeth
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis MN 55402
`(202) 626-6420
`
`8
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`ATTACHMENT
`
`ATTACHMENT
`
`
`
`
`
`Michael Zoppo
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Reece Nienstadt <rnienstadt@meimark.com>
`Tuesday, January 19, 2016 1:06 PM
`Michael Zoppo
`Thomas Rozylowicz; IPR36137-0007IP1; kcolantoni@meimark.com; mei@meimark.com
`Re: IPR2015-001842 Motion to Withdraw Counsel
`
`Michael,
`
`We are not opposing Patent Owners' motion for withdrawal and substitution of counsel.
`
`With best regards,
`Reece
`
`On Jan 19, 2016, at 12:39 PM, Michael Zoppo <Zoppo@fr.com> wrote:
`
`
`
`Hi Reece,
`
`
`We disagree that the issues are separate or “brand new”; Tom’s initial email to the PTAB raised
`the issue of a protective order. We will continue to oppose unless you represent to us and the
`PTAB that you will agree to a protective order in the IPR that includes a prosecution bar
`consistent with the prohibitions in your cited Endo case. Particularly, the bar must prohibit
`anyone who receives access to USAA confidential information in the EDVA litigation from (1)
`using USAA confidential information in the IPR proceeding or providing such information to
`others working on the IPR and (2) amending, drafting, or consulting on amendments to the
`claims of the challenged patent.
`
`
`We can’t agree with you that the issue is premature because, while I cannot reveal our
`litigation strategy, USAA is well within its rights to file additional briefing in the litigation that
`requires outside‐attorneys’‐eyes only treatment prior to the entry of a protective order
`pursuant to EDVA Local Rule 5.
`
`
`As our opposition is due tomorrow, kindly let us have your position as soon as possible.
`
`
`Thanks,
`
`
`Michael
`
`
`
`From: Reece Nienstadt [mailto:rnienstadt@meimark.com]
`Sent: Friday, January 15, 2016 5:38 PM
`To: Michael Zoppo
`Cc: Thomas Rozylowicz; IPR36137‐0007IP1; kcolantoni@meimark.com; mei@meimark.com
`Subject: Re: IPR2015‐001842 Motion to Withdraw Counsel
`
`
`1
`
`
`
`Michael,
`
`I'm similarly puzzled by the change of topic. The purpose of the meet‐and‐confer was to discuss USAA's
`holding up of the the Patent Owners' motion for withdrawal and appearance of counsel. In order to
`resolve the currently pending motion for withdrawal and appearance of counsel and thereby address
`the matter currently before the Board, please let me know whether USAA continues to oppose Patent
`Owners' motion for withdrawal and appearance of counsel.
`
`If you wish to discuss a brand new topic about a motion for protective order in the IPR, of course you
`can send me a draft proposed protective order at any time and we can discuss that, although I'm not
`sure if that wouldn't be a premature motion to bring at the Board at this time.
`
`Thanks,
`Reece
`
`On 1/15/2016 5:22 PM, Michael Zoppo wrote:
`
`
`
`
`
`
`
`Hi Reece,
`
`I wouldn’t normally respond to an email like this, but your response has me
`scratching my head and I have to ensure that we are not talking past each
`other: are you now saying that you would agree to protective order in the IPR
`so long as it is “reasonable”? I haven’t proposed a protective order to you
`because you have scoffed at the idea (and I’m equally puzzled why you are
`calling something I haven’t proposed “unreasonable”…).
`
`
`Thanks,
`
`
`Michael
`
`
`From: Reece Nienstadt [mailto:rnienstadt@meimark.com]
`Sent: Friday, January 15, 2016 5:15 PM
`To: Michael Zoppo
`Cc: Thomas Rozylowicz; IPR36137‐0007IP1; kcolantoni@meimark.com;
`mei@meimark.com
`Subject: Re: IPR2015‐001842 Motion to Withdraw Counsel
`
`
`Michael,
`
`I've already explained our position to you in my previous e‐mail and on the phone. It is
`not the extreme position that you continue to misrepresent it to be. As I said, I
`understand your concern and simply ask that you bring your concern about confidential
`information at the proper forum and at the proper time, in accordance with well
`established precedent in this area. Instead of frivolously holding up the withdrawal and
`appearance of counsel, we are open to discussing any proposed protective order that
`you wish to lodge at the District Court (and/or any reasonable protective order that you
`seek in the IPR ‐‐ which is not at all what you have described so far).
`
`
`2
`
`
`
`Even if you seek a protective order in the IPR, there is absolutely no basis for USAA to
`continue to hold up the withdrawal and appearance of counsel.
`
`With best regards,
`Reece
`
`On 1/15/2016 5:05 PM, Michael Zoppo wrote:
`
`
`
`Hi Reece,
`
`
`We are disappointed that you would resort to a threat of
`sanctions when the case you cite supports the concerns we raised
`on our call—that protections need to be put in place to ensure
`that no one with access to USAA’s confidential information is in a
`position to make claim amendments (whether in standard
`prosecution or in the IPR). If there is actual authority for your
`position that you should have free reign in the IPR despite all the
`other hats you want to wear, please share it. Also, please send us
`authority for your position that protective orders cannot be
`entered in the PTAB, as that contradicts our experience.
`
`
`As we continue to consider the issue of your appearance in the
`district court litigation, it’d be helpful to know whether you intend
`to maintain your appearance in the PTO in the pending
`continuation application or if lawyers/agents not involved in the
`litigation will handle instead (with appropriate walls in place
`shielding them from lawyers working in the PTO).
`
`
`Best,
`
`
`Michael
`
`
`
`From: Reece Nienstadt [mailto:rnienstadt@meimark.com]
`Sent: Friday, January 15, 2016 4:41 PM
`To: Michael Zoppo
`Cc: Thomas Rozylowicz; IPR36137‐0007IP1; kcolantoni@meimark.com;
`mei@meimark.com
`Subject: Re: IPR2015‐001842 Motion to Withdraw Counsel
`
`
`Michael and Tom,
`
`Thanks for participating in the telephonic meet‐and‐confer today. In
`the teleconference, I reiterated our position that for USAA to either
`continue opposing Patent Owners' appearance of counsel or move for a
`protective order is premature at this time, for at least the reason that
`we have not even had an initial conference and no discovery schedule
`has been entered in the District Court. More importantly, it is well
`established that any motion for a protective order or prosecution bar
`3
`
`
`
`based on the concerns you have articulated should be brought at the
`District Court.
`
`Please be mindful that, like Rule 11 in district courts, under 37 C.F.R.
`42.12 the Board can impose sanctions against a party for "advancing a
`misleading or frivolous argument or request for relief," "engaging in
`dilatory tactics," and/or "abuse of process." In my opinion, the well‐
`established case law on the issues we've discussed would support such
`relief if USAA continues to oppose Patent Owners' motion for
`appearance of counsel on the grounds it has articulated or if USAA files
`a frivolous and premature motion.
`
`If you have any questions, please let me know.
`
`With best regards,
`Reece
`
`
`
`--
`Reece Nienstadt
`Attorney at Law
`Mei & Mark LLP
`888-860-5678 x710 (US) | 202-567-6417 x710 (Int'l) |
`888-706-1173 (Fax)
`rnienstadt@meimark.com | GnuPG Key ID: 0x85C30122 |
`www.meimark.com
`Office Address: 818 18th Street NW, Suite 410,
`Washington, DC
`Mailing Address: P.O. Box 65981, Washington, DC
`20035-5981
`
`---
`This e-mail message is intended only for
`individual(s) to whom it is addressed and may contain
`information that is privileged, confidential,
`proprietary, or otherwise exempt from disclosure
`under applicable law. If you believe you have
`received this message in error, please advise the
`sender by return e-mail and delete it from your
`mailbox. Thank you.
`
`On 1/15/2016 11:22 AM, Michael Zoppo wrote:
`
`
`
`Hi Reece,
`
`
`Not having heard back, we propose a call at 4PM
`today to conduct our meet and confer on the IPR
`issue. Dial in: 888 706 0584, code 435 971.
`
`
`Look forward to speaking then concerning then.
`
`
`4
`
`
`
`Thanks,
`
`
`Michael
`
`
`From: Michael Zoppo
`Sent: Thursday, January 14, 2016 6:45 PM
`To: Reece Nienstadt
`Cc: Thomas Rozylowicz; Underwood, Cathy; IPR36137‐
`0007IP1; kcolantoni@meimark.com;
`mei@meimark.com
`Subject: Re: IPR2015‐001842 Motion to Withdraw
`Counsel
`
`
`Hi Reece,
`
`
`You seem to misunderstand our concern so let's
`schedule a meet and confer and spare Cathy this back
`and forth. Shoot us a note with your availability.
`
`
`Thanks much.
`
`Sent from my iPhone
`
`On Jan 14, 2016, at 5:45 PM, Reece Nienstadt
`<rnienstadt@meimark.com> wrote:
`
`Tom and Cathy,
`
`Since the concern raised in Tom's email
`appears to be limited to USAA's
`proprietary and confidential
`information that may be produced
`during discovery at the District Court in
`the future, it seems to me that these
`concerns should be raised at the District
`Court, not at the PTAB. At the District
`Court, neither a discovery schedule nor
`a protective order has been entered,
`and therefore this concern is
`speculative and better addressed to the
`District Court. We are open to
`discussing with Fish & Richardson a
`proposed prosecution bar to be lodged
`in the District Court.
`
`This concern certainly does not provide
`a basis for opposing a withdrawal or
`appearance of counsel in this IPR. It is
`well established that an IPR is
`analogous to a district court litigation
`for these purposes and a patent
`owner's counsel may therefore
`5
`
`
`
`participate in an IPR simultaneous with
`the litigation. See, e.g., Endo
`Pharmaceuticals Inc. v. Actavis Inc., et
`al., No. 1:12‐cv‐08115‐TPG‐GWG
`(S.D.N.Y. Aug. 13, 2014). (Indeed, Fish
`& Richardson is representing USAA in
`the IPR as well as in the District Court
`with the benefit of receiving Plaintiff's
`proprietary and confidential
`information, rather than having a
`different firm handle the IPR.)
`
`If you wish to schedule a meet‐and‐
`confer, I'm available.
`
`With best regards,
`Reece
`--
`Reece Nienstadt
`Attorney at Law
`Mei & Mark LLP
`888-860-5678 x710 (US) | 202-
`567-6417 x710 (Int'l) | 888-
`706-1173 (Fax)
`rnienstadt@meimark.com |
`GnuPG Key ID: 0x85C30122 |
`www.meimark.com
`Office Address: 818 18th
`Street NW, Suite 410,
`Washington, DC
`Mailing Address: P.O. Box
`65981, Washington, DC 20035-
`5981
`
`---
`This e-mail message is
`intended only for
`individual(s) to whom it is
`addressed and may contain
`information that is
`privileged, confidential,
`proprietary, or otherwise
`exempt from disclosure under
`applicable law. If you
`believe you have received
`this message in error, please
`advise the sender by return
`e-mail and delete it from
`your mailbox. Thank you.
`On 1/14/2016 1:10 PM, Thomas
`Rozylowicz wrote:
`
`
`
`Cathy and Reece,
`
`
`This email raises a few
`questions. First, we
`6
`
`
`
`duly note that Reece
`was appointed by the
`Patent Owner to
`prosecute the
`continuation
`application in
`December. And just
`yesterday, Reece
`sought leave to appear
`as litigation counsel in
`the related proceeding
`pending in the Eastern
`District of
`Virginia. Before USAA
`can indicate whether it
`opposes a motion to
`withdraw, USAA wants
`to better understand
`the process by which
`Reece and his firm will
`protect USAA’s
`proprietary and
`confidential
`information from
`improper usage in the
`IPR. The Patent Owner
`has the ability to abuse
`proprietary information
`through the
`amendment process
`and also in advancing
`claim constructions
`based upon a preferred
`infringement
`construction. USAA will
`not consent to any
`arrangement where
`prosecution and IPR
`counsel are given
`access to USAA’s
`proprietary
`information.
`
`In order to arrive at
`USAA’s final position,
`we propose a short call
`where Reece can advise
`whether these concerns
`can be adequately
`addressed.
`
`
`Regards,
`
`7
`
`
`
`
`
`Tom Rozylowicz
`
`
`Thomas Rozylowicz
`:: Principal :: Fish &
`Richardson P.C.
`+1-202-626-6395
`direct ::
`rozylowicz@fr.com
`fr.com :: Bio ::
`LinkedIn :: Twitter
`
`
`
`From: Underwood,
`Cathy
`[mailto:Cathy.Underwo
`od@USPTO.GOV]
`Sent: Thursday, January
`14, 2016 10:13 AM
`To: Michael Zoppo;
`IPR36137‐0007IP1;
`rnienstadt@meimark.c
`om;
`kcolantoni@meimark.c
`om;
`mei@meimark.com
`Subject: IPR2015‐
`001842 Motion to
`Withdraw Counsel
`
`
`Hello,
`
`
`
`On January 13, 2016,
`Counsel for Patent
`Owners filed a
`motion to withdraw
`as counsel. Does
`Petitioner oppose the
`motion to withdraw?
`
`
`
`Thank you,
`Cathy Underwood
`Trial Paralegal
`Patent Trial and
`Appeal Board
`U.S. Patent &
`Trademark Office
`cathy.underwood@usp
`to.gov
`
`8
`
`
`
`(DIRECT) 571-272-
`8358
`(MAIN) 571-272-9797
`
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`
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